DRAFT

U.S. Department of the Interior 

Bureau of Land Management 

Bering Sea - Western Interior

Resource Management Plan and Environmental Impact Statement

Volume 2: Appendices M – O 

March 2019 

Prepared by: 

US Department of the Interior 

Bureau of Land Management 

In Cooperation with: 

State of Alaska 

US Fish and Wildlife Service 

Native Village of Chauthbaluk 

Estimated Lead Agency Total Costs 

Associated with Developing and 

Producing this EIS: $5,941,000
 

Mission 

To sustain the health, diversity, and productivity of the 

public lands for the use and enjoyment of present and

future generations. 

Cover Photo: Old Woman Mountain, located on the 

Iditarod National Historic Trail between the Yukon River 

and the Bering Sea. Photo by Kevin Keeler (BLM). 

DOI-BLM-AK-A010-2013-0039-RMP-EIS 

BLM/AK/PL-19/004+1610+A020
 

 

Bering Sea-Western Interior 

Draft Resource Management Plan and

Environmental Impact Statement 

Volume 2: Appendices M-O 

Prepared by: 

U.S. Department of the Interior 

Bureau of Land Management 

Anchorage, Alaska 

In cooperation with: 

State of Alaska 

US Fish and Wildlife Service 

Native Village of Chauthbaluk 

March 2019 

Estimated Lead Agency 

Total Costs Associated with Developing 

and Producing this EIS: $5,941,000 
Blank page. 
BSWI Draft RMP/EIS Volume 2: Appendices M-O 

Table of Contents 

Volume 1 – Executive Summary, Chapters 1-3, and Appendices A-L 

Volume 2 – Appendices M-O 

Volume 3 – Maps 

Volume 2 

Appendix M: BSWI Affected Environment Report 

Appendix N: Supplemental Impact Analysis Information 

Appendix O: Alaska National Interest Lands Conservation Act (ANILCA) Preliminary Section 810 

Evaluation 

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Appendix M: BSWI Affected Environment Report 

Appendix M: BSWI Affected Environment Report Table of Contents 

Table of Contents 

Section 1. Introduction ..........................................................................................................................1-1 

Section 2. Resources...............................................................................................................................2-1 

2.1 Air Quality and Air Quality-Related Values............................................................................2-1 

2.1.1 Introduction.................................................................................................................2-1 

2.1.2 Laws, Regulations, and Policies .................................................................................2-1 

2.1.3 Resource Indicators.....................................................................................................2-4 

2.1.4 Current Conditions......................................................................................................2-6 

2.1.5 Resource Changes: Trends and Forecasts.................................................................2-22 

2.2 Climate Change......................................................................................................................2-22 

2.2.1 Introduction...............................................................................................................2-22 

2.2.2 Resource Indicators...................................................................................................2-23 

2.2.3 Current Conditions....................................................................................................2-23 

2.2.4 Resource Changes: Trends and Forecasts.................................................................2-23 

2.3 Soils........................................................................................................................................2-33 

2.3.1 Introduction...............................................................................................................2-33 

2.3.2 Laws, Regulations, and Policies ...............................................................................2-33 

2.3.3 Resource Indicators...................................................................................................2-33 

2.3.4 Current Conditions....................................................................................................2-34 

2.3.5 Resource Changes: Trends and Forecasts.................................................................2-41 

2.4 Water Resources ....................................................................................................................2-41 

2.4.1 Introduction...............................................................................................................2-41 

2.4.2 Laws, Regulations, and Policies ...............................................................................2-41 

2.4.3 Resource Indicators...................................................................................................2-44 

2.4.4 Current Conditions....................................................................................................2-44 

2.4.5 Resources Changes: Trends and Forecasts ...............................................................2-49 

2.5 Fisheries .................................................................................................................................2-49 

2.5.1 Introduction...............................................................................................................2-49 

2.5.2 Laws, Regulations, and Policies ...............................................................................2-50 

2.5.3 100-Year Floodplain .................................................................................................2-53 

2.5.4 Resource Indicators...................................................................................................2-54 

2.5.5 Current Conditions....................................................................................................2-54 

2.5.6 Resource Changes: Trends and Forecasts.................................................................2-64 

2.6 Vegetation ..............................................................................................................................2-66 

2.6.1 Introduction...............................................................................................................2-66 

2.6.2 Laws, Regulations, and Policies ...............................................................................2-66 

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Table of Contents Appendix M: BSWI Affected Environment Report 

2.6.3 Resource Indicators...................................................................................................2-66 

2.6.4 Current Conditions....................................................................................................2-67 

2.6.5 Resource Changes: Trends and Forecasts.................................................................2-76 

2.7 Wildlife and Special Status Species.......................................................................................2-78 

2.7.1 Introduction...............................................................................................................2-78 

2.7.2 Laws, Regulations, and Policies ...............................................................................2-78 

2.7.3 Resource Indicators...................................................................................................2-81 

2.7.4 Current Conditions – Wildlife Species .....................................................................2-82 

2.7.5 Current Conditions – Wildlife Habitats ..................................................................2-108 

2.7.6 Resource Changes: Trends and Forecasts...............................................................2-114 

2.8 Nonnative Invasive Species (Wildlife and Plant) ................................................................2-115 

2.8.1 Introduction.............................................................................................................2-115 

2.8.2 Laws, Regulations, and Policies .............................................................................2-115 

2.8.3 Resource Indicators.................................................................................................2-116 

2.8.4 Current Conditions..................................................................................................2-116 

2.8.5 Resource Changes: Trends and Forecasts...............................................................2-125 

2.9 Wildland Fire .......................................................................................................................2-125 

2.9.1 Introduction.............................................................................................................2-125 

2.9.2 Laws, Regulations, and Policies .............................................................................2-126 

2.9.3 Resource Indicators.................................................................................................2-127 

2.9.4 Current Conditions..................................................................................................2-128 

2.9.5 Resource Changes: Trends and Forecasts...............................................................2-132 

2.10 Cultural Resources ...............................................................................................................2-133 

2.10.1 Introduction.............................................................................................................2-133 

2.10.2 Laws, Regulations, and Policies .............................................................................2-134 

2.10.3 Resource Indicators.................................................................................................2-138 

2.10.4 Current Conditions..................................................................................................2-138 

2.10.5 Resource Changes: Trends and Forecasts...............................................................2-148 

2.11 Paleontological Resources ...................................................................................................2-149 

2.11.1 Introduction.............................................................................................................2-149 

2.11.2 Laws, Regulations, and Policies .............................................................................2-150 

2.11.3 Resource Indicators.................................................................................................2-155 

2.11.4 Current Conditions..................................................................................................2-155 

2.11.5 Resource Changes: Trends and Forecasts...............................................................2-158 

2.12 Visual Resources Management............................................................................................2-158 

2.12.1 Introduction.............................................................................................................2-158 

2.12.2 Laws, Regulations, and Policy................................................................................2-158 

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Appendix M: BSWI Affected Environment Report Table of Contents 

2.12.3 Resource Indicators.................................................................................................2-160 

2.12.4 Current Conditions..................................................................................................2-160 

2.12.5 Resource Changes: Trends and Forecasts...............................................................2-161 

2.13 Lands with Wilderness Characteristics ................................................................................2-161 

2.13.1 Introduction.............................................................................................................2-161 

2.13.2 Laws, Regulations, and Policies .............................................................................2-161 

2.13.3 Resource Indicators.................................................................................................2-162 

2.13.4 Resource Indicators.................................................................................................2-163 

2.13.5 Current Conditions..................................................................................................2-163 

2.13.6 Resource Changes: Trends and Forecasts...............................................................2-165 

Section 3. Resource Uses .......................................................................................................................3-1 

3.1 Forestry and Woodland Products.............................................................................................3-1 

3.1.1 Introduction.................................................................................................................3-1 

3.1.2 Laws, Regulations, and Policies .................................................................................3-1 

3.1.3 Resource Indicators.....................................................................................................3-1 

3.1.4 Current Conditions......................................................................................................3-2 

3.1.5 Resource Changes: Trends and Forecasts...................................................................3-3 

3.2 Grazing.....................................................................................................................................3-5 

3.2.1 Introduction.................................................................................................................3-5 

3.2.2 Laws, Regulations, and Policies .................................................................................3-5 

3.2.3 Resource Indicators.....................................................................................................3-5 

3.2.4 Current Conditions......................................................................................................3-5 

3.2.5 Resource Changes: Trends and Forecasts...................................................................3-7 

3.3 Locatable and Salable Minerals ...............................................................................................3-8 

3.3.1 Introduction.................................................................................................................3-8 

3.3.2 Laws, Regulations, and Policies .................................................................................3-8 

3.3.3 Resource Indicators.....................................................................................................3-9 

3.3.4 Current Conditions....................................................................................................3-10 

3.3.5 Resource Changes: Trends and Forecasts.................................................................3-13 

3.4 Leasable Minerals ..................................................................................................................3-13 

3.4.1 Introduction...............................................................................................................3-13 

3.4.2 Laws, Regulations, and Policies ...............................................................................3-13 

3.4.3 Resource Indicators...................................................................................................3-14 

3.4.4 Current Conditions....................................................................................................3-14 

3.4.5 Resource Changes: Trends and Forecasts.................................................................3-16 

3.5 Lands and Realty....................................................................................................................3-16 

3.5.1 Introduction...............................................................................................................3-16 

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Table of Contents Appendix M: BSWI Affected Environment Report 

3.5.2 Laws, Regulations, and Policies ...............................................................................3-16 

3.5.3 Resource Indicators...................................................................................................3-18 

3.5.4 Current Conditions....................................................................................................3-18 

3.5.5 Resource Changes: Trends and Forecasts.................................................................3-32 

3.6 Recreation and Visitor Services.............................................................................................3-32 

3.6.1 Introduction...............................................................................................................3-32 

3.6.2 Laws, Regulations, and Policies ...............................................................................3-32 

3.6.3 Resource Indicators...................................................................................................3-33 

3.6.4 Current Conditions....................................................................................................3-34 

3.6.5 Resource Changes: Trends and Forecasts.................................................................3-37 

3.7 Travel and Transportation Management ................................................................................3-38 

3.7.1 Introduction...............................................................................................................3-38 

3.7.2 Laws, Regulations, and Policies ...............................................................................3-38 

3.7.3 Resource Indicators...................................................................................................3-39 

3.7.4 Current Conditions....................................................................................................3-40 

3.7.5 Resource Changes: Trends and Forecasts.................................................................3-45 

3.8 Renewable Energy .................................................................................................................3-46 

3.8.1 Introduction...............................................................................................................3-46 

3.8.2 Laws, Regulations, and Policies ...............................................................................3-48 

3.8.3 Resource Indicators...................................................................................................3-51 

3.8.4 Current Conditions....................................................................................................3-51 

3.8.5 Resource Changes: Trends and Forecasts.................................................................3-55 

Section 4. Special Designations .............................................................................................................4-1 

4.1 Areas of Critical Environmental Concern................................................................................4-1 

4.1.1 Introduction.................................................................................................................4-1 

4.1.2 Laws, Regulations, and Policies .................................................................................4-1 

4.1.3 Resource Indicators.....................................................................................................4-1 

4.1.4 Current Conditions......................................................................................................4-2 

4.1.5 Resource Changes: Trends and Forecasts...................................................................4-6 

4.2 National Trails .........................................................................................................................4-6 

4.2.1 Introduction.................................................................................................................4-6 

4.2.2 Laws, Regulations, and Policies .................................................................................4-6 

4.2.3 Resource Indicators.....................................................................................................4-7 

4.2.4 Current Conditions......................................................................................................4-8 

4.2.5 Resource Changes: Trends and Forecasts.................................................................4-17 

4.3 Wild and Scenic Rivers..........................................................................................................4-21 

4.3.1 Introduction...............................................................................................................4-21 

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Appendix M: BSWI Affected Environment Report Table of Contents 

4.3.2 Laws, Regulations, and Policies ...............................................................................4-21 

4.3.3 Resource Indicators...................................................................................................4-21 

4.3.4 Current Conditions....................................................................................................4-22 

4.3.5 Resource Changes: Trends and Forecasts.................................................................4-24 

Section 5. Social and Economic Conditions.........................................................................................5-1 

5.1 Socioeconomics, Environmental Justice, and BLM Support for BSWI Communities............5-1 

5.1.1 Laws, Regulations, and Policies .................................................................................5-1 

5.1.2 Resource Indicators for Economic Conditions ...........................................................5-2 

5.1.3 Resource Indicators for Social Conditions..................................................................5-2 

5.1.4 Current Conditions for Socioeconomics .....................................................................5-3 

5.1.5 Current Conditions for Environmental Justice..........................................................5-15 

5.1.6 BLM Support for Planning Area Communities ........................................................5-15 

5.2 Subsistence.............................................................................................................................5-23 

5.2.1 Introduction...............................................................................................................5-23 

5.2.2 Laws, Regulations, and Policies ...............................................................................5-24 

5.2.3 Resource Indicators...................................................................................................5-26 

5.2.4 Current Conditions....................................................................................................5-26 

5.2.5 Non-Market Values of Subsistence Resources and Activities ..................................5-40 

5.2.6 Resource Changes: Trends and Forecasts.................................................................5-40 

5.3 Hazardous Materials and Health and Human Safety .............................................................5-40 

5.3.1 Introduction...............................................................................................................5-40 

5.3.2 Laws, Regulations, and Policies ...............................................................................5-41 

5.3.3 Resource Indicators...................................................................................................5-41 

5.3.4 Current Conditions....................................................................................................5-42 

5.3.5 Resource Changes: Trends and Forecasts.................................................................5-46 

Section 6. Reference List .......................................................................................................................6-1 

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Table of Contents Appendix M: BSWI Affected Environment Report 

List of Tables 

Table 2.1.2-1. National and Alaska Ambient Air Quality Standards.........................................................2-2 

Table 2.1.4-1. Summary of Normal Monthly Air Temperature, Precipitation/Snowfall, and Wind 

Speed – McGrath, Alaska ..................................................Error! Bookmark not defined. 

Table 2.1.4-2. Summary of Normal Monthly Air Temperature, Precipitation/Snowfall, and Wind 

Speed – Bethel, Alaska ......................................................Error! Bookmark not defined. 

Table 2.1.4-3. Summary of Normal Monthly Air Temperature, Precipitation/Snowfall, and Wind 

Speed – Nome, Alaska.......................................................Error! Bookmark not defined. 

Table 2.1.4-4. Survey-Based Emissions ......................................................Error! Bookmark not defined. 

Table 2.1.4-5. Donlin Gold Mine, Monitoring Data Summary, 2006-2009 ............................................2-13 

Table 2.2.4-2. Trends and Forecasts Related to Climate Change for Resources in the Planning 

Table 2.1.4-6. Alaska Historical and Reference Case GHG Emissions (MMTCO2e).............................2-17 

Table 2.2.4-1. Change in Mean Seasonal Temperatures (Degrees F)......................................................2-26 

Area................................................................................................................................2-28 

Table 2.4.4-1. Approximate Discharge and Water Quality Parameters of Major USGS-Gaged 

Streams in the Planning Area.........................................................................................2-45 

Table 2.4.4-2. Core and contingent aquatic indicators used for Alaska Implementation of the 

AIM-National Aquatic Monitoring Framework ............................................................2-47 

Table 2.5.5-1. Fish Species Present in Freshwater Habitats of the Planning Area ..................................2-56 

Table 2.5.5-2. Dates of Critical Activity for Important Subsistence, Commercial, and Sport Fish 

Species in the Planning Area .........................................................................................2-57 

Table 2.6.4-1. Vegetation Communities in the Planning Area ................................................................2-69 

Table 2.6.4-2. Current BLM-Designated Sensitive Plant Species Known within the Planning Area .....2-74 

Table 2.7.4-1. Native Amphibian and Mammal Species in the Planning Area .......................................2-83 

Table 2.7.4-2. Resident, Migratory, Wintering, Rare,* and Accidental Bird Species Found in the 

Planning Area ................................................................................................................2-97 

Table 2.7.4-3. Bird Species of Concern in the Planning Area ...............................................................2-104 

Table 2.7.5-1. Wildlife Habitat in the Current ACECs..........................................................................2-109 

Table 2.8.4-1. Nonnative Invasive Plant Species Known to Occur in the Planning Area .....................2-118 

Table 2.8.4-2. Marine or Freshwater Nonnative Invasive Species with Highest Potential for 

Spread or Introduction to the Planning Area ...............................................................2-120 

Table 2.9.4-1. Planning Area Decadal Fire History...............................................................................2-128 

Table 2.9.4-2. Planning Area Historical Fire Regimes Based on Fire Frequency and Severity ............2-128 

Table 2.9.4-3. Fuel Models within Planning Area ..............................................................................2-129 

Table 2.10.4-1. AHRS Site Types in Planning Area Regardless of Land Status...................................2-146 

Table 2.10.4-2. AHRS Site Types on BLM-Managed Lands ................................................................2-146 

Table 2.11.4-1. Paleontological Localities in the Planning Area...........................................................2-156 

Table 2.12.4-1. Visual Resource Inventory Values within the Planning Area ......................................2-160 

Table 2.13.5-1. Summary of Findings for Lands with Wilderness Characteristics for Planning 

Area..............................................................................................................................2-164 

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Appendix M: BSWI Affected Environment Report Table of Contents 

Table 2.13.5-2. Subunits Inventoried for Wilderness Characteristics....................................................2-164 

Table 3.5.4-1. Effect of ANCSA 17(d)(1) Withdrawals on Federal Public Lands ..................................3-19 

Table 3.5.4-2. R&PP Lands in the Planning Area ...................................................................................3-21 

Table 3.5.4-3. BLM-Managed Public Lands Considered for Exchange or Disposal in the Planning 

Area................................................................................................................................3-21 

Table 5.2.4-1. Yukon River Area Communities, Pounds of Resources Harvested by CommunityError! Bookmark not def

Table 5.2.4-2. Kuskokwim River Area Communities Villages, Pounds of Resources Harvested by 

Table 3.5.4-4. Withdrawals in the Planning Area....................................................................................3-24 

Table 3.5.4-5. Lands Considered for Acquisition in the Planning Area ..................................................3-28 

Table 3.6.4-1. Special Recreation Permits in the Planning Area by Type...............................................3-37 

Table 3.8.1-1. Distribution of BLM-Managed Public Land in Relation to Local Communities .............3-47 

Table 3.8.5-1. FERC Withdrawals Affecting BLM Land in Planning Area............................................3-55 

Table 4.1.4-1. Acres of Existing, Nominated, and Potential ACECs in Planning Area ............................4-3 

Table 4.3.4-1. Eligibility Determinations of 18 Rivers Located in the Planning Area ............................4-24 

Table 5.1.4-1. Social Conditions in Planning Area Communities .............................................................5-7 

Table 5.1.4-2. Economic Characteristics in Planning Area Communities...............................................5-13 

Community ........................................................................Error! Bookmark not defined. 

List of Figures 

Figure 2.1.4-1. Denali National Park and Preserve Visibility Trends, 1988-2015 (IMPROVE 

2016)..............................................................................................................................2-15 

Figure 2.1.4-2. Denali National Park and Preserve Light Extinction Summary – Clearest Days, 

Figure 2.1.4-3. Denali National Park and Preserve Light Extinction Summary – Haziest Days, 

Figure 2.1.4-5. Net Emissions from GHG “Sinks” and Wildfires in the State of Alaska (Exhibit 

1988-2015 (IMPROVE 2016)........................................................................................2-16 

1988-2015 (IMPROVE 2016)........................................................................................2-16 

Figure 2.1.4-4. Alaska Historical and Reference Case GHG Emissions (ADEC 2015b)........................2-19 

26, ADEC 2015b) ..........................................................................................................2-19 

Figure 2.1.4-6. Typical Noise Levels.......................................................................................................2-21 

Figure 2.2.4-1. Temperature Trends, 1949-2014 for McGrath, Alaska. ..................................................2-24 

Figure 2.2.4-2. Temperature Trends, 1949-2014 for Bethel, Alaska. ......................................................2-25 

Figure 2.2.4-3. Temperature Trends, 1949-2014 for Nome, Alaska........................................................2-25 

Figure 3.8.1-1. Average Solar Irradiance for Alaska ...............................................................................3-47 

Figure 3.8.5-1. FAA aircraft navigation beacon at Chandalar Lake in the Brooks Range of 

northeast Alaska. This is the type and scale of renewable energy development 

that could occur in the planning area. ............................................................................3-56 

List of Appendices 

Appendix M-1: BLM Alaska Sensitive Species 

vii 
 

List of Acronyms Appendix M: BSWI Affected Environment Report 

List of Acronyms 

μg/m3 micrograms per cubic meter 

AAC Alaska Administrative Code 

ACCS Alaska Center for Conservation Science 

ACEC Areas of Critical Environmental Concern 

ACHP Advisory Council on Historic Preservation 

ACIWG Aquatic Core Indicator Work Group 

ACRC University of Alaska Climate Research Center 

ADEC Alaska Department of Environmental Conservation 

ADF&G Alaska Department of Fish and Game 

ADNR Alaska Department of Natural Resources 

AEA Alaska Energy Authority 

AFS Alaska Fire Service 

AHPA Alaska Historic Preservation Act 

AHRS Alaska Heritage Resource Survey 

AIM Assessment, Inventory, and Monitoring 

AIRFA American Indian Religious Freedom Act 

AIWFMP Alaska Interagency Wildland Fire Management Plan 

AKEPIC Alaska Exotic Plant Information Clearinghouse 

AML Abandoned Mine Land 

AMS Analysis of the Management Situation 

ANCSA Alaska Native Claims Settlement Act 

ANILCA Alaska National Interest Lands Conservation Act 

AOP Annual Operating Plan 

APDES Alaska Pollutant Discharge Elimination System 

AQCR Air Quality Control Region 

ARC Alaska Road Commission 

ARPA Archaeological Resources Protection Act 

AS Alaska Statute 

ASCMCRA Alaska Surface Coal Mining Control and Reclamation Act 

ASIP Alaska State Implementation Plan 

ASOS Automated Surface Observing System 

ASTM American Society for Testing and Materials 

ATV all-terrain vehicle 

AWC Anadromous Waters Catalog 

AWFCG Alaska Wildland Fire Coordinating Group 

BCC Bird Species of Conservation Concern 

BIA Bureau of Indian Affairs 

BLM Bureau of Land Management 

BMP best management practice 

viii 
Appendix M: BSWI Affected Environment Report List of Acronyms 

BSWI Bering Sea-Western Interior 

Btu British thermal unit 

CAA Clean Air Act 

CEQ Council on Environmental Quality 

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act of 1980 

CFR Code of Federal Regulations 

CI confidence interval 

CMP comprehensive management plan 

CSU conservation system unit 

CUA Controlled Use Area 

CWA Clean Water Act 

CYRMP Central Yukon Resource Management Plan 

dBA A-weighted decibel 

DMLW Division of Mining Land and Water 

DOD Department of Defense 

DOI U.S. Department of the Interior 

EFH Essential Fish Habitat 

EIS Environmental Impact Statement 

EO Executive Order 

EPA U.S. Environmental Protection Agency 

ERMA Extensive Recreation Management Area 

ESA Endangered Species Act 

ESMP Enhanced Smoke Management Plan 

ES&R emergency stabilization and rehabilitation 

FAA Federal Aviation Administration 

FERC Federal Energy Regulatory Commission 

FLM Federal Land Manager 

FLPMA Federal Land Policy and Management Act 

FMP Fishery Management Plan 

FR Federal Register 

GHG greenhouse gas 

GHGRR Greenhouse Gas Reporting Rule 

GIS geographic information system 

HAP Hazardous Air Pollutant 

HVW high-value watershed 

IBA Important Bird Area 

IM Instruction Memorandum 

IMPROVE Interagency Monitoring Protected Visual Environments 

INHT Iditarod National Historic Trail 

KCH Kilbuck Caribou Herd 

KMS Kolmakof Mine Site 

ix 
List of Acronyms Appendix M: BSWI Affected Environment Report 

kwh kilowatt-hour 

LMP locatable mineral potential 

MBF thousand board-feet 

MCH Mulchatna Caribou Herd 

MLA Mineral Leasing Act of 1920 

MLRA Major Land Resource Areas 

MMT million metric tons 

MOU Memorandum of Understanding 

MS Manual Section 

MSA Magnuson-Stevens Fishery Conservation and Management Act 

MSGP Multi-Sector General Permit 

NAAQS National Ambient Air Quality Standards 

NADP National Atmospheric Deposition Program 

NAGPRA Native American Graves Protection and Repatriation Act 

NDVI normalized difference vegetation index 

NEPA National Environmental Policy Act of 1969 

NESHAP National Emission Standards for Hazardous Air Pollutants 

NHPA National Historic Preservation Act 

NLCS National Landscape Conservation System 

NMFS National Marine Fisheries Service 

NNIS nonnative invasive species 

NOAA National Oceanic and Atmospheric Administration 

NPL National Priorities List 

NPS National Park Service 

NRCS Natural Resources Conservation Service 

NRHP National Register of Historic Places 

NSEDC Norton Sound Economic Development Corporation 

NSPS New Source Performance Standards 

NTMC National Trails Management Corridor 

NTSA National Trails System Act 

NWS National Weather Service 

OFM Outcomes-Focused Management 

OHV off-highway vehicle 

OHWM ordinary high water mark 

ORV outstanding remarkable value 

P.L. Public Law 

PFYC Potential Fossil Yield Classification 

PGE platinum group elements 

PLO Public Land Order 

PM10 particulate matter less than or equal to 10 micrometers in diameter 

PM2.5 particulate matter less than or equal to 2.5 micrometers in diameter 

x 
Appendix M: BSWI Affected Environment Report List of Acronyms 

PRP potentially responsible party 

PRPA Paleontological Resources Preservation Act 

R&I relevant and important 

R&PP Recreation and Public Purposes 

RAC Resource Advisory Council 

RAM Removal Action Memorandum 

RCRA Resource Conservation and Recovery Act 

REA Rapid Ecoregional Assessment 

REE Rare Earth Elements 

REF Alaska Renewable Energy Fund 

RMA recreation management area 

RMP Resource Management Plan 

RNA Research Natural Area 

ROD Record of Decision 

ROW right-of-way 

RSC recreation setting characteristics 

RY Regulatory Year 

SHPO State Historic Preservation Office 

SIP State Implementation Plan 

SMCRA Surface Mining Control and Reclamation Act 

SNAP Scenarios Network for Alaska and Arctic Planning 

SRMA Special Recreation Management Area 

SRP special recreation permit 

SSS special-status species 

SWMFP Southwest Planning Area Management Framework Plan 

TCP Traditional Cultural Property 

TKC The Kuskokwim Corporation 

TMA Travel Management Area 

TSCA Toxic Substance Control Act 

U.S.C. U.S. Code 

UAS unmanned aerial system 

USDA U.S. Department of Agriculture 

USFWS United States Fish and Wildlife Service 

USGS U.S. Geological Survey 

VOC volatile organic compound 

VRI Visual Resource Inventory 

VRM Visual Resource Management 

WACH Western Arctic Caribou Herd 

WFDSS Wildland Fire Decision Support System 

WNS White Nose Syndrome 

WRCC Western Regional Climate Center 

xi 
List of Acronyms Appendix M: BSWI Affected Environment Report 

WSA Wilderness Study Area 

WSR Wild and Scenic River 

xii 
 

 

 

 

 

 

 

 

Appendix M: BSWI Affected Environment Report Section 1. Introduction 

Section 1. Introduction 

The purpose of this document is to describe the existing biological, physical, and socioeconomic 

characteristics of the Bering Sea-Western Interior (BSWI) Resource Management Plan (RMP) Planning 

Area (planning area), including human uses that could be affected by implementing the alternatives 

described in Chapter 2 of the BSWI Draft RMP/Environmental Impact Statement (EIS). 

It addresses environmental conditions that may have changed since the Southwest Planning Area 

Management Framework Plan (SWMFP) (BLM 1981) and the Resource Management Plan and Record 

of Decision for the Central Yukon Planning Area (CYRMP [BLM 1986a]) were completed as well as key 

findings and new information identified in the Analysis of the Management Situation [AMS], Bering SeaWestern Interior Resource Management Plan (BLM 2015a). 

The document is organized into four sections: Section 2, Resources; Section 3, Resource Uses; Section 4, 

Special Designations; and Section 5, Social and Economic Conditions. Each of these four sections is split 

further into resources or program areas. 

Each of these resource or program area sections include an introduction, a description of current 

conditions, and a description of resource changes: trends and forecasts, that explain the direction of 

change between the present and some point in the past, and indicators that can be measured to help 

explain present and future change. 

Acreages were calculated using geographic information system (GIS) technology and Bureau of Land 

Management (BLM) land status as of August 2016, and there may be slight variations in total acres 

between resources. The planning area includes all lands, regardless of jurisdiction, within the planning 

area boundaries. However, the BLM makes decisions on only the lands and federal mineral estate that it 

administers (the decision area). 

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Section 1. Introduction 

Appendix M: BSWI Affected Environment Report 

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1-2 
 

 

Appendix M: BSWI Affected Environment Report Section 2. Resources 

Section 2. Resources 

2.1 Air Quality and Air Quality-Related Values 

2.1.1 Introduction 

Impacts to air quality and air quality-related values resource are typically evaluated in comparison to air 

quality standards that are established in context of a robust and complex framework of federal, state, and 

local regulations. Therefore, a detailed review of relevant air quality standards and regulations follows. 

Additionally, a review of meteorology and climate in the area serves as important background because of 

the role it plays in air quality and the effects of natural and human-caused sources of air pollution on local 

and regional air quality. 

2.1.2 Laws, Regulations, and Policies 

Federal Regulations 

The federal Clean Air Act (CAA) and the CAA amendments form the basis for a broad range of 

regulations that control allowable emissions and ambient concentrations of air pollutants in the 

environment. This Act grants powers of enforcement to the U.S. Environmental Protection Agency 

(EPA), which establishes National Ambient Air Quality Standards (NAAQS) to protect the public from 

air pollution. Current NAAQS are summarized in Table 2.1.2-1, and descriptions of the pollutants 

themselves are provided below in the Criteria Pollutants section. 

Air pollutants for which NAAQS exist are called “criteria” pollutants: carbon monoxide (CO), lead (Pb), 

nitrogen dioxide (NO2), ozone (O3), particulate matter (including particulate matter equal to or less than 

10 micrometers in diameter and equal to or less than 2.5 micrometers in diameter (PM10 and PM2.5, 

respectively), and sulfur dioxide (SO2). Primary NAAQS are designed to protect public health, whereas 

secondary NAAQS are designed to protect the public welfare from effects such as visibility reduction, 

soiling, and nuisance. 

Geographic areas where concentrations of a given pollutant exceed an ambient air quality standard are 

classified as nonattainment areas for that standard. Previously designated nonattainment areas that are 

now in compliance with air quality standards are classified as maintenance areas. Areas that meet the 

standards and have met them for several years (usually at least 10 years) are classified as attainment areas. 

When available ambient air quality data are insufficient for a specific NAAQS, the area is designated 

either “Unclassifiable/Attainment,” or “Cannot be classified or better than national standards.” For 

regulatory purposes, such designations are presumed to be attainment. Federal regulations require states 

to prepare State Implementation Plans (SIP) that identify emission reduction strategies for nonattainment 

and maintenance areas, and compliance with federal air quality standards. The planning area is currently 

classified as attainment or unclassifiable/attainment for all current criteria pollutants (Title 40 Code of 

Federal Regulations [CFR] 81.302). 

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Table 2.1.2-1. National and Alaska Ambient Air Quality Standards 

Pollutant 

Averaging 

Time 

National Standard 

(NAAQS) 

Alaska 

Standard Remarks 

Carbon Monoxide (CO) 8-hour 9 ppmv (10 mg/m3) 10 mg/m3 (Primary) Not to be exceeded more than once per year. 

1-hour 35 ppmv (40 mg/m3) 40 mg/m3 

Lead (Pb) Rolling 

3-month 

0.15 μg/m3 0.15 μg/m3 (Primary and Secondary) Not to be exceeded. 

Nitrogen Dioxide (NO2) 1-hour 100 ppbv (188 μg/m3) 188 μg/m3 (Primary) 98th percentile of 1-hour daily maximum concentrations, 

averaged over 3 years. 

Annual 53 ppbv (100 μg/m3) 100 μg/m3 (Primary and Secondary) Annual Mean. 

Ozone (O3) 8-hour 0.070 ppmv (137 

μg/m3) 

0.070 ppmv (Primary and Secondary) Annual fourth highest daily maximum 8-

hr concentration, averaged over 3 years. 

Particulate Matter (PM) 

Particulate Matter Less than or Equal to 

2.5 micrometers in Diameter (PM2.5) 

Annual 12.0 μg/m3 12.0 μg/m3 (Primary) Annual mean, averaged over 3 years. 

Annual 15.0 μg/m3 - (Secondary) 98th percentile, averaged over 3 years. 

24-hour 35 μg/m3 35 μg/m3 (Primary and Secondary) 98th percentile, averaged over 3 years. 

Particulate Matter Less than or Equal to 

10 micrometers in Diameter (PM10) 

24-hour 150 μg/m3 150 μg/m3 (Primary and Secondary) Not to be exceeded more than once per 

year averaged over 3 years. 

Sulfur Dioxide (SO2) 1-hour 75 ppbv (196 μg/m3) 196 μg/m3 (Primary) 99th percentile of 1-hour daily maximum concentrations, 

averaged over 3 years. 

3-hour 0.5 ppmv (1,300 

μg/m3) 

1,300 μg/m3 (Secondary) Not to be exceeded more than once per year. 

Annual - 80 μg/m3 Annual mean. 

24-hour - 365 μg/m3 Not to be exceeded more than once per year. 

Ammonia [Not a criteria pollutant] 8-hour - 2.1 mg/m3 Not to be exceeded more than once per year. 

Source: EPA 2016a; ADEC 2016a 

Notes: 

mg/m3 = milligrams per cubic meter 

ppbv = parts per billion by volume 

μg/m3 = micrograms per cubic meter 

ppmv = parts per million by volume 

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There are other air pollutants that do not have ambient air standards, but are regulated, directly or 

indirectly, at their emission level. These include Hazardous Air Pollutants (HAPs), volatile organic 

compounds (VOCs), and greenhouse gases (GHGs). HAPs, also known as air toxics, are air pollutants 

that are known to cause cancer or other serious health impacts. They are regulated for stationary sources 

on a technology basis under National Emission Standards for Hazardous Air Pollutants (NESHAP) rules. 

VOCs, while also having potential health concerns, are regulated mostly for their involvement in creating 

photochemical smog under certain conditions. Like HAPs, VOC emissions are regulated on a technology 

basis, under New Source Performance Standards (NSPS), which also sets limits for some criteria 

pollutant emissions by source type. GHGs are gases that trap heat in the atmosphere and contribute to 

climate change (addressed below in Section 2.2, Climate Change). The main GHGs of concern in Alaska 

are carbon dioxide (CO2), methane (CH4), and nitrous oxide (N2O). Until recently, there were no federal 

or State regulations for GHG emission levels, only guidance, reporting requirements, and permitting 

thresholds. EPA has recently finalized rules for methane emissions from solid waste landfills and oil and 

natural gas sources under NSPS. The regulation of GHGs is evolving rapidly. EPA provides up-to-date 

scientific and regulatory information on its website at https://www.epa.gov/ghgemissions. 

Other federal air quality regulatory programs include Prevention of Significant Deterioration and the 

Title V Air Permitting Program for major stationary sources. These programs may apply to some 

stationary sources in the planning area, depending on specific facility applicability criteria. As with 

NESHAP and NSPS, they are addressed through permitting as administered by either federal or state air 

quality agencies, depending on the program, location, and/or source. 

The EPA Regional Haze Rule establishes a visibility protection program for federal Class I areas, which 

include national parks and some wilderness areas (EPA 2016b). The rule requires states to develop and 

implement protection plans as part of their SIPs. In coordination with the Regional Haze Rule and the 

State SIP, Federal Land Managers (FLMs) are responsible for protecting increments or limits on the 

maximum allowable increases in air pollutants and related impacts (such as visibility and deposition) at 

Class I and other sensitive Class II areas (wilderness areas and wildlife refuges, for example). The FLM is 

typically involved when a new or modified major facility is proposed within 100 kilometers of one or 

more of these areas (U.S. Forest Service et al. 2010). For larger facilities (with potential for greater 

pollutant emission levels), the FLM has discretion on their level of review. The planning area borders 

Denali National Park and Preserve (Class I), located on the northeast border, and several sensitive Class II 

areas lies within or adjacent to the planning area, the largest being the Yukon Delta and Innoko National 

Wildlife Refuges (NWRs), both within the planning area, and Lake Clark National Park and Reserve, 

outside the planning area, adjacent to the southeast border. 

As part of the CAA, the General Conformity Rule establishes a process to ensure that any proposed 

federal action would not cause or contribute to new violations of air quality standards, increase the 

frequency or severity of existing violations, or delay the timely attainment of a standard. This Rule only 

applies to federal actions occurring in nonattainment or maintenance areas, and would, therefore, not 

currently apply in the planning area. 

State and Local Regulations 

The Alaska Department of Environmental Conservation (ADEC) is the air quality management agency 

for the State of Alaska and is responsible for achieving and/or maintaining compliance with federal air 

quality standards. The Alaska State Implementation Plan (ASIP) is the federally enforceable plan 

identifying control measures and strategies for meeting these standards. The original ASIP was prepared 

in 1972 and has been updated regularly to meet changing federal standards and pollutant requirements in 

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the state (ADEC 1972). The planning area includes portions of two ASIP Air Quality Control Regions 

(AQCRs): the South Central Alaska Intrastate AQCR (which includes the southern portion of the 

planning area) and the Northern Alaska Intrastate AQCR (which includes the northern portion of the 

planning area). As stated above, the planning area is currently classified as attainment or 

unclassifiable/attainment for all current criteria pollutants. 

Current Alaska State Ambient Air Quality Standards are established in the Alaska Administrative Code 

(AAC) Title 18 AAC Chapter 50; these are shown along with the federal NAAQS in Table 2.1.2-1. Most 

of the federal standards have been adopted by the State, per 18 AAC 50.010. Alaska also has an ambient 

standard for ammonia (NH3), as shown in Table 2.1.2-1. 

Besides attaining and maintaining NAAQS, the ASIP contains provisions for implementing new or 

revised NAAQS, rule adoption into the ASIP, and State air quality programs (such as motor vehicles, 

outdoor/agricultural burning, indoor burning (woodstoves), and regional haze programs). Air permitting 

for commercial business and industry is also part of these programs. The State also has some industrial 

emission standards, as set forth in 18 AAC 50.050 and 055; these set limits on specific pollutants for 

certain industrial processes and fuel-burning equipment, including limits on visible emissions. In addition, 

ADEC operates an air quality-monitoring network to assess compliance with pollutant ambient air quality 

standards, and to develop strategies for maintenance of other regulatory requirements, such as visibility. 

Other Agency Policy and Guidance 

The BLM Soil, Water, and Air Program provides coordination and technical assistance for air issues on 

BLM lands in Alaska and ensures that BLM-related activities maintain air quality standards and noise 

objectives in cooperation with other federal, tribal, State, and local agencies. As such, air quality 

decisions and actions within the BLM must comply with the CAA and conform to the ASIP. The program 

also cooperates with other agencies to monitor climate conditions and trends (BLM 2018a). 

BLM's Alaska Fire Service (AFS) is responsible for wildland fire management on all Department of 

Interior (DOI)-administered land and native corporation lands designated under the Alaska Native Claims 

Settlement Act (ANCSA). AFS works cooperatively on an interagency basis with other federal, State, and 

tribal partners through the Alaska Wildland Fire Coordinating Group (AWFCG). This group represents 

federal and State agencies and native organizations with wildland fire and smoke management 

responsibilities in Alaska. The AWFCG sets guidance and procedures for smoke mitigation measures for 

all wildland fire (wildfire and prescribed fire) in Alaska (AICC 2016). ADEC is the regulatory agency 

responsible for smoke management in Alaska (ADEC 2016b). 

2.1.3 Resource Indicators 

The conditions that are established in the discussions below provide a baseline for air quality and air 

quality-related values, which the impact analysis will be based on. The following indicators, along with 

qualitative discussions, will be used to evaluate impacts associated with management decisions in the 

BSWI Draft RMP/EIS. 

• Acres accessible to commercial woodland activity 

• Acres accessible to livestock grazing 

• Acres accessible to mineral development 

• Acres accessible to transportation 

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• Wildland fire management Class I and Class II sensitive airsheds within the planning areas 

• Acres where BMPs may be required for allowable actions based on implantation-level decisions 

Criteria Pollutants 

Summary descriptions of each criteria pollutant are provided below. “Criteria” air pollutants refer to those 

air pollutants for which the EPA has developed criteria on which to base NAAQS under the CAA. 

Carbon Monoxide (CO) 

Carbon monoxide (CO) is a colorless, odorless, nonreactive gas that is a product of incomplete 

combustion. Emissions are mostly associated with motor vehicles and machinery burning fossil fuels, 

and, in residential areas, from wood burning stoves and fireplaces. High CO concentrations in the air 

develop primarily during winter when periods of light winds combine with the formation of ground level 

temperature inversions. These conditions result in reduced dispersion of emissions, leading to potentially 

elevated CO levels near the sources. When inhaled at high concentrations, CO combines with hemoglobin 

in the blood and reduces its oxygen carrying capacity, resulting in reduced levels of oxygen reaching the 

brain, heart, and other body tissues. Very high levels of CO are not common in outdoor areas. 

Lead (Pb) 

Sources of lead emissions include ore and metals processing, piston-engine aircraft using leaded fuel 

(avgas), waste incinerators, utilities, and lead-acid battery manufacturers and recyclers. The highest 

concentrations of lead in air are generally found near lead smelters and general aviation airports. The 

phase out of leaded gasoline for use in motor vehicles has resulted in dramatically decreased levels of 

atmospheric lead. Lead has a range of adverse neurotoxic health effects. Depending on the level of 

exposure, lead can affect the nervous system, kidney function, immune system, reproductive and 

development systems, and the cardiovascular system. 

Nitrogen Dioxide (NO2) 

Nitrogen dioxide (NO2) is in the group of highly reactive gases known as nitrogen oxides (NOx). The 

primary source of NO2 is combustion, with emissions from motor vehicles, power plants, and off-road 

equipment. NO2 is a lung irritant and can aggravate respiratory diseases and contribute to the 

development of asthma and infections. NO2 reacts with other chemicals in the air to form both particulate 

matter and ozone, which can also be harmful when inhaled (both criteria pollutants, described below). In 

addition to these health-based effects, NO2 can react to form acid rain, and nitrate particles, which can 

affect visibility and cause harmful terrestrial and marine deposition. 

Ozone (O3) 

Ground level ozone is regulated because of its health and environmental effects. It is not emitted directly 

into the atmosphere, but is a secondary air pollutant produced in the atmosphere through a complex series 

of photochemical reactions between NOx and VOCs, pollutants emitted by vehicles and other combustion 

sources, chemical plants, refineries, waste treatment facilities, etc. Unhealthy levels of ozone are more 

common on hot sunny days in urban areas. However, ozone is a regional pollutant; it can be transported 

long distances by wind, therefore even rural areas can exhibit high ozone levels. Ozone is a respiratory 

irritant and an oxidant that increases susceptibility to respiratory infections and other ailments. Ozone 

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affects sensitive vegetation and ecosystems and can also cause damage to other materials through 

oxidation. 

Particulate Matter (PM10 and PM2.5) 

PM10 and PM2.5 consist of airborne particles that measure 10 micrometers or less in diameter and 2.5 

micrometers or less in diameter, respectively. They represent fractions of particulate matter that can be 

inhaled into the air passages and the lungs, causing adverse health effects. Particulate matter in the 

atmosphere results from many kinds of dust and fume-producing industrial and agricultural operations, 

fuel combustion, wood burning stoves and fireplaces, and atmospheric photochemical reactions. Some 

sources of particulate matter, such as demolition, construction activities, and mining, consist of mostly 

larger particulate, and are more local in nature. Other sources, such as from combustion, fumes, and 

secondary formation consist of smaller particulate (fine inhalable) and can have a more regional effect 

depending on transport mechanisms (i.e., wind). PM10 and PM2.5 pose serious health risks, because they 

can be inhaled deep into the lungs. Depending on their chemical composition, they can contribute to acid 

rain, and can have adverse terrestrial, vegetative, and marine effects through deposition. Fine particles 

(PM2.5) are a major cause of reduced visibility or haze. 

Sulfur Dioxide (SO2) 

Sulfur dioxide (SO2) is primarily formed during combustion of fossil fuels, from power plants and large 

industrial facilities to locomotives, ships and other vehicles that burn fuel with a high sulfur content. 

Other sources of SO2 emissions include ore extraction and natural sources, such as volcanoes. Sulfur 

dioxide is also a precursor to the formation of atmospheric sulfate and particulate matter and contributes 

to potential atmospheric sulfuric acid formation that could precipitate downwind as acid rain. Exposure to 

SO2 can be harmful to respiratory systems, both directly and from resultant particulates. Environmental 

effects of SO2 are similar to those from particulates, including acid rain, deposition, and haze. 

2.1.4 Current Conditions 

Climate and Meteorology 

The discussion of air quality and atmospheric conditions in the planning area begins with a summary of 

the local climate and meteorological features. This background information is important in the role it 

plays in air quality and the effects of natural and human-caused sources of air pollution on local and 

regional air quality. Climate change is addressed in a separate section (see Section 2.2). Air quality, 

including levels of GHG in the atmosphere, is interrelated with climate change. Therefore, this section is 

also useful as background information for the climate change section. 

Weather, often termed as meteorology, deals with atmospheric conditions over short time periods 

(minutes to weeks); standard meteorological variables include temperature, humidity, precipitation, 

cloudiness, wind speed and direction, and solar radiation. Climate refers to weather ‘behavior’ of the 

atmosphere, over longer periods of time (months to years); both weather (short-term) and climate (longterm) influence the transport and dispersion of air pollutants. The generation of air pollutants is also 

affected by both weather and climate, as activity types and scheduling, heating requirements, and travel 

are often coordinated to meet weather criteria. Daylight hours also have an effect on climate (temperature 

and solar radiation, for example), and indirectly may also have an effect on air quality by dictating some 

seasonal construction and operation schedules. Daylight hours in the planning area range from 

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approximately 19 hours (southern boundaries) to 22 hours (northern boundaries) in the summer and 6 

hours (south) to 3 hours (north) in the winter (NOAA 2016). 

Due to the expanse of the state, along with the varied geological features, the climate of Alaska is broken 

out into five major zones (WRCC 2016a). The planning area is subarctic (below the Arctic Circle), and is 

located primarily within the transition climate zone, with influences of other climate zones in some 

portions of the planning area. The transition zone is located between the maritime and continental climate 

zones. The continental zone includes the interior basin, and exhibits large seasonal variation in 

temperatures, with minimum winter temperatures not uncommonly reaching the -50s (degrees F), and 

maximum summer temperatures in the upper 70s (degrees F). It is also relatively drier than coastal areas 

of Alaska, with annual average precipitation of 20 inches. On the other end of the spectrum, the maritime 

zone, located along the southern regions of the state, along the Gulf of Alaska (including the Aleutian 

Islands), has more moderate temperature ranges (winter to summer ranges from 20s to 60s (degrees F), 

with an annual average temperature of 42 degrees F), and precipitation averaging 70 inches of rain. 

Climate variables in the transition zone lie between those of the continental and maritime zones; annual 

average temperature is 27 degrees F, ranging from approximately 0 degrees F in winter to the low 60s 

(degrees F) in summer, and annual average precipitation is approximately 30 inches. Similar to the 

transitional zone, the maritime continental zone is a hybrid of the maritime and continental zones. As in 

maritime climates, the summer temperatures here are moderated by the open water of the Bering Sea. 

However, the presence of winter sea ice creates a cooler, more continental winter temperature pattern 

(approximately 10 degrees F cooler in winter than in the transition zone). 

There is not a definitive delineation between the climate zones in the planning area, and some locations 

may exhibit properties of more than one zone, with the influence of continental zone climate in the 

northeast, and the influence of maritime continental zone climate on the western boundary of the planning 

area. Due to its location between the Bering Sea and the extreme nature of air masses in the Interior, 

much of the planning area is truly a transition zone. 

The most comprehensive weather stations representative of the planning area are at McGrath, Bethel, and 

Nome. Nome is outside the planning area, to the west of the northern portion, and to the north (across 

Norton Sound) from the western portion. The three station locations represent the influential climate 

zones within the planning area and reach the approximate extent of the planning area boundaries 

(McGrath to northeast, Bethel to south, and Nome to northwest; see the BSWI Draft RMP/EIS, Map 1-2). 

These are considered “first order” National Weather Service (NWS) stations. They are Automated

Surface Observing System (ASOS) stations, a joint program between the NWS, Federal Aviation 

Administration (FAA), and the Department of Defense (DOD), and they provide large and consistent data 

sets that are normally acceptable for use in air quality analyses (NWS 1999). 

Table 2.1.4-1 through Table 2.1.4-3 show the summary of monthly normals of: maximum, minimum, and 

average temperatures, precipitation, snowfall, and daily wind speed for the McGrath, Bethel, and Nome 

stations, respectively. Although all are considered to be in the transition climate zone, the McGrath 

station, within the interior, is more influenced by the continental zone climate than maritime (as shown in 

the cooler winter temperatures, as compared to other two stations). The Bethel station exhibits some 

properties of maritime continental zone climate due to its proximity to the Bering Sea. The Nome station 

(outside the planning area, but somewhat representative of northwesterly coastal areas within the planning 

area) also shows influence of the maritime continental climate zone, with four months (December through 

March) showing average minimum temperatures below 0 degree F. The Bethel and Nome stations also 

show higher average wind speeds than the McGrath station, also a feature of more maritime exposure. 

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Table 2.1.4-1. Summary of Normal Monthly Air Temperature, Precipitation/Snowfall, and Wind Speed – McGrath, Alaska 

Jan Feb Mar Apr May Jun Jul Aug Sept Oct Nov Dec Ann 

Average Maximum 

Temperature 

(degrees F) 

1.0 11.4 22.9 39.1 56.0 66.8 68.5 63.2 52.9 32.3 13.0 2.2 35.8 

Average Temperature 

(degrees F) -7.7 4.4 10.5 30.9 47.2 58.3 60.2 55.2 45.5 25.8 7.2 -3.7 27.8 

Average Minimum 

Temperature 

(degrees F) 

-17.2 -11.3 -3.8 16.7 34.9 45.8 49.5 45.4 35.8 18.9 -2.8 -14.8 16.4 

Average Total 

Precipitation (in) 0.99 0.85 0.79 0.71 0.91 1.60 2.27 2.91 2.29 1.37 1.27 1.22 17.16 

Average Total 

Snowfall (in) 14.6 12.3 11.1 6.3 0.8 0.0 0.0 0.0 1.0 9.5 16.6 18.4 90.6 

Daily Average Wind 

Speed (mph) 1.8 2.4 4.3 5.1 5.3 4.5 4.4 3.9 4.0 3.6 2.4 1.5 3.6 

Source: WRCC 2016b 

Period of Record for Ave. Max. Temp, Ave. Min. Temp. Total Precip., and Ave. Snow is 04/01/1939 – 06/09/2016. Period of Record for Ave. Temp. and Ave. Wind Spd. Is July 1996-December 2008. 

Table 2.1.4-2. Summary of Normal Monthly Air Temperature, Precipitation/Snowfall, and Wind Speed – Bethel, Alaska 

Jan Feb Mar Apr May Jun Jul Aug Sept Oct Nov Dec Ann 

Average Maximum 

Temperature 

(degrees F) 

12.0 15.4 20.9 33.1 49.6 59.9 62.6 59.7 52.1 35.8 23.4 14.1 36.6 

Average Temperature 

(degrees F) 5.6 14.2 13.0 27.7 41.9 53.3 56.2 53.9 45.7 30.0 18.7 8.1 30.7 

Average Minimum 

Temperature 

(degrees F) 

-0.8 1.4 4.9 17.2 32.6 43.1 48.0 46.6 38.6 24.4 11.3 1.2 22.4 

Average Total 

Precipitation (in) 0.77 0.71 0.75 0.72 0.95 1.55 2.26 3.35 2.50 1.47 1.29 1.06 17.36 

Average Total 

Snowfall (in) 7.9 7.3 8.5 5.4 1.8 0.1 0.0 0.0 0.3 4.1 10.0 10.3 55.7 

Daily Average Wind 

Speed (mph) 13.2 12.3 12.4 11.7 10.0 9.2 9.6 9.3 9.6 10.2 11.1 11.7 10.9 

Source: WRCC 2016b 

Period of Record for Ave. Max. Temp, Ave. Min. Temp. Total Precip., and Ave. Snow is 08/01/1923 – 06/09/2016. Period of Record for Ave. Temp. and Ave. Wind Spd. Is July 1996-December 2008. 

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Table 2.1.4-3. Summary of Normal Monthly Air Temperature, Precipitation/Snowfall, and Wind Speed – Nome, Alaska 

Jan Feb Mar Apr May Jun Jul Aug Sept Oct Nov Dec Ann 

Average Maximum 

Temperature (degrees F) 13.2 13.7 17.1 26.7 42.6 53.4 57.3 55.8 48.7 34.3 22.9 14.4 33.3 

Average Temperature 

(degrees F) 4.6 9.5 9.7 21.1 36.0 47.9 51.4 49.9 42.9 28.8 18.4 7.7 27.3 

Average Minimum 

Temperature (degrees F) -2.4 -2.6 -0.2 11.7 29.8 39.7 45.3 44.2 36.6 22.7 10.3 -0.5 19.5 

Average Total Precipitation 

(in) 0.88 0.74 0.60 0.69 0.70 1.07 2.24 3.25 2.42 1.46 1.09 0.91 16.06 

Average Total Snowfall (in) 10.3 9.3 7.6 6.8 2.0 0.2 0.0 0.0 0.4 4.6 10.9 10.8 62.9 

Daily Average Wind Speed 

(mph) 9.1 10.7 9.1 9.2 8.4 8.5 9.1 9.4 9.8 9.1 10.1 9.5 9.3 

Source: WRCC 2016b 

Period of Record for Ave. Max. Temp, Ave. Min. Temp. Total Precip., and Ave. Snow is 08/01/1900 – 06/09/2016. Period of Record for Ave. Temp. and Ave. Wind Spd. Is July 1996-December 2008. 

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Based on the cooler temperatures and lower wind speeds in the winter months at McGrath, the northeast 

portions of the planning area would be more likely to have inversion events, which can trap air pollution 

in stagnant air. 

A review of climatological data from additional weather stations in the planning area shows concurrence 

with the McGrath, Bethel, Nome station normals. These stations are from the National Oceanic and 

Atmospheric Administration (NOAA)/NWS Cooperative Observer Network, which are operated by 

volunteer observers. They typically have less complete data sets and are only used to complement the 

ASOS site data for air quality analyses. An interactive map of available stations, linked to various station 

data (including monthly normals) is found on the Western Regional Climate Center (WRCC) website. 

These climate data are considered broadly representative of climate conditions found over much of the 

planning area. Additional climate data are available for selected sites from the University of Alaska 

Climate Research Center (ACRC) (see http://climate.gi.alaska.edu/Climate/Normals) as well as from 

previously noted agency sources. Specific weather events are influenced by variations in elevation, 

topography, and cloud cover. Wind conditions often reflect channeling and mountain valley flows due to 

complex terrain, especially in the interior regions. Storms can either develop in or move into the Bering 

Sea then move north or northeastward, creating strong winds along the western coastal area. Except for 

local strong wind conditions, wind speeds typically diminish from the coast to the interior. Wind direction 

trends northeast. 

Air Pollutant Sources 

As noted above, the planning area is currently classified as attainment or unclassifiable/attainment for all 

criteria pollutants. Much of the area is remote and rural, and air quality is generally good. Regional and 

local air quality however, is periodically affected by local, regional, and global natural events and humancaused activities. 

There are no large industrial facilities within the planning area. Some typical facilities include small 

diesel-fired power plants (and other diesel power generation), asphalt plants, rock and gravel plants, bulk 

storage facilities, and mining. All of these source types require some form of permitting or regulatory 

notification through ADEC, including quantification of potential emission. Exhaust from diesel power 

generators in some rural communities can adversely impact local air quality, visibility, and odor. Rural 

refuse sites and water treatment plants may also create nuisance odor levels. Noise pollution from 

motorized vehicles occurs locally from vehicles, boats, and aircraft. 

Residential emissions also occur in small towns and villages within the planning area. These generally 

include smaller sources, such as woodstoves, diesel generators, and mobile sources (vehicles and boats). 

These smaller residential sources are not individually quantified by ADEC, although estimates can be 

made using population-based emission factors. Survey-based emission inventories by borough were made 

in 2005 (Sierra Research 2007). Information was collected on seasonal activity and fuel use, and results 

were extrapolated to other communities based on similarities in geography, location, and size. Several 

communities within the planning area were included in that study. Borough population-based emission 

factors for criteria pollutants, VOCs, and NH3 can be determined from the data and used to estimate base 

emissions for current and future years. 

Table 2.1.4-4 provides the survey emissions for the two boroughs within the planning area, Bethel and 

Wade Hampton (also known as Kusilvak; approximately 100 kilometers northwest of Bethel), with 

comparison to all rural communities within the state. Note that these emissions do not include point 

sources (such as industrial facilities and power plants) or commercial marine and aviation sources. Both 

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survey year 2005 emissions and future year 2018 (prorated based on population trends at the time of the 

report) are included. These data have not been updated/revised since the original report in 2007; the 

population trends have not been verified with actual data for accuracy. Population-based emission factors 

were calculated based on this information and are also shown in the table. The emission factors, per 

capita, are lower for all pollutants in the Bethel area, as compared to Wade Hampton and the combined 

factors for all Rural Communities. Emission factors for 2018 are lower than 2005 factors in most cases. 

This is due to anticipated increases in combustion efficiency and other emission reduction programs for 

residential sources. 

Oil and gas development potentially produces criteria pollutants, HAPs, VOCs, and GHGs. Although 

mining activities primarily generate particulate emissions, they can also emit other criteria pollutants, 

HAPs, VOCs, and GHGs as well. These types of sources are typically located further from rural 

communities and are less likely to create local impacts in populated areas. Currently, there are no known 

oil and gas development projects in the planning area (per public ADEC permitting records) (ADEC 

2016c). 

The most significant pollutants in the planning area are particulate matter: fugitive dust (primarily PM10) 

and wood smoke (primarily PM2.5) (ADEC 2016d). Besides the potential health effects of these criteria 

pollutants, these forms of human-caused and natural air pollution may also impair visibility. Along with 

fine particulate, the smoke from burning wood contains a mix of gases, some of them harmful toxics (i.e., 

HAPs). The major sources of fugitive dust in rural Alaska are unpaved roads and exposed or braided 

riverbeds with high sediment loads. Emissions of these dust/smoke particulate types also vary seasonally, 

due to climate conditions. During snow-free seasons, the roads and riverbeds have more exposure and are 

more susceptible to re-entrainment in the atmosphere due to wind events. And in winter, temperature 

inversions (more likely to occur in continental-influenced climates in the eastern portion of the planning 

area (nearer to and within the Interior Basin), and at river bottoms or other topographically similar 

locations) may trap wood smoke and other pollutants at ground level. 

Additional sources of particulate emissions in the planning area include volcanic ash and wildfire smoke; 

these events are not regularly occurring but have the potential for large amounts of emissions in a single 

event. Pollutants from these events can be characterized and their contribution to ambient concentration 

levels can be assessed. However, the CAA Exceptional Events Rule exempts these types of sources from 

inclusion in attainment analyses (EPA 2016c). Therefore, emissions from wildfire or other natural events 

do not count toward nonattainment status, although prescribed burns are managed in coordination with 

the ASIP strategies and attainment status. 

Wildland smoke from natural or prescribed burns can severely limit local and regional visibility, airborne 

particulate concentrations may reach health hazard levels, and wildland fire odors can attain nuisance 

levels. Depending on atmospheric conditions, smoke and ash from large wildland fires outside of Alaska 

may be transported great distances, adversely affecting air quality within the planning area. The AFS and 

related fire management working groups collect fire data, including records of acreage burned and other 

variables that may affect emissions. 

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Table 2.1.4-4. Survey-Based Emissions 

Borough/Area Population Communities VOC CO NOx PM10 PM2.5 SOx NH3 

2005 Emission Inventory Data Annual Emissions (tons/year) 

Bethel 17,086 37 15,352 14,953 1,126 3,292 1,845 56 2 

Wade Hampton (Kusilvak) 7,863 20 12,084 10,743 643 6,453 2,014 23 1 

Total Rural Communities 249,654 365 360,001 318,650 30,364 196,363 63,853 3,032 84 

2018 Emission Inventory Data Annual Emissions (tons/year) 

Bethel 20,738 37 17,298 15,354 1,430 3,756 2,142 66 2 

Wade Hampton (Kusilvak) 9,834 20 14,875 12,220 852 8,066 2,515 28 1 

Total Rural Communities 325,959 365 510,423 408,785 38,067 291,337 94,526 3,739 117 

2005 Emission Inventory Data Population-Based Emission Factors (tons/person) 

Bethel 0.90 0.88 0.07 0.19 0.11 0.003 0.0001 

Wade Hampton (Kusilvak) 1.54 1.37 0.08 0.82 0.26 0.003 0.0001 

Total Rural Communities 1.44 1.28 0.12 0.79 0.26 0.012 0.0003 

2018 Emission Inventory Data Population-Based Emission Factors (tons/person) 

Bethel 0.83 0.74 0.07 0.18 0.10 0.003 0.0001 

Wade Hampton (Kusilvak) 1.51 1.24 0.09 0.82 0.26 0.003 0.0001 

Total Rural Communities 1.57 1.25 0.12 0.89 0.29 0.011 0.0004 

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Air Quality Monitoring 

Comprehensive monitoring of air quality in Alaska is difficult due to the size of the state and accessibility 

issues in remote regions. In addition, air quality monitoring is typically only conducted in areas where 

pollution is a problem, usually in larger population centers. ADEC conducts some monitoring in smaller 

towns that are representative of multiple communities, and also monitors in response to air quality 

complaints. Particulate pollution problems primarily occur in, and have been managed by, the local 

communities and ADEC individually collaborates with community leadership in locally resolving issues. 

In general, the status of air quality in the planning area is indicated by public observations and 

complaints, as reported to ADEC. No ADEC monitoring data are available for the planning area. 

ADEC conducted a survey of dust complaints in 2010 (ADEC 2012a).

1 The 2010 survey showed 

numerous locations in the planning area with dust complaints, and three sites within the planning area 

initiated monitoring programs (Bethel, Tununak [on the coast, due west of Bethel], and Mekoryuk [on the 

island across from Tununak]). No data from these sites are provided in the 2010 report. 

Based on regional monitoring and agency reports from areas to the east of the planning area (the Eastern 

Interior, including Fairbanks, Denali National Park and Preserve, and Whitehorse, Yukon Territory), 

existing air quality in this region is generally excellent, with the exception of periodic smoke and 

associated particulate matter from summer wildland fires (BLM 2016b). ADEC performed PM2.5 air 

monitoring at Denali between April 2000 and June 2003 (ADEC 2012b). This is the nearest, most 

representative, ambient air monitoring site for the remote regions in the planning area. The highest 

monitored 24-hour PM2.5 concentration during this period was 40.5 micrograms per cubic meter (μg/m3); 

ADEC believes this occurred during a wildfire smoke event. More typical values were much lower, the 

data showing concentrations at 6 μg/m3 or less 97 percent of the time, and 75 percent of the samples were 

below the instrument detection level of 2 μg/m3. 

Donlin Gold conducted ambient monitoring at their proposed site north of Crooked Creek (approximately 

155 kilometer northeast of Bethel) between 2006 and 2009 (USACE 2015). This site is located within the 

planning area, and ambient air quality should be representative of much of the remote portions of the 

region. The data show that baseline ambient air quality is well within the NAAQS. Table 2.1.4-5 

summarizes the data. Note that these data have not been reviewed for accuracy at this time. 

Table 2.1.4-5. Donlin Gold Mine, Monitoring Data Summary, 2006-2009 

Pollutant Averaging Period Monitored Value NAAQS AAAQS 

PM10 24-hour 14 μg/m3 150 μg/m3 150 μg/m3 

PM2.5 

Annual 2.3 μg/m3 12.0 μg/m3 12.0 μg/m3 

24-hour 14 μg/m3 35 μg/m3 35 μg/m3 

SO2 

Annual <0.0005 ppm -- 0.03 ppm 

24-hour 0.002 ppm -- 0.14 ppm 

3-hour 0.002 ppm 0.50 ppm 0.50 ppm 

CO 8-hour 0.4 ppm 9 ppm 9 ppm 

1-hour 0.6 ppm 35 ppm 35 ppm 

NO2 

Annual 0.01 ppm 0.053 ppm 0.053 ppm 

1-hour 0.014 ppm 0.100 ppm 0.100 ppm 

O3 8-hour 0.052 ppm 0.070 ppm 0.070 ppm 

1 The ADEC is currently conducting another survey; however, the results of the 2016 survey are not yet available. 

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Air Quality-Related Values 

An air quality-related value is an air quality resource in itself. The resource may include visibility or a 

specific scenic, cultural, physical, biological, ecological, or recreational resource identified by the FLM 

for a particular area. These resources may be adversely affected by a change in air quality. This section 

focuses on visibility as the primary air quality-related value in Alaska. 

Visibility is defined as the optical quality of the atmosphere, sometimes quantified as standard visual 

range. Visibility may be reported as visual range, in units of distance such as miles or expressed in terms 

of deciview, a measure for describing perceived changes. One deciview is defined as a change in visibility 

that is just perceptible to an average person. 

The Interagency Monitoring Protected Visual Environments (IMPROVE) program was established as part 

of the Regional Haze Rule to monitor visibility at federal Class I areas. The Bering Sea Wilderness is 

currently the only Class I area in the U.S. not being monitored. This is indicative of the limited data for 

the state, and specifically the planning area, which has no available data. The nearest IMPROVE site is at 

Denali National Park and Preserve. Figures 2.1.4-1 through 2.1.4-3 provide summary visibility data for 

this site (IMPROVE 2016). The first graph in Figure 2.1.4-1 shows the visibility on the haziest and 

clearest days in Denali National Park and Preserve with the top line showing haziest days, second line 

from the top showing the natural condition on the haziest days, the third line showing clearest days, and 

the last line showing the natural condition on the clearest days. The second graph in Figure 2.1.4-2 shows 

just the visibility on the clearest days, and the third graph in Figure 2.1.4-2 shows just the visibility on the 

haziest days. The Denali National Park and Preserve site is somewhat representative of the northeastern 

portions of the planning area. Due to higher winds, and locations closer to the Bering Sea, the western 

portion of the planning area is expected to have different visibility characteristics and pollutant 

compositions than these. 

The deciview and light extinction variables in these graphs and charts are measures of impairment; the 

decreasing values show the trend toward improved visibility over time. The Denali National Park and 

Preserve data show that wildland fires are the largest source of haze forming emissions; see “Haziest 

Days 1988-2015” pie chart in Figure 2.1.4-3 showing organic carbon as the largest fraction of haze 

particulate composition. The number of clear days is lowest in summer months, during fire season. The 

peak in haze in 2015 corresponds to the second highest fire season on record. Overall, Denali National 

Park and Preserve has some of the cleanest air measured in the U.S. According to the National Park 

Service (NPS), small amounts of industrial and agricultural contaminants from other continents make 

their way into the park each year in a recurring seasonal pattern. The peak concentrations of international 

contaminants generally occur in the late winter and spring. During summer, naturally occurring wildfire 

smoke is the primary contributor to air quality degradation (NPS 2015). 

The ADEC 2015 Regional Haze Report’s Areawide Pollutant Control Program for Regional Haze (ADEC 

2015a) identifies these types of emissions, effects, trends, and progress in reduction strategies for 

improvement of visibility. Overall, Alaska’s contribution of human-caused emissions contributing to 

visibility impairment at Class I areas is decreasing and is expected to continue decreasing with the 

implementation of the AWFCG smoke management programs. However, emissions from uncontrollable 

sources, including natural wildfire event, international sources, global transport of emissions, and offshore 

shipping in the Pacific are still prominent influences on visibility in Alaska. 

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Figure 2.1.4-1. Denali National Park and Preserve Visibility Trends, 1988-2015 (IMPROVE 2016) 

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Figure 2.1.4-2. Denali National Park and Preserve Light Extinction Summary – Clearest Days, 1988-2015 (IMPROVE 2016). 

Figure 2.1.4-3. Denali National Park and Preserve Light Extinction Summary – Haziest Days, 1988-2015 (IMPROVE 2016). 

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Atmospheric deposition refers to the process by which air pollutants are removed from the atmosphere 

and deposited on terrestrial and aquatic ecosystems. It is reported as the mass of material deposited on an 

area in a given amount of time (kilogram per hectare per year). Wet deposition pertains to air pollutants 

deposited by precipitation, such as rain and snow. One expression of wet deposition is precipitation pH, a 

measure of acidity or alkalinity of the precipitation. Dry deposition refers to gravitational settling of 

particles and adherence of gaseous pollutants to soil, water, and vegetation. Total deposition refers to the 

sum of the airborne material transferred to the Earth’s surface by both wet and dry deposition. The 

National Atmospheric Deposition Program (NADP) is a project that measures atmospheric deposition and 

studies its effects on the environment. Data for Denali National Park and Preserve have been collected 

since 1980 (NADP 2016). 

Greenhouse Gas Emissions 

There are no federal or State regulations that establish ambient air quality emissions standards for GHGs. 

However, the EPA requires mandatory reporting of GHG from large GHG emission sources and in 2010 

implemented the rule, referred to as the Greenhouse Gas Reporting Rule (GHGRR), requiring facilities 

emitting more than 25,000 metric tons of carbon dioxide equivalents (CO2e) on an annual basis to report 

their emissions to the EPA. 

The three most relevant greenhouse gases associated with this planning area are carbon dioxide (CO2), 

methane (CH4), and nitrous oxide (N2O), primarily due to fuel combustion (electric generation and 

transportation), with lesser amounts from waste and landfilling activities. GHG emissions are presented 

using a common metric, CO2e, which incorporates the relative contribution of each gas to the global 

average radiative forcing on a global warming potential weighted basis. 

In 2015, ADEC prepared a State GHG emission inventory using standard EPA methodologies, applying 

some fuel and vehicle efficiency adjustments to better represent Alaska (ADEC 2015b). This report 

provides statewide emissions as well as emissions from the stationary sources required to report under the 

federal GHGRR. Stationary sources are typically larger industrial facilities operating in the state and are 

subject to air quality permit requirements. 

Table 2.1.4-6 provides the 2015 inventory report’s GHG emission in Alaska partitioned by sectors for the 

years 1990, 2000, and 2005 through 2010, respectively, and includes emission sinks as well. From about 

1995 through 2003, GHG emissions were relatively stable at about 50 million metric tons (MMT) of 

CO2e. Emissions peaked in 2005 and by 2009 had declined by about 23 percent. Some of this decline may 

be due to the relatively recent economic recession as emissions increased in 2010. The industrial sector, 

including the oil and gas industries, produces the most GHG emissions in the state, followed by the 

transportation, the residential and commercial, and the electric generation sectors. The waste, agriculture, 

and industrial process sectors each produce relatively small quantities of GHG in Alaska. Figure 2.1.4-4 

summarizes the information graphically. 

Table 2.1.4-6. Alaska Historical and Reference Case GHG Emissions (MMTCO2e) 

Sector 1990 2000 2005 2006 2007 2008 2009 2010 

Electricity Production 3.05 3.62 3.69 3.96 3.74 3.73 3.65 3.51 

Residential & Commercial 4.36 5.27 4.90 5.35 4.97 5.03 4.68 5.02 

Industrial 24.87 26.33 27.02 23.21 23.36 21.33 21.04 20.26 

Transportation 11.18 14.31 17.37 17.37 16.35 13.89 11.64 13.36 

Industrial Processes 1.10 1.17 1.14 0.48 0.47 0.26 0.27 0.29 

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Sector 1990 2000 2005 2006 2007 2008 2009 2010 

Waste 0.32 0.4 0.45 0.47 0.49 0.5 0.52 0.53 

Agriculture 0.05 0.05 0.07 0.07 0.08 0.08 0.09 0.08 

Gross Emissions 44.93 51.16 54.64 50.92 49.45 44.81 41.88 43.04 

Increase in Gross 

Emissions Over 1990 0 6.23 9.71 5.99 4.52 -0.12 -3.05 -1.89 

Emission Sinks -6.5 -25.2 5.2 -29.04 -26.06 -30.31 -8.15 -22.37 

Net Emissions 38.43 25.96 59.84 21.87 23.39 14.5 33.74 20.67 

Source: ADEC 2015b 

These data indicate that in recent years, and as the population in Alaska has grown, there is more efficient 

energy use in these areas, likely due to various conservation and efficiency measures. They also indicate 

that the way land is used affects the ability of the natural environment to take up and store, or sequester, 

carbon, serving as “emission sinks” by removing carbon from the atmosphere. The land use, land use 

change, and forestry sector calculations consider a variety of factors that affect the ability of the soil and 

plants to store carbon. These emission sink factors are relatively stable over time, with the exception of 

wildfires, which can vary greatly from year-to-year. 

The CO2 from wildfires is excluded from this 2015 inventory reporting on the basis that it will be 

absorbed by other plants as they grow to replace those that burned during the fire. However, in addition to 

releasing CO2, wildfires also produce N2O and CH4, which are less readily incorporated into new plant 

growth. In addition, these two compounds are stronger GHGs (higher GWPs) than CO2. Figure 2.1.4-5 

shows the net emissions from emission sinks and wildfires (ADEC 2015b). In most years, this sector 

sequesters carbon from the atmosphere. However, in years with abundant wildfires, such as 2004 and 

2005, this sector contributes additional emissions to the atmosphere. Note: the analysis did not include 

any consideration of permafrost thaw and subsequent CH4 emissions; the complexity of such an analysis 

was beyond the scope of the 2015 inventory report effort. 

Because GHGs are global in nature, it is more important to look at the larger scale (as in the State data) 

and make assessments on individual activity changes in order to evaluate potential effects on resources. 

The GHG emissions shown above are inclusive of the whole state. 

Natural gas and petroleum, and their related industries, account for about 50 percent of the GHG 

inventory. These sectors are mostly non-existent in the planning area. Therefore, a rough estimate of 

GHG emissions in the planning area can be made by reducing these statewide GHG emissions by one half 

(for irrelevant sectors), and then applying a population-based factor of 0.034 (assuming a planning area 

population of 25,000 (BLM 2015a) and statewide population of 737,625 (ADLWD 2015). This gives a 

net GHG emission rate of 0.70 MMT for the planning area in 2010. 

GHG emissions from wildland fires can be estimated using EPA emission factors, which provide fuel 

loading values by region, along with criteria pollutant and GHG emission factors by region (EPA 1996). 

Prescribed burning emission factors are also provided by fire/fuel configuration. Additional burn data 

(area, and more detailed fuel type and loading, if available) would be required to apply these factors and 

estimate emissions. 

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Figure 2.1.4-4. Alaska Historical and Reference Case GHG Emissions (ADEC 2015b) 

Figure 2.1.4-5. Net Emissions from GHG “Sinks” and Wildfires in the State of Alaska (Exhibit 26, 

ADEC 2015b) 

Noise 

Sound is mechanical energy transmitted by pressure waves in a compressible medium (such as air) or 

incompressible medium (such as water). When sound becomes excessive, annoying, or unwanted, it is 

referred to as noise. Noise may be continuous (constant noise with uniform intensity), steady (constant 

noise with fluctuating intensity), impulsive (having a high peak of short duration), stationary (occurring 

from a fixed source), intermittent (occurring at a fixed rate), transient (occurring at a varying rate), or 

mobile (occurring from a non-fixed source). 

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The A-Weighted decibel Sound Level, expressed as dBA, can be used to quantify sound and its effect on 

people (EPA 1978). The A-weighted sound level is based on the dB unit but puts more emphasis on 

frequencies in the range that humans hear best, and less emphasis on frequencies that humans do not hear 

well, thus mimicking the human ear. On the dBA scale, normal conversation falls at about 60 to 65 dBA, 

and sleep disturbance at about 40 to 45 dBA. A change of 1 dBA cannot be perceived by humans, except 

in carefully controlled laboratory environments. Outside of the laboratory, a 3 dBA change is considered 

a just-perceivable difference by humans. Loudness (the subjective perception of sound by humans) is 

generally considered to double for approximately every 6 to 10 dB increase in sound level. 

Figure 2.1.4-6 shows typical sound levels for some common indoor and outdoor activities (Caltrans 2009) 

These are levels that would be heard at the source (or at a distance noted in the scale). Sound levels 

typically drop off at a rate of 6 dBA for each doubling of distance. 

Under the Noise Control Act of 1972 and the Quiet Communities Act of 1978, the EPA has implemented 

federal regulations covering standards for major sources of noise such as construction equipment, rail 

carriers and motor carriers, or transport equipment (EPA 2016d). 

In the past, the EPA coordinated all federal noise control activities through its Office of Noise Abatement 

and Control. The EPA phased out the office's funding in 1982 as part of a shift in federal noise control 

policy to transfer the primary responsibility of regulating noise to State and local governments. However, 

the Noise Control Act of 1972 and the Quiet Communities Act of 1978 were never rescinded by Congress 

and remain in effect today, although essentially unfunded (EPA 2017a). The EPA does not have any 

regulatory authority governing noise in local communities (EPA 2017b). 

Information about aircraft or plane noise is maintained by the FAA. In addition, the Federal Interagency 

Committee on Aviation Noise was formed in 1993 to provide forums for debate over future research 

needs to better understand, predict, and control the effects of aviation noise, and to encourage new 

technical development efforts in these areas (EPA 2017b). 

Local governmental (e.g., city) authorities may have local or State laws. In addition, many states run 

noise pollution programs (EPA 2017b). There are no noise or vibration regulations at the State level in 

Alaska. However, some communities in the planning area may have established noise ordinances at the 

local level that could apply to federal actions occurring in the vicinity. For example, in Bethel, the Bethel 

Municipal Code 18.32.080 Noise, Rural (R) District states: 

No loud noise, whether of public or private origin, shall be permitted within this land use district 

during the hours from 11:00 p.m. to 6:00 a.m. “Loud noise” is defined as a decibel level that 

exceeds 80 dBA max at the property line of the parcel within the R district that is receiving the 

noise. This provision applies to all noise sources, whether generated inside or outside the R 

district, but does not apply to noise associated with aircraft arriving at or departing from the 

airport or emergency equipment or signals operated by a government agency. 

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Figure 2.1.4-6. Typical Noise Levels 

Much of the planning area is located in rural and remote regions of Alaska characterized as having very 

little or no development and, therefore, few sources of artificial noise and vibration. No baseline 

environmental noise assessments have been conducted in the planning area. Baseline environmental noise 

assessments aid predictions or modeling of potential wildlife noise impacts, such as territory 

abandonment/relocation, foraging success, reproduction loss, increase predation due to masking, or 

pairing success. It can be assumed that noise levels in the planning area are likely to range from a low 

25 dBA, representing a quiet, rural nighttime location, to 50 dBA, representing a quiet urban daytime 

location (Caltrans 2009). According to EPA, noise levels in Wilderness Areas are typically 35 dBA (EPA 

1978). Locations near moving water sources (e.g., ocean and rivers) are likely to have increased ambient 

noise levels, depending on water flow characteristics. Winter months are likely to have lower ambient 

noise levels due to cessation of water flow at the surface. 

Proposed federal actions may produce noise from several types of sources, primarily transportation (e.g., 

vehicles, boats, and planes), heavy equipment for construction projects and/or facility operations, and 

mineral development. The effects of these noise sources may vary depending on the noise 

characterization and subsequent interference. Such noise sources may, for example, be chronic and 

predictable, which can cue masking in animals; while infrequent and unpredictable noise may initiate a 

startle response. Baseline noise assessments captured prior to the occurrence of any surface disturbance 

can not only help the prediction or modeling of potential effects to wildlife but assist the BLM and project 

proponent in considering mitigation measures to reduce the predicted impacts. This can be shown as: 

(Baseline + Model – Mitigation) = dBA 

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Both humans and animals in the planning area can be sensitive to sound level or vibration changes. 

Additional sections in this document contain more detailed information on where humans and animals are 

located in the planning area, including Fisheries (Section 2.5), Wildlife and Special Status Species 

(Section 2.7), Cultural Resources (Section 2.10), Recreation and Visitor Services (Section 6), National 

Trails (Section 4.2), Wild and Scenic Rivers (Section 4.3), Subsistence (Section 5.2), and Hazardous 

Materials and Health and Human Safety (Section 5.5). Impacts on these noise-sensitive receptors from 

sound level or vibration changes are discussed in the BSWI Draft RMP/EIS. 

2.1.5 Resource Changes: Trends and Forecasts 

While quantitative air quality data in the region is sparse, the available data indicate that ambient 

concentrations of criteria pollutants are well below the NAAQS. Further, the trends observed in the 

visibility data at Denali provide an indication that air quality in the region is generally improving. 

Wildfire and fugitive dust are two key sources of air quality pollutants that show a high degree of special 

and temporal variability and therefore could cause localized poor air quality events in some years under 

specific meteorological conditions. 

As wildfire and fugitive dust could be increased under a warming environment it is possible that air 

quality could worsen under predicted climate scenarios resulting from climate change. Increased 

development in the area would also have the potential to adversely impact air quality locally and/or 

regionally. 

2.2 Climate Change 

2.2.1 Introduction 

The temperature of the planet’s atmosphere is regulated by a balance of radiation received from the sun, 

and the amount of that radiation that is either re-radiated or absorbed. GHGs, as well as water vapor and 

particulate matter in the atmosphere, keep the planet’s temperature warmer than it would be otherwise; 

allowing the planet to sustain life. While these gases and particles have occurred naturally for millennia, 

there has been a marked increase in their atmospheric concentration since the start of the industrial age, 

which may be contributing to climatic variability beyond the historic norm. 

Ongoing scientific research has identified the potential impacts of human-caused GHG emissions and 

changes in biological carbon sequestration due to land management activities on global climate. Through 

complex interactions on a regional and global scale, these GHG emissions and net losses of biological 

carbon sinks may cause a net warming effect of the atmosphere, primarily by decreasing the amount of 

heat energy radiated by the earth back into space. Although GHG levels have varied for millennia, 

industrialization and burning of fossil carbon sources have caused CO2 concentrations to increase 

dramatically and may contribute to overall global climatic changes. The National Climate Assessment 

(NCA 2014) states that, “multiple lines of independent evidence confirm that human activities are the 

primary cause of the global warming of the past 50 years.”

The National Climate Assessment reports that the U.S. mean temperature has increased 1.3 to 1.9 degrees 

F since 1895; overall, Alaska has experienced the largest regional warming of any state in the U.S., with a 

rise in statewide average annual temperature of 3 degrees F and a rise in average winter temperature of 

6 degrees F over the last 60 years. Average annual temperatures in Alaska are projected to rise by an 

additional 2 to 4 degrees F by 2050 (NCA 2014). As with any field of scientific study, there are 

uncertainties associated with the science of climate change; as such, there is a high degree of confidence 

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in the trend of climate change but less certainty about the magnitude. Additionally, there still remain some 

differing opinions within the scientific community regarding climate science. 

Several natural and human-made activities contribute to the phenomenon of climate change, including 

emissions of GHGs (especially carbon dioxide and methane) from fossil fuel development, large 

wildfires, internal combustion engines, changes to the natural carbon cycle, and changes to radiative 

forces and reflectivity (albedo). It is important to note that GHGs may have a sustained climatic impact 

over different temporal scales. For example, recent emissions of CO2 and other GHG gases can influence 

climate for 100 years. 

The impacts of climate change are already affecting communities, natural resources, ecosystems, 

economies, and public health across the U.S. These impacts are often most significant for communities 

that already face economic or health-related challenges, and for species and habitats that are already 

facing other pressures. 

It may be difficult to discern whether global climate change is already affecting resources within the 

planning area. It is important to note that projected changes are likely to occur over several decades to a 

century. Therefore, many of the projected changes associated with climate change described below may 

not be measurably discernible within the reasonably foreseeable future. 

2.2.2 Resource Indicators 

The conditions that are established in the discussions below provide a baseline for climate change-related 

values, which the impact analysis will be based on. The following indicators, along with qualitative 

discussions, will be used to evaluate impacts associated with management decisions in the BSWI Draft 

RMP/EIS. 

• Estimated GHG emissions from the following: 

o Forest product harvesting 

o Recreation, and Travel and Transportation Management (recreational and subsistence vehicle 

activity) 

o Wildland fire management 

o Development of leasable minerals 

o Locatable and salable mineral development 

o OHV use 

2.2.3 Current Conditions 

The climate of the planning area was discussed in Section 2.1, Air Quality, as climate and meteorology 

are crucial in understanding the effects of natural and human-caused sources of air pollution on local and 

regional air quality. The climatic means, or normals, were also discussed in Section 2.1, Air Quality. 

2.2.4 Resource Changes: Trends and Forecasts 

The trends over periods of record are discussed here. The existing climate in the planning area was 

roughly based on data from three meteorological stations in or near the planning area. The three station 

locations represent the influential climate zones within the planning area and reach the approximate extent 

of the planning area boundaries (McGrath to the northeast, Bethel to the south, and Nome [outside the 

planning area] to the northwest). GHG emissions, a driving force, and thereby useful indicator of climate 

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change, were also discussed in Section 2.1, Air Quality, including current conditions and trends of those 

pollutants. 

Temperature Changes 

As discussed in Section 2.1, Air Quality, historical climate and weather information for the planning area 

is limited, making it difficult for models to determine the exact spatial and temporal variability of 

projected future conditions. The ACRC maintains historical annual air temperature data from 1949 

through 2015. 

The planning area has experienced significant climate change over the last half century, as evidenced in 

the change in mean seasonal temperature over the period and is projected to continue to experience more 

change over the rest of the 21st century. This is part of a larger warming trend seen across all highlatitude regions. 

Figures 2.2.4-1 through 2.2.4-3 (below) show the temperature trends for McGrath, Bethel, and Nome, 

Alaska, respectively, from 1949 to 2014. These graphs from ACRC show the annual means as dots, the 

smoothed data (5-year running means) with the red lines, and the solid black line showing the linear trend 

over the full period (ACRC 2016). In each case, the linear trend shows an increase of several degrees in 

mean annual temperature over the time period. The data also show a high degree of inter-annual 

variability in the seasonal means. 

Figure 2.2.4-1. Temperature Trends, 1949-2014 for McGrath, Alaska. 

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Figure 2.2.4-2. Temperature Trends, 1949-2014 for Bethel, Alaska. 

Figure 2.2.4-3. Temperature Trends, 1949-2014 for Nome, Alaska. 

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Table 2.2.4-1 shows the change in mean seasonal temperatures over this period (ACRC 2016). As shown 

in the table, warming in winter and spring has contributed more towards increased annual temperatures 

than summer or autumn. 

Table 2.2.4-1. Change in Mean Seasonal Temperatures (Degrees F) 

Station Winter Spring Summer Autumn Annual 

1949 through 2015 

McGrath 8.1 4.5 2.4 2.7 4.4 

Bethel 7.2 3.7 1.9 1.1 3.5 

Nome 4.9 2.6 2.2 1.6 2.8 

Trends of Other Climate-Related and Resource Variables 

During the past 50 years, three major trends resulting from warming atmospheric air temperatures have 

been documented in Alaska: growing season length, permafrost thaw, and increases in wildfire and insect 

outbreaks (NCA 2014). Details regarding these subjects are provided in specific resource sections related 

to these physical and biological subjects, including: vegetative communities, soil resources, water 

resources, fish and aquatic species, wildlife, special status species (SSS), and wildland fire ecology. In 

general, the length of the growing season and permafrost thaw are directly related to temperature; 

increases in temperature can cause increases in both of these parameters. These relationships are also 

shown in the figures in the next section for forecast trends. The relationships between wildland fires and 

insect outbreaks with warming temperatures are more complex and are discussed in the relevant resource 

sections. 

Forecasts of Climate Change 

The Scenarios Network for Alaska and Arctic Planning (SNAP) is a collaboration between several 

disciplines to develop and communicate plausible scenarios of the future climate. Data are derived from 

several climate models to produce climate information and climate projections. They provide modeled 

forecasts of air temperature and precipitation to many federal, State, and local governments, and nongovernmental organizations in Alaska. The SNAP general circulation model compilation tool was 

prepared for four different 10-year average time periods (the 2010s, 2020s, 2050s, and 2060s), using the 

mid-range emissions scenario (SNAP 2016). Details regarding the SNAP modeling are provided on their 

website (SNAP 2016). This includes descriptions of the individual models evaluated to prepare the 

coupled model, a compilation of 5-models (the “5-model average”) chosen as the most accurate for 

assessing climate effects for Alaska and the Arctic. The mid-range scenario assumes “a world of rapid

economic growth, a global population that peaks mid-century, rapid introduction of new and more 

efficient technologies, and a balance between fossil fuels and other energy sources.” This emissions 

scenario provides a more realistic assessment of future climate status on a global level. 

Maps 3.2.2-1 through 3.2.2-7 of the BSWI Draft RMP/EIS were created from the Yukon Kuskokwim 

Lowlands Rapid Ecoregional Assessment (REA) specifically to focus on the planning area. These maps 

show the projected average values for January temperature, July temperature, total annual precipitation, 

summer precipitation, winter precipitation, day of freeze, and day of thaw for each of the 10-year average 

time periods. Model outputs are averaged by decade (as opposed to reporting for a single year) to reduce 

statistical noise due to inter-annual variability. Also included for each parameter is a map showing the 

divergence between 2010 and 2060, specifically the maps show the difference between the forecasted 

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Appendix M: BSWI Affected Environment Report Section 2. Resources 

values for the 2060s and the 2010s to support an analysis of the degree of impact in that parameter across 

the study area. 

Maps 3.2.2-1 through 3.2.2-2 of the BSWI Draft RMP/EIS depict a shift towards warmer temperatures in 

the temperature range for the region in both the July and the January temperatures. The winter minimum 

and maximum temperatures for the region are projected to increase by approximately 3 degrees between 

the 2010s and the 2060s. The summer minimum and maximum temperatures for the region are projected 

to increase by approximately 1 degree between the 2010s and the 2060s. The same general geospatial 

pattern in temperatures across the planning area persists throughout the time period. The divergence plot 

for the January temperatures shows that the temperature change over this period was nearly double in the 

coastal area as compared to the interior portion of the study area. 

Maps 3.2.2-3 through 3.2.2-5 of the BSWI Draft RMP/EIS show the projected average annual 

precipitation, average summer precipitation, and average winter precipitation for the four decadal periods. 

On an annual basis, in summer, and in winter the models forecast that precipitation will increase in the 

future throughout much of the study area. The same general geospatial pattern in temperatures across the 

planning area persists throughout the time period. However, it is unclear whether increased precipitation 

will be offset by increasing evapotranspiration driven by warmer air temperatures. Therefore, it cannot be 

assumed that these models suggest a wetter future for the planning area. 

Map 3.2.2-6 of the BSWI Draft RMP/EIS shows the projected first freeze day (the first day that the 

consecutive monthly temperatures transition from above to below 0 degrees C), and Map 3.2.2-7 shows 

the first thaw day (the first day that the consecutive monthly temperatures transition from below to above 

0 degrees C) for the four decadal periods. The biggest changes in first freeze day in the planning area are 

seen along the southwestern coast of the planning area and the northeastern corner especially at lower 

elevations. The maps show a shift between the 2010s and the 2060s of first freeze along a much larger 

portion of the coast not happening until October-December and in the northeastern corner of the study 

area not happening till later in October. Changes in first thaw day are not as dramatic or heterogeneous as 

the changes in first freeze days. The maps show a shift between the 2010s and the 2060s of first thaw day 

of a much larger portion of the study area experience first thaw in late March to late April rather than 

between late April and Mid-May. Following the trend with freeze and thaw days, the length of the 

growing season increases by up to approximately 30 days between the 2010s and 2060s. Changes are 

fairly homogenous throughout the planning area, with the shift being more prevalent early on (between 

the 2010s and 2020s) in the northern interior regions. 

Effects on Resources and Resource Uses 

Table 2.2.4-2 shows the trends and forecasts for other planning area resources. Although increases in 

global GHG emissions are thought to have a causal relationship with global warming, as seen in the above 

forecast climate scenarios from SNAP, climate change on a local and regional level involves very 

complex relationships between atmospheric and geological variables beyond GHG emissions. Additional 

climate change indicators may cross over into other resource variables, which can provide advanced 

predictors for future changes in climate due to complex interactions. These may include indicators as 

shown in Table 2.2.4-2 and in the specific resource sections. 

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Section 2. Resources Appendix M: BSWI Affected Environment Report 

Table 2.2.4-2. Trends and Forecasts Related to Climate Change for Resources in the Planning Area 

Resource Trends Forecast 

Vegetative Specific evidence of climate change affecting riparian The current trends affecting riparian vegetation are predicted to continue. An 

communities − vegetation has not been recorded in the planning area. increasing growing season, potential increases in drought conditions during the hottest 

Riparian However, a longer growing season and hydrological changes 

(resulting from permafrost thaw) has likely affected the health 

and condition of riparian vegetative communities. 

months, and hydrological change due to permafrost thaw will likely continue to affect 

the health and condition of riparian vegetative communities. However, some 

researchers suggest that riparian ecosystems may be relatively resilient to climate 

changes because they have evolved under environmental variability and hydrologic 

extremes. 

Vegetative Forests and woodlands have been impacted by a warming Climate change is predicted to alter the boreal forest through: an overall increase in the 

communities – atmosphere evidenced by: increases in frequency and extent fire regime (frequency, severity, area burned, extent, longer season), and increase in 

Forests and of wildfire; increases in frequency and extent of insect insect and disease infestation, an altered treeline, and stand and landscape-scale 

woodlands outbreaks; warmer growing season temperatures; and 

permafrost thaw and deepening of the soil active layer. 

Additionally, the arctic tree-line has seen a shift northward and 

alpine tree-lines are encroaching into higher elevations. 

alteration of the mosaic composition of forests (age, structure, species composition). 

Additionally, drought stress, permafrost thaw, and deepening soil active layer will affect 

the landscape mosaic and composition of species. 

Four primary hypotheses for forest change in interior Alaska are: (1) landscape-scale 

conversion of conifer forests to broadleaf-dominated ecosystems resulting from 

increased fire frequency or severity; (2) the potential diminution of both white spruce 

(Picea glauca) and black spruce (P. mariana) across much of their current ranges due 

to temperature induced drought stress (3) a concomitant invasion of white spruce into 

previously treeless landscape positions, thereby converting tundra to forest over wide 

areas; and (4) potential increases in phytophagous insect outbreaks due to warming 

climate resulting in changes to forest structure . New research suggests that white 

spruce may gain dominance over black spruce in areas that have experienced 

permafrost thaw and deepened soil active layer. 

Expansion of forests and shrub-lands into tundra areas in the planning area is likely to 

accelerate with future climate warming deepening active layers and promoting 

decomposition, which increases available soil nutrients. Additionally, a shift in 

vegetation zones to higher elevations will likely continue to occur, with species 

expanding into newly favorable areas and declining in unfavorable areas, which has 

been well documented in other parts of the world. 

Vegetative Specific evidence of climate change affecting invasive plant It has been suggested that invasive plant species previously unable to survive Alaskan 

Communities – species has not been recorded in the planning area. Although environmental conditions may be able to thrive in a warmer Alaska. As climate change 

Nonnative it has been suggested that climate change has contributed to is expected to induce large-scale ecosystem function changes for all plant 

Invasive Plant invasive species infestations in the state, definitive research communities, this disturbance may provide an opportunity for invasive plant species to 

Species has not identified climate change as a strong factor in invasive 

species establishment or infestation in the planning area. 

establish and expand in areas they previously would not have survived. The increase 

in wildland fire associated with climate change will likely be an ideal disturbance for 

invasive plants to establish and expand. 

Vegetative 

Communities −

Other 

Tundra communities have shown increased growth rates 

(remote sensed photosynthetic rates) from 1981 to 2003 

indicating an increase in shrub dominance. Shrub expansion, 

specifically alders, has been noted in the Brooks Range 

foothills, Yukon-Kuskokwim Delta (observations of village 

residents), and the Alaska Peninsula. 

Climate change will likely drive additional alteration of plant community composition 

seen through increasing deciduous shrub and graminoid cover at the expense of 

lichens, mosses, and uncommon forbs. Long-term effects might include general treeline advance in elevation as well as latitude; colonization of formerly glaciated lands; 

and transition of woodlands (low tree density) with denser vegetation. 

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Appendix M: BSWI Affected Environment Report Section 2. Resources 

Resource Trends Forecast 

Soil Resources Specific evidence of climate change affecting soil resources 

has not been recorded in the planning area. 

Warmer air temperatures and subsequent rise in soil temperature are not likely to alter 

soil forming processes significantly. However, a rise in soil temperature has and will 

affect nutrient cycling and evapotranspiration (drier or wetter soil conditions). 

Decomposition of plant material has historically been very slow in the planning area. 

However, as soil temperatures rise and permafrost thaws, decomposition rates will 

increase, which will alter nutrient cycles affecting plant communities and other 

ecosystem functions. Plant root growth in permafrost areas is limited to the active soil 

layer (the topmost soil horizons that thaw every summer). As soil temperatures rise, 

the active layer deepens, and that soil becomes destabilized, leading to erosion and 

land subsidence. Structurally, the increase in active layer depth is expected to have an 

adverse effect on the ability of soil to carry loads, such as roads and structures. 

Water The timing of water body’s ice break-up has been noted to Climate change related effects will likely alter a number of hydrologic functions 

Resources occur earlier and freeze-up to occur later in the planning area. 

This directly affects hydrologic function, fish habitat, and 

therefore, fish population health, water body user access, and 

may play a role in the frequency and severity of extreme flood 

events. 

including: seasonal water flow timing and quantities, ice-cover thickness and duration, 

and the frequency and severity of extreme flood events. Stream and river 

geomorphology (sinuosity, bars, beaches, bends, ox bows, cut banks, pools, riffles, 

etc.) are determined by the slopes, discharge volumes, frequency, intensity, timing, 

obstructions, sediment loading, etc., all of which are continually affected by climate. 

Increased variation in climate and subsequent hydrology will result in river systems that 

increasingly move or migrate over the landscape compared to a period of relatively 

stable climate. Potential disruptions to infrastructure, changes in fish and wildlife 

habitat, and possible hazards to shoreline communities, fish camps, and recreation 

users are possible. 

It is unclear how stream water temperature will respond to climate change; a direct 

relationship between air temperature and stream, river, and lake temperature has not 

been found. Glacial fed streams could potentially become colder if glacial melt 

increases in a warmer climate. 

Air Resources Specific evidence of climate change affecting the air and 

atmospheric values has not been recorded in the planning 

area. 

Air pollution due to wildfire is expected to increase. Warmer air temperatures, longer 

growing season, and permafrost thaw will promote decomposition of ancient stored soil 

carbon. Decomposition will result in CO2 (carbon dioxide) and CH4 (methane) release 

into the atmosphere and contribute to climate warming. Additionally, increased 

frequency and extent of fire will contribute to CO2 emissions, especially in tundra areas 

that rarely experience fire, and will contribute to more episodes of air quality advisories 

due to smoke. 

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Section 2. Resources Appendix M: BSWI Affected Environment Report 

Resource Trends Forecast 

Fish Sediment and nutrient loading from thermokarst features in 

Arctic Alaska have been shown to significantly impact 

headwater stream ecosystems by disrupting primary and 

secondary production and benthic communities. Thermokarst 

features would behave in a similar fashion in the planning 

area. However, it is unclear if this has currently had a direct 

effect on fish populations. 

Additionally, it has been suggested that climate change has 

contributed to reduced population levels of several fish, 

especially Chinook salmon. However, definitive research has 

not established climate change as a primary factor in fish 

population declines. 

It is not completely clear how stream and river water temperature will respond to 

climate change and there is insufficient research to suggest that water temperatures 

will increase. However, climate change will result in two phenomena that will have 

major impacts on fish habitat: feeding habitats will remain ice-free for longer and 

permafrost thaw will destabilize adjacent riparian habitat. 

A longer ice-free period for streams and lakes could improve the quality of feeding 

habitats and the longer season will promote fish to mature at an earlier age due to 

increased feeding in a single year. Spawning could shift later in the year for autumn 

spawners and earlier in the year for spring spawners to correspond with the time of 

year that temperatures approach 0 degrees C or the time that aquatic habitats become 

ice-free. 

Permafrost thaw will destabilize adjacent terrestrial habitats and increase erosion and 

runoff into stream systems, increasing stream turbidity. This may reduce primary 

productivity and aquatic invertebrate populations, decreasing quality of fish feeding 

habitat. Alternatively, permafrost thaw may increase nutrient input into aquatic systems 

and increase primary production and invertebrate populations, therefore, increasing 

fish feeding habitat. Although it is unclear how permafrost thaw will affect fish habitat, it 

will likely be localized, with some feeding habitat decreasing in quality and some 

habitat increasing in quality. 

Additionally, it is unclear how ocean acidification will affect anadromous fish 

populations who spend multiple years in the ocean before returning to their spawning 

grounds in the planning area, but it is expected to be a significant impact on these 

species. 

Aquatic Species 

(include invasive 

aquatic species 

threats) 

Evidence of climate change affecting aquatic invasive species 

has not been recorded in the planning area. However, Alaska 

has seen an increase in aquatic invasive species in the past 

10 years, likely due to increased movement of people and 

goods from areas in the lower 48 that have experienced 

increases in invasive species. 

It has been suggested that invasive aquatic species previously unable to survive 

Alaskan environmental conditions may be able to thrive in a warmer Alaska. As climate 

change is expected to induce large-scale ecosystem function changes in riparian and 

aquatic habitats, this disturbance may provide an opportunity for invasive aquatic 

species to establish and expand in areas they previously would not have survived. 

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Appendix M: BSWI Affected Environment Report Section 2. Resources 

Resource Trends Forecast 

Wildlife (include Caribou populations and their movement in the planning area Climate change is expected to alter the range of most wildlife species primarily through 

invasive have changed dramatically in the past 20 years; however, changes in species’ habitats. Additionally, parasites and disease that have historically

terrestrial climate change has not been identified as a primary cause of been suppressed by cold temperatures and short summer seasons are expected to 

species threats) these changes. It is likely that alteration to wildlife habitat has 

been influenced by climate change related effects. However, 

specific declines in wildlife populations have not been 

attributed to climate change and related processes. 

Moose populations in specific regions of the planning area 

have recently experienced declines in populations. However, 

climate change has not been specifically implicated as a 

cause in these declines. 

increase in presence and impact. 

Moose populations would likely respond positively to increased fire frequency because 

it promotes the re-sprouting and re-seeding of deciduous hardwoods (aspen, willow, 

and birch) that provide winter forage for moose. Additionally, shrub species biomass, 

abundance, and cover are expected to increase, therefore increasing availability of 

forage species. Warming air temperatures and lengthened summer season is likely to 

cause an increase in parasite populations through increased rates for development, 

reduction in generation times, and broadened seasonal windows for transmission, 

potentially impacting moose populations. 

Caribou populations will likely be influenced by increasing fire frequency, reduced 

winter food sources and increased insect abundance. Lichen is an important source of 

food for caribou, especially in wintertime. When wildfire burns ground-dwelling lichens, 

it can take several decades for them return to pre-burn levels. Therefore, fire can 

decrease wintering caribou habitat health by eliminating lichens. Climate change also 

has the potential to influence insects, parasites, diseases, snow depth and condition, 

wind, temperature, and cloud cover, all of which have consequences either directly or 

indirectly on survival and reproductive success of caribou. 

Climate change will likely increase the number of days in the nesting season for 

migratory shorebirds, which is often measured in the number of ice-free days or days 

above freezing. For example, a study on the influence of season length on nesting 

range dynamics suggested the recent northerly expansion in distribution of the 

trumpeter swan is likely a result of earlier spring breakup dates and overall warmer 

temperatures. However, wetland drying and shrinkage due to deepening active layer 

and altered drainage may result in less suitable habitat. 

Climate change is likely to cause a general increase in the number of disease 

outbreaks in wildlife populations. Climate change is not expected to increase the 

planning area’s risk to establishment of invasive animal species.

Special Status Evidence of climate change affecting special status wildlife Climate change is expected to affect all BLM Alaska sensitive wildlife species by 

Species − species has not been recorded in the planning area. altering habitat. Increasing wildland fire, increasing length of growing season, altered 

Fauna hydrology due to permafrost thaw, deepening soil active layer, and increases in 

disease and insect outbreak will likely affect all sensitive species. Each of the 10 

wildlife sensitive species will respond differently to changes in their habitats, depending 

on their specific characteristics and survival strategies. 

Special Status Evidence of climate change affecting special status plant Four plant species on the Alaska BLM’s Sensitive Species list occur in the planning

Species − Flora species has not been recorded in the planning area. area. All of these species occur in sparsely vegetated areas or with dwarf vegetation, 

often on steep slopes and loose rocky terrain. Climate change may promote expansion 

of shrubby species into higher elevations and reduce habitat for these species. 

Wildland Fire Wildfire has dominated the disturbance regime of boreal Fire frequency and extent is expected to increase in the future. The Boreal Alaska 

Ecology and forests for the last 6,000 years. Wildfire maintains age Frame-Based Ecosystem Code (Boreal ALFRESCO) developed by University of 

Management structure, species composition, and diversity in the boreal 

forest (Van Wagner 1988). However, in the last 50 years, the 

Alaskan boreal forest has seen a doubling of annual burned 

area and more than doubled frequency of large fire years. 

Alaska Fairbanks Scenarios Network for Alaska and Arctic Planning forecasts an 

increase in fire events and total area burned in boreal areas of the planning area. Fire 

is also likely to become an increasingly important factor in promoting permafrost thaw. 

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Section 2. Resources Appendix M: BSWI Affected Environment Report 

Resource Trends Forecast 

Cultural Specific evidence of climate change affecting cultural Cultural resources in the planning area will experience greater risk of damage or 

Resources resources has not been recorded in the planning area. destruction by wildfire as frequency and extent of fire increases. Permafrost thaw 

underneath structures could result in ground collapse and significant damage to 

structures. Increased occurrences of strong storms could damage cultural sites and 

structures. 

Paleontological Specific evidence of climate change affecting archeological Deepening of the soil active layer and permafrost thaw will likely cause damage to 

Resources and paleontological resources has not been recorded in the 

planning area. No archeological or paleontological sites have 

been affected by erosion, either thermokarst or coastal 

erosion for storm surges within the planning area. 

archeological and paleontological resources; however, the extent and location of 

damage cannot be predicted. While erosional forces have, in the past, often exposed 

paleontological deposits, the rate of future erosion is projected to be faster and 

potentially more damaging. Deepening of the soil organic layer, even without erosional 

forces, will promote decomposition and could reduce preservation of organic 

paleontological materials, particularly Pleistocene fossils. 

Visual Specific evidence of climate change affecting visual resources Erosion caused through thermokarsts or other permafrost slumping, and thaw may 

Resources has not been recorded in the planning area. The warming 

trend experienced over the last half century (and all 

subsequent effects) has not been shown to be a cause in 

disrupting any view-sheds in the planning area. 

affect view-sheds near large rivers and coastlines. If climate warming or any 

subsequent effect of warming develops in the planning area, it could affect the visual 

resources. 

Lands with Specific evidence of climate change affecting lands with The planning area can currently be classified in almost its entirety as having wilderness 

Wilderness wilderness characteristics has not been recorded in the characteristics. In the future, regardless of extreme or minimal affects occurring due to 

Characteristics planning area. The warming trend experienced over the last 

half century (and all subsequent effects) has not been shown 

to be a cause in altering the quality of wilderness 

characteristics in any regions of the planning area. 

climate change-related impacts, the planning area will likely continue to display 

wilderness characteristics in all areas it does currently. One of the requirements to be 

classified as having wilderness characteristics is naturalness, defined as: appearing to 

have been affected primarily by the forces of nature and any work of human beings in 

the area must be substantially unnoticeable. It is likely that most areas of the planning 

area will continue to display wilderness characteristics, despite climate change-related 

affects, unless human development occurs. 

Note. Information sourced from BLM 2015a, which contains full list of technical references. 

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Appendix M: BSWI Affected Environment Report Section 2. Resources 

2.3 Soils 

2.3.1 Introduction 

This section describes the regulatory setting, along with the baseline conditions of in the Project Area. 

Maps 3.2.3-1 through 3.2.3-3 of the BSWI Draft RMP/EIS show the physiographic regions, geologic 

boundaries, and soil types in the planning area. 

2.3.2 Laws, Regulations, and Policies 

Several agencies including the State of Alaska, BLM, U.S. Fish and Wildlife Service (USFWS) and 

multiple ANCSA-recognized Native corporations are involved in the management and use of the lands 

with the planning area. Specific regulations that apply to the management of soils and other geologic 

resources are discussed below: 

• The Federal Cave Resources Protection Act of 1988 (43 CFR, Part 37). This act regulates 

management and identification of significant caves on federal lands. This act protects, to the 

extent practicable, significant caves and cave resources. 

• Clean Water Act (CWA). The EPA is responsible for enforcing the federally-mandated CWA. 

The CWA establishes the basic structure for regulating discharges of pollutants into waters of the 

U.S. and for regulating surface water quality standards. Regulations pertinent to soil in the project 

area include Section 404 of the CWA, which requires individuals, corporations, tribes, or 

government agencies intending to work in waters of the U.S. to obtain a permit from USACE 

before initiating any regulated activity. The permit process for Section 404 permits is 

administered by USACE and EPA. This is relevant to soils because wetlands are defined by soil 

characteristics. 

• Executive Order (EO) 11988 – Floodplain Management (May 24, 1977). This executive order 

requires federal agencies to avoid to the extent possible both long and short term adverse impacts 

on floodplains, which are prevalent across the southwestern portion of the planning area. 

• Alaska National Interest Lands Conservation Act (ANILCA). This act specifically provides 

the State of Alaska with rights to manage all navigable surface waterways, even those that cross 

through federal lands and maintain access to non-federal areas that may cross through federal 

lands. Non-navigable waterways remain under federal management. 

• ANCSA. Some of the lands in the planning area will be affected by ANCSA due to the fact that 

some native corporation selected BLM-managed public lands have current special protections 

status or subsurface rights that may be retained after ownership is transferred. 

• AAC Section 11 - Natural Resources. AAC Section 11 - Natural Resources governs the use, 

lease and development of all natural resources located within the State of Alaska including oil 

and gas, minerals and alternative energy sources such as geothermal energy, the development of 

which all directly impact soils in the area. 

A variety of federal and State laws and permit processes affect the use of soils directly or indirectly for 

specific resource uses. Those provisions will be brought into the analysis in the BSWI Draft RMP/EIS. 

2.3.3 Resource Indicators 

The conditions that are established in the discussions below provide a baseline for soils-related values, 

which the impact analysis will be based on. The following indicators, along with qualitative discussions, 

will be used to evaluate impacts associated with management decisions in the BSWI Draft RMP/EIS. 

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Section 2. Resources Appendix M: BSWI Affected Environment Report 

• Changes in acres of disturbance to soils 

2.3.4 Current Conditions 

In general, soils are the resource in this section that may be affected by BLM management practices. 

Physiography and geology in general will not be changed or altered by management practices set forth in 

this document and any such alterations. Water resources, leasable/locatable/salable minerals/fluids, and 

paleontological resources are subsets of geology, or are closely related, and are discussed elsewhere in the 

RMP. 

Physiography and Geology 

The planning area contains a diverse group of 12 different physiographic provinces (Map 3.2.3-1, BSWI 

Draft RMP/EIS) defined by their geology and surficial expression as defined by Wahrhaftig (1965). The 

following descriptions are excerpts from that reference. Additional discussion on the uses of the resources 

associated with the geology of the area is discussed in Section 3.3, Locatable and Salable Minerals, and 

Section 3.4, Leasable Minerals. 

Yukon-Kuskokwim Coastal Lowland 

The Yukon-Kuskokwim coastal lowland dominates the western portion of the planning area. The coastal 

lowland is a triangular, lake-dotted marshy plain that rises from sea level on its west margin to 100 to 300 

feet at its east end. Many low hills, 2,300 to 2,450 feet high, rise from the western part of the plain. Low 

ridges, marked by lines of thaw lakes, lie along part of the west coast. The area is crossed by meandering 

streams of extremely low gradient, many of which are channels or former channels of the Yukon River. 

These flow west to the Bering Sea. The Yukon River flows along the base of hills on the north side of the 

lowland and is building a delta into the Bering Sea. On the southeast side of the planning area, the 

Kuskokwim River ends in a marine estuary that appears to be a drowned river mouth. 

The lowland is dotted with innumerable thaw lakes, many of them 10 or more miles long. Some have 

scalloped shorelines and probably formed through the coalescence of several smaller lakes. Probably 30 

to 50 percent of the lowland is lake-surface. Underneath the area is discontinuous permafrost (ground 

perennially at temperatures below freezing but having no ice). 

Kuskokwim Mountains 

The Kuskokwim Mountains dominate the central portion of the planning area. They are a succession of 

northeast trending ridges having rounded to flat summits 1,500 to 2,000 feet in elevation and broad gentle 

slopes. Ridges crests north of the Kuskokwim River average 2,000 feet and are punctuated at intervals of 

10 to 30 miles by isolated circular groups of rugged glaciated mountains 3,000 to 4,400 feet in elevation. 

Valleys have flat floors 1 to 5 miles wide. 

The Kuskokwim Mountains are drained by tributaries of the Yukon and Kuskokwim Rivers. Major 

streams generally flow northeast to southwest; streams are fast and meandering and generally lie near the 

northwest walls of their valleys. The Kuskokwim River crosses the mountains in a gorge 100 to 400 feet 

deep incised in an older valley about 1,000 feet deep and 2 to 8 miles wide. Lakes are few. There are 

oxbow and thaw lakes in the valleys and a few cirque lakes in the glaciated mountains. Permafrost 

underlies most of the section, and periglacial erosional processes predominate. 

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Appendix M: BSWI Affected Environment Report Section 2. Resources 

Nulato Hills 

The Nulato Hills make up the majority of the northwest portion of the planning area. These consist, in 

general, of northeast trending even-crested ridges, 1,000 to 2,000 feet in elevation, having rounded 

summits and gentle slopes. Valleys are narrow and have flat floors that are about 30 feet deep in the 

upstream portions. Local relief is 500 to 1,500 feet. 

The topography is relatively fine textured; gullies are spaced 500 to 1,500 feet apart and second-order 

tributaries are one-half to 1 mile apart. Three highland areas of steeper ridges rise to about 4,000 feet in 

elevation. Streams on the east side of the section flow to the Yukon River and those on the west side to 

Norton Sound. Major streams are markedly parallel, flowing either northeast or southwest, and their 

courses are eroded along northeast-trending fault zones. Valley heads are generally connected by low 

passes along the faults. There are a few thaw lakes in the valleys. The entire physiographic province is 

likely underlain by permafrost. 

Nushagak-Big River Hills 

The Nushagak-Big River Hills located in the southeast portion of the planning area are largely rounded, 

flat-topped ridges rising to an elevation of 1,500 feet on the west and 2,500 feet on the east. The hills have 

broad gentle slopes and broad flat or gently sloping valleys. Local relief is 1,000 to 2,500 feet. Mountains 

in the northeastern part rise to an elevation of 4,200 feet. Ridges trend northeast in the eastern part but 

have no preferred trend in the southwestern part. The hills drain to the Kuskokwim River via the Big, 

Stony, Swift, and Holitna Rivers. The rivers rise from glaciers in the Alaska Range and flow across the 

hills. Some, like the Stony and Swift, are braided muddy streams. Others, like the Holitna, are clear and 

meandering. 

Some valleys contain thaw lakes. Ponds are abundant in the moraine-mantled eastern part of the hills. 

Most of the section is underlain by permafrost, and periglacial erosional processes predominate. 

Southern Alaska Range 

The planning area contains the portion of the Southern Alaska Range that drains into the Kuskokwim 

River basin. The Alaska Range consists of many parallel rugged glaciated north-trending ridges 7,000 to 

12,000 feet in elevation; south of Lake Chakachamna the ridges trend northeast and are 4,000 to 6,000 

feet in elevation. Between the ridges lie broad glaciated valleys, which have floors less than 3,000 feet in 

elevation. Local relief is between 4,000 and 9,000 feet. Many spire-like mountains rise in the central part 

of the range. 

Large braided glacial streams follow the north and northeast-trending valleys. They flow north or south to 

the Kuskokwim River and southwest to the Nushagak or Kvichak Rivers. 

Many large lakes occupy glaciated valleys within and on the margins of the range. The largest of these 

bodies is Lake Clark, which is 49 miles long and 1 to 4 miles wide. 

Extensive systems of valley glaciers radiate from the higher mountains. The elevation of the glaciers is 

lower, and the glaciers are larger on the southeast side of the range than on the northwest and west sides 

of the range. The extent of permafrost is unknown. 

Central Alaska Range 

The planning area contains that portion of the central part of the Alaska Range consisting of two or three 

parallel rugged glaciated ridges, 6,000 to 9,000 feet in elevation, surmounted by groups of extremely 

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rugged snowcapped mountains more than 9,500 feet in elevation. The ridges are broken at intervals of 10 

to 50 miles by cross-drainage or low passes; most of the drainage appears superposed. The range rises 

abruptly from lower country on either side, and its longitudinal profile, seen from a distance, is irregular. 

Denali, 20,269 feet high and the highest mountain in North America, is in the Alaska Range. 

The western part of the range drains to the Kuskokwim River. Streams are swift and braided, and most 

rivers start at glaciers. There are a few rock-basin lakes and many small ponds in areas of ground 

moraine. Lakes are rare for a glaciated area. 

The elevation of the glaciers on the north side of the Alaska Range is 6,000 to 8,000 feet; this change 

reflects the northward decrease in cloudiness and precipitation as one passes from the Gulf of Alaska 

coast to the interior. The high mountains are sheathed in ice. Short valley glaciers lie in north-facing 

valleys in the lower parts of the range. Rock glaciers are common. Permafrost is extensive and 

solifluction features are well developed. 

The Innoko Lowlands 

The Innoko Lowlands lie near the center of the planning area along the Yukon River and are a group of 

flat river floodplains, dendritic in pattern, with generally steep banks cut into the surrounding hills; in 

places, however, gentle silt-covered slopes merge with the surrounding hills. The Yukon River and a large 

tributary, the Innoko River, cross the lowlands. The main part of the lowlands has a complex intersecting 

network of meandering sloughs of these two rivers. 

Oxbow and meander-scroll lakes are abundant in recently abandoned floodplains and partly silted 

sloughs. Thaw lakes abound in old floodplains and on gentle silt-covered slopes. The lower parts of many 

tributaries from surrounding hills are dammed by alluvium from the Yukon River and form narrow 

dendritic lakes. Much of the section is underlain by permafrost. 

Holitna Lowland 

The Holitna Lowland located in the southeastern portion of the planning area makes up a small area of 

largely moraine-covered plain 300 to 800 feet in elevation and is crossed by several low arcuate 

hummocky ridges marking the end moraines of glacial advances and by broad outwash and meander 

plains along rivers. The Lime Hills, conspicuous isolated steep-sided ridges in the southern part of the 

lowland, rise to an elevation of 1,000 to 2,300 feet. The Holitna Lowland is drained by the Kuskokwim 

River and three of its tributaries, the Stony and Swift Rivers, which are glacial streams from the Alaska 

Range that have braided gravelly courses, and the Holitna River, a clear meandering stream that rises in 

uplands to the south. There are numerous morainal and thaw lakes throughout the lowland. This 

physiographic area probably has discontinuous permafrost. 

The Tanana-Kuskokwim Lowland 

A small portion of the western part of the Tanana-Kuskokwim Lowland is located along the east-central 

boundary of the planning area. It consists of a broad depression bordering the north flank of the Alaska 

Range with surfaces of diversified origin. Coalescing outwash fans from the Alaska Range slope 20 to 50 

feet per mile northward to floodplains along the axial streams of the lowland. Rivers from the range flow 

for a few miles at the heads of the fans in broad terraced valleys 50 to 200 feet deep. Semicircular belts of 

morainal topography lie on the upper ends of some fans. The floodplain of the Kuskokwim River is 

incised 50 to 200 feet below the level of the lowland. Several nearly level projections of the lowland 

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extend into uplands on the north. Large fields of stabilized dunes cover the northern part of the lowland 

and lower slopes of adjacent hills between Nenana and McGrath. 

The southwestern part of the lowland is drained by the Kuskokwim River; braided glacial streams rising 

in the Alaska Range flow north across the lowland at intervals of 5 to 20 miles. Outwash has pushed the 

axial streams of the Kuskokwim River against the base of hills on the north side of the range. Tightly 

meandering tributaries of low-gradient flow into the physiographic province from the north, and thaw 

lakes abound in areas of fine alluvium. Thaw sinks are abundant in areas of thick loess cover. The entire 

section is an area of permafrost. Porous gravel at the heads of the outwash fans has a deep water table and 

dry permafrost. 

Ahklun Mountains 

The northern tip of the Ahklun Mountains province lies within the southwest portion of the planning area. 

It contains groups of rugged steep-walled mountains that rise abruptly above the lowlands and low hills 

on the north and east. The peaks have sharp summits 2,000 to 5,000 feet in elevation, separated by broad 

flat valleys and lowlands. The Ahklun Mountains are drained on the north by shallow, clear streams that 

flow directly to the Bering Sea and the Kuskokwim River on the northwest. Most rivers are incised in 

bedrock gorges 20 to 50 feet deep in the downstream parts of their valleys. Drainage is roughly radial, and 

several streams in the northwestern part flow through canyons that cut directly across structurally 

controlled ridges. This province is outstanding for the number and beauty of its glacial lakes, which are 

long narrow bodies of water in U-shaped canyons. Kisaralik Lake is an excellent example; lake depths as 

great as 900 feet have been reported. A few small cirque glaciers are found in the highest parts of the 

mountains. Permafrost occurs sporadically. 

Bering Platform 

The Bering Platform province includes that portion of the planning area that lies within the Bering Sea. It 

is a monotonously smooth submarine plain 100 to 500 feet deep bordered on the southwest by a 

submarine scarp several thousand feet deep. The coastal lowland at the head of Norton Sound is included 

in this physiographic province. Several islands rise abruptly from the plain. Most of the islands are rolling 

uplands a few hundred to 1,000 feet high bordered by wave-cut cliffs. 

St. Lawrence Island, the largest, is about 100 miles long and 20 miles wide. It is chiefly a lake-dotted 

bedrock plain less than 100 feet in elevation, above which isolated mountain groups; bordered by old sea 

cliffs, rise to elevations of 1,000 to 1,500 feet. A large shield volcano with many vents is on the north 

coast of St. Lawrence Island. St. Matthew and Nunivak Islands consist largely of undissected volcanic 

topography. Many small rivers drain St. Lawrence Island and Nunivak Island; most small islands have no 

permanent streams. 

Thaw lakes abound on the lowlands of St. Lawrence Island and the lower parts of Nunivak Island; there 

are small crater lakes on Nunivak Island. Part of St. Lawrence Island and possibly Nunivak Island may be 

underlain by permafrost. St. Matthew Island, Nunivak Island, and northcentral St. Lawrence Island are 

made of Cenozoic basalt flows and pyroclastic debris interbedded with some sedimentary rock. St. 

Lawrence Island is underlain largely by intensely deformed Paleozoic and Mesozoic sedimentary and 

volcanic rocks and granitic intrusions. 

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Buckland River Lowland 

The Buckland River Lowlands contain low-elevation rolling hills consisting primarily of Quaternary lava 

flows covered by a thick layer of windborne silt. Small thaw and oxbow lakes are common along the 

Buckland River and in other flat valleys. 

Regional Geology 

The following summary description of regional geology and geologic history is taken from the works of 

Beikman (1980); Decker et al. (1994); Bundtzen and Miller (1997); Miller et al. (2002, 2005); Goldfarb et 

al. (2004) as written in the BLM Alaska Technical Report 60, Mineral Occurrence and Development 

Potential Report (Kurtak et al. 2010). The geology is depicted in Map 3.2.3-2 of the BSWI Draft 

RMP/EIS. 

The oldest rocks within the planning area consist of Early Proterozoic metamorphic rocks of the Idono 

Complex that occur locally within the central Kuskokwim Mountains. Late Proterozoic metamorphic 

rocks occur in the northern Kuskokwim Mountains and form the depositional basement for Paleozoic 

shelf deposits. Paleozoic continental margin deposits underlie much of the southwestern Alaska Range 

and northern Kuskokwim Mountains. These include greenschist facies metaigneous and metasedimentary 

rocks (Decker et al. 1994). Triassic-aged ultramafic rocks in the Mt. Hurst area are believed to be slivers 

of dismembered ophiolites, which host chromite occurrences and platinum group elements (PGE)-bearing 

placers. In the southern Alaska Range, Triassic-aged ultramafic rocks host nickel-copper-PGE 

mineralization. 

Unconformably overlying the older rocks is the regionally extensive Upper Cretaceous Kuskokwim 

Group, which is primarily a turbidite sequence composed of detritus derived from the varied preCretaceous terranes. The Kuskokwim Group consists largely of rhythmically interbedded sandstone and 

shale, but local Late Cretaceous tuff layers record intermittent regional volcanic activity. Erosion of preCretaceous rocks occurring to the north provided clastic material, which began to fill basins that formed 

in the area during middle to Late Cretaceous time. The Kuskokwim Group basin-fill sequence contains 

prograding turbidite, shallow-marine, and shoreline facies, which suggest that the basin filled in by early 

Late Cretaceous time (Bundtzen and Miller 1997). 

Late Cretaceous to early Tertiary volcanic-plutonic complexes, plutons, and extensive dike and sill 

complexes, intrude and overlie the Cretaceous flysch basin fill sediments. Extrusive sections of the 

complexes consist of basal tuffs overlain by andesite and basaltic andesite flows and lesser volcanic 

agglomerate. Plutonic rocks associated with the complexes range in composition from alkali gabbro to 

granite, but monzonite and quartz syenite are the most common compositions. Hornfels aureoles, up to 

1.2 miles wide, surround the larger plutons such as at the Russian, Horn, and Beaver Mountains. These 

areas host polymetallic vein-type mineralization. Age data for the plutons indicates a bimodal distribution 

of ages with one group from 64 to 61 million years and the other 71 to 66 million years. Intrusion of 

carbonate sequences by plutons resulted in the formation of gold-bearing copper skarn deposits in the 

Nixon Fork area (Bundtzen and Miller 1997). 

The dike and sill complexes cut the sedimentary rocks and form elongate belts. These appear to be 

structurally controlled in part by northeast-trending high-angle structures such as the Yankee-Ganes 

Creek and Iditarod-Nixon Fork faults. This includes the Ganes-Yankee Creek and Donlin Creek dike 

swarms. Locally the dikes have been altered by silicification and contain fine grained arsenopyrite, pyrite, 

and stibnite. Late-stage quartz veins and veinlet networks associated with the felsic dikes are the source of 

the gold at deposits such as the Independence Mine and Donlin Creek. Peraluminous granite-porphyry 

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dikes, stocks, and sills in the area and of similar age contain gold-copper polymetallic deposits such as at 

Chicken and Vinasale Mountains (Bundtzen and Miller 1997). 

The intrusive bodies and dikes are probably the source of the placer gold found in such drainages as 

Ganes and Flat Creeks and at Nyac. Placer gold has concentrated in both bench and modern stream 

placers. The modern stream placers were probably formed from reworking of the bench deposits during 

uplift and subsequent downcutting by area streams. Altered Tertiary-Cretaceous intermediate to mafic 

dikes, cutting the sedimentary units are associated with epithermal mercury-antimony deposits, 

concentrated mostly within the Kuskokwim River basin. 

Upper Cretaceous nonmarine sedimentary rocks occur within a series of fault-bound basins within the 

study area. These formations locally contain coal beds, which were mined for use by steamboats on the 

Yukon River. These occur mainly along that stretch of the Yukon River between Anvik and Kaltag. A 

large portion of the study area is covered by Quaternary surficial deposits consisting of young river, 

floodplain, glacial, alluvial, and lake deposits. These young continental sediments are concentrated mostly 

along the drainage basins of the Kuskokwim and Yukon Rivers. 

The youngest volcanic activity within the area consists of subaerial basalt flows and cinder cones of 

Quaternary to Tertiary age on the south side of Norton Sound. Pleistocene glaciation was confined to 

some of the isolated mountain ranges in the area such as the Horn and Russian Mountains and in the 

Alaska Range along the southern boundary of the study area. Cirque glaciers exist to the present day in 

the higher portions of the southern Alaska Range in the southeast corner of the area. 

Structural Geology and Tectonics 

The following description of planning area structural geology and tectonics is taken from BLM Alaska 

Technical Report 60, Mineral Occurrence and Development Potential Report (Kurtak et al. 2010; also see 

Map 3.2.3-2 of the BSWI Draft RMP/EIS). 

The structural geology of the study area is dominated by a series of northeast-trending right-lateral strikeslip faults with proposed offsets of up to 90 miles. These faults are listed from north to south: the Kaltag 

fault near Unalakleet; the Iditarod-Nixon Fork fault near McGrath; and the Denali-Farewell fault (see 

Map 3.2.3-2 of the BSWI Draft RMP/EIS). Movement along these faults is believed to be dominantly 

Cenozoic. These faults in part form boundaries between a series of geologic terranes including the Ruby, 

Nixon Fork, Dillinger, Innoko, Kahiltna, and Farewell terranes. They also cut overlapping younger units 

such as the Kuskokwim Group. The Farewell terrane makes up the bulk of the rock units within the study 

area and probably formed a significant part of the North American Continental margin against which the 

Mesozoic terranes of southern Alaska were accreted (Decker et al. 1994). 

Deformation affecting the Kuskokwim Group rocks began in Late Cretaceous time. Rock assemblages 

were deformed in a right-lateral wrench fault tectonic environment, as characterized by echelon folds and 

high-angle faults. One of the major right-lateral structures is the northeast-trending Iditarod-Nixon Fork 

fault along which there may be as much as 58 miles of right-lateral offset. This fault lies within what is 

termed the “Kuskokwim Mineral Belt” and is spatially associated with both placer and lode deposits 

within the study area. The Yankee-Ganes Creek fault parallels this structure and is spatially associated 

with mineralized small intrusive bodies and dike swarms. To the south lies the parallel Denali-Farewell 

fault, which runs along the Alaska Range front. The fault is estimated to have 80 miles of right-lateral 

offset. Offset streams and sag ponds along the fault trend are indicative of recent movement (see Map 

3.2.3-2 of the BSWI Draft RMP/EIS). The oldest rocks were subjected to multiple fold episodes as 

characterized by tight isoclinal folds. Late Cretaceous and younger rocks are more broadly folded. This 

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tectonic movement probably controlled the formation of the Kuskokwim basins and the emplacement of 

the Late Cretaceous to early Tertiary plutonic and volcanic rocks (Bundtzen and Miller 1997). 

Mineral Resources 

Mineral resources found within the planning area are discussed in Section 3.3, Locatable and Salable 

Minerals, and Section 3.4, Leasable Minerals. 

Soils 

Most soil resources in the planning area are largely in natural condition with minimal human-made 

disturbance. The planning area is sparsely populated with few commercial facilities or roads, and no 

large-scale commercial crop, livestock, or grazing activity. 

Soils in the planning area have been surveyed on a very broad scale in the Exploratory Survey of Alaska 

(USDA 1979) and in much greater detail over the central portion of the planning area Soil Survey of 

Western Interior Rivers Area, Alaska (USDA 2008). The 1979 report covers soils within the Kuskokwim 

Highlands, the Western Alaska coastal plains and deltas, the Alaska Range and the Bering Sea Islands. 

The 2008 U.S. Department of Agriculture (USDA) report focused on soils located in approximately 9.7 

million acres in the central portion of the planning area that straddles the Yukon and Kuskokwim Rivers 

as they move from interior to western Alaska and the Bering Sea and includes updated information on the 

Kuskokwim Highlands the Western Alaska coastal plains and deltas. The soil orders and their respective 

suborders in the planning area described in the USDA 1979 and 2008 reports in their environmental and 

hydrologic review of the Yukon and Kuskokwim River watersheds. Soils are depicted in Map 3.2.3-3 of 

the BSWI Draft RMP/EIS. Widespread alluvial, lacustrine, and eolian deposits occur in the Yukon Flats 

area. A soil survey and ecological site description of the Nulato Hills was initiated jointly by BLM and 

the Natural Resources Conservation Service (NRCS) in 2015 and will take several more years to 

complete. Data from these surveys will be used to further inform BLM management decisions in the 

future. 

Many of the soils in the planning area are poorly developed because the cold climate impedes most soilforming processes, except organic matter accumulation, and leads to the formation and preservation of 

permafrost (Ping et al. 2006). Decomposition is extremely slow in cold wet soils; chemical weathering to 

form clay minerals occurs at a negligible rate; and cryoturbation of soils counteracts typical soil profile 

development. Soil characteristics tend to vary with topography and slope-aspect. In the uplands, 

permafrost underlies most of the north slopes and most toe slopes of south-facing slopes. The welldrained and relatively warm soils of upland south-aspect slopes are generally permafrost-free with deeper 

and more mineral-dominated soils than those on north aspect slopes. In the lowlands, permafrost underlies 

much of the landscape except major river terraces, alluvial fans, and active floodplains. 

Parent materials from which soils in the planning area form include weathered bedrock, lake sediments, 

glacial deposits, eolian (wind) deposits, alluvium (stream) deposits and volcanic deposits. The upland 

portions of the planning area have generally thin poorly formed soils comprised of coarse colluvium and 

fine alluvial sediments and eolian loess (Oldefelt et al. 2016). Lowland soils are more developed and are 

predominantly comprised of loess, sand and gravelly alluvium derived from mountainous regions with 

large portions of organic matter (USDA 2008). Large areas of wet organics form extensive plains within 

the lowland areas of the planning area specifically in the Yukon and Kuskokwim delta regions. These 

lowlands areas with high organic quotients are less thaw sensitive than their shallow slope counterparts 

due to the insulative properties of the organic matter (Oldefelt et al. 2016) and generally finer-grained 

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sediments. The lower slopes of the more mountainous regions are more likely to exhibit erosion or 

modification because thaw-destabilized soils may freely flow downslope or be washed away by runoff 

(Oldefelt et al. 2016). 

The major soil resource management concerns are soil subsidence, erosion, and thermokarst. Thermokarst 

is a process whereby the thawing of ice-rich permafrost causes subsidence of the overlying soil. This 

process forms steep-walled pits that pockmark the landscape and may fill with meltwater from thawing 

permafrost. In the planning area soils, isolated masses of ground ice occur in deep loess deposits on river 

terraces and lower side slopes of hills. Areas with masses of ground ice or ice-rich permafrost are 

particularly sensitive to development, which may damage the insulating organic materials that overly 

these sensitive soils, and the potential effects of climate change warming these thaw-sensitive soils 

contributing to a potentially rapidly changing thermokarst landscape. Additionally, as these sensitive soils 

thaw, vegetation communities that are intrinsic to the stability of the soils will likely change and promote 

vegetation migration and release of carbon sequestered in these frozen soils (Oldefeldt et al. 2016; 

McGuire et al. 2016). 

Perennially frozen soil also creates many engineering problems. Removal of the insulating surface 

organic layer for these soils causes thawing in the upper part of the permafrost. This is commonly 

accompanied by thermokarst and increased potential for erosion. Roads and structures on these soils may 

settle unevenly. Much of the planning area is affected by discontinuous permafrost. Soils are nearly 

always saturated in summer in the zone above permafrost and wetlands are prevalent. 

2.3.5 Resource Changes: Trends and Forecasts 

Climate change will continue to lead to increased soil temperatures in the planning area, which could in 

turn result in active layer destabilization (permafrost thaw), increased soil and streambank erodibility, and 

increased nutrient cycling and decomposition. The lowland portions of the planning area are extensively 

and intermittently affected by permafrost and their degradation often exhibits a thermokarst landscape. 

The predominant sensitive soils in the planning area are located on lowland areas of the planning area and 

they are the most likely to be affected by permafrost thaw and thermokarst influenced by climate change. 

2.4 Water Resources 

2.4.1 Introduction 

This section describes the regulatory setting and baseline conditions of water resources; including surface 

water, groundwater, and water quality; in the planning area. 

2.4.2 Laws, Regulations, and Policies 

Appropriations Act of 1952, McCarran Amendment. This Amendment waives the United States’

sovereign immunity in suits concerning ownership or management of water rights, as long as they might 

be affected by the result of the suit. It gives others the right to join in such a lawsuit as a defendant. Prior 

to the Amendment, sovereign immunity kept the U.S. from being joined in any suits. The Amendment 

enabled suits concerning federal water rights to be tried in State courts. 

BLM Manual 7200 Series. The following BLM Manuals influence water management decisions in the 

planning area: 

• BLM Manual 1737: Riparian and Wetland Management 

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• BLM Handbook H17412: Water Developments 

• BLM Manual 6521: State Agencies 

CWA. The EPA is responsible for enforcing the federally mandated CWA. The CWA establishes the 

basic structure for regulating discharges of pollutants into waters of the U.S. and for regulating surface 

water quality standards. Regulations pertinent to surface water resources in the project area include: 

• Section 404 of the CWA requires individuals, corporations, tribes, or government agencies 

intending to work in waters of the U.S. to obtain a permit from USACE before initiating any 

regulated activity. The permit process for Section 404 permits is administered by USACE and 

EPA. 

• Section 402 of the CWA authorizes the National Pollution Discharge Elimination System permit 

program, controls water pollution by regulating point sources that discharge pollutants into waters 

of the U.S. The EPA administered the program in Alaska until permitting authority was 

transferred to the State in a phased approach beginning in 2008. 

• Stormwater: Stormwater discharge is caused by runoff from land surfaces and impermeable 

areas such as pavement and rooftops, during rainstorm and snowmelt events. As a result, 

stormwater discharges may contain pollutants that could affect surface water quality. In February 

2015, ADEC began issuing the Multi-Sector General Permit (MSGP) for Storm Water Discharges 

Associated with Industrial Activity. Operators of industrial facilities including mines requiring an 

Alaska Pollutant Discharge Elimination System (APDES) Stormwater Permit are eligible to 

obtain coverage under the 2015-MSGP if their activities are included within one of 29 industrial 

sectors. Permit applicants must submit a notice of intent and a Stormwater Pollution Prevention 

Plan that incorporates best management practices (BMPs). Permits would be issued if the ADEC 

approves the application. 

• Water Quality Protection: The ADEC has adopted the surface water quality standards published 

at 18 AAC 70. The State standards must be approved by the EPA before they can be used for 

actions regulated under the federal CWA. For action under State regulation only, the Alaska 

surface water quality standards may be used exclusively. ADEC Division of Water administers 

groundwater quality standards on behalf of the EPA. Alaska groundwater standards focus on 

protecting groundwater quality through regulation of contaminated sites by the Contaminated 

Sites Program in the Spill Prevention & Response Division. 

• Source Water Protection: Wellhead Protection and Source Water Assessment and Protection are 

national programs funded by EPA designed to help protect and prevent the contamination of 

drinking water sources. Both programs are part of the Safe Drinking Water Act of 1974 and have 

the same goal and mission but were created at different times. The ADEC administers this 

program in Alaska and gives approval to construct and operate public water supply systems; 

performs plan review and construction approval for domestic sewage systems and permits nondomestic wastewater disposal. 

Alaska Surface Coal Mining Control and Reclamation Act (ASCMCRA). The Alaska Department of 

Natural Resources (ADNR), Division of Mining Land and Water (DMLW), administers ASCMCRA and 

implements regulations for coal mining on private and public lands, which must comply with federal 

standards. ASCMCRA establishes a program for the regulation of surface mining activities. All coal 

mining permits including exploration, mining, and reclamation in Alaska must meet ASCMCRA permit 

requirements. These permits have requirements that protect the natural surface water flow and surface 

water quality in the area of the mining activity during operations and after closure. The ADNR is tasked 

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with developing a Cumulative Hydrologic Impact Assessment as part of their permit decision process that 

would be issued as supporting documentation in the permit approval or denial. 

Alaska Water Use Act. ADNR, DMLW, Water Management Unit, issues water rights permits and 

authorizations. There are two kinds of water rights administered: 

• A right to use water, which means taking it from streams, lakes, or underground aquifers, or 

changing the way it flows. Appropriation of a significant amount of water (as defined by 11 AAC 

93.035[a] and [b]) on other than a temporary basis requires authorization by a Water Rights 

Permit. The use has to be a “significant” amount (more than 500 gallons a day for 10 days a year, 

or 5,000 gallons in a single day). 

• A right to reserve water. Reserving water means protecting a specific flow of water, for a specific 

period of time, in sections of streams or rivers, or reserving water to maintain lake levels. The 

most common reason for reserving water is protecting fish and wildlife—their habitat, or 

migration, breeding, and rearing areas. 

A water right is defined as a legal right for the use of public surface and subsurface waters under the 

Alaska Water Use Act (Alaska Statute [AS] 46.15). When a water right is granted, it becomes appurtenant 

to the land where the water is being used for as long as the water is used. If the land is sold, the water 

right transfers with the land to the new owner, unless ADNR approves its separation from the land. 

State and Federal Habitat Regulations. The Alaska Department of Fish and Game (ADF&G) manages 

fisheries resources and their habitat in State waters (AS, Title 16). The Anadromous Fish Act (AS 

16.05.871- .901) requires that an individual or government agency provide prior notification and obtain 

permit approval from ADF&G Division of Habitat before altering or affecting “the natural flow or bed” 

of a specified waterbody, or fish stream. All activities within or across a specified anadromous waterbody 

require approval, including: construction; road crossings; gravel removal; mining; water withdrawals; the 

use of vehicles or equipment in the waterway; stream realignment or diversion; bank stabilization; 

blasting; and the placement, excavation, deposition, or removal of any material. 

The Fishway Act (or Fish Passage Act AS 16.05.841) requires that an individual or government agency 

notify and obtain authorization from the ADF&G, Division of Habitat for activities within or across a 

stream used by fish if it is determined that such uses or activities could represent an impediment to the 

efficient passage of resident or anadromous fish. 

Additionally, the National Marine Fisheries Service (NMFS) manages Essential Fish Habitat (EFH) 

provisions of the Magnuson-Stevens Fishery Conservation and Management Act (MSA), which includes 

freshwater habitat for anadromous fish species. As surface water is the habitat for fish, these agencies also 

regulate aspects of surface water hydrology. 

Pollution Prevention Act of 1990. This created a national policy to have pollution prevented or reduced 

at the source wherever possible. It also expanded the Toxics Release Inventory. 

Classification and Multiple Use Act called for classification of federal lands for retention or disposal 

and for the multiple-use management of the lands that were retained. 

Soil and Water Resource Conservation Act appraises the status and trends of soil, water, and related 

resources on non-federal land and assess their capability to meet present and future demands; evaluates 

current and needed programs, policies, and authorities; and develops a national soil and water 

conservation program to give direction to USDA soil and water conservation activities. 

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Watershed Protection and Flood Control Act of 1954. The Soil Conservation Service at the USDA 

provides planning assistance and construction funding for projects constructed by local sponsors, often in 

the form of flood control districts. 

Wild and Scenic Rivers Act of 1968 was created to preserve certain rivers with outstanding natural, 

cultural, and recreational values in a free-flowing condition for the enjoyment of present and future 

generations. The Act is notable for safeguarding the special character of these rivers, while also 

recognizing the potential for their appropriate use and development. Rivers may be designated by 

Congress or, if designated by a State or States and certain requirements are met, the Secretary of the 

Interior. Each river is administered by either a federal or State agency. Designated segments need not 

include the entire river and may include tributaries. The designated boundaries generally average one-half 

mile on rivers outside national parks in Alaska in order to protect river-related values and do not include 

State or private lands. 

Executive Orders. The following executive orders influence water management decisions in the planning 

area: 

• EO 11288, Prevention, control and abatement of water pollution by federal activities, July 2, 

1966 

• EO 11507, Prevention, control and abatement of air and water pollution at federal facilities, 

February 4, 1970. 

• EO 11514 as amended by Executive Order 11991, Protection and enhancement of environmental 

quality, March 5, 1970. 

• EO 11644, Use of Off-road Vehicles on Public Lands, February 8, 1972 (37 Federal Register 

[FR] 2877). To the extent this is relevant to this section, 43 CFR 36 addresses non-subsistence 

off-highway vehicle (OHV) use on DOI lands in Alaska and, 50 CFR 43 and 36 CFR 13 address 

subsistence OHV use on USFWS and NPS lands in Alaska. 

• EO 11988, Floodplain Management, May 24, 1977 (42 FR 26951). 

• EO 11990, Protection of Wetlands, May 25, 1977 (42 FR 26961). 

• EO 12088, Federal Compliance with Pollution Control Standards, October 13, 1978. 

• EO 12322, Water resources projects, September 17, 1981. 

2.4.3 Resource Indicators 

The conditions that are established in the discussions below provide a baseline for water resources-related 

values, which that the impact analysis will be based on. The following indicators, along with qualitative 

discussions, will be used to evaluate impacts associated with management decisions in the BSWI Draft 

RMP/EIS. 

• River miles and acreages open to surface-disturbing activities 

2.4.4 Current Conditions 

Surface Water 

The planning area encompasses approximately 62 million acres of land and includes all lands south of the 

Central Yukon watershed to the southern boundary of the Kuskokwim River watershed, all lands west of 

Denali National Park and Preserve and the divide of the Alaska Range to the Bering Sea (see BSWI Draft 

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Appendix M: BSWI Affected Environment Report Section 2. Resources 

RMP/EIS, Map 1-2). Major rivers in regard to management within the planning area include the Yukon, 

Kuskokwim, Anvik, and Unalakleet. 

Water quality impacts can be highly seasonal. Within the planning area, runoff containing natural or 

human-caused sediment and/or other pollutants can occur during spring snowmelt and heavy rainfall 

events in summer and fall. Abandoned non-reclaimed placer gold mine operations, active placer mining 

with erosion control-related non-compliance issues, and runoff from wildfire areas can contribute 

additional sediment and other pollutants to local streams during summer. Rivers and streams will often be 

clear running in the winter, albeit at much lower discharge volumes. 

Tributaries of the upper Yukon emanate from glaciated areas and carry heavy natural loads of sediment 

during summer. Except for suspended sediment, water quality is generally good to excellent, with low 

dissolved solids, dissolved oxygen near saturation, and neutral to moderately basic pH. 

Water temperatures during summer are typically less than 14 degrees C (57.2 degrees F). Small streams 

are often frozen to the bed by midwinter, and temperatures in large rivers are close to freezing. Flows in 

larger rivers are usually at a minimum in March and maximum in June, July, or August. Winter flows are 

generally about 20 percent of peak summer flows. Ice on lakes and larger streams is normally about 2 to 

4 feet thick by March. 

Discharge 

According to GIS analysis of the U.S. Geological Survey (USGS) National Hydrography Dataset river 

data sets, there are approximately 27,960 miles of streams and rivers and 63,130 acres of lakes and ponds 

present on BLM-managed public lands in the planning area (BLM 2015a). Timing and duration of flow 

are solely weather dependent, there are no significant artificial barriers to flow, and no impoundments. 

Table 2.4.4-1 lists data on discharge volumes where these data are available. 

Table 2.4.4-1. Approximate Discharge and Water Quality Parameters of Major USGS-Gaged 

Streams in the Planning Area 

Gauge 

Number Site Name Agency 

Mean January 

Discharge 

(cfs) 

Mean June 

Discharge 

(cfs) 

Period of 

Record 

15300100 Bear Creek at Illiamna USGS 6.1 7.8 2005-2017 

15304010 Crooked Creek USGS 55 590 2007-2017 

15304000 Kuskokwim at Crooked Creek USGS 13,300 79,200 1951-2017 

15303900 Kuskokwim at Lisky’s Crossing

Near Stoney River USGS 5,880 25,200 2010-2017 

15565447 Yukon at Pilot Station USGS 62,900 562,000 1978-2017 

15564800 Yukon at Ruby USGS 37,500 476,000 1957-1978 

15565200 Yukon at Kaltag USGS 45,500 645,000 1957-1966 

Source: USGS National Water System Web Interface. Note there are numerous other streams and rivers in the planning area that have not been 

fully measured. January and June results show the range of discharge common in the drainages. 

Water Quality Parameters 

The following is a list of parameter used to measure water quality in the planning area. 

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ADEC 

The water quality standards for the State of Alaska (18 AAC 70) are used to protect, maintain, or improve 

surface water resources in Alaska. Alaska BLM has adopted these water quality standards to protect 

public health and welfare and enhance the quality of the water on public lands within the state. 

BLM Alaska Land Health Standards 

BLM Alaska Land Health Standards (BLM 2004) lists possible water quality indicators as: 

• water temperature 

• dissolved oxygen 

• fecal coliform 

• turbidity 

• pH 

• populations of aquatic organisms 

• effects on beneficial uses (i.e., effects of management activities on beneficial uses as defined 

under the CWA and State regulations) 

• specific conductivity 

• water chemistry, including nutrients and metals 

• total sediment yield including bed load 

• levels of chemicals in bioassays 

• change in trophic status 

The water quality parameters typically measured by BLM and other agency personnel in the field include 

water temperature, dissolved oxygen, pH, specific conductivity, oxidation-reduction potential, and 

turbidity. Changes in these characteristics along a stream reach or over time can help identify changes in 

water quality. 

BLM Assessment, Inventory, and Monitoring Strategy (AIM) 

The Assessment, Inventory, and Monitoring Strategy (AIM) is a national initiative designed to promote 

integrated, cross-program resource inventory, assessment, and monitoring at multiple scales of 

management collecting consistent, comparable, and quantitative monitoring data that can be collected 

once and used many times for multiple reasons across spatial scales. One of the fundamental strategies of 

AIM is to establish core and contingent/supplemental surface water indicators and standardize how they 

are measured. Indicators within the AIM Strategy are outlined in Table 2.4.4-2. 

While not all the indicators on this list are direct measurements of water quality, many are indirect 

measurements, such as the presence of abundant aquatic life indicating the water to be relatively free of 

harmful pollutants. Other indicators that may help assess stream function and health include the 

following: 

• Floodplain connectivity 

• Sinuosity 

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• Riparian vegetation species composition 

• Flow duration 

• Velocity distribution 

• Bedform diversity 

• Flow dynamics 

• Ground water/surface water interaction 

• Sediment transport 

Table 2.4.4-2. Core and contingent aquatic indicators used for Alaska Implementation of the AIMNational Aquatic Monitoring Framework 

Land Health 

Fundamental Indicator Core 

Contingent/ 

Supplemental 

Water quality 

Acidity X 

Salinity X 

Temperature X 

Turbidity X 

Watershed 

function and 

instream habitat 

quality 

Residual pool depth, length and frequency X 

Streambed particle sizes X 

Bank stability and cover X 

Floodplain connectivity X 

Large woody debris X 

Ocular estimate of instream habitat complexity X 

Thalweg depth profile X 

Surveyed cross-sections X 

Biodiversity / 

riparian habitat 

quality 

Macroinvertebrate biological integrity X 

Ocular est. of riparian vegetative cover and structure X 

Canopy cover X 

Fish assemblage composition/presence X 

Notes Indicators are grouped by the BLM's Fundamentals of Land Health. 

Water Quality Impairments 

The water quality in a vast majority of the lakes and rivers in the planning area is in a natural state, and 

any existing impairment is due to natural conditions in the planning area. Numerous factors affect natural 

background levels of contaminants, including erosion and aerial deposition of naturally occurring 

contaminants, such as mercury. In general, turbidity levels are naturally elevated in most Alaska streams 

during high-flow events, regardless of land use. Glacial outwash streams have naturally elevated 

turbidities year-round. 

Sources of human-caused pollution, including sediment affecting water quality, are usually classified as 

point sources or nonpoint sources. Point source pollution originates from a direct source such as permitted 

discharge from water treatment plants or mining operations, or direct runoff from construction projects, 

and is easy to monitor and regulate. Nonpoint source pollution originates from sources that are difficult to 

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Section 2. Resources Appendix M: BSWI Affected Environment Report 

measure or regulate, such as urban runoff, atmospheric deposition of human-caused pollutants, and broad 

areas where vegetation has been removed or severely impacted. 

Land use practices on lands not under BLM management can affect water quality on BLM-managed land. 

Many of the water courses within the planning area flow through private, Native corporation, State, and 

other federally managed lands. In many cases, BLM can only address water quality-related issues that 

arise from activities on BLM-managed land or through cooperative efforts with ADEC and ADNR. 

Since the mid-1990s there has been a gradual and more consistent effort by BLM Alaska to ensure 

compliance with State regulations regarding water management and water quality. It is assumed that 

stricter enforcement of water quality standards for placer mine operations has improved water quality 

(including turbidity) downstream of active mines. Under existing conditions, there are about 38 miles of 

streams within active mining claims. 

CWA Section 303(d) requires monitoring and management of water bodies impaired by pollutants. 

According to Alaska’s Final 2012 Integrated Water Quality Monitoring and Assessment Report (ADEC 

2013), there are two water bodies within the planning area on the impaired Section 303(d). Both are in the 

Aniak Watershed, and exceed water quality standards for antimony, arsenic, and mercury: 

• Red Devil Creek. Red Devil Creek was placed on the 2010 Section 303(d) list for non-attainment 

of the toxic and other deleterious organic and inorganic substances standard for antimony, 

arsenic, and mercury. Sampling and data collected in 1971, 1979, 1988, and 1999 have 

documented exceedances for the metals antimony, arsenic, and mercury (ADEC 2013). The Red 

Devil mine site that is causing this impairment is under consideration for the Superfund National 

Priorities List (NPL) but did not make the NPL in 2011. The BLM began sampling, including 

surface soil, groundwater, sediment and surface water. A record of decision (ROD) is anticipated 

in the near future (BLM 2015a). 

• Kuskokwim River. The Kuskokwim River was placed on the 2010 Section 303(d) list for nonattainment of the toxic and other deleterious organic and inorganic substances standard for 

antimony, arsenic, and mercury (ADEC 2013). Sampling and data collected in 1971, 1979, 1988, 

and 1999 have documented exceedances for the metals antimony, arsenic, and mercury. The Red 

Devil mine site that is causing this impairment is under consideration for NPL but did not make 

the NPL in 2011. A ROD to remediate this problem is expected in the near future (BLM 2015a). 

Groundwater 

Groundwater is an important source of drinking water for communities in the planning area. In addition, 

groundwater maintains stream flow, supporting critical fish habitat. In the summer, the streams and rivers 

may transport heavy loads of glacial silt, making surface water unsuitable for household use. Use of 

groundwater avoids this seasonal problem. About 50 percent of Alaska’s population and 90 percent of the 

state’s rural residents depend primarily on groundwater for public supplies (ADEC 2008).

Unconsolidated sand and gravel deposited as alluvium or glacial outwash form the most productive 

aquifers in the planning area (Map 3.2.4-1 of the BSWI Draft RMP/EIS). In major watersheds these 

deposits comprise thick highly transmissive aquifers that yield large quantities of good quality water to 

wells. In many smaller upland and mountain valleys, limited groundwater is available in alluvium beneath 

permafrost or in unfrozen alluvium beneath or adjacent to riverbeds. The groundwater level generally 

reaches a seasonal low during late winter months, March or April, normally the period of lowest stream 

discharge. Watersheds are shown in Map 3.2.4-2 of the BSWI Draft RMP/EIS. 

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Appendix M: BSWI Affected Environment Report Section 2. Resources 

The presence of permafrost can greatly impact aquifers. Where the permafrost is shallow, groundwater 

can perch near the land surface and promote rapid runoff to streams during break up. Depending on its 

extent, permafrost may also act as a confining unit for aquifers in sub-permafrost aquifers. In such cases, 

natural discharge of water confined beneath the permafrost is possible only through unfrozen zones that 

perforate the permafrost layer (Miller et al. 1999). Factors that locally affect the presence and thickness of 

permafrost include air temperature, soil and rock type, relief, slope aspect (steepness and the direction that 

the slope faces), vegetation, snow cover, and the presence of surface-water bodies or flowing 

groundwater. In the planning area, permafrost is discontinuous. 

Most of the groundwater in unconsolidated deposits is suitable for domestic uses with moderate or 

minimal treatment. Locally, the most common treatment problems in groundwater systems are for 

naturally occurring concentrations of arsenic, antimony, iron, and manganese in excess of the 

recommended federal drinking-water standards (ADEC 2008). Alluvial groundwater is typically a 

calcium bicarbonate or calcium magnesium bicarbonate type and is hard to moderately hard and may 

require treatment for some uses. 

2.4.5 Resources Changes: Trends and Forecasts 

Climate change could alter precipitation patterns, increase evaporation, and alter water quality in the 

planning area. Changes in precipitation could affect the availability of water resources by raising or 

lowering surface water and groundwater levels seasonally or from year to year. Increased or more erratic 

surface water flow would make the water more turbid, thereby decreasing water quality. Increased 

temperatures and vegetation growth would increase the rate of evaporation and evapotranspiration, 

thereby altering the water budget for watersheds in the planning area. Given that many aquifers are 

present below permafrost, aquifers can be impacted by melting of permafrost, either due to surface 

disturbance, or climate change. This could also impact groundwater recharge, storage capacity, 

movement, and discharge in the planning area. 

In view of projected climate warming and increased global demand for fresh water, Alessa et al. (2011) 

noted that Alaska is a relatively water-rich region of the world and its role in future international water 

markets may be significant. They suggest the state’s exceedingly long coastline provides ample locations 

for establishing ice-free export infrastructure that would make it possible to ship water in large quantities. 

At present only a small proportion of the freshwater in the planning area, as well as in Alaska in general, 

has been developed or modified. Substantial water resource development is not expected in the 

reasonably foreseeable future because a majority of the planning area is remote, with little or no road 

access, and no expectation of large-scale industrial development. 

2.5 Fisheries 

2.5.1 Introduction 

The purpose of this section is to describe fisheries resource characteristics of the planning area that could 

be affected by implementing the various management alternatives described in Chapter 2 of the BSWI 

Draft RMP/EIS. The section provides background information on relevant fisheries and fish habitat laws, 

regulations, and policies. Fisheries resource indicators are identified that will be used to evaluate impacts 

associated with management decisions. Fish and fish habitat resources, activities and stressors potentially 

impacting them, and how the resources are projected to change are further discussed. 

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Section 2. Resources Appendix M: BSWI Affected Environment Report 

2.5.2 Laws, Regulations, and Policies 

Several federal and State laws, regulations and statutes directly govern the management of fish, fish 

habitat, and commercial, subsistence, and sport fishing in Alaska. Within the planning area, the State of 

Alaska has primary direct responsibility for the management of fishing seasons, fish harvest allocation, 

fish habitat management, and protection. The BLM manages one subsistence fishing district in the 

Unalakleet drainage and relies on in-season data provided by the ADF&G to determine openings and 

closures. 

Magnuson-Stevens Fishery Conservation and Management Act (MSA) and Essential Fish 

Habitat (EFH) 

The MSA of 1996, as amended by the Sustainable Fisheries Act of 1996 (Public Law 104-267), 

establishes procedures designated to identify, conserve, and enhance EFH for those species regulated 

under a federal Fishery Management Plan (FMP). Section 305(b)(2) of the MSA requires federal agencies 

to consult with the NMFS on all actions or proposed actions authorized, funded, or undertaken by the 

agencies that might adversely affect EFH. 

The EFH Guidelines, 50 CFR 600.05 – 600.930, outline the procedures that federal agencies must follow 

to satisfy MSA consultation requirements. Federal agencies must provide the NMFS with an EFH 

Assessment if the federal action may adversely affect EFH. An EFH Assessment is to include the 

following contents (50 CFR 600.920(e)): (1) a description of the action, (2) an analysis of the potential 

effects of the action on EFH and managed species, (3) the federal agency’s view of the effects of the 

action, and (4) proposed mitigation, if necessary. 

EFH guidelines were set forth by the NMFS to help Fisheries Management Councils fulfill requirements 

of the MSA. Consultation between federal permitting or action agencies and the NMFS Habitat 

Conservation Division is required by the MSA when a federal action agency determines the action it is 

approving may adversely affect EFH designated through FMPs. The MSA also requires that the federal 

permitting or action agency respond to comments made by NMFS. 

EFH is defined as waters and substrate necessary to fish for spawning, breeding, feeding, or growth to 

maturity (50 CFR Part 600). For the purposes of this definition: 

• "waters" means aquatic areas and their associated physical, chemical, and biological properties; 

• "substrate" means sediment, hard bottom, structures underlying the waters, and associated 

biological communities; 

• "necessary" means the habitat required to support a sustainable fishery and healthy ecosystem; 

and 

• "spawning, feeding, and breeding" means to encompass the complete life cycle of a species (50 

CFR 600). 

EFH is designated based on the best available scientific information and the information levels defined by 

the MSA (NMFS 2005) listed below: 

• Level 1 – distribution 

• Level 2 – density or relative abundance 

• Level 3 – growth, reproduction, or survival rates 

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Appendix M: BSWI Affected Environment Report Section 2. Resources 

• Level 4 – production rates 

In the planning area, EFH has been designated under the FMP for Salmon Fisheries in the Exclusive 

Economic Zone off the Coast of Alaska (Salmon FMP). The Salmon FMP has designated all waters 

offshore of Alaska as EFH for all five species of Pacific salmon. The FMP also designates waters 

identified by the ADF&G Catalog of Waters Important for the Spawning, Rearing, or Migration of 

Anadromous Fishes (Anadromous Waters Catalog [AWC]) (Johnson and Litchfield 2016a–c) as 

important for Pacific salmon, as EFH. Salmon EFH in Alaska is based primarily on Level 1 distribution 

information. 

ANILCA 

The significance of the ANILCA to management within the planning area is discussed in detail in other 

sections of this document. In the context of fish management, Section 1314 regarding State management 

authority and Title VIII regarding subsistence are particularly relevant. Title VIII declares that: 

the continuation of the opportunity for subsistence uses by rural residents of Alaska, including 

both Natives and non-Natives, on the public lands and by Alaska Natives on Native lands is 

essential to Native physical, economic, traditional, and cultural existence and to non-Native 

physical, economic, traditional, and social existence. 

Title VIII establishes that non-wasteful subsistence uses of fish and wildlife and other renewable 

resources shall be the priority consumptive uses of all such resources on the public lands of Alaska when 

it is necessary to restrict taking in order to assure the continued viability of a fish or wildlife population or 

the continuation of subsistence uses of such population, the taking of such population for non-wasteful 

subsistence uses shall be given preference on the public lands over other consumptive uses (ANILCA 

section 802); Title VIII also establishes that the Secretary shall permit on the public lands appropriate use 

for subsistence purposes of snowmobiles, motorboats, and other means of surface transportation 

traditionally employed for such purposes by local residents, subject to reasonable regulation (ANILCA 

section 811). Access and reasonable opportunity to harvest fisheries resources must be maintained as the 

preferred use on federally managed lands. Federal management cannot unduly restrict access to, or 

harvest of, subsistence fish resources. 

State of Alaska Fishway Act, AS 16.05.841 

The Fishway Act (AS 16.05.841), requires that all dams or other obstructions constructed below the 

ordinary high water mark (OHWM) in a stream that supports salmon or other fish provide for efficient 

passage of fish. The statute requires submittal of plans and specifications to the Commissioner of the 

ADF&G for review and pre-construction approval. The Commissioner has delegated this authority to the 

Division of Habitat. Upon review of plans and specifications, the Division of Habitat either issues a Fish 

Habitat Permit authorizing the construction and maintenance of the structure or makes recommendations 

for plan modifications to ensure that fish passage will be maintained. Once permitted, all structures must 

be maintained free of obstructions and are required to be supplied with a sufficient amount of water to 

allow for the free passage of fish as long as the structure is present. 

Implementation of AS 16.05.841 is somewhat discretionary in that the Division of Habitat can determine 

a permit is not needed if the activity is unlikely to affect fish passage. Activities subject to review and 

permitting under the statute can include the construction of dams, culverts, bridges, ice bridges, the use of 

fish exclusion intake screens associated with water withdrawals, aspects of placer mining, suction dredge 

mining, and any other mechanized activities that could block fish passage. Activities conducted with hand 

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Section 2. Resources Appendix M: BSWI Affected Environment Report 

tools typically do not require a Fish Habitat Permit. Implementation of AS16.05.841 applies to all lands 

within Alaska regardless of ownership. 

State of Alaska Anadromous Fish Act, AS 16.05.871 

AS 16.05.871(a) of the Anadromous Fish Act requires the Commissioner of the ADF&G to specify the 

portions of streams, rivers, lakes and ponds that are important for the spawning, rearing, or migration of 

anadromous fish. This section of the Act established the creation of and maintenance of the AWC in State 

statute. The statute further establishes that prior to conducting most any mechanized activity below the 

OHWM, and in cases, activities occurring above the OHWM, of a stream section listed in the AWC that 

could affect anadromous fish habitat that applicants must submit complete and detailed plans and 

specifications for their project to the Commissioner for review and approval through issuance of a Fish 

Habitat Permit. The Commissioner has delegated this authority to the Division of Habitat. The review and 

approval process is similar to that described for the Fishway Act. 

The Anadromous Fish Act authorities are much broader than those of the Fishway Act, as they specify the 

proper protection of fish and game (e.g., fish habitat as enumerated by the AWC) in connection with the 

proposed action. Fish passage, as required by the Fishway Act, is the minimum requirement under the 

Anadromous Fish Act. Any mechanized activity that occurs within the OHWM of a listed stream segment 

requires issuance of Fish Habitat Permit under the statute. Unlike the Fishway Act, issuance is not 

discretionary. Examples of activities that require issuance of a Fish Habitat Permit under AS16.05.871 

include any activity that could divert, obstruct, pollute, or change the flow or bed of a specified 

waterbody, the use of wheeled, tracked, or excavating equipment, or log-dragging equipment in the bed of 

a specified waterbody. Fish Habitat Permits issued under the Anadromous Fish Act undergo review 

consistent with the ADF&G Mitigation Policy, which seeks, in order of preference, to avoid, minimize, 

rectify, reduce, and lastly to compensate for unavoidable impacts. Final issued permits are conditioned to 

ensure the proper protection of important anadromous fish habitats. Conditions can be more or less 

stringent, depending on the known cataloged habitat uses. For example, activities occurring within 

documented salmon spawning areas will necessarily be more stringent than those occurring in areas only 

known to be used for summer rearing. Implementation of AS16.05.871 applies to all lands within Alaska 

regardless of ownership. 

State of Alaska Fishing Regulations 

Subsistence, commercial, and sport fishing is regulated by the ADF&G Commercial and Sport Fish 

Divisions under the oversight of the Board of Fisheries. The Board of Fisheries’ main role is to conserve 

and develop the fishery resources of the state. This involves setting seasons, bag limits, methods and 

means for the state’s subsistence, commercial, sport, guided sport, and personal use fisheries, and it also 

involves setting policy and direction for the management of the state’s fishery resources. The Alaska 

Board of Fisheries is charged with making allocative decisions, and the ADF&G is responsible for 

management based on those decisions. The Alaska Board of Fisheries is established under AS 16.05.221 

for the purposes of the conservation and development of the fisheries resources of the state. The Alaska 

Board of Fisheries has the authority to adopt regulations described in AS 16.05.251 including: 

establishing open and closed seasons and areas for taking fish; setting quotas, bag limits, harvest levels 

and limitations for taking fish; and establishing the methods and means for the taking of fish. The Alaska 

Board of Fisheries has authority over the regulations in Title 5 AAC Chapter 1 through Chapter 77. 

Commercial and subsistence fisheries are generally managed in-season by district and sub-district with 

controlled opening and closings. In the planning area, the 2016-2019 Arctic-Yukon-Kuskokwim 

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Appendix M: BSWI Affected Environment Report Section 2. Resources 

Commercial, Subsistence, Personal Use Finfish and Shellfish Fishing Regulations apply (ADF&G 

2016a). Sport fishing regulations for the planning area are in the annual Northern Alaska Sport Fishing 

Regulations Summary, organized by major drainages/geographic region; Kuskokwim-Goodnews 

Drainages, Yukon Drainage, and Northwestern Drainages (ADF&G 2018a). 

Subsistence Fishing 

Subsistence fisheries are managed by the ADF&G in state waters and by the Federal Subsistence Board in 

federal public waters. In the Unalakleet River, upstream of the Chiroskey River, the BLM Field Manager 

is authorized to open the closed area. ADF&G reports are used to manage the openings. 

The State of Alaska defines subsistence uses of wild resources as “noncommercial, customary and 

traditional uses” for a variety of purposes. As defined by AS 16.05.940, these subsistence uses include: 

direct personal or family consumption as food, shelter, fuel, clothing, tools, or transportation, for the 

making and selling of handicraft articles out of nonedible by-products of fish and wildlife resources taken 

for personal or family consumption, and for the customary trade, barter, or sharing for personal or family 

consumption (ADF&G 2016b). 

AS 16.05.258, Subsistence Use and Allocation of Fish and Game, directs the Alaska Board of Fisheries to 

identify fish stocks that support subsistence fisheries and, if there is a harvestable surplus of these stocks, 

adopt regulations that provide reasonable opportunities for these subsistence uses to take place. Whenever 

it is necessary to restrict harvests, subsistence fisheries have a preference over other uses of the stock. 

2.5.3 100-Year Floodplain 

The 100-year floodplain is the area inundated by the 100-year flood or the 1 percent annual exceedance 

probability flood. It is the flood event that has a 1 percent chance of being equaled or exceeded in any 

single year. It is often mistakenly thought of as the flood that occurs every 100 years. In actuality, if one 

has a project located within the 100-year floodplain and the project life is expected to be 30 years, it 

would have a 25 percent chance of experiencing flood damage due to a 100-year flood. For a project with 

an anticipated life of 15 years, the chance of incurring flood damage due to a 100-year flood would be 14 

percent. 

The 100-year floodplain is difficult to accurately map without extensive ground surveys. On-the-ground 

surveys conducted within the Central Yukon planning area typically employ the Freeboard Approach, 

which is based on the current 1 percent annual chance flood elevation, with the addition of freeboard to 

account for uncertainties in future conditions (see Guidelines of Implementing EO 11988, Floodplain 

management; October 2015) to determine the horizontal floodplain. With this approach, the BLM uses 

three times maximum bankfull depth as an estimate of the 100-year floodplain. 

Given the difficulty of remotely mapping the 100-year floodplain and the desire to convey the intent of 

the various management alternatives to the reader, riparian buffer distances are used in this report as 

proxies for the 100-year floodplain. Buffer distances are given as a distance from bankfull elevation and 

are dependent on stream order. Buffer distances apply to each side of the stream, as follows: 

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Section 2. Resources Appendix M: BSWI Affected Environment Report 

Stream Order Buffer Distance (feet) 

1st and 2nd 100 

3rd 500 

4th and 5th 1,000 

6th, 7th, and 8th 1,500 

2.5.4 Resource Indicators 

The conditions that are established in the discussion below provide a baseline for fisheries-related values, 

which the impact analysis will be based on. The following indicators, along with qualitative discussions, 

will be used to evaluate impacts associated with management decisions outlined in the BSWI Draft 

RMP/EIS. 

• Stream miles right-of-way (ROW) open, avoidance, or exclusion areas 

• Waterbodies acreage within ROW open, avoidance, or exclusion areas 

• Stream miles within commercial woodlands closed, permittable, and permitted for harvesting 

• Waterbodies acreage within commercial woodlands closed, permittable, and permitted for 

harvesting 

• Stream miles within areas open and closed to grazing 

• Waterbodies acreage within areas open and closed to grazing 

• Acres open to locatable, salable, and leasable minerals 

• Linear miles of potential stream/acres of potential pond/lake habitat potentially affected 

• Linear miles of documented anadromous stream/acres of documented anadromous pond/lake 

habitat potentially affected, including all documented anadromous fish spawning habitats 

potentially affected 

• Acres of designated Areas of Critical Environmental Concern (ACECs) 

2.5.5 Current Conditions 

Habitat and Fish Resources 

There are approximately 133,853 miles of streams and rivers and 3.91 million acres of lakes and ponds 

within the planning area, and 17,962 miles of streams and 414,967 acres of lakes and ponds have been 

cataloged as important for the spawning, rearing and migration of anadromous fish (Johnson and 

Litchfield 2016 a–c). Of the habitats cataloged in the AWC within the planning area, there are 

approximately 5,248 miles of streams and rivers and 287,550 acres of lakes and ponds designated as EFH 

for Pacific salmon. Approximately 23 percent (30,507 miles) of all streams and 1.4 percent (53,796 acres) 

of pond/lake habitats in the planning area occur on BLM-managed public lands. Similarly, about 

22 percent (3,997 miles) of anadromous streams, less than 1 percent (34 acres) of anadromous lakes and 

ponds, less than 24 percent (3,950 miles) of EFH streams and less than 1 percent (34 acres) of EFH lakes 

and ponds cataloged in the AWC are on BLM-managed public lands in the planning area (see 

Maps 3.2.5-1 and 3.2.5-2 of the BSWI Draft RMP/EIS). However, it is recognized that the AWC is only a 

subset of actual important anadromous fish habitats as the AWC reflects the extent of salmon documented 

through fish surveys, and not necessarily the actual limits of salmon habitat. It is estimated that 

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potentially half of the anadromous waters habitat in the state have not been documented (ADF&G 2013a). 

It is certain that additional important anadromous habitats remain undocumented. 

Currently, there is a lack of comprehensive information about adult salmon stock population structure, 

abundance, timing, distribution, and critical habitats on much of the BLM-managed public lands in the 

planning area. Many of the miles of streams and rivers not documented as anadromous waters have been 

shown to have resident fish in the ADF&G Alaska Freshwater Fish Inventory, which maps freshwater 

fish locations. While surveys have not been conducted to identify their presence, it is highly likely that 

fish are present in many more areas. In addition to streams and rivers, there are many lakes, sloughs, and 

other off-channel habitats in the planning area that support resident fish species. Few population surveys 

or critical habitats have been identified for non-anadromous fish on BLM-managed public lands in the 

planning area. 

The planning area is composed of three watersheds: the Unalakleet, Kuskokwim, and lower portion of the 

Yukon Rivers. The Unalakleet River drainage within the planning area has approximately 8,145 miles of 

stream habitat, 887 miles of documented anadromous stream habitat and 292 miles of documented 

anadromous fish spawning habitat, which includes 849 miles of pacific salmon stream EFH and 292 miles 

of stream spawning EFH (BSWI Draft RMP/EIS, Map 3.2.5-1 and 3.2.5-2; Johnson and Litchfield 

2016c). The drainage also has 26,920 acres of lake and pond habitat including 306 acres of documented 

anadromous fish habitat, none of which has been documented as important for spawning. Within the 

Unalakleet River drainage 6,022 miles of stream habitat, 603 miles of anadromous stream habitat and 163 

miles of documented spawning habitat occur within BLM-managed public lands. While 4,270 acres of 

lake and pond habitat is located on BLM-managed public lands within the planning area, none have been 

documented as anadromous fish habitat. Of the BLM-managed land, 567 miles of stream EFH and 163 

miles of stream spawning EFH are documented. The Unalakleet River drainage is used for spawning and 

rearing by all five Pacific salmon species, whitefish (predominantly least cisco and resident round 

whitefish), and a variety of other resident fish species. 

The Yukon River drainage within the planning area has 53,173 miles of stream habitat, 6,724 miles of 

documented anadromous stream habitat, including 2,039 miles of known anadromous fish spawning 

habitat, 6,557 miles of stream EFH and 2,039 miles of stream spawning EFH (BSWI Draft RMP/EIS, 

Map 3.2.5-1 and 3.2.5-2; Johnson and Litchfield 2016a, 2016b). The drainage also has 1.45 million acres 

of lake and pond habitat including 57,055 acres of documented anadromous fish habitat including 107 

acres of lacustrine spawning habitat. Within the Yukon River drainage 14,363 miles of stream habitat, 

1,953 miles of anadromous stream habitat, and 977 miles of spawning habitat occur within BLMmanaged public lands. Similarly, 27,038 acres of lake and pond habitats, 40 acres of which are 

anadromous habitats occur within BLM-managed public lands; no lacustrine anadromous spawning 

habitats are currently identified on BLM-managed public lands within the Yukon drainage. Of the BLMmanaged land, 1,942 miles of stream EFH and 977 miles of stream spawning EFH are documented. The 

Yukon River drainage is used for spawning and/or rearing by all five Pacific salmon species, sheefish, 

broad whitefish, humpback whitefish, least and Bering cisco, and lamprey, as well as resident fish 

species. 

The Kuskokwim River drainage within the planning area has 72,477 miles of stream habitat, 10,350 miles 

of which are documented as anadromous stream habitat, including 2,039 miles of known anadromous fish 

spawning habitat, 1,441 miles of stream EFH and 350 miles of stream spawning EFH (BSWI Draft 

RMP/EIS, Map 3.2.5-1 and 3.2.5-2; Johnson and Litchfield 2016a, 2016b). The drainage also has 2.43 

million acres of lake and pond habitat including 357,606 acres of documented anadromous fish habitat of 

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which 24,902 acres is documented lacustrine spawning habitat. Within the Kuskokwim River drainage 

10,122 miles of stream habitat, with 1,441 miles of anadromous stream habitat, and 359 miles of 

documented anadromous fish spawning habitat occur within BLM-managed public lands. Similarly, 

22,488 acres of lake and pond habitats occur within BLM-managed public lands, however only 0.4 acres 

are documented as important anadromous fish habitat. Of the BLM-managed land, 1,441 miles of stream 

EFH and 350 miles of stream spawning EFH are documented, while no lacustrine EFH is documented. 

The Kuskokwim River drainage is used for spawning and/or rearing by all five Pacific salmon, whitefish, 

lamprey, and rainbow smelt. The only known spawning area for rainbow smelt in the Kuskokwim River 

occurs within the planning area near Upper and Lower Kalskag but is outside of BLM-managed public 

lands. Significant whitefish spawning areas are identified in the Swift River area and specifically for 

sheefish in the Big River drainage. 

Native fish species are widely distributed throughout the planning area and occur in a wide variety of 

habitats. Forty native species, including nearshore marine fish, are known to be supported by the planning 

area (USFWS 2004). Twenty-eight freshwater fish species occur within the planning area, possibly 

including two BLM sensitive species, Alaskan brook lamprey and Arctic char (Table 2.5.5-1). All five 

Pacific salmon occur within the planning area and EFH is identified for each species in the State of 

Alaska AWC. In addition to Pacific salmon, eight additional anadromous fish species are present within 

the freshwaters of the planning area: Pacific lamprey, broad whitefish, humpback whitefish, least cisco, 

Bering cisco, sheefish, Dolly Varden, and rainbow smelt (Table 2.5.5-1). Table 2.5.5-2 provides 

approximate sensitive periods of the year for select subsistence and commercially important fish species 

in the planning area. 

Important salmon fisheries are based in the rivers of the planning area. Fish species in the planning area 

may be described by four general groupings all of which can overlap in use. These include: subsistence, 

commercial, sport, and forage. In rural Alaska, subsistence fish species are extremely important for both 

diet and culture. Fish caught for subsistence include all five Pacific salmon species (Chinook, chum, pink, 

sockeye, and coho salmon), and non-salmon species such as whitefish, sheefish, burbot (also known as 

lush), northern pike, Alaska blackfish, Dolly Varden, rainbow trout, rainbow smelt, and Arctic lamprey. 

There is a commercial fishery for chum, sockeye, pink, and coho salmon and also a commercial fishery 

for Bering cisco and Arctic lamprey within the planning area, but not in habitats managed by the BLM. 

Sport fish species include Arctic grayling, northern pike, burbot, rainbow trout, Dolly Varden, sheefish, 

and salmon. Forage species are important prey for other species and include longnose suckers, slimy 

sculpin, lake chub, and ninespine stickleback. 

Table 2.5.5-1. Fish Species Present in Freshwater Habitats of the Planning Area 

Family Scientific Name Common Name Native 

Esocidae Esox lucius northern pike x 

Catostomidae Catostomus longnose sucker x 

Cottidae Cottus cognatus slimy sculpin x 

Cyprinidae Couesius plumbeus lake chub x 

Gasterosteidae Pungitius ninespine stickleback x 

Lotidae Lota burbot x 

Lampetra japonica Arctic lamprey x 

Petromyzontidae Lampetra alaskense1 Alaskan brook lamprey x 

Lampetra tridentate Pacific lamprey x 

Percopsidae Percopsis omiscomaycus trout-perch x 

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Family Scientific Name Common Name Native 

Osmeridae Osmerus mordax3 rainbow smelt x 

Hypomesus olidus pond smelt x 

Salmonidae 3 Coregonus nasus broad whitefish x 

Coregonus pidschian3 humpback whitefish x 

Coregonus laurettae3 Bering cisco x 

Coregonus sardinella3 least cisco x 

Prosopium cylindraceum round whitefish x 

Stenodus leucichthys3 sheefish/inconnu x 

Oncorhynchus gorbuscha2,3 pink salmon x 

Oncorhynchus keta2,3 chum salmon x 

Oncorhynchus kisutch2,3 coho salmon x 

Oncorhynchus nerka2,3 sockeye salmon x 

Oncorhynchus tshawytscha2,3 Chinook salmon x 

Oncorhynchus mykiss rainbow trout x 

Salvelinus namaycush lake trout x 

Salvelinus alpinus1 Arctic char x 

Salvelinus malma3 Dolly Varden x 

Thymallus arcticus Arctic grayling x 

Umbridae Dallia pectoralis Alaska blackfish x 

1

BLM sensitive species, possible – not documented as present. 2EFH species 

3State of Alaska anadromous species. 

Table 2.5.5-2. Dates of Critical Activity for Important Subsistence, Commercial, and Sport Fish 

Species in the Planning Area 

Species Crucial Season Approximate Dates 

Arctic grayling spawning May–June 

egg incubation May–July 

Burbot spawning February – March 

egg incubation February – April 

Chinook salmon spawning July–August 

egg incubation July–February 

Coho salmon spawning August–October 

egg incubation August–March 

Chum salmon spawning July–August 

egg incubation July–April 

Rainbow smelt spawning May 

egg incubation May – mid-June 

Northern pike spawning May–June 

egg incubation May–July 

Whitefish species spawning September–November 

egg incubation September–March 

Chinook Salmon 

The Alaska Board of Fisheries listed Yukon River Chinook salmon as a stock of yield concern in 2000, 

according to guidelines set forth in the Policy for the Management of Sustainable Salmon Fisheries (5 

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AAC 39.222). Continued in 2007, this designation is based on the inability to maintain expected yields, or 

harvestable surpluses, above the stock’s escapement needs, despite the use of specific management 

measures. Unalakleet River Chinook salmon were also listed as a stock of yield concern in 2004 (Kent 

and Bergstrom 2009). 

Social and economic hardship for many communities in rural and urban Alaska has been created because 

of a statewide downturn in productivity and abundance of Chinook salmon, which are crucially important 

to subsistence, commercial, and sport users across diverse fisheries in Alaska (ADF&G 2013a). 

Coho Salmon 

Although their distribution in portions of the Yukon and Kuskokwim Rivers are not as well understood as 

that of Chinook or chum salmon, coho salmon have been documented throughout the planning area, and 

spawning populations are well-documented in the Unalakleet River drainage of the Kuskokwim and much 

of the Yukon. 

Although not as abundant as chum salmon in the Yukon River drainage, coho salmon are an important 

subsistence resource. There are commercial fisheries for coho salmon in all three watersheds inside the 

planning area, as well as a small commercial fishery for coho salmon outside the planning area in the 

upper Yukon River and Tanana River. However, the harvest of coho salmon is constrained because of the 

stock of concern status for fall chum salmon, which have overlapping run times and are susceptible to 

similar types of fishing gear on the Yukon River. 

Chum Salmon 

Chum salmon have the widest distribution of Pacific salmon species: in North America, they range from 

California to Alaska (Hale et al. 1985). Within this range, the Yukon River is the greatest producer of 

chum salmon (Morrow 1980). In addition to contributing to an important commercial fishery, chum 

salmon in the planning area are widely used for subsistence purposes. The Yukon River has distinct 

summer and fall chum salmon runs, with summer chum salmon entering the river in June, and fall chum 

salmon entering the river in late June or July. While summer chum salmon are primarily used as a food 

source for dogs, fall chum salmon tend to have a higher oil content, and are generally of higher quality 

(Morrow 1980). Summer chum salmon generally spawn in the lower part of the Yukon River drainage, 

with over half the summer chum salmon spawning in the Anvik River. 

In 2000, under the State of Alaska Policy for the Management of Sustainable Salmon Fisheries (5 AAC 

39.222), Yukon River summer and fall chum salmon were designated as stocks of concern. For their 

failure to produce an expected harvestable surplus, fall chum salmon were considered stock of yield 

concerns. While this designation was continued in 2004, based on estimates of fall chum salmon run sizes 

that were at or above average between 2003 and 2006, it was discontinued in 2007. 

Arctic Grayling 

Once found in many parts of the northern United States, Arctic grayling have almost disappeared from 

many areas due to habitat loss, overfishing, and competition from nonnative species (ADF&G 2007a); 

however, in Alaska they are widespread, and are present throughout the planning area. Arctic grayling 

generally remain in freshwater throughout their lifecycle and are popular sport fish. The preferred habitats 

for Arctic grayling are clear waters of large rivers, rocky streams, and lakes (Mecklenburg et al. 2002). 

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Whitefish 

Inhabiting nearly all rivers and other freshwater habitats in the planning area, whitefish are the most 

abundant type of fish north of the Alaska Range (ADF&G 2007a). Common whitefish in the planning 

area include round-, broad-, and humpback whitefish; least- and Bering cisco; and sheefish. Round- and 

humpback whitefish and ciscoes provide some sport fishing opportunities; while sheefish are the most 

sought-after sport fish of the whitefishes in the planning area. Sheefish, broad whitefish, humpback 

whitefish, and ciscoes are important subsistence resources. There is a small commercial fishery for Bering 

cisco in the lower Yukon River. 

Northern Pike 

Found in waters throughout the planning area, northern pike are an important subsistence and sport fish 

resource. Spending the winter in relatively deep waters in rivers and lakes, northern pike move into 

marshy off-channel habitats in the spring and early summer to spawn. Fish begin spawning during the 

spring of their third year (Cheney 1971). Eggs hatch within 4 weeks of spawning, and the fry feed on 

zooplankton and aquatic insects until they reach a size of 2 inches (5 centimeters), at which point the fry 

shift to a fish diet (Morrow 1980). 

Distribution – Kuskokwim Watershed 

Sheefish, broad and humpback whitefish are culturally significant species along the Kuskokwim River 

and throughout much of the watershed, they are harvested for subsistence use by residents of many 

communities up and down the entire river and throughout the whitefish annual cycle. Whitefish are 

harvested on their wintering areas in the lower estuarine portion of the Kuskokwim, in spring and summer 

in both pre-migration foraging areas and as migrants in the main river, during fall spawning along the 

middle and upper river, and during their late fall downriver migration. Whitefish are often caught before 

salmon in the spring and offer an opportunity for fresh fish early in the season. In recent years, Chinook 

salmon have been in decline and there has been a resulting increase in harvest of whitefish and other 

salmon species. This trend has been particularly significant in the last couple of years during which early 

season subsistence fishing on the Kuskokwim River was restricted to the use of small-mesh “whitefish” 

nets. Even prior to the recent decline of Chinook salmon, however, whitefish were a consistently 

important component of the Kuskokwim River subsistence harvest, comprising between a quarter to 

nearly 60 percent of the annual non-salmon subsistence harvest (Harper et al. 2012). 

Whitefish spawning areas are limited in the Kuskokwim watershed. The proposed Sheefish Spawning 

ACEC (BLM 2018b) includes the most important of only four known humpback whitefish spawning 

areas, and one of only two broad whitefish spawning areas (Harper et al. 2012; BLM 2018b) (BSWI Draft 

RMP/EIS, Map 3.4.1-2). About 80 percent of sheefish radiotagged in the Kuskokwim River drainage in a 

study conducted by the ADF&G were relocated in a 15.5-mile reach of the Big River during spawning, 

suggesting the area is of particular significance to sheefish (Stuby 2012). Other sheefish were relocated in 

shorter stretches of the Middle and South Fork Kuskokwim River during the spawning period (Stuby 

2012). Of those important spawning habitats, approximately 3 miles of habitat occur on BLM managed 

lands. 

While the AWC does not identify the Swift River as important whitefish spawning habitat, Harper et al. 

(2012) reports “The Swift River spawning area is probably the most important area thus far identified for 

humpback whitefish in the Kuskokwim River drainage based upon the spawning destination of radiotagged fish” (Harper et al. 2012). The whitefish species that spawn in the Swift River have been 

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documented to overwinter and feed in the lower reaches of the Kuskokwim River, indicating they move 

over 500 miles from the lower Kuskokwim River to the Swift River to spawn. There are approximately 

18 subsistence communities between the Swift River and the lower reach of the Kuskokwim River that 

utilized these fish. In addition, the telemetry work confirmed that fish spawning within the Swift River 

did indeed migrate downstream into the lower Kuskokwim River to overwinter and are harvested 

throughout the river as an important subsistence resource. Because these populations occur along 

hundreds of miles of the Kuskokwim River over the course of their annual cycles, from the upper river to 

the tidally influenced lower river, they are considered spawning habitats. Spawning areas include the 

lower reaches of the Holitna River (south of Itulilik) and its tributaries, which include the Chuckowan and 

Kogrukluk Rivers and Shotgun Creek. Further south and west there are whitefish spawning areas within 

the Hoholitna River to White Lake and the South Fork tributary of the Hoholitana River. There are also 

several whitefish spawning areas within the lower Kuskokwim watershed including south of Bethel, 

Nimgum Creek is also shown as another area for whitefish spawning. 

Factors Impacting Fisheries Resources 

Habitat Disruption 

The major activities that are affecting, or are likely to affect, fish habitat and aquatic productivity within 

the planning area are activities with the potential to cause surface disturbances near water bodies and 

activities that occur within waterbodies. Major activities that occur within the planning area that have the 

highest potential to affect fish production include placer mining, hard rock mining, and gravel mining 

within or near important fish habitats; timber harvests near important fish habitats; and stream crossings 

of roads, trails, and utility corridors in important fish habitats. Stream crossings with potential to impact 

fish production include road crossings with culverts and bridges, ice bridges, fords with heavy equipment 

and light-duty equipment including OHVs, and trench-buried utility crossings. Activities and stream 

crossings that occur within particularly sensitive habitats such as spawning and overwintering habitats, or 

those that could preclude or inhibit access to those habitats, have the highest potential to impact fish 

productivity. 

Human activity has been minimal in the majority of the watersheds in the planning area and most riparian 

and stream habitats are in natural condition. However, placer mining at Tuluksak, the upper Innoko River 

drainage, the Ophir mining area, and Iditarod/Flat Mining Districts and other placer mines throughout the 

planning area have likely affected fish habitat. No studies have been identified within the planning area 

that quantify the impacts to fish and aquatic habitats. While outside the planning area, streams impacted 

by placer mining during the early 1980s gold rush in Interior Alaska, the Birch and Chatanika River 

drainages were found to be in poorer overall condition with significantly reduced riparian habitat and 

invertebrate productivity (Weber and Post 1985; Weber 1986; Townsend 1987). Mined streams exhibited 

high turbidity, high suspended solids, and increased erosion and substrate embeddedness when compared 

to reference streams in the drainages (Weber and Post 1985; Weber 1986; Townsend 1987). There were 

cases in the Birch Creek drainage where historically present fish populations in streams affected by placer 

mining had been reduced or entirely displaced (Weber and Post 1985). In the mid-1980s, a collaborative 

approach involving multiple State agencies and miners was undertaken and best practices were designed 

and implemented, resulting in an immediate reduction in suspended solids in the upper Chatanika River 

drainage (Townsend 1987). Variable success has been seen in active restoration efforts in reestablishing 

viable fish habitats and populations in Alaska. Restoration success has been largely related to the 

complexity of the rehabilitation goals (Parry et al. 1993). Parry et al. (1993) found that 47 percent of 

restoration projects were successful in meeting their restoration goals, while about 20 percent were either 

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partially successful or unsuccessful. The remainder of projects reviewed had either uncertain outcomes or 

were still too early in the process to determine success. They found that projects focused on creating 

salmon spawning habitats were most variable in terms of a successful long-term outcome. 

There are 765 rivers and streams in the planning area. The water quality in a vast majority of the lakes 

and rivers in the planning area are unperturbed and represent natural conditions. Any existing 

impairments in these unperturbed waters are due to natural conditions in the planning area. The following 

exceptions exist to this general rule (ADEC 2013; BLM 2015a): 

• Red Devil Creek was placed on the 2010 Section 303(d) list for non-attainment of the toxic and 

other deleterious organic and inorganic substances standard for antimony, arsenic, and mercury. 

Water quality and sediment are impacted by the presence of processed tailings left in place by 

past mining activity. Sampling and data collected sporadically since 1971 and regularly since 

2010 have documented exceedances for antimony, arsenic, and mercury adjacent to mine 

workings but concentrations of all three metals meet ambient water quality standards at the mouth 

of the creek (where it discharges into the Kuskokwim River). The BLM initiated a 

Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA) 

investigation/feasibility study of the mine site and adjacent reach of the Kuskokwim River in 

2010. It is anticipated that future cleanup action will address the processed tailings and impacted 

soil and sediment. 

• Gray et al. (2000) conducted a study near the Red Devil Mine site to evaluate the effects of 

abandoned mercury mines on fish and the aquatic ecosystem. Fish tissue samples from Arctic 

grayling (Thymallus arcticus) and Dolly Varden (Salvelinus malma) collected downstream from 

mercury mines, including the Red Devil Mine, on the Kuskokwim River contained as much as 

420 and 620 nanograms per gram mercury (wet weight muscle). These concentrations were 

several times higher than that in fish collected from regional baseline sites. Gray et al. (2000) 

concluded that elevated mercury concentrations in freshwater fish collected near abandoned 

mercury mines indicate that some biologically available mercury is bioaccumulated; however, the 

sample size (n=8) was limited and did not include top-predatory species more susceptible to 

methylmercury bioaccumulation, such as northern pike. 

• The Kuskokwim River was placed on the 2010 Section 303(d) list for non-attainment of the toxic 

and other deleterious organic and inorganic substances standard for antimony, arsenic, and 

mercury. The section of the Kuskokwim River placed on the Section 303(d) list is adjacent to the 

Red Devil Mine and is a direct result of sediment sampling and analysis conducted as part of the 

CERCLA investigation. Water quality in this section of the Kuskokwim River has not been 

shown to be impacted by contaminants migrating from the mine site. The middle Kuskokwim 

River runs through a highly mineralized region of Alaska that contains mercury, antimony, gold, 

silver, and polymetallic deposits (Szumigala and Swainbank 1998). This area is referred to as 

Alaska’s “mercury belt” because of the numerous mercury mineral deposits and mines in the 

watershed (Gray et al. 2000). Two hundred twenty-eight of the 332 cinnabar (mercury sulfide) 

locations in Alaska are within the Yukon-Kuskokwim region; 82 of these have been mined. 

Elemental mercury, or quicksilver, was produced from eight mines at five locations along the 

Kuskokwim River, including the Alice and Bessie (or Parks), Kolmakof, Cinnabar Creek, Lucky 

Day, and Red Devil mines. The Red Devil Mine, abandoned in 1971, was the largest, but 

Cinnabar Creek also produced substantial amounts of mercury (Sainsbury and MacKevett 1965). 

Remnant waste rock and processed ore are still present from early and mid-twentieth century 

mines (USGS 2003). Recent efforts by the BLM to establish a baseline condition of several 

different metals in fish tissue, including mercury and methyl mercury (MeHg; the most toxic 

form), along a roughly 270-mile stretch of the Kuskokwim River and selected tributaries between 

the Aniak and Takotna Rivers has provided significant insight regarding key fish species 

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movement patterns and the identification of areas causing the greatest exposure to metals, 

including mercury (BLM 2016b). While it is clear that the mineralized region of the Kuskokwim 

River basin contributes significantly a variety of metals detected in the aquatic environment, 

including mercury; it is unclear what role the many mined areas within the basin contribute 

regarding the levels of metals at the larger river scale. A supplemental investigation and 

feasibility study conducted by the BLM in 2016-2017 quantifies the environmental risk to human 

health and the environment attributable to tailings in Kuskokwim River sediment that originated 

on the Red Devil Mine site. 

• In 2010, BLM and ADF&G sampled several hundred fish from the middle Kuskokwim River and 

eight tributaries. Sampling included both forage fish species and top-predatory fish, such as 

northern pike and burbot. These sampled were analyzed for 19 metals, including mercury, and the 

data are currently being analyzed by a USFWS Toxicologist. Preliminary results indicate a 

similar pattern of contamination as samples collected in the lower Kuskokwim and Yukon Rivers 

during the last decade with larger, older fish exhibiting higher concentrations than smaller, 

younger fish. These data also indicated that top-predatory fish species had higher concentrations 

in the two major tributaries, the Holitna and George Rivers, compared to the middle Kuskokwim 

River samples. Preliminary results also indicated that forage fish collected from Red Devil Creek 

had increased concentrations of mercury compared to other sampled tributaries. 

• The upper 81 river miles of the Unalakleet River was designated as “Wild” by ANILCA. When 

this river was designated as a component of the National Wild and Scenic (WSR) System 

(National System), Congress intended that it would be preserved in a free-flowing condition, and 

that the river and its immediate environment would be protected for the benefit and enjoyment of 

present and future generations. 

Placer mining typically involves stripping vegetation and topsoil and often rerouting streams into 

temporary or permanent bypass channels to reach gold or desired metals in the streambed gravels (Yeend 

et al. 1998). Due to gold-bearing gravels often being associated with the historic stream beds, mining the 

gold resource requires disturbing the benches and lowlands connected by stream valleys. This disturbance 

can lead to increased erosion of stream banks and stream beds, which in turn can increase turbidity and 

suspended solids, as well as increase substrate embeddedness. High suspended and total sediment load 

can persist for many years because revegetation may be slowed by stripping of the overburden, lack of 

organic material in mine waste (tailings) piles, and lack of stream channels during high flows in 

unconsolidated tailings piles (Kennedy and Langley 2007). Of the 6,618 mining claims currently within 

the planning area, 219 are under federal management (Kurtak et al. 2010). As of December 2016, there 

are four active placer mines, one active lode mine, and two temporary placer mine closures on BLMmanaged lands in the planning area. The number of active and temporarily closed mines changes 

annually. 

Increased substrate embeddedness and turbidity, resulting from active and abandoned mining claims, both 

directly and indirectly impact fish populations. Reynolds et al. (1989) reported that decreased survival of 

Arctic grayling fry and juveniles in Birch Creek resulted from the loss of interstitial space in the stream 

bed due to siltation. However, indirect effects of mining, such as loss of summer feeding and reproduction 

habitat, may have more severe effects on Arctic grayling and other fish species populations than direct 

effects (Reynolds et al. 1989). While Birch Creek is outside of the planning area, the situation is 

applicable to the current area of interest and represents potential affects from unregulated mining activity. 

Development of material sources and placer mining within floodplains could have a variety of effects on 

fish and habitat. Material extraction sites studied in Arctic and Subarctic floodplains in Alaska have 

demonstrated adverse and some beneficial effects on fish and fish habitat (Joyce et al. 1980; Ott et al. 

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2014). The effects of gravel extraction from floodplains on fish and fish habitat is dependent on many 

factors including the type and size of the river, method of material extraction employed, and the amount 

of material extracted. Material site development can lead to destabilization of river channels, river 

channel capture, floodplain widening, increased erosion and sedimentation, increased water velocities, 

reduced water quality, and can lead to aquatic habitat shifts. In some instances, material site development 

has been documented to cause surface flows into the gravels creating a barrier to fish passage (Joyce et al. 

1980). Fish habitat changes then lead to changes in fish distributions in terms of fish species and age class 

distributions within the altered habitats. Material sites that alter the hydrologic regime of a stream can 

have long-term deleterious effects on fish and their habitats (Joyce et al. 1980). The study by Joyce et al. 

(1980) determined that active channel mining should be avoided as much as possible, particularly when 

important spawning or wintering habitats are nearby. Fish entrapment potential was also documented 

where extraction sites left depressions in floodplains that were flooded at high water and then became 

isolated as water levels dropped. However, Joyce et al. (1980) did identify configurations, which could 

produce habitat enhancements and minimize the potential for stream altering processes to be initiated, 

such as specific gravel mining methods of floodplain features, limitations of gravel removed specific to 

stream type and size, and location of removal sites. Furthermore, the AWC does not consider the value of 

contributing headwater streams to the productivity and health of anadromous sections of stream further 

down in the watershed. Implementation of the guidelines identified has led to benefits to local fish 

populations, including the creation of wintering habitats and productive feeding habitats. 

Ott et al. (2014) summarizes fish use of several gravel mine sites on Alaska’s North Slope, most 

constructed as pits that were subsequently connected to nearby drainages. They noted that rehabilitated 

gravel mining sites connected to small streams often provide the only overwintering habitat in the 

drainage for fish and that those connected even to larger drainages can provide an appreciable increase in 

available naturally occurring overwintering habitat that are often limited to a small number of deepwater 

pools. Gravel mine sites developed on the North Slope since the mid-1990s have been designed with 

primary rehabilitation goals, when practicable, to provide for fish overwintering, but also to provide 

shallow water habitats to foster both productivity and enhanced overwintering habitat. The concepts 

presented by Joyce et al. and Ott et al. could be applied to reclamation activities outside of material source 

development including placer mine reclamation. 

Timber harvest activities have the potential to destabilize soils within drainages and reduce the function 

of riparian zones along streams. These activities can increase stream temperatures, turbidity, total 

suspended solids, increase substrate embeddedness, and generally lead to decreased stream function and 

fish productivity. Affects are scale- and location-dependent with larger scale harvests having higher 

potential for impacts to fish than smaller scale personal-use firewood cutting. Harvest locations near 

particularly sensitive fish habitats, such as spawning and overwintering habitats, can have the highest 

potential to impact fish survival. Road/equipment stream crossings including ice bridge construction can 

also affect fish survival and habitats by directly compromising spawning and overwintering habitats, or 

by affecting access to those important habitats as described below for stream crossings. 

Stream crossings of roads and trails can impede the free and efficient passage of fish and can, in some 

cases, lead to increased erosion, sedimentation, substrate embeddedness, and a loss of lower trophic level 

production. Any condition that increases water velocity, decreases water depth, decreases flow or causes 

flow to go subsurface, or blocks a watercourse would impede fish passage and alter hydro-geomorphic 

river processes. The effects of altering fish passage can vary depending on the timing and duration of the 

blockage. For example, some spring-spawning resident fish are dependent on short windows during 

spring when conditions are optimal for spawning, particularly Arctic grayling and northern pike. Arctic 

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grayling is a common species in the planning area that spawn in a fairly narrow temperature window each 

spring. Blockages of even a few days just after breakup can affect spawning success and result in low or 

failed age classes. Failure to reach preferred spawning habitats when water temperature conditions 

become optimal can lead to spawning in locations with suboptimal habitat, resulting in reduced fry 

production. This type of effect could indirectly affect the population for several years after the event. 

Blockages can also affect fish survival by inhibiting fish access to viable wintering habitat. Conversely, 

blockages preventing fish from migrating from wintering habitats to vital summer feeding and rearing 

habitats would also affect fish survival 

Streams crossings that appreciably alter river flows and stream processes can also affect fish productivity 

by causing increased turbidity, sedimentation, and erosion. However, direct habitat effects from most 

stream crossings remain relatively localized. The greatest potential for direct effects on fish productivity 

would be from placement of crossings within sensitive habitats previously described. Compromised fish 

passage associated with stream crossings has the highest potential for long-term effects on fish 

productivity. 

Invasive Species 

Fourteen nonnative invasive fish species have been identified as occurring in Alaska, including Atlantic 

salmon (Salmo salar) and yellow perch (Perca flavescens) (McClory and Gotthardt 2008). Of these 

fourteen species, some are considered native to other parts of the state but have been noted in new parts of 

the state in which the species was not previously known to occur and was not considered native. None of 

the listed fish species have been demonstrated to establish breeding populations in Alaska. Northern pike, 

a fish species that does occur within the planning area, is considered to be a nonnative invasive fish 

species in parts of the state but is considered native within the entire planning area (ADF&G 2018b). 

Section 2.8, Nonnative Invasive Species, provides a discussion of non-fish aquatic invasive species, such 

as Elodea, Chinese mitten crab, Chytrid fungus, invasive tunicates, New Zealand mudsnails, northern 

pike, Quagga mussels, red-legged frog, and zebra mussels (ADF&G 2016c). 

2.5.6 Resource Changes: Trends and Forecasts 

Fisheries 

Based on past commercial, subsistence, and personal use fisheries harvest data, resident fish production is 

generally forecasted to remain stable in the planning area. However, there have been concerns about the 

status of the Kuskokwim’s whitefish populations. Traditional ecological knowledge has indicated that 

whitefish abundance and size has declined in recent decades, while recent research has determined that 

age at maturity, mean age, and overall size have declined. When 1) the overall scarcity of spawning 

grounds, 2) changes in size and age structure, and 3) increased harvest in recent years are all considered 

together, it is clear that these species are of particular conservation concern. In this context, the spawning 

areas identified by the BLM (2016a) within the proposed Whitefish Spawning ACEC are not only rare, 

but irreplaceable insofar as they play a crucial role in sustaining those vulnerable populations. 

Chinook salmon production in the planning area has been considerably less than the long-term average, 

however some indication of a rebound in 2016 in the Yukon and Kuskokwim drainages has been 

observed. Highly restricted and/or prohibited commercial, subsistence, and personal use harvest of 

Chinook salmon in the planning area over the past decade is expected to continue until escapement goals 

are achieved. Because Chinook salmon are encountered incidentally in other fisheries, a suite of strategies 

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will be used to minimize impacts to the run. Fall chum salmon production over the past two decades has 

substantially fluctuated, particularly in the Yukon River. Large swings in production are expected to 

continue. Escapement and harvest monitoring projects are in place to aid in managing for sustained yield 

objectives. Proposal 194, Yukon River Drainage Fall Chum Salmon Management Plan (5 AAC 01.249), 

was submitted to revise management triggers for subsistence and commercial fisheries. 

Because coho salmon runs overlap with fall chum, and they are susceptible to similar types of fishing 

gear, harvest is expected to remain constrained on the Yukon River. Proposal 199 has been submitted to 

the BOF for consideration of changes to the Yukon River Coho Salmon Management Plan (5 AAC 

05.369) to allow late season harvests after the majority of fall chum salmon have migrated through. 

Habitat 

The forecasted extent of disturbances to habitat is expected to remain minimal throughout the majority of 

the watersheds in the planning area. Activities that occur within the planning area that have the highest 

potential to affect fish production include placer mining, hard rock mining, and gravel mining, timber 

harvests, and stream crossings of roads, trails, and utility corridors in important fish habitats. Impacts 

from these potential activities are unknown, though not expected to substantially increase in the near 

future. 

A consideration of the attributes and processes crucial to sustaining functioning lotic ecosystems is 

required when determining the conditions and trends of stream and river systems. The Aquatic Core 

Indicator Work Group (ACIWG) characterized functioning lotic ecosystems as the integrated product of 

hydrologic, geomorphic, chemical, and biotic processes by following the BLM’s four fundamentals and 

proper functioning condition (Prichard et al. 1998; Gregory et al. 1991). The interaction of hydrologic 

processes with channel structure/stability, riparian vegetation, and water quality collectively determine 

the habitat suitability for aquatic biota: one of the primary beneficial uses of BLM streams and rivers. The 

ACIWG used these four ecosystem processes and their associated attributes to guide the selection of 

aquatic core and contingent indicators. 

To prioritize attributes for indicator development, the ACIWG also used the conceptual framework of 

stressor-response model relationships (Noon et al. 1999). Specifically, group members were able to 

conceptualize the mechanisms by which land uses (e.g., grazing, timber harvest, oil and gas development, 

and recreation) impact key ecosystem processes and attributes, as well as how the magnitude and 

direction of the impacts vary as a function of intrinsic drivers, by using published studies and their best 

professional judgment. For example, livestock grazing can act as an extrinsic stressor to stream systems 

via multiple pathways, as more than 80 percent of western riparian areas have been affected (Kauffman et 

al. 1997). Reductions in vegetative cover can potentially increase stream temperature and changing 

instream biotic assemblages due to an increase in thermal loading (Tait et al. 1994; Beschta 1997; Herbst 

et al. 2012). Similarly, changes in channel morphology and an increase in fine sediment loading can be 

initiated by alterations in vegetative composition and cover (Knapp and Matthews 1996; Coles-Ritchie et 

al. 2007; Herbst et al. 2012); however, the degree of alteration is potentially dependent on the intrinsic 

drivers of local climate, lithology, and topography. Ideally, the guidance for ameliorating adverse impacts 

to lotic systems will be in the predictive or anticipatory models identifying linkages between crucial 

ecosystem attributes, monitoring indictors, human-caused disturbances, and management actions. 

The AIM protocol will be applied to establish the current aquatic condition of the planning area and will 

establish the aquatic conditions at the land use plan scale initially, which will be refined over time. The 

AIM framework for aquatic monitoring will focus on establishing reference conditions for key fish and 

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aquatic habitat quality indicators including for water quality, watershed function and habitat quality, and 

biodiversity and riparian habitat quality (BLM 2015b). 

Invasive Species 

The 2010 BLM Alaska State Invasive Species Policy (Instruction Memorandum [IM] AK-2011-001a ) 

provides statewide guidance for nonnative invasive species (NNIS) management (BLM 2010a), and 

incorporates principles outlined in the 2004 National Strategy and Implementation Plan for Invasive 

Species Management (U.S. Forest Service 2004); the 2016 Safeguarding America’s Lands and Waters 

from Invasive Species: a National Framework for Early Detection and Rapid Response (DOI 2016); and 

the 2016 Arctic Invasive Alien Species (ARIAS) Action Plan (CAFF 2016). 

Existing regulations intended to reduce the introduction of NNIS in Alaska include the ADF&G 

prohibition on sport angler use of felt soles in fresh waters of Alaska, effective January 1, 2012 (ADF&G 

2012); the Alaska Board of Game’s prohibition of footgear with absorbent, fibrous material soles for 

hunters in fresh water effective January 1, 2013; the State of Alaska regulations concerning permitted 

conditions and prohibitions for importing, possessing, transporting, or releasing fish and animals into the 

wild Alaska (AS 03.05.010, AS 03.05.027, AS 03.05.040, AS 44.37.030, AS 03.05.090, 11 AAC 34.130, 

11 AAC 34.140, 11 AAC 34.160, 11 AAC 34.170, AAC 34.115); and the ADNR quarantine of five 

aquatic invasive plants, effective March 5, 2014 (ADNR 2014). 

2.6 Vegetation 

2.6.1 Introduction 

This section presents the regulatory framework, resource indicators, current conditions, and trends and 

forecasts for vegetation resources in the planning area. 

2.6.2 Laws, Regulations, and Policies 

The BLM Alaska Land Health Standards and Guidelines (BLM-AK IM 2004-23) provide general 

guidance for managing healthy ecosystems, focusing on retaining natural populations consistent with 

potential and capability of the landscape. The BLM National Vegetation Classification and Associated 

Mapping (BLM-AK IM 2013-11) provides a standard, hierarchical classification system for existing 

vegetation consistent with the 2008 National Vegetation Classification Standard. The BLM Revegetation 

and Wildlife Habitat Rehabilitation Criteria for Upland Mine Reclamation on BLM-Managed Lands in 

Alaska (IM-AK-2017-01) provides consistent and measurable parameters for evaluating revegetation of 

mining operations through clear benchmarks for reclamation success. This policy criteria applies to 

uplands and a delineated portion of the flood prone area disturbed by mining operations and complement 

Reclamation Effectiveness Monitoring criteria for placer-mined streams. Naturally reclaimed sites would 

need to display approximately 70 percent or more native plant foliar cover for a minimum of two growing 

seasons with an absence of NNIS above baseline. 

2.6.3 Resource Indicators 

The conditions that are established in the discussions below provide a baseline for vegetation-related 

values, which that the impact analysis will be based on. The following indicators, along with qualitative 

discussions, will be used to evaluate impacts associated with management decisions in the BSWI Draft 

RMP/EIS. 

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• Removal or degradation of vegetation communities due to proposed human disturbances 

associated with the following: 

o Surface-disturbing actions 

o Woodland harvest actions 

o Fire and fuels treatments 

o OHV use 

o Livestock grazing 

o Land disposals 

• Extent of vegetation communities identified for protection, monitoring, reclamation, and 

mitigation, and/or adherence to cited standards associated with other resource uses or 

designations. 

2.6.4 Current Conditions 

Vegetation Communities 

Vegetation provides many key functions in ecosystems, such as serving to insulate and stabilize soil, to 

prevent erosion, as a carbon dioxide sink, as an oxygen source, to maintain species diversity, and to 

provide wildlife habitat. Vegetation has economic benefits such as providing grazing habitat, berries for 

subsistence, or firewood, and is an integral part of scenery and viewsheds. 

Vegetation can be measured in many ways to provide information on ecosystem health. BLM’s land

management policies are directed toward managing for healthy vegetation communities that support 

resilient ecological systems. As defined in the Alaska BLM Statewide Land Health Standards (BLM 

2004), functioning physical condition is a characteristic of a component of an ecosystem (usually a 

portion of a landscape or watershed) that indicates the degree of sustainability of that component. 

Properly functioning condition is an attribute of a landform that indicates its ability to produce desired 

natural resources in a sustained way. Potential natural condition refers to the desired functioning 

condition within the planning area for vegetation. Several indicators were selected to measure landscape 

maintenance within a statistically significant range of variability from potential natural condition. These 

include the following: 

• amount of bare ground 

• vegetation composition and distribution 

• nonnative invasive plant species presence 

• presence of plant species of management concern 

• vegetation height 

• soil aggregate stability 

• moss/ duff depth 

• active layer depth (when permafrost in present) 

• other indicators to be determined with neighboring landowners and partners 

NNIS are addressed in Section 2.8, Nonnative Invasive Species. 

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Ecoregions 

Ecoregions are relatively large geographic areas with characteristic and distinct climate, geology, and 

assemblages of vegetation and natural communities. Lands managed by the BLM in the planning area 

occur primarily in the following ecoregions: Yukon-Kuskokwim Delta, the Nulato Hills, the Kuskokwim 

Mountains, and the Davidson Mountains, with some area in the Kotzebue Sound Lowlands, Lime Hills, 

Alaska Range, and Tanana-Kuskokwim Lowlands (Nowacki et al. 2001). The climate is generally 

subarctic with a more oceanic subarctic regime in the western regions, and a more continental subarctic 

climate in the interior of the planning area. Precipitation is variable throughout the area, ranging between 

10-100 inches annually. 

Vegetation Community Types 

Vegetation in the planning area occurs in characteristic community types, which tend to co-occur within 

landscapes with similar ecological processes, substrates, and/or environmental gradients. A vegetation 

community is the basic unit of vegetation that allows for the representation of an assemblage of 

ecologically interrelated vegetative species (Daubenmire 1968). Specific vegetation community types are 

regionally important vegetation classes that represent the characteristic vegetation assemblages and 

encompass many of the dominant ecological processes and patterns of the planning area. 

There are many unknown factors concerning the extent and current condition of vegetation communities 

in the planning area due to limited on-the-ground inventory and monitoring information. Many parcels of 

BLM-managed public lands in the planning area are remote and difficult to efficiently access. However, 

there are several datasets available with vegetation or related parameter information. Available datasets 

derived from satellite imagery have been applied to create vegetation community type (also referred to as 

vegetation cover type) maps. These datasets assign a vegetation cover class at a resolution of 30m x 30m 

pixels and has adequate accuracy assessments (54 percent and higher) (Boggs et al. 2016a). 

There is also MODIS-derived NDVI (normalized difference vegetation index) metrics available for the 

State of Alaska, including for the planning area, from the USGS EROS Center, accessed from the GINA 

(Geographic Information Network of Alaska) website (GINA 2018). These data provide information 

about a variety of vegetation metrics, including onset of greenness, end of greenness, duration of 

greenness, rate of green up, and related parameters that provide information on seasonality and changes in 

vegetation. 

Published Ecological Site Description reports are available from NRCS for locations within the planning 

area, including Major Land Resource Areas of Alaska (MLRAs) 230-Yukon-Kuskokwim Highlands, 238-

Yukon-Kuskokwim Coastal Plain, and 240-Nulato Hills-Southern Seward Peninsula Highlands (NRCS 

2018). Published soil information is also available for the Western Interior Rivers Area, which covers 

sections of MLRA 230, as well as parts of MLRA 229-Interior Alaska Lowlands and MLRA 237-Ahklun 

Mountains, which partially overlap the planning area (NRCS 2008, updated information available on Web 

Soil Survey). A 2016 forest inventory report with vegetative cover mapping for the Kuskokwim from 

Lower Kalskag to McGrath is expected to be published in early 2019. 

Vegetation community types, derived from existing classifications and supervised satellite imagery 

classification, are illustrated for the planning area in BSWI Draft RMP/EIS, Map 3.2.6-1. Table 2.6.4-1 

provides acreages of vegetation communities within the planning area. 

Vegetation community type descriptions for the planning area are based on levels III and IV of the 

Viereck et al. (1992) classification and encompass the habitat requirements for most native species in the 

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planning area. These classes were analyzed in the Yukon Lowlands-Kuskokwim Mountains-Lime Hills 

REA, an assessment conducted by the Alaska Center for Conservation Science (ACCS; formerly the 

Alaska Natural Heritage Program) in cooperation with the BLM (Trammell et al. 2014). Vegetation 

classification tiers to the classification structure described in BLM-AK IM 2013-11; the Viereck system 

predates the National Vegetation System Classification adopted in 2008 but follows the same 

classification procedure for existing vegetation community types. 

Forest insect and disease activity detected during annual aerial surveys by the U.S. Forest Service (Forest 

Service) and ADNR over the last 15 years reflect modest activity levels within the planning area, with 

defoliators and bark beetles being the most prominent forest pests detected (U.S. Forest Service 2015). 

Table 2.6.4-1. Vegetation Communities in the Planning Area 

Vegetation Community Acres 

Percent of Total 

Planning Area 

(%) 

Bare Ground 1,338,834 2.14 

Deciduous Forest (Open-Closed) 2,722,339 4.35 

Dwarf Shrub 4,444,748 7.10 

Dwarf Shrub-Lichen 7,447,950 11.90 

Burn Scar 435,331 0.70 

Freshwater or Saltwater 4,314,515 6.89 

Herbaceous (Aquatic) 15,098 0.02 

Herbaceous (Marsh) (Interior Alaska, Cook Inlet basin) 9,415 0.02 

Herbaceous (Marsh) (Northern and Western Alaska) 1,393,769 2.23 

Herbaceous (Mesic) (Interior Alaska, Cook Inlet basin) 622,217 0.99 

Herbaceous (Mesic) (Northern and Western Alaska) 401,591 0.64 

Herbaceous (Wet) (Interior Alaska, Cook Inlet basin) 1,323,320 2.11 

Herbaceous (Wet) (Northern and Western Alaska) 3,121,839 4.99 

Herbaceous (Wet-Marsh) (Tidal) (Western Alaska, Cook Inlet basin) 845,360 1.35 

Ice-Snow 950,171 1.52 

Lichen 330,909 0.53 

Low Shrub 5,845,188 9.34 

Low Shrub/Lichen 216,790 0.35 

Moss 104,385 0.17 

Sparse Vegetation (Interior Alaska, Cook Inlet basin) 20,946 0.03 

Sparse Vegetation (Northern and Western Alaska) 16,751 0.03 

Tall Shrub (Open-Closed) 4,872,160 7.78 

Tussock Tundra (Low shrub or Herbaceous) 1,397,589 2.23 

Unclassified 1,162,074 1.86 

Urban, Agriculture, Road 3,468 0.01 

White spruce or Black spruce (Open-Closed) 7,604,843 12.15 

White spruce or Black spruce (Woodland) 5,645,151 9.02 

White spruce or Black spruce/Lichen (Woodland-Open) 2,932,829 4.69 

White spruce or Black spruce-Deciduous (Open-Closed) 3,047,496 4.87 

Grand Total 62,587,077 100.00 

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Upland and lowland black spruce (Picea mariana) forests are common in the eastern side of the planning 

area and may provide a suitable source of biomass for communities. Black spruce forests tend to occur in 

open canopy stands on lowlands and north-facing uplands, such as sites with cold and wet soils and 

typically shallow permafrost. The ground layer is typically dominated by feathermosses (Hylocomium 

spp.) and sphagnum moss (Sphagnum spp.). Lichens can be abundant, especially in older stands and in 

areas with shallow or rocky soils. Common shrubs are willow (Salix spp.), green alder (Alnus viridis), 

shrub birch, Labrador tea (Ledum spp.), bog blueberry (Vaccinium uliginosum), and low bush cranberry 

(Vaccinium vitis-idaea). Birch (Betula papyrifera) and white spruce (Picea glauca) occur occasionally. 

Black spruce forests are also highly flammable. Following fire, a black spruce stand may be replaced by a 

community very similar to the previous forest community, except that black spruce occur only as 

seedlings, and an increase in abundance of herbs, grasses, and shrubs typically occur for a number of 

years. In drier sites and/or conditions of severe fire (exposed mineral soil), black spruce may be replaced 

by birch or aspen (Populus tremuloides). 

White spruce is found on warmer, well-drained sites and is also often the spruce species occurring at treeline. White spruce is a late-succession seral stage, which is typically preceded by deciduous forest. Mixed 

stands of white spruce and aspen or birch are common. Common shrubs in white spruce stands are 

blueberry (Vaccinium spp.), low bush cranberry, and Labrador tea. Feathermosses often dominate the 

ground layer and herbs include horsetails (Equisetum spp.) and pumpkinberry (Geocaulon lividum). In 

well-drained floodplain sites, white spruce often occurs with balsam poplar (Populus balsamifera subsp. 

balsamifera) and alder (Alnus spp.) shrub and will replace the balsam poplar as succession proceeds. At 

treeline, white spruce occurs in an open woodland (often mixed with black spruce) with shrub birch 

(Betula nana, B. neoalaskana) and willow understories. Commercial logging for manufacturing in 

Interior Alaska is focused on white spruce stands on productive sites. 

Pure deciduous forests occur relatively infrequently in the planning area. Deciduous forests are found 

most commonly on south-facing slopes or well-drained sites on other aspects. Aspen dominates on the 

drier, south-facing slopes while birch stands occur on somewhat cooler, moister sites such as east-and 

west-facing slopes. Aspen stands often have in the shrub layer willow, highbush cranberry (Viburnum 

edule), prickly rose (Rosa acicularis), and buffaloberry (Shepherdia canadensis); and in the herb layer 

bedstraw (Galium spp.), pumpkinberry, and bluejoint reedgrass (Calamagrostis canadensis). Mosses and 

lichens are typically scarce. If moisture is sufficient, white spruce may establish and dominate in late 

succession. Birch dominated stands typically have alder, willow, rose (Rosa spp.), highbush cranberry, 

and low bush cranberry as shrubs. Bluejoint reedgrass or horsetail are often the dominant herb, and heavy 

leaf litter limits moss and lichen cover. Drier birch stands can have scattered white spruce and may be 

replaced by white spruce in late succession, while wetter sites can contain some black spruce and may be 

replaced by black spruce. Narrow stands of balsam poplar can occur along larger rivers. 

Non-forested lowland bogs occur where shallow permafrost impedes drainage and the soil remains too 

wet for tree growth. These bogs are dominated by tussock-forming cottongrass (Eriophorum vaginatum) 

or Bigelow’s sedge (Carex bigelowii). Where shrub cover exceeds 25 percent, they are generally 

considered shrublands and include shrub birch, Labrador tea, bog rosemary (Andromeda polifolia) and 

bog cranberry (Vaccinium oxycoccus). Cottongrass tussock tundra occurs on shallow slopes in the uplands 

as well. 

Shrub types occur in a variety of habitats. Shrubs may be abundant in many sites following wildland fire. 

Willows and alder shrublands often occur in moist draws and along rivers and streams. Alder slopes occur 

occasionally near treeline. The most common shrubland is dominated by dwarf birch and Labrador tea; it 

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occurs commonly near treeline and also on north facing slopes and areas with little slope or poor 

drainage. Dwarf birch shrublands often intergrade with open woodland black spruce and tussock tundra. 

Above treeline, low shrub grades into the lower-stature dwarf shrub tundra, which is typically dominated 

by bog blueberry, crowberry (Empetrum nigrum), low bush cranberry, and bearberry (Arcostaphylos 

alpina). Lichens and mosses can be abundant. Wet areas above treeline often support herbaceous 

communities. 

Steep south-facing slopes may support steppe-like (treeless) communities. They are dominated by 

drought-tolerant species of bunchgrasses, sage (Artemesia spp.), and a variety of herbs. Although they 

occur on a very small proportion of lands, they support a high number of species endemic (limited in 

distribution to a particular locality) to Alaska or Beringia (an area comprising the Bering Strait and 

adjacent Siberia and Alaska, which was ice-free in past glacial time periods), as well as other species 

characteristic of the intermountain western U.S. They are sites of typically high species diversity and, due 

to atypical vegetation, add diversity to the surrounding area. Many of the BLM Alaska sensitive and 

watch species plants in the planning area occur on these “steppe” sites. Where not as steep or dry, these 

south-facing slopes support open aspen forests and also open white spruce or birch. 

Vegetation Communities of Interest 

The vegetation communities described below are of particular interest to prevent from diverging from 

potential natural conditions: 

I. Tall shrub, low shrub, and floodplains (generalized moose habitat) 

II. Lichen habitats (generalized caribou habitat) 

III. White spruce on well-drained floodplains 

IV. Dwarf shrub and sparsely vegetated areas (generalized BLM Sensitive plant species habitat) 

V. Herbaceous wetlands 

Tall shrub is dispersed throughout the planning area. This class is defined by areas with 25 percent to 

100 percent of tall shrub cover. The shrub layer is comprised primarily of alder and/or willow. At least 25 

percent of these sites consist of shrubs greater than 1.3 m in height. Tall shrub is widespread on 

mountains and hill slopes, and elevations range from 22 to 4,875 feet. Soils are typically mesic. Common 

tall shrubs include Siberian alder (Alnus viridis ssp. fruiticosa), green alder, grayleaf willow (Salix 

glauca), Barclay’s willow (Salix barclayi), and tealeaf willow (Salix pulchra). Additional species include 

red elderberry (Sambucus racemose), bog blueberry, low bush cranberry, dwarf birch, marsh Labrador tea 

(Ledum palustre ssp. decumbens), crowberry, beauverd spirea (Spiraea stevenii), mountain-avens (Dryas 

spp.), and white arctic mountain heather (Cassiope tetragona). Mosses include splendid feathermoss 

(Hylocomium splendens) and dicranium moss (Dicranum spp.). This class is often mosaicked with low 

shrub tundra and dwarf-shrubs. 

Low shrub occurs throughout the planning area. This class is defined as shrubs with 25 percent to 100 

percent vegetation cover where shrubs greater than 4.3 feet in height contribute less than 25 percent of 

vegetation cover of the site, and either more than 25 percent of the site consists of shrubs between 0.6 and 

4.3 feet in height, or shrubs between 0.6 and 4.3 feet in height are the most common shrubs. The low 

shrub vegetation is common on wet and mesic mountain slopes, hill slopes, flats, and stream banks and 

also occurs in lowlands and wetlands. Low shrub sites occur from 20 feet to 6,255 feet within the 

planning area. Patch size is small to large, can be matrix-forming, and are often linear along small 

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streams. Soils range from mesic, wet, mineral, and organic peat. Permafrost is often present. Common 

shrubs include dwarf birch, marsh Labrador tea, tealeaf willow, grayleaf willow, barrenground willow, 

Chamisso’s willow, Bebb’s willow, Barclay’s willow, crowberry, leatherleaf (Chamaedaphne 

calyculata), bog blueberry, and sweetgale (Myrica gale). Other shrubs include Siberian alder, Kamchatka 

rhododendron (Rhododendron camtschaticum), bog cranberry, marsh fivefinger (Comarum palustre), and 

Alaska bog willow (Salix fuscescens). Additional species include bluejoint reedgrass, water sedge (Carex 

aquatilis), and sphagnum moss (Sphagnum spp.). Lichen cover (primarily Cladina spp.) can be greater 

than 20 percent and occur in large patches between shrubs. 

Floodplains and riparian areas are the lands adjacent to a stream or river that stretches from the banks 

of its channel to the base of the enclosing valley walls and experiences flooding during periods of high 

discharge. These fluvial plains include meandering or straight active streams, braided channels, 

abandoned channels, oxbows, and alluvial terraces. Permafrost is typically absent. Floodplains represent a 

biophysical setting and occur in large, continuously connected vegetated, un-vegetated and water 

polygons that follow the major rivers. Two types of forested floodplain biophysical settings occur in 

floodplains, including colder Interior Alaska sites with permafrost underlying the ancient terraces and 

warmer southern Interior Alaska sites with no permafrost underlying the ancient terraces. Riparian 

vegetation follows large and small order streams, both perennial and ephemeral. 

Lichen habitats occur both independently and among many other vegetation types (white spruce 

woodlands, dwarf shrub, and low shrub) that have 20 percent or more lichen cover. They tend to occur on 

summits, ridgelines, hillslopes, riparian benches, and other well drained sites. Foliose and fruticose 

lichens usually dominate and include navel lichen (Umbilicaria spp.), world map lichen (Rhizocarpon 

geographicum), star reindeer lichen (Cladina stellaris), racomitrium moss (Racomitrium lanuginosum), 

flavocentraria lichen (Flavocetraria spp.) and witch’s hair lichen (Alectoria ochroleuca). Common dwarf 

shrubs found amongst lichens include alpine azalea (Loiseleuria procumbens), dwarf birch, marsh 

Labrador tea, crowberry, and bog blueberry. When lichens are found in black or white spruce woodlands, 

the shrub layer is open and typically includes dwarf shrub, buffaloberry, bearberry, bog blueberry, or 

crowberry. Lichens (primarily Cladina spp.) often occur in small round patches between trees. 

White spruce on floodplains generally occurs as co-dominant or dominant species in the canopy. Tree 

cover ranges from 10 percent to 100 percent, with 75 percent or more of the trees being needle leaf. White 

spruce on floodplains occurs at lower elevations with generally flat slopes. Other sub-dominant trees 

include Betula neoalaskana and Populus tremuloides. Common understory shrubs may include Rosa 

acicularis, Vaccinium vitis-idaea, Betula nana, Alnus spp., Shepherdia canadensis, and Linnaea borealis. 

Common herbaceous species include Pyrola spp., Equisetum spp., Calamagrostis canadensis, Carex spp., 

Eriophorum angustifolium, Eriophorum vaginatum, Carex bigelowii, and Mertensia paniculata. Common 

bryophytes may include Hylocomium splendens, and Pleurozium schreberi. Lichens, such as Cladina 

spp., may be abundant. 

Dwarf-shrub and sparse vegetation is primarily distributed throughout the southern region of the 

planning area. The shrub layer is composed of Dryas, ericaceous, and/or Salix species. At least 25 percent 

of the site consists of shrubs less than 0.6 feet in height. Dwarf-shrub and sparse vegetation commonly 

occurs on sideslopes, ridges, summits, floodplains, valleys, late-lying snow beds, and bluffs. Elevation 

ranges from 20 to 7,449 feet. Sites are typically dry to mesic with lithosols common. Permafrost can be 

present or absent beneath this vegetation type. Patch size ranges from small to large. This vegetation type 

does not include peatland plateaus or wetlands. Plant species diversity is high in dwarf-shrub sites. 

Common dwarf-shrub species include Dryas integrifolia, D. octopetala, Betula nana, Cassiope tetragona, 

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Salix arctica, S. phlebophylla, S. reticulata, S. rotundifolia, Vaccinium uliginosum, V. vitis-idaea, 

Empetrum nigrum, Rhododendron tomentosum ssp. decumbens, Diapensia lapponica, Harrimanella 

stelleriana, Kalmia procumbens, and Arctous spp. Common herbaceous species may include Boykinia 

richardsonii, Geum glaciale, Pedicularis lanata, Eriophorum angustifolium ssp. triste, Senecio lugens, 

Anemone spp., Hierochloe alpina, Arnica lessingii, Carex scirpoidea, C. bigelowii, C. microchaeta, C. 

scirpoidea, Festuca spp., Lupinus arcticus, Artemisia globularia, Bistorta officinalis, Luzula spp., 

Antennaria alpina, and Equisetum spp. Common mosses may include Rhytidium rugosum, Aulacomnium 

turgidum, A. palustre, Distichium capillaceum, Hylocomium splendens, Racomitrium spp., Dicranum 

elongatum, Pleurozium schreberi, Polytrichum spp., and Tortula ruralis. Lichens may be common and 

can include Cladina rangiferina, C. stellaris, Cetraria cucullata, Stereocaulon spp., Alectoria nigricans, 

and Thamnolia vermicularis. Some south facing slopes also support a unique assemblage of species, 

including Artemisia frigida, Artemisia alaskana, Juniperus communis, Arctostaphylos uva-ursi, 

Shepherdia canadensis, Pseudoroegneria spicata, Bromopsis pumpelliana, Calamagrostis purpurascens, 

Festuca altaica, and Poa spp. 

Herbaceous wetlands occur throughout the planning area, with some regions having greater 

concentrations than others. Shrubs contribute less than 25 percent of the vegetation cover, while 

herbaceous species contribute more than 25 percent in this vegetation type. Sites can be wet with no 

standing water, permanently wet, flooded with standing water, or permanently flooded and dominated by 

aquatic plants. Herbaceous wetlands do include herbaceous peatlands, but not tussock tundra. Herbaceous 

wetlands occupy elevations ranging from 19 to 8,122 feet in the planning area. Permafrost ranges from 

absent to common. This class occurs in areas of thermokarst. In periodically wet or continually flooded 

sites, vegetation is dominated by emergent herbaceous plants such as sedges, cattails, and rushes. 

Dominant vegetation includes Northwest Territory sedge (Carex utriculata), softstem bulrush 

(Schoenoplectus tabernaemontani), broadleaf cattail (Typha latifolia), buckbean (Menyanthes trifoliata), 

water horsetail (Equisetum fluviatile), common spikerush (Eleocharis palustris), marsh fivefinger, 

common mare's-tail (Hippuris vulgaris), and pendantgrass (Arctophila fulva). Other common species 

include water sedge, Northwest Territory sedge, woollyfruit sedge (Carex lasiocarpa), tall cottongrass 

(Eriophorum angustifolium), bluejoint reedgrass, water arum (Calla palustris), and marsh horsetail 

(Equisetum palustre). Shrubs include dwarf birch, sweetgale, gray alder (Alnus incana ssp. tenuifolia), 

and willow species. Permanently flooded sites may be dominated by a variety of rooted or floating 

aquatic herbaceous species, including yellow pond-lily (Nuphar polysepala), pondweeds (Potamogeton 

spp.), common duckweed (Lemna minor), bur-reeds (Sparganium spp.), and water buttercups 

(Ranunculus spp.). Other common species include milfoil species (Myriophyllum spp.), common mare’s 

tail, spiny-spore quillwort (Isoetes tenella), and water-starworts (Callitriche spp.). In areas of closed bogs 

and poor fens, thick peat-forming sedges dominate, including tufted bulrush (Trichophorum cespitosum), 

manyflower sedge (Carex pluriflora), creeping sedge (Carex chordorrhiza), livid sedge (Carex livida), 

and red cottongrass (Eriophorum russeolum). Dwarf and low shrubs include bog cranberry, bog 

rosemary, bog blueberry, marsh Labrador tea, and crowberry. Aquatic mosses can be present including 

sphagnum moss species. 

Rare Ecosystems 

Ecosystems that are considered rare, or of special conservation value, occur within the planning area. 

Special conservation value ecosystems are defined as those that support unique assemblages of 

specialized and/or diverse flora and fauna within a small geographic area or restricted range. For these 

ecosystems within the planning area, remoteness preserves many in pristine condition, yet some naturally 

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uncommon systems are in decline due to their intrinsic vulnerabilities (small, unconnected systems 

subject to changes in hydrology, or shifts in microclimate) or large-scale threats (such as climate change 

or development) (Boggs et al. 2016b). These ecosystems within the planning area have been identified as 

pingos (or dome-shaped mounds consisting of a layer of soil over a large core of ice, occurring in 

permafrost areas) in interior Alaska that support forests; tamarack (Larix laricina) dominated 

associations; dunes that have been stabilized by forests, typically aspen/black spruce; limestone geologic 

substrate areas; and serpentine geologic substrate areas. These areas are not well mapped at this time. 

Sensitive Plant Species 

Within the planning area, there are no plant species listed, proposed, or a candidate for listing as 

threatened or endangered under the Endangered Species Act (ESA). However, the BLM-Alaska Special 

Status Species list includes 32 sensitive plant species found within Alaska, all of which are ranked S1, S2, 

or S3 by the ACCS. Many species on this list do not occur within the planning area. There are four BLMAlaska sensitive plant species that have been documented in the planning area, three of which have been 

found to occur on BLM-managed public lands through on-the-ground inventory (Table 2.6.4-2 and Map 

3.2.6-2 of the BSWI Draft RMP/EIS). 

Table 2.6.4-2. Current BLM-Designated Sensitive Plant Species Known within the Planning Area 

Scientific Name Common Name 

Occurrences in 

Planning Area 

Occurrences on 

BLM-Managed 

Land 

Douglasia beringensis Arctic dwarf primrose 14 11 

Koeleria asiatica Oriental junegrass 1 1 

Smelowskia pyriformis Pearshaped smelowskia 20 3 

Trisetum sibiricum ssp. torale Siberian false-oats 1 0 

These sensitive plant species were found primarily on three vegetation land-cover classes (defined by the 

Vegetation Map and Classification of Northern, Western, and Interior Alaska, Boggs et al. 2016a): 

• Bare-ground, sparsely vegetated mesic herbaceous areas (more than 20 percent herbaceous cover 

and over 50 percent bare-ground) 

• Dwarf shrub 

• Persistently snow-covered areas 

Map 3.2.6-1 of the BSWI Draft RMP/EIS shows the extent of these vegetation land-cover classes in the 

planning area. The known locations of the three sensitive species on BLM-managed land were found 

primarily on higher elevations, on mountain side slopes of the Lime Hills, Nulato Hills, Terra Cotta 

Mountains, Kuskokwim Mountains, and Alaska Range. 

Calcareous soils are formed on the shale and limestone parent materials of the Nulato Hills and Lime 

Hills but are an uncommon substrate in the planning area. Unique plant communities occur on this soil 

type due to its relatively higher soil pH, deficiency of some nutrients and excess of other nutrients, and 

low moisture content. The three sensitive plant species on BLM-managed public land occur on these 

substrates among sparsely vegetated, dwarf shrub, and bare-ground plant communities. The species 

assemblages that occur on calcareous soils are less common than similar land-cover types that occur on 

soils of lower pH. 

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Presence of rare species highly associated with calcareous soils can be used as a bioindicator of the health 

of bare-ground, sparsely vegetated, dwarf shrub plant communities. These plant communities are least 

common in the planning area and although they are currently considered to be in a stable and healthy 

condition (due to the lack of development in their habitat), they may be impacted in the future by 

telecommunication towers, OHV trails, or transmission line corridors. 

Trends for these special status plant species are unknown. Extremely limited inventory and monitoring 

efforts for rare plants have occurred in the planning area. However, most sensitive plant species 

populations in Alaska occur in undisturbed habitats and, therefore, are assumed to be unaffected by rural 

development, nonnative invasive and noxious species (Carlson and Shepard 2007), and other human 

impacts. 

Wetlands and Riparian Areas 

Uplands are lands above the riparian/wetland area, or active floodplains of rivers and streams, and 

includes lands not influenced by the water table or by free or unbound water; commonly represented by 

tow slopes, alluvial fans, and side slopes, shoulders and ridges of mountains and hills. 

Wetlands are areas that are inundated or saturated by surface or groundwater at a frequency and duration 

sufficient to support, and which under normal circumstances do support, a prevalence of vegetation 

typically adapted for life in saturated soil conditions. 

Riparian areas are defined as an area of land directly influenced by permanent water. It has visible 

vegetation or physical characteristics reflective of permanent water influence. Lake shores and 

streambanks are typical riparian areas. Excluded are such sites as ephemeral streams or washes that do not 

have vegetation dependent on free water in the soil. 

A variety of plant communities or types can occur in wetlands. Hydrophytic vegetation (vegetation 

typically adapted for life in saturated soil conditions) is one indicator of wetlands. Shallow permafrost, 

which results in near-surface saturated soils occurs throughout much of the planning area and many 

Interior Alaska plants are adapted to saturated soil conditions. As a result, large parts of the planning area 

would be considered wetlands, including much of the black spruce forests in lowlands and north-facing 

slopes. In addition, many shrublands and tussock tundra communities have saturated soils that would 

result in their consideration as wetlands. 

More detailed information on riparian and wetland habitat is found in Section 2.4, Water Resources, and 

Section 2.5, Fisheries. 

Vegetation and Wildland Fire 

Northern boreal forests are adapted to wildland fires. After a fire, vegetation recovers by sprouting from 

roots, from underground or canopy seed banks, or from seed transported from outside the burned area via 

wind, animals, or other vector. The exact response varies by fire intensity, season, moisture condition, and 

plant species. In general, sites with more severe fire (greater organic layer consumption and more mineral 

soil exposure) and lower soil moisture are more likely to change from spruce-dominated to deciduousdominated following fire (Johnstone and Hollingsworth 2007). Some later successional species, 

especially lichens, will be scarce in post-fire stands for long periods. Lichens, which are important winter 

forage for caribou and reindeer, typically require 60-to-80 years to reach abundance (Thomas et al. 1996; 

Joly et al. 2003; Collins et al. 2011). Black spruce often replaces itself as the dominant tree in the absence 

of competition from other tree species. Post-fire recovery of white spruce stands depends on the stage of 

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seed production at wildland fire occurrence and the distance to unburned spruce as sources of new seed 

and/or the presence of dispersal agents. 

In terms of climate change, wildland fire is not specifically mentioned but may need to be considered in 

calculations of GHG per the BLM Permanent IM 2017-003 such that all relevant National Environmental 

Policy Act of 1969 (NEPA) documents are consistent with Council on Environmental Quality (CEQ) 

guidance for the planning area (BLM 2017a). More detailed information on wildland fire is found in 

Section 2.9, Wildland Fire. 

2.6.5 Resource Changes: Trends and Forecasts 

Vegetative communities in this large and relatively inaccessible planning area are largely undisturbed by 

human activities. Given the relatively natural condition of much of the landscape, maintaining land health 

rather than restoring it is key in managing vegetation and multiple land uses. 

Vegetation communities within the planning area are trending favorably and maintaining proper 

functioning condition. Active management of vegetation has been minimal since the drafting of the 

SWMFP (1981), and has consisted primarily of fire suppression activities, a small number of authorized 

harvests of forest products. The loss of vegetation from development has been insignificant within the 

planning area. 

Maintenance for properly functioning condition is ensuring that ecological processes are being maintained 

while supporting healthy forest conditions and providing productive habitats, biotic populations and 

communities and resources to local communities. 

Mining 

Placer mining has caused local disturbance of riparian vegetation in a small portion of the planning area. 

Changes in requirements for reclamation of placer mined lands (initiated in 1981), and changes in mining 

practices have resulted in generally faster and more effective natural revegetation of mined sites. In some 

cases, however, placer-mined land has not recovered functionally or in terms of vegetation health. 

Riparian areas, and their associated streams and wetlands, are also indicators of watershed health, as they 

are among the first landscape features to reflect damage from improper management or natural events 

within the watershed. 

New metrics for determining when to release mining reclamation were adopted in 2017. These describe 

the vegetation conditions miners are expected to meet in order for reclamation to be approved and bonds 

to be released. These measures were developed to ensure sites were on the correct track to provide 

acceptable wildlife habitat over time. 

Off-Highway Vehicle Use 

OHV route use patterns throughout the planning area typically start at a community or an access point 

along a community road, river-boat landing site, or airstrip, and radiate outward as terrain permits, with 

routes leading to the location of potential subsistence resources. There are 60 rural communities within 

the planning area, with 26 in the immediate vicinity of BLM-managed public lands. Almost all routes 

have been established casually, and without regard to surface soil and vegetation conditions or the 

viability of repeated use of the route. Most summer overland routes in the planning area are located in 

terrain that is treeless due to climatic conditions, presence of permafrost, soil types, wetlands, and/or 

elevation. The use of modern OHVs for subsistence, hunting, transportation, and recreational activities 

has substantially increased since the 1980s and the SWMFP (BLM 1981). Almost all overland summer 

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routes evident today within the planning area are the result of OHV use in the past two to three decades. 

Improvements in all-terrain vehicle technology have led to vehicles traveling faster and farther onto 

public lands (BLM 2015a). The increased production, acquisition, and use of summer OHVs that are 

“two-person-wide," as compared to the current predominance of “single-person-wide” OHVs may result 

in an increase in the width of overland travel routes from such vehicles, with an increase in the number of 

impacted acres and associated resources (BLM 2015a). 

Climate Change 

Warming climate trends are expected to continue to impact vegetation, resulting in altered growth 

patterns, shifting habitat ranges, hydrological changes, and shifts in wildland fire timing, number, and 

severity. 

Potential shifts of white spruce and black spruce habitat may occur (Barber et al. 2000; McGuire et al. 

2010; Beck et al. 2011). New research suggests that white spruce may gain dominance over black spruce 

in areas that have experienced permafrost thaw and deepened soil active layer (Roland et al. 2013). White 

spruce has been shown to exhibit varying responses to warming climates depending on geographical area. 

In the western part of the planning area, white spruce is growing better than ever before, while in the 

eastern part, growth has declined to record low levels, presumably due to drought stress (Juday et al. 

2015; Barber et al. 2000; Lloyd and Fastie 2002). It is suggested that spruce that decrease in growth as 

temperatures increase are very near survival limits. Large-scale biome shifts are possible and have been 

illustrated through modeled potential scenarios for Alaska (SNAP-EWHALE 2012). There may also be 

potential increases in vegetation-impacting insect outbreaks altering forest structure (Volney and Fleming 

2000). 

Closed-basin wetlands have been drying in many areas of Alaska (Riordan et al. 2006), and evidence 

suggests that large-scale drought trends, including reduced precipitation or changes in precipitation 

seasonality, will continue within the planning area (USGS 2016). 

Expansion of forests and shrub-lands into tundra areas in the planning area is likely to accelerate with 

future climate warming deepening active layers, promoting decomposition, which increases available soil 

nutrients. Additionally, a shift in vegetation zones to higher elevations is likely to continue to occur, with 

species expanding into newly favorable areas and declining in unfavorable areas; this phenomenon has 

been well documented in other parts of the world (Lenoir et al. 2008). Studies have recorded woody 

vegetation (trees and shrubs) encroachment into alpine habitats and sedge wetlands in nearby Denali 

National Park and Preserve between 1976 and 2005 (NPS 2011). Treeline in portions of the planning area 

has been noted as rising. Studies have noted tundra conversion to shrub or forest (Cooper 1986; Suarez et 

al. 1999; Lloyd and Fastie 2002; Lloyd and Fastie 2003; Stueve et al. 2011). 

Fire regimes in Alaska spruce forest types have been generally characterized by low frequency/high 

intensity fire events. The range of reported fire cycles reported by Viereck (1983) is roughly 40–120 years 

for black spruce forest and 80 to 150 years for floodplain white spruce. Wildland fires have changed in 

timing and increased in frequency in the twenty-first century. Large acreages burned in Alaska were 

recorded in 2004, 2005, and in 2015. Wildland fires tend to occur earlier in the spring compared to 

historical conditions, possibly due to warmer winters and reduced snow cover (USGS 2016). Expected 

changes include vegetation type conversion at a landscape scale due to changes in fire frequency or 

severity (Rupp et al. 2000; Johnstone et al. 2010; Shenoy et al. 2011). As mentioned earlier, wildland fire 

is not specifically mentioned but may need to be considered in calculations of GHG per the BLM 

Permanent IM 2017-003 such that all relevant NEPA documents are consistent with CEQ guidance for 

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the planning area (BLM 2017a). More detailed information on wildland fire is found in Section 2.9, 

Wildland Fire. 

Climate change may contribute to a northward expansion or increased populations of native spruce bark 

beetle (Dendroctonus rufipennis) infestations, which were documented in the late 1990s and early 2000s, 

and impacted forest cover primarily in the Kenai Peninsula (ADNR 2018; USDA 2018). Current and 

prior outbreaks have been attributed to warming winters that allow the species to overwinter, increasing 

population size. 

2.7 Wildlife and Special Status Species 

2.7.1 Introduction 

Approximately 50 species of mammals, 152 species of birds, and one species of amphibian are found in 

the planning area. With the exception of big game animals and some bird species, current numbers and 

population trends for these species on BLM lands in the planning area are unknown, and no specific 

management goals have been established. This section provides baseline information on the wildlife 

habitats and species in the planning area, including SSS and habitats of high value to wildlife. 

Information on trends in populations and habitat condition are provided, where information is available. 

2.7.2 Laws, Regulations, and Policies 

This section provides a general summary of the applicable agencies with jurisdictional authority and their 

relevant regulatory requirements related to wildlife and SSS in the planning area. This information is 

provided to increase the understanding of the alternatives being considered and associated impact 

analysis. 

State of Alaska 

The responsibility for managing wildlife populations traditionally rests with the State of Alaska, except in 

special cases. These cases include the management of marine mammals, migratory birds, and federally 

listed threatened or endangered species, which are, at least in part, the responsibility of the federal 

government. Additionally, in Alaska, subsistence harvest management on federal lands is also a federal 

responsibility and several federal agencies share in this responsibility, including the BLM. The BLM 

conducts wildlife habitat management and population monitoring, which supports the State of Alaska’s 

wildlife population management objectives, and the Federal Subsistence Management Program 

necessitated by ANILCA. 

ANILCA requires management of BLM lands in Alaska not only to provide healthy populations, but also 

to minimize impacts on subsistence resources and use of those resources. ANILCA section 802 states, 

“...consistent with sound management principles, and the conservation of healthy populations of fish and

wildlife, the utilization of public lands in Alaska is to cause the least adverse impact possible on rural 

residents who depend upon subsistence uses of the resources of such lands.” 

BLM Wildlife Habitat Management 

Current wildlife habitat management is a sub-activity (6500) of the BLM manual and includes 

management of wildlife habitat on public lands. On federal lands, under Title VIII of ANILCA, ensuring 

a priority for harvests of fish and wildlife and other renewable resources by subsistence users is also a 

BLM responsibility, mandated under ANILCA. The State of Alaska operated a subsistence management 

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program on all lands in Alaska that met the federal requirements until July 1990, when the Alaska 

Supreme Court decision in McDowell v. State of Alaska became effective. In the McDowell decision, the 

court ruled that the statutes used by the State to provide a subsistence priority for rural Alaskans violated 

the equal protection clause of the Alaska Constitution. The court allowed the State government six 

months to remedy the situation before the decision became effective. The State was unsuccessful in 

amending its laws to comply with ANILCA Title VIII. On July 1, 1990, the federal government was 

forced to assume management of subsistence activities on federal public lands in Alaska. On federally 

managed lands in Alaska, Title VIII of ANILCA mandates that qualified rural subsistence users be 

accorded a priority for harvesting fish and wildlife over non-rural residents of the state. 

The federal government’s subsistence regulations created the Federal Subsistence Board and charged it 

with the responsibility for subsistence activities on federal public lands in Alaska. The Board is composed 

of Alaska Regional Directors of the USFWS and the NPS; the Alaska Regional Forester (Forest Service); 

the BLM State Director; and the Alaska Area Director of the Bureau of Indian Affairs (BIA). These 

regulations delegate authority to BLM for management of subsistence resources on federal public lands 

managed by BLM. 

BLM Manual 6840 - SSS Management establishes the BLM’s primary policy on the management of 

SSS, including plants. BLM SSS include species listed or proposed for listing under the ESA, candidate 

species, and species delisted from the ESA for a period of five years after delisting. SSS also include 

those that require special management consideration to promote their conservation and reduce the 

likelihood and need for future listing under the ESA, as determined by the BLM State Director. 

BLM Manuals 1730, 1740-45, 6500-6800-Wildlife Management, Habitat Management, Population 

Management. Departmental Manuals Parts 135, 500-501, 515-520, 585-619, 630-644, 702-729 and 765. 

It is BLM policy to manage habitat with emphasis on ecosystems to ensure self-sustaining populations 

and a natural abundance and diversity of wildlife, fish, and plant resources on public lands. 

These manuals provide DOI Policy guidance for wildlife management and public land management 

including forest, minerals, lands, special programs, and NEPA. 

Federal Acts 

ANILCA 

The significance of the ANILCA to management within the planning area is discussed in detail in other 

sections of this document. In the context of fish management, Section 1314 regarding state management 

authority and Title VIII regarding subsistence are particularly relevant. Title VIII declares that: 

the continuation of the opportunity for subsistence uses by rural residents of Alaska, including 

both Natives and non-Natives, on the public lands and by Alaska Natives on Native lands is 

essential to Native physical, economic, traditional, and cultural existence and to non-Native 

physical, economic, traditional, and social existence. 

Title VIII establishes that nonwasteful subsistence uses of fish and wildlife and other renewable resources 

shall be the priority consumptive uses of all such resources on the public lands of Alaska when it is 

necessary to restrict taking in order to assure the continued viability of a fish or wildlife population or the 

continuation of subsistence uses of such population, the taking of such population for nonwasteful 

subsistence uses shall be given preference on the public lands over other consumptive uses (ANILCA 

section 802). Title VIII also establishes that the Secretary of the Interior shall permit on the public lands 

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appropriate use for subsistence purposes of snowmobiles, motorboats, and other means of surface 

transportation traditionally employed for such purposes by local residents, subject to reasonable 

regulation (ANILCA section 811). 

Fish and Wildlife Coordination Act 

The act authorizes the Secretary of the Interior to assist federal, State, and other agencies in the 

development, protection, rearing and stocking fish and wildlife on federal lands, and to study the effects 

of pollution on fish and wildlife. Acting agencies are required to consult with the USFWS and the State of 

Alaska species managing agencies to develop mitigation or compliance for proposed land use 

authorizations. 

Federal Cave Resources Protection Act 

Caves on federal lands are managed under 43 CFR, Part 37. These regulations provide guidance for 

identifying, nominating, evaluating, and designating significant cave resources. The purposes of this Act 

are (1) to secure, protect, and preserve significant caves on federal lands for the perpetual use, enjoyment, 

and benefit of all people; and (2) to foster increased cooperation and exchange of information between 

governmental authorities and those who utilize caves located on federal lands for scientific, education, or 

recreational purposes. It is the policy of the U.S. that federal lands be managed in a manner that protects 

and maintains, to the extent practical, significant caves. 

ESA 

The ESA requires all federal agencies to conserve and protect all species, subspecies or populations of 

plants and animals and the ecosystems upon which they depend, that have been officially listed as 

threatened or endangered by the Secretary of the Interior. The act also requires consultation with USFWS 

and NMFS if any action may affect a federally listed species or its critical habitat. 

Bald and Golden Eagle Protection Act 

The act provides for protection of bald eagles and golden eagles by prohibiting, except under certain 

specified conditions, the taking, possession, and commerce in such birds, their nests, eggs, or feathers. 

This act is administered by the USFWS. 

Migratory Bird Treaty Act 

This act establishes a federal responsibility for the protection of international migratory birds. The act 

provides for regulations to control taking, selling, transporting and importing birds, their nests, eggs, parts 

or products and provides enforcement authority and penalties for violations. It also establishes the 

regulatory framework for sport and subsistence harvest of migratory birds under the jurisdiction of the 

USFWS. 

EO 13186, Responsibility of Federal Agencies to Protect Migratory Birds 

This order directs federal agencies to take certain actions to conserve migratory birds in the furtherance of 

the obligations of the U.S. under the migratory bird conventions and Migratory Bird Treaty Act. It also 

directs agencies to enter into a Memorandum of Understanding (MOU) with the USFWS that outlines 

measures that will be utilized to ensure migratory bird conservation in conjunction with carrying out 

agency missions. In their 2010 MOU, the BLM agreed to evaluate effects of their actions on migratory 

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birds during the NEPA process and identify where take reasonably attributable to agency actions may 

have a measurable adverse effect on migratory bird populations, focusing first on species of concern, 

priority habitats, and key risk factors. In coordination with the USFWS, BLM would develop 

conservation measures and ensure monitoring of the effectiveness of conservation measures to minimize, 

reduce or avoid unintentional take (BLM 2010b). 

Federal Land Policy and Management Act 

The FLPMA authorizes the designation of ACECs to protect and prevent irreparable damage to fish and 

wildlife, and other resources. The Act places fish and wildlife on an equal footing with other traditional 

land uses. It requires consideration of fish and wildlife resources before approval of land exchanges. 

2.7.3 Resource Indicators 

The conditions that are established in the discussions below provide a baseline for wildlife and SSSrelated values, which the impact analysis will be based on. The following indicators, along with 

qualitative discussions, will be used to evaluate impacts associated with management decisions in the 

BSWI Draft RMP/EIS. Because monitoring is typically limited in scope for any given species or habitat, 

few quantitative indicators are possible. Acres of habitat type, (e.g., caribou calving habitat or raptor 

nesting habitat), is the primary indicator by which the impacts of each alternative will be assessed. 

“Wildlife habitat,” as used in the indicators below, refers to all land that may support wildlife, regardless 

of its condition or quality. As developed areas support some species of wildlife (e.g., bats in mine 

buildings), the analysis assumes that the entire planning area provides some type of wildlife habitat. 

• Areas where land uses that could result in adverse impacts to wildlife habitat connectivity 

between known and/or protected habitat are not permitted, as measured by number, size (acres), 

and/or location of connectivity corridor(s) and the management measures associated with these 

geographic areas (e.g., mineral entry, ROW). 

• Riparian areas (defined as areas within 300 feet of streams) in the planning area. 

• Riparian areas open to locatable and salable mineral development in areas of medium to high 

mineral potential, as measured by overlap of riparian areas with areas of medium to high mineral 

potential. 

• Areas where land uses that could result in adverse impacts to nesting raptors are not permitted, as 

measured by the management measures associated with these geographic areas. 

• Acres of the planning area in which there are no restrictions on mineral development, commercial 

woodland harvest, ROWs, and OHV use. 

• Acres of the planning area in which there are no restrictions on mineral development, commercial 

woodland harvest, ROWs, and OHV use, that overlap riparian areas; caribou, moose, wood bison, 

and muskox ranges; Audubon Important Bird Areas; and Innoko Bottoms. 

• Acres of the planning area covered by protections that target key wildlife habitat: connectivity 

corridors, Innoko Bottoms, riparian areas, caribou and moose calving and wintering areas, moose 

and caribou crucial winter habitat. 

• Acres of land acquisitions and disposal in the planning area. 

• Acres of land acquisitions and disposals that overlap riparian areas, the Innoko Bottoms Priority 

Wildlife Habitat Area, Audubon Important Bird Areas, caribou and moose calving and wintering 

areas, potential caribou migration habitat, wood bison range, and muskox range. 

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• Riparian areas protected as high-value watersheds (HVWs) that overlap caribou, moose, wood 

bison, and muskox ranges; Audubon Important Bird Areas; Innoko Bottoms. 

• Acres of the planning area within Travel Management Areas (TMAs) and the management 

measures associated with these geographic areas. 

• Acres of caribou habitat in planning area with limitations on OHV use. 

• Acres of the planning area within TMAs and the management measures associated with these 

geographic areas. 

• Acres of Visual Resource Management (VRM) Class I and II that overlap riparian areas; caribou, 

moose, wood bison, and muskox ranges; Audubon Important Bird Areas; and Innoko Bottoms. 

• Acres of lands managed for wilderness characteristics that overlap riparian areas; caribou, moose, 

wood bison, and muskox ranges; Audubon Important Bird Areas; and Innoko Bottoms 

• Acres of lands designated as ACECs that overlap riparian areas; caribou, moose, wood bison, and 

muskox ranges; Audubon Important Bird Areas; and Innoko Bottoms. 

• Acres of lands within WSR corridors that overlap riparian areas; caribou, moose, wood bison, and 

muskox ranges; Audubon Important Bird Areas; and Innoko Bottoms. 

• Acres of migratory bird habitat covered by seasonal use restrictions 

2.7.4 Current Conditions – Wildlife Species 

Information on current conditions of wildlife species in the planning area is most extensive for species 

that are the focus of monitoring and management. Important species for game management and 

subsistence uses within the planning area include muskox (Ovibos moschatus), caribou (Rangifer 

tarandus), moose (Alces alces), wood bison (Bison bison athabascae), brown bears (Ursus arctos), black 

bears (Ursus americanas), and furbearers (wolf [Canis lupus], wolverine [Gulo gulo], mink [Neovison 

vison], muskrat [Ondatra zibethicus], hoary marmot [Marmota caligata], beaver [Castor canadensis], red 

fox [Vulpes vulpes], river otter [Lontra canadensis], weasel [Mustela sp.], lynx [Lynx canadensis], and 

marten [Martes americana]), as well as marine mammals (seals, Pacific walrus [Odobenus rosmarus 

divergens],and beluga whale [Delphinapterus leucas]), and waterfowl. These species are important for 

purposes of subsistence and sport hunting, and their presence as a whole is a sign of biological diversity 

and ecological health (BLM 2015a). 

Monitoring and management of game species in the planning area supports the State of Alaska’s wildlife 

population management objectives. Efforts have been made over the past 20 years to inventory and 

monitor population, distribution, and habitat of some key wildlife populations (moose, caribou, muskox, 

waterfowl, land birds). Most monitoring is conducted in conjunction and cooperation with the ADF&G. 

The planning area encompasses, wholly or in part, Wildlife Management Units (Units) 18, 19A, 19B, 

19C, 19D, 20C, 21A, 21D, 21E, and 22A, as discussed in Section 5.2, Subsistence, and shown on Map 

3.5.2-1 of the BSWI Draft RMP/EIS. 

Table 2.7.4-1 presents a list of amphibian and mammal species known to occur in the planning area. 

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Table 2.7.4-1. Native Amphibian and Mammal Species in the Planning Area 

Common Name Scientific Name 

Amphibian 

Wood frog Rana sylvatica 

Large land mammals 

Black bear Ursus americanus 

Brown bear Ursus arctos 

Caribou Rangifer tarandus granti 

Dall sheep Ovis dalli dalli 

Moose Alces alces 

Muskox Ovibos moschatus 

Plains bison (nonnative game species managed by the State of Alaska) Bison bison bison 

Wood bison (ESA threatened / Section 10(j) population) Bison bison athabascae 

Small land mammals 

Alaskan (tundra) hare Lepus othus 

Arctic fox Alopex lagopus 

Arctic ground squirrel Spermophilus parryii 

Arctic shrew Sorex arcticus 

Beaver Castor canadensis 

Brown lemming Lemmus sibiricus 

Collared lemming Dicrostonyx torquetus 

Coyote Canis latrans 

Dusky shrew Sorex monticolus 

Ermine Mustela erminea 

Gray wolf Canis lupus 

Hoary marmot Marmota caligata 

Least weasel Mustela rivalis 

Little brown bat Myotis lucifugus 

Lynx Lynx canadensis 

Marten Martes americana 

Masked shrew Sorex cinereus 

Meadow jumping mouse Zapus hudsonius 

Meadow vole Microtus pennsylvanicus 

Mink Mustela vison 

Muskrat Ondatra zibethicus 

Northern bog lemming Synaptomys borealis 

Northern red-backed vole Clethrionomys rutilus 

Porcupine Erethizon dorsatum 

Pygmy shrew Microsorex boyi 

Red fox Vulpes vulpes 

Red squirrel Tamiasciurus hudsonicus 

River otter Lontra canadensis 

Singing vole Microtus gregalis 

Snowshoe hare Lepus americanus 

Tundra shrew Sorex tudrensis 

Tundra vole Microtus oeconomus 

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Common Name Scientific Name 

Wolverine Gulo gulo 

Marine mammals-adjacent to coastal areas 

Bearded seal (Threatened) Erignathus barbatus 

Beluga whale Delphinapterus leucas 

Harbor seal Phoca vitulina 

Northern fur seal Callortinus ursinus 

Ribbon seal Phoca fasciata 

Ringed seal (Threatened status was overturned but is currently under 

appeal) 

Phoca hispide 

Spotted seal Phoca largha 

Steller sea lion (Western DPS – Endangered) Eumetopias jubatus 

Walrus Odobenus rosmarus 

DPS = distinct population segment 

Mammals 

BLM Sensitive Species –Mammals 

The BLM has utilized the ranking system developed by the Alaska Natural Heritage Program and The 

Nature Conservancy, plus an international network of natural Heritage Programs and Conservation 

Database Centers, which assess state and global rarity, for assistance in developing Special Status and 

sensitive species lists for Alaskan plants and animals. 

There is only one BLM sensitive mammal species known or likely to occur within the planning area: the 

Alaskan hare (2010 BLM Alaska Sensitive Species List [IM AK-2010-018]). The complete list of BLM 

Alaska sensitive species is found in Appendix A, BLM Alaska Sensitive Species. A brief description of 

this species is below, followed by brief descriptions of other important terrestrial mammals that occur in 

the planning area. 

Alaskan Hare 

The Alaskan hare, also called the tundra hare, is found only in western Alaska and the Seward Peninsula 

in open and upland tundra areas and is larger than the more widely distributed snowshoe hare, although 

both species have grey-brown fur in summer and turn white in winter (ADF&G 1994). Alaskan hares are 

found in open and alpine tundra habitats, in areas with dwarf willow, grasses sedges and heath, its main 

food sources (Murray and Smith 2008). It occupies habitats from sea level to 2,100 feet (Flux and 

Angermann 1990), and its range includes the southern Nulato hills, including lands managed by BLM 

within the planning area. The total size of the current population is not known; however, it is thought to 

be stable and healthy (Murray and Smith 2008). Habitat loss has been identified as a threat to Southern 

populations of the species, with climate change a possible factor, although complete data are lacking 

(Murray and Smith 2008). There are currently no conservation measures in place, and there is no closed 

season and no limit for the harvest of Alaskan hares throughout the planning area (ADF&G 2018c). 

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Other Terrestrial Mammals 

Caribou and Reindeer 

Two major caribou herds depend on habitats within the planning area for either winter or summer ranges 

and during seasonal migrations; the Western Arctic Caribou Herd (WACH), and the Mulchatna Caribou 

Herd (MCH) (Map 3.2.7-4 of the BSWI Draft RMP/EIS). The Kilbuck Caribou Herd (KCH) has been a 

distinct population in the past but has been assimilated by the larger MCH. The relatively small Beaver 

Mountain, Sunshine Mountain, Farewell-Big River and Rainy Pass and Tonzona caribou herds in the 

McGrath area also range within the planning area but use relatively small portions of BLM-managed 

public lands within their range (Seavoy 2011). Caribou herd populations are naturally cyclic in nature, 

with the timing of decline and increases and population size being difficult to predict. Overhunting, 

varying weather patterns, population density, predation by wolves and grizzly bears, and disease 

outbreaks influence population size (ADF&G 2015a). 

Alaska reindeer, also known as Chukotkan reindeer, are domesticated caribou (Rangifer tarandus granti) 

that exist as different subspecies. They were introduced to Alaska from Siberia, Russia over 100 years 

ago. Reindeer have frequently escaped and joined wild caribou herds in Alaska, and wildlife biologists 

have had concerns that interbreeding may reduce the fitness of caribou herds. However, studies have 

shown that genetic differences between wild caribou and domestic reindeer in Alaska are high, indicating 

limited gene flow between them and data has shown that major adverse effects of reindeer interbreeding 

with caribou have not occurred (Cronin and Patton 2002). 

Western Arctic Caribou Herd 

The WACH, the largest caribou herd in the state, migrates into the northern portions of the planning area 

(Units 22A and 21D) in mid to late winter. Winter ranges of the herd extend south of Unalakleet in some 

years, and historically, as far south as St. Michael (Western Arctic Caribou Herd Working Group 2011), 

although in some years since 1996, much of the WACH has wintered on the eastern half of the Seward 

Peninsula, outside the planning area (ADF&G 2011). Caribou from this herd are an important subsistence 

species for rural residents as well as game for sport hunters. Factors that influence the WACH population 

size include human harvest (sport and subsistence), predation, environmental contaminants, range 

degradation, weather events, resource development and road construction, and disease. The WACH range 

condition has not been monitored, however, satellite collar location data shown caribou avoiding winter 

range habitat burned by wildfire (Joly et al. 2007; Joly et al. 2009). In addition, winter icing events caused 

by rain on existing snow packs have been documented in recent years, causing high, localized mortality of 

the herd. 

The WACH population is currently in decline, although the rate of decline seems to have eased recently. 

A population survey conducted in 2016 places the herd population at 201,000 (ADF&G 2016d). The 

previous estimate of 235,000 animals was made in July 2013 (ADF&G 2014a), which is lower than the 

325,000 caribou estimated in the 2011 census, and down from the peak of 490,000 animals in 2003 

(ADF&G 2014a). The management objective is to manage for a healthy population using strategies 

adapted to population levels and trends while recognizing that caribou numbers naturally fluctuate 

(ADF&G 2015a). 

Caribou calving range and winter range for both the WACH and the MCH are recognized as the most 

sensitive habitats, and protective management should be considered for all BLM-managed public lands 

within these habitats. These herds are widely migratory, and seasonal habitats that are important to the 

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herds will vary over time. Management decisions will need to account for this variability to be effective 

and maintain the viability of these herds. 

Mulchatna Caribou Herd 

Over the past 30 years, the MCH has made dramatic changes in its range, splitting into two distinct east 

and west sub-herds on both summer and winter range, with total range encompassing more than 60,000 

square miles (Woolington 2011). 

The MCH ranges south of the Kuskokwim River and extends to the coasts of Bristol and Kuskokwim 

bays; however, portions of the herd’s calving areas and migration habitats are within the northern portions 

of the planning area (ADF&G 2011). BLM works cooperatively with ADF&G and USFWS Togiak NWR 

to monitor the movements and distribution of the MCH. The management objective for the herd is to 

maintain a population of 30,000 to 80,000 caribou, with a minimum bull: cow ratio of 35:100, and to 

manage the herd for maximum opportunity to hunt caribou (Woolington 2011). 

Kilbuck Caribou Herd 

Historically, the KCH range was located in the Kilbuck and Kuskokwim Mountains southeast of Bethel. 

Their range included the western portion of Units 19B and 17B that includes portions of current BLMmanaged public lands within the planning area. However, since 1994, large numbers of the MCH have 

expanded their range into this area and have essentially assimilated the KCH (ADF&G 2011). These 

caribou herds are, therefore, managed as one in Unit 18, which includes portions of BLM-managed public 

lands in the planning area within its range. 

Beaver Mountains, Sunshine Mountains, Farewell-Big River and Rainy Pass, Tonzona Caribou Herds 

Five relatively small caribou herds exist in the McGrath area, and include the Beaver Mountains, 

Sunshine Mountains, Farewell-Big River, Rainy Pass, and Tonzona herds, all of which are distinct from 

the much larger MCH. These herds combined total annual range is within the drainages of the 

Kuskokwim River in Unit 19, the Innoko River drainage in Unit 21A, and between the Iditarod and 

Innoko drainages and the Yukon River downstream to Blackburn Creek in Unit 21E, all within the 

planning area, but with only small portions of the range on BLM-managed public lands. Current 

estimated population sizes of these herds are based on incidental observations and hunter harvest 

information; although a minimum population count was last completed in 2007 for the Sunshine and 

Beaver Mountain herds. The most current minimum population size estimates include: Beaver Mountain: 

100−150; Sunshine Mountain: 100−125 animals (Seavoy 2011). Surveys in 2005 estimated 1,500−2,000

in the Rainy Pass herd, 750−1,500 in the Farewell-Big River herd, and 750−1,000 in the Tonzona herd, 

although hunter reports suggested far fewer animals were present during 2008−2009 years (Seavoy 2011). 

Lichen habitat on winter ranges for all five herds is abundant and not thought to be limiting population 

size (Seavoy 2011). Both sport and subsistence harvest of the herds is low, with minimal population 

estimate surveys conducted. 

The management objectives are as follows (ADF&G 2015a): 

• Farewell-Big River Herd – provide for a harvest of up to 100 bull caribou. 

• Rainy Pass Herd – provide for a harvest of up to 75 bull caribou. 

• Sunshine and Beaver Mountains Herds – provide for a combined harvest of up to 25 caribou. 

• Tonzona Herd – provide for a harvest of up to 50 caribou. 

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Moose 

Moose occur throughout the planning area in lower elevations, along major rivers and recently burned 

areas that have generated stands of willow, aspen and birch shrubs. Map 3.2.7-5 of the BSWI Draft 

RMP/EIS shows the moose habitat within the planning area. They forage on early successional trees and 

shrubs, including aspen and birch, and in particular, willow. During fall and early winter, mid- to highelevation shrub and open spruce habitats support higher densities of moose. As snow accumulates through 

winter, moose tend to concentrate at lower elevations and especially along riparian areas of creeks and 

rivers. In summer, moose are more widely dispersed, and pregnant cows often travel long distances to 

low-elevation areas with abundant wetlands for calving and summer. 

Populations vary considerably between game management units and even major watersheds in the 

planning area, as numbers are affected greatly by predation and winter severity. In areas with little 

predation and low to moderate snowfalls, and preferred willow shrub habitats, moose populations can be 

relatively high. In some areas, moose populations are limited by the quality and quantity of food 

resources, especially in the winter when snow depth limits access to browse. Moose populations are also 

limited by predation (wolves, black and brown bear), hunting, and severe weather (Crouse and Crouse 

2008). 

Unit 18 includes BLM-managed public lands north of the Yukon River between Marshal and Russian 

Mission. Moose densities in this area (Paimiut Slough area), much of which is BLM-managed public 

lands, grew from an estimate of 3,614 moose in 2006 (± 18.1 percent) to 5,597 moose in 2013 (± 14.9 

percent) (Perry 2014). The density of this moose population has changed from 2.3 moose/mi2 in 2006 to 

3.6 moose/mi2 in 2013. Moose composition surveys in 2013 revealed 72 calves per 100 cows, and 41 bull 

moose per 100 cows in the Lower Kuskokwim portion of the unit (Perry 2014). Population management 

for the unit focuses on providing moose for consumptive human harvest. Since 2010, BLM has worked 

cooperatively with the USFWS, Innoko NWR to provide subsistence permits for the Paimiut Slough area 

and the adjacent Unit 21E for a winter moose subsistence hunt. The moose population in the Middle 

Yukon count area grew from an estimate of 418 moose in 2002 (± 22.4 percent) to 2,748 moose in 2012 

(± 16.6 percent) (Perry 2014). The density of this moose population has changed from 0.4 moose/mi2 in 

2002 to 2.4 moose/mi2 in 2012. 

In Unit 19, BLM-managed public lands are largely north of the Kuskokwim River from Aniak to Stony 

River, and south of the Kuskokwim River from McGrath to Lime village, largely in Units 19A and 19D. 

Moose population estimation surveys have been conducted by ADF&G in portions of Unit 19A five times 

since February 2005 (Seavoy 2014). In the Holitna count area, estimated moose densities ranged from 

0.44 observable moose/mi2 in 2008 (±28 percent) to 0.25 observable moose/mi2 in 2011 (±18 percent). 

Analysis of the 2011 survey data including sightability correction factors produced a density of 0.43 total 

moose/mi2 (±36 percent). In the Aniak count area, estimated moose densities ranged from 0.39 observable 

moose/mi2 in 2006 (±15 percent) to 0.33 observable moose/mi2 in 2011 (±15 percent). Confidence 

intervals overlap for these surveys and no trend is detected in either area. Moose population abundance 

has not been measured in Unit 19B, but densities are likely at or below those found in Unit 19A. 

Composition counts in the Holitna count area in 2001 indicated only 6 bulls per 100 cows and 8 calves 

per 100 cows. In the Aniak count area during a 2004 survey there were 20 bulls per 100 cows and 23 

calves per 100 cows (Seavoy 2014). These low density and productivity numbers prompted ADF&G to 

conduct aerial wolf control in unit 19A in March 2004, January 2006, and May 2006, and in May 2009, 

reauthorized through 2014 (Seavoy 2014). During the most recent surveys (2013), there were 55 bulls per 

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100 cows and 50 calves per 100 cows in the Holitna count area and 38 bulls per 100 cows and 41 calves 

per 100 cows in the Aniak count area (Seavoy 2014). 

Spring twinning surveys in unit 19A in the Aniak trend count area in 2008 recorded 100 percent of cows 

with calves had twins, indicating that habitat is of good quality (Seavoy 2010). The Central Kuskokwim 

Working Group, made up of multiple users, developed the Central Kuskokwim Moose Management plan, 

which was finalized in 2004. The group works with ADF&G, USFWS, and BLM to promote an increase 

in moose population for the area through increased harvest reporting, reducing predation through predator 

control, minimizing illegal harvest of cows, and informing hunters on current moose population 

information and using survey results and traditional knowledge in moose management decisions (Seavoy 

2010). 

Wolf control was authorized in the Bear Control Focus Area around McGrath (Unit 19D) in 1995, 2000, 

2001, 2003, 2006 and reauthorized in 2009 through 2014 (Seavoy 2014). The estimated population of 

moose in this area ranged from 440 moose in 2001 to 658 moose in 2011 (Seavoy 2014). In the larger 

surrounding area, the lower Kuskokwim moose management area, population estimates ranged from 868 

in 2001 to 1,820 in 2009. 

Moose population estimation surveys have not been conducted in Unit 19C. However, moose numbers in 

Unit 19C are likely similar to those of the late 1980s and early 1990s (Savoy 2014). Trend count data 

indicate 134 moose/hour were detected in 2009 and 110 moose/hour were detected in 2010. These 

detection rates are similar to those during 1987–1997 when an average of 150 moose/hour were detected 

(range 100–194 moose/hour). 

ADF&G estimated 3,800 moose (0.6 moose/mi2) in Unit 20C outside Denali National Park and Preserve 

during 2011 and 2012, based on a smaller moose survey area in eastern Unit 20C in November 2011. 

In Unit 21, BLM-managed public lands are in Units 21A and 21E in the Yukon and Innoko River area. 

Moose densities in 21A in 2009 were 0.50 moose/mi2, and in 21E, 1.2 moose/mi2 (Pierce and Seavoy 

2008). Fall composition counts in 2009 indicated 36−64 bulls:100 cows, and 8−40 calves per 100 cows in 

Unit 21A, and composition counts in 2010 in 21E indicated 32 bulls:100 cows and 18 calves:100 cows 

(Pierce and Seavoy 2008). Twinning rates in 21E in spring 2010 were 50 percent (Pierce and Seavoy 

2008). In 2008, the BLM cooperated with ADF&G, USFWS, and the Innoko NWR on a moose satellite 

collaring project to determine moose movement, habitat use, and survival in Units 21A and 21E. The 

study that concluded in 2013 documents seasonal movements between the lowlands and adjacent hills 

(ADF&G 2014b). 

In Unit 22, BLM-managed public lands are in the southern Nulato Hills from the mouth of the Golsovia 

River north to the Shaktoolik River, and in the Unalakleet Wild River Corridor above the Chirosky River. 

BLM has worked cooperatively with ADF&G from 2003 to 2012 to survey moose in the Unalakleet 

watershed in Unit 22A, within the planning area. Moose populations have been declining since 1995, and 

a complete closure of hunting in the central Unit 22A began in 2005, in an effort to increase the 

population. A limited subsistence-only hunt was initiated in 2009, with a joint State and federal moose 

hunt by permit. In Unit 22A, the 2012 GSPE (geospatial population estimation) survey estimated 545 

observable moose (90 percent confidence interval [CI]: 452–638), 0.23 moose/mi2, 24 calves: 100 adults, 

and a 19 percent recruitment rate (ADF&G 2014b). These results indicate a significant rate of increase in 

the population between the 2003 and 2012 surveys; however, moose densities are very low compared to 

other areas in Alaska, as well as within the planning area. Therefore, limited harvest levels will likely 

remain in place until the 22A moose population increases. 

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In Units 21A and 21E, moose populations appear to be stable (Pierce 2014). The current population 

estimate for Unit 21A is 2,442 observable moose. Because this estimate is not corrected for sightability it 

is a conservative estimate. The current population estimate for all of Unit 21E is 6,959 moose. This is 

below the Unit 21E intensive management objective of at least 9,000 moose (9,000–11,000). 

In Unit 21D, the moose population trend counts during Regulatory Year (RY) 11–RY12 showed a 

generally stable index to abundance in Unit 21D over recent years as previously described (Stout 2014). 

Density estimates in the western Galena GSPE analysis area of Unit 21D also indicated a stable trend. In 

2010 769 moose were classified during the GSPE survey (covering 3,516 mi2 in the upper Bear Creek and 

upper Dulbi River drainages). In the 2011 GSPE survey (which overlapped survey areas sampled in RY01 

and RY04) 5,620 moose were classified. By combining estimates for individual drawing hunt areas in 

Unit 21D, a Unit 21D population of 8,611 observable moose was estimated in RY11. This estimate did 

not change for RY13 because no GSPE surveys were conducted. The population estimate for the total 

area calculated from the 2011 survey was not significantly different (95 percent CI) from the 2001 or 

2004 estimates; however, the 2011 point estimate was lower than 2001 and 2004. The regression analysis 

of the 1987–2011 survey estimates indicated a slight decline (P = 0.08; 95 percent CI). 

In Unit 22A, the 2012 GSPE survey estimated 545 observable moose (90 percent CI: 452–638), 0.23 

moose/mi2, 24 calves: 100 adults, and a 19 percent recruitment rate (ADF&G 2013b). This is a 14 percent 

rate of increase between 2008 and 2012, and current densities (0.23 moose/ mi2) are above what was 

found in the area during the late 1980s. 

Bison 

The two subspecies of bison (wood bison and plains bison) that have been introduced into the planning 

area are closely related. Physical and genetic differences distinguish the two subspecies, although they are 

genetically very similar and have historically interbred when located in the same geographic area (Cronin 

et al. 2013). Maintenance of two genetically distinct subspecies appears to be dependent on preventing 

interbreeding by keeping herds separated geographically (i.e., by distances of 100 miles or more) 

(ADF&G 2007b). The wood bison is the largest surviving native terrestrial mammal in North America. 

Plains bison are smaller and lighter in color than wood bison. Historically, the range of the wood bison 

was generally north of that occupied by the plains bison and included most boreal regions of northern 

Alberta; northeastern British Columbia; a small portion of northwestern Saskatchewan; the western 

Northwest Territories south and west of Great Slave Lake; the Mackenzie River Valley; most of The 

Yukon Territory; and much of interior Alaska (USFWS 2016). 

Map 3.2.7-6 of the BSWI Draft RMP/EIS shows the ranges of wood bison and plains bison within the 

planning area. 

Wood Bison 

Wood bison have historically inhabited large portions of Interior Alaska for approximately 10,000 years, 

but gradually diminished and disappeared from Alaska altogether about 200 years ago (ADF&G 2007b). 

Wood bison were listed as endangered under the ESA in 1969. Their status was changed to threatened in 

2012. The ESA requires a range of protections for listed species and various restrictions on land use to 

protect habitat. Concerns about these protections and restrictions generated opposition to restoring wood 

bison in Alaska. Therefore, ADF&G worked with USFWS to develop a federal rule, which was published 

in 2014 (79 FR 26175), to designate wood bison in Alaska as a nonessential experimental population 

under Section 10(j) of the ESA. This classification status greatly reduced restrictions and gave ADF&G 

primary management responsibility for leading and implementing the restoration effort. 

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In 2015, the ADF&G released 130 wood bison to the wild along the Innoko River near the community of 

Shageluk. About 16 wild born calves were recruited into the population in the summer of 2015. As of 

October 2015, the core range of these wood bison, known as the Lower Yukon/Innoko Rivers Herd, was 

within 30 miles of Shageluk, except for two lone bison that have explored habitats along the Yukon River 

from Russian Mission to Galena. 

Plains Bison 

A population of introduced plains bison has been established in the Farewell area south of the 

Kuskokwim River and west of the Alaska Range (ADF&G 2016e). The bison in the Farewell population 

are descendants of animals that were transplanted from Montana in 1928 to Delta Junction, outside the 

planning area. The Farewell herd inhabits the Farewell area of the drainages flowing into the Kuskokwim 

River upstream of the Lower Kalskag in Units 19C and 19D. The herd was established by a translocation 

of 18 animals from the Delta Bison Herd in 1965 and supplemented by an additional transplant of 20 

bison from the Delta herd in 1968. The Farewell herd is important for conservation because DNA samples 

confirmed this is a pure plains bison strain, unlike many herds in the Lower 48 that have some cattle 

incursions in the genome (ADF&G 2014c). 

Harvest is managed by a drawing permit system. Between 10 and 80 permits were issued annually since 

hunting began in 1972, and annual harvest averaged about 20 animals. The management objective is to 

maintain a minimum population of 300 bison, allowing for an annual harvest of up to 40 bison. Bison 

habitat in the Farewell area is currently maintained by frequent naturally occurring fires. The herd grew 

over the years and numbered about 350 animals by the late 1990s. Then bison numbers began declining 

around 2000; a 2007 survey counted 187 animals. The population most likely decreased because of a 

combination of declines in the quality of their fire driven habitat, and too much harvest of female bison. 

Harvest was reduced to 10 permits each year, and a wildland fire in the area in 2010 rejuvenated the 

habitat and improved the quality of the forage. Numbers began increasing and the 2014 survey counted 

about 400 bison. 

Muskox 

Muskox, an important subsistence species, are found mainly on the Seward Peninsula, but populations are 

increasing and have expanded into previously unoccupied and unsurveyed habitat in the planning area in 

the southern Nulato hills, between Shaktoolik and Unalakleet (BSWI Draft RMP/EIS, Map 3.2.7-6; 

Harper and McCarthy 2017). The most current total population estimate for muskox on the Seward 

Peninsula, adjacent to the planning area is approximately 2,287 animals, including 164 animals found in 

recent surveys within the planning area near Shaktoolik in Units 22A and a portion of Unit 21D (Harper 

and McCarthy 2017). There are currently no muskox hunts in Unit 22A (Harper and McCarthy 2017); 

however, the demand to establish a limited subsistence hunt in the unit is increasing. BLM administers 

permits for a limited subsistence muskox hunt on federal lands in Unit 22B, outside, but adjacent to the 

northern border of the planning area. 

Based on ADF&G survey results, the muskox population on the Seward Peninsula was increasing 

between 1970 and 2007, stable during 2007 to 2010, and then declined between 2010 and 2012 (Harper 

and McCarthy 2017). The population overall was stable between 2012 and 2015 although the core count 

area experienced a decline. The open tundra habitats of the Seward Peninsula and the southern Nulato 

Hills are not considered limiting for muskox. Limiting factors may include predation, nutrition, and 

disease. 

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Dall Sheep 

Dall sheep are found on the north side of the Alaska Range east of the Nenana River, west of the Delta 

controlled use area, outside of, but adjacent to the eastern edge of the planning area (ADF&G 2013c) 

(BSWI Draft RMP/EIS, Map 3.2.7-6). There is an open sport hunting season for sheep in Unit 19, in 

mountainous sheep habitat of the Alaska Range on the eastern boundary of the planning area; however, 

these lands are managed by the State of Alaska or within the Lake Clark National Preserve, and outside 

BLM management. 

Density of sheep observed during the latest ADF&G surveys in 2013 was lower than the last count 2010 

(1.7 and 2.8 sheep/mi2) (ADF&G 2014d). The lower densities were in large part due to fewer lambs, 

which apparently had very poor survival in 2013. The percentage of legal rams identified during 2013 

(5.8 percent) was slightly higher than 2010 (4.8 percent). However, there is no level of precision 

associated with these surveys. The higher percentage of full-curl rams observed was likely due to the fact 

fewer sheep were seen overall in 2013, yet a similar number of full-curl rams. The number of lambs 

observed in 2013 was the lowest recorded since 2008 in these areas. The ewe-like category was also the 

lowest of any survey with 273 in 2013 compared to 491 in 2010. A significant icing event in January 

2013, as well as a very late break-up in May, may have had an adverse impact on ewe-like sheep and 

lambs (ADF&G 2014d). 

Sheep populations are influenced by snow depth, summer drought and predation by wolves, coyotes and 

golden eagles, and populations typically fluctuate irregularly (ADF&G 2013c). Dall sheep have naturally 

low birth rates, and live in difficult high alpine environments, causing naturally low population growth 

rates. Disease is also an important factor as Dall sheep are extremely susceptible to respiratory diseases 

introduced by domestic livestock when domestic sheep and goats are allowed to occupy wild sheep 

ranges (ADF&G 2013c). Domestic sheep and goats are carriers of bacteria that may cause substantial 

wild sheep mortality as a result of respiratory disease. In order to manage domestic sheep and goats to 

sustain wild sheep, it is policy of the BLM to (1) achieve effective separation of BLM-authorized 

domestic sheep or goats from wild sheep on BLM-managed public lands, and (2) to minimize the risk of 

contact between the species (BLM 2016d). 

Brown (Grizzly) Bear 

Brown bears are found throughout the planning area. Biological requirements dictate what parts of their 

home range are preferred at different times of the year. Brown bears are only active for a portion of the 

year, denning within their home ranges from October to April (or longer in the case of females with cubs). 

When not in dens, bears occupy all available habitats within their home range to take advantage of 

seasonally available food sources. Populations and local densities vary depending on the productivity of 

the habitat and seasonal availability of forage and prey. The current condition of brown bear habitat in the 

planning area has not been quantified. For the most part, the habitat is in a natural condition. Although the 

statewide brown bear population is estimated at 30,000 animals (ADF&G 2010a), the number of brown 

bears in the planning area is unknown. However, the ADF&G brown bear management reports for each 

Unit estimate bear densities using an estimate of habitat quality. The latest report (ADF&G 2015b) 

estimated 350-400 brown bears in Units 21B, 21C, and 21D, assuming 25 bears/1,000mi2 in the highest 

density bear habitat and 10 bears/1,000km2 in the remainder of the reporting area. In Unit 21D the best 

bear habitat is in the Nulato Hills (ADF&G 2015b). 

Brown bears are an important traditional subsistence species, and many are taken annually through sport 

and subsistence hunts in the planning area. Brown bears are capable predators of newborn moose and 

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caribou and can also kill and eat healthy adults of these species (ADF&G 2010a). ADF&G removed four 

brown bears during a predator control program conducted in May 2013, in an effort to decrease moose 

calf predation by bears, and thereby, increase moose populations in Unit 19A (ADF&G 2015c). 

Brown bear populations are stable or increasing within the planning area. However, bears are predatory 

on local moose populations and the Alaska Board of Game has chosen to give subsistence and sport 

hunting of moose a higher priority than predators like wolves and bears (OSM 2016). Liberal hunting 

regulations in the planning area reflect a management effort to reduce bear numbers to increase moose 

and caribou populations. 

Black Bear 

Black bears are found throughout the planning area. Statewide, an estimated 100,000 black bear inhabit 

Alaska (ADF&G 2010b), although the number of black bears and population trends are unknown for the 

planning area. However, the ADF&G black bear management reports for each Unit estimate bear 

densities using an estimate of habitat quality. The latest report (ADF&G 2014e) reports the population for 

the entire management area [Units 19A, 19B, 19C, 19D, 21A, and 21E] is estimated to be 8,300–16,600 

black bears, based on overall densities of 15–30 bears/100 mi2. The population has probably been stable 

or slowly increasing since 1995, based on local observations (ADF&G 2014e). 

Black bears are opportunistic and depend on both plant and animal food sources. In the spring, freshly 

sprouted vegetation, including grass, horsetails, and poplar buds, is an important food source for bears. 

Bears readily scavenge winter-killed animals, and in some areas black bears are effective predators on 

newborn moose calves. 

However, bears are predatory on local moose populations, which have subsistence and sport hunting 

priority over predators like wolves and bears (OSM 2016). Liberal hunting regulations in the planning 

area reflect a management to reduce bear numbers to increase moose and caribou populations. ADF&G 

began predator control of black bears in Unit 19A in 2013 in an effort to increase moose populations by 

reducing predation of moose calves by black bears. ADF&G removed 84 black bears during a predator 

control program conducted in May 2013, in an effort to decrease moose calf predation by bears and 

thereby increase moose populations in Unit 19A (ADF&G 2015c). Predator control for brown bears and 

black bears in 19A occurred in May 2013 and May 2014 for both species. The 2014 removal was 40 

independent black bears and 9 independent brown bears. 

Gray Wolf 

Wolves are managed by the State of Alaska as both furbearers and big game (ADF&G 2016f). Wolves 

occur throughout mainland Alaska. Presently wolves are common over much of the state with densities as 

high as one wolf per 25 square miles in favorable habitats with abundant prey. In general, wolves use a 

wide variety of habitats and are found throughout the planning area but are more abundant in areas where 

numbers of prey species are greater. They are carnivorous, and in most of Alaska, moose and/or caribou 

are their primary food. During summer, small mammals including voles, lemmings, ground squirrels, 

snowshoe hares, beaver and occasionally birds and fish supplement their diet (ADF&G 2013b). Wolf 

populations are limited by prey species abundance, and in some areas by human harvest (e.g., McGrath 

area) or direct control activities. Wolves have become more numerous on the Seward Peninsula, 

especially in areas occupied by wintering caribou from the Western Arctic caribou herd and muskox 

herds that have expanded their historic range eastward (ADF&G 2013b). Wolves are a natural predator on 

moose and caribou, and wolf control efforts in portions of Units 19 and 21 have been carried out by 

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ADF&G in recent years to increase ungulate populations (ADF&G 2015a). The ADF&G is currently 

conducting active Intensive Management programs in Units 19A and 19D (ADF&G 2016g). In Unit 21E 

an Intensive Management program is authorized but would occur only if moose abundance dropped 

below one moose per square mile, which has not occurred. These efforts are often controversial and 

sometimes have inconclusive results (ADF&G 2015a). 

Furbearers 

Furbearers include those species of mammals that are routinely sought by licensed trappers who place 

commercial value on the animals’ pelts or are considered subsistence species and are trapped for

traditional uses. Furbearers found in the planning area include beaver, red fox, lynx, marten, mink, 

muskrat, marmot, river otter, coyote, wolverine, weasel, and wolf (ADF&G 2013b). Coyotes are 

uncommon in the planning area but are increasing in portions of Interior and western Alaska. Wolves are 

discussed above. Most furbearer harvest (by both hunting and trapping) in the planning area is by 

subsistence and recreational users or is done opportunistically while engaged in other activities. Definitive 

species population and distribution information is not available, and consequently, ADF&G wildlife 

biologists rely upon annual trapper harvest reports and opinions, and field observations by department 

personnel to gauge furbearer status and trend information. The price paid for animal pelts is the greatest 

determining factor in trapper harvest effort, and subsequently affects harvest. Reporting of harvest is 

required for only a few species, those required to be sealed (marked with metal tag) by ADF&G 

employees (e.g., lynx, river otter, wolf, and wolverine). 

The ADF&G collects and reports information regarding furbearer management and harvest. The 

information below has been summarized from the latest ADF&G reports: 

• The Furbearer Management Report of Survey-inventory Activities, 1 July 2009–30 June 2012 

(ADF&G 2013b) provides detailed information for each species every 2 or 3 years by the area 

management biologists for game management units in their areas. 

• The Alaska Trapper Report (Parr 2016) presents data collected from state questionnaire sent to 

active trappers. 

Wolverine 

Wolverines are generally distributed throughout Alaska and the planning area (ADF&G 2013b). 

Wolverines are a wide-ranging species with populations that are naturally at low densities and require 

large expanses of wilderness. The primary natural mortality factors are starvation, being killed by larger 

predators, primarily wolves, and by other wolverines. Wolverines are vulnerable to harvest and because 

of their limited reproductive capability can be sensitive to overharvest (ADF&G 2008). Sustainable 

harvests in heavily trapped areas of Alaska depend on the presence of refugia as the source population of 

wolverines. They have tremendous physical endurance, with movements of 40 miles in a day documented 

(ADF&G 2013b). In general, males have larger home ranges that females, females not accompanied by 

kits have larger ranges compared to females with kits, and home range size and use changes with season 

of the year. In Alaska, resident male home range sizes are large, ranging between 200−260 square miles. 

Resident females have home ranges as large as 115 square miles. Home range size and use patterns are 

thought to be a response to the availability of resources being food or for adult females the presence of 

persistent snow cover for denning. Studies in southcentral Alaska found that wolverines preferred higher 

elevations during the summer and lower elevations during the winter due to varying food availability 

(ADF&G 2013b). Data indicate that wolverines will move long distances in short periods of time to take 

advantage of these resource sites. Population levels within the planning area are unknown; however, 

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wolverine numbers are naturally low, and as human recreational pursuits expand into more remote areas, 

greater protection of natal denning areas may become an important management issue. Wolverine pelts 

are an important subsistence resource in the planning area. 

In Alaska, wolverines are classified as both big game and as a furbearer, and in the planning area open 

seasons are between November and February, with no limits on numbers taken (ADF&G 2016g). 

Wolverines were reported by trappers as scarce with no information regarding the trend (Parr 2016). 

River Otter 

The river otter is widely distributed across Interior Alaska. Although river otters are long-lived (20 or 

more years), they do not breed until two or more years old, and produce only two or three pups annually, 

keeping their numbers naturally low (Solf and Golden 2013) No population estimates or trend analysis for 

river otters in the planning area are available. There is no limit on trapping otters from November to 

March within the planning area (ADF&G 2016g). Harvest of otters is relatively low within the planning 

area, with reported harvest averaging 35 otter per year in Unit 19 and 15 per year in Unit 21 through the 

1998−2009 regulatory years (ADF&G 2013b). Because of their strong terrestrial-aquatic association, 

river otters are especially vulnerable to human impacts to their habitat, such as mining. River otter were 

reported by trappers as scarce with no change in the trend (Parr 2016). 

Beaver 

The beaver is widely distributed and common throughout forested areas of Alaska, although current 

populations are unknown. Beavers are ecosystem engineers that modify streams and surrounding 

woodlands and provide habitat for numerous other species. Modifications by beavers can improve the 

health of riparian habitats, raise the water table, improve downstream water quality, and create or improve 

habitat for fish, amphibians, invertebrates, birds, and large land mammals (ADF&G 2018d). Beaver is an 

important subsistence species and is trapped for both its fur and meat in the planning area, although 

reported harvest has declined in the past decade, due to lower pelt prices (Harper and McCarthy 2013). 

Few non-residents trap beaver. The trapping season is from September to June. There is no limit on take 

by trapping within all game management units in the planning area. Sealing of beaver is not required so 

current harvest information is limited (ADF&G 2016g). Beaver in the planning area were reported by 

trappers as abundant with no change regarding the trend (Parr 2016). 

Marten 

Marten are found throughout forested habitats of Interior Alaska and within the planning area. Marten are 

the focus of most trapping effort in Units 19 and 21 due to their fur value. Sealing is not required, and so 

definite harvest figures are not known. There is no limit on trapping in Units 21 and 19, with an open 

season from November through February annually (ADF&G 2016g). Marten in the planning area were 

reported by trappers as common with no change regarding the trend (Parr 2016). 

Coyote 

Coyote range throughout the planning area. Coyotes were first noted in the state shortly after the turn of 

the twentieth century. Populations were first reported on the mainland of southeastern Alaska, and then 

slowly expanded northward into the upper Tanana Valley from which they radiated in all directions and 

into the planning area. A statewide population peak occurred around 1940; since that time, numbers have 

declined in many areas (ADF&G 2007c). ADF&G does not document coyote harvest or conduct 

population surveys in a regular manner; therefore, current populations are unknown. Coyote in the 

planning area were reported by trappers as scarce with no information regarding the trend (Parr 2016). 

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Red Fox 

Red fox range widely throughout Alaska except for some southeastern islands, the western Aleutians, and 

Prince William Sound. Population trend is unknown, but the population is estimated to be abundant and 

bag limits are unlimited, with seasons between November and April (ADF&G 2016g). Red fox can also 

be a vector for the transmission of rabies, which is caused by a virus spread in the saliva of infected 

animals. All warm-blooded mammals can be infected. In Alaska, rabies occurs most often in arctic fox 

and red fox from the north coast, west coast and Alaska Peninsula (ADF&G 2013b). Red fox in the 

planning area were reported by trappers as scarce with no information regarding the trend (Parr 2016). 

Muskrat 

Muskrat are found throughout Alaska’s mainland, except the Arctic Slope north of the Brooks Range, and 

are common throughout the planning area. Muskrat habitat is most abundant in the broad floodplains and 

deltas of major rivers and in marshy areas dotted with numerous small lakes - habitats common in the 

planning area. No specific information is available on population sizes or trends for muskrat, and bag 

limits from trapping are unlimited (ADF&G 2016g). Muskrats in the planning area were reported by 

trappers as scarce with no change regarding the trend (Parr 2016). 

Mink 

Mink are found throughout Alaska. Mink are aggressive carnivores and will consume virtually everything 

of manageable size that they can capture (ADF&G 2013b). Little is known of the status of mink in the 

planning area. Mink are found in close association with water, preferring saltwater beaches and riparian 

habitats of lakeshores, marshes, and stream banks (ADF&G 2013b). Within Units 19 and 21, the trapping 

season for mink is November to February and the bag limit is unlimited (ADF&G 2016g). Mink in the 

planning area were reported by trappers as scarce with no change regarding the trend (Parr 2016). 

Lynx 

Lynx inhabit much of Alaska's forested terrain and use a variety of habitats, including spruce and 

hardwood forests, and both subalpine and successional communities. The best lynx habitat in Alaska 

occurs where fires or other factors create and maintain a mixture of vegetation types with an abundance of 

early successional growth. This provides the best habitat for snowshoe hares and other small prey. Lynx 

populations fluctuate cyclically and are associated with snowshoe hare population cycles (ADF&G 

2016h). Within Units 19 and 21, the trapping season is November to March and the bag limits for 

trapping lynx are unlimited (ADF&G 2016g). Lynx in the planning area were reported by trappers as 

scarce with no information regarding the trend (Parr 2016). 

The current population numbers for most furbearer species on BLM-managed public lands in the planning 

area are unknown. Habitats remain relatively undisturbed in the planning area, and most populations 

likely fluctuate within normal levels. 

Bats 

The only bat species known to occur in the planning area is the little brown bat. The planning area 

contains Ordivician limestone and dolomite, which locally hosts karst features. In the Hoholitna River 

drainage these include vertical solution cavities and sink holes large enough to be entered, but of 

unknown vertical extent. It is unknown if any of these cavities have been explored or if they are used by 

bats. BSWI Draft RMP/EIS, Map 3.2.7-7, shows the potential bat habitat in the planning area, which is 

the known lode mines, along with areas of geologic areas that may include cave/karst habitat; however, it 

should be noted that bats may occur anywhere in the planning area and are also known to inhabit human 

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structures. There may be additional karst features in other parts of the planning area underlain by 

limestone and dolomite. 

Little brown bats are managed as “unclassified game” in Alaska and there are no seasons or bag limits. 

Bats may only be harassed or killed under the terms of a wildlife nuisance permit issued by the ADF&G. 

This species appears to be uncommon in interior Alaska, but few data are available (Whitaker and 

Lawhead 1992). Colonies ranging in size from 70 (Salcha River; Whitaker and Lawhead 1992) to 200 

(Fairbanks; Rydell et al. 2002) and 461 (White Sulfur Hot Springs, Southeast Alaska; West and Swain 

1999) reported in the literature. They are abundant relative to other bat species documented in Alaska 

(Parker 1996). 

The BLM is required to comply with the Federal Cave Resources Protection Act regarding caves in the 

planning area. Caves on federal lands are managed under 43 CFR, Part 37. These regulations provide 

guidance for identifying, nominating, evaluating, and designating significant cave resources. According to 

the Federal Cave Resources Protection Act, a cave is “any naturally occurring void, cavity, recess, or 

system of interconnected passages which occurs beneath the surface of the earth or within a cliff or ledge 

and which is large enough to permit an individual to enter, whether or not the entrance is naturally formed 

or manmade. Such term shall include any natural pit, sinkhole, or other feature, which is an extension of 

the entrance.”

The following description of the different types of roosting habitat is summarized from the Alaska Zoo 

(2016). The little brown bat occupies three types of roosts (resting places): Day, night, and hibernation 

roosts. Locations of roosts are chosen based on the presence of stable ambient temperatures. Day and 

night roosts are used by active bats and include, but are not limited to, buildings, trees, under rocks, and 

in piles of wood. Day roosts have very little or no light, provide good shelter, and typically have 

southwestern exposures to provide heat for arousal from daily torpor. Night roosts are selected for their 

confined spaces where large concentrations of bats can cluster together to increase the temperature in the 

roost. Night roosts are usually away from day roosts, which may diminish the accumulation of feces at 

day roosts and avoid signaling predators. Day and night roosts are inhabited during spring, summer, and 

fall months, whereas during the winter, hibernacula sites are used. The little brown bat hibernates from 

September/October to April/May. Hibernacula include, but are not limited to, caves, tunnels, abandoned 

mines and similar sites. This species does not show territoriality at roosts and large colonies of as many as 

300,000 bats have been reported in a single roost. 

Tessler and Snively (2014) reported the results of the citizen science-based Alaska Bat Monitoring 

Project, which was initiated in 2004 to investigate the distribution, habitat use, and seasonal ecology of 

the little brown bats in Southcentral, Central, and Western Alaska. As of 2012, reports of bats had come 

in from 252 unique locations across the focus area, including Kotzebue, White Mountain, Saint Michael, 

and the Semidi Islands, which represent significant range extensions for bats in the state. Ninety-seven 

percent of 111 roosts reported were located in human structures. Maternity colonies were identified in 48 

locations, all in human structures. The majority of observations were reported in late July, August, and 

September, but observations were recorded every month of the year. The 25 reports of bats observed 

during the winter months (October to April) were all associated with buildings unless observed flying 

outdoors; no hibernacula in natural substrates were documented. The authors concluded that the timing 

and locations of winter observations imply that bats in the most northerly areas are likely non-migratory 

and overwinter in human structures, while winter observations in Southcentral Alaska suggest both 

migratory and non-migratory behavior. 

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The population size and status of little brown bats in Alaska is unknown (ADF&G 2016j). They are 

apparently widespread but in low numbers. Threats include disease (ADF&G 2016j), habitat loss (Parker 

1996; Parker et al. 1996), use of pesticides (Fenton and Barclay 1980; Agosta 2002), use of cyanide in 

mining (Helfferich 1991), and destruction of caves and shafts associated with karst topography (Agosta 

2002). 

Hibernating bats are sensitive to human disturbance (Thomas 1995). Special precautions should be taken 

when mine and cave surveys are conducted during breeding periods and winter hibernation. Disturbance 

of breeding colonies can cause young to lose their grasp and fall to their death. Disturbance during 

hibernation can cause bats to use up stored fat reserves and starve to death. 

Currently, insectivorous bats in North America are experiencing sudden and dramatic population declines 

resulting from two new threats: large-scale wind energy development is causing unprecedented mortality 

in several migratory tree-dwelling bat species in eastern North America; and White Nose Syndrome 

(WNS), a devastating fungal infection that has contributed to the death of 5–6 million bats in northeastern 

North America since 2006 (ADF&G 2016j). Hibernating bats with WNS arouse more frequently and for 

longer than normal, causing them to burn their winter fat reserves prematurely and resulting in death from 

starvation. Although bat-to-bat contact is believed to be the primary means of transmission, humans may 

also play a role by spreading fungal spores on clothes and caving gear. WNS has not been documented in 

Alaska but was confirmed in Washington State in 2016. 

The lack of information on overwintering habits of bats in Alaska, as well as the absence of any baseline 

data on population sizes and trends will complicate the ability to detect WNS and monitor its impacts 

should the disease reach Alaska. The extent to which these threats may impact the conservation or 

persistence of bats in Alaska is unknown because information on the distribution, habitat associations, 

and ecology of Alaska’s bats is lacking.

Birds 

A total of 158 species of birds are known to occur in the planning area (Table 2.7.4-2). Migratory birds 

that are considered BLM SSS or birds of conservation concern are considered in further detail. 

Table 2.7.4-2. Resident, Migratory, Wintering, Rare,* and Accidental Bird Species Found in the 

Planning Area 

Common Name Scientific Name 

Red-throated loon Gavia stellata 

Pacific loon Gavia pacifica 

Common loon Gavia immer 

Arctic loon Gavia arctica 

Yellow-billed loon Gavia adamsii^ 

Horned grebe Podiceps auritus 

Red-necked grebe Podiceps grisegena 

Double-crested cormorant Phalacrocorax auritus 

Pelagic cormorant Phalacrocorax pelagicus 

Red-faced cormorant Phalacrocorax urile 

Tundra swan Cygnus columbianus 

Trumpeter swan Cygnus buccinator^ 

Canada goose Branta canadensis 

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Common Name Scientific Name 

Greater white-fronted goose Anser albifrons 

Snow goose Chen caerulescens 

Emperor goose Philacte canagica^ 

Cackling goose Branta canadensis minima 

Brant Branta bemicia 

Green-winged teal Anas carolinensis 

Blue-winged teal Anas discors 

Mallard Anas platyrhyncos 

Northern pintail Anas acuta 

Northern shoveler Anas clypeata 

Gadwall Anas strepera 

American wigeon Anas americana 

Canvasback Aythya valisineria 

Redhead Aythya americana 

Ring-necked duck Aythya collaris 

Greater scaup Aythya marila 

Lesser scaup Aythya affinis 

Black scoter Melanitta nigra 

White-winged scoter Melanitta deglandi 

Surf scoter Melanitta perspicillata 

Harlequin duck Histrionicus histrionicus 

Long-tailed duck Clangula hyemalis 

Barrow’s goldeneye Bucephala islandica 

Common goldeneye Bucephala clangula 

Bufflehead Bucephala albeola 

Common merganser Mergus merganser 

Red-breasted merganser Mergus merganser 

Osprey Pandion haliaetus 

Northern harrier Circus cyaneus 

Golden eagle Aquila chrysaetos^ 

Bald eagle Haliaeetus leucocephalus 

Sharp-shinned hawk Accipiter striatus 

Northern goshawk Accipiter laingi 

Red-tailed hawk Buteo jamaicensis 

Swainson’s hawk Buteo swainsoni 

Rough-legged hawk Buteo lagopus 

American kestrel Falco sparverius 

Merlin Falco columbarus 

Peregrine falcon Falco peregrines 

Gyrfalcon Falco rusticolus 

Short-eared owl Asio flammeus^ 

Boreal owl Aegolius funereus 

Great gray owl Strix nebulosa 

Great-horned owl Bubo virginianus 

Snowy owl Bubo scandiacus 

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Common Name Scientific Name 

Northern hawk owl Surnia ulula 

Spruce grouse Falcipennis canadensis 

Ruffed grouse Bonasa umbellus 

White-tailed ptarmigan Lagopus leucura 

Rock ptarmigan Lagopus muta 

Willow ptarmigan Lagopus lagopus 

Sharp-tailed grouse Tympanuchus phasianellus 

Lesser sandhill crane Grus canadensis 

Black-bellied plover Pluvialis squatarole 

American golden plover Pluvialis dominica 

Pacific golden plover Pluvialis fulve 

Semipalmated plover Charadrius semipalmatus 

Lesser sand plover (Mongolian plover) Charadrius mongolus* 

Black oystercatcher Haematopus bachmani 

Greater yellowlegs Tringa melanoleuce 

Lesser yellowlegs Tringa flavipes 

Wandering tattler Heteroscelus incanus 

Solitary sandpiper Tringa solitaria 

Semi-palmated sandpiper Calidris pusilla 

Pectoral sandpiper Calidris melanotos 

Least sandpiper Calidris minutilla 

Spotted sandpiper Actitis macularius 

Whimbrel Numenius phaeopus 

Bristle-thighed curlew Numenius tahitiensis 

Bar-tailed godwit Limosa lapponica 

Hudsonian godwit Limosa haemastica 

Black turnstone Arenaria melanocephala 

Ruddy turnstone Arenaria interpres 

Surfbird Aphriza virgata 

Rock sandpiper (Bering Sea) Calidris ptilocnemis tschuktschorum^ 

Red knot Calidris canutus* ^ 

Sanderling Calidris alba* 

Dunlin (Arctic-breeding) Calidris alpina arcticola 

Semipalmated sandpiper Calidris pusilla 

Western sandpiper Calidris pusilla 

Least sandpiper Calidris minutilla 

Baird’s sandpiper Calidris bairdii* 

Long-toed stint Calidris subminuta* 

Red-necked stint Calidris ruficollis* 

Pectoral sandpiper Calidris melanotos* 

Sharp-tailed sandpiper Calidris acuminate* 

Buff-breasted sandpiper Tryngites subruficollis* 

Short-billed dowitcher Limnodromus griseus 

Long-billed dowitcher Limnodromus scolopaceus 

Wilson’s snipe Gallinago gallinago 

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Common Name Scientific Name 

Red-necked phalarope Phalaropus lobatus 

Red phalarope Phalaropus fulicaria* 

Pomarine jaeger Stercorarius pomarinus 

Long-tailed jaeger Stercorarius longicaudus 

Parasitic jaeger Stercorarius parasiticus 

Bonaparte’s gull Larus piladelphia 

Mew gull Larus canus 

Herring gull Larus argentatus 

Glaucous gull Larus huperbor 

Glaucous-winged gull Larus glaucescens 

Slaty-backed gull Larus schistisagus 

Black-legged kittiwake Rissa tridactyla 

Sabine’s gull Xema sabini 

Arctic tern Stema paradisaea 

Belted kingfisher Megaceryle alcyon 

Aleutian tern Stema aleutica 

Common murre Uria aalge 

Kittlitz’s murrelet Brachyramphus brevirostris 

American three-toed woodpecker Picoides dorsalis 

Black-backed woodpecker Picoides arcticus 

Downy woodpecker Picoides pubescens 

Hairy woodpecker Leuconotopicus villosus 

Northern flicker Colaptes auratus 

Olive-sided flycatcher Contopus cooperi ^ 

Alder flycatcher Empidonax alnorum 

Say’s phoebe Sayomis saya 

Northern shrike Lanius excubitor 

Gray jay Perisoreus canadensis 

Black-billed magpie Pica hudsonia 

Common raven Corvus corax 

Horned lark Eremophilla alpestris 

Tree swallow Tachycineta bicolor 

Violet-green swallow Tachycineta thalassina 

Bank swallow Riperia riparia 

Cliff swallow Petrochelidon pyrrhonota 

Black-capped chickadee Poecile hudsonica 

Boreal chickadee Parus hudsonica 

Red-breasted nuthatch Sitta canadensis 

Gray-cheeked thrush Catharus minimus 

Swainson’s thrush Catharus ustulatus 

Hermit thrush Catharus guttatus 

Varied thrush Ixoreus naevius 

American robin Turdus migratorius 

Eastern yellow wagtail Motacilla flava tschutschensis 

American pipit Anthusrubescens 

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Common Name Scientific Name 

Bohemian waxwing Bombycillagarrulus 

Orange-crowned warbler Vermivora celata 

Yellow-rumped warbler Dendroica coronata 

Townsend’s warbler Dendroica townesndi 

Blackpoll warbler Dendroica striata^ 

Yellow warbler Dendroica petechia 

Wilson’s warbler Wilsonis pusilla 

Northern waterthrush Seiurus noveboracensis 

American tree sparrow Spizella arborea 

Fox sparrow Passerella iliaca 

Savannah sparrow Passerculus sandwicensis 

Lincoln’s sparrow Melospiza lincolnii 

White-crowned sparrow Zonotrichia leucophrys 

Song sparrow Melospiza melodia 

Brown creeper Certhia americana 

Pacific wren Troglodytes troglodytes 

American dipper Cinclus mexicanus 

Golden-crowned kinglet Regulus saatrapa 

Ruby-crowned kinglet Regulus calendula 

Arctic warbler Phylloscopus borealis* 

Northern wheatear Oenanthe oenanthe 

White-crowned sparrow Zonotrichia leucophrys 

Golden-crowned sparrow Zonotrichia atricapilla 

Slate-colored junco Junco hyemalis 

Lapland longspur Calcarius lapponicus 

Snow bunting Plectrophenax nivalis 

McKay’s bunting Plectrophenax hyperboreus* ^ 

Rusty blackbird Euphagus carolinus^ 

Red crossbill Loxia curvirostra 

White-winged crossbill Loxia leucoptera 

Pine grosbeak Pinicola enucleator 

Pine siskin Carduelis pinus 

Gray-crowned rosy finch Leucosticte tephrocotis 

Common redpoll Carduelis flammea 

Hoary redpoll Carduelis homemanni 

Source: BLM 2015a and USFWS Innoko NWR bird list 

* Indicates “rare” birds and denoted in BLM 2015a 

^ BLM-AK Sensitive 

Migratory birds are known to occupy every habitat type within the planning area including riparian, 

wetland, forest, shrub, and alpine tundra. Given Alaska’s short summers, the success of nesting birds 

depends greatly on their ability to locate suitable nesting habitat in a timely fashion, endure infrequent 

adverse weather conditions, evade predators, and avoid disruption of their normal routine. Suitable 

nesting habitat is especially important to the success of nesting birds, as it enables them to meet the 

specific needs of rearing young while expending as little energy as possible in the process. Because bird 

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species occupy a wide variety of habitats, it is difficult to generalize on habitat condition. However, most 

of the planning area is in a natural state. 

Summary of Surveys 

Nesting bird surveys have been conducted on the Unalakleet and Anvik Rivers annually since 1997. 

These surveys have recorded the presence of 45 species of song birds, waterfowl, shorebirds and raptors, 

including grey-cheeked thrush, and blackpoll warbler, both BLM sensitive species (BLM 2018b). 

Raptors 

There have been numerous raptor surveys in the planning area, some long-term, although most were 

focused on cliff-nesting species such as peregrine falcons, golden eagles, and gyrfalcons. White and 

Boyce (1978) documented high densities of nesting raptors on many rivers in western Alaska, including 

the Kisaralik River. Mindell (1983) surveyed 16 rivers within BLM jurisdiction in southwestern Alaska 

from 1979 to 1982 and found that gyrfalcons, golden eagles and osprey were widespread but generally 

uncommon breeders, and that high densities of gyrfalcons and golden eagles were found in a few areas. 

Mindell also observed merlin, northern harrier, sharp-shinned hawk, goshawk, great-horned owl, hawk 

owl, American kestrel, boreal owl, short-eared owl and great gray owl. Gerhardt (1989) surveyed selected 

areas of the southern Akinuk Mountains and found 10 nests of rough-legged hawk, merlin, and gyrfalcon. 

Between 1991 and 2004, the Yukon Delta NWR conducted annual surveys of cliff-nesting raptors in the 

Kilbuck Mountains of western Alaska and resumed the surveys in 2012. McCaffery et al. (2011) studied 

gyrfalcons in the Askinuk Mountains, the Ingakslugwat Hills, and the Kilbuck Mountains and reported 

that the extensive uplands north of the Yukon River and east of the Kuskokwim River support 79 nesting 

territories. A fourth area, the Andreafsky Wilderness, was searched less frequently and less 

comprehensively, but McCaffery et al. (2011) reported that it may support even higher local densities 

than the primary study areas. In addition to cliff nests, gyrfalcons were also observed nesting in trees in at 

least three geographically separate regions. 

Portions of the Kuskokwim River between Aniak and McGrath contain significant amounts of cliffnesting habitat for peregrine falcons. These areas are on a mosaic of BLM, State, and Native corporation 

land ownership. 

Peregrine falcons were listed as threatened under the ESA in 1970 and were de-listed in 2003 due to 

evidence of population recovery (USFWS 2016). As part of the post-delisting process, surveys for the 

peregrine falcon nesting and productivity surveys were conducted on the Kuskokwim River between 

Aniak and McGrath from 2000-2004, and again in 2008, 2011, and 2013. These surveys concentrated on 

the cliff nesting habitats along that portion of the Kuskokwim River. These surveys showed a recovery in 

the number of nesting pairs of peregrine falcons on cliff nesting habitats along the Kuskokwim River 

from the low population levels during the 1970s and 1980s when the species was listed as threatened 

under the ESA (Seppi 2007). 

The number of peregrines and young produced were compared with data from 1976 when populations 

were first accurately assessed. The results of this study and comparisons with earlier data suggest that the 

peregrine population was at or near its lowest level in 1976, then steadily increased throughout the 1980s 

and early 1990s. In 2004, 20 pairs of peregrines occupied nesting territories, indicating the nesting 

population may still be increasing. 

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Special Status Species 

BLM SSS include species listed or proposed for listing under the ESA and species that are designated as 

BLM Alaska sensitive species by the State Director. Currently, the only ESA-listed species in the 

planning area is the wood bison, which is listed as threatened. The recently reintroduced population of 

wood bison was designated as a nonessential experimental population under section 10(j) of the ESA. 

This special rule allows some of the management requirements of the ESA to be relaxed to facilitate 

acceptance by local landowners and managers. Within this final rule, there are exemptions for the 

incidental effects of development, land management and other lawful activities, and for regulated hunting, 

in order to ensure management flexibility. 

Should any additional species within the planning area be listed in the future, the requirements of BLM 

policy will be followed, including the need for consultation under Section 7 of the ESA. Therefore, no 

further discussion or analysis of this category of SSS is provided. 

The emphasis of SSS management by the BLM will be an ecosystem management approach that will 

attempt to reduce the likelihood of a species being listed under the ESA, although specific measures will 

be taken to conserve species and their habitats when necessary. 

The BLM Alaska has utilized the ranking system developed by the ACCS (formerly the Alaska Natural 

Heritage Program) and The Nature Conservancy, plus an international network of natural Heritage 

Programs and Conservation Database Centers, which assess state and global rarity, for assistance in 

developing Special Status and sensitive species lists for Alaskan plants and animals. Species designated 

as BLM sensitive must be native species that occur on BLM-managed public lands, and for which BLM 

has significant management capability to affect their conservation status. In addition, one of the following 

two criteria must also apply: 

1. There is information that a species is known or predicted to undergo a downward trend such that 

viability of the species or a distinct population segment of the species is at risk across all or a 

significant portion of its range, or 

2. The species depends on ecological refugia, specialized habitats or unique habitats, and there is 

evidence that such areas are threatened with alteration such that the continued viability of the 

species in that area would be at risk. 

Brief descriptions of BLM Alaska sensitive bird species known or likely to occur in the planning area are 

included below in Table 2.7.4-3 (2010 BLM Alaska Sensitive Species List [IM AK-2010-018]). 

The BLM Alaska Watch List species are species for which data are insufficient to satisfy sensitive species 

eligibility criteria in Manual 6840. They should be emphasized for inventory, monitoring, and research as 

funding and time allow and should be re-evaluated during subsequent sensitive species list revisions. A 

few watch species of note are discussed in the following sections. 

Bird Species of Conservation Concern 

In addition to the BLM sensitive birds discussed above, there are several other species that the USFWS 

lists as Bird Species of Conservation Concern and/or are “featured species” in Alaska’s Wildlife Action 

Plan (ADF&G 2015c). Interim guidance has directed BLM planners to consider these species of concern 

during the planning process. These species are listed in Table 2.7.4-3 with BLM sensitive and watchlist 

species. These species are designated for a variety of reasons. They may be small in population or range, 

showing a decline in populations in part or all their range, dependent on habitats viewed as susceptible to 

human disturbance or development, or considered worthy of more intensive monitoring due to any of 

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these factors. In addition to Alaska “featured species” and the USFWS Bird Species of Conservation 

Concern (BCC), species that the Partners in Flight organization has designated as Alaska Priority 

Species, are listed in this table. 

Table 2.7.4-3. Bird Species of Concern in the Planning Area 

Species 

BLMAlaskaa USFWS BCCb USFWS 

BCR4c 

Alaska 

SWCSd 

Alaska 

Statee BPIFf 

Yellow-billed loon Sensitive 

Red-throated loon Watch 

Species 

featured 

Emperor goose Sensitive 

Grey-cheeked thrush Watch 

Species 

SOC Priority 

Long-tailed duck featured 

Olive-sided flycatcher Sensitive BCC/N featured SOC Priority 

Trumpeter swan Sensitive BCC Interior 

Population 

Blackpoll warbler Sensitive BCC/R, Region 

7 

featured SOC Priority 

Townsend’s warbler Watch 

Species 

featured SOC Priority 

McKay’s bunting Sensitive 

American peregrine falcon BCC/N BCR4 featured SOC 

Golden eagle Sensitive 

Harlequin duck 

Black scoter GBADC featured 

Surf scoter GBADC featured 

Buff-breasted sandpiper Watch 

Species 

BCC/N featured 

Rusty blackbird Sensitive featured Priority 

Bristle-thighed curlew Sensitive 

Red knot Sensitive 

Bering Sea rock sandpiper Sensitive 

Kittlitz’s murrelet Sensitive 

Wandering tattler featured 

Solitary sandpiper BCC/N featured 

Short-billed dowitcher BCC/N BCR4 

Hudsonian godwit Watch 

Species 

BCC/N BCR4 

Bar-tailed godwit Watch 

Species 

American golden plover BCC/N BCR4 

Northern harrier BCC/N featured 

Short-eared owl Sensitive BCC/N featured 

Surfbird BCC/N BCR4 

Arctic tern BCC/R region 7 featured 

Arctic warbler BCC/R region 7 

Whimbrel BCC/N BCR4 

Gyrfalcon Priority 

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Species 

BLMAlaskaa USFWS BCCb 

USFWS 

BCR4c 

Alaska 

SWCSd 

Alaska 

Statee BPIFf 

Sharp-tailed grouse Priority 

American dipper Priority 

Northern shrike Priority 

White-winged crossbill Priority 

Bohemian waxwing Priority 

Black-backed woodpecker Priority 

Boreal owl Priority 

Varied thrush Priority 

Great Gray owl Priority 

Golden-crowned sparrow Priority 

a Species listed by BLM in Alaska as sensitive or as watch species. 

b Species listed as a Bird of Conservation Concern (BCC) in US (N) or portion (region 7 = Alaska) and Game Birds Above Desired Condition 

(GBADC). 

c Species listed as a Bird of Conservation Concern in Bird Conservation Region 4 (Interior Alaska) (BCR4). 

d Species listed in the Alaska State Wildlife Conservation Strategy as a featured species. 

e State of Alaska designated species of concern (SOC). 

f Species listed by the Alaska Boreal Partners in Flight as Priority Species in Alaska. 

g Not likely found in planning area in significant numbers 

BLM Sensitive Bird Species in the Planning Area 

Trumpeter swan 

Due to the remote nature of their preferred habitat in Alaska, trumpeter swans have been relatively 

unaffected by human development in Alaska, and during a 1990 census were found to number over 

13,000 statewide (Conant et al. 2002). Trumpeter swans breed widely in central and southern Alaska 

(Mitchell and Eichholz 2010), including areas in the upper Kuskokwim River watershed on BLMmanaged public lands within the planning area. Breeding habitat includes a wide variety of wetlands with 

irregular shorelines, emergent vegetation, diverse communities of aquatic plants and early ice-off 

(Mitchell and Eichholz 2010), with the amount of human disturbance and regional climate also affecting 

habitat use and productivity. Adults are predominately herbivorous (submerged and emergent vegetation), 

but occasionally eat fish and fish eggs. Cygnets feed on aquatic invertebrates and vegetation. In the postbreeding period, when cygnets are able to fly, trumpeter swans congregate at staging areas in preparation 

for flying southward. Habitat use during migration is limited by ice, forage, and disturbance; freshwater 

marshes, ponds, lakes, rivers, and brackish estuaries with high abundance of preferred aquatic plant 

rhizomes and tubers (La Montagne et al. 2003). These staging areas are usually large shallow lakes and 

represent important trumpeter swan habitat. 

Emperor goose 

The emperor goose is unique to Alaska and eastern coastal Siberia; its breeding range is primarily 

restricted to the west-coastal areas of the Yukon-Kuskokwim Delta, and most of the world’s population 

winters in the Aleutian Islands (Schmutz et al. 2011). The population appears to be stable in North 

America, with the 2015 spring count, taken on the spring staging areas in southwestern Alaska, estimated 

at just over 98,000 birds (USFWS 2015). Breeding habitats are within the planning area boundaries, but 

do not include lands BLM manages. Migration staging areas are in coastal lagoons and estuaries and 

outside of the planning area. 

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Golden eagle 

Golden eagles are found breeding throughout the planning area, and use habitats dominated by rugged 

topography and mountainous terrain, near or above tree line, and along riparian areas, although the 

species is found in low densities throughout most of the northern hemisphere (Peterson et al. 1991; Young 

et al. 1995). Cliff nests are most common, but nesting on human-made structures also occurs (Kochert et 

al. 2002). Prey items in Alaska include arctic ground squirrels, snowshoe hares and arctic hares (Poole 

and Bromley 1988). Long-term surveys show declines in nesting populations in the western United 

States, but not Alaska or Canada (Kochert and Steenhof 2002), although availability of food and nesting 

sites determines nesting density (Hunt et al. 1995). Much remains unknown about the breeding ecology of 

golden eagle populations in Alaska and Canada (Kochert et al. 2002) 

Bristle-thighed curlew (Numenius tahitiensis) 

Bristle-thighed curlews breed exclusively in Alaska and make long-distance trans-oceanic migrations to 

winter on remote islands in the south Pacific (Marks et al. 2002). Breeding grounds are known only in 

western Alaska between the Yukon River and the northern Seward Peninsula, and include an area in the 

southern Nulato Hills within the planning area and managed by BLM. Population surveys of known 

breeding range in 1988−1992 yielded about 3,200 breeding pairs, 60 percent of which used habitats in the 

southern Nulato Hills, and are characterized by rolling upland tundra and dwarf shrub meadows (Marks et 

al. 2002). The worldwide population is naturally small, breeds only in two areas in Alaska, and winters on 

islands in Oceania, making the population particularly vulnerable to disturbance, degradation of habitat, 

and human impacts. 

Short-eared owl (Asio flammeus) 

Short-eared owls occur throughout Alaska and can be found across the planning area. Habitats include 

marshes, grasslands, and tundra, particularly where populations of prey species such as voles and 

lemmings are found (Wiggins et al. 2006). The species is found nearly worldwide, although the 

population trend shows a 30 percent decline in the past 10 years (BirdLife International 2012). 

Fluctuations in the short-eared owl population, due most likely to cyclical variation in the population of 

voles, make it difficult to determine long-term trends. However, declines have been recorded from many 

parts of the species range, and short-eared owls are listed as an at-risk species by Partners in Flight. 

Development and agriculture in the lower 48 states, which result in loss of winter habitat, are the most 

significant threats to the North American population (Wiggins et al. 2006). 

Olive-sided flycatcher (Contopus cooperi) 

Olive-sided flycatchers breed at low densities throughout the coniferous boreal and coastal forests of 

Alaska, including central, southcentral, southeast, and occasionally western Alaska (Kessel and Gibson 

1978), and are found throughout BLM-managed public lands in the planning area. It breeds in habitat 

along forest edges and openings, including burns; natural edges of bogs, marshes, and open water; semiopen forest; and harvested forest with some structure retained. Tall, prominent trees and snags, which 

serve as singing and foraging perches, and unobstructed air space for foraging, are common features of all 

nesting habitats (Altman and Sallabanks 2012). Olive-sided flycatchers are highly migratory, with 

principal wintering ranges in Central America and northern South America (Boreal Songbird Initiative 

2016). In Alaska, the birds use relatively open boreal forest (Kessel and Gibson 1978) and are often 

associated with openings such as meadows, muskegs, burns, and logged areas and water (streams, beaver 

ponds, bogs, and lakes) (Altman 1997). Birds prey almost exclusively on flying insects and often forage 

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from the tops of snags or dead branches at the top of live trees. During nesting season in Alaska, birds 

most frequently prey on yellow-jacket wasps and dragonflies (J. Wright in Altman and Sallabanks 2012). 

North American Breeding Bird Survey data indicate population declines since 1966 across much of the 

North American range with an overall decline of 2.7 percent per year from 1966 to 2011 (Sauer et al. 

2012). In Alaska, a population decline of 3.1 percent per year occurred from 1966 to 2007, based on data 

from 56 breeding bird survey routes (Sauer et al. 2012). Factors in population declines likely include 

habitat changes or alteration in both wintering and nesting grounds, changes in availability of prey 

species, exposure to pesticides, nest predation, and forest management practices (Altman and Sallabanks 

2012). In Alaska, habitat concerns include logging, salvage logging associated with beetle infestations in 

white spruce, and fire suppression. Olive-sided flycatchers have been recorded annually during Breeding 

Bird Surveys conducted along the Unalakleet and Anvik rivers within the planning area (Pardieck et al 

2018). 

Blackpoll warbler (Dendroica striata) 

Blackpoll warblers occur throughout western and interior Alaska and northern Canada, are found across 

the planning area in boreal forest and riparian shrub habitats, and in the transition zones between tundra 

and taiga (DeLuca et al. 2013). The birds winter in northern South America below 9,842 feet elevation in 

wooded habitats and undertake the longest migration of any North American warbler, with some 

individuals traveling over 5,000 miles from Alaska to Brazil (Nisbet et al. 1995). Diet during the nesting 

season consists primarily of adult and larval insects (Tramer and Tramer 1977). Data from the North 

American Breeding Bird Survey indicate this species has suffered the steepest long-term decline of any 

neotropical nearctic migrant landbird since 1980, with populations diminished by over 50 percent and 90 

percent across breeding ranges in Alaska and Canada, respectively (Sauer et al. 2005). A large proportion 

(25 percent) of the global population is estimated to breed in Alaska (Gotthardt et al. 2012). Blackpoll 

warblers have been recorded annually during Breeding Bird Surveys conducted along the Unalakleet and 

Anvik rivers within the planning area (Pardieck et al 2018). 

Rusty blackbird (Euphagus carolinus) 

Rusty blackbirds are found throughout the planning area, and in Alaska nests in black spruce forests or 

willow shrubs near water (Matsuoka et al. 2010). The species feeds mainly on seeds and insects. Rusty 

blackbirds have declined alarmingly (85 to 95 percent) in numbers over the past 40 years (1970−2010), 

creating an interest in the study of this species (Matsuoka et al. 2010). Factors contributing to this decline 

include wetland loss in southeastern North America, contaminants on the nesting grounds, poisoning of 

other blackbird species on winter roosts, and increased disturbance on boreal wetland breeding habitats 

outside the planning area, although other unknown factors may be involved (Avery 2013). Rusty 

blackbirds have been recorded annually on Breeding Bird Surveys conducted along the Unalakleet and 

Anvik Rivers, both on BLM-managed public lands within the planning area (Pardieck et al 2018). 

McKay’s bunting (Plectrophenax hyperboreus). 

McKay’s buntings are found only in Alaska, breed exclusively on St. Matthew Island in the North Central 

Bering Sea, and winter along the Bering Sea coast from Kotzebue to Cold Bay (Montgomerie and Lyon 

2011). The McKay’s bunting is similar to the snow bunting (Plectrophenax nivalis) but is considered a 

separate species due to its morphological distinctiveness and geographical isolation (Montgomerie and 

Lyon 2011). The total breeding population of McKay’s buntings is estimated at 31,200 birds (Matsuoka 

and Johnson 2008). There is no immediate threat to the population, but due to the small population size 

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and very restricted breeding range, the species is susceptible to introduced predators (rats, weasels, fox) 

and reindeer grazing disturbing nesting habitats (Matsuoka and Johnson 2008). McKay’s buntings have 

been observed in Unalakleet in March (Pardieck et al 2018) and likely use winter habitats in the coastal 

areas of Norton Sound that are within the planning area and managed by BLM. 

2.7.5 Current Conditions – Wildlife Habitats 

The planning area includes a variety of upland and lowland vegetation communities (see Table 2.7.5-1) 

that provide important breeding, wintering, and migration habitat for the wildlife species described in the 

previous section. This section focuses on areas that the BLM has identified as important from a wildlife 

habitat or conservation perspective. 

Current ACECs 

The wildlife habitat within the 11 current ACECs is described below. Nineteen new ACECs have been 

nominated. The BLM (2016a) evaluated 30 ACECs and concluded that a total of 17 ACECs met both the 

relevance and importance criteria. The size and wildlife habitat of the current 11 ACECs are presented in 

Table 2.7.5-1 (BLM 2018b). 

Migratory Bird Habitat 

The USGS (2016) designated five Bird Conservation Regions in Alaska as part of the North American 

Bird Conservation Initiative to provide a framework that would facilitate coordinated conservation and 

evaluations of major bird initiatives. Two of these overlap the boundaries of the planning area: Western 

Alaska and Northwest Interior Forest (BSWI Draft RMP/EIS, Map 3.2.7-1). Within these two regions are 

several subregions. The subregions that overlap the boundaries of the planning area are described below. 

These summaries of bird use are useful for their descriptions of bird use by habitat. 

Western Alaska 

This region consists of the coastal plain and mountains of western and southwestern mainland Alaska. 

The Sub-regions that overlap the planning area are: A) Subarctic Coastal Plain and Seward Peninsula, and 

B) Ahklun and Kilbuck Mountains and Bristol Bay-Nushagak Lowlands. Permafrost is continuous except 

in southern parts of the region. Sea cliffs are present as are mountains that exceed 3,300 feet in elevation. 

Wet and mesic graminoid herbaceous communities dominate the lowlands and numerous ponds, lakes, 

and rivers dot the landscape. Tall shrub communities are found along rivers and streams and low shrub 

communities occupy uplands; forests of spruce and hardwoods penetrate the region on the eastern edge. 

High densities of breeding waterfowl and shorebirds are found on the coastal plain of the Yukon and 

Kuskokwim Rivers. Intertidal areas support millions of shorebirds during migration (e.g., dunlins, 

western sandpipers, red knots, and bar-tailed godwits). Western Alaska includes a unique Beringian 

breeding avifaunal element (e.g., black turnstone, bristle-thighed curlew) and several Old World species 

are regular breeders or migrants in this region (e.g., sharp-tailed sandpiper, red-throated pipit, white 

wagtail). Passerine diversity is greatest in tall, riparian shrub habitats (e.g., arctic warbler, gray-cheeked 

thrush, blackpoll warbler) and raptors (e.g., gyrfalcon, rough-legged hawk) nest along the riverine cliffs. 

Mainland sea cliffs contain nesting colonies of, largely, black-legged kittiwakes, common murres, and 

pelagic cormorants. 

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Table 2.7.5-1. Wildlife Habitat in the Current ACECs 

ACEC Acres Wildlife Habitat Description 

Anvik River ACEC 

(existing) 115,106 

North American Breeding Bird surveys have been conducted on the Anvik River annually since 1997, as part of a nationwide 

census to determine bird population trends. The surveys detected 43 species of song birds, shorebirds, waterfowl and raptors, 

including rusty blackbird, a BLM SSS. In 2003, harlequin duck aerial helicopter surveys were conducted in the upper portions of 

the Anvik River (Otter Creek, Swift River, and Beaver Creek) watershed to determine use of the habitats during spring migration 

by harlequin duck breeding pairs. The survey found low densities of harlequin ducks equal to 0.007 pairs/kilometer of river 

surveyed. Harlequin ducks have been considered a BLM sensitive species but were removed from the list in 2008. 

The Anvik River watershed provides habitats for populations of moose, black bears and brown bears, as well as shrub habitats 

for at least 45 species of land birds, waterfowl, shorebirds and raptors. The watershed exists in a pristine state, with little 

permanent human development, and an intact ecological hierarchy including predators (wolves, brown bears, black bears, lynx) 

to terrestrial and aquatic prey species, including four species of salmon. This large parcel of land is also situated between two 

wildlife refuges and may help to provide some connectivity between them. 

Kuskokwim River Raptor 

Nesting Habitat ACEC 6,072 

In 1981, The Kuskokwim River area was important nesting habitat for bald eagles, golden eagles, osprey, and gyrfalcons. The 

concentration of these important or endangered species was the basis for ACEC designation. 

As part of the post-delisting, surveys for the peregrine falcon nesting and productivity surveys were done on the Kuskokwim 

River between Aniak and McGrath from 2000-2004, and again in 2008, 2011, and 2013. These surveys concentrated on the 

cliff nesting habitats along that portion of the Kuskokwim River. These surveys showed a recovery in the number of nesting 

pairs of peregrine falcons on cliff nesting habitats along the Kuskokwim River from the low population levels during the 1970s 

and 1980s when the species was listed as threatened under the ESA. 

The bluffs and cliffs along the Kuskokwim River provide nesting habitat for many species of raptors and are not found in 

abundance in other portions of the planning area. The cliff nesting habitats are situated along the river corridor and provide an 

important food source for nesting raptors. The cliff habitats along the river in that area produce at least 20 peregrine and 20 

rough-legged nests annually. 

Peregrine Falcon Nesting 

Habitat ACEC 8,096 

The peregrine falcon nesting habitat ACEC was nominated to protect cliff nesting habitats and active nest sites along the Yukon 

River. While peregrine falcon populations have increased and stabilized since the species was delisted from a threatened 

status in 1999, these areas remain important cliff nesting habitats along the Yukon River. 

Drainages of the 

Unalakleet River ACEC 415,184 

Breeding bird surveys have been conducted on the Unalakleet River annually since 1997. These surveys have recorded the 

presence of 45 species of song birds, waterfowl, shorebirds and raptors, including grey-cheeked thrush, blackpoll warbler (BLM 

sensitive species). 

The Unalakleet River watershed provides habitat for moose, caribou, brown bear, wolf, and wolverine. These species are 

important to local subsistence users, as well as local guides and outfitters that provide services to resident and non-resident 

sport hunters, providing benefit to the local economy as well as providing opportunity for qualified subsistence users from 

Unalakleet and Shaktoolik. The watershed is also a natural, complete ecosystem with an intact ecological food web. 

North River ACEC 137,349 

The North River watershed provides habitat for moose, caribou, brown bear, wolf, and wolverine. These species are important 

to local subsistence users, as well as local guides and outfitters that provide services to resident and non-resident sport 

hunters, providing benefit to the local economy as well as providing opportunity for qualified subsistence users from Unalakleet 

and Shaktoolik. The watershed is also a natural, complete ecosystem with an intact ecological food web. 

Box River Treeline 

Research Natural Area 

(RNA) ACEC 

13,592 The Box River Treeline RNA is important winter habitat for the Western Arctic Caribou Herd. 

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ACEC Acres Wildlife Habitat Description 

Inglutalik ACEC 71,716 

The Inglutalik ACEC provides habitat for moose, caribou, brown bear, wolf, and wolverine. These species are important to local 

subsistence users, as well as local guides and outfitters that provide services to resident and non-resident sport hunters, 

providing benefit to the local economy as well as providing opportunity for qualified subsistence users from Unalakleet and 

Shaktoolik. The watershed is also a natural, complete ecosystem with an intact ecological food web. 

Ungalik River ACEC 112,719 

The Ungalik River watershed provides habitat for moose, caribou, brown bear, wolf, and wolverine. These species are 

important to local subsistence users, as well as local guides and outfitters that provide services to resident and non-resident 

sport hunters, providing benefit to the local economy as well as providing opportunity for qualified subsistence users from 

Unalakleet and Shaktoolik. The watershed is also a natural, complete ecosystem with an intact ecological food web. 

Shaktoolik River ACEC 192,591 

The Shaktoolik River watershed provides habitat for moose, caribou, brown bear, wolf, and wolverine. These species are 

important to local subsistence users, as well as local guides and outfitters that provide services to resident and non-resident 

sport hunters, providing benefit to the local economy as well as providing opportunity for qualified subsistence users from 

Unalakleet and Shaktoolik. 

Kateel River ACEC 568,083 

The Kateel River watershed provides habitat for moose, caribou, brown bear, wolf, wolverine. These species are important to 

local subsistence users, as well as local guides and outfitters that provide services to resident and non-resident sport hunters, 

providing benefit to the local economy as well as providing opportunity for qualified subsistence users. The watershed is also a 

natural, complete ecosystem with an intact ecological food web. 

Gisasa River ACEC 278,057 

The Gisasa River watershed provides habitat for moose, caribou, brown bear, wolf, and wolverine. These species are important 

to local subsistence users, as well as local guides and outfitters that provide services to resident and non-resident sport 

hunters, providing benefit to the local economy as well as providing opportunity for qualified subsistence users. 

Total Existing ACECs 

Acres: 1,918,565 

Source: BLM 2018b 

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Northwest Interior Forest 

This region is an extensive (278,800 square miles) patchwork of ecological types. The Sub-regions that 

overlap the planning area are: A) Interior Highlands and Ogilvie Mountains, B) Alaska Range/Wrangell 

Mountains/Copper Plateau, and B) Interior Forested Lowlands and Uplands, Interior Bottomlands, and 

Yukon Flats. A mosaic of vegetation communities arise from the interplay of elevation, permafrost, 

surface water, fire, and aspect. All forest types (needleleaf, deciduous, and mixed) are found in the region 

and are dominated by white spruce, black spruce, poplars, and paper birch. Tall shrub communities occur 

along rivers, drainages, and near treeline. Bogs, consisting of low shrubs and shrub-graminoid 

communities, are common in the lowlands. Alpine dwarf scrub communities are common in Interior 

Highlands and throughout mountainous regions; highest elevations are generally devoid of vegetation. 

Despite the varied ecoregions, many bird species are shared among the regions. Lowlands, bottomlands 

and flats harbor many species of migrating and breeding waterfowl (e.g., northern pintail, northern 

shoveler, green-winged teal) and swans. These ecoregions, combined with forested lowlands and uplands 

support breeding shorebirds such as greater and lesser yellowlegs, solitary and spotted sandpipers, and 

common snipe. American golden-plovers and surfbirds are found in alpine habitats in Interior Highland 

and mountainous ecoregions. A suite of passerines inhabit forest, scrub, and graminoid communities in 

the region. Black-capped and boreal chickadees, ruby-crowned kinglets, Swainson’s thrushes, yellowrumped warblers and dark-eyed juncos are common forest species. Tall shrub communities host whitecrowned, American tree, and fox sparrows, Wilson’s and yellow warblers, gray-cheeked thrushes, and 

common redpolls, among others. At high elevations, horned lark and Lapland longspur are common 

breeders. 

The Important Bird Areas Program (IBA), a global initiative of BirdLife International (implemented by 

Audubon and local partners in the United States), is an effort to identify and conserve areas that are vital 

to breeding, migrating, and wintering birds. Because of the vast, intact habitats in Alaska, there are more 

globally significant IBAs in this state than any other in the U.S. (Audubon 2014). 

Map 3.2.7-2 of the BSWI Draft RMP/EIS shows the locations of the three IBAs in the planning area. The 

following descriptions of these areas are summarized from Audubon 2016. 

The Andreafsky Wilderness IBA is a vast area of rolling montane tundra that supports about 60 percent 

(2,500 pairs) of the world's breeding population of bristle-thighed curlews, a unique species of large 

upland nesting shorebird that is listed as "vulnerable" in the world list of threatened birds. The BLM and 

USFWS manage approximately 97 percent of the IBA. The habitat consists of dwarf shrub meadows, low 

shrub/tussock tundra, tall shrub, mixed shrub/thicket tundra, lichen meadow, and shrub meadow/tundra. 

While there are no major threats to birds in this area, subsistence harvest may pose a threat to breeding 

adults, while eggs and nests may be trampled occasionally by caribou in the area. Land use consists of 

occasional hunting and recreation, although difficult terrain and difficult access to the area limit the 

number of visitors. 

The Iditarod River Lowlands IBA is a large wetland complex within the Innoko NWR, a relatively flat 

plain dominated by numerous slow-moving silty rivers, small lakes, streams, and bogs. There are no BLM 

lands in this IBA, but it is in the planning area. This region is a transition zone between interior boreal 

forest and the shrub-land and tundra common in western and northern Alaska. One of the primary reasons 

for establishment of the Innoko Refuge was protection of the vast wetland complex surrounding the 

confluence of the Innoko and Iditarod Rivers important to waterbirds during many life stages. The unique 

water regime in this area, characterized by frequent flooding and slow drawdown of lakes, creates 

excellent habitat for breeding, molting, and migrating birds. The Iditarod River Lowlands is home to 

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molting greater white-fronted geese, and breeding populations of several species identified as BCC by the 

USFWS, including American golden-plover, solitary sandpiper, whimbrel, and Hudsonian godwit. 

Landbird species common to the area include olive-sided flycatcher, blackpoll warbler, and rusty 

blackbird. All three of these species reach some of their highest known breeding densities in riparian 

habitats in western Alaska. Due to the region’s remoteness and lack of human inhabitants, direct threats to 

bird life are few. The major threat is large-scale ecological shifts due to climate change. A recent study of 

wetland drying across interior Alaska from 1950 until 2002 documented the highest wetland area loss (31 

percent) on the Kaiyuh Flats, just 93 miles north of Innoko NWR. 

The Turquoise Lake IBA lies partially within the planning area. The Turquoise Lake basin lies within 

Lake Clark National Park and Preserve on the west slope of the Neacola Mountains of southwestern 

Alaska. The 5-mile-long by 1.5-mile-wide lake is located 2,503 feet above sea level and is one of a series 

of glacially formed, east/west oriented lakes whose moderate to steep-sloping valley walls include 

remnants of the most recent series of recessional Late Wisconsin glacial moraines. From the surface of 

Turquoise Lake these stair-step moraine terraces rise an additional 787-2,096 feet onto gently rounded 

plateaus. Information from several studies over 10 years points to the importance of this montane area as 

nesting habitat for a unique assemblage of birds, most notably several medium- to large-sized shorebirds 

and several passerine species. Species known to breed in the area include American golden-plover, 

surfbird, wandering tattler, Baird’s sandpiper, gray-crowned rosy-finch, and northern wheatear. Enough 

data and anecdotal observations have been collected to suggest that this region represents not only a major 

breeding range extension for most of these species but also support significant numbers of each. Recent 

regional and national shorebird conservation planning efforts have identified certain shorebird species 

(including many of the above species) and habitats as being of high conservation concern, primarily due 

to documented or perceived population declines and/or restricted distributions. 

Innoko Bottoms 

The Innoko Bottoms area (BSWI Draft RMP/EIS, Map 3.2.7-3) corresponds to the Proposed Innoko 

Bottoms Wildlife Area, which includes BLM-managed land within the ADF&G-designated Paradise 

Controlled Use Area (CUA). The Paradise CUA was established in 1977 to reduce the competition 

between sport and subsistence moose hunters by preventing hunting access to the area by aircraft 

(ADF&G 2014a). The Paradise CUA is closed to the use of aircraft for hunting moose, including the 

transportation of moose hunters, their hunting gear, or parts of moose. 

Habitat 

The Innoko Bottoms area is bounded on the north by the Innoko NWR, on the east by the Innoko River, 

on the west by Yukon River, and on the south by the confluence of the two rivers. Riverine habitats and 

wetlands hydrologically connected to the Innoko and Yukon Rivers have extensive shallow areas and 

seasonally fluctuating water levels that produce favorable conditions for aquatic plant growth. Seasonal 

flooding of the lowlands inhibits succession of woody shrubs and promotes growth of grasses and sedges 

creating large open meadows interspersed with boreal forest habitats on higher terrain. The area contains 

abundant meandering sloughs and oxbow lakes that provide high-value habitat for waterfowl and moose. 

Waterfowl 

The Innoko Bottoms area is an important waterfowl production area, with the highest densities of water 

birds observed along river corridors where water levels of associated lakes fluctuate to create important 

breeding habitat (Platte 1996). Spring flooding of the Innoko and Yukon Rivers provides a large area of 

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temporary islands that are less accessible to predators, and provide nesting habitat for ducks, geese and 

swans. Flooded sloughs and hydrologically connected wetlands in the area provide nesting and brood 

rearing habitat for at least 10 species of dabbling and diving ducks (Seppi 1993). 

The area between the Yukon and Innoko Rivers supports two mapped traditional migratory flight lines of 

breeding water bird pairs (Platte 1996), and the area provides a stopover sight for waterfowl migrating to 

the Y-K Delta during spring migration (Spragens 2016). 

Moose 

The Innoko Bottoms area supports known winter concentrations of moose (BSWI Draft RMP/EIS, Map 

3.2.7-5), providing lower-elevation foraging areas with abundant willows for browse in the floodplain 

meadows (ADF&G 2014a). Moose densities for the larger management area (Unit 21E) are estimated at 

1.2 moose per square mile (ADF&G 2014d), although densities are likely higher than this in the Innoko 

Bottoms area. Riparian willow stands along the Yukon and Innoko Rivers provide winter moose browse 

(ADF&G 2014a), and support known winter concentrations of moose (BSWI Draft RMP/EIS, Map 3.2.7-

5). 

Wood Bison 

In the spring and summer of 2015, a nonessential experimental population of wood bison (the Lower 

Yukon/Innoko Rivers herd) was released in the Innoko Bottoms area near the village of Shageluk by the 

ADF&G. The site was determined to be appropriate for the release, in part because of its large size and 

abundant suitable forage for bison (ADF&G 2018e). 

The reintroduction has been successful, with most of the herd remaining in the Innoko Bottoms area, and 

stable to slowly increasing population numbers and successful breeding and calf survival documented 

(ADF&G 2017b). The ADF&G wood bison management plan calls for growth of the Lower 

Yukon/Innoko Rivers wood bison herd, and population models suggest that the 130 animals reintroduced 

to the wild in 2015 could grow to about 250 by 2021 and to 500 by about 2030, based on growth observed 

in populations reintroduced to areas of Canada in recent decades. Biologists are closely monitoring how 

the newly reintroduced bison are responding to their new habitat. The ADF&G will manage the 

population under sustained yield principles, which will allow limited subsistence and sport hunting when 

the herd reaches a population level that can sustain harvest (ADF&G 2015b). 

As shown in BSWI Draft RMP/EIS, Map 3.2.7-3, Innoko Bottoms also provides important connectivity 

corridors between the Innoko NWR and the Yukon Delta NWR. Connectivity corridors are climateresilient corridors that facilitate movement between conservation lands. These corridors were identified 

using the geodiversity model described in Magness et al (2018). The model uses topographic inputs to 

define geodiversity of the landscape and uses resistance surfaces to identify the most efficient but 

permeable paths between conservation units. From a planning perspective, connectivity corridors 

represent a small percentage of total BLM land area that can be managed for structural landscape 

connectivity. These corridors can help maintain general wildlife habitat connectivity, increase species 

adaptability to climate change, minimize habitat fragmentation and loss, and avoid or minimize barriers to 

wildlife movement (Magness et al. 2018). 

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Subsistence Hunting 

Fall hunting in the area for moose and waterfowl is largely by Yukon and Innoko River village residents 

using river boats. A winter subsistence moose hunt occurs in February and March using snowmobiles. 

Moose are an important subsistence resource for village residence of the area. 

Two federal moose hunts occur in Unit 21E in September and March and include the Innoko Bottoms 

area. A State nonresident permit drawing for a September hunt in Unit 21E was established in fall 2006 

to limit nonresident sport hunting of moose. 

Land Use Plan Decisions 

The proposed Innoko Bottoms Priority Wildlife Habitat Area would be consistent with BLM Planning 

Handbook H-1610-1 (Appendix C, E: Fish and Wildlife [BLM 2005]) and also support Secretarial Order 

3356 by enhancing waterfowl production and waterfowl hunting opportunities in Alaska as well as in 

states along the Pacific Flyway and areas where migratory waterfowl will be wintering. The Innoko 

Bottoms area is an important waterfowl production area in Alaska and contributes to waterfowl 

populations nationwide. 

The establishment of the Innoko Bottoms Priority Wildlife Habitat Area also supports Secretarial Order 

3362 by working with the State wildlife agency to enhance moose and introduced wood bison populations 

to protect habitats important to their winter range and seasonal movements. Conservation of the area 

provides access to the area for moose hunts by sport and subsistence users and helps ensure healthy 

populations of moose and wood bison, using the best available wildlife management practices. 

Moose populations in the Innoko Bottoms area are recognized as having some of the highest population 

densities in the State of Alaska by both Alaska resident and non-resident sport and subsistence hunters. 

Wood bison in the area are recognized for their remnant character as well as public interest for a species 

that has been absent from the landscape but recently been re-introduced to the area. 

2.7.6 Resource Changes: Trends and Forecasts 

In general, populations of wildlife in the planning area appear to be fluctuating within what is likely a 

natural range. Exceptions probably include several migratory bird species that are affected by impacts on 

winter ranges or migration routes occurring outside of Alaska, such as the olive-sided flycatcher 

(Contopus cooperi), and rusty blackbird (Euphagus carolinus). 

Caribou herd populations are naturally cyclic in nature, but recent research has suggested that increased 

tundra fires in northwestern Alaska could decrease the availability and quality of winter habitat available 

to caribou over the short term (up to 55 years), potentially influencing caribou herd population dynamics 

and reducing sustainable harvest levels (Joly et al. 2007). 

Moose populations in some regions of the planning area have recently experienced declines, although 

populations vary considerably across the planning area. 

The wood bison management plan calls for growth of the Lower Yukon/Innoko Rivers herd. Population 

models suggest that the 130 animals reintroduced to the wild in 2015 could grow to about 250 by 2021 

and to 500 by about 2030, based on growth observed in populations reintroduced to areas of Canada in 

recent decades. Biologists are closely monitoring how the newly reintroduced bison are responding to 

their new habitat. The ADF&G will manage the population under sustained yield principles, which will 

allow limited hunting (ADF&G 2015b). 

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Additional information on population trends is provided on a species-by-species basis in the Current 

Conditions – Wildlife Species section earlier in this document. 

2.8 Nonnative Invasive Species (Wildlife and Plant) 

2.8.1 Introduction 

This section presents the regulatory framework, resource indicators, current conditions, and trends and 

forecasts for NNIS in the planning area. 

2.8.2 Laws, Regulations, and Policies 

The BLM Alaska Land Health Standards and Guidelines (BLM 2004) provide general guidance for 

managing healthy ecosystems, focusing on retaining natural populations consistent with potential and 

capability of the landscape. The guidelines state that seeding and planting nonnative vegetation should 

only be used in cases where native species are not available in sufficient quantities; where native species 

are incapable of maintaining or achieving standards; or where nonnative species are essential to the 

functional integrity of the site. 

The 2017 Department of the Interior Department Manual, Part 524 (Invasive Species Management), 

Chapter 1 (Invasive Species Policy), establishes DOI policy that directs bureaus/offices to manage the 

risk of invasive species in their activities, and to minimize that risk where applicable and practicable, 

including preventing the introduction, establishment, and spread of invasive species, and providing for 

eradication and control to minimize adverse impacts, such as impacts to the environment, human health, 

cultural resources, and the economy. The 2010 BLM Alaska State Invasive Species Policy (IM AK-2011-

001a) provided statewide guidance for NNIS management (BLM 2010a), and incorporates principles 

outlined in the 2004 National Strategy and Implementation Plan for Invasive Species Management (U.S. 

Forest Service 2004); the 2016 Safeguarding America’s Lands and Waters from Invasive Species: a 

National Framework for Early Detection and Rapid Response (DOI 2016); and the 2016 Arctic Invasive 

Alien Species (ARIAS) Action Plan (CAFF 2016). 

The BLM Manual has three sections that apply specifically to NNIS management. These include 9220 –

Integrated Pest Management (1981), 9015 – Integrated Weed Management (1992), and 9011 – Chemical 

Pest Control (1992). 

The Carlson-Foley Act of 1968 (Public Law [P.L.] 90-583) provides authorization for federal agency or 

department heads to control noxious plants on federal lands in compliance with approved agency or 

department plans. 

EO 13112, Invasive Species (1999) provides guidelines to prevent the introduction of invasive species 

and provide for their control and to minimize economic, ecological and human health impacts that 

invasive species cause. This EO established the National Invasive Species Council, which regularly 

updates National Invasive Species Council Management Plans (2001-2018). 

The 2007 ROD for Vegetation Treatments Using Herbicides on Bureau of Land Management Lands in 17 

Western States Programmatic Environmental Impact Statement (BLM 2007a) guides actions regarding 

application of 11 herbicides. The 2016 ROD for Vegetation Treatments Using Aminopyralid, Fluroxypyr, 

and Rimsulfuron on BLM Lands in 17 Western States Programmatic Environmental Impact Statement 

(EIS) guides actions regarding these three herbicides for application control options for NNIS on BLM 

lands in Alaska (BLM 2016e). The Federal Insecticide, Fungicide, and Rodenticide Act of 1975 (7 U.S. 

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Code [U.S.C.] 136 et seq.) establishes an extensive regulatory system for controlling the sale, distribution, 

and application of pesticides. 

The Plant Protection Act (Title IV of the Agricultural Risk Protection Act of 2000) consolidates and 

modernizes statutes pertaining to plant protection, importation, transport, and quarantine that were 

previously addressed in various statutes, including the Federal Noxious Weed Act of 1974, the Federal 

Plant Pest Act, and the Plant Quarantine Act. The act also provides authorization for such entities as 

Animal and Plant Health Inspection Service to enforce transportation and quarantine practices to prevent 

NNIS spread. 

Existing regulations intended to reduce the introduction of NNIS in Alaska include the ADF&G 

prohibition on sport angler use of felt soles in fresh waters of Alaska, effective January 1, 2012 (ADF&G 

2012); the Alaska Board of Game’s prohibition of footgear with absorbent, fibrous material soles for 

hunters in fresh water effective January 1, 2013 (ADF&G 2013d); the State of Alaska regulations 

concerning permitted conditions and prohibitions for importing, possessing, transporting, or releasing fish 

and animals into the wild Alaska (AS 03.05.010, AS 03.05.027, AS 03.05.040, AS 44.37.030, AS 

03.05.090, 11 AAC 34.130, 11 AAC 34.140, 11 AAC 34.160, 11 AAC 34.170, AAC 34.115); and the 

ADNR quarantine of five aquatic invasive plants, effective March 5, 2014 (ADNR 2014). 

2.8.3 Resource Indicators 

The conditions that are established in the discussions below provide a baseline for NNIS-related values, 

which the impact analysis will be based on. The following indicators, along with qualitative discussions, 

will be used to evaluate impacts associated with management decisions in the BSWI Draft RMP/EIS. 

• Potential for increase in colonization and/or spread of nonnative invasive plants (terrestrial and 

aquatic) and wildlife (fish, aquatic invertebrates, and mammals) due to the following: 

o Surface-disturbing minerals actions 

o Wildland fire, firefighting actions, and prescribed fire 

o Woodland harvest actions 

o Recreation visitor use 

o Livestock grazing 

o Travel and transportation management actions, including OHV use 

Extent of occurrence of all taxa of invasive species will be presented in this section. Changes to these 

extents may be analyzed in terms of acres affected (plants), acres of wildland fire, acres of prescribed fire, 

number of permits issued for permitted activities, estimated recreational use volume, miles of waterway 

affected (aquatic freshwater plants or aquatic animals), amount of vessel traffic, estimated OHV use, 

known or estimated aircraft use and landings, or estimated or modeled numbers, vectors, and range 

(terrestrial animals or marine animals) as appropriate. 

2.8.4 Current Conditions 

Nonnative Invasive Terrestrial Plant Species 

In this document, the term nonnative invasive plant is an inclusive term to describe plants that are not 

native to Alaska. The term “weed” is commonly used for nonnative species but is often applied to both 

native and nonnative vegetation and is considered any plant that is growing where it is undesirable. The 

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term invasive species applies to a species whose introduction does or is likely to cause economic or 

environmental harm or harm to human health (EO 13112).Of the nonnative invasive plants known to 

occur within the planning area, some may be considered noxious plants. In BLM's national plan, Partners 

Against Weeds, An Action Plan for the Bureau of Land Management, a “noxious weed” is defined as “a 

plant that interferes with management objectives for a given area of land at a given point in time” (BLM

1996). As defined in the Alaska BLM Statewide Land Health Standards (BLM 2004), native species are 

any species of plant or animal naturally occurring within a given area of land or body of water; or part of 

the original flora or fauna of the United States; or indigenous. A noxious weed is referred to as an 

undesirable plant because it is of no forage value (or even toxic) or is capable of invading a community 

and replacing native species. 

Most invasive species occur in disturbed areas such as along roadsides and within communities. Invasive 

species also occur in association with disturbances from placer mining, recreation, road repair and gravel 

extraction. Most of these species come from South America, Europe, Asia, or Russia. These plants were 

usually imported, either intentionally for their perceived value to humans, or inadvertently as 

contaminants in other products. Invasive species include plants able to establish on a site where they were 

not present in the original plant composition. Invasive species aggressively out-compete native species 

within a community and often alter the physical and biotic components enough to affect the entire 

ecological community. Invasive species are of particular concern following a disturbance. 

Presence of nonnative invasive terrestrial plant species is undesirable as a departure from properly 

functioning condition (see Section 2.6, Vegetation, for a discussion of properly functioning condition in 

the context of the planning area). Several indicators can be applied annually as a proxy for field surveys 

or field monitoring activities in order to assess risk of new infestations or to assess risk of spread of 

existing populations. These include: 

• Acres of burned areas or human activity (including fire suppression or prescribed fire activities) 

that are proximate to existing infestations 

• Acres of planned construction activities, such as new roads, structures, temporary or permanent 

camps 

• Number of permitted mining activities 

• Number of special permits issued 

• Estimated recreational use (number of users) 

• Estimated OHV use (number of vehicles) 

• Statewide nonnative invasive plant data to assess new potential threats near the planning area 

• Plane or helicopter landings, boat launchings (self-reported or other) 

• Habitat mapping that incorporates predicted temperature and precipitation data to predict likely 

areas of infestation 

If field surveys are conducted for detection or monitoring purposes, locations should focus on: 

• Recently burned areas 

• Areas of recreation use, such as trails, OHV tracks, or campsites 

• Special permit areas 

• Documented areas of presence or infestations (see Table 2.8.4-1) 

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• Mining activity areas 

• Areas with any reclamation activities 

• Any locations with surface-disturbing construction or other activity 

• Landing pads or landing strips 

• Boat launches or landings 

• Areas around structures, cabins, or other infrastructure 

• High likelihood areas determined by predictive habitat mapping 

• Areas identified by prior surveys as having high likelihood of infestation 

• Areas reported through the State of Alaska's online reporting system (phone, online, or email, 

http://www.adfg.alaska.gov/index.cfm?adfg=invasive.report) 

Table 2.8.4-1. Nonnative Invasive Plant Species Known to Occur in the Planning Area 

Family Scientific Name Occurrences Common Name Rank 

Amaranthaceae Amaranthus retroflexus 1 redroot pigweed 45 

Asteraceae Crepis tectorum 126 narrowleaf hawksbeard 56 

Gnaphalium uliginosum 1 marsh cudweed Not 

Assigned 

Leontodon autumnalis 7 fall dandelion 51 

Leucanthemum vulgare 8 oxeye daisy 61 

Matricaria discoidea 85 pineappleweed 32 

Senecio vulgaris 2 common groundsel 36 

Taraxacum officinale 60 common dandelion 58 

Tripleurospermum inodorum 3 scentless false mayweed 48 

Brassicaceae Brassica napus 1 rapeseed 47 

Brassica rapa 3 field mustard 50 

Capsella bursa-pastoris 11 shepherd's purse 40 

Descurainia sophia 5 herb sophia 41 

Lepidium densiflorum 1 common pepperweed 25 

Campanulaceae Campanula rapunculoides 1 rampion bellflower 64 

Caryophyllaceae Cerastium fontanum ssp. 

Vulgare 

7 big chickweed 36 

Stellaria media 36 common chickweed 42 

Chenopodiaceae Chenopodium album 70 lambsquarters 37 

Fabaceae Caragana arborescens 3 Siberian peashrub 74 

Melilotus albus 1 white sweetclover 81 

Trifolium variegatum 1 whitetip clover Not 

Assigned 

Trifolium hybridum 8 alsike clover 57 

Trifolium pratense 3 red clover 53 

Trifolium repens 22 white clover 59 

Vicia cracca ssp. cracca 2 bird vetch 73 

Lamiaceae Galeopsis bifida 16 splitlip hempnettle 50 

Galeopsis tetrahit 8 brittlestem hempnettle 50 

Orobanchaceae Euphrasia nemorosae 3 common eyebright 42 

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Family Scientific Name Occurrences Common Name Rank 

Plantaginaceae Linaria vulgaris 9 butter and eggs 69 

Plantago major 80 common plantain 44 

Poaceae Bromus inermis 5 smooth brome 62 

Poaceae Elymus repens 6 quackgrass 59 

Hordeum jubatum 74 foxtail barley 63 

Hordeum vulgare 3 common barley 39 

Lolium multiflorum 1 Italian ryegrass 41 

Lolium perenne 2 perennial ryegrass 52 

Phleum pratense 1 timothy 54 

Poa annua 6 annual bluegrass 46 

Poa pratensis ssp. irrigata 7 spreading bluegrass or Kentucky 

bluegrass 

52 

Schedonorus pratensis 1 meadow fescue Not 

Assigned 

Polygonaceae Fallopia convolvulus 2 black bindweed 50 

Polygonum aviculare 41 prostrate knotweed 45 

Rheum rhabarbarum 1 garden rhubarb Not 

Assigned 

Rumex acetosella 12 common sheep sorrel 51 

Rumex crispus 3 curly dock 48 

Ranunculaceae Ranunculus repens 3 creeping buttercup 54 

Rosaceae Prunus padus 2 European bird cherry 74 

Prunus virginiana 2 chokecherry 74 

Sorbaria sorbifolia 1 false spiraea Not 

Assigned 

Violaceae Viola tricolor 1 johnny jumpup 34 

Source: AKEPIC 2016 

Known nonnative invasive plant species populations within the planning area have been documented with 

the Alaska Exotic Plant Information Clearinghouse (AKEPIC) of the ACCS (formerly the Alaska Natural 

History Program) (AKEPIC 2016) (BSWI Draft RMP/EIS, Map 3.2.8-1). There are 50 species 

representing 15 families with 758 total occurrences within the planning area, with risk rankings from 32 

to 81 (Table 2.8.4-1). Ranking is a score between 0 and 100 based on ecological impacts, biological 

characteristics and dispersal ability, distribution, and feasibility of control. Scores greater than 80 indicate 

the species is Extremely Invasive, 70 to 79 are Highly Invasive, both very threatening to Alaska; scores of 

60 to 69 are Moderately Invasive, while 50 to 59 are Modestly Invasive, both posing substantial risks to 

ecosystems in Alaska; scores of 40 to 49 are Weakly Invasive, and scores less than 40 are considered 

Very Weakly Invasive, and probably do not require as much attention as other species (Nawrocki et al. 

2011; Carlson et al. 2008). 

ACCS has been controlling infestations of nonnative invasive plant species around the Rohn cabin since 

2009 (ACCS 2015). This cabin is a hub of activity for the Iditarod Trail Sled Dog Race, in which a large 

amount of materials are transported to the site, such as straw for dog bedding. Control methods include a 

combination of hand pulling, tarping with landscape fabric, and mulching with local materials. The Nixon 

Fork mine is also thought to have done some invasive control work. There are no other known organized 

control or eradication efforts underway on known nonnative invasive plant species within the planning 

area, or on BLM lands within the planning area. 

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BSWI Draft RMP/EIS, Map 3.2.8-1 illustrates location and numbers of known nonnative invasive 

terrestrial plant species in the region based on 2016 AKEPIC data. At all known locations, between one 

and sixteen species were recorded. In some locations, the number of individuals per species or number of 

species was high, so a scaled map legend best depicts the density across the landscape. The number of 

species is scaled by smaller green dots (one species), then larger yellow dots (2-5 species), then larger 

orange dots (lighter shade, 6-10 species; darker shade, 11-15 species), and finally the largest red dot (16 

species). Areas with greater concentrations of species may be sources of potential invasion into 

neighboring non-invaded areas and may be target areas for focused control or eradication efforts. Highest 

concentrations of species are found in developed areas including villages, roadways, boat landings, 

airstrips, and trails. 

Nonnative Invasive Aquatic Species 

Fish and aquatic biota and habitat, both freshwater and marine, can be affected by invasive species 

introduced to streams, lakes, ponds, wetlands, estuaries, beaches, coastal areas, and other aquatic habitat. 

Table 2.8.4-2 lists nonnative invasive aquatic species (plant and animal) that are either known to occur in 

Alaska or gives the nearest known location for species considered to be high risk to Alaska aquatic 

habitats. Both freshwater and marine habitats exist in the project area that may be vulnerable to 

infestation by nonnative invasive aquatic species. 

Table 2.8.4-2. Marine or Freshwater Nonnative Invasive Species with Highest Potential for Spread 

or Introduction to the Planning Area 

Common Habitat and Nearest 

Category Name Scientific Name Vector Ecophysiology Occurrence 

Fish Atlantic salmon Salmo salar Escapement 

from pens 

Estuarine environments. 

Voracious feeder on juvenile 

native crab and shellfish. 

Washington State and 

British Columbia fish 

farms; a few 

individuals found in 

SoutheastSouthcoastal Alaska 

areas 

Fish yellow perch Perca flavescens Deliberate 

introductions 

Warm or cool lakes, ponds, 

sluggish streams, lakes with 

soft bottoms; eats 

zooplankton then crabs, 

snails, isopods, and insect 

larvae. Can complete with 

native resident fish species. 

Native to most of 

North America 

including parts of 

northern Canada; few 

individual have been 

found in central 

Alaska; species is 

considered eradicated 

in Alaska 

Crab European Carcinus maenas larval transport in Estuarine environments. British Columbia 

green crab ballast water Voracious feeder on juvenile 

native crab and shellfish. 

Algae caulerpa, killer 

seaweed 

Caulerpa taxifolia aquarium dumps; 

larval transport in 

ballast water 

Cold temperate marine 

environments. Common 

aquarium species. Grows 

voraciously on all surfaces 

in marine environments. 

Outcompetes all other 

species. 

Northern California 

(considered 

eradicated) 

Algae Asian kelp, 

wakame 

Undaria pinnatifida larval transport in 

ballast water; hull 

fouling 

Cold temperate marine 

environments. Cultivated 

food species. Outcompetes 

other species and smothers 

marine surfaces. 

Argentina, New 

Zealand 

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Category 

Common 

Name Scientific Name Vector 

Habitat and 

Ecophysiology 

Nearest 

Occurrence 

Amphipod no common 

name 

Monocorophium 

ascherusicum 

ballast water Free marine species. 

Ecophysiology largely 

unknown. 

Pacific Ocean 

Amphipod no common 

name 

Elasmopus rapax ballast water Free marine species, depth 

range from about 0 to 100 

meters. Often among algae 

in shallow sub-tidal habitats. 

Pacific Ocean 

Ascidian - sea squirt, Didemnum floating rafts, Forms colonies. Completely Sitka, AK; west coast 

colonial marine vomit, vexillum infested material, smothers seafloor, grows of North America 

tunicate d-vex infested 

aquaculture 

stock 

over all substrate and other 

organisms, destroys marine 

habitat. 

Ascidian - star ascidian, Botryllus schlosseri floating rafts, Forms colonies in flat sheets West coast of North 

colonial golden star infested material, that often appear lobate. America; Asian 

tunicate tunicate infested 

aquaculture 

stock, hull fouling 

Adheres to docks, boat 

hulls, buoys, ropes, pilings, 

rocks, mussels, solitary sea 

squirts, seaweeds, and 

eelgrass. Filter feeder by 

water pump. 

Pacific Ocean 

Ascidian - sea squirt Botrylloides floating rafts, Forms colonies arranged in Detected in Gulf of 

colonial violaceus infested material, columnar systems with a Alaska; North Pacific 

tunicate infested 

aquaculture 

stock, hull fouling 

firm, clear matrix. Adheres 

to docks, boats hulls, buoys, 

ropes, pilings, rocks, 

eelgrass blades, and 

seaweeds. Overgrows 

mussels, barnacles, 

bryozoans, and solitary sea 

squirts. Filter feeder by 

water pump. 

Ocean 

Ascidian - vase tunicate, Ciona intestinalis hull fouling, Solitary form with vase-like Asian and North 

solitary sea squirt infested shape. Grows on pilings, Pacific Ocean 

tunicate materials, ballast 

water 

aquaculture gear, floats, and 

boat hulls. Lower intertidal 

to tidal zone 

Ascidian - transparent Ciona savignyi hull fouling, Solitary form with pillar-like West coast of North 

solitary ciona, Pacific infested shape up to 15 cm long. America 

tunicate transparent sea 

squirt 

materials, ballast 

water 

Forms dense patches on 

docks, pilings, marinas, 

harbors, and aquaculture 

structures. 

Ascidian - club tunicate, Styela clava hull fouling, Solitary form with club-like Asian Pacific Ocean 

solitary stalked tunicate infested shape up to 20 cm long. 

tunicate materials, ballast 

water 

Often covered with other 

organisms. Grows on rocks, 

floats, pilings, oyster and 

mussel shells, and 

seaweeds. Filter feeder by 

siphon. 

Bryozoan no common 

name 

Waterispora 

subtorquata 

hull fouling Colonial growth on rocks, 

shells, docks, vessel hulls, 

pilings, debris, kelp holdfast, 

other bryozoans. 

Pacific Ocean 

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Category 

Common 

Name Scientific Name Vector 

Habitat and 

Ecophysiology 

Nearest 

Occurrence 

Bryozoan spiral tufted 

bryozoa 

Bugula neritina hull fouling Colonial growth in upright, 

bushy, branching tufts up to 

15 cm, often mistaken for 

seaweed. Filter feeding by 

tentacles. Grows in intertidal 

to shallow subtidal zones on 

docksides, buoys, pilings, 

rocks, shells, seaweeds, 

sea grasses, sea squirts, 

and other bryozoans. 

Pacific Ocean 

Snail Japanese drill 

snail, 

hornmouth 

snail 

Ceratostoma 

inornatum 

larval transport in 

ballast water 

Estuarine and marine 

habitats in cool waters. 

Feeds voraciously on 

oysters. 

British Columbia 

Snail Eastern oyster 

drill, Atlantic 

oyster drill 

Urosalpinx cinera ballast water Intertidal and shallow 

subtidal waters to a 

maximum depth of 15m. 

Common on rocks and 

oyster reefs. Feeds on 

oysters, barnacles, mussels, 

and snails. 

British Columbia 

Snail Eastern mud 

snail 

Nassarius 

obsoletus 

(Ilyanassa 

obsoleta) 

larval transport in 

ballast water 

Mud flats in intertidal and 

shallow subtidal zones, in 

sounds and inlets. Forms 

large herds. Feeds on 

diatoms, algal detritus, 

worms, dead fish, crabs, 

and other animal remains. 

Northern California 

Copepod no common 

name 

Oithona davisae ballast water Free marine species in 

temperate coastal waters. 

Ecophysiology largely 

unknown. 

Detected in Pacific 

Ocean near California 

Aquatic cordgrasses Spartina spp. (S. floating plant Mudflats. Fills and uplifts British Columbia 

Plant, alterniflora, S. parts habitats. Alters fish nursery 

Marine anglica, S. 

alternaflora x 

foliosa, S. 

densifolora, S. 

densiflora x foliosa, 

S. patens) 

habitat structure and 

shoreline structure. 

Aquatic elodea, Elodea spp. (E. plant parts, Still or moving freshwater Chena Slough, 

Plant, waterweed nuttallii, E. transport by float lakes, ponds, and streams. Fairbanks, AK; Kenai 

Freshwater canadensis, 

hybrids) 

plane or boat Tolerates freezing and very 

cold temperatures. Can 

reproduce from tiny 

fragments. Spreads rapidly. 

Outcompetes native aquatic 

vegetation and chokes 

waterways. 

Peninsula, AK; 

Anchorage, AK; 

Matanuska-Susitna 

Valley, AK 

Source: Davis 2015; Shaw 2015 

Fourteen nonnative invasive fish species have been identified as occurring in Alaska, including Atlantic 

salmon (Salmo salar) and yellow perch (Perca flavescens) (McClory and Gotthardt 2008). Of these 

fourteen species, some are considered native to other parts of the state but have been noted in new parts of 

the state in which the species was not previously known to occur and was not considered native. None of 

the listed fish species have been demonstrated to establish breeding populations in Alaska. Northern pike, 

a fish species that does occur within the planning area, is considered to be a nonnative invasive fish 

species in parts of the state but is considered native within the entire planning area (ADF&G 2018b). 

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Only one nonnative invasive freshwater plant species, elodea or waterweed (Elodea canadensis, E. 

nuttallii, and hybrids) is known within the State of Alaska. This species could survive in habitats within 

the planning area, although elodea is not currently known to occur within the planning area. Elodea can 

be transported by several vectors including freshwater vessels, floatplanes, birds such as waterfowl, or on 

gear or equipment. 

Only one nonnative invasive marine species, the seasquirt (Didemnum vexillum), is known to occur within 

the State of Alaska near Sitka. Vessel traffic to the Port of Bethel is a potential vector for nonnative 

invasive marine species introduction. Ballast water and hull fouling (biofouling) are two major vectors for 

aquatic invasive species, particularly marine invasive species. Biofouling is considered one of the 

strongest vectors of invasion transport in marine environments. In Alaska, the EPA Vessel General Permit 

required for barges outlines BMPs for hull fouling prevention and management but has no regulatory 

authority. The U.S. Coast Guard, under the Department of Homeland Security, provides information 

about voluntary anti-fouling practices. 

Presence of nonnative invasive aquatic species is undesirable in an ecological context. Several indicators 

can be applied annually as a proxy for field surveys or field monitoring activities in order to assess risk of 

new infestations or to assess risk of spread of existing populations. These include: 

• Barge traffic numbers (Port of Bethel or smaller ports) 

• River vessel volume estimates or counts 

• Floatplane landings and boat launchings (self-reported or other) 

• Number of special permits issued in or near aquatic habitats 

• Estimated recreational use (number of users) in or near aquatic habitats 

• Estimated OHV use (number of vehicles) in areas adjacent to aquatic habitats 

• Aquatic habitat modeling that incorporates predicted water temperature or level changes to 

predict likely areas of infestation 

• ADF&G statewide data on known infestations 

• Vector models that predict rate and direction of spread if infestations are discovered near the 

planning area 

If field surveys are conducted for detection or monitoring purposes, locations should focus on the specific 

species of interest (freshwater or marine), and include: 

• Marine traffic areas (port sites, docks, cargo storage areas, port infrastructure) 

• Aquatic areas adjacent to recreation use, such as boat launches, docks, or campsites 

• Special permit areas in or near aquatic habitats 

• Any newly documented areas of presence or infestations 

• Areas with any reclamation activities in or near aquatic habitats 

• Any locations with surface-disturbing construction or other activity in or near aquatic habitats 

• Water bodies big enough for floatplane presence 

• Boat launches or landings 

• High likelihood areas determined by predictive habitat or vector modeling 

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• Areas identified by prior surveys as having high likelihood of infestation 

• Areas reported through the State of Alaska's online reporting system (phone, online, or email, 

http://www.adfg.alaska.gov/index.cfm?adfg=invasive.report) 

Nonnative Invasive Mammal Species 

Alaska currently has few nonnative invasive mammal species that have spread to the point of causing 

major ecological effects, except on the Aleutian Islands (ADF&G 2015c). Norway rats (Rattus 

norvegicus) are a nonnative invasive terrestrial mammal species that has colonized numerous cities and 

islands in Alaska, including Dutch Harbor, Nome, and Fairbanks (ADF&G 2015c). The potential for 

invasions of rats from barges and other vessels has existed for many years; however, if any have reached 

shore in any coastal communities or the Port of Bethel within the planning area, they have apparently not 

persisted or established known colonies. This may be the result of typical invasion barriers, which include 

a combination of biological factors (e.g., predation by domestic and wild predators), physical factors (e.g., 

widely distributed small communities that reduce the availability of suitable habitats) and simple luck or 

lack of sufficient repeated introductions. Rats can have a variety of adverse effects on the ecosystem and 

other terrestrial mammals, including competition for a wide range of food resources and the potential to 

spread parasites and diseases. Rats have had devastating effects on some islands, primarily by eating 

seabirds and disrupting their nesting efforts, but also by changing vegetation patterns and the presence of 

other predators (AMNWR 2007). Invasions of rats have typically occurred when rats living on marine 

vessels have escaped while the vessel was in port, or during shipwrecks. Under Alaska law (5 AAC 

92.141), it is illegal for any property owner or vessel operator to knowingly transport Muridae rodents 

(including Norway rats) into Alaska and it is the responsibility of the property or vessel owner to develop 

and implement ongoing rodent control and eradication plans if any such rodents are discovered. 

Presence of nonnative invasive mammal species is undesirable in an ecological context. Due to the 

currently small numbers of known species in Alaska, there are few indicators that can be applied to assess 

risk of new infestations or to assess risk of spread of existing populations. These include the following: 

• Barge traffic numbers (Port of Bethel or smaller ports) 

• River vessel volume estimates or counts 

• Historical records of introduction 

• Vector models that predict rate and direction of spread if infestations are discovered near the 

planning area 

• ADF&G data on statewide infestations 

If field surveys are conducted for detection or monitoring purposes, locations should focus on the 

following: 

• Marine traffic areas (port sites, docks, cargo storage areas, port infrastructure) 

• Any newly documented areas of presence or infestations 

• High likelihood areas determined by predictive habitat or vector modeling 

• Areas identified by prior surveys as having high likelihood of infestation 

• Areas reported through the State of Alaska's online reporting system (phone, online, or email, 

http://www.adfg.alaska.gov/index.cfm?adfg=invasive.report) 

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Other Nonnative Invasive Species 

Nonnative invasive bird and invertebrate species have been detected in Alaska but are not known within 

the planning area (ADF&G 2015c). Nonnative invasive insect species are forests pests tracked by the 

Alaska Forest Health Protection Program of ADF&G, in cooperation with the Forest Service, including 

the introduced birch leaf miner (Fenusa pusilla). Birch defoliation has been detected within the planning 

area in aerial insect and disease detection surveys (U.S. Forest Service 2015), which may indicate 

presence of the nonnative invasive birch leaf miner but may also be attributed to native insects such as 

aphids (superfamily Aphidoidea). Currently, no serious nonnative invasive pathogens are known to occur 

in Alaska. Nonnative invasive pathogens include microscopic organisms such as viruses that can cause 

disease in trees, plants, birds, or wildlife species. 

2.8.5 Resource Changes: Trends and Forecasts 

As most vegetative communities in this large and relatively inaccessible planning area are largely 

undisturbed by human activities, the volume of NNIS is low. Concentrated populations are found near 

areas of human disturbance. Given the relatively pristine condition of much of the landscape, early 

detection and rapid response to any new infestations is key to maintaining healthy landscape conditions. 

Additional species, beyond those known to occur in the planning area, have been recorded regionally that 

could potentially move into the planning area. Transport vectors or pathways for invasion include 

vehicles, vessels, planes, or equipment moving from an invaded location to a non-invaded location 

without proper sanitation or cleaning practices; ballast water exchange; contaminated soil, nursery stock, 

or seeds; natural transport through wind, water, animal, or other natural process movement across the 

landscape; or intentional transport as a result of deliberate action to translocate an organism. Increases in 

surface-disturbing activities or development may provide additional habitat for establishment of 

additional or expanded NNIS populations. Control or eradication of existing population should be 

considered to prevent infestations from spreading into new or larger areas. Education efforts concerning 

NNIS risks, pathways and vectors may help reduce unintentional and intentional introductions and 

transport. 

Climate change is predicted to increase suitable habitat for all taxa of NNIS in all environments, including 

terrestrial, marine aquatic, and freshwater aquatic habitat. Alaska was at one time thought to be too cold 

to support large-scale populations of NNIS; however, invasion demography studies suggest that repeated 

introductions of viable species within an area of suitable habitat is a stronger driver in successful and 

persistent nonnative invasive populations. Once established, NNIS have adaptations that may enable them 

to persist and outcompete native species. 

Of serious concern is the potential for introduction and spread of nonnative invasive pathogens such as 

virus-causing diseases that may impact fish or wildlife species (ADF&G 2015c). Increases in wildfire 

frequency and severity due to a changing climate have the potential to increase available habitat for 

invasions, as well as providing more opportunity for introduction by equipment, vehicles, and gear 

vectors. 

2.9 Wildland Fire 

2.9.1 Introduction 

This section discusses the policy, management direction, and resource conditions impacting wildland fire 

in the decision area. A brief history of fire in the planning area, as well as a discussion of fire frequency 

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and severity and prevalent fuel models in the planning area is included. Vegetation conditions are further 

discussed in Section 2.6, Vegetation. 

2.9.2 Laws, Regulations, and Policies 

Fire management in Alaska is regulated through the following guidances and procedures: 

• Federal Wildland Fire Management Policy of 1995 

• Review and Update of the 1995 Federal Wildland Fire Management Policy (January 2001) 

• Guidance for Implementation of Federal Wildland Fire Management Policy (February 13, 2009) 

• A Collaborative Approach for Reducing Wildland Fire Risks to Communities and the 

Environment: 10 Year Comprehensive Strategy (August 2001) 

• Record of Decision: Final Vegetation Treatments Using Herbicides on Bureau of Land 

Management Lands in 17 Western States Programmatic Environmental Impact Statement (2007) 

• BLM Fire Management Handbook #H-9211-1, Healthy Forests Restoration Act of 2003 

• BLM Burned Area Emergency Stabilization and Rehabilitation Handbook #H-1742-1 (2007) 

• Alaska Land Use Plan Amendment for Wildland Fire and Fuels Management (2016) 

• Healthy Forests Restoration Act 2003 

• The Federal Land Assistance, Management and Enhancement Act of 2009 (FLAME Act) and 

Alaska Enhanced Smoke Management Plan for Planned Fire Procedures Manual June 3, 

2015Department of Interior Manual 620 DM 5 

• Alaska Master Cooperative Wildland Fire Management and Stafford Act Agreement (2015 or 

most current) 

• Alaska Statewide Annual Operating Plan (2017 or most current) 

• Alaska Interagency Wildland Fire Management Plan (2017 review, or most current) 

The federal policy identifies guiding principles, management intent and implementation strategies that are 

to be used to achieve fire management goals and objectives identified in land use plans or specific fire 

management plans. These principles and policies address fire fighter and public safety, fire management 

and ecosystem sustainability, response to wildland fire, use of wildland fire, rehabilitation and restoration, 

protection priorities, wildland urban interface, planning, science, preparedness, suppression, prevention, 

standardization, interagency cooperation and coordination, communication and education, agency 

administrator and employee roles and evaluation (USDA et al. 2009). 

Federal wildland fire policy forms the basis for all BLM fire management programs in Alaska. In Alaska, 

the BLM Alaska Fire Service was created to provide suppression services for all DOI agencies and lands 

conveyed under ANCSA (BLM-AFS 2016). Department of the Interior Manual 620 Chapter 5, the Alaska 

Master Cooperative Wildland Fire Management and Stafford Act Response Agreement (Alaska Master 

Agreement) and the Alaska Statewide Annual Operating Plan (Alaska AOP) work together to define an 

interagency organization that manages wildland fire across agency boundaries throughout the state. The 

organization separates protecting responsibilities from jurisdictional responsibilities to reduce duplication 

and provide efficiencies of scale. Current BLM fire management direction for the planning area is defined 

in the 2005 Land Use Plan Amendment for Wildland Fire and Fuels Management for Alaska 

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managed public lands is further defined in the 2005 BLM – Alaska Wildland Fire Management Plan and 

is supported by direction in the 2006 Alaska Interagency Wildland Fire Management Plan (AIWFMP). 

The response to a wildfire is based on the ecological, social, and legal consequences associated with the 

fire. Suppression strategies are based on the circumstances under which a fire occurs; and will prioritize 

firefighter and public safety, protecting human communities and infrastructure, and protecting natural and 

cultural resources threatened. 

The AIWFMP, which has been incorporated by reference into the Alaska AOP, defines four Fire 

Management Options that provide initial response direction for managing wildfires in Alaska. The 

Management Options span jurisdictional boundaries and are designed to collectively achieve the 

following: 

• Prioritize areas for protection actions and the allocation of available firefighting resources to 

achieve protection objectives; 

• Optimize the ability to achieve land use and resource management objectives and integrate fire 

management, mission objectives, land use, and natural resource goals; and 

• Reinforce the premise that the cost of suppression efforts should be commensurate with the 

values identified for protection (AWFCG 2016). 

Management options are reviewed on an annual basis and may be updated as needed through a process 

defined in the AIWFMP to ensure they remain consistent with direction provided by jurisdictional RMPs. 

For fires extending beyond initial-attack BLM Fire Managers use a decision support process to guide and 

document wildfire management decisions, provide situational assessments, analyze hazards and risk, 

define implementation actions and document decisions and rationale for those decisions (FEC 2009). The 

current decision support process used by BLM, other federal agencies, and the State of Alaska is the 

Wildland Fire Decision Support System (WFDSS). The WFDSS process is used by managers to bring 

together the values, objectives, and management requirements identified by all affected jurisdictions; 

analyze risk associated with the fire using a suite of tools that includes fire behavior and spread prediction 

models; develop courses of action designed to meet objectives; and document decisions and rationales. 

The process is iterative and requires periodic re-assessment in order to ensure selected courses of action 

continue to support objectives and maintain an appropriate level of risk. 

2.9.3 Resource Indicators 

The conditions that are established in the discussions below provide a baseline for wildland fire-related 

values, which the impact analysis will be based on. The following indicators, along with qualitative 

discussions, will be used to evaluate impacts associated with management decisions in the BSWI Draft 

RMP/EIS: 

• Extent and severity of potential wildland fires 

• Potential for human caused fire 

• Areas open to fuels treatments, treatment priorities, and restrictions on treatments 

• Potential for changes to fuel model acres and fire behavior, including burn severity 

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2.9.4 Current Conditions 

Fire History 

Wildfires within the planning area are predominantly ignited by lightning. Human caused fires result from 

ignitions from campfires, burning debris, vehicles and other sources. In general, fire frequency increases 

from coastal areas into the interior (BLM 2015a). Fires are rare within 100 miles of the coast. Fire history 

data for large wildfires reported by BLM from 1977 to 2016 within the planning area show a total of 

8,875,141 acres burned (See Table 2.9.4-1) (BLM GIS 2016). Decadal acres burned have increased from 

a low of 541,421 in the 1980s to a high of 2,709,820 acres in the 1990s (BLM GIS 2016). Acres burned 

have continued to exceed 2.0 million acres for each 10-year period from 1990 through 2010 (BLM GIS 

2016). 

Table 2.9.4-1. Planning Area Decadal Fire History 

Years Acres Burned 

1977-1980 730,136 

1980-1990 541,421 

1990-2000 2,709,820 

2000-2010 2,607,432 

2010-2016 2,286,332 

Total 8,875,141 

Note: Includes all BLM-managed and non-BLM-managed lands within the planning area 

Source: BLM GIS 2016 

Fire Regime 

A natural fire regime is a general classification of the role fire would play across a landscape in the 

absence of modern human intervention but including the possible influence of aboriginal fire use (Agee 

1993; Brown and Smith 2000). The five natural fire regime groups are classified based on the average 

number of years between fires (fire frequency or mean fire interval) combined with characteristic fire 

severity reflecting percent replacement of dominant overstory vegetation (NIFIT 2010). These five 

natural fire regimes are defined in Table 2.9.4-2. Approximately 61 percent of the planning area is located 

with Fire Regime Groups III, IV, and V (BSWI Draft RMP/EIS, Map 3.2.9-2). The balance of the 

planning area comprises 14 percent with unburnable surface material, and 25 percent for which the fire 

regime has not been determined. 

Table 2.9.4-2. Planning Area Historical Fire Regimes Based on Fire Frequency and Severity 

Fire 

Regime 

Group 

Fire Frequency and Severity 

Percent Vegetation in 

Planning Area by Fire 

Cycle (%) 

Acres in Planning 

Area 

I 0-35 years; low severity (surface fire most common) 0 0 

II 0-35 years; high severity (stand replacement) 0 0 

III 35-100+ years; mixed severity 7 3,838,950.5 

IV 35-100+ years; high severity (stand replacement) 31 19,766,504 

V > 200 years; high severity (stand replacement) 23 14,335,450 

Note: Includes all BLM-managed and non-BLM-managed lands within the planning area. Approximately 14 percent of the planning area is 

unburnable, and 25 percent is indeterminate. 

Sources: Fire regime group definitions source FRCC Guidebook version 3.0, September 2010. Planning area vegetation data source LANDFIRE data 

(Barrett et al. 2010) 

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Fire Fuel Models 

Fuels within the planning area include a mix of burnable vegetation types ranging from boreal hardwood 

and conifer forests to shrub and sedge dominated tundra (see BSWI Draft RMP/EIS, Map 3.2.9-3). 

Twenty of the forty fuel models in Scott and Burgan's comprehensive set (Scott and Burgan 2005) are 

represented within the planning area; including models for grasses, shrubs, timber, and non-burnable 

vegetation types. Table 2.9.4-3 shows the acreage associated with each of these models within the 

planning area. 

Black spruce forests are the most common forest type within the planning area. The interior of the 

planning area is dominated by Alaskan black spruce communities that form mosaics with quaking aspenbirch, white spruce, and mixed wood (spruce-hardwood) stands. Black spruce is adapted to fire through 

semi-serotinous cones held high in the canopy that rain seed for several years post-fire. Their seeds can 

germinate and survive on remaining duff after low and moderate severity fires. High severity fires that 

burn to mineral soil favor the establishment of birch or aspen. Black spruce is susceptible to crown fire 

because they retain lower branches near ground level and maximum foliar moisture content is much lower 

than other conifer species. Wildfire is carried easily from low branches to crowns especially when 

understory shrubs are present providing ladder fuels to the tree canopy (Fryer 2014). 

The major timber fuel models within the planning area include: 

• TU4, which includes stands dominated by either black spruce or black/white spruce paper birch, 

tamarack, and quaking aspen 

• TU1, which includes closed white spruce forest types and some scattered paper birch or balsam 

poplar 

• TU5, which includes white spruce, ranging in cover from 25–60 percent, black spruce, paper 

birch, and aspen and a resin birch shrub layer. 

• TU3, which includes overstory dominated by black spruce with low productivity, white spruce 

and paper birch. 

The major shrub fuel component within the planning area is SH 2, comprised of birch, willow or 

ericaceous shrubs. 

The major grass fuel models within the planning area include GR1 and GR2. These communities mostly 

comprise tundra dominated by grasses and sedges, primarily tussock cotton grass (Eriophorum 

vaginatum) or Bigelow’s sedge (Carex bigelowii). Associated species are dryas, lichens, bearberry, 

Vaccinium species, crowberry, mountain heath, and cassiope. Mosses and lichens are nearly continuous 

(Scott and Burgan 2005; Cella et al. 2008). 

Table 2.9.4-3. Fuel Models within Planning Area 

Fuel 

Model 

Code 

Fuel Model 

Name Fuel Model and Fire Behavior Description 

Fuel Model 

Acres within 

Planning 

Area 

NB 1 Non-burnable Consists of land covered by urban and suburban development. 2,114.8 

NB 2 Non-burnable Consists of Land covered by permanent snow or ice is included 127,559.7 

NB 8 Non-burnable Includes land covered by open bodies of water such as lakes, rivers 4,909,670.6 

NB 9 Non-burnable Includes bare ground 4,845,233.8 

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Fuel 

Model 

Code 

Fuel Model 

Name Fuel Model and Fire Behavior Description 

Fuel Model 

Acres within 

Planning 

Area 

GR 1 Grass - short 

grass 

Includes short, sparse grass - predicted spread rate and flame length are low 

compared to other GR models. These communities are dominated by dryas, 

fruticose lichens, bearberry, Vaccinium species, crowberry, mountain heath, 

cassiope, sedges are common, primarily tussock cotton grass (Eriophorum 

vaginatum) or Bigelow’s sedge (Carex bigelowii), mosses and lichens are nearly 

continuous. Dwarf willows and shrubs, like alder, may be tall or short with less 

than 25 percent cover growing (Scott and Burgan 2005; Cella et al. 2008). 

8,980,472.3 

GR 2 Grass - low load Low Load - Short, Sparse Dry Climate Grass - Load is greater than GR1, and 

fuelbed may be more continuous. These communities are dominated by dryas, 

fruticose lichens, bearberry, Vaccinium species, crowberry, mountain heath, 

cassiope, sedges are common, primarily tussock cotton grass or Bigelow’s

sedge, mosses and lichens are nearly continuous. Dwarf willows and shrubs, 

like alder, may be tall or short with less than 25 percent cover growing (Scott 

and Burgan 2005; Cella et al. 2008). 

6,530,732.1 

GR 3 Grass-coarse Low Load, Very Coarse, Humid Climate Grass - Grass and herb fuel load is 

relatively light; fuelbed depth is about 2 feet. 

604,952.6 

GR 4 Grass-moderate 

load 

Moderate Load, Dry Climate Grass - Continuous, dry-climate grass load and 

depth are greater than GR2; fuelbed depth is about 2 feet. 

190,694.4 

GS 1 Grass Shrub -low 

load 

Low Load, Dry Climate Grass-Shrub - Primary 1 carrier of fire in GS1 is grass 

and shrubs combined. Shrubs are about 1 foot high, grass load is low. Spread 

rate is moderate; flame length low. 

1,855,389.4 

SH 1 Shrub – low load Low Load, Dry Climate Shrub - Primary carrier of fire is woody shrubs and shrub 

litter. Low shrub fuel load, fuelbed depth about 1 foot; some grass may be 

present. Spread rate is very low; flame length very low. 

179,460.1 

SH 2 Shrub – moderate 

load 

Moderate Load, Dry Climate Shrub - The primary carrier is woody shrubs and 

shrub litter, moderate fuel load (higher than SH1), no grass fuel present, spread 

rate is low; flame length low. Comprised of birch, willow or ericaceous shrubs. 

3,717,768 

SH 3 Shrub – moderate 

load 

Moderate Load, Humid Climate Shrub - Primary carrier of fire in SH3 is woody 

shrubs and shrub litter. Moderate shrub load, possibly with pine overstory or 

herbaceous fuel, fuel bed depth 2 to 3 feet. Spread rate is low; flame length low. 

713,291 

TL 1 Timber Litter – low 

load 

Low Load Compact Conifer Litter - Primary carrier of fire is compact forest litter. 

Light to moderate load, fuels 1 to 2 inches deep, spread rate is very low; flame 

length very low. 

11,719.5 

TL 2 Timber Litter-low 

load 

Low Load Broadleaf Litter - Primary carrier of fire is broadleaf (hardwood) litter 

spread rate is very low; flame length very low. 

3,019,850.9 

TL 3 Timber Littermoderate load Moderate Load Conifer Litter - Carrier of fire is moderate load conifer litter, light 

load of coarse fuels. Spread rate is very low; flame length low. 

258,096.8 

TL 6 Timber Littermoderate load Moderate Load Broadleaf Litter - Carrier of fire is moderate load broadleaf litter, 

less compact than TL2, spread rate is moderate; flame length low. 

2,320,178.7 

TU 1 TimberUnderstory-low 

load 

Low Load, Dry Climate Timber-Grass-Shrub – Primary carrier of fire is low load 

of grass and/or shrub with litter. Spread rate is low; flame length low. Includes 

closed white spruce forest types and some scattered paper birch or balsam 

poplar 

5,890,772.8 

TU 3 TimberUnderstorymoderate load 

Moderate Load, Humid Climate Timber-Grass-Shrub - Primary carrier of fire is 

moderate forest litter with grass and shrub components. Extinction moisture is 

high. Spread rate is high; flame length moderate. Includes overstory dominated 

by black spruce with low productivity, white spruce and paper birch. 

74,491.7 

TU 4 TimberUnderstory Dwarf 

Conifer 

Dwarf Conifer with Understory - Primary carrier of fire is short conifer trees with 

grass or moss understory. Spread rate is moderate; flame length moderate. 

Dominated by either black spruce or black/white spruce paper birch, tamarack, and 

quaking aspen 

7,289,361.8 

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Fuel 

Model 

Code 

Fuel Model 

Name Fuel Model and Fire Behavior Description 

Fuel Model 

Acres within 

Planning 

Area 

TU 5 TimberUnderstory- High 

load 

Dwarf Conifer with Understory - Primary carrier of fire is heavy forest litter with a 

shrub or small tree understory. Spread rate is moderate; flame length moderate. 

Includes white spruce, ranging in cover from 25–60%, black spruce, paper birch, 

and aspen and a resin birch shrub layer. 

5,017,930.9 

Source: Scott and Burgan 2005 

Includes all BLM-managed and non-BLM-managed lands within the planning area. 

Fuels Management 

BLM uses an integrated vegetation management approach to achieve hazardous fuels management 

objectives. Management actions include vegetation manipulation to remove hazardous fuels to reduce the 

severity, intensity and spread of wildfire. Common treatment methods include prescribed fire, mechanical 

manipulation (e.g., mowing), applying herbicides, seeding, and biological treatments to reduce fuels or 

create fuel breaks. Treatments are strategically placed to support suppression operations, protect human 

communities and protect important resource values. Vegetation manipulation treatments serve also to 

improve vegetative health by enhancing species diversity and sustainability. Following treatments, areas 

may be seeded where residual vegetation is not adequate to naturally revegetate or to prevent soil erosion. 

Minimal restriction on hazardous fuels treatments are currently in place, however, there have been few 

BLM hazardous fuel treatment projects implemented within the planning area. 

Prescribed fire is used to alter, maintain, or restore vegetative communities to achieve desired resource 

conditions and protect life, property, and values that would be degraded or destroyed by wildfire. The 

BLM utilizes the Interagency Prescribed Fire Planning and Implementation Procedures Guide (PMS484) 

(2014) for guidance, procedures, and planning prescribed fires. This handbook identifies; goals and 

responsibilities, risk management, which includes requirements for preparation of prescribed fire burn 

plans, ignitions plans, contingency planning and smoke monitoring (NWCG 2014). Minimal restriction 

on prescribed fires are currently in place, however, there have been no known prescribed fires in the 

planning area other than pile burning. 

Emergency Stabilization and Rehabilitation 

The BLM utilizes the Burned Area Emergency Stabilization and Rehabilitation Handbook #1742 (2007), 

which provides policies, standards, and procedures used for stabilization and rehabilitation of burned 

areas following wildfire. Emergency stabilization and rehabilitation (ES&R) management includes 

planned actions to minimize the threats to life and property resulting from wildfire and to stabilize and 

prevent unacceptable degradation of natural and cultural resources from the effects of wildfire (BLM 

2007b). Treatments to stabilize and/or rehabilitate burned areas may include installation of erosion control 

structures, removal of hazardous trees, replacement of burned or damaged values, soil stabilizations 

treatments such as seeding, planting, mulching, stabilization, invasive plant and weed control, and use 

closures. ES&R funds can only be spent on ANCSA corporation lands when there is a "direct benefit" to 

federal lands as authorized by the Wyden Amendment, such as preventative measures on Native 

corporation lands designed to prevent degradation of nearby federal lands (AWFCG 2016). ES&R project 

priorities within the planning area include; providing public health and safety, erosion control treatments, 

tree felling, slash spreading, travel corridor treatments, repair of facilities and infrastructure and post fire 

monitoring. 

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Smoke Management 

Smoke is managed by the BLM in consultation with the ADEC, the authority responsible for managing 

air quality within the state. Smoke from wildfire is not regulated but is considered in control tactics. 

Smoke from prescribed fire is addressed in burn plans, which are developed in consultation with the 

ADEC and the Alaska Enhanced Smoke Management Plan (ESMP), written and adopted by the Alaska 

Wildland Fire Coordinating Group. The ESMP outlines the process and identifies issues that need to be 

addressed to ensure that prescribed fire minimizes smoke and air quality problems. Prescribed burns are 

planned to be implemented under favorable atmospheric conditions for smoke dispersion. Historically, 

there have been no known prescribed burns within the planning area. The AWFCG maintains an Air 

Quality and Smoke Management Committee. 

Fire Prevention 

Fire prevention includes agencies, partners, affected groups, and individuals working together to prevent 

unauthorized ignition of wildfires. The primary goal of fire prevention and education is to reduce human 

caused fires through education. Most fires within the planning area are lightning caused with few humancaused fires; see Table 2.9.4-1. Fire prevention and education efforts are challenged by the remoteness of 

communities in the planning area. Prevention education is provided in conjunction with local fire crew 

training, Community Wildland Fire Protection Planning, FireWise planning, and organized workshops 

and conferences in larger communities. The AWFCG maintains a Fire Prevention Committee. 

2.9.5 Resource Changes: Trends and Forecasts 

Ecological condition of most vegetation within the planning area show little departure from historical 

conditions as the planning area is remote, access is limited, and there have been relatively few resource 

uses or activities that have changed vegetation conditions. Areas where ecological conditions show a 

vegetation departure from historic conditions include areas disturbed from wildfire, road construction, 

logging along river corridors, and areas where nonnative plant species have established (BLM 2015b). 

Native spruce bark beetle (Dendroctonus rufipennis) infestations were documented in the late 1990s and 

early 2000s, and impacted forest cover primarily in the Kenai Peninsula (ADNR 2018; USDA 2018). 

Current and prior outbreaks have been attributed to warming winters that allow the species to overwinter 

increasing population size. Infestations can change fuel types and contribute to increased large woody 

debris accumulation. However, there is little evidence that dead or diseased trees have greatly increased 

the intensity, size, or duration of wildland fires in the planning area. 

The highest level of anthropomorphic vegetation changes in the planning area can be seen in areas along 

river corridors and near mines logged for fuel wood. Most BLM-managed land, however, is not near 

navigable rivers. It is anticipated that future conditions of vegetation would continue to be impacted by 

these factors on a limited, site specific basis. There have historically been few BLM hazardous fuel 

treatment projects implemented within the planning area and no prescribed fires. It is anticipated that 

future treatments would continue to be limited but may be implemented for the protection of site specific 

resources. 

The location, number, and size of wildfire may be impacted by changing climate conditions. As noted in 

Section 2.2, Climate Change, Alaska has experienced the largest regional warming of any state in the 

U.S., with a rise in statewide average annual temperature of 3 degrees F and a rise in average winter 

temperature of 6 degrees F over the last 60 years. Average annual temperatures in Alaska are projected to 

rise by an additional 2 to 4 degrees F by 2050 (NCA 2014). 

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These warming conditions have contributed to the increase in the number and size of wildfires. Increased 

summer temperatures dry fuels increasing the potential for wildfires ignition and spread. Decadal acres 

burned within the planning area have increased from a low of 541,421 in the 1980s to a high of 2,709,820 

in the 1990s. Decadal acres burned have continued to exceed 2 million in Alaska for each of the ten-year 

periods from 1990 through 2010 (see Table 2.9.4-1). Drought conditions have reduced fuel moisture in 

vegetation and organic soil layers increasing the potential for larger more intense wildfires. Larger 

wildfires may cause potential shifts of forest types that currently dominate the Alaskan boreal forest 

resulting in a decline in abundance of black spruce and increasing the potential of deciduous forests in 

former black spruce habitat (Euskirchen et al. 2010). Ecosystems in the planning area are stressed by 

climate change. 

2.10 Cultural Resources 

2.10.1 Introduction 

It is important to note that under NEPA, impacts to all types of cultural resources are considered even if 

they are not National Register of Historic Places (NRHP)-eligible, i.e., designated as “historic properties”

per the National Historic Preservation Act (NHPA). A wide range of cultural resource types can include, 

but are not limited to: 

• “Cultural resources” can refer to specific locations and/or tangible remains and material evidence 

resulting from, or associated with, past human activity. Cultural resources also include traditional 

cultural properties, defined by associations with the practices, traditions, beliefs, lifeways, arts, 

crafts, or social institutions of a living community. Cultural resources encompass a diverse array 

of property types including sites, buildings, structures, objects, and districts. 

• Historic properties defined as “any prehistoric or historic district, site, building, structure, or 

object included in, or eligible for inclusion in, the NRHP maintained by the Secretary of the 

Interior. This term includes artifacts, records, and remains that are related to and located within 

such properties. The term includes properties of traditional religious and cultural importance to an 

Indian tribe or Native Hawaiian organization and that meet the National Register criteria” (36

CFR 800.16), and as used in Section 106 of the NHPA. 

• Native American (in this case, Alaska Native) cultural items such as human remains, funerary 

items, sacred objects, and objects of cultural patrimony. 

• Archaeological resources, which include pre-contact (i.e., dating to the period in North America 

predating the arrival of Euroamericans) and historic archaeological sites that may or may not be 

historic properties. 

Certain places of traditional, cultural, or religious importance to a living community or cultural group 

may qualify for consideration as Traditional Cultural Properties (TCPs). TCPs can include: 

• Cultural resources entail the traditions, beliefs, practices, lifeways, arts, crafts, and social 

institutions of any community, such as local indigenous groups, ethnic groups, or the people of 

the state or nation as a whole. As such, cultural resources can consist of locations associated with 

the traditional beliefs of native groups, locations where native religious practitioners have 

historically gone, or go to today, or a location where a community has traditionally carried out the 

economic, artistic, and other cultural practices important in maintaining its identity (Parker and 

King 1998). 

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The term “cultural resources” also includes: 

• Cultural landscapes, which are classified either as historic sites, historic designed landscapes, 

historic vernacular landscapes, or ethnographic landscapes (ACHP 2012a, 2012b; Page et al. 

1998). 

2.10.2 Laws, Regulations, and Policies 

Federal historic preservation laws provide a mandate and procedures for the identification, 

documentation, evaluation, and protection of cultural resources that may be affected by federal 

undertakings or actions. The NHPA (54 U.S.C. 300101 et seq. as amended), as outlined in its 

implementing regulations 36 CFR 800 (“Protection of Historic Properties”), is the primary piece of 

federal legislation protecting cultural resources in cases where federal undertakings would have an effect. 

Section 106 of the NHPA requires federal agencies to consider the effects of their “undertakings” on 

historic properties and afford the Advisory Council on Historic Preservation (ACHP) a reasonable 

opportunity to comment. “Undertakings” is a NHPA term defined by 36 CFR 800.16 (y) as “a project , 

activities, or program funded in whole or in part under the jurisdiction of a Federal agency, including 

those carried out by or on behalf of a Federal agency; those carried out with Federal financial assistance; 

and those requiring a Federal permit, license or approval.”

NEPA requires federal agencies involved in actions to consider the potential effects to the “human 

environment”—an all-encompassing term that has been interpreted to include historical and 

archaeological resources. Under NEPA, the term “cultural resources” covers a wider range of resources

than the “historic properties” considered under Section 106 of the NHPA, and includes sacred sites, 

archaeological sites not eligible for the NRHP, and archaeological collections (CEQ and ACHP 2013). 

The National Trails System Act (NTSA) (16 U.S.C. Section 1241) addresses management of national 

recreation, scenic, and historic trails including the Iditarod National Historic Trail (INHT) and connecting 

or side trails providing access to the INHT. The NTSA directs the Secretary of the Interior or the 

Secretary of Agriculture to administer and manage designated National Trails. Section 7(c) of the NTSA 

requires the assessment of potential effects of proposed actions on designated National Trails. While 

BLM is the federal administrator for the INHT, the INHT traverses federal, State, and private land. 

Numerous other laws, regulations, and EOs protect cultural resources. The Antiquities Act of 1906 (16 

U.S.C. 431 et seq.) was the first legislation protecting archaeological sites on public lands and establishes 

penalties for damage and destruction of archaeological sites on federal lands. The Archaeological 

Resources Protection Act of 1979 (ARPA; 16 U.S.C. 470) establishes a permit process on public and 

Native American lands and provides penalties for violations and damages to archaeological sites. The 

American Indian Religious Freedom Act (AIRFA) of 1978 (42 U.S.C. 1996) requires that federal 

agencies consider the effects of their actions on cultural resources that are of religious significance to 

Native Americans and Alaska Natives. EO 130007 (“Indian Sacred Sites”) directs federal agencies to

allow Native Americans to worship at sacred sites located on federal property and to avoid adversely 

affecting such sites to the extent practicable. EO 13287 “Preserve America” directs federal agencies to

build partnerships with local governments, Indian tribes, and the private sector to preserve cultural 

resources, and improve the stewardship of cultural resources. 

The Native American Graves Protection and Repatriation Act (NAGPRA; 25 U.S.C. 3001-3013) 

addresses the rights of lineal descendants, Indian tribes, and Native organizations to Native American 

cultural items, including human remains, funerary objects, sacred objects, and objects of cultural 

patrimony. Alaska’s State laws are also applicable to the discovery of human remains. The State Medical 

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Examiner has jurisdiction over all human remains in the state, regardless of age. Specifically, AS 

11.46.482(a)(3), which applies to all lands in Alaska, makes the “intentional and unauthorized destruction

or removal of any human remains or the intentional disturbance of a grave” a class C felony; AS 

41.35.200, which applies only to State lands, makes the disturbance of "historic, prehistoric and 

archaeological resources" (including graves, per definition) a class A misdemeanor. AS 18.50.250, which 

applies to all lands in Alaska, requires permits for the transport, disinterment, and reinterment of human 

remains. Regulations found in AS 12.65.5 require the immediate notification of a peace officer of the 

state (police, Village Public Safety Officer, or Alaska State Trooper) and the State Medical Examiner 

when death has been caused by unknown means, such as human remains found in archaeological 

contexts. 

Other federal cultural resource protections include: the Historic Sites Act of 1935 (16 U.S.C. 461467); EO 

11593, Protection and Enhancement of the Cultural Environment, May 13, 1971 (36 CFR 8921); the 

Archaeological and Historic Preservation Act of 1974, which amends the Reservoir Salvage Act of 1960 

(P.L. 86523; P.L. 93291; 16 U.S.C. 469 et seq.); Curation of Federally Owned and Administered 

Archaeological Collections (36 CFR 79); 43 CFR, subpart 62, 3622, 3621, 3610, 3802, 3809, 8200, 

1610.72, 8364, and 8365.15; and 43 CFR 3809.420(b)(8). 

State of Alaska laws and regulations require State agencies to consider the effects of their actions on 

cultural resources. The Alaska Historic Preservation Act (AS 41.35.070) codifies the State policy to 

preserve and protect the historic, prehistoric, and archaeological resources of Alaska and asserts the 

State’s title to all historic, prehistoric, and archaeological resources situated on land owned or controlled 

by the State, including tideland and submerged land. If a project requires any involvement from the State 

of Alaska, a review under the Alaska Historic Preservation Act is needed. This includes public 

construction, public improvement, or any other project undertaken by the state, or governmental agency 

for the state by a private person under contract with or licensed by the state, or agency for the state. 

NEPA Definition of Cultural Resources 

Under NEPA, a wider range of cultural resource types are assessed and can include, but are not limited to: 

• Historic properties, defined as “any prehistoric or historic district, site, building, structure, or

object included in, or eligible for inclusion in, the NRHP maintained by the Secretary of the 

Interior,” in 33 CFR 325, Appendix C.1 (a) and (b), and as used in Section 106 of the NHPA. 

• Native American cultural items such as human remains, funerary items, sacred objects, and 

objects of cultural patrimony. 

• Archaeological resources, which include prehistoric and historic archaeological sites that may or 

may not be historic properties. 

• Cultural uses of the natural environment, such as traditional cultural use of places, plants, 

animals, and minerals. 

• Locations of traditional cultural, ceremonial, spiritual, or religious importance, or sacred sites. 

Historic Properties 

Section 106 of the NHPA requires federal agencies to consider an undertaking’s effects on “historic 

properties,” which are defined as cultural resources listed or determined eligible for listing on the NRHP 

(16 U.S.C. 470, Sec. 301.5). The NRHP is the nation’s inventory of significant cultural resources; it 

contains a wide range of historic property types such as buildings, structures, sites; groups of structures, 

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buildings and sites forming historic or archaeological districts or cultural landscapes; and individual 

objects. Such properties reflect many kinds of significance in architecture, history, archaeology, and 

culture. In addition to location and site boundaries, the NRHP contains detailed information regarding the 

property’s nature, characteristics, associated elements, integrity, and statements of significance. 

The NRHP describes historic resources as standing or collapsed buildings, unique engineering designs, 

mines, ranches, and railroad grades that are at least 50 years old, or have achieved significance within the 

past 50 years. Archaeological resources are prehistoric or historic remains of human lifeways or activities 

that are at least 50 years old, and include artifact concentrations or scatters, whole or fragmentary tools, 

rock carvings or paintings, and buildings or structures. Resources that incorporate geographic areas, 

including both cultural and natural features, and that are associated with historic events or other cultural 

values include Traditional Cultural Properties, cultural landscapes, ethnographic landscapes, rural historic 

landscapes, and historic mining landscapes (ACHP 2012a, 2012b). 

For purposes of Section 106 compliance, resources determined NRHP-eligible through consultation as 

well as those already listed on the NRHP warrant impact assessment. To qualify as a historic property, a 

property must generally be at least 50 years old, retain its physical integrity—that is “integrity of location, 

design, setting, materials, workmanship, feeling and association” (36 CFR 60; NPS 1997), and it must 

meet the NRHP Criteria for Evaluation (36 CFR 800.4; NPS 1997): 

• The quality of significance in American history, architecture, archeology, engineering, and 

culture is present in districts, sites, buildings, structures, and objects that possess integrity of 

location, design, setting, materials, workmanship, feeling, and association and meet at least one of 

the following criteria: 

o Criterion A - that are associated with events that have made a significant contribution to the 

broad patterns of our history; 

o Criterion B - that are associated with the lives of persons significant in our past; or 

o Criterion C - that embody the distinctive characteristics of a type, period, or method of 

construction, or that represent the work of a master, or that possess high artistic values, or that 

represent a significant and distinguishable entity whose components may lack individual 

distinction; or 

o Criterion D - that have yielded, or may be likely to yield, information important in prehistory 

or history. 

If significant (i.e., NRHP-eligible) resources are identified, then federal agencies are directed to take 

prudent and feasible measures to avoid or reduce adverse impacts. 

Prehistoric archaeological sites are most often found eligible under Criterion (d), while archaeological 

sites containing historical deposits as well as some prehistoric sites are also often considered under 

criteria (a) through (c) when applicable. Likewise, historic buildings and structures (as opposed to 

archaeological sites) are assessed under a variety of NRHP criteria. While nearly all sites have the 

potential to yield information useful in addressing a limited number of research questions, this limited 

potential is not considered sufficient to qualify a site for inclusion on the NRHP under Criterion (d). By 

establishing guidelines, agencies have clearly set the precedent that not all information is important, and 

thus, not all sites are important. Federal guidelines encourage the use of a set of research questions that 

are generally recognized as important research goals as a means of evaluating significance. If a site 

contains information that is demonstrably useful in answering such questions, it can be considered an 

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important site. NRHP evaluation guidelines state that a site must retain integrity to be considered eligible 

under one or more of the criteria. 

Traditional Sites 

Cultural resources also include TCPs that are important to a community’s practices and beliefs and that 

maintain a community’s cultural identity. In order to be eligible for listing on the NRHP, a traditional 

property must be associated with the cultural practices or beliefs of a living that are: (1) rooted in that 

community’s history, and (2) are important in maintaining the continuing cultural identity of the 

community. As with the case of historic properties described above, to qualify for listing on the NRHP 

TCPs must retain integrity—that is, integrity in terms of both physical characteristics, and also integrity 

of the relationship between the property and the cultural beliefs or practices that may give it significance. 

Thus, two crucial questions arise in assessing NRHP eligibility and Section 106 considerations in relation 

to TCPs: 1) does the property retain an integral relationship to traditional cultural practices or beliefs, and 

2) is the condition of the property such that the relevant relationships survive? (Parker and King 1998). 

As established under AIRFA, federal agencies are required to consider the effects of their actions on sites, 

locations, areas, and other resources (e.g., plants) that are of religious significance to Native Americans 

and Alaska Natives. AIRFA also mandates that federal agencies protect and preserve access to sacred 

sites. Verifiable Native American and Alaska Native graves, burial grounds, and associated funerary 

objects are protected by NAGPRA. 

Cultural Landscapes 

Section 106 reviews can reveal a large-scale historic property of cultural and religious significance to 

Indian Tribes or Alaska Native organizations. These large-scale properties are often comprised of 

multiple, linked features that form a cohesive “landscape” (ACHP 2011). The NPS (Birnbaum 1994)

defines a cultural landscape as “a geographic area, including both cultural and natural resources and the 

wildlife or domestic animals therein, associated with a historic event, activity, or person exhibiting other 

cultural or aesthetic values.” The same document describes four general types of cultural landscapes, 

which are not mutually exclusive (Birnbaum 1994): 

• Historic Designed Landscape comprised of built environment features a landscape that was 

consciously laid out by a landscape architect, master gardener, architect, or horticulturist 

according to design principles, or an amateur gardener working in a recognized style. The 

landscape may be associated with a significant person(s), trend, or event in landscape 

architecture. Aesthetic values play a significant role in designed landscapes. Examples include 

parks, campuses, and estates. 

• Historic Vernacular Landscape that has evolved through use by the people whose activities or 

occupancy shaped that landscape. Through social or cultural attitudes of an individual, family or a 

community, the landscape reflects the physical, biological, and cultural character of those 

everyday lives. Function plays a significant role in vernacular landscapes. They can be a single 

property such as a farm or a collection of properties such as a district of historic farms along a 

river valley. Examples include rural villages, industrial complexes, and agricultural landscapes. 

• Historic Sites Landscape, which is a landscape significant for its association with a historic 

event, activity, or person. Examples include battlefields and president’s house properties.

• Ethnographic Landscape, which contains a variety of natural and cultural resources that 

associated people define as heritage resources. Examples are contemporary settlements, religious 

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sacred sites and massive geological structures. Geographic features, plant communities, animals, 

subsistence and ceremonial grounds are often components. 

In order to be NRHP-eligible and afforded Section 106 protections, a cultural landscape must possess 

significance in at least one of the four aspects of cultural heritage defined by the NRHP criteria (Page et 

al. 1998). The NPS (2009) states that in order for a landscape to be considered significant, character 

defining features that convey its significance in history must not only be present, but they must also 

possess physical, historical and cultural integrity. Location, setting, design, materials, workmanship, 

feeling and association should be considered in determining whether a landscape and its characterdefining features possess integrity. Further, to evaluate significance, the contributing elements and 

features that give the landscape its historic and cultural character should be documented and reported. 

2.10.3 Resource Indicators 

Cultural resource indicators are based on the presence and density of previously identified archaeological, 

historic, or traditional properties, the probability for the presence of unidentified properties of these types, 

and the likelihood of impacts to these resources. Identified indicators include the following: 

• Acres with no or limited land use restrictions that server to limit surface disturbance and protect 

cultural resources 

• Acres open to actions that cause surface disturbance 

• Acres of BLM-managed lands identified for acquisition, retention, or disposal 

• Acres affected by land withdrawals 

• Land use restrictions that server to limit surface disturbance and protect cultural resources or 

result in further resource identification 

• VRM classes near known sites, particularly the INHT National Trails Management Corridor 

(NTMC) 

• Acres with no or limited (less restrictive) land use designations regarding development uses 

2.10.4 Current Conditions 

Regional Prehistory 

Given the vast size and remote nature of this area, its prehistory remains poorly understood and most 

current knowledge comes from coastal or near coastal sites. Archaeological investigations within interior 

Western Alaska began in the 1920s and 1930s and have been conducted sporadically since that time, with 

more recent investigations largely linked to specific projects and along major river corridors. Regional 

chronological sequences have been developed and refined by Ackerman (1979, 1996), and Dumond 

(1984), and others, and have been summarized by Potter and Cook (2006). From oldest to most recent, 

these traditions have been termed Paleoindian, American Paleoarctic, Northern Archaic, Arctic Small 

Tool Tradition, Western Thule/late prehistoric Inupiaq, and Athabaskan. 

Paleoindian and Paleoarctic Tradition (~10,000-7,000 years ago) 

The earliest residents of Southwestern Alaska are believed to have migrated from Siberia along a land 

bridge, though evidence of Paleoindian sites is scarce. The Paleoindian Tradition, dated 10,000 to 8,000 

years ago, is the earliest occupation recognized in the region. Though there is some evidence suggesting 

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human occupation of Southwest Alaska prior to 10,000 years ago, including cut marks on a 15,000-yearold caribou humerus, the earliest sites with unequivocal artifacts date to approximately 10,000 years ago. 

The nature of archaeological assemblages associated with these sites implies temporal and cultural 

connections with early sites in more temperate latitudes such as the Great Plains and the American 

Southwest; fluted points are believed to have been a plains culture element that diffused northward. This 

complex is typified by the assemblage at Spein Mountain, radiocarbon dated to 10,050±90 BP, which 

Ackerman has tied to components at the Mesa and Bedwell sites on the North Slope. Information from the 

Mesa site, along with others such as the fluted point Putu and Lisburne sites, implies temporal and 

cultural connections with early sites in more temperate latitudes such as the Great Plains and the 

American Southwest. Remarkable similarities exist in artifact forms, particularly projectile points, 

scrapers and spurred gravers, site settings, and implied subsistence patterns. Ackerman denotes a “nonmicroblade complex” in southwest Alaska, consisting of lanceolate and leaf shaped projectile points, 

bifacial knives, gravers, notches, various scrapers, and flake knives. Ackerman notes that the occurrence 

of microblades at Swan Point (Holmes et al. 1996) dating to over 11,000 BP, indicates that this nonmicroblade complex and Denali Complex are likely contemporary cultural complexes that derive from 

rather different cultural traditions (Potter and Cook 2006). 

With the exception of these few isolated finds, evidence for Paleoindian occupation in the planning area is 

rare. More commonly encountered is evidence of microblade technology, characteristic of the American 

Paleoarctic Tradition and generally thought to date to between about 10,000 and 7,000 years ago (Gaines 

et al. 2006). Side-notched spear points, large knives, chopping tools, scrapers, net sinkers, and burins are 

associated with the microblade tradition, which emerged coterminous with the late Paleoindian culture 

and suggests the arrival of new populations traveling across the land bridge and arriving in Western 

Alaska. Distinctive artifacts found in American Paleoarctic sites are remarkably similar to stone 

technologies from Northeast Eurasia, suggesting cultural connections across the Bering Land Bridge. 

American Paleoarctic tool kits are generally thought to have been oriented toward the production of 

composite antler and stone projectiles, used to hunt late Pleistocene-early Holocene fauna. This cultural 

tradition of production of parallel-sided prismatic stone blades and microblades underwent several 

regional variations and spanned the period from about 10,000 to 2,000 years ago. Lime Hills Cave is an 

example of a site containing evidence of this archaeological culture (Ackerman 1996). 

Northern Archaic (~6,000-2,000 years ago) 

Sometime after 6,000 years ago, side-notched projectile points–the hallmark of the Northern Archaic 

tradition dated to 6,000 to 2,000 years–begin to appear in interior, northern, and western Alaska 

archaeological assemblages (Potter and Cook 2006). The broad occurrence of this point type throughout 

interior and northern Alaska and the Yukon Territory, along with distinctive scraping implements and 

other lithic tools, is thought to perhaps represent the spread of a new boreal forest-oriented cultural 

tradition, though this interpretation is in part contradicted by similar sites in tundra environments. 

Sites in southwest Alaska attributed to Northern Archaic Tradition have been found along the coast 

(Security Cove) and the interior (GDN-094 at Kagati Lake). Another site, GDN 069, near Goodnews 

Lake, contained notched points and core platforms. This tradition is as yet undated in the planning area, 

but based on similar assemblages in the Alaska Peninsula and Interior Alaska, it probably dates to 

between 5000 and 3500 BP. The Northern Archaic is also represented on the coast of the North Slope at 

sites such as Kuparuk Pingo and the Putuligayuk River Delta Overlook Site. Little is known of the coastal 

Northern Archaic subsistence economy, although it is presumed that caribou hunting was important 

(Potter and Cook 2006). 

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Arctic Small Tool Tradition (4,500 to 1,100 years ago) 

Following the Northern Archaic Tradition, beginning roughly 4,500 years ago is a prehistoric culture 

known as the Arctic Small Tool tradition, known for tiny, finely flaked stone tools (Potter and Cook 

2006). The original definition of this culture has been expanded, and now includes later cultures such as 

Norton and Ipiutak (Gerlach and Hall 1988). The dramatic change in stone tool technology from the 

earlier Northern Archaic to the later Arctic Small Tool tradition assemblages may mark the introduction 

of the bow and arrow and is interpreted by many archaeologists as a direct ancestral lineage to modern 

Inuit and Inupiaq people in Alaska and the arctic regions of Canada and Greenland. Shaw theorizes that 

the first inland inhabitants of the Yukon-Kuskokwim Delta arrived about 2000−1500 Before Present, but 

few sites have been found to prove this theory. Sites with Norton Phase artifacts have been found in 

southwest Alaska in Unalakleet and Lake Minchumina, among other sites (Dumond 1984; Potter and 

Cook 2006). 

Western Thule and Late Prehistoric (900-1790 AD) 

Following the gradual decline of the microblade tradition is the transition into prehistoric Athabaskan 

culture. This shift is associated with the appearance and abundance of side-notched points, along with the 

absence of microblade technology. 

As discussed in the BSWI AMS (BLM 2015a), archaeological, linguistic and ethnographic evidence 

indicates that the Western Thule people are the direct ancestors of the Yup’ik and Iñupiat people who 

currently inhabit the planning area. Artifacts associated with the Western Thule include ground slate 

tools, flaked stone tools, pottery, and birch bark baskets (Dumond 1984). Sites in and around the planning 

area with Western Thule components include Nunivak Island, Hooper Bay, Togiak, and Platinum. Late 

prehistoric sites include Kolmakovsky Redoubt and Crow Village. Late Prehistoric sites associated with 

Athabaskan cultures rather than Yup’ik generally consist of subterranean housepit features, flaked stone 

tools, ground stone artifacts, and a small number of European goods in the case of protohistoric sites. 

Sites attributed to the Late Prehistoric Athabaskan culture near the planning area include Anvik Point, 

Lake Minchumina, and Telida Lake (BLM 2015a). 

Regional Ethnography 

The planning area is inhabited by three Alaska Native cultural groups, divided into several linguistic 

dialects (BLM 2015b; Krauss et al. 2011). These are the Yup’ik, Iñupiat, and Athabaskan languages 

(BLM 2015b). 

Yup’ik

As discussed in the BSWI AMS (BLM 2015a), the western portion of the planning area is inhabited by 

the Central Yup’ik. The Yup’ik speaking Kuskowagamiut, are believed to have moved from the coastal 

areas up the Kuskokwim drainage into Interior Alaska about 500 years ago. Others have hypothesized that 

they moved into the Interior slightly later, following the development of fish nets. The Central Yup’ik

culture includes several regional subgroups (BLM 2015a; Spartz and Mishler 1985). A Russian Army 

lieutenant, Zagoskin, who visited the area in the 1840s, noted that this group subsisted primarily on 

salmon and lived in relatively permanent settlements. Zagoskin’s account is the first detailed ethnographic 

account of this group. Settlements were located mainly along rivers and could contain as many as 300 

people. Houses were made from wooden posts and planks and were dug slightly into the ground. Light 

and heat came from central hearths and from seal oil lamps. Mattresses and blankets were made from 

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animal skins and were located on wall benches. Cooking was done with both ceramic and wooden dishes, 

and food was cooked with boiling stones. Structures included houses for women and their older daughters 

and young children of both sexes, and the men’s house, which housed men and older boys and functioned

as a bathhouse and ceremonial space. Families lived together when traveling to fish camps away from the 

main village. Both skin boats and birch bark canoes were used for travel and hauling cargo. Elder 

members of the community were valued for their knowledge, and the dead were buried in a flexed 

position in raised plank coffins (BLM 2015a; Spartz and Mishler 1985). 

The seasonal round included leaving winter camps for tundra camps by dogsled, where men hunted birds 

and fished, while women gathered berries. After breakup, people traveled by boat to prepare for summer 

fishing. At this time, they lived in river villages or in temporary fish camps and fished using nets, weirs, 

or fish traps. Women dried the fish to prepare it for winter. In the fall, they moved to tundra camps to hunt 

and trap animals including birds, small game, fur-bearing animals, and caribou. Midwinter was the 

ceremonial season. People moved back to winter villages and went ice fishing when possible (BLM 

2015a; Spartz and Mishler 1985). 

Iñupiat 

The Iñupiat are found in the north of the planning area, mostly in Unalakleet and nearby coastal areas. 

Historically, Iñupiats had an egalitarian social structure, with no specified leader. Prior to European and 

later American arrival, the Iñupiat of the region participated in an economy that relied on subsistence 

resources and utilized trade to acquire goods not readily available in their immediate area. They traded 

widely with interior groups. Cooperation was a hallmark of their culture, as families worked together in 

subsistence hunting and fishing. Iñupiats were also very dependent upon sharing across the community. 

Aggregated household units considered themselves related and lived in nearby houses. Iñupiat group 

territories were maintained based on marriage or trading alliances and were also influenced by military 

conflict (Ray 1986). Groups were defined by kinship as well as membership in hunting parties and further 

extensions of partnerships and friendships Historically, men were responsible for the hunting and fishing 

portions of subsistence, while women were in charge of preparing food and managing the household 

(BLM 2015a; Schwede 2005). 

Iñupiat settlement patterns were characterized by permanent villages along the coast with outlying minor 

settlements of both permanent and temporary nature. Each village was a focus for social activity as well 

as identity (Ray 1986). One reason for the Iñupiat villages’ permanence was due to the marine mammal 

resource base from which community members subsisted. Marine mammals, particularly the bowhead 

whale, provided large quantities of food and had a fairly predictable migratory pattern. Coastal locations 

also provided access to a variety of other subsistence resources including anadromous fish, sea ducks, 

invertebrates, and caribou drawn to the area for insect relief. 

Ray (1986) provides an overview of the annual cycle of subsistence activities among the Bering Straits 

Iñupiat. Spring was a renewal period and marked the beginning of the seasonal round. This was one of the 

most important harvesting seasons as this was the time when whales were hunted, and various groups 

came together to cooperate in the spring caribou hunt. In summer, the Iñupiat along the coast would 

harvest walrus and other marine mammals as well as undertake inland trips to harvest caribou or fish. 

Interior Iñupiat would begin preparations in the summer for traveling to the trading fairs with interior 

Athabaskan bands. As late summer turned to fall, the Iñupiat participated in their second annual caribou 

drive. The winter months were passed through various social activities, creating and repairing tools, and 

searching for seals through the ice, which was a mainstay of the winter diet. 

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Athabaskan 

The eastern regions of the planning area are Athabaskan territory. Major Athabaskan groups historically 

living within the planning area are the, Holikachuk, Koyukon, Ingalik, Kolchan, and Dena’ina, (BLM 

2015a). 

The Holikachuk lived along the Innoko River. They had a culture similar to the Ingalik, but they spoke a 

distinctive language. Because salmon do not spawn in the Innoko, they traveled to the Yukon to gather 

fish. They generally participated in the ceremonial rounds of the Ingalik that lived around Anvik and 

Shageluk (BLM 2015a; Simeone 1985). 

The Koyukon inhabit the northeastern portions of the planning area. Their subsistence relied heavily on 

fishing in the summer and on moose, caribou, and small game during the fall and winter. They traded 

salmon, furs, and wooden goods for coastal foods with the Yup’ik speaking peoples around Norton

Sound. The Koyukon exploited their position along the Unalakleet River, an important trade route, and 

became a kind of middleman for trade between the Norton Sound Yup’ik and the Athabaskans living on

the Yukon and Innoko Rivers. They traveled frequently by sled in winter between the coast and the 

Yukon, and historically relied heavily on this trade, reportedly having to do very little hunting and fishing 

themselves (BLM 2015a; Simeone 1985; Spartz and Mishler 1985). 

The Ingalik lived primarily in the Yukon River drainage, but also lived on parts of the Kuskokwim, 

Innoko, and Holitna Rivers. They relied heavily on fishing for subsistence, moving from their winter 

villages to small lakes to begin to look for fresh fish in spring. Throughout the summer and fall, they 

caught and dried fish, moving and changing tactics depending on the fish and the time of year. They also 

hunted or trapped small game and birds throughout the summer, while women gathered berries, plants, 

and eggs. In the fall, they moved back to their villages and semi-subterranean houses, and they ice-fished 

after the rivers froze. In the winter, men moved inland and hunted caribou and later went fur trapping, 

while women stayed in the villages and snared rabbits and ptarmigan. The southernmost populations of 

Ingalik, between the Kolmakov and Holitna Rivers, were strongly influenced by their Yup’ik-speaking 

neighbors, the Kuskowagamiut, adopting many of their cultural practices, clothing, and dances. The two 

groups also intermarried and were consequently speaking primarily Yup’ik in this area at the turn of the 

twentieth century (BLM 2015a; Simeone 1985; Spartz and Mishler 1985). 

The Kolchan lived along the upper Kuskokwim River, in an area including the modern communities of 

McGrath, Medfra, and Nikolai, and were divided into approximately six bands. They subsisted primarily 

on caribou rather than fish, using small lakes and streams for limited fishing, and using the Kuskokwim 

for trade and transportation. In the winter, the Kolchan lived in semi-subterranean houses along streams 

or rivers, and lived off of small game, caribou, and fish. In the spring, they moved upland to caribou 

hunting grounds, and worked cooperatively to drive caribou into brush corrals they had constructed. In 

the summer, the men continued to hunt caribou, as well as sheep and bears, while women gathered 

berries. Some fishing was conducted downstream in the fall, using nets and weirs. Transportation of 

people and goods was accomplished using birch bark canoes and toboggans, and by using pack dogs 

(BLM 2015a; Simeone 1985; Spartz and Mishler 1985). 

The Dena’ina inhabited areas of Southcentral and Southwestern Alaska, particularly along Cook Inlet, 

and shared traits with both Inupiaq and other Athabaskans. At the time of Euroamerican contact with 

Alaskan Natives in the 1700s, the Upper Cook Inlet region was occupied by the Dena’ina. The 

ethnographic, ethnohistoric, archaeological, and linguistic evidence for Dena’ina movement from interior 

Alaska shows that sometime around 1,000 to 1,500 years ago, ancestral Dena’ina moved into Cook Inlet 

from the Kuskokwim River drainage, displacing the earlier Inupiaq or Alutiiq occupation. The interior 

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groups along the Kuskokwim fished and hunted along the waterways but resources were less abundant 

than on the coast. Populations consolidated into Lime Village, Nondalton, and Pedro Bay by the 1970s. 

Considerable intermarriage occurred between the Stony River Dena’ina and Kuskokwim Deg Hit’an over 

at least the past 100 years. Although Inland Dena’ina Athabaskan is the dominant cultural heritage of

Lime Village, by the mid-1980s most residents were of mixed racial heritage. The Cook Inlet remains the 

Dena’ina heartland, but Dena’ina territory extends in the eastern portions of the planning area. 

Historically the Dena’ina were a ranked society with a redistributive economic system. High-ranking 

individuals or “rich men” took the role as leaders and functioned as a center for redistribution of goods. 

They were responsible for caring for their kin group and were responsible for widows, orphans, and the 

infirm. Sharing of meat was typical between hunting partners. A small potlatch would be given by a 

father when his son killed his first big game (Osgood 1976; Townsend 1981). 

Regional History 

As discussed in the AMS (BLM 2015a), Captain James Cook and his crews first mapped and documented 

the coast of the planning area during their search for the Northwest Passage in 1778. Their attempts to 

further chart the Yukon-Kuskokwim Delta were thwarted by the large amount of mud and silt; concerns 

over grounding the ships led to Cook’s decision to continue north rather than risk damage to the ships.

Russian exploration of the area and expansion of their bases in the Aleutian Islands, driven by the fur 

trade, began in the 1790s. Employees of the Lebedev-Lastochkin Company traveled from Lake Iliamna to 

the Nushagak River and from there to the Kuskokwim and then the Yukon Rivers. Another Russian 

expedition traveled from Lake Clark on the Alaska Peninsula to the Kuskokwim region in 1818, but it 

was not until 1830 that the Russians specifically explored the Kuskokwim River watershed. At that time, 

Ivan Vasilev led a party, hoping to expand the reach of their fur trading operation, from Nushagak Bay in 

the Bristol Bay area to the Kuskokwim, and then followed the river back to the ocean. An aborted mission 

attempted to ascend the Stony River in 1833; it is believed that this expedition introduced smallpox to the 

area, killing an estimated half of the population in the Kuskokwim Basin. As a result of these 

explorations, the first Russian station was established on the Kuskokwim River near present-day 

Sleetmute in 1832 and 1833. A second, Lukin’s Odinochka, was founded farther downstream in 1833,

and a third, Kolmakovsky Redoubt, was established even farther downstream in 1841. This third outpost 

was the only year-round Russian presence in inland western Alaska, but all three stations allowed the 

Russian-American Company to greatly expand their fur trading activities. A Russian Orthodox Church 

was established at Kolmakovsky Redoubt. Most historical information on the area is based upon the 

records of Zogoskin’s travels in the area in 1843 and 1844. Russian activity and settlement within the 

planning area was limited to a few settlements along the Bering Sea Coast, and later, as sea otter 

populations decreased, on a small number of trading posts (generally seasonal), along the Yukon and 

Kuskokwim Rivers (BLM 2015a; Spartz and Mishler 1985). 

Russians began withdrawing from Alaska in the mid-1860s before the sale of the territory to the United 

States. Russian-American Company property was sold to the Alaska Commercial Company after the sale 

of Alaska in 1867, and the Alaska Commercial Company was operating within the planning area by about 

1870. A second company, the Western Fur Trading Company, operated a trading post at the site of 

Lukin’s Odinochka from about 1878−83, but American efforts at the fur trade remained minor (BLM 

2015a; Spartz and Mishler 1985). 

The Moravian and Roman Catholic churches both built missions, as well as boarding schools and 

orphanages, along the Yukon and Kuskokwim Rivers starting in the late 1880s. The Moravians also 

introduced reindeer herding into the area, but the enterprise struggled and finally failed in the mid2-143 
 

 

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twentieth century. Reindeer herding was more successful around the Norton Sound area, where it was 

managed by missionaries under the guidance of the BIA, and continues there today, where it is permitted 

by the BLM. The Organic Act of 1884 created a civilian government for Alaska, which included the 

establishment and management of schools, but soon after the schools were segregated when Native 

American education, as well as other services like health care, were taken over by the BIA. The main BIA 

school and medical facility in the planning area were located in Bethel (BLM 2015a; Spartz and Mishler 

1985). 

The Gold Rush affected events in the planning area, as it did elsewhere in Alaska. Prospectors were 

reported in the Kuskokwim River basin as early as 1889. Gold was discovered near Aniak in 1900, but 

very little was found in the end. In 1906, gold was discovered on Ganes Creek, leading to the 

establishment of the town of Ophir, which in turn became a supply hub for surrounding mines in the 

Innoko District. The first gold discoveries in the Iditarod District were made in 1908 and led to the 

founding of the towns of Flat and Iditarod, which led to one of the last major gold rushes in Alaska. The 

Flat area contained the richest placer deposits within the planning area, and the Iditarod District is the 

third largest placer district in Alaska. Gold has also been discovered on the Tuluksak River near Aniak, 

and near the community of Marshall. Lode gold was discovered on the Nixon Fork of the Kuskokwim 

River in 1918−1919, and active claims still exist on the Nixon Fork Mine. The region is the largest lode 

gold producer in the planning area; although copper is also mined here. In addition, lode gold has been 

found near Ophir and Flat. As discussed in the AMS (BLM 2015a), the planning area contains 11 mining 

districts, and has made a significant contribution to mining in Alaska. NEPA reviews are currently 

underway for a proposed lode gold mine near Crooked Creek. Russian explorers reported the presence of 

cinnabar, an ore for mercury, on the Kuskokwim as early as 1838; Red Devil became the largest mercury 

producer in the state and operated until the 1970s (BLM 2015a; Kurtak et al. 2010). 

A larger gold strike was found near Ophir in 1908, and several contemporary discoveries were made 

along the Yukon and Kuskokwim Rivers, leading to the establishment and boom of communities like 

Ophir, Iditarod, Flat, Georgetown, and Sleetmute. Mercury also was discovered near Sleetmute in 1906, 

leading to the establishment of the Red Devil Mine, which reached the peak of its production in 1939 

(BLM 2015a; Spartz and Mishler 1985). 

Other explorations and activities in the area included a geological exploration in 1898, an exploration of 

the Kuskokwim headwaters by the U.S. Army in 1899, an ethnographic project by George Gordon in 

1907, anthropological research by Ales Hrdlicka in 1930, and a survey of the Government Trail – now 

known as the Iditarod Trail – by the Alaska Road Commission in 1908 (BLM 2015a; Spartz and Mishler 

1985). 

The late nineteenth and early twentieth century gold discoveries described above attracted thousands of 

people to the area. Trails used for thousands of years by the indigenous inhabitants were reused, and trails 

were extended, improved, or blazed as needed to access mining areas, to become the network of trails 

known as the Iditarod trail network. Commercial posts were established along transportation routes and in 

some places grew into communities. In 1908, the Alaska Road Commission (ARC) surveyed a route that 

became known as the Iditarod Trail. Subsequently, the ARC and other people blazed trails that connected 

to the surveyed trail. From ARC’s survey of the trail through the 1930s, it was the principal long-distance 

winter overland corridor linking south central Alaska, including the ice-free port at Seward with west 

central and western Alaska, ending at Nome. From 1930-1942, the trail was heavily used to move mail 

and freight to mines, camps and villages, and to ship ore from the mines. With the rise of the Alaska 

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Railroad, and other changes to the state’s economy during WWII, the year 1942 effectively marks the end

of the Iditarod Trail as a long-distance winter travel route (Antonson and Lewis 2016). 

Bethel was the major port and trading center in the planning area in the twentieth century. Commercial 

fishing began about 1913 at the mouth of the Kuskokwim and continued to be important to the economy 

of both coastal communities such as Bethel, and to inland communities on the river as fishing expanded. 

The area was closed to commercial fishing at various times starting in the mid-1920s to allow overfished 

areas to recover (Spartz and Mishler 1985). While most commercial fishing in the region was 

concentrated on marine resources, this focus did spread up the Kuskokwim. This economic focus may 

have led to some population shifts in the Yukon-Kuskokwim Delta and may have led to changes in the 

subsistence lifestyle of many Yukon-Kuskokwim Delta residents (BLM 2015a). 

The Alaska National Guard was established during World War II in several communities within the 

planning area and was regionally headquartered at Bethel both before and after the war. Today, the most 

populated commercial communities in the area are Aniak, Bethel, McGrath, St. Michael, and Unalakleet 

(BLM 2015a; Spartz and Mishler 1985). 

Known Sites 

The planning area contains a wide variety of cultural resources, including prehistoric resources, historic 

resources, and traditional use areas important to contemporary Native peoples. However, at this time, a 

large proportion– more than 90 percent – of the planning area has not been subjected to cultural resources 

inventory. Nearly all of the archaeological work in the planning area in the past 30 years has been Section 

106 surveys (Potter and Cook 2006) or mitigation excavations (Gaines et al. 2006). Most research has 

been along the coast, though several surveys and excavations have been conducted in the interior. Given 

the low amount of survey coverage in the planning area, it is reasonable to assume that there are many 

unknown cultural resources that have been neither inventoried nor evaluated for eligibility for inclusion in 

the NRHP (BLM 2015a). 

Data Sources 

Information presented herein is based primarily on a review of data on file at the Alaska Heritage 

Resource Survey (AHRS; ADNR-OHA 2016)—a statewide GIS database of archaeological, historical, 

and paleontological sites that provides locational information and coordinates, descriptions of site 

characteristics, features, associated artifacts, chronology and time period, NRHP listing or eligibility 

status if available, site condition, and other important site information. There are, however, certain 

limitations to AHRS data. Data reported in the AHRS comes from a variety of sources and can be 

inconsistent, particularly in the case of reported landowner of site location. Many of the sites were 

recorded before the advent of GPS technology, so reported locations and site extents are often imprecise. 

While ongoing efforts are underway to update the database, many of the sites have not been frequently 

updated and may have been removed or destroyed since being reported, may not resemble provided 

descriptions, or may not be described accurately or in detail. Despite these limitations, however, the 

AHRS files, including the GIS and map-based data, archived documents, and reports, represent the best 

available information for archaeological and historic site locations and extents for the project area. BLM 

sources (BLM 2015a; BLM 2018b) also provided information on cultural resource sites in the planning 

area. 

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Archaeological Sites and Historic Properties 

As of 2017, there are 1,932 known archaeological sites in the AHRS database within the boundaries of 

the planning area. These include both sites on BLM-managed public lands, and those on lands managed 

by the State of Alaska, other federal agencies, Native corporations, and private landowners. There is a 

wide variety of historic, prehistoric, and protohistoric site types including prehistoric villages and artifact 

scatters, historic cabins, historic mining sites, World War II sites, mid-twentieth century Cold War 

military sites, and historic trails, many of which were used in pre- and proto-historic times. Twenty-eight 

of the sites are paleontological sites from Lindsey (1986) described in a separate section. The number of 

site types in the planning area regardless of land status is provided in Table 2.10.4-1. 

Table 2.10.4-1. AHRS Site Types in Planning Area Regardless of Land Status 

Period Number 

Historic 1,200 

Historic/Protohistoric 7 

Prehistoric 349 

Prehistoric/Historic 110 

Protohistoric 11 

Unknown 227 

Total 1,904 

Note. Total does not include 28 paleontological sites listed in AHRS. 

There are 135 sites within the planning area that have the BLM listed as landowner on their AHRS site 

card (BLM 2015a). There are also over 900 sites within the planning area that have no landowner listed 

on their site card. Additional sites list “U.S. Government” as the owner on their site card without naming 

the specific agency. Some of these might also be located on BLM-managed public lands. 

GIS analyses of AHRS geospatial database identifiy 101 AHRS sites on BLM-managed public lands 

within the planning area. The discrepancy between this number (n=101) derived from geospatial analysis 

and the number of sites with the BLM listed as landowner their site card (n=135) is due to limitations 

with the current state of AHRS data detailed in the preceding section. Twenty of these are paleontological 

sites listed in Lindsey (1986) and are discussed in a separate section. Table 2.10.4-2 provides site type, 

except for paleontological, for AHRS sites on BLM-managed public lands in the planning area. 

Table 2.10.4-2. AHRS Site Types on BLM-Managed Lands 

Period Number 

Historic 41 

Historic/Protohistoric 3 

Prehistoric 27 

Prehistoric/Historic 4 

Protohistoric 0 

Unknown 6 

Total 81 

Note: Total does not include 20 paleontological sites listed in AHRS. 

The number, nature, and location of known cultural resources present within any given area of the 

planning area vary depending on numerous factors. Some are due to actual site occurrence from 

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prehistoric and historic human behavior and activity. Others are due to taphonomy, preservation and 

visibility. In most cases in the planning area, though, known site distribution is primarily influenced by 

areas where archaeological research has actually been conducted. Through modeling efforts in Alaska, 

archaeologists have identified several key factors that influence site locations and types including such 

factors as elevation, slope, aspect, distance to permanent and/or intermittent water, and presence or 

absence of resources of interest (e.g., fish or wildlife resources, valuable minerals). 

The degree to which these factors influence the type and density of cultural resource sites in a given area 

also varies depending on the time period–prehistoric or historic–considered. For example, technological 

advances during the historic period made it possible for people to live and work in areas that would have 

been less desirable during the prehistoric period. Long-term settlements or habitation sites, particularly 

during the prehistoric period, were typically located in areas in proximity to water resources–on or near 

rivers, creeks and streams, or lake and coastal shorelines–that would have provided opportunities to 

harvest fish and marine resources. Short-term camps, however, related to big-game hunting could be 

located in all types of environments, but are typically found in areas of higher topographical relief that 

would have provided viewsheds from which to spot animals. Short-term campsites tend to have smaller 

numbers of artifacts, such as projectile points for hunting, that are typically associated with acquiring a 

specific resource and they generally lack permanent features such as living or storage structures. Longterm settlements frequently contain large numbers of artifacts and a wider diversity of artifact types, 

including items for processing rather than simply obtaining resources, and at least some evidence of 

structures. 

Prehistoric sites in the planning area range from surface or shallowly buried lithic scatters, campsites, 

resource procurement area, and land large pithouse villages. The majority of known sites are located in 

more easily accessible areas: along the Bering Sea coast on the Yukon-Kuskokwim Delta, along the 

Yukon, Kuskokwim, and Unalakleet Rivers, and near communities such as Unalakleet and McGrath. 

Major sites in the northwest portion of the planning area, near the community of Unalakleet, include Old 

Fish Camp, near the Yukon River, and Unalaqliq and Tagilgayak on the Unalakleet River (BLM 2015a). 

Sites on the coast are due to prehistoric exploitations of the Bering Sea’s rich marine resources.

Prehistoric sites occur locally along rivers, streams, tributaries, lakes that would have provided access to 

fish resources, and on topographically higher terrain with better drained soils and prominent viewsheds 

from which to spot game animals. 

In both BLM lands and the total planning area, historic sites outnumber prehistoric sites. This is likely 

due to several reasons. First of all, historic sites are typically surface occurrences. They are collapsed and 

ruined buildings, structures, equipment and other artifacts and features that are visible on or above the 

present ground surface. Most are less than 100 years old, which means they are likely not completely 

eroded or degraded down to the ground and are clearly visible today. Consequently, they are found more 

readily than buried prehistoric sites, and are more likely to be recorded. Second, two of the main 

occupations that drew people into the region during the early-mid twentieth century were placer gold 

mining and trapping, and both focused much of their activities immediately alongside creeks and rivers. 

This extensive, yet narrow geographic focus of activities, typically within a few dozens of feet of a stream 

edge, makes finding sites related to these two economic activities relatively easy. Third, due to logistical 

and funding considerations associated with conducting fieldwork in this remote, isolated region, surveys 

have tended to focus on areas that are relatively cheaper and easier to get to, such as areas immediately 

adjacent to roads, trails, and floatable rivers and creeks where historic sites tend to be located. 

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Historic Trails 

Historic and prehistoric trails, whose use is verified by oral accounts, historic records, and physical 

evidence, are an important resource in the planning area. The AHRS lists 35 trails in the planning area; 

six of these are plotted within BLM-managed public lands. These are primarily associated with the INHT, 

discussed in Section 4.2, National Trails, as well as the Iditarod Trail itself, and the Kaltag Portage. Trails 

in the planning area were used to transport goods, supplies and mail, and include paths and roads used for 

foot travel, dog sled travel, and mule and horse-drawn transport. Many remain in use (Antonson and 

Lewis 2016). 

The Iditarod Trail network includes primary routes between communities and connecting trails between 

camps. The network’s trails generally follow natural corridors, such as the Kaltag Portage on the 

Unalakleet River. They were primarily used in the winter when lowlands area were frozen, and rivers, 

creeks, lakes and tundra could be more easily crossed. Trails and routes used by Alaska Native peoples in 

prehistoric and protohistoric times were incorporated into the Iditarod Trail network blazed in 1910–1911. 

For example, the Kaltag Portage, which is a key segment of the Iditarod Trail, provided a vital link from 

the rivers of interior Alaska to the Bering Sea coast used for thousands of years by Native peoples, as well 

as early Euroamerican explorers. 

Sites of Traditional Cultural Importance 

Sites of traditional cultural importance are distinguished from archaeological sites in order to discuss 

places of traditional, religious, sacred, or cultural importance that are not necessarily associated with 

prehistoric or historic artifact assemblages, collections or structures. These sites are typically identified by 

tribal representatives during the government-to-government consultation process required of federal 

agencies. Such sites may qualify as TCPs, or large-scale cultural landscapes, under Section 106 of the 

NHPA. Some common site types are lakes, rivers and springs, land features, and traditional gathering or 

collection areas. 

The BSWI ACEC Summary Report (BLM 2018b), currently provides the best source of data on locations 

of traditional importance in the planning area. Six potential ACECs meet the relevance and importance 

criteria for cultural resources. Five of these six ACECs were associated with historic archaeological sites 

and the Iditarod and Kaltag portage trail networks. One ACEC qualifies as a traditional use ACEC—the 

proposed Tagagawik River ACEC, a 301,044-acre area that has importance as the region for trade 

between the Koyukon Athabaskan and Selawik Iñupiat and may qualify as TCP (BLM 2018b). Eight 

other areas, while not found to meet ACEC criteria, were identified as having important traditional use 

areas: the Anvik River; the Anvik River watershed; Egavik Creek; the Bonasila River watershed; Old 

Anvik Village; the Egavik Creek watershed; the Golsovia River watershed; the Tenmile River watershed; 

the Holy Cross area; and Ohogamiut (BLM 2018b). Further tribal consultation may reveal TCPs within 

these regions, or other specific areas of traditional importance. These areas may also be found to qualify 

as Traditional Cultural Landscapes. Future land use managers should anticipate additional areas of 

traditional importance in these, or other, locations in the planning area to be identified during further 

tribal consultation. 

2.10.5 Resource Changes: Trends and Forecasts 

Preferred conditions for cultural resources on federal lands is that they remain stabilized and not 

adversely affected by natural and cultural processes, and that they are used towards increased educational 

and interpretive use. The current trend for NRHP-eligible or listed sites in the planning area is that those 

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adjacent to populated areas are subject to greater potential for damage, removal, or alteration from agents 

caused by people and their equipment. Those resources farther from developed areas are relatively 

stabilized and are not subject to affects from routine activities. 

Large-scale and intense wildland fires can and will occur in interior Alaska. Such fires, if they sweep 

through specific portions of the planning area, could have a severe effect on the significant cultural 

resources of that area. 

Interest in mining gold and other minerals has also increased in recent years on both private and BLMmanaged lands, as the value of these commodities has increased. Current federal law and BLM 

management, regulations, and policies permit mining wherever it is legally allowable and where it does 

not adversely affect important resources. As a result, more mining on BLM-managed lands is occurring 

relative to only a few years ago when commodity prices were much lower. Whether this recent upsurge in 

mining activity is normal, or whether it forecasts the beginning of a larger trend, is not currently known. 

Qualitative observation indicates a downward trend in condition for recorded and unrecorded cultural 

resources that are not associated with formal surface disturbing management proposals. Illegal removal of 

artifacts, surface disturbance associated with recreational activity, limited law enforcement, and intensive 

grazing practices all contribute to the downward trend. Based on current management practices, improved 

access to BLM-managed lands, and increased development, the forecast would be to continue this 

downward trend of cultural resource conditions due to the following factors: 

• Greater potential for cultural resources being illegally removed or damaged, due to increases in 

recreational and commercial usage, and limited law enforcement presence; 

• A likelihood for continued large-scale wildfires in the planning area resulting in damage; 

• Continued activities that result in damage or destruction of cultural resources on private, State, 

and non-BLM-managed lands; and 

• Continued permitting of authorized actions by BLM including mining and energy development 

that contribute to sites and artifacts being affected. 

2.11 Paleontological Resources 

2.11.1 Introduction 

Paleontology is a multidisciplinary science that combines elements of geology, biology, chemistry, and 

physics in an effort to understand the history of life on earth. Paleontological resources are defined as any 

fossilized remains, traces, or imprints of organism, preserved or in the earth’s crust, that are of 

paleontological interest and that provide information about the history of life on earth, with the exception 

of materials associated with an archaeological resource or any cultural item as defined in the NAGPRA. 

Paleontological resources are considered finite non-renewable resources because the organisms they 

represent no longer exist; once destroyed, they can never be replaced. 

Paleontological resources include mineralized, partially mineralized, or un-mineralized: 

• bones and teeth; 

• soft tissue; 

• skin or soft tissue impressions; 

• shells, and other invertebrate remains; 

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• flora--wood, leaf or plant impressions; 

• footprints, trails, or trackways; 

• burrows; 

• microscopic remains; and 

• fossil amber with insect remains. 

As the occurrence of paleontological resources is closely tied to the geologic units (e.g., beds, formations, 

or members) that contain them, paleontological resources are not just the fossils themselves, but also 

include host rocks or organic matter and physical characteristics of the fossil-bearing sedimentary matrix. 

Paleontological resources are important scientific resources that can be used to: 

• document the presence, geographic distribution, and range of now-extinct organisms; 

• study the evolutionary relationships among extinct organisms, and their relationships to modern 

groups; 

• reconstruct ancient environments, climate change, and paleoecological relationships; 

• provide indices for relative geologic dating; 

• provide indices to determine the relationship of stratigraphic units at local, regional, continental 

and global scales; 

• understand tectonic movements of land masses and ocean basins through time; 

• study patterns and processes of evolution, extinction, and speciation; 

• identify causes and effects of global environmental and climate change; and 

• understand faunal and floral responses to global environmental and climate change. 

It is important to note that the list above is not all-inclusive of the potential significant scientific 

contributions of the fossil record. Thorough, detailed documentation of the fossil record has the potential 

to answer other important contemporary or future scientific research questions. 

BLM guidance (IM 2009-011) defines significant paleontological resources as any paleontological 

resource that is considered to be of scientific interest, including most vertebrate fossil remains and traces 

and certain rare or unusual invertebrate and plant fossils. Scientific importance results from resources that 

are rare or previously unknown species, of high quality and well-preserved, preserve a previously 

unknown anatomical or other characteristic, provide new information about the history of life on earth, or 

have identified educational or recreational value. Paleontological resources that may be considered to not 

have paleontological significance include those that lack provenience or context, lack physical integrity 

because of decay or natural erosion, or that are overly redundant or are otherwise not useful for research. 

Vertebrate fossil remains and traces include bone, scales, scutes, skin impressions, burrows, tracks, tail 

drag marks, vertebrate coprolites (feces), gastroliths (stomach stones), or other physical evidence of past 

vertebrate life or activities. 

2.11.2 Laws, Regulations, and Policies 

The Paleontological Resources Preservation Act of 2009 (PRPA; Under Omnibus Public Lands Act of 

2009; 16 U.S.C. 470aaa) provides specific direction regarding management of paleontological resources 

on federal lands, including permitting enforcement, and penalties. The PRPA provides federal agencies 

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with a consistent paleontological resources management framework and mandates them to “manage and

protect paleontological resources on federal lands using scientific principles and expertise.” In passing the

PRPA, Congress officially recognized the scientific importance of paleontological resources on federal 

lands by declaring that fossils from these lands are federal property that must be preserved and protected. 

The PRPA codifies existing policies of the various federal land management agencies and provides 

uniform criminal and civil penalties for illegal sale and transport, and theft and vandalism, and destruction 

of fossils from federal lands, including inadvertent destruction from land use projects or development. 

For actions on federal lands, the PRPA establishes that potentially affected paleontological resources and 

paleontologically sensitive areas must be identified, potential impacts identified and assessed, and proper 

treatment and mitigation actions implemented to protect significant paleontological resources. 

ARPA (P.L. 9695; 16 U.S.C. 470ee) prohibits unauthorized removal of fossils that are in an 

archaeological context from federal lands. Fossils on federal lands have been interpreted as federal 

property, and as such receive protection from Damage to Federal Property (18 U.S.C. 1361), which 

protects fossils from disturbance resulting in damage, and Theft of Government Property (18 U.S.C. 641), 

which views unauthorized collection of fossils as theft of government property. 

Additional federal protections for fossils and/or paleontological resources on public lands include: Federal 

Cave Resources Protection Act of 1988 (P.L. 94579; 43 U.S.C. 1701 et seq.), which includes protection 

of fossils contained within caves; 43 CFR 3809.420 (b)(8) prohibits the willful disturbance, alteration, 

removal or destruction of paleontological resources from mining operations on public lands; 43 CFR 

3610, which addresses protection of significant fossils from operations authorized under mining laws; 43 

CFR 3622, 3602, and 3604 which addresses the collection of petrified wood for commercial and noncommercial uses; 43 CFR 8200, which covers management of lands that have exceptional natural history 

values, such as fossils, which are of scientific interest; 43 CFR 1610.7-2, which deals with establishing 

ACECs for management and protection of significant natural resources, such as paleontological localities; 

and 43 CFR 8365.15, which prohibits willful disturbance, removal and destruction of scientific resources 

such as fossils. The CFRs for management of paleontological resources are in draft and will be followed 

when finalized. 

The BLM has also developed general procedural guidelines for the management of paleontological 

resources—BLM Manual 8270, Handbook 8720-1, IM 2008-009, IM 2009- 011, and IM 2016-124. 

Paleontological resource management objectives include the evaluation, management, and protection of 

fossils on BLM-managed public lands. The management policy found in Appendix C of BLM Handbook 

H-1601-1 (BLM 2005) also includes measures to ensure that proposed land-use projects do not 

inadvertently damage or destroy significant paleontological resources. The authority for the BLM to issue 

paleontological resource use permits from lands under its jurisdiction is granted by Secretarial Order 

3104. Note that the BLM manual pre-dates the PRPA and IMs discussed here; when updated, it will 

follow the new CFRs, once finalized. 

Paleontological resources are protected on State of Alaska lands under the Alaska Historic Preservation 

Act (AHPA; AS 41.35.010-41.35.240), which codifies State policy to “preserve and protect the historic, 

prehistoric, and archaeological resources of Alaska from loss, desecration, and destruction” (AS 

41.35.010). Under the regulations implementing the AHPA, prehistoric archaeological resources are 

explicitly defined to include paleontological resources. The AHPA mandates paleontological surveys, 

impacts assessment and avoidance or mitigation prior to any public construction or public improvement 

by the State, a governmental agency of the State, or a private person under contract with or licensed by 

the State or governmental agency of the State. 

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Potential Fossil Yield Classification System 

Potential paleontological resource impacts tend to be determined at the geologic unit level (unlike cultural 

resources, which are managed at the site level). The premise behind determining potential paleontological 

resource impacts at the geologic unit level is that because fossils are typically encased in bedrock, 

sediments, or in the case of Alaska, permafrost, field surveys that employ surface inspections or shallow 

subsurface testing in unconsolidated sediments (such as cultural resource field surveys) have limited 

utility in determining the presence or absence of paleontological resources. The BLM’s Potential Fossil 

Yield Classification (PFYC) system ranks geologic units by their potential for containing significant 

paleontological resources. It is the primary means for assessing potential impacts to paleontological 

resources and is one of the initial criteria to help determine whether field surveys are required for land 

management decisions. 

As discussed in IM 2016-124 (BLM 2016d), which describe the PFYC, occurrences of paleontological 

resources are closely tied to the geologic units (i.e., formations, members, or beds) that contain them. The 

probability for finding paleontological resources can be broadly predicted from the geologic units present 

at or near the surface. Therefore, geologic mapping can be used for assessing the potential for the 

occurrence of paleontological resources. However, it is impossible to predict the specific types of fossils 

that will be found or their exact locations in a geologic unit. 

Using the PFYC system, geologic units are classified based on the relative abundance of vertebrate fossils 

or scientifically significant invertebrate or plant fossils and their sensitivity to adverse impacts, with a 

higher class number indicating a higher potential. This classification is applied to the geologic formation, 

member, or other distinguishable unit, preferably at the most detailed mappable level. It is not intended to 

be applied to specific paleontological localities or small areas within units. Although significant localities 

may occasionally occur in a geologic unit, a few widely scattered important fossils or localities do not 

necessarily indicate a higher class; instead, the relative abundance of significant localities is intended to 

be the major determinant for the class assignment (BLM 2016d). 

The PFYC system is meant to provide baseline guidance for predicting, assessing, and mitigating 

paleontological resources. The classification should be considered at an intermediate point in the analysis 

and should be used to assist in determining the need for further mitigation assessment or actions. 

The descriptions for the classes below are written to serve as guidelines rather than as strict definitions. 

Knowledge of the geology and the paleontological potential for individual units or preservational 

conditions should be considered when determining the appropriate class assignment. PFYC rankings and 

associated maps are currently being developed for the State of Alaska. BLM paleontologists determine 

the appropriate PFYC rankings for the state after reviewing PFYC assignment recommendations. 

The PFYC system rates geologic units according to their likelihood for containing recognizable fossil 

remains as follows (from BLM 2016d): 

Class 1 – Very Low: Geologic units that are not likely to contain recognizable fossil remains. 

• Units that are igneous or metamorphic, excluding reworked volcanic ash units. 

• Units that are Precambrian in age or older. 

Management concern for paleontological resources in Class 1 units is usually negligible or not applicable. 

The occurrence of significant fossils is nonexistent or extremely rare. Assessment or mitigation is usually 

unnecessary. The probability for impacting any fossils is negligible. 

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Class 2 – Low: Sedimentary geologic units that are not likely to contain vertebrate fossils or scientifically 

significant non-vertebrate fossils. 

• Field surveys have verified that significant paleontological resources are not present or are very 

rare. 

• Units are generally younger than 10,000 years before present. 

• Recent aeolian deposits. 

• Sediments that exhibit significant physical and chemical changes (i.e., diagenetic alteration). 

Management concern for paleontological resources in Class 2 units is generally low (also applies to Class 

1). Localities containing important resources may exist but would be rare and would not influence the 

classification. Assessment or mitigation is usually unnecessary except in rare or isolated circumstances. 

The probability for impacting vertebrate fossils or scientifically significant invertebrate or plant fossils is 

low. Class 2 localities would be managed on a case-by-case basis. An assignment of Class 2 may not 

trigger further analysis unless paleontological resources are known or found to exist. However, standard 

stipulations should be put in place prior to authorizing any land use action in order to accommodate 

unanticipated discoveries. 

Class 3 – Moderate: Sedimentary geologic units where fossil content varies in significance, abundance, 

and predictable occurrence; or sedimentary units of unknown fossil potential. Units assigned to Class 3 

have some of the following characteristics: 

• Marine in origin with sporadic known occurrences of paleontological resources. 

• Paleontological resources may occur intermittently, but abundance is known to be low. 

• Units may contain significant paleontological resources, but these occurrences are widely 

scattered. 

• The potential for an unauthorized land use to impact a significant paleontological resource is 

known to be low-to-moderate. 

Management concerns for paleontological resources are moderate because the existence of significant 

paleontological resources is known to be low. Common invertebrate or plant fossils may be found in the 

area, and opportunities may exist for casual collecting. Paleontological mitigation strategies will be 

proposed based on the nature of the proposed activity. 

This classification includes units of moderate or infrequent occurrence of paleontological resources. 

Management considerations cover a broad range of options that may include record searches, predisturbance surveys, monitoring, mitigation, or avoidance. Surface-disturbing activities may require 

assessment by a qualified and BLM-permitted paleontologist to determine whether significant 

paleontological resources occur in the area of a proposed action, and whether the action could affect the 

paleontological resources 

Class 4 – High: Geologic units that are known to contain a high occurrence of significant fossils. Units 

assigned to Class 4 typically have the following characteristics: 

• Significant paleontological resources have been documented but may vary in occurrence and 

predictability. 

• Surface disturbing activities may adversely affect paleontological resources. 

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• Rare or uncommon fossils, including nonvertebrate (such as soft body preservation) or unusual 

plant fossils, may be present. 

• Illegal collecting activities may impact some areas. 

Class 5 – Very High: Highly fossiliferous geologic units that consistently and predictably produce 

significant paleontological resources. Units assigned Class 5 have some or all of the following 

characteristics: 

• Significant paleontological resources have been documented and occur consistently. 

• Paleontological resources are highly susceptible to adverse impacts from surface disturbing 

activities. 

• Unit is frequently the focus of illegal collecting activities. 

Management concern for paleontological resources in Class 5 areas is high to very high. A field survey by 

a qualified and BLM-permitted paleontologist is almost always needed. The probability for impacting 

significant paleontological resources is high. The area should be assessed prior to land tenure adjustments. 

Pre-work surveys are usually needed and on-site monitoring may be necessary during land use activities. 

Avoidance or resource preservation through controlled access, designation of areas of avoidance, or 

special management designations should be considered. 

Class U – Unknown: Geologic units that cannot receive an informed PFYC assignment. Characteristics 

of Class U may include: 

• Geological units may exhibit features or preservational conditions that suggest significant 

paleontological resources could be present, but little information about the actual paleontological 

resources of the unit or area is known. 

• Geological units represented on a map are based on lithologic character or basis of origin but 

have not been studied in detail. 

• Scientific literature does not exist or does not reveal the nature of paleontological resources. 

• Reports of paleontological resources are anecdotal or have not been verified. 

• Area or geologic unit is poorly or under-studied. 

Until a provisional assignment is made, geologic units that have an unknown potential have medium to 

high management concerns. Lacking other information, field surveys are normally necessary, especially 

prior to authorizing a surface-disturbing activity. An assignment of “Unknown” may indicate the unit or 

area is poorly studied, and field surveys are needed to verify the presence or absence of paleontological 

resources. Literature searches or consultation with professional colleagues may allow an unknown unit to 

be provisionally assigned to another Class, but the geological unit should be formally assigned to a Class 

after adequate survey and research is performed to make an informed determination. 

Class W – Water: Includes any surface area that is mapped as water. 

Class I – Ice: Includes any area that is mapped as ice or snow. 

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Planning Area PFYC Assignments 

The PFYC of the planning area has been broadly characterized by the BLM regional paleontologist as 

part of a statewide PFYC study in 2010 (BLM 2015a). PFYC assignments in some areas of the planning 

area were later refined by the BLM during BSWI RMP planning. 

Planning area PFYC assignments are depicted in BSWI Draft RMP/EIS, Map 3.2.11-1. As discussed in 

the BSWI AMS (BLM 2015a), the overwhelming majority of the planning area falls under Class U 

“unknown” or Class 3 “moderate” potential for significant fossils. Reports of Quaternary vertebrate 

fossils from placer mines in the Flat, Ophir, Willow Creek, and Julian mining districts are common. The 

planning area is also home to the Cretaceous-period Kuskowkim Group deposits that have the potential 

for dinosaur fossils. 

The classification of most the planning area as “unknown” is symptomatic of data gaps resulting from the 

low number of paleontological studies in the planning area. PFYC assignments in the planning area will 

be refined and updated as future land use planners follow the guidance in IM 2009-11 (BLM 2008) to 

assess potential effects to paleontological resources under PRPA, NEPA, and other relevant legislation. 

2.11.3 Resource Indicators 

The conditions that are established in the discussions below provide a baseline for paleontological-related 

values, which the impact analysis will be based on. The following indicators, along with qualitative 

discussions, will be used to evaluate impacts associated with management decisions in the BSWI Draft 

RMP/EIS. 

• Acres with no land use restrictions that serve to limit surface disturbance and protect 

paleontological resources 

• Acres of BLM-managed lands identified for acquisition, retention, or disposal 

• Acres subject to permitting stipulations for land use 

• Change in acres with land use restrictions that serve to limit surface disturbance and protect 

paleontological resources or promote the identification and inventory of fossil locations. 

2.11.4 Current Conditions 

Fossil Occurrences 

Little work has been done to inventory fossil occurrences on BLM-managed public lands in the planning 

area. In 1986, the BLM contracted for a collection and synthesis of existing data on paleontological 

resources on BLM-managed public lands in Alaska, including the planning area (Lindsey 1986). 

Paleontological resources surveys and inventories conducted as part of the proposed Donlin Gold mine in 

part occurred on BLM-managed public lands in the planning area (Druckenmiller et al. 2013; Jacobus and 

Druckenmiller 2013; Reuther et al. 2014). Available data also include the Alaska Paleontology Database 

(Zhang and Blodgett 2003), a cumulative database of paleontological localities, which is searchable by 

USGS quadrangle for the entire State of Alaska, regardless of land ownership status. As discussed in the 

BSWI RMP AMS (BLM 2015a), the Alaska Paleontological Database tends to focus on pre-Quaternary 

invertebrate fossils. Lindsey includes all fossils reported from his reference sources. Neither database is 

exhaustive of the fossil localities in the planning area. The absence of known fossil localities in any given 

region of the planning area could be the result of a lack of investigation, survey and inventory, rather than 

a true absence of paleontological sites. Further, there is undoubtedly overlap between the two sources, 

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making an exact count of localities difficult to ascertain. Despite these limitations, however, these 

databases remain the best sources of information for paleontological localities in the planning area. The 

following discussion is based primarily on these two sources 

The ARCTOS database contains accession records for paleontological materials housed in the Earth 

Sciences Collection at the University of Alaska Museum of the North. This database provides information 

on specimens recovered or collected from the planning area. The ARCTOS database is, however, 

organized by specimen and lists museum curation information. Provenience information, if available, is 

typically at the level of USGS quadrangle; it is not organized by paleontological “site” or “locale.” 

Further, as many of the specimens in the ARCTOS database were donated to the museum by early 

twentieth century miners or avocational collectors, the provenience information is oftentimes imprecise or 

inaccurate. While these limitations hinder the use of the ARCTOS database for determining fossil 

localities in the planning area, it does provide information regarding Pleistocene vertebrates from the 

planning area that augments the information from Lindsey (1986) and the Alaska Paleontological 

Database. 

Table 2.11.4-1 summarizes the known fossil localities with the boundaries of the planning area as 

reported by Lindsey (1986) and Alaska Paleontological Database (Zhang and Blodgett 2003). 

Table 2.11.4-1. Paleontological Localities in the Planning Area 

USGS Quadrangle Name 

Number of Fossil Occurrences 

(Zhang and Blodgett 2003*) 

Number of Fossil Localities on BLMmanaged Public Lands (Lindsey 1986) 

Baird Inlet 0 0 

Bethel 138 4 

Black 0 0 

Candle 8 1 

Holy Cross 4 0 

Hooper Bay 1 0 

Iditarod 31 4 

Kateel River 33 26 

Kuskokwim Bay 0 0 

Kwiguk 12 0 

Lake Clark 28 0 

Lime Hills 30 1 

Marshall 5 0 

McGrath 101 33 

Medfra 134 0 

Norton Bay 39 2 

Nulato 72 28 

Nunivak 4 0 

Ophir 9 0 

Russian Mission 30 2 

Sleetmute 61 0 

Taylor Mts. 112 0 

Unalakleet 38 14 

*Includes all data from USGS quadrangle regardless of land status and is not restricted to BLM-managed public lands. 

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As discussed in the BSWI AMS (BLM 2015a), and shown in Table 2.11.4-1 above, the most concentrated 

fossil localities are located in two groups of two adjacent quadrangles: the McGrath and Medfra, and 

Bethel and Taylor Mountain areas. These areas are both also near important mining localities. Fossil types 

found include corals, gastropods, ammonites, trilobites, and Mesozoic plants. Marine invertebrates, 

including bivalves are reported from the McGrath B-2 and B-1 quadrangles. The McGrath B-3 

quadrangle has abundant Cenozoic plant macrofossils, contained within volcanoclastic sandstones. 

McGrath B-4 contains fossiliferous sandstones containing Cenozoic plant fossils and the potential for 

vertebrate body and trace fossils, such as impressions and casts. The McGrath A-5 quadrangle contains 

fossiliferous sandstones with Cenozoic flora fossils, as well as a fossiliferous Devonian limestone unit 

containing Devonian corals, brachiopods and foraminifera. McGrath A-5 also has a micaceous sandstone 

unit containing Silurian graptolites (Jacobus and Druckenmiller 2013). The McGrath area is also home to 

the Terra Cotta Mountains that contain a long sequence of rock containing graptolites, which is an 

important biostratigraphic reference for Silurian and Ordovician zones elsewhere in Alaska. This 

formation is located on State of Alaska patents, but is within the planning area and is within 31 miles (50 

kilometers) of BLM lands (Churkin and Carter 1996). 

Within the Iditarod, Russian Mission, Sleetmutes, Bethel and Taylor Mts. quadrangles is the Gemuk 

Group, which has produced marine invertebrates (pelecypods) from the Upper Jurassic, and the 

Kuskokwim Group, which has also produced marine invertebrates (pelecypods) from the Middle Jurassic 

from its lower members. Previous research has shown that the Late Cretaceous Kuskokwim Group is 

dominated by deep water marine turbidite facies sedimentary rock. Cady et al. (1955) used 38 fossil 

locations to determine the age of the Kuskokwim Group sedimentary rocks as Late Cretaceous. Most 

fossils in the area consist of marine invertebrate fossils and are more abundant in the younger (upper 

strata) of the Kuskokwim Group. Fauna include pelecypod and cephalopod mollusks, as well as annelid 

worms, brachiopods, and barnacles. Fish fossils occur locally, and where present, are abundant. Flora 

fossils include terrestrial ferns and flowering plants. Most fossil material is fragmental, which suggests 

transport from place of origin prior to deposition. Cady et al. (1955), Box and Elder (1992) and Elder and 

Box (1992) identify 15 Inoceramid bivalves of Late Cretaceous age in the Kuskokwim Group. Quaternary 

vertebrate fossils have also been reported in overlying sediments in the area (Reuther et al. 2014). There 

is good potential that these units could also contain evidence of terrestrial vertebrates, especially of 

dinosaur tracks, but possibly also dinosaur skeletal material (Jacobus and Druckenmiller 2013). Nonmarine strata within the Kuskokwim Group are known to contain abundant plant fossils, which are 

associated with a high potential for dinosaur tracks and skeletal remains based on geologic similarities 

with other depositional settings of Cretaceous age, such as the Cantwell Formation of Denali National 

Park and Preserve (Fiorillo et al. 2014; Jacobus and Druckenmiller 2013). 

Pleistocene vertebrate fossils are known from exposures on the Yukon River (Lindsey 1986), from the 

Kuskowkim River (Reuther et al. 2014), from the Kateel River (Lindsey 1986) from the Norton Bay area 

(Lindsey 1986), from the Unalakleet area (Lindsey 1986), and from placer mines in the planning area 

(Blanchard 2016). 

The University of Alaska Fairbanks Museum of the North Museum ARCTOS database houses 218 

Pleistocene vertebrate specimens from the planning area. Nearly all of these (N=213) were found by 

placer miners on State lands in Colorado Creek. The Colorado Creek material consists of the partial 

remains of two mammoths (Mammuthus sp.) as well as bones of horse (Equus sp.), steppe bison (Bison 

priscus), caribou, and wolf, with most of the material dated to between ca. 15,000 and 23,000 14C yr B.P. 

One Ice-Age bison (Bison antiquus) specimen was collected in the Ophir mining district. Two wooly 

mammoth (Mammuthus primigenius) specimens are listed as coming from Chefornak. Of two Pleistocene 

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horse specimens, one is reportedly from Shageluk, and one is from the lower Yukon. Additional oral 

reports of BSWI mining district placer deposits yielding abundant Pleistocene vertebrate specimins attest 

to the presence of Quaternary vertebrates. These reports underscore the potential for these Ice Age 

mammal remains in Quaternary deposits throughout the planning area. Because of the high potential for 

these remains to be encountered, field surveys, site inspections, and monitoring should be done as 

possible at placer mines and other areas where Quaternary vertebrates may be exposed. 

2.11.5 Resource Changes: Trends and Forecasts 

The current management trend for paleontological resources in the planning area is toward continued 

scientific research and increased opportunities for environmental education and interpretive use. 

Resources farther from populated areas are relatively stabilized and are not, in large measure, adversely 

affected by human activity. However, all areas of fossil-bearing sediments are trending toward increased 

recreational use, and protection of paleontological resources is subject to the limits to the availability of 

resource staff and law enforcement monitoring. 

Based on current management practices, improved access to BLM-managed lands, and increased 

urbanization, there is the potential for paleontological resources to be illegally removed or damaged in the 

future due to increases in recreational and commercial usage, and limited law enforcement presence. 

2.12 Visual Resources Management 

2.12.1 Introduction 

This section discusses existing visual values within the planning area as defined by the BLM’s VRM 

System. 

2.12.2 Laws, Regulations, and Policy 

The Federal Land Policy and Management Act (FLPMA) establishes authority and guidance for the BLM 

to “prepare and maintain on a continuing basis an inventory of all public lands and their resource and

other values (including ... scenic values) ...” (43 U.S.C. 1711). The FLPMA, together with regulations in 

43 CFR 1600, also sets forth the requirements for the BLM to develop, maintain, and revise RMPs under 

the principles of multiple use and sustained yield. 

NEPA establishes that it is the federal government’s responsibility to “assure for all Americans safe, 

healthy, productive, and aesthetically and culturally pleasing surroundings” and to include consideration

of visual resources in environmental assessments, in land use planning decisions, and in the 

implementation of resource projects. 

BLM accomplishes its statutory responsibilities through its VRM program. The VRM program involves 

inventorying scenic values to create a baseline understanding of the existing condition, establishing 

management objectives for allowable levels of modification to the visual environment through the RMP 

process, and evaluating proposed activities to determine whether they conform to the management 

objectives. BLM policy and guidance for the VRM program is largely found in the 8400 series manuals 

and handbooks. The VRM program contains the following components: 

• Visual Resource Inventory: The Visual Resource Inventory (VRI) provides nationally 

consistent data sets that describe the existing condition and status of public land scenic values. 

The inventory approach is described in BLM Manual H-8410-1 (1986b). The inventory identifies 

the visual resources of an area by rating the following components: 

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o Scenic Quality Evaluation – A measure of the visual appeal of a tract of land 

o Sensitivity Level Analysis – A measure of the public concern for scenic quality 

o Visual Distance Zones – A measure of the landscape’s relative visibility from travel routes or 

common observation points 

Inventoried lands are placed into one of four VRI classes—Classes I and II being the most 

valued, Class III representing a moderate value, and Class IV being of least value—based on the 

three factors listed above. 

• Visual Resource Management: During the land use planning process, VRM class objectives are 

designated within the RMP. VRM class objectives describe the allowable levels of visual 

modification to the land under the implementation for the RMP. Each VRM class permits a level 

of noticeability by the public (the “casual observer” or “stakeholder”). VRM classes are

established through the RMP process and that process is described in BLM Manual H-1601-1 

(BLM 2005). The four VRM Classes are defined as follows: 

o Class I – The objective of this class is to preserve the existing character of the landscape. 

This class provides for natural ecological changes; however, it does not preclude very limited 

management activity. The level of change to the characteristic landscape should be very low 

and must not attract attention. 

o Class II – The objective of this class is to retain the existing character of the landscape. The 

level of change to the characteristic landscape should be low. Management activities may be 

seen but should not attract the attention of the casual observer. Any changes must repeat the 

basic elements of form, line, color, and texture found in the predominant natural features of 

the characteristic landscape. 

o Class III – The objective of this class is to partially retain the existing character of the 

landscape. The level of change to the characteristic landscape should be moderate. 

Management activities may attract attention but should not dominate the view of the casual 

observer. Changes should repeat the basic elements found in the predominant natural features 

of the characteristic landscape. 

o Class IV – The objective of this class is to provide for management activities that require 

major modifications of the existing character of the landscape. The level of change to the 

characteristic landscape can be high. These management activities may dominate the view 

and be the major focus of viewer attention. However, every attempt should be made to 

minimize the impact of these activities through careful location, minimal disturbance, and 

repeating the basic elements. 

During the planning process, the VRI serves as the principal consideration when making VRM decisions 

that may protect or affect the landscape character. The inventory values are considered in combination, as 

VRI class and independently (individual factors of scenic quality, sensitivity, and distance zones) when 

evaluating land use plan alternatives and making RMP decisions. Visual values coexist with other 

resource values on BLM public lands that also have management objectives that may or may not coincide 

with the protection of visual resources. Decisions on VRM class objectives should result from a 

coordinated and detailed examination of a range of alternatives that maximize the protection of visual 

values while also contemplating other resource needs and land use priorities. 

VRM class objectives are not the same as VRI classes. VRI classes assign value, while VRM class 

objectives direct management. VRM class objectives may or may not direct management levels that are 

commensurate with the VRI value. For example, it may be decided that an area inventoried as VRI 

Class II be managed as VRM Class III due to other desired resource uses or that an area inventoried as 

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VRI Class IV be managed as VRM Class III due to public preferences and other resource concerns. An 

update to the VRI does not affect established VRM classes in an active RMP. 

2.12.3 Resource Indicators 

The conditions that are established in the discussion below provide a baseline for visual resources-related 

values, which the impact analysis will be based on. The following indicators, along with qualitative 

discussions, will be used to evaluate impacts associated with management decisions in the BSWI Draft 

RMP/EIS. 

• Change in scenic quality 

• Change in visual sensitivity 

• Change in visual distance zone 

• Change in overall VRI class 

2.12.4 Current Conditions 

A visual resource inventory of the planning area was completed in March 2018 according to guidelines in 

BLM Manual Handbook H-8410-1, Visual Resource Inventory (BLM 1986b, 2018b). The scenic quality, 

sensitivity, distance zone, and resulting visual resource inventory distribution for the planning area is 

presented in Table 2.12.4-1, below, and in Maps 3.2.11-1 through 3.2.11-4 I of the BSWI Draft RMP/EIS. 

Table 2.12.4-1. Visual Resource Inventory Values within the Planning Area 

Visual Resource Inventory Component Acres Percent of Decision Area 

Scenic Quality 

A 3,178,607 4.9%1 

B 46,444,967 71.5%1 

C 15,346,944 23.6%1 

Visual Sensitivity 

High 42,024,047 64.7%1 

Moderate 12,490,370 19.2%1 

Low 10456100 16.1%1 

Visual Distance Zone 

Foreground-Middleground 14,938,502 23.0%1 

Background 4,857,647 7.5%1 

Seldom Seen 45,174,369 69.5%1 

Visual Resource Inventory Class 

VRI Class I 52,873 0.4%2 

VRI Class II 482,459 3.6%2 

VRI Class III 1,758,017 13.1%2 

VRI Class IV 11,172,455 83.0%2 

1 Percentage based on the acres surveyed in the entire planning area (64,970,518 acres) 2 Percentage based on BLM-managed land in the planning area (13,465,894 acres) 

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2.12.5 Resource Changes: Trends and Forecasts 

Because of the remoteness of the planning area, there is a low potential for change in visual resource 

values, and landscape character remains stable. BLM-managed lands also include encumbered lands that 

are selected by, but not yet conveyed to, the State of Alaska and Alaska Native corporations (referred to 

as State-selected and Native corporation-selected lands, respectively). Once conveyed, the BLM would 

not control trends for visual values of those areas. 

2.13 Lands with Wilderness Characteristics 

2.13.1 Introduction 

This section describes the laws, regulations and policies related to lands with wilderness characteristics, 

as well as the resource indicators that will be used to evaluate impacts to lands with wilderness 

characteristics. The section also includes a discussion of the current condition of lands with wilderness 

characteristics and trends in resource uses and conditions that may affect lands with wilderness 

characteristics in the future. 

2.13.2 Laws, Regulations, and Policies 

Since 1976, Section 201 of FLPMA has required the BLM to continue to maintain an inventory of all 

public lands and their resources and other values. This inventory requirement includes maintaining 

information regarding wilderness characteristics. In 2012, the BLM reaffirmed this policy to continue to 

conduct and maintain inventories regarding the presence or absence of wilderness characteristics, and to 

consider identified lands with wilderness characteristics in land use plans and when analyzing projects 

under NEPA (BLM Manual 6320-Considering Lands with Wilderness Characteristics in the BLM Land 

Use Planning Process). 

BLM-managed public lands in Alaska are subject to several ANILCA provisions, including exceptions 

for designated Wilderness in Alaska that include motorized methods of access, cabins, navigation aids, 

and temporary facilities associated with the take of fish and wildlife. 

Section 1320 of -ANILCA states that: 

Notwithstanding any other provision of law, section 603 of the Federal Land Policy and 

Management Act of 1976 shall not apply to any lands in Alaska. However, in carrying out his 

duties under section 201 and section 202 of such Act and other applicable laws, the Secretary 

may identify areas in Alaska which he determines are suitable as wilderness and may, from time 

to time, make recommendations to the Congress for inclusion of any such areas in the National 

Wilderness Preservation System, pursuant to the provisions of the Wilderness Act. In the absence 

of congressional action relating to any such recommendation of the Secretary, the Bureau of 

Land Management shall manage all such areas which are within its jurisdiction in accordance 

with the applicable land use plans and applicable provisions of law. 

The BLM must determine which lands within the planning area possess wilderness characteristics to 

consider planning for this resource. The BLM will consider whether lands identified as having wilderness 

characteristics will be managed to preserve some or all of their values with other land management tools 

(e.g., recreation management area designations, OHV designation, limitations on mining and leasing, 

VRM, travel management planning, management of recreation settings and activities, and so forth). 

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Existing Alaska policy allows for inventory of wilderness characteristics in areas that have ANILCAspecified uses occurring such as for snowmobiles, airplanes, subsistence cabins, and navigational aids. 

2.13.3 Resource Indicators 

Procedures for conducting inventories for lands with wilderness characteristics are laid out in BLM 

Manual 6310 – Conducting Wilderness Characteristics Inventory on BLM Lands (BLM 2012a). This 

manual provides guidance for areas that are not under wilderness study area designation. The inventory 

process entails the identification of wilderness inventory units, an inventory of roads and wilderness 

characteristics, and a determination of whether or not the area meets the overall criteria for wilderness 

character. Units found to possess such character are evaluated during the land use planning process to 

address future management for wilderness characteristics. Wilderness characteristics considered in this 

analysis include size (i.e., must be roadless areas larger than 5,000 acres), naturalness, and outstanding 

opportunities for solitude or a primitive and unconfined type of recreation. An area with wilderness 

characteristics may also contain other values not necessary for the determination of wilderness character; 

these are known as supplemental values. 

• Size. An area must be a roadless area of 5,000 acres of contiguous BLM-managed public lands 

or, if less than 5,000 acres, must be contiguous with BLM-managed public lands that have been 

formally determined to have wilderness or potential wilderness values (e.g., designated 

wilderness and Wilderness Study Areas [WSAs]) or any federal lands managed for the protection 

of wilderness characteristics. 

• Naturalness. Land and resources exhibit a high degree of naturalness, are affected primarily by 

the forces of nature, and are areas where the imprint of human activity is substantially 

unnoticeable. The BLM has authority to inventory, assess, and/or monitor the attributes of the 

land and resources on public lands, which, taken together, are an indication of an area’s 

naturalness. These attributes may include the presence or absence of roads and trails, fences and 

other improvements; the nature and extent of landscape modifications; and the appearance of 

naturalness to the casual observer; the presence of native vegetation communities; and the 

connectivity of habitats. 

• Outstanding opportunities for solitude or primitive and unconfined types of recreation. 

o Solitude: Visitors may have outstanding opportunities for solitude when the sights, sounds, 

and evidence of other people are rare or infrequent and where visitors can be isolated, alone, 

or secluded from others. 

o Outstanding opportunities for primitive and unconfined types of recreation: Visitors may 

have outstanding opportunities for primitive and unconfined types of recreation where the use 

of the area is through non-motorized, non-mechanical means, and where no or minimal 

developed recreation facilities are encountered. 

• Supplemental Values. The area may contain ecological, geological, or other features of 

scientific, educational, scenic, or historical value. 

Public lands may be managed to maintain these characteristics, or to minimize impacts to wilderness 

characteristics while giving priority to other resources/uses. Public lands possessing the above values may 

be managed to maintain some or all of those characteristics. Wilderness characteristics such as solitude, 

primitive recreation, and naturalness are a part of the land use planning process and will be evaluated and 

addressed along with all other resource values and uses. The BLM is authorized to consider this 

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information when developing the affected environment section and the range of alternatives, or to analyze 

the environmental impacts to other resources. 

In general, wilderness characteristics conditions tend to be more qualitative in nature, measured by the 

overall visual quality and naturalness of an area that may be affected by changes to levels of recreational 

activities, development, and surrounding land use. Indicators that can quantitatively be measured include 

changes to the frequency and number of routes, including the number of unauthorized trails, the number 

of encounters with other users, and increased requests for use of areas with wilderness characteristics for 

renewable or non-renewable resource development. 

2.13.4 Resource Indicators 

The conditions that are established in the discussions below provide a baseline for land with wilderness 

characteristics-related values, which the impact analysis will be based on. The following indicators, along 

with qualitative discussions, will be used to evaluate impacts associated with management decisions in 

the BSWI Draft RMP/EIS. 

• Acres of lands with wilderness characteristics not managed to protect wilderness character as a 

priority 

• Acres of lands with wilderness characteristics land managed as VRM Class III and IV 

• Acres of lands with wilderness characteristics that would be open to mineral location and entry in 

areas of medium or high potential 

• Acres of lands with wilderness characteristics that would be open to ROW authorizations 

• Acres of lands with wilderness characteristics that would be proposed for disposal 

• Acres of lands with wilderness characteristics that would be open to grazing 

2.13.5 Current Conditions 

Previous planning documents did not provide special management for areas with wilderness 

characteristics. During this RMP planning process, the BLM completed a comprehensive review of BLMmanaged public lands within the planning area to determine whether they possess wilderness 

characteristics. Results are documented in the BSWI RMP Wilderness Characteristics Inventory Report 

(BLM 2018b). This document is a comprehensive evaluation of wilderness characteristics on BLMmanaged public lands in the planning area, as directed by Section 603 of FLPMA. 

The total acreage of BLM-managed public lands in the planning area is 13,466,118 acres. A total of 

13,373,454 acres met the size criteria of at least 5,000 continuous acres. All lands that met the size criteria 

were also found to contain naturalness, due to the fact that there are substantially unnoticeable humanmade features throughout the areas. It has also been determined from the inventory that all areas that met 

the size criteria were found to possess outstanding opportunities for solitude or a primitive and 

unconfined type of recreation. The total percentage of lands that contain wilderness characteristics within 

the planning area is 99.3 percent (BSWI Draft RMP/EIS, Map 3.2.12-1). A summary of inventory 

findings for the entire planning area is presented in Table 2.13.5-1. 

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Table 2.13.5-1. Summary of Findings for Lands with Wilderness Characteristics for Planning Area 

Total Acres BLMManaged Public Lands Total Acres That Meet 

Size Criteria 

Total Acres That Meet 

Criteria For Lands With 

Wilderness 

Characteristics 

Total Acres That Did Not 

Meet Criteria For Lands 

With Wilderness 

Characteristics 

13,466,118 13,373,454 13,373,454 69,828 

Source: BLM 2018b 

Notes: Lake Minchumina was in the original inventory but is not a parcel of BLM-managed lands identified in the 2016-08-31 GIS data, resulting in an 

overage in acres and percentage reporting. This data issue may be resolved in a future version of BLM-managed lands data. As a result, 13,466,118 

acres is reported here for BLM-managed lands, instead of 13,465,894 acres, which is consistent with other sections. 

The original inventory was performed on an earlier version of the BLM-managed lands GIS data. The inventory acreages have been updated to match 

the BLM-managed lands current as of 2016-08-31 and are constrained to the quality of the data. Since the update, some BLM-managed lands were 

discovered that were not a part of the original inventory. These have been categorized as “Not Inventoried.”

The planning area was broken up into seven inventory subunits (North Nulato Hills, South Nulato Hills, 

Yukon River Lowlands, Kuskokwim Mountains, Tanana-Kuskokwim Lowlands, Lime Hills, and Ahklun 

Mountains) based on ecoregions. Findings from the BLM Wilderness Characteristics Inventory by 

subunit are summarized in Table 2.13.5-2. 

Table 2.13.5-2. Subunits Inventoried for Wilderness Characteristics 

Subunit 

Inventory Area Unit Identifier(s) Ecoregion 

Inventoried 

Acres 

Acres With 

Wilderness 

Characteristics 

Acres Without 

Wilderness 

Characteristics 

N. Nulato Hills AK-010-2 N. Nulato Hills 3,550,709 3,550,709 0 

S. Nulato Hills AK-010-1, 3, 4, 5, 6, 7, 

50, 51, 52, 53, 54, 55, 

56, 57 

S. Nulato Hills 3,849,056 3,832,852 16,204 

Yukon River 

Lowlands 

AK-010-8, 9, 10, 11, 12, 

13, 14,15, 47, 49, 58 

Yukon R. 

Lowlands 

244,748 237,642 7,107 

Kuskokwim AK-010-16 to AK-010-26, Kuskokwim 2,927,704 2,923,563 4,141 

Mountains AK-010-39, AK-010-48, 

AK-010-59, AK-010-60, 

AK-010-80 

Mountains 

Tanana- AK-010-27, 28, 29, 30, Tanana- 1,661,483 1,622,275 39,208 

Kuskokwim 31, 32, 33, 34, 35, 36, Kuskokwim 

Lowlands 37, 38, 61, 62, 63, 64, 

65, 66, 67, 68, 69, 70, 

71, 72, 73, 74, 75, 76, 

77, 78,79 

Lowlands 

Lime Hills AK-010-44, 45, 46 Lime Hills 971,020 971,020 0 

Ahklun 

Mountains AK-010-40, 41, 42, 43 Ahklun Mountains 

238,561 235,393 3,168 

Totals 13,443,281 13,373,454 69,828 

Source: BLM 2018b 

Note: The original inventory was performed on an earlier version of the BLM-managed lands GIS data. The inventory acreages have been updated to 

match the BLM-managed lands current as of 2016-08-31 and are constrained to the quality of the data. Since the update, some BLM-managed lands 

were discovered that were not a part of the original inventory. These have been categorized as “Not Inventoried.”

The BLM will continue to conduct wilderness characteristics inventories (and update as applicable) under 

current policy and the direction of Section 201 of FLPMA. The BLM will also consider protection of and 

analyze impacts to this resource through the land use planning and NEPA process. However, ANILCA 

section 1320 exempts BLM lands in Alaska from FLPMA Section 603 but does authorizes BLM to 

conduct wilderness studies periodically. Therefore, under both ANILCA and current policy, the BLM will 

not complete formal wilderness studies as outlined in Section 603 of FLPMA and the BLM will not 

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designate any new or additional wilderness study areas, nor make recommendations to Congress 

regarding wilderness suitability. Per current policy, the BLM will continue to conduct wilderness 

character review on public lands. FLPMA requires the continued inventory of public lands for potential 

wilderness characteristics even though there is no authority to establish new WSAs, should any be found. 

According to BLM RMP guidance found in 43 CFR 1610, BLM RMPs and amendments must be 

consistent, to the extent practical, with officially approved or adopted resource-related plans of State and 

local governments, other federal agencies, and tribal governments so long as the guidance and RMPs are 

also consistent. Because there is no current management direction for wilderness characteristics on BLMmanaged public lands within the planning area, there is no basis to determine consistency of BLM 

wilderness characteristics with neighboring land owners. Therefore, consistency will be accomplished in 

the RMP by incorporating the wilderness characteristics policies, programs, and provisions of public land 

laws and regulations as directed by the BLM RMP guidance found in 43 CFR 1610.3-2 (b). 

2.13.6 Resource Changes: Trends and Forecasts 

The types of permitted and unpermitted/dispersed recreation activities within the planning area include 

dog sledding, big game guide-outfitting, hunting, snowmobiling, human endurance events, fishing, 

boating, camping, hiking, wildlife viewing, OHV use, photography, and commercial filming. 

The continued popularity of all-terrain vehicles and utility terrain vehicles in the past decades has led to 

an increase in OHV casual and subsistence use on public lands that can impact the naturalness and 

solitude of previously undisturbed areas (ADNR 2016; BLM 2015a). Improvements in OHV technology 

have led to vehicles traveling faster and farther onto public lands. This type of access can potentially 

further affect the existing primitive and naturalness of BLM-managed public lands found within the 

planning area, particularly those public lands located near communities within the planning area. Terrain 

limitations in the planning area have made the use of OHVs difficult and their use is not widespread, but 

generally limited to areas near villages and long-established airplane landing strips. 

Recent interest in bringing high-speed Internet access and wireless telephone communications to various 

regions of western Alaska has led to the development of communication towers and associated facilities. 

Some of these communication sites have already been constructed and several more are planned within 

the next few years, involving remote sections of public lands within the planning area, which can affect 

the availability of natural areas that provide solitude or unconfined recreation opportunities. 

There has also been an increase in interest by small and large production companies in commercial 

filming operations at locations within the planning area. Examples of recent filming activities include The 

Discovery Channel and the Iditarod Trail Sled Dog Race and television hunting programs involving big 

game hunting. 

Evidence of climate change trends affecting wilderness characteristics have not been documented in the 

planning area. The warming trend experienced over the last 50 years has not been shown to be a cause in 

altering the quality of wilderness character in any regions of the planning area, considering the 

characteristics of lands with wilderness characteristics as defined. 

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Section 3. Resource Uses 

3.1 Forestry and Woodland Products 

3.1.1 Introduction 

This section discusses the regulations of harvest and current conditions for forest and woodland products, 

including but not limited to firewood, biomass, house logs, saw logs, berries, and mushrooms for personal 

or commercial use. Vegetation types are discussed in detail in Section 2.6, Vegetation. 

3.1.2 Laws, Regulations, and Policies 

The BLM’s Forest and Woodland products program is guided at the national level by 43 CFR 5000. 

Timber sales are managed under CFR 5400, and free use timber is managed under CFR 5510. Several 

regulations promote improvement of forest health, including 2003 Healthy Forests Restoration Act and 

the Protection Act of September 20, 1922 (16 U.S.C. 594), which allows for the protection of timber from 

fire, disease, or insects. In addition, direction is provided in Section 11 of the Act of May 14, 1898, which 

was first instituted to promote cutting and use of timber in Alaska by settlers, residents, miners (16 U.S.C. 

607a). Today, AS 41.17 (Forest Resources and Practices Act), promotes the sustainable use of forest 

products. 

The BLM responds to requests for forest products through the established permitting system to provide 

sustained yield of forest products and vegetative materials. The authorities and policies for the sale of 

forest products from BLM-managed public lands are outlined in BLM Manuals in the 5000 and 9000 

series. 

Forest products, including berries, firewood, and other products represent an important resource for area 

communities. Stewardship contracting is managed under the Agricultural Act of 2014 Section 820516 

U.S.C 6591. Stewardship contracting includes natural resource management practices seeking to promote 

a closer working relationship with local communities in a broad range of activities that improve land 

conditions. These projects shift the focus of federal forest management towards a desired future resource 

condition. They are also a means for federal agencies to contribute to the development of sustainable rural 

communities, restore and maintain healthy forest ecosystems, and provide a continuing source of local 

income and employment. Subsistence continues to represent a significant portion of forest and wood 

product use in the planning area. Details of the BLM’s Alaska Forest Policy for subsistence wood permits 

are currently outlined in IM AK2012-012 Subsistence wood harvests. 

3.1.3 Resource Indicators 

The conditions that are established in the discussions below provide a baseline for forest and woodland 

products-related values, which the impact analysis will be based on. The following indicators, along with 

qualitative discussions will be used to evaluate impacts associated with management decisions in the 

BSWI Draft RMP/EIS. 

• Acres that are available and accessible for commercial woodland harvest 

• Acres that are available and accessible for subsistence and casual use gathering 

• Changes to vegetation cover type for species with commercial or subsistence use value 

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Section 3. Resource Uses Appendix M: BSWI Affected Environment Report 

3.1.4 Current Conditions 

It is estimated that 25 percent of Interior Alaska is covered by non-commercial forest and 7 percent has 

commercial forest (i.e., forest capable of producing a minimum of 20 cubic feet of industrial wood per 

acre annually) (BLM 2015a). The tree species with potential commercial value for manufactured wood 

products in Interior Alaska are: white spruce (Picea glauca), paper birch (Betula neoalaskana), aspen, 

and balsam poplar. Most stands of commercial forest are mixtures of the different species. Productivity of 

these forests is low to moderate, with average annual production ranging from 3 to 18 cubic feet per acre 

(BLM 2015a). Historically, limited forest inventory data has been available to quantify the extent of 

commercial timber. However, recently completed inventories have provided forestry data for a portion of 

the planning area (see BSWI Draft RMP/EIS, Map 3.3.1-1). Spruce beetle (Dendroctonus rufipennis) 

infestations were documented in the late 1990s and early 2000s, and impacted forest cover primarily in 

the Kenai Peninsula (ADNR 2018; USDA 2018). Current and prior outbreaks have been attributed to 

warming winters that allow the species to overwinter increasing population size. Prior outbreaks resulted 

in an increase in the firewood industry from the increase in product resources from diseased trees. Current 

outbreaks would be expected to have similar effects on forest resources. 

Subsistence 

The forest resources within the planning area have provided the essentials of life, food, heat, and shelter 

since the time of first human habitation. Indigenous peoples have been using the natural forest resources 

in their surroundings to meet their subsistence needs for centuries. In the planning area, as is true for 

Alaska’s vast rural areas, these uses are passed on through traditions and informal institutions that survive 

today in the subsistence way of life. These practices are not static, but rather change over time, 

continually adapting to the changing social, economic and ecological conditions of the time. 

Forest resources used by area residents [ANILCA’s subsistence provisions apply according to location of

residence not Alaska Native status] have included: roots, seeds, cones, mosses, mushrooms, edibles, 

medicinals, feed, forage, floral, boughs, transplants, ornamentals, burls, saplings, branches, logs, and 

timbers. The majority of subsistence activity throughout the planning area has been the harvesting of 

wood for fuel and shelter construction, as well as building materials for fish-drying racks, fish wheels, 

smoke houses, sweat houses and dog sleds. Firewood (driftwood) has also been collected along the coast 

and along inland rivers. Berries provide a major staple for the subsistence diet in many communities. 

Most forest products used for subsistence have come from State- and Native-selected lands near the 

communities along the major waterways. These lands are more accessible and provide a higher quality 

forest product than most BLM-managed public lands. Because these lands have now been conveyed, less 

subsistence gathering occurs on BLM-managed public lands (see Section 3.5, Lands and Realty, for more 

information on land conveyance). 

In the planning area, all forest lands are currently open to subsistence harvest except crucial wildlife 

habitat and the eight RNAs within the CYRMP decision area. Free-use permits are not currently issued 

for subsistence use in the planning area. Location and level of use are impacted by accessibility. 

Forest products will likely continue to be harvested from productive lands nearest to those communities 

under conveyance to ANCSA village corporations. While the quantity of unregulated harvest is unknown, 

it would be reasonable to assume that it is at least equivalent and very likely much greater than the 

amount harvested under permit (BLM 2015a). 

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Appendix M: BSWI Affected Environment Report Section 3. Resource Uses 

Commercial 

Since the advent of small portable sawmills and the demand for milled lumber products in communities 

throughout rural Alaska, many sawmills have been purchased and transported for local use. Several small 

portable sawmills are still located in communities within the planning area and have intermittently 

produced rough lumber to satisfy the small local demand. Between 1965 and 1968, 19 sales containing 

897 thousand board-feet of timber (MBF) occurred in the Kuskokwim drainage (BLM 2015a). During 

this same period, 14 free-use permits containing 83 MBF were issued in this area. Shortly afterwards, a 

sale of 311 MBF of white spruce located about 18 miles above Stony River was made by the BLM with a 

local sawmill operator (Hegg and Sieverding 1979). Nelson Brothers Enterprises, located in the 

community of Chuathbaluk on the Kuskokwim River, operated a small commercial sawmill serving the 

local and downriver markets for rough-milled lumber from the 1970s until around 2007. The Chuathbaluk 

mill was capable of producing a variety of products but relied on air drying to season the lumber and did 

not have the capacity to grade lumber for construction certification. In 2017, this mill was purchased by 

the village of Napaimute and moved to a site just west of Lower Kalskag to be reassembled and restarted. 

It is anticipated that wood for this operation may come from as far away as Stony River and has the 

potential to include timber from BLM-managed lands. 

As for subsistence use, all forest lands are currently open to commercial harvest except crucial wildlife 

habitat and the eight RNAs within the Central Yukon RMP decision area. Location and level of use are 

impacted by accessibility and commercial vegetation type availability. There have been limited 

commercial timber requests over the past 10 years. In 2013, the village of Napaimute requested a timber 

sale from BLM, but later decided to postpone the purchase until more accessible wood had been removed. 

The village has a 1,000 cord per year contract to deliver firewood to Bethel to pay for their wood 

harvesting machinery. With the purchase and restart of the sawmill, Napaimute Logging intends to begin 

delivering house packages as well as firewood further west in the basin. 

3.1.5 Resource Changes: Trends and Forecasts 

The BLM will continue to permit the harvest of forest products under sustained yields. Limited forest 

inventory information and lack of access remain significant challenges. Demand for firewood and berries 

is likely to remain high in local communities. Overall, demand for other forest resources would remain 

low. To the extent that the State’s “Roads to Resources” program provides improved access, demand for 

small commercial sales for firewood, biomass, or local building use may increase slightly. In addition, 

local capacity to harvest larger quantities of forest products with mechanized equipment has recently been 

improved with the acquisition of a mechanical harvester/processor in the Kuskokwim Basin. 

The greatest potential for wood utilization and forest management on BLM-managed lands in remote 

Alaska is biomass. All types of forest stands could be utilized for biomass. The opportunity lies mostly in 

community-based systems that would provide combined heat and power for one or more large structures 

within a village. Wood for these systems will come from many sources, of which BLM-managed lands 

are one component. This material may be salvaged from beetle kill or fire activities, forest thinning, or 

regular harvesting operations. There is currently more potential than demand for biomass but with rising 

fossil fuels costs and high unemployment in villages there is a potential for biomass to fill a multifaceted 

need. There may be opportunities to create plantations of cottonwood, willows or other fast-growing 

species on selected sites to provide readily available materials at a known cost. Most remote villages are 

surrounded by Native corporation, village, State, or federal lands with very minimal private lands. 

Although BLM-managed public lands may not be the most accessible lands to a village for biomass use, 

there have been inquiries as to the availability of wood from these lands for biomass. BLM-managed 

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public lands are expected to play some role in the long-term biomass market within the planning area, 

including in opportunities for involvement at the feasibility discussion level, in long term stewardship 

contracts, and in assisting communities with the steps required to bring this material on line. BLM will be 

actively involved with the Alaska Energy Authority (AEA), the Alaska Wood Energy Task Force, 

regional corporations and local villages to support biomass utilization. The following 13 communities 

within the planning area have considered biomass heating projects within the past 4 years: 

• Koyukuk 

• Grayling 

• Anvik 

• Holy Cross Village 

• Lower Kalskag 

• Upper Kalskag 

• Aniak 

• Georgetown 

• Sleetmute 

• Stony River 

• McGrath 

• Unalakleet 

• Napaimute 

The development of biomass facilities within the planning area and the availability of river transport on 

both the Yukon and Kuskokwim Rivers may result in increased demand for use of BLM forest products 

for biomass use. However, other factors remain unresolved (e.g., small-diameter logs, high defect rates, 

infrastructure deficiencies, and long distances to significant markets). Currently, there is no large-scale 

global demand for wood fiber to attract industry to the boreal regions for large-scale development. 

As home heating fuel oil prices remain high throughout the planning area, the demand for woodgenerated heat in the form of firewood will remain high. Subsistence use is likely to continue to be the 

primary use in the area, while biomass for wood energy is one of the few opportunities for future 

development opportunities of the forest in the planning area, as discussed above. 

Climate change is expected to affect timber and other woodland products through further increases in 

wildfire and potential changes in hydrologic function due to permafrost thawing. Increases in insect 

outbreaks may also occur, as seen in the continental US, but specific projections of insect outbreaks are 

difficult to develop, and there is inconsistent research on how climate change will affect insect outbreaks 

in the planning area. Warmer winter temperatures may make transportation and access to timber harvest 

sites more difficult. 

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Appendix M: BSWI Affected Environment Report Section 3. Resource Uses 

3.2 Grazing 

3.2.1 Introduction 

The BLM manages livestock grazing through permits and leases issued by BLM to public land ranches. 

Livestock grazing species identified in most BLM RMPs include cattle, sheep, horses, mules, goats, pigs, 

and turkeys. Potential grazing species in the planning area also include domesticated bison, musk ox, elk 

and reindeer. Although it is not known if domestic sheep or goats currently graze on BLM-managed lands 

in the planning area, BLM has recently established policy for the management of domestic sheep and 

goats (BLM 2016d). 

3.2.2 Laws, Regulations, and Policies 

The 1927 Alaska Livestock Grazing Act (43 U.S.C 316) allowed the government to lease grazing 

privileges on the grazing districts established in Alaska to qualified applicants under 43 CFR 4200. 

However, BLM Final Rule 63 FR 51853 (1998) removed 43 CFR 4200 after deeming it obsolete and 

unnecessary due to lack of public interest. BLM still has the authority to issue grazing permits in 

accordance with the provisions of the statute, pending future development of regulations. The 1937 

Reindeer Industry Act (25 U.S.C 500) further defined and directed the management of the reindeer 

industry and removed authority to issue leases for reindeer grazing under the 1927 Act. This Act was 

passed as a means to provide subsistence for Alaska Natives through a self-sustaining reindeer industry. 

BLM Final Rule 63 FR 55548 (1998) revisited regulations to provide for the administration of permits for 

grazing reindeer in Alaska under 43 CFR 4300. Reindeer grazing on BLM-managed public lands is 

currently regulated by 43 CFR 4300 and the 1937 Reindeer Industry Act. 

For slaughtering and selling to nationwide markets, current regulations state that reindeer meat must come 

from a USDA-inspected slaughtering and processing plant. However, reindeer meat in Alaska has 

exceptions to this rule under Alaska State Regulation 18 AAC 31.820. This exception allows reindeer 

meat to be sold to local markets if: (1) it is processed under State inspection in a State-approved slaughter 

facility; or (2) slaughtered and dressed outdoors at temperatures ≤ 32 degrees F with adequate snow 

cover, carcasses are covered prior to moving, carcasses are frozen immediately after slaughter, and are 

visibly clean (18 AAC 31.820). 

3.2.3 Resource Indicators 

The conditions that are established in the discussions below provide a baseline for grazing resourcerelated values, which the impact analysis will be based on. The following indicators, along with 

qualitative discussions, will be used to evaluate impacts associated with management decisions in the 

BSWI Draft RMP/EIS: 

• Acres open to grazing; acres open to grazing that are considered suitable habitat. 

• Travel management decisions or permitted disturbance to vegetation can be considered 

qualitatively. 

• Suitable grazing habitat acres and percent in areas open to grazing. 

3.2.4 Current Conditions 

Alaska reindeer, also known as Chukotkan reindeer, are simply domesticated Caribou that exist as 

different subspecies. These reindeer were introduced to Alaska on the Seward Peninsula from Russia in 

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Section 3. Resource Uses Appendix M: BSWI Affected Environment Report 

1891 in order to provide Alaska Natives an animal production system providing predictable red meat 

supply and economic development (Stern et al. 1980). Through domestication and selective breeding, 

reindeer and caribou have unique physical and behavioral differences. For example, while both 

subspecies exhibit seasonal grazing patterns, reindeer movements remain mostly within a well-established 

home range (UAF RRP 2016). 

Reindeer grazing within the planning area is known to have historically occurred; however, locations and 

extent of the operations are not well known. There are several reindeer herds located outside of BLMmanaged public land in the St. Michaels and Stebbins vicinity. An existing reindeer herd in the St. 

Michael and Stebbins area is estimated to be approximately 6,000 head and grazes primarily on Native 

corporation land. Reindeer grazing is common in areas adjacent to the planning area on the Seward 

Peninsula, and on St. Lawrence and Nunivak islands. 

Typically, the only fencing involved with reindeer grazing is that for corralling structures; otherwise, the 

reindeer are normally free roaming, moved by herders on foot or with aircraft and OHVs. It is not known 

if there are any unauthorized reindeer grazing operations in the planning area. 

The only currently permitted grazing range in the planning area is for reindeer in a northern portion of the 

planning area in the Sagoonick area (see BSWI Draft RMP/EIS, Map 3.3.2-1). However, the herd left the 

area with caribou migrations in the 1990s, and there are currently no domestic reindeer on the range. The 

Sagoonick reindeer grazing permit is still valid. 

Potential grazing use may be evaluated from a variety of spatial and data indicators. Existing GIS data on 

land cover type, land use designation, special use or protected areas, informed by existing NRCS grazing 

evaluations, may be applied to identify areas suitable for grazing use. 

Existing NRCS grazing studies include extensive studies conducted for reindeer on the Seward Peninsula, 

just north of the planning area. These reindeer feed on a variety of vegetation throughout the season. In 

the spring (April-May), lichens dominate their diet, followed by mosses, sedges, and shrubs. During June 

reindeer feed more on willows and sedges, although lichens still comprise a substantial amount. Salix, 

sedges, and lichen dominate their diet in July. Fall and winter mark a notable shift in their diet towards 

primarily lichen (Finstad 2008). 

Lichen species consumed by reindeer include Cladina rangiferina, Cladina mitis, Cladina stellaris, 

Cladina arbuscula, Cladonia uncialis, Cetraria islandica, Cetraria nivalis, and Cetraria cucullata (Pegau 

1970). These lichen species grow very slowly even under favorable conditions, approximately 5 

millimeters per year (Pegau 1970). 

Permitted grazing use may be evaluated from specific data gathered from these grazing studies to 

determine impacts to natural resources, as well as rangeland health assessments developed by NRCS and 

BLM. Along with spatial data on existing grazing use locations and current travel use (such as OHV 

travel mileage), assessments may be made to guide management of continued or future grazing resource 

use. The impacts of climate change may have indirect or direct impacts on resources tied to grazing use, 

such as impacts of changes in wildland fire frequency, location, timing, or severity; acres of permafrost or 

snow and ice cover change; or changes in vegetation community composition or increases in NNIS. 

Future monitoring may include more comprehensive coverage of various land use types or land cover 

types that may be identified as vulnerable to change. 

Ongoing rangeland health is measured by Alaska-specific range utilization checks developed by NRCS 

and BLM: A Procedure for Evaluating Lichen Utilization on Reindeer Range (NRCS 2001). This 

procedure was originally developed in 1990, specifically for evaluating forage utilization on reindeer 

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Appendix M: BSWI Affected Environment Report Section 3. Resource Uses 

ranges in Alaska and serves as the guideline for making range utilization checks. The procedure uses the 

Alaska Grazed Class Method to measure lichen cover and lichen utilization. Monitoring, or utilization 

checks, are important for the development of grazing management plans and maintaining sustained forage 

production systems for reindeer. 

A comprehensive range survey was completed for the Seward Peninsula Reindeer Ranges in 1985 by 

NRCS. This survey was designed to provide information useful for resource management with special 

emphasis on reindeer range planning and management. However, the survey included only a small portion 

of the planning area acreage north of Unalakleet in the permitted Sagoonick reindeer grazing range. 

Between 2005 and 2014, the NRCS conducted a range survey of ecological sites in the Stebbins and St. 

Michael area, involving mostly Native corporation and USFWS lands. This survey identified prime 

reindeer grazing habitat in the Nulato Hills and surrounding area, with rich lichen resources and suitable 

seasonal habitat. These data can be used in conjunction with the recent Vegetation Map and Classification 

for Northern, Western, and Interior Alaska (Boggs et al. 2016a) as a first step in determining suitable 

grazing habitat throughout the planning area (BSWI Draft RMP/EIS, Map 3.3.2-2; see Map 3.3.2-3 for 

suitable grazing habitat range in the Stuart Range in the Stebbins and St. Michael area). Winter lichen 

ranges usually have lichen cover greater than 20 percent (NRCS 2001). 

In addition to the annual grazing monitoring through range utilization checks, BLM is involved with a 

collaborative effort for monitoring grazing exclosures on BLM-managed public lands within active 

reindeer ranges of the Seward Peninsula. These monitoring programs determine percent lichen cover and 

estimate vegetative recovery and changes in community composition (Moore 2011). No such monitoring 

currently exists in the planning area. 

3.2.5 Resource Changes: Trends and Forecasts 

Grazing is typically managed on a geographical unit extending across land manager boundaries, often 

encumbering a watershed(s) or natural land barriers and can occupy up to 1 million acres or more for a 

viable reindeer herd with seasonal habitat needs. Smaller grazing ranges are feasible pending management 

objectives and strategies. 

Due to range health and limited grazing capacity of St. Michael and Stebbins area lands, reindeer herd 

owners are seeking public land use for grazing opportunities. An application to graze this herd on BLMmanaged public land is being developed by the reindeer herd owners. This proposal will likely involve 

BLM-managed public lands in the planning area, south and east of the communities of Stebbins and St. 

Michael. The application process is ongoing. 

It is foreseeable that reindeer may occupy the Sagoonick permitted area when conditions are favorable. 

There is concern that domesticated reindeer may emigrate with the nearby caribou in the WACH and the 

MCH. This has occurred for decades with reindeer grazing on BLM-managed public lands on the Seward 

Peninsula, and is a possibility for reindeer in the planning area (Finstad et al. 2006). 

Future interest in reindeer grazing permits is anticipated on BLM-managed public lands as rural 

communities seek long-term and sustainable industry to support economic welfare and to preserve rural 

Alaska lifestyle, culture, and tradition. A primary reason that there are not more commercial grazing 

operations within the planning area is a lack of infrastructure to prepare and ship meat to market and 

limitations meeting USDA requirements. The lack of roads and utilities within the planning area to 

support such an operation has posed significant challenges to meeting the need. However, actions to 

address this are being developed by the University of Alaska Reindeer Research Program, with assistance 

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Section 3. Resource Uses Appendix M: BSWI Affected Environment Report 

from Kawerak Reindeer Herders Association, and the BIA and collaborative support from the Alaska 

Reindeer Council: A mobile slaughter facility prototype has been designed and in use for a couple years 

as teaching facility associated with the University of Alaska Fairbanks High Latitude Range Management 

Curriculum. The Midnite Sun Reindeer Ranch north of Nome obtained one mobile slaughter unit in 2016 

to help meet USDA requirements and sell meat to nationwide markets outside the community; they are 

fundraising for a second unit. 

3.3 Locatable and Salable Minerals 

3.3.1 Introduction 

This section describes the regulatory setting along with the baseline conditions of locatable and salable 

minerals within the planning area. Locatable minerals are minerals for which the right to explore, 

develop, and extract mineral resources is established by the staking of mining claims, as authorized under 

the General Mining Law of 1872. Examples of locatable minerals include metallic minerals (gold, silver, 

platinum, copper, lead and zinc) and non-metallic minerals such as precious stones (e.g., jade, diamonds) 

and sometimes industrial minerals (e.g., garnet, quartz sands). Salable minerals are those that may be sold 

under the Material Sale Act of 1947. The primary salable materials are sand and gravel. 

3.3.2 Laws, Regulations, and Policies 

Several agencies including the State of Alaska, BLM, and multiple Native corporations are involved in 

the management and use of locatable and salable minerals within the planning area. Specific regulations 

that these entities utilize for lease management are discussed below. 

The General Mining Act of 1872 authorizes and governs prospecting and mining for economic minerals, 

such as gold, platinum, and silver, on federal public lands. 

Surface Resources Act of 1955 is an amendment to the Act of July 31, 1947, and provides for multiple 

uses of the surface of the same tracts of public lands. 

Mining and Minerals Policy Act of 1970 declares that it is the continuing policy of the federal 

government to foster and encourage private enterprise in the development of a stable domestic minerals 

industry and the orderly and economic development of domestic mineral resources. 

FLPMA reiterates that the Mining and Minerals Policy Act of 1970 shall be implemented and directs that 

public lands be managed in a manner that recognizes the Nation’s need for domestic sources of minerals 

and other resources. 

The National Materials and Minerals Policy, Research and Development Act of 1980 requires the 

Secretary of the Interior to improve the quality of minerals data in federal land use decision-making. 

ANILCA specifically provides the State of Alaska with rights to manage all surface waterways, even 

those that cross through federal lands and maintain access to non-federal areas that may cross through 

federal lands. 

ANCSA. Some of the lands in the planning area will be affected by ANCSA due to the fact that some 

native corporation selected BLM managed lands have current special protections status or subsurface 

rights that may be retained after ownership is transferred. 

Domestic Minerals Program Extension Act of 1953 states that each department and agency of the 

federal government charged with responsibilities concerning the discovery, development, production, and 

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Appendix M: BSWI Affected Environment Report Section 3. Resource Uses 

acquisition of strategic or essential minerals and metals shall undertake to decrease further, and to 

eliminate where possible, the dependency of the United States on overseas sources of supply of each such 

material. 

APDES. Wastewater discharge from mining and activities relating to development of resources or 

industrial activity are governed and enforced according to Senate Bill 110, August 2005 authorization. 

The Anadromous Fish Act (AS 16.05.871- .901) requires that an individual or government agency 

provide prior notification and obtain permit approval from ADF&G before altering or affecting “the 

natural flow or bed” of a specified waterbody, or fish stream. All activities within or across a specified 

anadromous waterbody require approval from the Division of Habitat, including construction; road 

crossings; gravel removal; mining; water withdrawals; the use of vehicles or equipment in the waterway; 

stream realignment or diversion; bank stabilization; blasting; and the placement, excavation, deposition, 

or removal of any material. 

The Fishway Act (or Fish Passage Act AS 16.05.841) requires that an individual or government agency 

notify and obtain authorization from the ADF&G, Division of Habitat for activities within or across a 

stream used by fish if it is determined that such uses or activities could represent an impediment to the 

efficient passage of resident or anadromous fish. 

Alaska Dam Safety Act. Development that require dams for impoundment of water or tailings fall under 

the jurisdiction of both Alaska Statue 46.17,900 and AAC Title 11, Part 6, Chapter 93, Article 3, Alaska 

Dam Safety, which dictate safe construction and operation of all dams within Alaska regardless of land 

ownership status. 

Title 43 CFR. These include a number of regulations pertinent to locatable and salable minerals, 

including: 

• 3600 - Mineral Materials Disposal 

• 3710 - Public Law 167; Act of July 23, 1955 

• 3800 - Mining Claims Under the General Mining Laws 

BLM Handbooks. A number of BLM policy handbooks have been created to guide regulation of 

locatable and salable minerals on BLM-managed public lands. These include: 

• BLM Handbook H-3600-1, Mineral Materials Disposal Handbook 

• BLM Handbook H-3809-1, Surface Management 

• BLM Handbook H-3830-1, Administration of Mining Claims, Mill Sites, and Tunnel Sites 

• BLM Handbook H-3890-3, Validity Mineral Reports 

3.3.3 Resource Indicators 

The conditions that are established in the discussions below provide a baseline for locatable and salable 

minerals-related values, which the impact analysis will be based on. The following indicators, along with 

qualitative discussions, will be used to evaluate impacts associated with management decisions in the 

BSWI Draft RMP/EIS. 

• Acres of land or river miles withdrawn from the total number of acres or river miles of locatable 

minerals identified in the planning area, when available 

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• Acres of land or river miles of salable minerals in the planning area closed to development, when 

available 

• Number of operations able to maintain compliance without the assistance of the Alaska Statewide 

Bond Pool for reclamation 

3.3.4 Current Conditions 

Physiography 

The physiography of the planning area is broken up into 12 specific regions described in detail in 

Section 2.3, Soils. 

Locatable Minerals 

Distribution of locatable mineral occurrences within the planning area is illustrated in BSWI Draft 

RMP/EIS, Map 3.3.3-1, and is generally concentrated in the upland areas of the planning area and 

lowlands in the immediate vicinity of these uplands where placer deposits occur. 

The most current report used to detail mineral occurrences within the planning area for this document is 

the Mineral Occurrence and Development Potential Report - Locatable and Salable Minerals Bering SeaWestern Interior Resource Management Plan (Kurtak et al. 2010). 

History and Development 

The planning area includes all or portions of 11 mining districts (BSWI Draft RMP/EIS, Map 3.3.3-2) as 

established by Ransome and Kerns (1954). The Ophir, Akiak, and Iditarod districts are classified as some 

of Alaska’s major gold producing areas. The planning area contains 453 documented mineral occurrences 

(BSWI Draft RMP/EIS, Map 3.3.3-1) and 2,480 mining claims, with 207 of those under federal 

management. This includes placer gold, gold-bearing quartz veins, copper-gold skarns, and silicacarbonate mercury deposits. As of December 2016, there are four active placer mines, one active lode 

mine, and two temporary placer mine closures on BLM-managed public lands in the planning area. The 

number of active and temporarily closed mines changes annually. Documented mineral production in the 

planning area totals 3.2 million oz. gold, 151,750 oz. silver, and 2.1 million pounds of copper and 41,767 

flasks of mercury. The international unit of measurement of elemental mercury is a flask, which weighs 

34.5 kg or 76 pounds (USGS 2003). This translates to approximately 3.17 million pounds of elemental 

mercury. 

The history of placer mining within the planning area is dominated by gold mining and began as early as 

1889 with reports of prospectors working in the Kuskokwim River basin near Aniak; however, the first 

significant discovery of gold took place in 1906 resulting in establishment of the community of Ophir. 

The first placer discoveries in the Iditarod District were made in 1908 resulting in one of the last major 

gold rushes in Alaska and establishment of the towns of Flat and Iditarod. Gold was found on the 

Tuluksak River Drainage in 1907 and resulted in one of the longest continuous paystreaks in the planning 

area. Many of these areas have continued to have placer mining activities through the present time; 

however, at this time there is little interest in staking claims on unencumbered BLM-managed public land 

and there are no currently permitted placer mining operations on these unencumbered BLM lands. The 

BLM does manage three active placer operations on BLM-managed mining claims that were excluded 

from Native and State land conveyances under ANILCA. 

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Historic lode mining in the planning area has focused predominantly on gold, copper, and mercury. Lode 

mining on BLM-managed lands within the planning area has been minimal. However, the BLM manages 

the only lode mine, Nixon Fork Mine, in the planning area. This lode mine operates on BLM lode claims 

that were excluded from Native and State land conveyances under ANILCA. 

Though there has been no historic mining of Rare Earth Elements (REEs), there is future potential for 

development of this resource in the planning area; however, little of this would occur on BLM-managed 

public lands because most occurrences are not on BLM lands. 

Areas of high locatable mineral potential (LMP) have been identified within the planning area (BSWI 

Draft RMP/EIS, Map 3.3.3-3). The mineral potential score is composed of the number and quality of 

mineral occurrences and claims located within the section and the intersection of areas designated as 

being significant to mineral potential. A total of 101 areas have been designated as high LMP including 

several areas that fall within BLM managed lands and are covered by federal mining claims (Kurtak et al. 

2010). These include the Nixon Fork Mine area, Flat-Chicken Mountain area, the Ophir Creek drainage 

(Kilbuck Mountains), and the NYAC (Shamrock Creek) area. Additional areas of interest include the high 

LMP areas on State-selected lands near Little Creek, Oskawalik, Julian Creek, and the Granite-Willow 

Creek areas. 

Current and future mineral exploration and development of locatable mineral resources within the 

planning area could have impacts on BLM-managed public lands; however, the potential for development 

on BLM lands is considered low due to a relative lack of high LMP resources. Exploration and mining on 

non-BLM managed high LMP areas adjacent to BLM lands will necessitate management to prevent 

unnecessary disturbance to BLM-managed public lands by ROW corridors, roads and development on 

these adjacent high LMP lands. 

The Alaska Division of Geological & Geophysical Surveys, in the 2014 Mineral Industry Report 70, lists 

12 separate companies or individuals (11 open pit placers and one hard rock mine) that are estimated to be 

producing metals (predominantly gold) in the planning area in 2014 (Freeman et al. 2015). Additionally, 

the Donlin Gold Mine near Crooked Creek is an advanced stage exploration project that is currently 

seeking permit approval for initial mine startup. 

Placer Gold 

Placer deposits within the planning area (BSWI Draft RMP/EIS, Map 3.3.3-4) have historically been the 

most productive and the main deposit type mined in the area. Placer gold is the main commodity 

produced along with lesser amounts of PGE, cinnabar, and scheelite. The planning area contains 162 

placer gold occurrences. Records show production from 90 of these placers. Some of the deposits were 

rich, such as Flat Creek in the Iditarod District, which produced over 650,000 oz. of gold. Source rocks 

for most of the placers include Cretaceous-aged volcanic-plutonic and felsic dike complexes. These 

roughly parallel the trend of the Iditarod-Nixon Fork fault in a northeast-southwest trend through the heart 

of the planning area. 

Currently eleven operators are producing gold from placer operations within the planning area and three 

mines are in temporary shutdown status. However, none of these are operating on BLM-managed land, 

and either operate wholly on private lands or within historic in-holdings on BLM-managed public lands 

(Whitlock 2016). 

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Lode Minerals 

Lode mining potential in the planning area is focused predominantly on gold, copper, silver and, to a 

much lesser extent, mercury, which was mostly mined historically as it was important in the 

amalgamation process in gold mining. These lode minerals occur predominantly in quartz veins, coppergold skarns, and silica-carbonate mercury deposits located within the central and southeastern portion of 

the planning area. 

Currently the Nixon Fork Mine is the only active lode mine in the planning area, and operates on BLM 

lode claims that were excluded from Native and State land conveyances under ANILCA. 

Multiple high LMP lode mineral areas, such as the currently proposed Donlin gold deposit, Independence 

Mine, and Golden Horn Mine exist within the planning area; however, these sites and most of the 

remaining current claims and exploration areas, are located on State- or Native-owned lands. 

Rare Earth Elements 

There is currently no development or exploration targeting REEs occurring within the planning area, but 

with demand for these minerals increasing the planning area could see much more exploration and 

potential development for these resources. A total of seven REE occurrences have been identified in the 

planning area of which none are located on BLM-managed lands (Kurtak et al. 2010; Szumigala and 

Werdon 2011). Development of these resources would likely have a secondary impact on BLM-managed 

public lands due to development of adjacent property and access through BLM lands. 

Salable Minerals 

Sand and Gravel 

The primary mineral material commodities used within the planning area are crushed rock, and sand and 

gravel. A total of 13 material sites were reported to be active in 2008 in Southwest Alaska, which includes 

the planning area (USGS 2008). Sand and gravel is used in construction and road maintenance. The local 

demand for salable materials is generally being met by sand and gravel producers located on private or 

State-owned lands. This status is unlikely to change in the foreseeable future due to lack of appropriate 

BLM-managed public lands in the vicinity of population centers that require sand and gravel. 

Future demand for additional sand and gravel will be driven by development in the planning area, such as 

the proposed Donlin Gold Mine. However, because the proposed road and pipeline routes for this project 

are mostly on State- or Native-held lands, it is foreseeable that most of the sand and gravel for the 

proposed routes will be met by producers located on those lands. 

Peat 

Currently BLM-managed public land within the planning area does not have any requests to develop peat, 

and only one feasibility study on large-scale use of peat has been completed in the planning area to date. 

This study was completed for the proposed Donlin Gold Mine in the central portion of the planning area. 

It was concluded that due to inadequate drainage and pervasive permafrost that it was uneconomical to 

mine peat for energy generation. The probability that additional interest in large-scale peat mining is low, 

due to these factors and the lack of infrastructure and population density that would make peat mining 

economical. 

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Appendix M: BSWI Affected Environment Report Section 3. Resource Uses 

It is possible that villages and individuals in the planning area could develop peat as a resource for smallscale energy and heat generation. Development of this type is unlikely on BLM-managed public lands, as 

most villages in the planning area have enough land to harvest peat on their own, or on adjacent State 

lands with fewer restrictions. Additional discussion of peat resources can be found in Section 3.8, 

Renewable Energy. 

3.3.5 Resource Changes: Trends and Forecasts 

Management needs for locatable and salable resources on BLM-managed land in the planning area are 

predicted to be low in the foreseeable future based on the relatively low development potential of 

locatable minerals and the lack of demand and low economic feasibility of extracting salable materials. 

Climate change could lead to permafrost thaw, glacial retreat, and altered water availability in the 

planning area. Permafrost thaw can adversely impact mining activities and overland travel. Retreat of 

glaciers could expose additional mineral resources. Changes to water availability could impact hazardous 

materials controls at mine sites, dust abatement activities, and other mine operations. 

3.4 Leasable Minerals 

3.4.1 Introduction 

This section describes the regulatory setting and summarizes the baseline conditions for leasable 

resources located within the planning area. 

3.4.2 Laws, Regulations, and Policies 

Several agencies including the BLM, State of Alaska, and Native corporations are involved in the 

management and use of leasable minerals with the planning area. Specific regulations that these entities 

utilize for lease management are discussed below. 

Mineral Leasing Act of 1920 (MLA) authorizes and governs leasing of public lands for developing 

deposits of coal, petroleum, natural gas and other hydrocarbons, in addition to phosphates, sodium, sulfur, 

and potassium in the United States. The Federal Coal Leasing Amendments Act of 1976 (amendment 

to the MLA) requires that all public lands available for coal leasing be leased competitively. 

Mineral Leasing Act for Acquired Lands of 1947 extends the provisions of the MLA and the authority 

of the Secretary of the Interior over oil and gas operations to federal "acquired lands." 

Additional legislation also governs which lands can be leased for leasable minerals including oil and gas, 

coal, and geothermal and how they can be developed, including Energy Policy Act of 2005, Mining and 

Minerals Policy Act of 1970, the Mineral Leasing Act for Acquired Lands of 1947, Domestic Minerals 

Program Extension Act of 1953, the National Materials and Minerals Policy, and the Research and 

Development Act of 1980. 

Surface Mining Control and Reclamation Act of 1977 (SMCRA) is the primary federal law that 

regulates the environmental effects of coal mining in the U.S. SMCRA created two programs: one for 

regulating active coal mines and a second for reclaiming abandoned mine lands. It also allows the states 

to develop State-specific versions of this act, which can be tailored to State-specific conditions. In Alaska, 

this has resulted in the Alaska SMCRA, which is administered by the ADEC and is designed to address 

Alaska-specific reclamation issues. 

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Geothermal Steam Act of 1970 authorizes the Secretary of the Interior to issue leases for development 

and utilization of geothermal steam and associated geothermal resources on federal lands. 

ANILCA specifically provides the State of Alaska with rights to manage all surface waterways, even 

those that cross through federal lands and maintain access to non-federal areas that may cross through 

federal lands. 

Some of the lands in the planning area will be affected by ANCSA due to the fact that some Native 

corporation-selected BLM-managed lands have current special protections status or subsurface rights that 

may be retained after ownership is transferred. 

Title 43 CFR. These include a number of regulations pertinent to leasable minerals, including: 

• 3000 - Minerals Management: General 

• 3100 - Oil and Gas Leasing 

• 3200 - Geothermal Resource Leasing 

• 3400 - Coal Management: General 

• 3500 - Leasing of Solid Minerals Other Than Coal and Oil Shale 

There are a variety of BLM Handbooks that also specifically apply to leasable minerals, including: 

• BLM Handbook H-3070-2, Economic Evaluation of Oil and Gas Properties 

• BLM Handbook H-3073-1, Coal Evaluation 

• BLM Handbook H-3100-1, Oil and Gas Leasing Handbook 

• BLM Handbook H-3101-1, Issuance of Leases 

• BLM Handbook H-3150-1, Onshore Oil and Gas Geophysical Exploration Surface Management 

Requirements 

• BLM Handbook H-3203-1, Leasing Terms 

• BLM Handbook H-3468, Coal Inspection and Enforcement 

• BLM Manual 1624, Planning for Fluid Mineral Resources 

3.4.3 Resource Indicators 

The conditions that are established in the discussions below provide a baseline for leasable mineralsrelated values, which the impact analysis will be based on. The following indicators, along with 

qualitative discussions, will be used to evaluate impacts associated with management decisions in the 

BSWI Draft RMP/EIS. 

• Acres of State- or ANCSA corporation-selected lands 

• Acres of land or river miles in the planning area closed to leasable minerals exploration and 

development 

3.4.4 Current Conditions 

Minerals and materials designated leasable under federal law include coal, natural gas, oil, phosphate, 

sodium, and geothermal Leasable mineral potential for resources within the planning area has been 

defined as low. 

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Appendix M: BSWI Affected Environment Report Section 3. Resource Uses 

Coal 

The areas in the planning area that contain coal within the planning area have been divided into one field 

and five districts: Farewell (Little Tonzona) Coal Field, and the Windy Fork, Middle Fork, Cheeneetnuk, 

Big River, and Nelson Island Districts (BSWI Draft RMP/EIS, Map 3.3.4-1) in the planning area. The 

quality of coal is ranked by the amount of metamorphism it has undergone since burial. Coal qualities are 

divided into four classes or ranks: in decreasing order of carbon content and heat value, these are 

anthracite, bituminous coal, subbituminous coal, and lignite. Within the bituminous class, coals are 

further subdivided based on the amount of volatile matter (low, medium, and high volatiles present) and 

heat value (A, B, and C). 

The majority of the coal in the planning area is tertiary-aged and subbituminous and underlies 

approximately 200 square miles of the Farewell Field, Windy-Middle Forks, Big River, and Cheeneetnuk 

River areas. Potential coal production estimates for all five districts has been defined as low. This 

estimate is based on the low grade of the coal and the lack of infrastructure in the region. 

Coalbed Natural Gas 

Coalbed natural gas is low cost, clean burning, natural gas recovered and produced from coal beds. 

Unlike conventional gas, it is a nontraditional reservoir in the sense that the coal beds are both the source 

and reservoir for the methane gas (Tyler et al. 2000). Most coal and coal gas reservoirs (see BSWI Draft 

RMP/EIS, Map 3.3.4-1) in the planning area have low development potential due to the high initial cost 

of production and a lack of local infrastructure for storage and distribution. 

Oil and Gas 

There are seven potential oil and gas bearing basins in the planning area including the Bethel Basin, 

Galena Basin, Holitna Basin, Innoko Basin, Minchumina Basin and the Yukon Delta (BSWI Draft 

RMP/EIS, Map 3.3.4-2). 

The planning area has received limited, intermittent interest and activity in oil and gas exploration since 

the early 1960s due to poor source and reservoir potential in the Cretaceous sedimentary rocks (Kirchner 

1994). The presence of sufficiently large commercially valuable accumulations of gas is also presently 

unknown. Little additional subsurface well or seismic information has been collected in the planning area 

to date and much of the data collected remains proprietary. 

No recent federal oil and gas leasing has taken place in the planning area. Prospective oil and gas basins 

in the region of the planning area include the Holitna, Bethel, and Minchumina basins, along with the 

Yukon Delta. 

There are 59 oil and gas pending Pre-Reform Act lease offers within the planning area, all within the 

boundary of the Yukon Delta NWR and, as such, they have been suspended. No additional oil and gas 

lease offers may be filed until the land selection process that the State and various Alaska Native entities 

are undertaking is complete. 

Geothermal 

There are two confirmed geothermal springs within the planning area: Ophir Hot Springs and Chuilnuk 

Hot Springs (BSWI Draft RMP/EIS, Map 3.3.4-3). The only spring that is currently being used as a 

source of energy is the hot spring occurrence near Ophir Creek (Bundtzen and Kline 1986). Both 

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occurrences are located on private inholdings. No significant geothermal reservoirs exist elsewhere in the 

planning area. 

Phosphate, Potassium, Sodium, Sulfur, Oil Shale 

No information currently exists for oil shale, phosphate, potassium, sulfur, or sodium resources within the 

planning area. If any studies have been conducted, the data remains proprietary. 

3.4.5 Resource Changes: Trends and Forecasts 

Management needs for leasable resources in the planning area are predicted to be low in the foreseeable 

future based on the remoteness of the area, lack of infrastructure, and low development potential of the 

resources. Over time, climate change could affect the accessibility or demand for leasable resources in the 

planning area; however, the nature and extent of these impacts cannot be confidently predicted with 

currently available data. 

3.5 Lands and Realty 

3.5.1 Introduction 

This section describes the regulatory setting and baseline conditions of land ownership and land use 

authorizations in the planning area. Refer to BSWI Draft RMP/EIS, Map 1-2 for land ownership and 

parcel boundaries for the planning area. 

3.5.2 Laws, Regulations, and Policies 

The lands and realty program manages land use under the authority of multiple statutes, regulations and 

guidance, such as FLPMA, the Recreation and Public Purposes Act (R&PP), and the MLA. Land 

ownership in the planning area is influenced by three main entitlement Acts: the Native Allotment Act of 

1906 (including the Alaska Native Veteran Allotment Act of 1998), the Alaska Statehood Act, and 

ANCSA. Implementation of these land management laws also have to accommodate, and in some cases, 

defer to other land management laws, such as the Wild and Scenic Rivers Act, and the NTSA. 

The two primary objectives of the BLM’s lands and realty program are to implement the actions 

contained in the FLPMA, MLA and the R&PP, and the second is to facilitate the transfer of lands to the 

State of Alaska, ANCSA Native corporations, and individuals. Although millions of acres of land have 

been conveyed to individual Alaska Natives, Native corporations, and the State of Alaska, there is still 

land that will be conveyed out of federal ownership in the near future. 

The BLM can authorize use of public lands through: FLPMA and MLA ROW grants; FLPMA leases and 

land use permits; R&PP Act leases and/or patents, FLPMA-authorized withdrawals for benefit of federal 

agencies; and FLPMA land tenure adjustment actions such as sales, exchanges or acquisitions. BLM also 

addresses realty trespass issues that affect selected and non-selected public lands and provides support to 

other internal programs that protect or utilize resources. The BLM manages public easements reserved in 

the conveyance of lands to ANCSA corporations and manages those easements unless BLM has 

transferred the easement management to another entity. Management actions may include marking, 

relocating, termination, and acquisition of easements. 

Lands that are selected by Native corporations or the State that are within the boundaries of a 

Conservation System Unit (CSU) are managed in the interim by the federal agency that administers that 

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CSU. BLM has an adjudicative role in conveying land within CSUs held by other agencies, but not 

surface management responsibilities. 

In addition to those listed above, the lands and realty program operates in accordance with multiple laws, 

regulations, and guidance. The following laws have a significant influence on BLM lands and realty 

management in the planning area: 

Alaska Statehood Act (1958). Under the Alaska Statehood Act, the State of Alaska is entitled to receive 

104 million acres of federal land. Approximately 2.6 million acres of BLM-managed public lands in the 

planning area are State-selected. Final conveyance priority lists for State selections have been submitted 

to the BLM. At the present time the State has selected more lands than their remaining entitlement, and is 

allowed by law to over-select up to 25 percent on a statewide basis. As a result, some of the selected lands 

will remain in federal ownership over the long-term. 

Native Allotment Act (1906). The Native Allotment Act (43 U.S.C. 270–1 through 270–3, 1970) and the 

Alaska Native Veterans Allotment Act (43 U.S.C. 1629g, as amended) allow for the transfer of up to 160 

acres of land to eligible Alaska Natives if they occupied the land on August 31, 1971. These are called 

Native allotments. There are approximately 5,200 allotments within the planning area (a total of 

approximately 430,000 acres, or 0.7 percent of the planning area). There remain some Native allotment 

applications in the planning area that have not been finalized; however, no new applications can be filed. 

ANCSA (1971). ANCSA established Alaska regional and village corporations and granted them the right 

to select approximately 44 million acres of federal land in Alaska. Approximately 144,000 acres of BLMmanaged public lands in the planning area are Native-selected. Final conveyance priority lists for Native 

selections have been submitted to the BLM. At the present time, ANCSA regional and village 

corporations, as they are allowed, have selected more than what will be their ultimate entitlement under 

ANCSA. As a result, some of the selected lands will remain in federal ownership over the long-term. 

ANILCA (1980). ANILCA established and expanded national parks and preserves, national wildlife 

refuges, national conservation and recreation areas, WSRs, national monuments, and wilderness areas on 

federal lands in Alaska. The Unalakleet Wild River Corridor (located in the planning area) was 

established through ANILCA. Among other provisions, ANILCA provides for general public and 

subsistence access. 

NHPA (1966). Pursuant to the NHPA, a qualified archeologist reviews permits for land use 

authorizations and realty actions to avoid impacts to cultural resources by project redesign, project 

abandonment, and/or mitigation of adverse impacts through scientific recovery and analysis. When 

impacts to cultural resources cannot be avoided, the BLM will complete a Determination of Eligibility to 

the State Historic Preservation Officer (SHPO) to determine a site’s significance and eligibility to the 

NRHP, and follow prescribed NHPA Section 106 [54 U.S.C. 306108] consultation for all sites 

determined eligible. If a site is determined eligible, the BLM will develop a memorandum of agreement to 

mitigate the action. 

Alaska Land Transfer Acceleration Act (2004). The act represents an attempt to speed up the State 

selection process as well as finalize the regional and village corporation selections by establishing 

sequential deadlines for prioritizing selections [P.L. 108-152, 118 Stat. 3575]. It was an attempt to resolve 

the conflicting land claims of in time for the fiftieth anniversary of Alaska's statehood in 2009. 

National Wild and Scenic Rivers Act (1968). The WSR Act was established to preserve certain rivers 

with outstanding natural, cultural, and recreational values in a free-flowing condition for the enjoyment of 

present and future generations [16 U.S.C. 1271-1287]. Section 5(d)(1) of the National Wild and Scenic 

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Section 3. Resource Uses Appendix M: BSWI Affected Environment Report 

Rivers Act requires that the BLM and other federal agencies inventory streams on public lands to 

determine their eligibility and suitability to be components of the National System. 

National Trails System Act (1968). The NTSA established a network of scenic, historic, and recreation 

trails that provide for outdoor recreation needs. National historic trails are specifically designated areas in 

the U.S. containing the route of nationally and historically significant trails and areas adjacent to the trails 

to be utilized for scenic, historic, natural, cultural, or developmental purposes. 

3.5.3 Resource Indicators 

The conditions that are established in the discussions below provide a baseline for lands and realty-related 

values, which the impact analysis will be based on. The following indicators, along with qualitative 

discussions, will be used to evaluate impacts associated with management decisions in the BSWI Draft 

RMP/EIS. 

The primary indicators for lands and realty are as follows: 

• Acres of BLM-managed lands identified for acquisition, retention, or disposal 

• Acres or river miles affected by land withdrawals 

• Acres of BLM-managed surface ownership affected by ROW lease or permit restrictions (i.e., 

avoidance or exclusion areas, no surface occupancy) 

• Acres of BLM-managed lands that would be open to potential mineral entry or oil and gas 

development 

• Acres or river miles open to locatable and leasable minerals 

• Total VRM Class Acreages 

3.5.4 Current Conditions 

Land Tenure/Land Ownership 

Section 1.3.3, roughly 13.5 million acres in the 62.3 million-acre planning area are managed by the BLM, 

including approximately 10.7 million acres of BLM unencumbered lands, as well as encumbered lands 

that are selected but not yet conveyed under the Alaska Statehood Act and ANCSA. Land conveyances 

are ongoing; therefore, the BLM land status acreage frequently changes. BSWI Draft RMP/EIS, Map 1-2, 

shows the location of the planning area within the Alaska and depicts the varying ownership and 

conveyance status. 

ANCSA and ANILCA Withdrawals 

A withdrawal is a formal action that sets aside, withholds, or reserves federal lands by administrative 

order or statute for public purposes. The effect of a withdrawal is to segregate and close federal land to 

the operation of all or some of the public land laws and/or one or more mineral laws; transfer total or 

partial jurisdiction of federal land between federal agencies; or dedicate federal land for a specific federal 

purpose. 

A series of public land orders (PLOs) issued from 1972 to 1975 that placed a protective withdrawal on 

federal lands under a variety of ANCSA authorities including ANCSA 17(d)(1), which gave authority to 

withdraw land for the purpose of study and review to determine the proper classification and “to insure 

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that the public interest in these lands is properly protected.” The PLOs often cite more than one authority, 

including Sections 11 and 14 and sometimes Sections 17(d)(2) of ANCSA. 

The intent of the withdrawals based on Section 17(d)(1) was to limit appropriation of the lands to 

complete inventories of resources and assessment of values that meet public needs within the planning 

area affected by 17(d)(1) withdrawals. In the 1980s studies and assessments were completed, and opening 

orders were issued on some lands covered by ANCSA 17(d)(1). Under existing conditions, ANCSA 

17(d)(1) withdrawals cover almost all BLM-managed land in the planning area (13,461,531 acres; over 99 

percent). Table 3.5.4-1 describes some ANCSA 17(d)(1) withdrawals within the planning area (BLM 

2006). 

Table 3.5.4-1. Effect of ANCSA 17(d)(1) Withdrawals on Federal Public Lands 

PLO Description 

PLO 5170 Withdrew lands for selections by village, corporations and regional corporation in Bering Straits region and for 

classification for lands in withdrawals. Amended by PLO Nos. 5395, 5450 and 5557. 

PLO 5172 Withdrew lands for selections by village, corporations and regional corporation in Bering Straits region and for 

classification for lands in withdrawals. Amended by PLO Nos. 5395, 5450 and 5557. 

PLO 5173 Withdrew for selections by village corporations and regional corporation in Tanana region and for 

classification for lands in withdrawals. Modified and corrected by PLO No. 5191 (37 FR 6089). Amended by 

PLO Nos. 5213, 5252, 5391; amended and corrected by PLO No. 5321 (37 FR 26595). 

PLO 5174 Withdrew lands for village or regional deficiency selections under the authority of Section 11(a)(3) of ANCSA. 

Each of these PLOs contained a paragraph in which a withdrawal under Section 17(d)(1) was also placed on 

the same lands. Lands were withdrawn from selection by the State, not open to location and entry under the 

mining laws, nor leasing under the MLA. Section 906(j) of ANILCA and PLO 6092 opened most 17(d)(1) 

withdrawals to State Selections. 

PLO 5179 Withdrew approximately 80 million acres of land in aid of legislation for creating or adding to CSUs under the 

authority of Section 17(d)(2) of ANCSA, which had a termination provision. A second paragraph added a 

17(d)(1) withdrawal to the same lands and did not have a termination provision. Lands were withdrawn from 

selection by the State, not open to location and entry under the mining laws, nor leasing under the MLA. PLO 

5657 opened many lands to State Selection except in Umiat and portions of Kateel River Meridians. 

PLO 5180 Placed a 17(d)(1) withdrawal on approximately 47 million acres including the lands in the transportation and 

utility corridor withdrawn by PLO 5150. Lands were withdrawn from selection by the State, not open to 

location and entry under the mining laws (except locations for metalliferous minerals), nor leasing under the 

MLA. PLO 5180 was amended by PLO 5418, which placed a 17(d)(1) withdrawal on all unreserved land and 

any lands that may become unreserved in the future. PLO 5657 opened many lands to State Selection. 

PLO 5181 Placed a 17(d)(1) withdrawal on lands for classification and study as possible additions to the NWR System. 

Closed lands to all forms of appropriation under public land laws, including selections by the State of Alaska 

under the Alaska Statehood Act, 72 Stat. 339 and from location and entry under the mining laws and from 

leasing under the MLA. 

PLO 5184 Placed a 17(d)(1) withdrawal on lands originally withdrawn under section 11 of ANCSA for selection by the 

village corporations, and all of those lands lying between 58 degrees N. and 64 degrees N. Latitude, and 

west of 161o W. Longitude that were not withdrawn for any part of the NWR System. These areas are 

withdrawn from all forms of appropriation under public land laws, (except State Selection) and from location 

and entry under the mining laws and from leasing under the MLA. All of those lands withdrawn under section 

11 lying between 58 degrees N. and 64 degrees N. Latitude, and west of 161o W. Longitude that were not 

withdrawn for any part of the NWR System are withdrawn from all forms of appropriation including State 

Selections. Set aside for study and review by the Secretary of the Interior for the purpose of classification or 

reclassification of any lands not conveyed pursuant to section 14 of said Act. 

PLO 5186 Withdrawal for classification and protection of the Public Interest in lands not selected by the State. Lands are 

not open to location and entry under the mining laws (except locations for metalliferous minerals), nor leasing 

under the MLA. Lands are available for State Selection. 

PLO 5157 Classification and protection of the public interest in military reservations: segregates the land from all forms 

of appropriation under the public land laws including selection by the State of Alaska. 

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Section 3. Resource Uses Appendix M: BSWI Affected Environment Report 

There are 23 case types dealing with withdrawals within the planning area (see BSWI Draft RMP/EIS, 

Map 3.3.5-1). In addition, there are administrative, recreation, power site, military, and other withdrawals 

in place, other than the ANCSA authorities, many of which were created for a specific purpose that may 

now be obsolete, which make up about 34 percent of the planning area. Many of these withdrawals 

overlap ANCSA 17(d)(1) withdrawals. Creating, modifying, renewing or revoking withdrawals for other 

federal agencies is forecast to continue to be a recurring function of BLM. As resource demand increases 

in the region for economic and social development, or resources within withdrawals are sought by the 

public, agencies that hold the withdrawals may feel increased pressure to modify existing withdrawals or 

limit future withdrawals. 

While some land use plan decisions become effective with approval of the ROD for the RMP, other 

programs have specific requirements that must be taken in order to make certain decisions or 

recommendations effective. Modification or revocations of any administrative withdrawal orders 

including those under Section 17(d)(1) of ANCSA requires a formal action that includes Secretarial-level 

review and approval, resulting in a public land order signed by the Secretary of the Interior that will 

formally revoke or modify the 17(d)(1) withdrawal order(s). After the ROD is signed, BLM will draft and 

prepare all the required documents for the "PLO package." The package will also include the relevant 

parts of the BSWI Final EIS and ROD, which will fully cover NEPA adequacy in assessing the impact of 

revoking the 17(d)(1). This PLO package will be reviewed by the Solicitor for legal sufficiency before 

being submitted to the Secretary of Interior for approval. 

Disposal Actions 

Discretionary disposal actions are usually initiated in response to public requests or application and result 

in transfer of title and lands from the public domain. These include airport conveyances, R&PP sales, 

FLPMA sales, and exchanges. Disposals such as airport conveyances and most R&PP sales include 

revisionary clauses to return the lands to the public domain, if the land is no longer used for the purposes 

conveyed. FLPMA sales and exchanges do not include reversionary clauses and are generally final. This 

sub-section will address both new disposal actions under this authority and prior disposals that have 

returned to the public domain through reversion. 

Reserved federal interests in split estate lands anywhere in the planning area may be considered for 

conveyance out of federal ownership. Non-discretionary disposal actions, such as Native and State 

conveyances, and Native allotments, are not subject to the BLM planning process. 

Airport Conveyance 

The Airport and Airway Improvement Act of September 3, 1982, and 43 CFR 2640 authorize and 

regulate the issuance of conveyance documents for lands under the jurisdiction of the DOI to public 

agencies for use as airports and airways. Under the regulations those lands proposed for conveyance are 

segregated from appropriation under the public land laws, including the mining laws. Furthermore, airport 

patents contain provisions allowing for reversion of the lands to the U.S. under certain circumstances. 

R&PP Sales 

The R&PP Act authorizes the Secretary of the Interior to convey those public lands other than: 1) lands 

withdrawn or reserved for national forests, national parks and monuments, and national wildlife refuges; 

2) Indian lands and lands set aside for the benefit of Indians, Aleuts, and Eskimos; and 3) lands, which 

have been acquired for specific purposes, under conditions set forth in 43 CFR 2740. Though minerals 

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Appendix M: BSWI Affected Environment Report Section 3. Resource Uses 

remain reserved to the U.S., there is no provision for mineral entry or development on R&PP patents. 

R&PP patents contain provisions allowing for reversion of the lands to the U.S. under certain 

circumstances; in some cases, the reversionary clause is limited to 25 years. 

The needs of local communities will be considered and may also be met by lease or sale under the R&PP 

Act (43 U.S.C. 869 et seq.). Although no exchanges, sales, or R&PP disposals have been made in recent 

years, there are five existing R&PP leases in the planning area, shown in Table 3.5.4-2, with reversionary 

clauses that could be identified for disposal under this authority. If these lands become unencumbered 

within the life of the plan, they could be suitable for disposal, determined on a case-by-case basis. There 

may be municipal, school, and federal reserves and withdrawals that may be no longer needed by the U.S. 

for the purposes for which they were reserved. Where this is occurring, the land could potentially be used 

locally through the R&PP process, or they could be sold or leased. 

Table 3.5.4-2. R&PP Lands in the Planning Area 

Serial Number Acres Legal Description 

AKF 013187 1.04 S021N070W027 

AKF 032313 2.25 S008N071W009 Lot 1 

AKF 033548 0.35, 0.46 K023S018W024 Lot 3, 4 

AKF 034685 10.54 S008N071W018 Lot 15 

AKF 035163 1.72 S021N048W032 Lot 11 

FLPMA Sales 

Section 203 of FLPMA establishes criteria under which public lands may be considered for disposal. In 

general, all such proposals are to be reviewed under the criteria established by FLPMA on a case-by-case 

basis and will require a site specific environmental assessment. 

Finalization of conveyances to the State of Alaska, Native corporations, and individuals (Native 

allotments) are ongoing. Unselected lands in the planning area are currently retained for public use. Any 

selected lands which remain after all entitlements are fulfilled, will also generally be retained for public 

use. There are no pending FLPMA sales within the planning area; however, tenure adjustments, including 

sale or exchange, may be made in order to meet management needs (such as disposing of isolated 

parcels). Specifically, BLM-managed public lands that are inholdings of other federal lands, Native 

corporations, and/or State lands meet the criteria for potential exchange or disposal. Table 3.5.4-3 is a 

non-inclusive list of BLM land that could be considered for exchange or disposal to meet management 

needs. There are no pending FLPMA sales, and one sale has occurred. 

Table 3.5.4-3. BLM-Managed Public Lands Considered for Exchange or Disposal in the Planning 

Area 

Case (If Applicable) Township/Range Section(s) and/or Section Range(s) Acres 

AKAA 091175 T24S, R18W 25, 26, 35 1,920 

AKAA 091175 T25S, R18W 1 to 2, 11 to 14 3,840 

T25S, R17W 7 to 30, 33 to 36 17,920 

T25S, R16W 25 to 36 7,680 

AKFF 085667 T31N, R58W 3 to 10, 17 to 20, 30 to 31 8,960 

AKFF 085667 T30N, R59W 1, 12 1,280 

AKFF 085667 T30N, R59W 3 to 10 5,120 

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Case (If Applicable) Township/Range Section(s) and/or Section Range(s) Acres 

AKAA 00810305 T31N, R57W 7, 18 1,280 

AKAA 00810305 T29S, R7W 2 640 

AKFF 085667 T31N, R56W 1 to 3, 10 to 12 3,840 

AKFF 085667 T31N, R56W 17 to 36 12,800 

AKFF 085667 T30N, R57W 1 to 5, 8 to 36 21,760 

AKFF 085667 T29N, R58W 1, 12, 13, 24, 25, 36 3,840 

AKAA 00810305 T28N, R60W 2, 11 1,280 

T23S, R6W 25, 36 1,280 

T24S, R6W 1, 12 to 14, 23 to 26, 34 to 36 7,040 

AKAA 00810343 T22S, R5W 27, 34 1,280 

AKAA 00810349 T26S, R6W 3, 10 ,15, 22, 27, 34 3,840 

AKAA 00810351 T27S, R6W 3, 10, 15 1,920 

AKAA 012873 T27S, R6W 20, 29, 32 1,920 

AKAA 00810305 T32N, R54W 4 640 

AKAA 00810305 T32N, R54W 15 640 

AKAA 00810305 T32N, R54W 28 to 29 1,280 

AKFF 085667 T20N, R69W 1 to 4 2,560 

AKFF 085667 T20N, R69W 5 640 

AKAA 076404 T20N, R68W 1, 12 1,280 

AKAA 087834 T20N, R69W 6 640 

AKAA 076992 T23N, R58W 13 to 16, 20 to 36 13,440 

AKAA 076546 T23N, R56W 13 to 20, 23 to 25, 29 to 33, 36 10,880 

AKFF 085667 T24N, R55W 1, 2, 11, 12, 14, 22, 23, 26, 27 5,760 

AKAA 00810364 T25N, R54W 34, 35 1,280 

AKFF 085667 T25N, R56W 2 to 11, 14 to 18 9,600 

AKAA 076578 T25N, R56W 1, 12, 13 1,920 

T33N, R60W 12, 13, 23 to 26, 35, 36 5,120 

T29S, R6E 1, 2, 3 1,920 

T18S, R3W 1, 2, 3, 10 to 15 5,760 

AKAA 012892 T17N, R54W 20, 22, 23, 25 to 36 9,600 

AKAA 021474 T17N, R53W 21, 22, 23, 25 to 36 9,600 

T18N, R52W 1, 2, 3, 10 to 15, 22 to 27, 34, 35, 36 11,520 

AKAA 074571 T18N, R51W 6, 7, 18, 19 2,560 

T19N, R51W 31 640 

AKAA 070152 T18N, R51W 25 to 36 7,680 

AKAA 076495 T14N, R57W 13, 14 1,280 

AKAA 076494 T14N, R56W 18, 19, 20 1,920 

AKAA 061005 T14N, R56W 13, 14, 23 to 28, 34, 35, 36 7,040 

T13N, R56W 1, 2, 12 1,920 

AKAA 012898 T17N, R50W 1 to 4, 7 to 10, 15 to 18 7,680 

AKFF 014900 A T16N, R51W 19 640 

AKAA 00810363 T25N, R53W 19 to 22, 27 to 34 7,680 

AKAA 00810365 T24N, R54W 1 to 10 6,400 

T18N, R50W 4 to 9, 16 to 21, 28, 29 8,960 

AKAA 021483 T19N, R50W 1 to 4, 9 to 17, 20, 21, 28, 29, 32, 33 12,160 

AKAA 074568 T20N, R50W 33 to 36 2,560 

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Appendix M: BSWI Affected Environment Report Section 3. Resource Uses 

Case (If Applicable) Township/Range Section(s) and/or Section Range(s) Acres 

T20N, R49W 8, 9, 16 to 21 5,120 

T21N, R49W 4, 5, 7, 8, 9, 15 to 23, 26 to 33 14,080 

T22N, R46W 22, 23 1,280 

AKAA 086371 T19N, R44W 5 to 8 2,560 

AKFF 014936 A T19N, R43W 25 to 29 3,200 

AKFF 014936 A T18N, R44W 36 640 

AKFF 014936A2 T18N, R43W 31 640 

AKAA 012894 T19N, R40W 18 640 

AKFF 014838A2 T18N, R39W 9, 13 to 17, 24 4,480 

AKAA 021475 T18N, R38W 18, 19, 20 1,920 

AKAA 021475 T18N, R38W 29 to 32 2,560 

AKAA 076405 T21N, R38W 2, 11, 14, 15 2,560 

AKAA 076405 T21N, R38W 1, 12, 13 1,920 

T21N, R38W 25 to 29, 32 3,840 

AKFF 014838A2 T21N, R38W 33 to 36 2,560 

AKAA 076405 T20N, R39W 1 640 

AKAA 076161 T18N, R34W 25, 26, 27, 31 to 36 5,760 

AKAA 076160 T18N, R33W 31, 32 1,280 

AKAA 076393 T17N, R34W 3 to 6, 8, 9, 10, 15, 16, 17, 21, 22 7,680 

AKAA 00810304 T29S, R15E 2, 3 1,280 

AKAA 021571 T34N, R35W 31 to 36 3,840 

AKAA 00810303 T33N, R35W 3 to 6 2,560 

AKAA 021572 T33N, R36W 11 to 14, 23, 24 3,840 

AKAA 076309 T32N, R31W 17, 18 1,280 

AKAA 021550 T32N, R33W 25 to 36 7,680 

AKAA 021535 T31N, R34W 9 640 

AKAA 021535 T31N, R34W 31 to 33 1,920 

AKAA 021523 T30N, R35W 5 to 10, 15 to 22, 27 to 34 14,080 

AKAA 00810397 T30N, R35W 11 640 

AKAA 00810371 T30N, R34W 1, 12, 13, 24, 25, 36 3,840 

AKAA 00810372 T29N, R35W 3 to 10, 14 to 23, 26 to 35 17,920 

AKFF 014906 A T27S, R22E 25 to 27, 29, 31 to 36 6,400 

AKFF 014906 A T27S, R24E 9, 10, 15, 16 2,560 

AKAA 00810301 T22S, R28E 26 640 

AKAA 012630 T23S, R28E 2, 11, 14, 15 2,560 

AKAA 00810301 T23S, R29E 28 640 

AKAA 021319 T23S, R30E 26 to 29, 32 to 35 5,120 

AKAA 012644 T17S, R28W 1 to 12 7,680 

AKAA 012644 T17S, R28W 32 to 36 3,200 

AKAA 00810309 T24S, R22E 1 to 36 23,040 

AKAA 021220 T11S, R23W 19 to 21, 28 to 30 3,840 

AKAA 076554 T12S, R23W 28 to 33 3,840 

AKFF 015380 T28N, R23W 7 640 

Note: Acres are rounded to the nearest whole number. 

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Section 3. Resource Uses Appendix M: BSWI Affected Environment Report 

Withdrawals 

A withdrawal is a formal action that sets aside, withholds, or reserves federal lands for public purposes. 

Withdrawals accomplish one or more of the following: 

• Transfer total or partial jurisdiction of federal land between federal agencies; 

• Dedicate federal land to a specific purpose 

• Segregate (close) federal land from operation of some or all of the public land laws and (or) 

mineral laws. All the existing withdrawals segregate from operation of the public land laws, 

unless the surface estate is in nonfederal ownership. 

Table 3.5.4-4 below summarizes the withdrawals in the planning area based on the best available 

information. 

Table 3.5.4-4. Withdrawals in the Planning Area 

Case File PLO/ SO/ EO Purpose and Segregative Effect 

Managing 

Agency 

AA-60766 ANILCA 603 Unalakleet River withdrawal: segregates the land from entry, sale, or 

other disposition under the public land laws of the United States. 

BLM 

AA-65514 PLO 5172 Withdrew lands for village and regional corporation selections for the 

Association of Village Council Presidents Region under ANCSA. Also 

allows the Secretary to grant leases, permits, rights-of-way or 

easements on lands withdrawn prior to conveyances. The lands are 

withdrawn, subjection to valid existing rights, from all forms of 

appropriation under the public land laws, including selections by the 

State of Alaska, location and entry under the mining laws and from 

leasing under the MLA. Also reserved the lands for the purpose of 

study and review by the Secretary for classification or reclassification 

of any lands not conveyed under Section 14 of ANCSA. 

BLM 

AA-17989 EO 3406 Reserves 168 parcels for lighthouse purposes, subject to valid 

existing rights. 

USCG 

AA-87847 FA 12879 Aniak Alaska 31 Project: segregates the land from “entry, location, or

other disposal under the laws of the United States unless otherwise 

directed by the Federal Energy Regulatory Commission or by 

Congress.” 43 CFR 2320.0-3. 

FERC 

AA-87849 FA 12881 McGrath Alaska 28 Project: segregates the land from “entry, location, 

or other disposal under the laws of the United States unless 

otherwise directed by the Federal Energy Regulatory Commission or 

by Congress.” 43 CFR 2320.0-3. 

FERC 

AA-93287 FA 14369 Chikuminuk Lake Hydro Project-transmission line: segregates the 

land from “entry, location, or other disposal under the laws of the

United States unless otherwise directed by the Federal Energy 

Regulatory Commission or by Congress.” 43 CFR 2320.0-3. 

FERC 

F-28299 NT19620524 PLO 

2745 

Unalakleet VORTAC: segregates the land from all forms of 

appropriation under the public land laws, including mining. 

FAA 

F-10165 PLO 1142 Stony River Lime Hills: segregates the land from all forms of 

appropriation under the public land laws, including mining and 

mineral leasing laws. 

DOD-USAF 

F-12980 PLO 1472 Mt. Sparrevohn White Alice Site: segregates the land from all forms 

of appropriation under the public land laws, including the mining and 

mineral leasing laws. 

DOD-USAF 

F-16448 PLO 1700 Tatalina (Takotna) reserve: segregates the land from all forms of 

appropriation under the public land laws, including mining and the 

mineral leasing laws (PLO 731), opens the land in PLO 731 to 

selection for the mental health program, homesteads and home sites 

by veterans of WWII and the Korean War, non-mineral applications, 

mining, and mineral leasing. 

DOD-USAF 

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Appendix M: BSWI Affected Environment Report Section 3. Resource Uses 

Case File PLO/ SO/ EO Purpose and Segregative Effect 

Managing 

Agency 

F-12026 PLO 1771 Unalakleet Air Force station: segregates the land from all form of 

appropriation under the public land laws including the mining and 

mineral leasing laws and disposals under the act of July 31, 1947. 

The BLM retains jurisdiction over management of surface and 

subsurface mineral resources. 

BLM/ DODUSAF 

F-11997 PLO 1813 Cape Romanzof: segregates the land from all forms of appropriation 

under the public land laws including the mining and mineral leasing 

laws and disposals under the act of July 31, 1947. 

DOD-USAF 

F-14030 PLO 1862 Unalakleet North River Air Force Station: segregates the land from all 

forms of appropriation under the public land laws, including mining 

and mineral leasing laws. It is still subject to the Act of July 31, 1947, 

which allows for the disposal of materials not covered under existing 

mining and mineral leasing laws. 

DOD-USAF 

F-22950 PLO 2020 Akiachak National Guard Site: segregates the land from all forms of 

appropriation under the public land laws, including mining. It is still 

subject mineral leasing laws and to the Act of July 31, 1947, which 

allows for the disposal of materials not covered under existing mining 

and mineral leasing laws. 

DOD-ARMY 

F-22952 PLO 2020 Eek National Guard Site: segregates the land from all forms of 

appropriation under the public land laws, including mining. 

DOD-ARMY 

F22953 PLO 2020 Kasigluk National Guard Site: segregates the land from all forms of 

appropriation under the public land laws, including mining. 

DOD-ARMY 

F-22955 PLO 2020 Kipnuk National Guard Site: segregates the land from all forms of 

appropriation under the public land laws, including mining. 

DOD-ARMY 

F-22959 PLO 2020 Kwethluk National Guard Site: segregates the land from all forms of 

appropriation under the public land laws, including mining. 

DOD-ARMY 

F-22960 PLO 2020 Napakiak National Guard Site: segregates the land from all forms of 

appropriation under the public land laws, including mining. 

DOD-ARMY 

F-22961 PLO 2020 Napaskiak National Guard Site: segregates the land from all forms of 

appropriation under the public land laws, including mining. 

DOD-ARMY 

F-22962 PLO 2020 Newtok National Guard Site: segregates the land from all forms of 

appropriation under the public land laws, including mining. 

DOD-ARMY 

F-22963 PLO 2020 Noatak National Guard Site: segregates the land from all forms of 

appropriation under the public land laws, including mining. 

DOD-ARMY 

F-22964 PLO 2020 St. Michael National Guard Site: segregates the land from all forms 

of appropriation under the public land laws, including mining. 

DOD-ARMY 

F-22965 PLO 2020 Shishmaref National Guard Site: segregates the land from all forms 

of appropriation under the public land laws, including mining. 

DOD-ARMY 

F-22966 PLO 2020 Shungnak National Guard Site: segregates the land from all forms of 

appropriation under the public land laws, including mining. 

DOD-ARMY 

F-22967 PLO 2020 Tuluksak National Guard Site: segregates the land from all forms of 

appropriation under the public land laws, including mining. 

DOD-ARMY 

F-22968 PLO 2020 Tununak National Guard Site: segregates the land from all forms of 

appropriation under the public land laws, including mining. 

DOD-ARMY 

F-22969 PLO 2020 Tuntutuliak National Guard Site: segregates the land from all forms of 

appropriation under the public land laws, including mining. 

DOD-ARMY 

F-22686 PLO 2133 McGrath Fire Control Station/Air Navigation Site: segregates the land 

from all forms of appropriation under the public land laws, including 

the mining and mineral leasing laws, but not disposals of materials 

under the Act of July 31, 1947. Some lands would be open to 

homestead and homesite entry after September 22, 1960. 

BLM/ FAA 

F-31712 PLO 3413 Bethel Fire Control and Administrative Site: segregates the land from 

all forms of appropriation under the public land laws, including the 

mining laws, but not from leasing under the mineral leasing laws. 

BLM 

F-31751 PLO 3428 Emmonuk & Kwiguk National Guard Site: segregates the land from 

all forms of appropriation under the public land laws, including mining 

but not the mineral leasing laws. 

DOD-ARMY 

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Section 3. Resource Uses Appendix M: BSWI Affected Environment Report 

Case File PLO/ SO/ EO Purpose and Segregative Effect 

Managing 

Agency 

F-31675 PLO 3445 Bethel airport: segregates the land from all forms of appropriation 

under the public land laws, including the mining laws, but still open to 

mineral leasing. 

FAA 

AA-61301 PLO 5156 Withdraws lands in former reservations: segregates the land from all 

forms of appropriation under the public land laws including selection 

by the State of AK, leasing under the MLA, and location and entry 

from mining laws. It allowed selection of land by native corporations 

under the ANCSA, and was set to expire on December 18, 1973 and 

would then be open to selection by the State of AK. 

BLM 

FF-85702 PLO 5156 Withdrawal of lands in former reservations: segregates from all forms 

of appropriation under the public land laws including selection by the 

State of Alaska, location and entry under the mining laws, and 

leasing under the MLA. It allowed selection of land by native 

corporations under the ANCSA, and was set to expire on December 

18, 1973 and would then be open to selection by the State of AK. 

BLM 

AA-61299 PLO 5179 17(d)(1) Aid of legislation for additions or creation of units of National 

Park, Forest, Wildlife Refuge and Wild and Scenic River Systems 

and classification: segregates the land from all forms of appropriation 

under the public land laws including selection by the State of AK, 

location and entry under the mining laws, leasing under the MLA, and 

selection by regional corporations under Sec. 12 of ANCSA. 

BLM 

FF-16301 PLO 5173 17(d)(1) Withdrew lands for village and regional corporation 

selections for the Tanana Region under ANCSA. Also allows the 

Secretary to grant leases, permits, rights-of-way or easements on 

lands withdrawn prior to conveyances. The lands are withdrawn, 

subject to valid existing rights, from all forms of appropriation under 

the public lands laws, including selections by the State of Alaska, 

location and entry under the mining laws and from leasing under the 

MLA. Also reserved the lands for the purpose of study and review by 

the Secretary for classification or reclassification of any lands not 

conveyed under Section 14 of ANCSA. 

BLM 

FF-16304 PLO 5180 17(d)(1) Classification and protection of public interest lands: 

segregates the land from all forms of appropriation under the public 

land laws including Selection by the State of AK, location and entry 

under the mining laws except for locations for metalliferous minerals, 

and leasing under the MLA. 

BLM 

AA-64307 PLO 5181 17(d)(1) Classification and study for possible additions to National 

Wildlife Refuge: segregates the lands from all forms of appropriation 

under the public lands laws including selection by the State of AK, 

location and entry under the mining laws, and leasing under the MLA. 

BLM 

AA-65512 PLO 5183 Withdrawal for Classification and Aid to legislation: segregates the 

land from selection by the regional corporations, located within 

certain national forests, wildlife refuges and wildlife ranges, and lands 

withdrawn by Sec. 11 of ANCSA that are within the boundaries of the 

Naval Petroleum Reserve No. 4. 

BLM 

FF-85667 PLO 5184 17(d)(1) Classification or reclassification of lands withdrawn by 

Section 11 of ANCSA: segregates the land withdrawn by Sec. 11 of 

ANCSA from all forms of appropriation under the public land laws, 

location and entry under the mining laws, leasing under the MLA, and 

selection by the State of AK until December 18, 1975. Also 

segregates the land described in paragraph 2, which is “all those

lands withdrawn by section 11 of the Act lying between 58 ̊ N. and

64 ̊ N. latitude, and west of 161 ̊ W. longitude not withdrawn for any 

part of the National Wildlife Refuge System,” that are not also

conveyed by Sec. 14 of ANCSA, from selection by the State of AK, 

all forms of appropriation under the public land laws, entry and 

location under the mining laws, and leasing under the MLA. 

BLM 

AA-61005 PLO 5186 17(d)(1) Classification and protection for lands not selected by the 

State of Alaska: segregates the land from all forms of appropriation 

under the public land laws, location and entry under the mining laws 

except for locations of metalliferous minerals, and leasing under the 

MLA. 

BLM 

3-26 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Appendix M: BSWI Affected Environment Report Section 3. Resource Uses 

Case File PLO/ SO/ EO Purpose and Segregative Effect 

Managing 

Agency 

FF-86064 PLO 5187 Classification and protection of the public interest in military 

reservations: segregates the land from all forms of appropriation 

under the public land laws including selection by the State of AK 

DOD 

AA-47429 PLO 6098 Minchumina 1008 Opening: modifies certain lands within PLOs 5173, 

5180 and 5184 to settlement claims for trade and manufacturing 

sites, headquarters sites, homesites, and opens certain lands to the 

operation of the mineral leasing laws, and the operation of the 

general mining laws. 

BLM 

FF-81398 PLO 6477 Seward Peninsula Partial revocation & Open Entry for general Mining 

Laws: opens certain lands for mineral leasing, mining location and 

entry and allows certain lands to be opened to permit sale or lease 

under the FLPMA. This PLO does not open lands designated for 

study as additions to the Wild and Scenic River system, National 

Preserves, National Monuments, or wildlife refuges. 

BLM 

AA-53140 PLO 6787 Iditarod/George 1008 Opening: modifies certain lands within PLOs 

5180 and 5184 to make them suitable for FLPMA, location and entry 

under the mining laws, and appropriation under the mineral leasing 

laws. 

BLM 

F-30974 SO 19360420 

ANS 105 

Big Delta, Deering, McGrath, Unalakleet, Valdez Air Navigation Sites: 

segregates the land from all forms of appropriation under the public 

land laws, subject to valid existing rights. 

BLM 

AA-63714 SO 19391103 

ANS 131 

Rohn/Tatina Airstrip Air Navigation Site: segregates the land from all 

forms of appropriation under the public-land laws, subject to valid 

existing rights. 

BLM 

F-30970 SO 19391103 

ANS 131 

Takotna & Tatina Rive Air Navigation Site: segregates the land from 

all forms of appropriation under the public land laws, subject to valid 

existing rights. 

BLM 

F-30972 SO 19400417 

ANS 140 

Bremner, Candle, Ophir, Peters Creek Air Navigation Site: 

segregates the land from all forms of appropriation under the public 

land laws, subject to valid existing rights. 

BLM 

F-30973 SO 19400626 

ANS 142 

Flat Air Navigation Site: segregates the land from all forms of 

appropriation under the public land laws, subject to valid existing 

rights. 

BLM 

F-28822 SO 19401126 

ANS 146 

Kuskokwim Air Navigation Site: segregates the land from all forms of 

appropriation under the public land laws. 

BLM 

FF-496 SO 19411001 

ANS 145 

McGrath air navigation: segregate the land from all forms of 

appropriation under the public land laws. 

BLM 

F-7195 SO 19411231 

ANS 172 

Galena Airport: segregates the land from all forms of appropriation 

under the public land laws. 

BLM 

FF-677 SO 19420721 AN 

183 

Aniak Air Navigation Site: segregates the land from all forms of 

appropriation under the public land laws, also partially revokes 

ANS146 

BLM 

F-24672 SO 19420721 

ANS 183 

Aniak air navigation: segregates the land from all forms of 

appropriation under the public land laws, partially revokes ANS 146. 

BLM 

F-9137 SO 19420814 

ANS 185 

Unalakleet Airport: reduces ANS 105, segregates the land from all 

forms of appropriation under the public land laws, renamed ANS 185 

BLM 

F-8649 SO 19420924 

ANS 189 

Fairwell Airport: segregates the land from all forms of appropriation 

under the public land laws. 

FAA 

F-23812 SO 19420924 

ANS 190 

Minchumina: segregates the land from all forms of appropriation 

under the public land laws and partially revokes ANS 172. 

FAA 

F-17903 SO19581024 

ANS 146 & 16 

Bethel Airport: segregates the land from all forms of appropriation 

under the public land laws. 

FAA 

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Section 3. Resource Uses Appendix M: BSWI Affected Environment Report 

Acquisitions and Exchanges 

FLPMA authorizes the acquisition of real property where it is consistent with the mission of the 

department and departmental land use plans. No pending acquisitions are being actively pursued by BLM 

within the planning area. If a private parcel of land is surrounded by BLM land, and the parcel becomes 

available for sale, the BLM may determine to acquire that land. If a parcel of land along the Unalakleet 

Wild River Corridor or the INHT becomes available for sale, the BLM may determine to acquire the 

parcel from willing sellers or acquire an easement for the INHT. 

Sec. 1302(h) of ANILCA authorizes the Secretary of Interior to exchange public lands or interests 

(including Native selection rights) for non-federal lands and interests. No exchanges have been made or 

are pending within the planning area at this time. Table 3.5.4-5 is a non-inclusive list of State or Native 

patented or selected parcels that BLM could consider for acquisition via land exchange to meet 

management needs. 

Land Use Authorizations 

BLM may authorize various uses through land use permits, leases, and rights-of-way as well as acquire 

easements on a willing seller basis or reserve easements in ANCSA conveyance. The sections below 

provide brief descriptions of the various authorizations available to the BLM. 

Table 3.5.4-5. Lands Considered for Acquisition in the Planning Area 

Case (If Applicable) Township/Range Section(s) and/or Section Range(s) Acres 

AKAA 076413 T21N, R68W 1 to 4, 9 to 16 7,632 

AKAA 076412 T22N, R67W 32, 33 1,274 

AKAA 076412 T21N, R67W 4 to 10, 15 to 23, 25 to 34 16,558 

AKAA 076532 T20N, R69W 8 to 17, 20 to 24 9,600 

AKAA 076404 T20N, R68W 2 to 11, 13 to 20 11,394 

AKAA 076411 T20N, R67W 4 ,9, 16, 17, 18 2,842 

AKAA 076282 T27N, R65W 28, 29, 31, 32, 33 3,177 

AKAA 076259 T26N, R66W 1, 11 to 14, 23 to 26, 34 to 36 7,680 

AKAA 076258 T26N, R65W 1 to 36 22,941 

AKAA 076257 T26N, R64W 5 to 8, 18, 19, 30 4,393 

AKAA 076259 T25N, R66W 2, 3, 4, 9, 10 3,200 

AKAA 076241 T25N, R65W 3, 4, 5, 7, 8, 9, 16 to 20, 7,021 

AKAA 012880 T28N, R59W 19 to 21, 25 to 36 8,004 

AKAA 076432 T27N, R58W 6, 7, 13 to 24, 29 to 31 9,210 

AKAA 076273 T27N, R55W 6 to 8, 17 to 20, 29 to 32 5,705 

AKAA 076288 T28N, R53W 2 to 23, 26 to 34 19,609 

AKAA 076288 T29N, R52W 31, 32 1,279 

AKAA 076402 T20N, R59W 26, 32 to 36 3,840 

AKAA 076402 T19N, R59W 1 to 5, 8 to 17, 21, 24, 25 11,520 

AKAA 076402 T19N, R58W 5 to 8, 17 to 20, 30 5,621 

AKAA 076402 T20N, R58W 31, 32 1,247 

AKAA 076575 T18N, R58W 1 to 4, 9 to 17, 20 to 24 10,720 

AKAA 076575 T18N, R57W 1 to 30 19,065 

AKAA 076575 T18N, R56W 5 to 8, 17 to 20, 29, 30 6,315 

AKAA 076182 T22N, R55W 31 628 

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Appendix M: BSWI Affected Environment Report Section 3. Resource Uses 

Case (If Applicable) Township/Range Section(s) and/or Section Range(s) Acres 

AKAA 076182 T21N, R56W 1, 12, 13, 24, 25, 35, 36 4,480 

AKAA 076182 T21N, R55W 6, 7, 18, 19, 30, 31 3,807 

AKAA 076182 T20N, R56W 4, 5, 8, 9, 16, 17, 20, 21, 28, 29, 32, 33 7,680 

AKAA 076401 T19N, R56W 4, 5, 8, 9, 16, 17, 20, 21, 28, 29, 32, 33, 34 8,320 

AKAA 076396 T18N, R56W 3, 4, 9, 10, 15, 22 3,840 

T18N, R56W 16, 21, 27, 28 2,560 

AKAA 076191 T21N, R54W 15, 16, 17, 19 to 22, 28 to 33 8,311 

AKAA 076191 T21N, R55W 36 640 

AKAA 076181 T20N, R55W 2 to 10, 18, 19 6,924 

AKAA 076181 T20N, R55W 23 to 26, 33, 34, 35 4,480 

AKAA 076400 T19N, R55W 3, 4, 9 1,920 

AKAA 076203 T23N, R47W 1, 2, 11 to 15, 22 to 27, 33 to 36 10,880 

AKAA 076415 T22N, R47W 1, 11, 12, 13, 24, 25, 26 4,480 

AKAA 076415 T22N, R46W 2 to 11, 17 to 21, 27 to 30 12,054 

AKAA 074575 T19N, R45W 4 to 9, 18 4,392 

AKAA 076172 T19N, R45W 30 to 33 2,514 

AKAA 076172, 

AKAA 074575 

T19N, R45W 23 to 26, 34, 35, 36 4,480 

AKAA 076172 T19N, R46W 25 to 28, 33 to 36 5,120 

AKAA 076165 T18N, R46W 1 to 4, 9 to 13, 24 6,400 

AKAA 076172 T18N, R45W 3 to 10, 16 to 21 889 

AKAA 012897 T19N, R43W 20 to 24 3,200 

AKAA 012896 T19N, R42W 1, 2, 3, 11, 12 3,200 

AKAA 012896 T19N, R42W 4, 5, 9, 10 2,560 

AKAA 012896 T19N, R42W 6, 7, 8 1,859 

AKAA 076413 T21N, R68W 5, 8 1,091 

AKAA 076532 T20N, R69W 5 640 

AKAA 076532 T20N, R69W 26 to 29 2,560 

AKAA 076404 T20N, R68W 1, 12 1,280 

AKAA 076404 T20N, R68W 21 640 

AKAA 076579 T18N, R56W 2 640 

Unknown T19N, R55W 5, 8 1,275 

AKAA 076400 T19N, R55W 20, 29 1,280 

Note: Acres are rounded to the nearest whole number 

Rights-of-Way 

A ROW grants an applicant the right to use specific public land to build such things as roads, 

communication facilities and power lines. Generally, ROWs are issued for long-term projects that require 

significant investment. ROWs are a possessory interest in land. Usually, ROWs are issued for a maximum 

of 20 year terms with the option to renew. ROWs can be issued under Title V of the FLPMA or Section 

28 of the MLA depending upon the purpose of the ROW. 

Airport Leases 

The Act of May 24, 1928, as amended, authorizes the Secretary of the Interior to lease for use as a public 

airport any contiguous unreserved and unappropriated public lands not to exceed 2,560 acres in area. In 

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accordance with the regulation, those lands leased for airport purposes will not be subject to appropriation 

under the public land laws, including the mining laws. There are no pending airport lease applications and 

only one authorized lease within the planning area as of February 2018. 

R&PP Leases 

The R&PP Act authorizes the Secretary of the Interior to lease public lands, following the same criteria 

for sales. Under these regulations, lands leased for R&PP are segregated from entry under the public land 

laws, including the mining laws (43 CFR 2091.3-2). There is one R&PP sale pending, one lease issued, 

and five sales that have been authorized within the planning area as of February 2018. 

FLPMA Leases and Permits 

Section 302 of FLPMA contemplates a wide variety of land uses for lease and permit including, but not 

limited to, habituation, cultivation, and the development of small trade or manufacturing concerns. In 

general, leases are for long-term land uses while permits are used to authorize short-term land uses or uses 

with little impact. This section of the act is implemented by regulations in 43 CFR 2920 and BLM 

Manual 2920, which further define these uses to exclude private recreational habitation such as seasonal 

use cabins. All such proposals are to be reviewed under the criteria established by FLPMA on a case-bycase basis and require a site-specific environmental assessment. Five permits/leases have been authorized 

in the planning area as of August 2018. 

Prior to the passage of FLPMA, rights-of-way for communication sites and transmission lines were issued 

under the act of March 4, 1911. FLPMA repealed the act and regulations governing ROWs are found at 

43 CFR 2800. BLM has 15 ROW applications pending in the planning area, which include seven pending 

RS2477 ROWs. There are 19 ROWs authorized within the planning area. 

Before FLPMA, 44LD 513 (letter of instruction found in Volume 44, Land Decisions, page 513 dated 

January 13, 1916) was used to recognize telephone lines, roads, trails, bridges, and similar improvements 

constructed on federal lands with federal monies and being maintained by and for the U.S. 

FLPMA Easements 

A FLPMA easement is an authorization for a non-possessory interest in lands that specifies the rights of 

the holder and the obligations of the BLM to use and manage the lands in a manner consistent with the 

terms of the easement. For example, easements may be used to ensure that uses of public lands are 

compatible with non-federal uses occurring on adjacent or nearby land. There are no FLPMA easements 

authorized or pending in the planning area as of February 2018. 

Revised Statute 2477 ROW 

Section 8 of the Mining Act of 1866 provided: “and be it further enacted, that the ROW for the 

construction of highways over public lands, not reserved for public uses, is hereby granted.” The statute 

was self-enacting; rights being established by “construction” of a “highway” on unreserved public lands, 

without any form of acknowledgement or action by the federal government. This section of the statute 

was later re-codified as Revised Statute 2477 (RS 2477). RS 2477 was repealed by FLPMA on October 

21, 1976, with a savings provision for rights established prior. 

The BLM does not recognize RS 2477 routes until asserted in a court of competent jurisdiction. 

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ANCSA 17(b) Easements 

ANCSA 17(b) easements were reserved through the adjudicative processes of land transfers by ANCSA. 

This type of easement only exists on Native corporation land and is a non- possessory lands interest 

intended to provide access to publicly-owned lands and waterways. BLM retains management authority 

on these easements; however, BLM has an MOU with the NPS and an MOU with USFWS that transfers 

the administration of the 17(b) easement that access the CSU managed by these agencies. When lands 

access non-federal public lands, BLM can also transfer administration to State or local agency with their 

consent. There are currently no regulations that address easement management. A 17(b) easement 

management handbook and IM (IM AK 2007-037) provide management guidance. Easements are noted 

on easement quadrangle maps, which are available to the public. The 17(b) easements are described in the 

various conveyance documents to the ANCSA corporations, which are also available to the public. 

Discretionary actions which may be taken on 17(b) easements such as locating, marking, relocating, 

constructing, maintaining, repairing or compliance monitoring, or terminating 17(b) easements will be 

addressed outside of this planning effort. ANCSA 17(b) easements are beyond the scope of this planning 

effort. 

Unauthorized Use or Trespass 

Unauthorized use and/or unauthorized occupancy of the public lands (trespass) will be addressed and 

resolved in accordance with the regulations found in 43 CFR 9220.1-2 and the guidance provided by 

BLM’s Realty Trespass Abatement Handbook H-9232-1. Unauthorized uses are activities that are not 

approved by the BLM and would require a permit, lease, or ROW. Unauthorized occupancies are 

activities resulting in full or part time human occupancy or use. Unauthorized development issues arise 

from activities that disturb the earth’s surface or physically alter the character of the land or vegetation.

Collectively, the above activities are termed “trespass.” 

It is the responsibility of the BLM to protect the public’s best interest in regard to BLM-managed public 

lands. Over the years, individuals have built structures for various purposes (e.g., occupancy, commercial 

uses, and recreational uses) on public land without authorization. The BLM attempts to manage this 

problem through a program of detection, control, and abatement. The size of the planning area makes a 

complete inventory difficult and a number of trespasses have been identified. Each situation is handled on 

a case-by-case basis, according to BLM regulations and policies. There are 19 unauthorized occupancies, 

one unauthorized development, two unauthorized use, and three trespass cases currently pending within 

the planning area at this time. When presented with a trespass situation, BLM has three options to resolve 

the situation: 

• If the structure is used for allowable purposes as defined by Sec. 302 of FLPMA, and is 

compatible with other resource management objectives, the trespass can be authorized once the 

trespass is resolved. 

• If the structure is not allowable under FLPMA, but is compatible with other resource objectives, 

it could be transferred to federal ownership and maintained as a public use cabin or for 

administrative purposes. 

• If the structure is not allowable under FLPMA and is either unsuitable for public use or is 

incompatible with other management objectives, it is removed. 

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Access Corridors 

There are no legislatively-designated access routes in the planning area, nor are there plans by the BLM to 

designate one during the life of this plan. 

3.5.5 Resource Changes: Trends and Forecasts 

Land status changes slowly as lands that are selected by the State or ANCSA corporations are conveyed 

out of BLM management and to the ownership of the selector. It is anticipated that the current trend will 

continue, and lands will be conveyed at the current rate until all land conveyances are complete. 

Land exchanges, acquisitions, and disposals from all landowning agencies occur occasionally and will 

continue at the current rate. 

3.6 Recreation and Visitor Services 

3.6.1 Introduction 

This section describes the current conditions related to recreation and visitor services in the planning area. 

3.6.2 Laws, Regulations, and Policies 

The BLM is the primary agency with jurisdictional authority and relevant regulatory requirements related 

to recreation and visitor services on BLM-managed public lands in the planning area. 

Federal regulations addressing management of recreation and visitor services can be found at 43 CFR 

8360 through 8365 – Visitor Services; 43 CFR 2932 – Special Recreation Permits; 43 CFR 2650.1 –

Interim Management; 43 CFR 8340 – Off-Road Vehicles; and 43 CFR 36 – ANILCA Title XI 

implementing regulations, including general public access, applicable to CSUs in Alaska. 

BLM policy guiding the consideration of recreation and visitor services in the land use planning process 

can be found in BLM Manual 8320: Planning for Recreation and Visitor Services (BLM 2014a), and 

BLM Handbook H-1601-1: Land Use Planning (BLM 2005). These guiding policy documents establish 

the BLM’s recreational planning framework and provide specific procedures and instructions for 

designating recreation management areas (RMAs) and integrating planning concepts such as OutcomesFocused Management (OFM) and recreation setting characteristics (RSCs) into the land use planning 

process. 

OFM recognizes that the BLM can manage certain activities, experiences and benefits while protecting 

the natural and cultural resources. Using OFM helps the BLM to provide direction for recreation 

planning, budgeting, organization, staffing and training, leading to a more efficient, cost-effective and 

accountable recreation program. RSCs are derived from the older Recreation Opportunity Spectrum. The 

RSCs are categorized as physical, social and operational components and are further subdivided into 

specific characteristics (attributes). These characteristics are categorized across a spectrum of classes that 

describe a range of qualities and conditions of a recreation setting, such as a physical setting spectrum 

from primitive to urban. Supporting information is contained in BLM Handbook H-8320-1: Planning for 

Recreation and Visitor Services. 

BLM Manual 2930-1: Recreation Permits and Fees, guides the issuance and management of special 

recreation permits (SRPs) (BLM 2014b). It also contains policy, direction, and guidance for establishing, 

modifying and managing recreation fees and for issuing and administering the various recreation permits 

as a means of authorizing recreational uses of public lands and related waters. 

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The planning area also includes lands administered by the USFWS, NPS, State of Alaska, and private 

entities. These entities manage recreation and visitor services consistent with their own regulations, 

policies, and guidance. 

Recreation Management Areas 

Since adopting the 1981 SWMFP and 1986 CYRMP, the BLM released updated policy for the 

identification of RMAs and associated management during the land use planning process (BLM Manual 

MS-8320). RMAs are a land unit where recreation and visitor services objectives are recognized as a 

primary resource management consideration and specific management is required to protect the recreation 

opportunities. The RMA designation is based on recreation demand and issues, recreation setting 

characteristics, need to resolve user conflicts, compatibility with other resource uses, and resource 

protection needs. There are two types of RMAs, special recreation management areas (SRMAs) and 

extensive recreation management areas (ERMAs). 

The SRMA is an administrative unit where the existing or proposed recreation opportunities and 

recreation setting characteristics are recognized for their unique value, importance, and distinctiveness, 

especially as compared with other areas used for recreation. Management of SRMAs protects and 

enhances the area’s unique recreation opportunities and RSCs. In SRMAs, recreation and visitor services 

is the BLM’s priority management focus, where specific recreation opportunities and recreation setting 

characteristics are managed and protected on a long-term basis. The BLM may divide a SRMA into 

recreation management zones to provide more focused management of specific recreation opportunities. 

ERMA designations provide specific management consideration for recreation use, demand, and program 

investments. The BLM manages ERMAs to support and sustain the area’s principal recreation activities 

and the associated qualities and conditions of the ERMA in a manner that is commensurate with the 

management of other resources and resource uses. 

Lands not designated as an SRMA or ERMA are managed to meet basic recreation and visitor services 

and resource stewardship needs. Outside of RMAs, the BLM manages recreation and visitor services to 

allow recreation uses that are not in conflict with the primary uses of these lands. While recreation 

activities may occur, they are not emphasized. Lands closed to public use are not available for recreation. 

3.6.3 Resource Indicators 

The conditions that are established in the discussions below provide a baseline for recreation and visitor 

services-related values, which the impact analysis will be based on. The following indicators, along with 

qualitative discussions, will be used to evaluate impacts associated with management decisions in the 

BSWI Draft RMP/EIS: 

• An increase or decrease in the number of acres managed as SRMAs or ERMAs 

• In SRMAs, a change in the desired recreation opportunities and setting characteristics 

• In ERMAs, a decrease in the quality, quantity, and conditions of the ERMA or an impediment of 

users’ ability to engage in the principal recreational activities being managed for in the ERMA

• Change in the quality of recreation opportunities resulting from a change in the recreation setting 

or opportunity based on VRM management, minerals management, and/or lands and realty 

• Change in the quantity of recreation opportunities 

• A change in the number or types of SRPs issued 

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• Potential for visitor displacement 

• Change in recreation setting due to degradation of resources (e.g., air, permafrost) 

3.6.4 Current Conditions 

Components and characteristics of the physical, social, and operational RSCs in the planning area 

influence the types, extent, and location of recreational opportunities and the desired outcomes visitors 

seek from those opportunities. The physical RSCs within the planning area are primitive. The area is 

remote and does not have recreation facilities (e.g., campgrounds, trailheads, and interpretive signage) 

typically found in front country and urban areas. The social setting is also largely primitive, with some 

areas trending toward back country. Contact with other visitors and evidence of use is rare; group sizes 

tend to be small. Areas along the INHT and popular hunting and fishing areas exhibit slightly less 

primitive, backcountry social RSCs. Operational RSCs are also largely primitive because there is limited 

access, management controls, or visitor services. Some areas along the INHT where there is seasonal 

(wintertime) access and more management controls have less primitive, backcountry operational RSCs. 

Primary recreation opportunities in the planning area consist of big game hunting; fishing; wildlife 

viewing; berry picking; dogsledding, snowmobiling, and OHV use of the INHT; river touring; and 

sightseeing via airplane or helicopter. Because of the planning area’s remoteness and lack of recreation 

facilities or road-based access points, recreation typically takes place as part of a specially permitted event 

or guided tour. For example, big game hunting occurs in Guide Use Areas that are established by the State 

of Alaska Big Game Commercial Services Board. There are 19 Guide Use Areas within the planning area 

(ADCCED 2009). Isolated subsistence fishing by Alaska residents takes place throughout the planning 

area. Guided recreational fishing takes place along the Unalakleet, Yukon, and Kuskokwim Rivers. 

Popular fish species for recreational and subsistence anglers include all five species of Pacific salmon, 

Dolly Varden, arctic char, and arctic grayling. The ADF&G regulates subsistence, sport, and commercial 

fishing. A State license is required to participate in commercial and sport fishing, and in some cases for 

certain types of subsistence fishing (ADF&G 2016a,b). There are abundant opportunities to view moose, 

bears, bald eagles, ospreys, wolves, fox, beaver, and other wildlife. Dogsledding and snowmobiling are 

popular along the INHT and connecting trails that are used for competitive events and transportation. 

River touring, primarily via commercial float trips, take place on the Unalakleet and Kuskokwim Rivers. 

There are few roads, trails, airstrips, or other means to access the planning area. In the winter, snow 

conditions require that visitors access the planning area by air, snowmobile, snowshoeing, or similar oversnow means. There are 126 miles of roads and approximately 260 miles of State-managed winter trails in 

the planning area and. Motorized and pedestrian-based recreation occurs in the winter, especially along 

the INHT, when snow conditions permit. There are 424 miles of trail on the INHT primary trail, and an 

additional 791 miles of connecting and side trails to the INHT. Snow storms, frigid temperatures, and 

little to no sunlight influence the types of outdoor recreation opportunities available to non-residents from 

November through January. From February to April, there is typically an influx of non-residents to 

participate in winter trail-based recreation opportunities. A lack of roads and trails combined with wet 

ground conditions in the late-spring, summer, and early fall often preclude overland OHV, mechanized, 

and pedestrian recreation opportunities throughout much of the planning area. Year-round access is 

primarily by air and waterways. Rivers and bays serve as primary travel corridors and provide access to 

recreation and subsistence resources. When the waterways are not frozen, motorboats are the primary 

mode of travel. In the winter when the waterways are frozen, waterways act as travel surfaces for other 

travel modes, such as snowmobiles, and in some cases, autos. Transportation and access, including the 

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methods of accessing different recreational opportunities, is described in more detail in Section 3.7, 

Travel and Transportation Management. 

The BLM manages five public safety shelters in the planning area, all of which are along the INHT (BLM 

2015a). There are also non-BLM managed hunting and fishing lodges within the planning area that are 

popular destinations for commercial hunting and fishing tours. These lodges are mostly accessible by air 

or boat and are typically open during the summer only. 

Visitors to BLM-managed public lands within the planning area include Alaska residents and those 

traveling from outside the state or country. Alaska’s statewide population is approximately 736,000,

approximately 54 percent of which reside in the Anchorage and the Mat Su economic region, located 

southeast of the planning area (ADNR 2016). For Alaska residents, high gas prices and air travel costs 

limit recreation opportunities in rural areas, such as the planning area (ADNR 2016). More accessible 

recreation options, such as Denali and Kenai Fjords national parks, near Anchorage, are more practical 

and affordable outdoor recreation options for many Alaska residents. In a recent statewide survey of 

Alaska’s youth, responses to an open-ended question indicated Denali National Park and Preserve as the 

most popular park or outdoor recreation area in Alaska. None of the respondents identified a location or 

recreation activity in the planning area (ADNR 2016). 

Tourism is a major component of the Alaskan economy. In 2008, more than 1.7 million people visited 

Alaska and spent nearly $1.6 billion within the state. The largest and fastest growing source of tourism 

revenue for Alaska is the cruise industry, which brings visitors to port cities outside the planning area 

(ADNR 2009). Wildland tourism is a smaller, but essential part of Alaska’s tourism economy. Out-ofstate visitors are attracted to the planning area’s remoteness and opportunities to experience competitive 

events along the INHT. Most out-of-state visitors to the planning area participate in some form of guided 

fishing or big game hunting or are involved with a competitive event on the INHT. Some visitors plan 

their own trips and pay for a chartered aircraft or other means of transportation, but most use the services 

provided by commercial outfitter guides (BLM 2015a). 

Iditarod National Historic Trail 

Congress established the INHT in 1978; it is the only national historic trail to commemorate winter use. 

Originally consisting of 2,300 miles of winter trails that connected Alaska’s rural villages and provided 

access during the Alaskan gold rush, there are now 1,500 miles of the historic trail open for public use, 

including over 700 miles within the planning area. Of that, the BLM manages approximately 200 miles of 

the trail, including 70 miles of Congressionally-designated Primary Route, along with five public shelter 

cabins adjacent to the trail. While the INHT Comprehensive Management Plan (BLM 1986c) guides 

BLM’s management of the trail, the plan does not establish a management corridor. Without a defined 

management corridor it is difficult to evaluate the potential effects of management actions surrounding 

the trail. 

Most wintertime trail use takes place from February to April, although winter use begins when 

sufficiently cold weather and snow coverage enable overland travel. Winter overland travel is mostly via 

snowmobile and dogsled. Alaska residents and those visiting from outside the state and country use the 

trail for competitive events, such as the Iditarod Sled Dog Race, the Iron Dog snowmobile race, and 

various human powered (foot, bicycle, and ski) endurance races. 

The annual Iditarod Sled Dog Race is a nearly 1,000-mile endurance race that takes place in early March. 

The race route annually uses the Farewell Burn and Kaltag Portage segments of the INHT managed by 

the BLM. In 2017, the race start was moved from Anchorage to Fairbanks and the race route bypassed all 

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the planning area, except for the Kaltag Portage segment of the INHT along the Unalakleet River 

(Iditarod 2017). 

The Iron Dog snowmobile race is an approximately 2,000-mile snowmobile race that takes place each 

year in February. The race route uses the Farewell Burn and Kaltag Portage segments of the INHT 

managed by the BLM (Iron Dog Snowmachine Race 2017). 

The various human powered endurance races The Iditarod Trail Invitational also takes place on the INHT 

annually in late February. The 1,000-mile race typically follows the route used by the Iditarod Sled Dog 

Race, and usually crosses the Farewell Burn and Kaltag Portage segments of the INHT managed by the 

BLM. When the Iditarod Sled Dog Race is relocated to a Fairbanks start, the Iditarod Trail Invitational 

follows the route of the Iron Dog race north from Ophir to Ruby (Iditarod Trail Invitational 2017). 

Competitive events are scheduled in late-February and early-March due to the greater amount of daylight, 

milder temperatures and maximum, end-of-season, snow conditions. Observed warmer wintertime 

temperatures since the late 1970s, in response to factors such as climate change, are decreasing snow 

coverage and shortening the winter season (ACRC 2018). Warmer temperatures can also preclude the 

freezing of rivers, wetlands, and tundra required for winter trail use. Since 2014, for example, the Iditarod 

Sled Dog Race has been rerouted or experienced uncharacteristically mild temperatures and lower than 

average little snow coverage. 

Summer use of the INHT is less frequent compared with winter because surface conditions make access 

difficult. Summer use primarily occurs on segments near Anchorage and Nome outside of the planning 

area. Much of the interior portion of the trail is not accessible in the summer due to the predominance of 

wetlands and lack of airplane or floatplane access. Summer recreation on the INHT could increase with 

the expected lengthening of the summer season and warmer summer temperatures, while winter users 

would be competing for use during a shorter season, primarily January through March. Additional details 

regarding the INHT are provided in Section 4.2, National Trails. 

The Rohn Air Navigation Site is a culturally and historically important feature along the INHT. It 

includes a 1,200-foot unmaintained gravel airstrip, a segment of the INHT’s Connecting Trail, and the 

historic Rohn Public Shelter Cabin. The cabin is accessible by air year-round and has been the only 

habitable public shelter along the INHT between Rainy Pass Lodge (25 air miles to the east) and Nikolai 

(60 air miles to the north) for the past century. The cabin is typically a checkpoint for the Iditarod Sled 

Dog Race and the Iron Dog Snowmachine Race. Big game hunters use the cabin as a base camp during all 

seasons. 

Additional details regarding the INHT can be found in Section 4.2, National Trails. 

Unalakleet Wild River 

The Unalakleet River is 90 miles long, 83 miles of which are managed by the BLM as a nationally 

recognized Wild River (BLM 1983). There are no established campsites or public facilities along the river 

and the Unalakleet’s remoteness results in lower recreational use and visitation compared with other 

designated rivers in Alaska. Because the river’s classification is “wild,” BLM’s primary management 

focus is to maintain the river’s free flowing condition, primitive recreation opportunities, 

wildlife/wildlands-oriented use, primitive RSCs, and historical and archeological values. Access to 

recreational opportunities in the river corridor is by snowmobile in the winter months and by boat and 

plane in the summer months. Commercial float trips occur from June through mid-September and provide 

visitors with opportunities to engage in boating, fishing and primitive camping in a pristine, wild setting. 

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In the winter, visitors also use the Unalakleet Wild River Corridor segment for snowmobiling, dog 

mushing, ice fishing, hunting, and trapping. The INHT parallels or passes over portions of the Wild River 

segment and is a popular segment of the INHT for winter recreation when the river is frozen. 

Additional details regarding management of the Unalakleet River can be found in Section 4.3, Wild and 

Scenic Rivers. 

Special Recreation Permits 

Consistent with BLM Manual 2930-1: Recreation Permit and Fee Administration, the BLM issues SRPs 

to guides, outfitters, and event coordinators (BLM 2017b). As of February 2017, there were 24 active 

SRP operations occurring on BLM-managed public lands within the planning area (see Table 3.6.4-1). 

Table 3.6.4-1. Special Recreation Permits in the Planning Area by Type 

Special Recreation Permit (SRP) Type Number of Permits 

Big Game Hunting Guides 18 

Snowmobile Races 1 

Dog Mushing Races 2 

Human powered endurance events 2 

Adventure touring 1 

Total 24 

The BLM requires each permit holder to provide an annual report summarizing the number of trips, 

visitors, and other metrics from the previous year. The BLM also requests that permit holders report on 

social factors, which can include participant survey results and observed encounters with other guides and 

outfitters while in the field. These reports indicate that the presence of other groups and noise from 

firearms increasingly influences opportunities for visitors to experience a complete sense of solitude in a 

wildland setting. 

The economic conditions and trends related to recreation tourism, including commercial guides and 

outfitters, are discussed in Section 5.1, Socioeconomics, Environmental Justice, and BLM Support for 

BSWI Communities. 

3.6.5 Resource Changes: Trends and Forecasts 

While overall recreation use in the planning area is expected to remain relatively low compared with other 

locations outside the planning area, the types, locations, and intensity of use are expected to change 

throughout the life of the plan, especially in response to climate change, growing popularity of the INHT, 

new technology, and new forms of recreation. The anticipated lengthening of the summer season is 

expected to compress the winter recreation season, which would decrease winter recreation opportunities, 

such as dogsledding and snowmobiling, along the INHT and other winter recreation activities throughout 

the planning area. There are segments of the INHT that are not used for recreation or special events. The 

management plan for the INHT only covers the designated sections, and consequently provides no 

guidance on the non-designated portions of the trail. With an increasing trend for recreation and general 

transportation use along the route, there will continue to be a need for recreation and historic preservation 

planning. 

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Section 3. Resource Uses Appendix M: BSWI Affected Environment Report 

The number of permitted events and tours along the INHT and elsewhere in the planning area has been 

increasing over the past ten years, which requires careful scheduling to avoid conflicts between permittees 

and participants. The increase in requests for SRPs, such as a permit request in 2017 to allow a private 

dog mushing adventure with helicopter support, appears to be a trend, which may require management 

controls to prevent recreation conflict. The BLM is collaborating with ADNR to identify ways reduce 

competition and conflict among recreation uses and improve overall user experiences to address the 

emerging issue of crowding along the INHT. 

New vehicle technology may also improve access and increase associated recreational use. More frequent 

use of eight-wheel-drive semi-amphibious OHVs instead of typical four-wheel drive OHVs is expected to 

extend summertime access into areas previously inaccessible because of saturated soil conditions. The use 

of unmanned aerial systems (UAS), or drones, could gain popularity in the planning area, especially in 

association with commercial recreation activities. Outfitters may request the use of UAS to capture aerial 

footage of individual tours for purchase by users or for marketing purposes. Guides and outfitters will 

continue to provide opportunities for big game hunting and commercial fishing, which may increase 

demand for OHV and UAS uses. 

3.7 Travel and Transportation Management 

3.7.1 Introduction 

This section describes the laws, regulations and policies related to travel and transportation management, 

as well as the resource indicators that will be used to evaluate impacts to travel and transportation 

management. The section also includes a discussion of the current condition of travel and transportation 

within the project area and trends in resource conditions that may affect travel and transportation 

management in the future. 

3.7.2 Laws, Regulations, and Policies 

Travel and transportation management is a comprehensive approach to on-the-ground management and 

administration of travel and transportation networks of roads, primitive roads, primitive routes, trails, and 

areas associated with the use of BLM-managed public lands (BSWI Draft RMP/EIS, Map 3.3.7-1). Travel 

and transportation management also includes the management of vehicle types and classes. Additionally, 

travel and transportation management broadly refers to planning decisions, route inventory and mapping, 

signing area and route designations, education and interpretation, law enforcement, easement acquisition, 

monitoring activities, and other measures necessary for providing access to and across BLM-managed 

public lands. Travel and transportation management is applicable to a wide variety of uses, including 

recreational, traditional, authorized, commercial, educational, and for other travel and transportation 

purposes. It pertains to all forms of motorized and non-motorized access or use, such as foot, pack stock 

or animal-assisted travel, mountain bike, OHV, and other forms of transportation. 

BLM Handbook H-8342, Travel and Transportation (BLM 2012b) and BLM Manual 1626, Travel and 

Transportation Management (BLM 2016g) provide specific guidance for preparing, amending, revising, 

maintaining, implementing, monitoring, and evaluating BLM land use and travel management plans. 

Land use planning decisions contained within this document are those that provide direction for land 

management actions and subsequent site-specific travel and transportation implementation plans. Travel 

and trails management decisions for this document would include OHV area designations and 

identification of TMAs. 

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BLM regulation 43 CFR Part 8340 recognizes recreational OHV use as an “acceptable use of public land

wherever it is compatible with established resource management objectives.” The regulation also 

establishes the criteria for designating public motorized access under three possible categories based on 

BLM land use planning decisions that consider resource protection and public safety. The options for 

public lands OHV access as (1) open, which allows for unlimited travel, including cross-country, (2) 

limited, where motorized use is restricted to meet specific resource management objectives, and (3) 

closed to motorized use. It also defines “off-road vehicle,” an older term that has been replaced by the 

term “off-highway vehicle,” or OHV. Subpart 8342 prohibits recreational OHV areas or trails in officially 

designated wilderness areas or primitive areas. 

Through the RMP planning effort, the BLM designates lands in the decision area as open, limited, and 

closed for public motorized access and identifies areas in limited designations where future 

implementation-travel management planning would occur. The BLM would complete implementation 

travel management planning within areas in limited designations within 5 years after the completion of 

the RMP. Although the land use planning-level designations of open, limited, or closed address only 

public motorized access, subsequent implementation-level travel management planning would address all 

modes of public travel, including non-motorized travel. 

The RMP also establishes TMAs to address area-specific travel issues and identify where unique travel 

management circumstances require a particular focus, specific management prescriptions, or additional 

analysis. The TMAs identify discrete areas within the larger planning area for consideration of special 

resource characteristics and manageability of the area. 

ANILCA section 811 provides that rural residents engaged in subsistence uses shall have reasonable 

access to subsistence resources on the public lands and provides for use of snowmobiles, motorboats, and 

other means of surface transportation traditionally employed for such purposes by local residents, subject 

to reasonable regulation. ANILCA section 1110 provides for the use of snowmobiles, motorboats, 

airplanes, and non-motorized surface transportation methods for traditional activities and for travel to and 

from villages and homesites within CSUs, National Recreation Areas, National Conservation Areas, and 

WSAs, subject to reasonable regulation to protect the natural and other values of the area. 

Under ANCSA, 43 U.S.C. 1616(b) and 43 CFR 2650.4-7, the BLM reserves and manages transportation 

easements (Section 17(b) easements) when the BLM conveys land to a Native corporation to allow the 

public to cross private property to reach public lands and major waterways. 

3.7.3 Resource Indicators 

The conditions that are established in the discussions below provide a baseline for travel and 

transportation management, which the impact analysis will be based on. The following indicators, along 

with qualitative discussions, will be used to evaluate impacts associated with management decisions in 

the BSWI Draft RMP/EIS: 

• Change in ability to access existing routes, areas, or BLM lands in general 

• Change in ability of users with various types of vehicles to access areas 

• Change in aircraft landing accessibility 

• Change in airspace that aircraft are allowed to access over BLM lands 

• Acres of an alternative that would be designated as an ACEC 

• Acres of land where ANCSA 17(d)(1) withdrawals would be retained 

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Section 3. Resource Uses Appendix M: BSWI Affected Environment Report 

• Acres of land where FLPMA withdrawals would be pursued 

• Acres of land within ROW exclusion and avoidance areas 

• Acres that would be excluded from wind energy development 

• Change in the size of the transportation network 

• Increase or decrease in opportunities for unauthorized use of routes 

• Increase or decrease in the potential locations where routes may be placed 

• Physical degradation or expansion of route 

• Increase or decrease in ability to access emergency services/facilities 

• Change in the number of private transporters 

• Assistance or hindrance of implementing travel and transportation management actions 

3.7.4 Current Conditions 

Area Profile 

The following profile of the planning area, including summer and winter uses, is summarized from the 

BSWI AMS (BLM 2015a). 

The planning area encompasses one of the most remote, roadless areas in the U.S. Travel in the planning 

area is restricted seasonally and by weather to an extent largely inconceivable to residents of the 

contiguous 48 states. The planning area is virtually roadless, with only a handful of short roads serving 

local communities, or remaining from past human activities. Additionally, the planning area is not 

connected by road to the remainder of Alaska. Almost all of the existing roads in the planning area are 

located on lands managed by entities other than the BLM. 

Year-round transportation for travel, postal service, and freight hauling depends on commercial air 

service. The State maintains airfields at most inhabited communities. Larger communities (e.g., Bethel, 

Aniak, McGrath, and Unalakleet) are served by daily commuter air service originating from Anchorage. 

In turn, these communities are the hub for small plane transport to smaller outlying villages (e.g., Holy 

Cross, Grayling, and Sleetmute). Some communities have less-than-daily air service or no air service at 

all (e.g., Nikolai and Takotna). 

Most bulk freight (fuel, dry goods, building materials, vehicles) are shipped by ocean and river-going 

barges from Anchorage or Seattle, Washington, in summer months. As a portion of the total quantity of 

freight hauled, only a small percentage is hauled by air, due to high prices. 

Community road systems typically consist of a crisscross grid within the built-up portion of the 

community, and to community infrastructure such as the local airstrip, riverside boat landing site, landfill, 

telecommunication sites, community water intake or gravel pits. Except for the largest communities, snow 

is not removed from roads in the winter and these community roads become impassable to automobiles in 

winter (November through May), with residents instead relying primarily on snowmobiles or walking for 

transportation and access. 

The few extended road systems found in the planning area are historic remnants of mining and military 

infrastructure, such as found near the towns of Takotna, McGrath, Unalakleet, or the ghost towns of Flat 

and Ophir. 

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Appendix M: BSWI Affected Environment Report Section 3. Resource Uses 

In general, many planning area residents rely on “four-wheelers” (quad-type OHVs with a straddle-type 

seat, also commonly known as all-terrain vehicles [ATVs]), multi-person utility terrain vehicles with sideby-side seating, or snowmobiles for in-town transportation throughout the year. This is partially due to the 

high cost of shipping and maintaining an automobile in these communities (vehicles have to be barged or 

flown in to the local community), as well as the high cost of fuel. 

Current surface uses and use areas or use routes can be categorized as summer-related or winter-related. 

Summer-related Use 

The season of summer-related use for the purpose of this document is defined as the period during which 

lands and waterways are not frozen. The demand for non-mechanized and non-motorized overland 

summer use is almost non-existent; therefore, the discussion of overland summer travel pertains to 

motorized use only. 

The favored motorized/mechanized vehicles within the planning area are small one and two person OHVs 

with four-, six- or eight-wheel drive. Most OHVs are untracked and rely on wheels and low pressure tires 

for traction, although a few do exist with after-market track units. Eight-wheel-drive ARGO semiamphibious submersible OHVs are a favorite for hunters in areas with wet bogs, but have less utility in 

towns and, therefore, are used mostly for hunting and gathering. Remote BLM-managed lands within the 

planning area are accessed by both commercial air charter operations and non-commercial pilots using 

single engine “bush” aircraft, mostly for non-subsistence hunting of large wildlife (e.g., bear, moose, 

muskox). These “Cub” strips (named for the Cessna Supercub aircraft often used for access) are 

undeveloped, unmaintained areas found on river sand and gravel bars, or upland areas, suitable for small 

aircraft lands, and are unrestricted on BLM-managed lands. In a few cases, due to proximity to local 

communities and large numbers of target species, some strips see significant use during local hunting 

seasons. 

Motorboats are commonly used throughout the planning area for subsistence and recreational purposes 

and to access remotes sites, including those lands managed by the BLM. In addition, jet boat and airboat 

use is becoming more common in Alaska to access lands (ADNR 2016). In some cases motorboats are 

used to transport OHVs to remote areas in Alaska. 

On BLM-managed public lands in the planning area, there are no designated summer trails or travel 

routes, and no designated primitive roads.2 Almost all overland summer trails evident today within the 

planning area are the result of OHV use in the past two to three decades for subsistence and recreation 

uses. While the INHT is still used today, it is considered to be a winter trail and not suitable for summer 

motorized use. 

User objectives largely determine where use occurs and what type of equipment is used for access, in 

combination with limitations imposed by terrain. Summer overland travel is largely oriented to harvesting 

of subsistence resources, including wildlife, fish, berries, and firewood, with limited amounts of use for 

guided hunting, and casual individual use. Summer overland travel is rarely undertaken for inter-village 

transportation, and summer overland travel to private cabins and/or inholdings is virtually non-existent on 

BLM-managed public lands as most inholdings are accessed by motorboat. Summer overland 

2 “Primitive roads” refers to a class of BLM transportation route based on the type of use, the other classes including 

roads and trails. Roads are passable by automobiles, primitive roads by high clearance vehicles, and trails by offroad vehicles, foot, or stock only. 

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Section 3. Resource Uses Appendix M: BSWI Affected Environment Report 

transportation by “cat trains” (bulldozer pulling a trailer with fuel, equipment and crew quarters) for 

purposes of mineral exploration is nearly non-existent due to impracticality. OHV use for installation of 

infrastructure does occur, and is usually localized to small project areas, with equipment usually airlifted 

or barged to the work site, and use limitations emplaced as part of the permit for the facility 

Generally throughout the planning area, route use patterns typically start at a community or an access 

point along a community road, river-boat landing site, or airstrip, and radiate outward as terrain permits, 

with routes leading to the location of potential subsistence resources. Most summer overland routes in the 

planning area are located in terrain that is treeless due to climatic conditions, presence of permafrost, soil 

types, wetlands, and/or elevation. The majority of current routes on BLM-managed public lands are 

located in alpine settings, although the beaches lining Norton Sound are also used as they provide ready 

access from watercraft to hunting, fishing, berry and firewood resources in nearby uplands. 

Almost all routes have been established casually, and without regard to surface soil and vegetation 

conditions or the viability of repeated use of the route. Trail improvements or construction outside of 

communities are rare, except improvements for immediate passage (e.g., brush cutting, temporary 

bridges). Few if any routes meet the guidelines for “sustainable trail design” as commonly described as 

best management practices in technical publications (Meyer 2013). As a result, route braiding (the 

widening of a route or the establishment of a new parallel route), rutting, and waterway interception 

frequently occurs where users pass over wetlands and disturb the wet soils. Impact area can extend to 

dozens or hundreds of feet or more in width, and miles in length. In contrast, the rocky soils found in 

alpine areas are more resilient to OHV passage, and usually show limited signs of route braiding (Leung 

and Marion 1996; Wiedmer 2002). 

Impacts of OHV use on the natural landscape are documented and recognized in Alaska (Arp and 

Simmons 2012; Jubenville and O’Sullivan 1987; Racine and Ahlstrand 1991; Slaughter et al. 1990; 

Sparrow et al 1978). The biological effects of OHV use can include the interception and redirection of 

watercourses, alteration of fish spawning and rearing habitat via siltation or dewatering, the physical 

alteration and destruction of fish and bird habitat, along with changes to vegetation species composition. 

OHV use may also diminish the viewsheds of otherwise unaltered landscapes, and impede non-motorized 

use of travel routes, both historic and new (Ahlstrand and Racine 1993; Wilkinson 2001; Rinella and 

Bogan 2003; Arp and Simmons 2012; Slaughter et al. 1990). 

Winter-related Use 

The season of winter use is defined as the period during which lands and waterways are frozen. Most onland winter travel routes are modern-day adaptations of historic routes that crossed the planning area and 

linked communities within the planning area. The most-recognized winter overland trail on BLM lands in 

the planning area is the congressionally designated INHT. Approximately 67 miles of the Primary Route 

of the INHT exist on BLM-managed public lands within the planning area, and another 15 miles of 

side/connecting trails that are considered part of the trail system. 

Winter overland travel is undertaken for inter-village travel, subsistence, sport-hunting, trapping, ice 

fishing, firewood collection, casual recreation, guided tours, and medium and long-distance trail-based 

competitive events, such as the Iditarod Trail Sled Dog Race and Irondog (snowmobile) Race. 

Occasionally a “cat train” consisting of a bulldozer pulling sledge-mounted fuel, equipment, and crew 

quarters will traverse a route within the planning area that passes over BLM-managed lands, typically 

between a community and a mining area. 

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Appendix M: BSWI Affected Environment Report Section 3. Resource Uses 

A system of ice roads is usually established in winter on the Kuskokwim River from Bethel to nearby 

communities, allowing residents to drive automobiles between communities, although these routes are 

located wholly on State of Alaska navigable waters and distant from BLM-managed public lands. 

Within the planning area, there are no single winter use designated trails, such as “ski-only” trails. 

Virtually all winter trail use is shared between motorized and non-motorized users. 

While the majority of winter overland travel is motorized via snowmobile, there is a significant amount of 

non-mechanized / non-motorized travel by dogsled on the INHT as part of the Iditarod Sled Dog Race 

and other regional qualifying dog sled races. Additionally, there is a small amount of non-mechanized 

travel that includes cross-country skiing, snowshoeing, and foot travel, both casually and as part of 

organized events. Also, a small amount of mechanized/non-motorized travel occurs using the newly 

developed class of fat-tire bikes (i.e., mountain bikes with large, oversize, low pressure tires built for 

over-snow travel) as part of muscle-powered long-distance endurance races. 

Given frozen and snow-covered terrain and advances made in snowmobile technology, almost all of the 

planning area is physically accessible to snowmobiles, although most use is found on inter-village travel 

routes, near communities for casual riding, and to and from remote areas for the harvest of wildland 

resources. An estimate of the total mileage of winter travel routes within the planning areas is not 

available. 

For ease of passage, many routes follow frozen waterways for much of their length, including both large 

rivers and small waterways. Because most of the travel is point-to-point between communities and the 

straightest alignment is preferred, sinuous river alignments are often shortcut, with travel routes passing 

through intervening segments of forest or tundra. Brush and vegetation removal along non-Iditarod Trail 

segments is usually undertaken by local users. Along the INHT, a combination of race volunteers and 

BLM-supported efforts have attended to both trail brushing and trail route marking over the past three 

decades. 

The effects of snowmobile trail use are highly variable, depending on the typical winter conditions found 

at a particular site. Narrow (4 feet to 6 feet wide) corridors cleared of major vegetation have been 

established extensively through closed canopy mixed deciduous/conifer forest (e.g., paper birch/white 

spruce, or willow/cottonwood) and open canopy conifer forest (e.g., black spruce). 

The annual amount of snow (or ice) at any given site is a major determinant of the effect of motorized 

winter trail use on native vegetation, local waterways, and other biota of concern (along with pre-existing 

permafrost conditions). Areas with deep snow typically show lesser changes to vegetation from overland 

travel than areas with a shallower snowpack. Areas with a typically shallow snowpack are prone to a 

deeper below-ground freeze due to snow compaction and reduction of the insulating effects of snow. This 

can ultimately result in a change in vegetation species composition along the travel-way, as the ground 

under the travel-way remains colder longer than the surrounding, uncompacted lands, ultimately delaying 

budding and growth of plants. Additionally, the frozen subsurface often impedes water drainage and 

captures or ponds water in locations that may not otherwise have such conditions present (Pers. obs., 

Keeler 2012, 2013). 

Existing Travel and Transportation Management 

To comply with BLM regulation 43 CFR 8342.1, all BLM-managed public lands must be categorized 

with one of the following designations: 

• Open: OHVs may travel anywhere; cross-country travel is permitted. 

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Section 3. Resource Uses Appendix M: BSWI Affected Environment Report 

• Limited: OHVs are restricted to certain areas or specific trails, with restrictions that can include 

number of vehicles, vehicle weight, type of vehicle, seasonal limitations, or travel restricted to 

designated trails. 

• Closed: No OHV activity is allowed in these areas. 

ANILCA section 811 ensures that rural residents shall have reasonable access to subsistence resources on 

public lands. Currently, all BLM-managed public lands within the planning area are undesignated and 

allow ATV and snowmobile cross-country use. This allowed use does not pertain to large cat-trains, 

which are authorized through a permit (such as overland moves or mineral exploration) and are subject to 

applicable use stipulations under NEPA. The undesignated status in the planning area includes BLMmanaged lands with Congressional designations (primarily the INHT and the Unalakleet Wild River 

Corridor) that are potentially vulnerable to impacts from OHV use; subject to ANILCA access provisions 

(see Sections 4.2, National Trails, and 4.3, Wild and Scenic Rivers). Similarly, ACECs and HVWs are 

undesignated without limit to OHV and snowmobile use. To date, these areas have been largely protected 

due to their remote location and a lack of demand for uses that could result in resource impacts. 

Consistent, interagency management of OHV routes that cross in and out of BLM-managed public lands 

is an issue both within the planning area and statewide. One such issue is the implementation of 

consistent vehicle weight limitations between State and BLM lands; another is the management of 

ANCSA Section 17(b) transportation easements. 

The generally allowable uses on neighboring State lands for using a recreation-type vehicle off-road or 

ATV allows a curb weight of up to 1,500 pounds. The State defines curb weight as the weight of a vehicle 

with a full tank of fuel and all fluids topped off, but with no one sitting inside or on the vehicle and no 

cargo loaded. Curb weight is much more difficult to determine and enforce, especially in remote areas. 

BLM currently does not have any OHV weight restrictions in place within the planning area, but in other 

areas around the state, BLM has established a gross vehicle weight rating that enables use of most classes 

of small OHVs, and is consistent with existing State of Alaska weight restrictions. 

ANCSA Section 17(b) transportation easements are found extensively within the planning area, and play 

a significant role in providing public access across private native corporation lands. Around 70 Section 

17(b) easements are found within the planning area. OHV use on ANCSA Section 17(b) easements are 

subject to a variety of limitations determined at the time of easement establishment, including common 

allowable uses, and seasonal and vehicle weight restrictions, and easement type (i.e., trail, road, or site). 

Many ANCSA Section 17(b) easements within the planning area are limited to winter use only. BLM 

represents the federal government regarding to realty issues associated with individual easements, 

particularly petitions for easement vacations and/or relocations. The de facto federal policy for 

determining the federal agency responsible for marking of a particular easement is based on the 

destination of the easement. That is, the federal land unit (and associated manager) to which a particular 

easement provides access is expected to provide necessary marking of that easement, in order to prevent 

trespass onto adjacent private lands. The extent and type of marking is assumed to be determined by each 

respective federal land manager accessed by the easement. Federal law specifies that trespassing and use 

conflict issues associated with ANCSA Section 17(b) easements is to be handled by local law 

enforcement and does not provided any funding for such actions. BLM has published outreach materials 

to inform the public about their rights and responsibilities related to ANCSA Section 17(b) easements; 

outside of these informational materials, this document will not make recommendations for the 

management of 17(b) easements. 

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Appendix M: BSWI Affected Environment Report Section 3. Resource Uses 

In terms of managed BLM land uses that could generate demand for overland transportation, the disposal 

of public BLM lands for private cabins or homesteads was discontinued three decades ago and is not 

expected to be continued any time in the future. The development of commercial lodges or structures 

associated with commercial ventures is possible, via a prescribed BLM permitting process. Temporary 

commercial land use for commercial ventures such as guided hunts and hunting camps are regulated 

through BLM’s SRP process. This includes route monitoring and agency review of overland OHV use, 

along with use stipulations. 

Motorboats, inboard jet motorboats, airboats, and hovercraft access to BLM-managed public lands within 

the planning area is unrestricted, subject to future management decisions. 

Fixed-wing aircraft and helicopter access to BLM-managed public lands within the planning area is also 

unrestricted. Minimal hand clearing of airstrips is allowed to move small obstacles and brush. Any other 

surface-disturbing improvements such as vegetation removal or site leveling require a permit from the 

BLM. 

3.7.5 Resource Changes: Trends and Forecasts 

Potential transportation corridors are under review by the State of Alaska and include two road and ROW 

corridors: the Western Alaska Access Planning Study (DOWL HKM 2010), also known as ”the road to 

Nome,” and the Yukon-Kuskokwim Energy Corridor Plan, both of which would cross BLM-managed 

public lands within the planning area. The Western Alaska Access Planning Study has evaluated three 

routes, including the preferred Yukon River Corridor, to connect the Nome-Council Road to the existing 

road system in the Fairbanks area. The proposed final stage of the Yukon River Corridor is between the 

villages of Koyuk and Nulato, and would cross BLM-managed public lands in the Nulato Hills region of 

the planning area. The Yukon-Kuskokwim Energy Corridor Plan evaluated overland transport routes in 

the Portage Mountains area to connect the Yukon and Kuskokwim Rivers for fuel and freight transport 

purposes. The assessed routes would cross BLM-managed lands to the northeast of Upper and Lower 

Kalskag. 

Specific evidence of climate change affecting travel and transportation management has not been 

recorded in the planning area. However, impacts by a warming atmosphere evidenced by: increases in 

frequency and extent of wildfire (Chapin et al. 2008); increases in frequency and extent of insect 

outbreaks; warmer growing season temperatures (Hinzman et al. 2005); and permafrost thaw and 

deepening of the soil active layer. Due to these impacts, travelers are now faced with unreliable 

conditions during the summer months and periods before and after freeze up. 

Atmospheric warming has primarily occurred during winter months in the past several decades (see 

Section 2.2, Climate Change), affecting winter travel via snowmobile. The lengthening of the summer 

season has likely reduced the functional time period for winter travel. Anecdotal reports from residents of 

the planning area indicate the annual season for winter travel has been shortening over the past halfcentury. Delayed freeze-up, diminished snowfall, and rain/warm weather episodes have become more 

common in early winter (November-December), and where winter travel was once possible for much of 

the month of April, travelers are now faced with unreliable conditions starting in early April. If extremely 

dry, low-snowfall, and anomalously warm winters similar to that experienced in 2013–14 and 2014–15 

continue to occur again in future years, winter travel season within the planning area may be shortening 

by one to two months. Additionally, in addition to shortened travel seasons, winter travel may be more 

difficult and/or dangerous due to unreliable ice conditions on riverine routes and crossings. 

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Section 3. Resource Uses Appendix M: BSWI Affected Environment Report 

3.8 Renewable Energy 

3.8.1 Introduction 

This section describes the laws, regulations and policies related to renewable energy, as well as the 

resource indicators that will be used to evaluate impacts to renewable energy. The section also includes a 

discussion of the current condition of renewable energy resources within the project area and forecasts 

related to potential renewable energy opportunities within the project area in the future. 

The BLM Land Use Planning Handbook (BLM 2005) requires that plans address existing and potential 

development areas for renewable energy projects consistent with the goals and objectives for natural 

resources in the planning area. The BLM describes criteria that must be met for economically feasible 

utility-scale solar, wind, and biomass development in Assessing the Potential for Renewable Energy on 

Public Lands (BLM-DOE 2003). The assessment reviewed the potential for concentrated solar power, 

wind, biomass, and geothermal on BLM lands in the west. Alaska was not included in this report. 

However, some of the site screening criteria outlined in this report were used to determine potential for 

renewable energy development in the planning area. 

Some renewable energy resources in the planning area are considered to be very low potential for 

development: 

• Tidal and wave power are not present, and has not been demonstrated to work yet anywhere in 

Alaska, and in only a few places in the world. 

• Only sites with a solar resource of 6 kWh/m2/day or greater would likely be commercially 

developed (BLM-DOE 2003). Figure 3.8.1-1 (National Renewable Energy Laboratory 2007) 

shows that the planning area only has 3-4 kWh/m2/day, which is consistent with the rest of the 

state with the exception of a few areas along the northern Arctic coast, which are between 2.5 and 

3 kWh/m2/day. To date, BLM has not authorized any photovoltaic facilities for commercial 

power production, nor has any interest been expressed by industry in developing such facilities on 

BLM-managed public lands within the planning area (see BSWI Draft RMP/EIS, Map 3.3.8-4). 

• Geothermal power is considered to be renewable power; however, it is a leasable resource, much 

like oil, gas, and coal. It is discussed in more detail under Section 3.4 of this document. It should 

be noted that there are few identified geothermal resources in the planning area. 

• Biomass heat has the potential to supply up to 80 percent of village energy requirements through 

individual and community biomass heat projects. Biomass is readily available on lands adjacent 

to the villages and will potentially come from BLM lands in the future. At least 12 villages within 

the planning area have completed biomass feasibility studies for one or more community 

buildings and are awaiting funding to complete the projects. 

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Appendix M: BSWI Affected Environment Report Section 3. Resource Uses 

Figure 3.8.1-1. Average Solar Irradiance for Alaska 

These forms of renewable energy are considered to have very low potential for development in the 

planning area, and therefore will not be discussed further in this section. The remaining potential 

renewable resources that will be considered in this planning document are wind, hydropower, biomass 

(harvested plant material), and peat. 

Due to the isolated nature of the planning area, the low population, lack of roads or transmission lines, it 

is felt that renewable power projects, if constructed, are likely to be small, and located in the immediate 

vicinity of the local communities. In such an instance, it is unlikely that these facilities would impact 

BLM-managed public lands in the planning area. Land around the local communities has been largely 

selected under ANILCA, and very little BLM-managed land exists within 30 miles of the communities 

(Table 3.8.1-1). In addition, the markets for energy in this area are relatively small, meaning such 

developments are likely to have limited impact. 

Table 3.8.1-1. Distribution of BLM-Managed Public Land in Relation to Local Communities 

Local Communities Distance from BLM Distance from BLM 

Lands (miles) Local Communities Lands (miles) 

Akiachak 44.0 Mertarvik 102.7 

Akiak 37.6 Mountain Village 61.9 

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Section 3. Resource Uses Appendix M: BSWI Affected Environment Report 

Local Communities Distance from BLM 

Lands (miles) Local Communities 

Distance from BLM 

Lands (miles) 

Alakanuk 91.2 Napakiak 64.8 

Aniak 2.5 Napaskiak 57.4 

Anvik 4.0 Newtok 102.5 

Atmautluak 53.9 Nightmute 126.5 

Bethe 57.1 Nikolai 6.9 

Chefornak 128.6 Nunam Iqua 105.1 

Chevak 121.6 Nunapitchuk 54.2 

Chuathbaluk 3.8 Oscarville 58.5 

Crooked Creek 0.6 Pilot Station 33.2 

Eek 76.0 Pitkas Point 46.9 

Emmonak 86.2 Red Devil 0.6 

Flat 4.3 Russian Mission 1.8 

Grayling 2.3 St. Mary's 46.9 

Holy Cross 4.6 St. Michael 5.4 

Hooper Bay 138.8 Scammon Bay 120.1 

Kasigluk 56.2 Shageluk 2.3 

Kipnuk 137.3 Sleetmute 2.9 

Kongiganak 110.0 Stebbins 6.3 

Kotlik c 50.0 Stony River 1.1 

Kwethluk c 45.7 Takotna 1.6 

Kwigillingok 121.3 Toksook Bay 130.8 

Lake Minchumina 8.9 Tuluksak 30.1 

Lime Village 1.6 Tuntutuliak 87.3 

Lower Kalskag 11.3 Tununak 128.1 

McGrath 6.7 Unalakleet 4.0 

Marshall 6.2 Upper Kalskag 10.3 

3.8.2 Laws, Regulations, and Policies 

The following laws, regulations and policies are relevant to the consideration of renewable power 

resources in the planning area. 

Secretarial Order No. 3285 

Secretarial Order No. 3285, issued on March 11, 2009, “Addressing the Impacts of Climate Change on 

America's Water, Land, and Other Natural and Cultural Resources,” made production and transmission of 

renewable energy on public lands a priority for the DOI. This Order establishes a DOI-wide approach for 

applying scientific tools to increase understanding of climate change and to coordinate an effective 

response to its impacts on tribes and on the land, water, ocean, fish and wildlife, and cultural heritage 

resources that the DOI manages. 

Energy Policy Act of 2005 

The Energy Policy Act of 2005 (P.L. 109–58) changed U.S. energy policy by providing tax incentives 

and loan guarantees for renewable energy production. Provisions relevant to the document include tax 

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Appendix M: BSWI Affected Environment Report Section 3. Resource Uses 

credits for wind and other alternative energy producers; grants for biomass projects; studies of renewable 

energy resources by the Department of Energy; designation of National Interest Electric Transmission 

Corridors where there are significant transmission limitations adversely affecting the public. 

The Energy Independence and Security Act of 2007 

This Act was designed to move the U.S. toward greater energy independence, to increase the production 

of clean renewable fuels, and support modernization of the nation’s electricity transmission and

distribution system. 

The BLM Energy and Mineral Policy (2008) 

The policy has several requirements directly impacting development of renewable power projects. These 

include the following: 

• The BLM land use planning and multiple-use management decisions will recognize that energy 

and mineral development can occur concurrently or sequentially with other resource uses, 

providing that appropriate stipulations or conditions of approval are incorporated into 

authorizations to prevent unnecessary or undue degradation, reduce environmental impacts, and 

prevent a jeopardy opinion. 

• Land use plans will incorporate and consider energy and geological assessments as well as energy 

and mineral potential on public lands through existing energy, geology and mineral resource data, 

and to the extent feasible, through new mineral assessments to determine mineral potential. 

Partnerships with the National Renewable Energy Laboratory, federal and State agencies, such as 

the USGS and State geologists, to obtain existing and new data will be considered. 

• Withdrawals and other closures of the public land must be justified in accordance with the DOI 

Land Withdrawal Manual 603 DM 1 and the BLM regulations at 43 CFR 2310. Petitions to the 

Secretary of the Interior for revocation of land withdrawals in favor of energy and mineral 

development will be evaluated through the land use planning process. 

• The BLM endorses sustainable development that encourages social, environmental, and economic 

considerations before decisions are made on energy and mineral operations. The BLM actively 

encourages private industry development of public land energy and mineral resources, and 

promotes practices and technology that least impact natural and human resources. 

• The BLM will adjudicate and process energy and mineral applications, permits, operating plans, 

leases, rights-of-ways, and other land use authorizations for public lands in a timely and efficient

manner and in a manner to prevent unnecessary or undue degradation. The BLM will require 

financial assurances, including long-term trusts, to provide for reclamation of the land and for 

other purposes authorized by law. Prior to mine closure, reclamation considerations should 

include partnerships to utilize the existing mine infrastructure for future economic opportunities 

such as landfills, wind farms, biomass facilities, and other industrial uses. 

• Energy and mineral-related permit applications will be reviewed consistent with the requirements 

of NEPA and other environmental laws. The BLM will work closely with federal, State, and 

tribal governments to reduce duplication of effort while processing energy and mineral-related 

permit applications. 

• The BLM will monitor locatable, salable and leasable mineral operations and energy operations 

to ensure proper resource recovery and evaluation, production verification, diligence, and 

enforcement of terms and conditions as applicable. The U.S. will receive market value for its 

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Section 3. Resource Uses Appendix M: BSWI Affected Environment Report 

energy and mineral resources unless otherwise provided by statute, and royalty rates will be 

monitored and evaluated to protect the public interest. 

ANILCA Title XI, Rights-of-way for Transportation or Utility Systems 

Should a Title XI application be received by the BLM for large-scale utility or energy project in the 

planning area, the BLM will consider alternative locations consistent with the Title XI process. 

Notwithstanding any decision in this document and in accordance with ANILCA Title XI, ROWs for 

transportation or utility systems will be considered throughout the National System, CSUs, and National 

Landscape Conservation System (NLCS) units are excluded from wind energy uses. Any approval or 

disapproval of these ROWs will be consistent with the provisions of ANILCA. 

FERC Permitting Requirements 

The Energy Policy Act of 2005 gave the Federal Energy Regulatory Commission (FERC) permitting 

responsibilities that are applicable to renewable power, including reviews of electric transmission projects 

under limited circumstances; and licenses and inspects private, municipal, and State hydroelectric 

projects. 

NEPA 

NEPA requires federal agencies to assess the environmental effects of their proposed actions prior to 

making decisions. The range of actions covered by NEPA is broad and includes making decisions on 

permit applications, adopting federal land management actions, and constructing highways and other 

publicly-owned facilities. Using the NEPA process, agencies evaluate the environmental and related 

social and economic effects of their proposed actions. Agencies also provide opportunities for public 

review and comment on those evaluations. This act would apply to any large-scale renewable energy 

development. 

Alaska Energy Authority Rural and Statewide Energy Programs (AS 42.45) 

This regulation established the power cost equalization and rural electric capitalization fund for 

equalizing power cost per kilowatt-hour statewide. It also makes grants to eligible utilities under AS 

42.45.180 to improve the performance of the utility. 

Alaska Energy Authority Regulations (3 AAC 105.010 - 3 AAC 109.900) 

These regulations created the AEA as an independent corporation with the mission to “reduce the cost of

energy in Alaska.” AEA is the State's energy office and lead agency for statewide energy policy and 

program development. AEA’s core programs work to diversify energy Alaska’s energy portfolio, lead 

energy planning and policy, invest in Alaska’s energy infrastructure and provide rural Alaska with

technical and community assistance. AEA also manages the Renewable Energy Fund, the Emerging 

Energy Technology Fund, the Power Cost Equalization Program and various Energy Efficiency and 

Conservation Programs. 

Alaska Renewable Energy Fund/Task Force/Assistance Act 

The Alaska Renewable Energy Fund (REF) provides benefits to Alaskans by assisting communities 

across the state to reduce and stabilize the cost of energy. The program is designed to produce costeffective renewable energy for heat and power to benefit Alaskans statewide. The REF was established by 

the Alaska State Legislature in 2008, and extended 10 years in 2012. The REF is managed by the AEA 

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Appendix M: BSWI Affected Environment Report Section 3. Resource Uses 

and provides public funding for the development of qualifying and competitively selected renewable 

energy projects in Alaska. 

Alaska Sustainable Energy Act 

The Alaska Sustainable Energy Act stipulates that Alaska will meet 50 percent of its energy needs via 

renewable power by 2025. It contains provisions for renewable tax production credits, and emerging 

technology fund, a renewable energy fund, and alternative energy loans. 

3.8.3 Resource Indicators 

The conditions that are established in the discussions below provide a baseline for renewable energyrelated values, which the impact analysis will be based on. The following indicators, along with 

qualitative discussions, will be used to evaluate impacts associated with management decisions in the 

BSWI Draft RMP/EIS. 

• Acreage available for development of renewable resources and access to that acreage 

• Acreage available for transmission of energy from sources to the users 

• Additional development cost for renewable energy projects 

3.8.4 Current Conditions 

Wind Resources 

The AEA, through the REF, is developing wind energy projects in Alaska’s western and southwestern

areas (AEA 2014). The potential to use wind as a supplemental energy source for local communities 

within the planning area is high. Communities in the planning area rely almost exclusively on costly 

diesel-powered generating stations. Supplementing the diesel generation with wind energy can save 

significant amounts of fuel, and significantly reduce energy costs. 

Several communities in the planning area including Unalakleet, Toksook Bay, and Kwigillingok already 

use wind energy to supplement diesel-powered generating stations. 

The BLM encourages the development of wind energy within acceptable areas, consistent with the 

Energy Policy Act of 2005 and the BLM 2008 Energy and Mineral Policy. However, for several reasons, 

large-scale wind projects are unlikely to be built on BLM-managed public land in the planning area for 

the foreseeable future. The primary criteria for utility-scale wind development (BLM-DOE 2003) include: 

• A wind power Class 4 and above for short-term, and Class 3 and above for long-term; 

• Transmission access within 25 miles; and 

• Road access within 50 miles. 

Wind speed in Alaska has been estimated at 50 meters above the ground and depicts the resource that 

could be used for utility-scale wind development (BSWI Draft RMP/EIS, Map 3.3.8-1). As a renewable 

resource, wind is classified according to wind power classes, which are based on typical wind speeds. 

These classes range from Class 1 (the lowest) to Class 7 (the highest). In general, wind power Class 4 or 

higher can be useful for generating wind power with large turbines and are considered good resources. 

Given the advances in technology, some locations in Class 3 areas may suitable for utility-scale wind 

development. 

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Section 3. Resource Uses Appendix M: BSWI Affected Environment Report 

Within the planning area, wind potential is generally poor to fair (Class 1-3) (AEA 2010). This class of 

wind resource is unlikely to ever be developed. Given that many of the areas with Class 4 or higher wind 

potential are excluded from potential development by policy, no lands with high potential for utility-scale 

wind development have been identified in the planning area. Most of the area with high potential is 

located near the coast and is not on BLM-managed public lands within the planning area (see BSWI Draft 

RMP/EIS, Map 3.3.8-1). 

The population in the planning area is low (with correspondingly low energy demand), particularly in 

areas near BLM-managed public lands, infrastructure to transport electricity to regional population 

centers is extremely limited. Transmission is costly to build, and typically, a large demand is necessary to 

warrant long distance transmission lines. 

Biomass 

Woody biomass is commonly defined as the by-product of forest management, restoration, and hazardous 

fuel reduction treatments, and includes whole trees, woody plants, stems, branches, limbs, tops, needles, 

leaves and all other woody parts grown in a forest, woodland, or rangeland environment. In Alaska 

biomass will include standing timber both dead and green as well. 

In 2005, a group of federal and State agencies formed the Alaska Wood Energy Development Task Force, 

and began distributing federal dollars to perform pre-feasibility studies for wood energy projects across 

the state. To date, projects in 57 communities have received funding to analyze wood energy feasibility, 

while 26 of those projects have received additional funding, primarily from the AEA, to design, construct 

and operate new community wood heating systems. At least 14 communities within the planning area 

have requested such assistance and several of these are actively pursuing biomass systems for heating. 

Combined Heat and Power systems may follow at a later date. 

More than 100,000 cords of wood per year are used for residential space heating statewide (AEA 2016a). 

Small wood-fired boilers are present in Tok, Coffman Cove, Craig, Gulkana, Elim, Thorne Bay, Haines, 

and Tanana (AEA 2016a). These facilities are often being fueled by locally harvested wood or mill byproducts. Some have proposed the use of imported pellets created from timber harvest elsewhere. 

There are relatively few pellet manufacturers in the state. Superior Pellets in North Pole, Alaska is an 

industrial producer of pellets, it initially struggled to secure proper feed stocks to produce quality pellets. 

It is capable of producing an estimated 30,000 tons of pellets per year. However, the current dilemma has 

been the lack of a strong market for their product. The Native Village of Gulkana in Copper River, a 

small plant in Ketchikan, and Logging and Milling in Dry Creek are the only other known producers of 

pellets in Alaska. All three producers use woody biomass from State and Native lands, in conjunction 

with a local sawmill. The Village of Napiamuit has a contract to deliver 1,000 cords of wood from the 

Middle Kuskokwim river area to Bethel to meet annual heating needs. 

There are no existing biomass projects using woody biomass from BLM-managed public lands in the 

planning area. This type of biomass development in the planning area is anticipated, however, because the 

pellets are likely to originate outside the planning area, these types of operations are not considered to 

have any significant impact. 

Primary criteria for commercial biomass projects include a biomass power plant and a population center 

with a skilled labor force within 50 miles of the source of the biomass. These criteria are not met inside 

the planning area because BLM-managed public lands are typically too far away and inaccessible to local 

communities (Table 3.8.1-1). 

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Appendix M: BSWI Affected Environment Report Section 3. Resource Uses 

Normalized difference vegetation index (NDVI) is derived from the hyperspectral reflectance data, and is 

considered indicative of the abundance of photosynthetically active vegetation. This is a rough measure of 

the amount of biomass available on the land, and can be derived from aerial and satellite imagery. The 

BLM Land Use Planning Handbook (BLM 2005) describes areas that may be likely to have biomass 

harvesting in the future to be those with an NDVI of 4 or greater, communities at risk from fire, and those 

in proximity to Forest Service lands (less than 100 miles). Very little of the planning area has a NDVI >4, 

and none of the land is in proximity to BLM-managed public lands, making large-scale biomass projects 

unlikely (BSWI Draft RMP/EIS, Map 3.3.8-2). The recent forest inventory of BLM lands also provided 

information on The Kuskokwim Corporation (TKC) lands and includes estimates of standing and dead 

material that could be considered for use in a biomass operation. 

In accordance with direction from the BLM-Washington Office, the BLM will continue to encourage 

biomass utilization to promote the use of renewable energy. With the recent inventory of forested lands 

around communities completed, it may be possible to promote further utilization of forest resources 

locally. 

Peat 

Peat is partially decayed and compacted vegetable matter accumulated over decades, where soil is wet 

enough to minimize oxidation. In its natural state, peat is around 95 percent water by weight and 

frequently contains some sand, clay, or other minerals. The energy content per pound is similar to wood, 

and half of most coal. Peat is soft, easily compressed, and once the water has been removed, can be used 

as a source of fuel. The planning area contains large amounts of peat (BSWI Draft RMP/EIS, Map 3.3.8-

3); however, according to the American Society for Testing and Materials (ASTM) fuel grade peat must 

have a minimum thickness of 5 feet, have an energy value of 8,300 British thermal unit (Btu) per pound, 

and have an ash content of less than 25 percent (Lukens 1981). 

Production costs (on a large scale) are therefore high when compared to other fossil fuels, and longdistance transportation of the material is usually economically impractical. Peat is best viewed as a 

significant resource only if the resource is located immediately adjacent to the existing infrastructure in 

need of energy resources (Bundtzen and Kline 1986). 

Interest in developing the use of peat for energy purposes has been relatively low in the U.S. A small 

(23-megawatt) power plant was constructed in 1990 in Maine, to be fueled by local peat; however, for 

several reasons, the boilers are now mainly fueled by wood chips (IPS 2016). Only in some areas in the 

midlands of Canada is peat used today on a minor scale as a local fuel. 

Until the 1950s, peat was still regarded as an important fuel in many countries in Europe, and large 

development programs were being undertaken in Ireland, Sweden, Germany, Denmark, Finland and in the 

member states of the then Soviet Union (IPS 2016). In the 1960s, the availability of cheap oil and coal 

started to affect the competitiveness of peat as fuel and the role of energy peat began to decrease in these 

countries, except for Ireland and the Soviet Union, where peat continued to play an important role as a 

fuel in power generation and also in small local consumption. 

Major environmental concerns regarding the use of energy peat are principally the same as those for other 

fuels. This includes damage to the natural land, and air emissions from the burning of peat resources. Peat 

typically has relatively low sulfur concentrations, and therefore low sulfur dioxide emissions. 

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Section 3. Resource Uses Appendix M: BSWI Affected Environment Report 

Drainage is a significant issue because the peat needs to be drained before harvesting. Typically this is 

done by creating ditches to carry water to streams and rivers. This draining process can discharge solid 

substances and nutrients to surface water. 

Peat is classified as a fossil fuel and CO2 emissions released during its combustion are taken into account 

in the calculations of the International Panel for Climate Change. This classification has been strongly 

criticized, especially in Finland and Sweden, because it does not take into account annual growth of peat 

(IPS 2016). In some countries, peat is now being classified as biomass and is considered to be a 

renewable energy source. 

Mining of peat in the lower 48 is commonly associated with its use for making topsoil, and therefore it is 

typically considered a salable commodity, much like sand and gravel. It is recognized that the mining of 

peat in the planning area may have an entirely different usage, and that there has been some community 

interest in utilizing this resource for power generation. For that reason, it is discussed in both sections. 

In 1995, the total area of the U.S covered by peat soils (known as histosols) was some 214 000 km2, of 

which Alaska accounted for just over 50 percent (WEC 2001). The total volume likely exceeds 100 

billion tons. Peat production in Alaska was estimated to be 30,600 cubic meters in 2000 (Szumigala and 

Swainbank 2001). There are no known updates to this estimate. 

Barrick Gold conducted the Donlin Creek Peat Resource Evaluation to assess the feasibility of using peatfired power plants to operate the proposed Donlin Gold Mine. This study included testing and sampling 

peat deposits on two currently unencumbered parcels of BLM-managed public lands and State-selected 

land near the proposed mine (BLM 2007b). The work was done in the Kolmakof and the Tango Area 

(BSWI Draft RMP/EIS, Map 3.3.8-3). It was determined that the use of peat to fuel peat-fired power 

plants was not feasible because all of the peat drilled and sampled existed in permafrost, and excavation 

of the peat resource was likely to be costly and damaging to the permafrost conditions. Based on this 

study, it is unlikely that most of the peat resources in the planning area could be considered economically 

viable. 

In 2012, the community of McGrath solicited some funding from AEA to develop a renewable power 

peat processing plant (AEA 2012). The plan was to create a self-sustaining system to produce 3,600 tons 

(60 billion Btu) of peat pellets per season. A projected retail price of $300/T ($17/ one million Btus 

(mBtu) was estimated as compared to local fuel oil prices at $53/mBtu and wood at $19/mBtu. The 

project would replace 400 cords of wood (a resource becoming ever more depleted) and 25,000 gallons of 

fuel oil, for space heating in McGrath and four other villages of similar size. Such a system could easily 

supply smaller villages in Alaska with sufficient peat from lands outside of BLM-managed public lands. 

This application was not selected for further investigation by AEA (AEA 2016b). 

Hydropower 

Hydroelectric plant configurations include conventional dam reservoir projects, which regulate flows 

through the drawing down of reservoir levels, and smaller capacity run-of-the-river projects, which rely 

upon the rate and fall of natural streamflow to produce power. Though time consuming to permit and 

expensive to construct, hydropower is a mature technology with the capability of locking in power rates 

for 50 to 100 plus years. 

There are currently at least 52 operating hydroelectric projects in Alaska. Most are owned by the utilities 

they serve. Alaska has a significant amount of untapped hydroelectric potential. The majority of Alaska’s 

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Appendix M: BSWI Affected Environment Report Section 3. Resource Uses 

hydroelectric energy resources are located mainly in southeast and southcentral Alaska, with some 

resource opportunities in the interior, southwest and the Aleutians. 

For a hydropower resource to be capable of economically viable power production, a number of attributes 

must be present: (1) flowing water of sufficient quantity, (2) sufficient elevation drop in the river or 

stream (head), (3) typically, the further the power source is from the market, the larger that source needs 

to be to justify transmission costs. 

In the case of the planning area, there are relatively limited resources located on BLM lands. Three FERC 

hydropower withdrawals have been made within the planning area (Table 3.8.4-1), but none have resulted 

in project initiation. The Aniak and McGrath permits are still in place. The Chikuminuk Lake 

Hydroelectric Project proposed a 13.4-megawatt project in southwest Alaska that would raise the level of 

Chikuminuk Lake by 60 feet in order to generate year-round hydropower. The project (by Nuvista Light 

& Electric Cooperative, Inc.) went through the preliminary stages of permitting. The preliminary permit 

for this project was surrendered by the applicant in September 2014. Per FERC notice, the permit for the 

project was terminated effective October 18, 2014 (FERC 2014). 

3.8.5 Resource Changes: Trends and Forecasts 

It is possible that small, localized wind development may occur in the vicinity of the communities in the 

planning area. However, most BLM lands are not within 25 miles of a major transmission line or local 

community (Table 3.8.5-1). It is possible that some small-scale facilities may be developed for BLM 

administrative use, or that the BLM may authorize small-scale facilities to promote energy to rural areas 

(Figure 3.8.5-1). 

Table 3.8.5-1. FERC Withdrawals Affecting BLM Land in Planning Area 

Case File 

Number 

PLO/ SO/ EO Acres Header 

AA-87847 FA 12879 1 Aniak Alaska 31 Project: segregates the land from “entry, location, or

other disposal under the laws of the United States unless otherwise 

directed by the Federal Energy Regulatory Commission or by 

Congress.” 43 CFR 2320.0-3. 

AA-87849 FA 12881 5 McGrath Alaska 28 Project: segregates the land from “entry, location, 

or other disposal under the laws of the United States unless 

otherwise directed by the Federal Energy Regulatory Commission or 

by Congress.” 43 CFR 2320.0-3. 

AA-93287 FA 14369 5,0352.5 Chikuminuk Lake Hydro Project-transmission line: segregates the 

land from “entry, location, or other disposal under the laws of the

United States unless otherwise directed by the Federal Energy 

Regulatory Commission or by Congress.” 43 CFR. 2320.0-3. 

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Section 3. Resource Uses Appendix M: BSWI Affected Environment Report 

Figure 3.8.5-1. FAA aircraft navigation beacon at Chandalar Lake in the Brooks Range of northeast 

Alaska. This is the type and scale of renewable energy development that could occur in the 

planning area. 

There is a small potential for high value wind resources to require transmission corridors across BLM 

lands to population centers. BLM policy is not to issue ROW authorizations for wind energy development 

for areas where such development is incompatible with specific resource values. Specific lands excluded 

from wind energy site monitoring and testing and wind energy development include designated areas that 

are part of the NLCS (I.M. 2009-043). 

As with other renewable resources, most of BLM lands in the planning areas are far from population 

centers making the large-scale use of biomass economically unlikely in the near future. The Village of 

Napaimute requested permits to harvest biomass from BLM land in 2013, but ultimately chose to utilize 

other sources first. The probability of future requests on BLM lands in this area is considered to be low 

initially, but may grow if additional biomass facilities come on line. However, small community-based 

heat or combined heat and power projects may eventually need to reach out to BLM-managed public 

lands to meet their future needs if they continue to expand the scope of biomass projects within the 

region. 

Because of the low demand, potential for permafrost, and availability of alternate peat sources not on 

BLM-managed public lands, the potential for large-scale development and use of peat in the planning area 

is considered to be low. 

Overall, there appears to be limited potential for significant hydropower development on BLM-managed 

public lands within the planning area, and most hydropower projects are likely to be small and located 

close to existing communities. 

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Appendix M: BSWI Affected Environment Report Section 4. Special Designations 

Section 4. Special Designations 

4.1 Areas of Critical Environmental Concern 

4.1.1 Introduction 

This section describes the ACECs in the planning area. An ACEC is defined in FLPMA (Public Law 94-

579, Section 103(a)) as an area within BLM-managed public lands where special management attention is 

required to protect and prevent irreparable damage to important historic, cultural, geologic, 

paleontological, or scenic values, to fish and wildlife resources or other natural systems or processes, or to 

protect life and safety from natural hazards. 

4.1.2 Laws, Regulations, and Policies 

Regulations for implementing the ACEC provisions of FLPMA are found at 43 CFR 1610.7-2. The 

ACEC is a BLM-specific administrative designation that is accomplished through the land use planning 

process. ACECs differ from other special designations in that the designation by itself does not 

automatically prohibit or restrict other concurrent use within the area. Restrictions that arise from an 

ACEC designation are determined and applied at the time of designation and are designed to protect the 

identified values within the ACEC or serve the purposes for which the designation was made. Special 

management attention is designed specifically for the relevant and important (R&I) values found within 

the specific ACEC. Therefore, management decisions and actions may vary between ACECs. The BLM 

identifies goals, standards, and objectives for each proposed ACEC, as well as general management 

practices and uses, including necessary constraints and mitigation measures. This EIS identifies a 

reasonable range of alternatives that includes current management of existing ACECs, as well as 

management for proposed ACECs. In addition, ACECs are subject to the provisions of 43 CFR 

3809.14(b)(3), which require an approved plan of operations for activities resulting in more than 5 acres 

of disturbance. 

Nominations for the establishment of an ACEC can be made at any time; nominations are suggested 

either internally by the BLM or externally through the public, special interest groups, Tribes, or federal, 

State, or local agencies. Only BLM-managed public lands are included in ACEC boundaries. During the 

planning process, the BLM interdisciplinary team evaluates nominated ACECs to determine if the area 

specifically meets the relevance and importance criteria, as defined by 43 CFR 1610-7-2(a)(1–2), and as 

defined in the BLM Manual 1613, Areas of Critical Environmental Concern (BLM 1988). Areas 

determined to meet the relevance and importance criteria are provided temporary management to protect 

human life and safety or significant resource values from degradation until the area is fully evaluated 

through the RMP process. 

4.1.3 Resource Indicators 

The conditions that are established in the discussions below provide a baseline ACECs that the impact 

analysis will be based on. The following indicators, along with qualitative discussions, will be used to 

evaluate impacts associated with management decisions in the BSWI Draft RMP/EIS. 

• For ACECs with cultural resources value: 

o Acres closed to mineral entry in medium-high potential mineral areas 

o Acres managed as limited for travel 

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Section 4. Special Designations Appendix M: BSWI Affected Environment Report 

o Acres open to commercial woodland harvest and demand for this use 

o Designation of ROW exclusion or avoidance areas 

o Acres designated NTMC 

o Acres managed as VRM class I or II 

o Acres managed for ACEC 

o Acres managed for WSR 

o Increased understanding and documentation of cultural resources 

• For ACECs with fisheries value: 

o Acres affected by land withdrawals and level of mineral potential 

o Acres open to commercial woodland harvest and grazing, and demand for this use 

o Size and route restrictions for summer travel 

o Designation of ROW exclusion or avoidance areas 

o Acres affected by land withdrawals and level of mineral potential 

4.1.4 Current Conditions 

Within the planning area, there are 11 existing ACECs totaling 1,884,376 acres of BLM-managed land 

(BSWI Draft RMP/EIS, Map 3.4.1-1). To date, no activity-level management plans for any existing 

ACEC has been completed. During the BSWI RMP planning process, 19 additional areas were nominated 

as ACECs either internally by the BLM or externally. Some existing ACECs and nominated areas 

overlap. In total, 30 separate areas totaling 11,279,369 acres were evaluated to determine if they meet the 

relevance and importance criteria. 

As described in the ACEC Summary Report (BLM 2018b), the BLM evaluated existing and nominated 

ACECs for relevance and importance of significant historic, cultural, or scenic values; fisheries and 

wildlife resource values; natural processes or system values; and areas of natural hazards. Some existing 

ACECs were found to no longer meet the relevance and importance criteria for the values for which they 

were designated. 

Of 30 areas that were evaluated, 17 areas meet both the relevance and importance criteria for at least one 

of these values. Of these 17 potential ACECs, six are existing ACECs; the remaining are nominated areas, 

some of which overlap with existing ACECs (BSWI Draft RMP/EIS, Map 3.4.1-2). All existing ACECs 

would remain ACECs under the No Action Alternative. Existing ACECs that were found to still meet 

both the relevance and importance criteria for at least one value are proposed as an ACEC in an action 

alternative if their relevant and important values would be protected by another proposed ACEC with 

overlapping boundaries. Table 4.1.4-1 identifies the 11 existing ACECs, 23 nominated ACECs, and 17 

potential ACECs found to contain relevant and important values. 

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Appendix M: BSWI Affected Environment Report Section 4. Special Designations 

Table 4.1.4-1. Acres of Existing, Nominated, and Potential ACECs in Planning Area 

ACEC Name 

Existing 

Acres 

Nominated 

Acres 

Potential 

ACEC Acresa Relevant and Important Value(s) 

Existing 

Anvik River ACEC 115,106 0 115,106 Fish. Largest single wild stock producer of summer chum 

salmon in the Yukon River drainage. 

Box River Treeline RNA ACEC 13,592 0 0 None identified 

Drainages of the Unalakleet River ACEC 415,184 0 415,184 Fish, Cultural. Crucial anadromous spawning areas; 

significant cultural resources, including the Kaltag Portage. 

Inglutalik ACEC 71,716 0 71,716 Fish. Critical spawning and rearing habitat for a variety of 

salmon and other species of fish. 

Kuskokwim River Raptor Nesting Habitat ACEC 6,072 0 0 None identified 

North River ACEC 137,349 0 137,349 Fish. Significant critical spawning and rearing habitat for 

salmon species. 

Peregrine Falcon Nesting Habitat ACEC 8,096 0 0 None identified 

Shaktoolik River ACEC 192,591 0 192,591 Fish. Salmon produced here contribute to the availability 

and abundance of subsistence fish resources in Norton 

Sound and contribute to the overall genetic health of 

salmon stocks. 

Ungalik River ACEC 112,719 0 112,719 Fish. Highly productive aquatic environment that provides 

critical spawning and rearing habitat for a variety of 

salmon and other species of fish. 

Existing and Nominated 

Gisasa River ACEC (existing and externally 

nominated) 

278,057 278,057 278,057 Fish. Highly productive aquatic environment that provides 

critical spawning and rearing habitat for a variety of 

salmon and other species of fish. 

Kateel River ACEC (existing) 568,083 0 568,083b Fish. Highly productive aquatic environment that provides 

critical spawning and rearing habitat for a variety of 

salmon and other species of fish. 

ACEC externally nominated by the USFWS that 

includes portions of the existing Kateel River 

ACEC 

0 675,627 675,627 b Same as existing Kateel River ACEC. 

ACEC externally nominated by Koyukuk Tribal 

Council that includes portions of the existing 

Kateel River ACEC 

0 311,658 311,658 b Same as existing Kateel River ACEC. 

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Section 4. Special Designations Appendix M: BSWI Affected Environment Report 

ACEC Name 

Existing 

Acres 

Nominated 

Acres 

Potential 

ACEC Acresa Relevant and Important Value(s) 

ACEC internally nominated by the BLM: 

308,361 acres of lands not included in the 

existing Kateel River ACEC; nominated area 

includes the two externally nominated areas (see 

above), as well as additional lands that are not 

within the existing ACEC or externally nominated 

areas 

0 308,361 308,361 Same as existing Kateel River ACEC. 

Nominated 

Anvik River Watershed ACEC (externally 

nominated; nominated area includes some of the 

existing Anvik River ACEC) 

0 249,607 249,607 Fish. The summer chum salmon that spawn in the Anvik 

River is considered the largest single wild stock producer 

of summer chum salmon in the Yukon River drainage. 

Anvik Traditional Trapping Area ACEC 

(externally nominated) 

0 21,699 21,699 Cultural. The Iditarod National Historic Trail is of national 

significance, as is indicated by its designation by Congress 

as a National Historic Trail. 

Bonasila River Watershed ACEC (externally 

nominated) 

0 291,136 0 None identified 

Egavik Creek Watershed ACEC (externally 

nominated) 

0 60,052 0 None identified 

Golsovia River Watershed ACEC (externally 

nominated) 

0 21,771 0 None identified 

Grayling Area Habitat ACEC (externally 

nominated) 

0 98,682 0 None identified 

Holy Cross ACEC (externally nominated) 0 1,702,030 0 None identified 

Honhosa River ACEC (externally nominated) 0 93,412 0 None identified 

Huslia ACEC (externally nominated) 0 170,763 0 None identified 

Nulato River ACEC (externally nominated) 0 342,824 342,824 Fish. Highly productive aquatic environment that provides 

critical spawning and rearing habitat to a variety of salmon 

and other species of fish. 

Ohogamiut ACEC (externally nominated) 0 1,634,358 0 None identified 

Old Anvik Village Area ACEC (externally 

nominated) 

0 60,259 0 None identified 

Sheefish ACEC (internally and externally 

nominated) 

0 698,260 698,260 Fish, Cultural. The only identified sheefish spawning area 

on entire Kuskokwim; contains known sites associated 

with the INHT. 

Swift River Whitefish Spawning ACEC (internally 

nominated) 

0 220,032 220,032 Fish. Includes one of the most important of only four 

known humpback whitefish spawning areas. 

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Appendix M: BSWI Affected Environment Report Section 4. Special Designations 

ACEC Name 

Existing 

Acres 

Nominated 

Acres 

Potential 

ACEC Acresa Relevant and Important Value(s) 

Tagagawik River ACEC (externally nominated) 0 301,044 301,044 Cultural. The area would likely be found eligible as a TCP 

of regional importance because of the historical 

importance of the region for trade between the 

Athabascan (Koyukuk) and Inupiat (Selawik). 

Tenmile River Watershed ACEC (externally 

nominated) 

0 36,278 0 Fish. Important Chinook and coho salmon spawning area. 

Unalakleet ACEC (externally nominated; 

nominated area includes some of the existing 

Drainages of the Unalakleet River ACEC and 

some of the nominated Unalakleet River 

Watershed ACEC) 

0 1,520,015 0 Cultural. The Kaltag Portage, as a part of the INHT, is of 

national significance. It was also a prehistorically important 

route for Alaska Natives to travel between the coast and 

the Yukon River. 

Unalakleet River Watershed ACEC (externally 

nominated; nominated area includes some of the 

existing Drainages of the Unalakleet River 

ACEC) 

0 251,978 251,978 Fish, Cultural. Presence of spawning areas for all five 

species of Pacific Salmon; the Kaltag Portage, as a part of 

the INHT, is of national significance. 

Whitefish Spawning ACEC (externally 

nominated) 

0 290,958 0 None identified 

Total 1,640,508 9,638,861b 4,284,610b 

Source: BLM 2018b 

a Potential ACECs are those that meet the relevance and importance criteria and will be analyzed under one or more alternatives, which may be limited to the current management alternative, in the Draft 

RMP. b Total acres may not be the sum of each separate ACEC due to overlapping acres. 

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Two potential ACECs, Tenmile River Watershed ACEC and the Unalakleet ACEC, are not considered for 

ACEC designation under any alternative. This is because the relevant and important values for these two 

nominated ACECs would be adequately protected by the potential Unalakleet River Watershed ACEC; 

therefore, their designation would be redundant. Therefore, 15 of the 17 potential ACECs are considered 

for ACEC designation in at least one alternative. 

The proposed management for each ACEC was developed to provide protection and focused management 

for relevant values beyond that provided through general planning area management. A comprehensive 

description and evaluation of all existing and nominated ACECs can be found in the ACEC Summary 

Report (BLM 2018b). 

4.1.5 Resource Changes: Trends and Forecasts 

The relevant and important values of the Anvik River, Drainages of the Unalakleet River, Inglutalik, 

North River, Shaktoolik River, and Ungalik River ACECs have been protected. The values would 

continue to be protected if their ACEC designation continues, and would not be protected without 

continued ACEC designation. 

The values of the Box River Treeline RNA, Kuskokwim River Raptor Nesting Habitat, and Peregrine 

Falcon Nesting Habitat ACECs are no longer relevant and important, as described in the ACEC Summary 

Report (BLM 2018b). 

4.2 National Trails 

4.2.1 Introduction 

This section describes the national trail found within the planning area. 

4.2.2 Laws, Regulations, and Policies 

National Trails System Act of 1968 

The National Trails System is the network of scenic, historic, and recreation trails created by the NTSA of 

1968. These trails provide for outdoor recreation needs; promote the enjoyment, appreciation, and 

preservation of outdoor areas, cultural, and historic resources; and encourage public access and citizen 

involvement. Throughout the U.S. are 30 long-distance routes, 19 of which are National Historic Trails 

and 11 of which are National Scenic Trails that, combined with more than 1,000 National Recreation 

Trails, comprise the National Trail System (AmericanTrails.org 2016). 

National Historic Trails are extended trails that closely follow a historic trail or route of travel of national 

significance. Designation identifies and protects historic routes, historic remnants, and artifacts for public 

use and enjoyment. Trails must meet the following three criteria listed in Section 5(b)(11) of the NTSA to 

be designated a National Historic Trail: 

• The trail must follow an actual documented route of historic use. 

• The trail must be of national significance. 

• The trail must possess significant potential for public recreation or interpretation. 

National Historic Trails are specifically designated areas in the U.S. containing the route of nationally and 

historically significant trails and areas adjacent to the trails to be utilized for scenic, historic, natural, 

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cultural, or developmental purposes. Only Congress can designate new National Historic Trails or 

National Scenic Trails. National Recreation Trails are designated by the U.S. Departments of Interior or 

Agriculture. 

The INHT is the only National Trail within the planning area. The INHT is one of 30 long-distance 

historic routes that comprise the National Trail System. The INHT celebrates the historic 2,300-mile 

winter trail system, including side and connecting trails, from Seward to Nome (BLM 1986c; BSWI Draft 

RMP/EIS, Map 3.4.2-1). It is the only congressionally designated National Trail in Alaska and the only 

National Historic Trail established to commemorate winter trail use. Over 1,500 miles of the historic 

winter trail system are open for public use across State and federal lands (BLM 2018d). The trail 

originally served as a trade route connector for Alaska Native Villages, then as a portage during the 

Alaskan gold rush, and now as a travel and recreation route in contemporary Alaska. 

ANILCA 

Congressionally designated segments of national trails are part of the BLM’s National Landscape 

Conservation System. National Trails are designated CSUs under the ANILCA, and ANILCA Title 11 

access provisions apply. 

BLM Manual 6280 – Management of National Scenic and Historic Trails and Trails under 

Study or Recommended as Suitable for Congressional Designation 

BLM Manual 6280 (BLM 2012c) requires the establishment of an NTMC that provides for land 

management measures that safeguard the nature and character of the corridor to meet the legislative goals 

of the special designation. Note that the establishment of the NTMC pertains only to the primary route of 

the INHT and not to the side/connecting trails (BLM 2015a). BLM Manual 6280 (BLM 2012c) also 

requires inventorying National Trail resources, qualities, values, and associated settings and the primary 

use or uses of the trail, as well as the identification of management goals, objectives, and actions for each 

National Trail. 

4.2.3 Resource Indicators 

The conditions that are established in the discussions below provide a baseline for National Trails-related 

values, which the impact analysis will be based on. The following indicators, along with qualitative 

discussions, will be used to evaluate impacts associated with management decisions in the BSWI Draft 

RMP/EIS. 

• Acres of the NTMC with direct and/or indirect impacts resulting in the loss of integrity (e.g., 

setting, feeling, and association) or destruction of physical remnants of a trail, including rutting 

and trail braiding resulting from OHV compaction during periods of insufficient snow depth 

• Acres of the INHT directly or indirectly affected by change in the cultural landscape (e.g., visual, 

pollution, or audible elements) that diminish the integrity of the trail’s historic character (e.g., 

setting and feeling) 

• Acres of the NTMC with direct and/or indirect impacts resulting in “substantial interference” 

with the nature and purpose of the INHT, as defined by the minutes of the Senate Committee on 

Energy and Natural Resources (May 17, 1978) 

• Total acres of the INHT directly or indirectly affected by climate change. Examples of impacts 

related to climate change could include change in vegetation community composition (as defined 

by the REA) 

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• Adverse effects on the INHT per the NHPA 

4.2.4 Current Conditions 

Current Management Framework 

The initial version of the NTSA was approved on October 2, 1968, for the purpose of establishing a 

national system of recreational and scenic trails. It directed that 14 routes be studied to determine the 

desirability of designation as National Scenic Trails. “Gold Rush Trails in Alaska” were identified in the 

Act as a route named for study, with the U.S. Bureau of Outdoor Recreation later leading this study. 

In September 1977, the U.S. Bureau of Outdoor Recreation study team released a report on Alaskan Gold 

Rush Trails and recommended that an Iditarod Trail system be designated as a National Trail. 

Concurrently, race organizers and volunteers for the Iditarod Trail Sled Dog Race lobbied Congress for 

the inclusion of the trail in the National Trail System. 

In November 1978, Public Law 95-625 (National Parks and Recreation Act) amended the NTSA by 

adding a new category called “National Historic Trails” and added four new historic trails to the system: 

the Lewis and Clark Trail, the Oregon Trail, the Mormon Pioneer Trail, and the Iditarod Trail. The NTSA 

set forth the goal of National Historic Trail designation, stating, “National historic trails shall have as their 

purpose the identification and protection of the historic route and its historic remnants and artifacts for 

public use and enjoyment.” 

The Act stated that, unlike National Scenic Trails, which are managed by one federal agency from end to 

end, the level of public access and development for any part of a National Historic Trail would be at the 

discretion of each individual (nonfederal) landowner over which the trail passes. Federal land manager 

participation is mandated by law. Inclusion of a non-federal segment or site as part of the National Trail 

System is achieved through cooperative agreements between the landowner and the federal trail 

administrator. The BLM is the federal trail administrator for the INHT. 

Congressional intent with regard to the “nature and purposes” of the INHT is articulated in the minutes of 

the Senate Committee on Energy and Natural Resources (May 17, 1978). This statement of intent is an 

important yardstick to determine the suitability of various management options that could affect the trail, 

including those management alternatives analyzed this document. In the report, the Senate Committee 

described the nature of the INHT as “offering a rich diversity of climate, terrain, scenery, wildlife, 

recreation, and resources in an environment largely unchanged since the days of the stampeders...the 

isolated, primitive quality...makes the National Historic Iditarod Trail...unique.” The nature of the INHT 

is further elaborated with a comparison of magnitude to other units in the National Trail System: 

“nowhere in the National Trail System is there such an extensive landscape...during...winter season of 

travel.”

The purposes of the trail are to provide an opportunity for contemporary users to experience the natural 

primitive settings and challenges experienced by gold stampeders a century ago, and to test the mettle of 

users, stated in terms relative to other units of the National Trail System: “Nowhere in the National Trail 

System is...so demanding of durability and skill during its winter season of travel. On the Iditarod, 

today’s adventurer can duplicate the experience and challenge of yesteryear.” Implicit in this statement is 

the retracement or the “re-creation” of the historic route to experience challenge.

Pursuant to the National Trails Act (as amended in November 1978), the U.S. Department of Interior 

assigned the BLM Alaska to assemble an interagency planning team and a Federal Advisory Council to 

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develop a comprehensive management plan (CMP) for the trail, which the Secretary of the Interior would 

submit to Congress. The goals of the plan were as follows: 

• Identify all significant national, historical, and cultural resources to be preserved, specific trail 

management objectives and practices, and anticipated cooperative agreements with other 

government agencies or parties. 

• Identify high-potential historic sites and route segments for outdoor recreation or historic 

interpretation. 

• Identify acquisition needs for high-potential sites. 

• Identify the trail ROW. 

• Identify the process for marking the trail. 

• Identify important side or connecting trails to complement and complete the trail system. 

• Devise a uniform marker for the trail. 

• Issue regulations necessary for the use, protection, management, development, and administration 

of the trail. 

Portions of the INHT within the planning area are not currently managed under any provisions contained 

within the SWMFP (BLM 1981). That plan states, “The Iditarod National Historic Trail Management 

Plan is in the final stages. Therefore, the Iditarod Trail is not addressed directly in the Southwest 

[Management Framework Plan]. Decisions in the Management Framework Plan must be consistent with 

the Iditarod plan” (BLM 1981). 

The ANILCA of 1980 designated National Historic Trails on federal lands within Alaska (i.e., the INHT) 

as a conservation system unit (Sec. 102[4]). Based on subsequent policy development, this refers to the 

Primary Route only of the INHT system. As a result, the Primary Route of the INHT on federal lands is 

affected by several special ANILCA-only provisions for subsistence use, adjacent landowners right of 

access, snowmobile use, adjacent State and private lands access for survey, exploration, and installation 

of air and water navigation aids, research sites, and transportation and utility systems. 

In September 1981, the BLM published the INHT CMP Volume I, which was effectively a draft of the 

CMP until it was ultimately adopted. During development of the CMP, the Federal Advisory Council, 

with the BLM’s concurrence, recommended to the Secretary of Interior that the BLM be appointed the 

permanent administrator of the INHT. About the same time, the BLM, with the State of Alaska Division 

of Parks and Outdoor Recreation, opened a Joint Federal State Trail Office to continue mandated planning 

work on the trail. Interagency work on the trail included a baseline inventory of re-locatable historic 

roadhouses and communities along the trail, most of which had been abandoned in the previous 50 years. 

In July 1982, the BLM published the CMP Resource Inventory (BLM 1982) for the trail as a companion 

document to Volume I of the CMP. The resource inventory included an inventory and naming convention 

of all routes to be included in the INHT System, identified high-potential segments and historic sites, 

provided detailed information on all historic sites along the trail from field visits, provided an inventory 

and rating of the scenic resources visible from the entire trail, provided land status, and provided a use 

classification system by trail segment. 

The INHT CMP was revised and adopted by the Secretary of Interior on July 3, 1986, and submitted to 

Congress. With the adoption of the CMP (BLM 1986c), the BLM became the federal administrator for the 

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Section 4. Special Designations Appendix M: BSWI Affected Environment Report 

entire trail system and was charged with working to facilitate the implementation of the CMP among 

multiple parties, along with managing a couple hundred miles of the trail on BLM-managed public lands. 

As an interagency concept plan, the CMP did not apply trail or land management regulations or protection 

measures on behalf of other agencies; those decisions are made at the discretion of relevant land 

management agencies, consistent with the intention of the NTSA. 

To meet the requirements of the NTSA, the interagency CMP (BLM 1986c) for the trail identified two 

categories of trails comprising the INHT system. The Primary Route3 of the INHT is the “most important

travelway of the Trail system [between Seward and Nome] during the Iditarod Gold Rush... Connecting 

Trails were important components of this gold rush trail system...branching from the INHT primary 

route....” The CMP further classified the Primary Route and Connecting Trails as active or inactive 

depending on their contemporary use. The CMP also distinguished between segments for active 

management (approximately 1,500 miles) and minimal management (approximately 900 miles). The 

CMP defined segment names and recommended the width of trail management corridors, improvements, 

and applying for listing on the NRHP for numerous sites and segments. 

Within the planning area, the INHT crosses lands managed by the BLM, the U.S. Fish and Wildlife 

Service (within the boundaries of Innoko NWR), and general State of Alaska lands. These parties (and 

other entities outside of the planning area) entered into an agreement with BLM in 1988 to implement the 

recommendations of the adopted CMP, within the limits of available funding. Management objectives 

established by the INHT CMP (BLM 1986c) include the following: 

• Trail segments identified for active management should be managed to protect their historic 

values and identified by uniform markers. 

• Public use of trail segments should be encouraged, and the trail should be protected and managed 

to the extent that such use does not impact the historic values of the INHT. Rights-of-way, 

easements, management corridors, cooperative agreements, and access improvements will be 

used to meet this objective. 

• Motorized use is authorized pursuant to the INHT CMP and ANILCA sections 811 and 1110. 

• Encourage nonfederal sites and segments to be included in the INHT though cooperative 

agreements. 

• Maps, publications, and interpretation materials concerning the INHT should be made publicly 

available to increase appreciation and understanding of the INHT system. 

• Identified historic sites along the INHT should be further evaluated for possible nomination to the 

NRHP. 

Numerous historic sites have been identified along the INHT management corridor, with a number of 

sites being eligible for listing on the NRHP. Completions of applications for register listing have been 

limited. These sites are managed through active and passive preservation strategies to mitigate and protect 

against disturbance or destruction. The BLM works in conjunction with the Alaska SHPO to continue to 

identify and inventory historic sites along the INHT to be nominated to the NRHP (BLM 2014c). Since 

the INHT CMP (BLM 1986c), several associated sites and connecting trails have been documented and 

3 The terms “trail” and “route” were used interchangeably in the INHT CMP in regards to the description of the “Primary” 

travelway and are used in this document in the same manner. 

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listed in the Alaska SHPO’s Alaska Heritage Resource Survey database as contributing elements 

associated with the INHT, or have been determined eligible for listing on the NRHP. 

The INHT CMP (BLM 1986c) recommends a corridor in the Farewell Burn segment of 100 feet (for nonBLM-managed public lands) to 1,000 feet (for BLM-managed public lands), and on the Kaltag Portage 

segment a minimum of 1,000 feet. Formal rulemaking or implementation of a policy on BLM-managed 

public lands within the planning area for the withdrawal and/or delineation of a management corridor 

specifically for the INHT has not occurred to date (BLM 2015a). 

The INHT retraces a winter Gold Rush trail network connecting Seward in southcentral Alaska to Nome 

in northwestern Alaska via the Iditarod gold mining district. The 938-mile main winter trail between 

Seward, Iditarod, and Nome was established in the early 1900s by users and the Alaska Road 

Commission on existing Alaska Native trails and newly pioneered routes. Branching from the main route 

are hundreds of miles of parallel, connecting, and side trails that also played an important role in the 

historic Gold Rush, and are included as part of the INHT System. 

Historically, overland travel on the INHT was limited to winter months. Many users walked over the 

snow on the trail, and an extensive array of dog teams carried passengers, freight, mail, and gold to and 

from the Iditarod area, with attendant infrastructure built up to serve the needs of the dog teams. Trail 

users relied largely on private roadhouses and, later, public shelter cabins for overnight refuge during 

their journey. With the introduction of aircraft and decrease in mining activity, sections of the trail, 

mostly outside the planning area, fell into disuse by World War II. 

With the concurrent developments of reliable snowmobile technology and annual long-distance, winter 

trail-based competitions in the 1970s (e.g., the Iditarod Sled Dog Race, the Gold Rush Classic/Iron Dog 

[snowmobile] Race, and the Iditabike), sections of the historic route were reestablished as the primary 

winter overland travel route between otherwise isolated communities in the upper Kuskokwim River 

drainage and the middle Yukon River in the planning area. 

The majority of current trail use occurs between February and April, although use begins when 

sufficiently cold weather and snowfall enables overland travel (historically in late fall). Residents travel 

the INHT by snowmobile between villages to visit relatives, shop for groceries and goods, hunt, and 

attend sports tournaments and community events. Trail users rely on a single, snowpacked trail travel way 

that is approximately 48 inches wide (although it may be cleared to a wider width through forested areas). 

Additionally, some residents use the trail for fur trapping ‘lines,’ to access firewood cutting areas, or to

participate in other subsistence activities. Also, a modest number of non-planning area residents travel by 

snowmobile from southcentral Alaska to participate in an annual bison hunt in the area between the 

Alaska Range and Nikolai, or to follow the Iditarod Sled Dog Race. 

The biggest influx of non-planning area resident winter trail users is in February and March, associated 

with the internationally recognized long-distance trail-based races (e.g., the Iditarod Sled Dog Race, the 

Iron Dog [snowmobile] Race, the Iditarod Invitational Ultramarathon [a long-distance running, biking, 

and skiing race], and the Iditasport). These events include not only the passage of hundreds of motor- and 

muscle-powered competitors over the trail system, but also rely on extensive trail-based volunteer support 

from local, statewide, national, and international persons for trail maintenance, materials staging, and 

shelter preparation and operations. Additionally, the events generate thousands of hours of vicarious use 

of the historic trail system via worldwide-available video and social media coverage. 

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INHT Segments 

Collectively, the historic trail segments and associated historic sites on federal lands and the lands of nonfederal cooperators make up the INHT System. Of the 2,400-mile system, approximately 1,600 miles 

have been identified for active, modern-day use, and a user could travel the entire route between Seward 

and Nome on public lands and public ROWs. 

Of the actively used segments, slightly over 700 miles are within the planning area. Approximately 77 

miles of the INHT are located on BLM-managed lands within the planning area. Approximately 62 miles 

are part of BLM’s National Conservation Lands. The INHT is also a designated CSU under the ANILCA. 

The 62 miles of trail that are designated as a CSU and National Conservation Lands are composed of 

three segments located in geographically distinct areas within the planning area. The three segments are 

part of the Primary Route. The boundaries of the two largest segments (Farewell Burn and Kaltag 

Portage) are located 10 and 35 trail miles, respectively, from the nearest community. 

Farewell Burn Segment 

The first segment, located southeast of McGrath, traverses a nearly straight 20-mile alignment laid out by 

Alaska Road Commission surveyors in 1911. The segment was named the “Farewell Lake to Big River 

Roadhouse Primary Trail” in the CMP (BLM 1986c). The Farewell Burn Segment is a contributing 

segment of the Rainy Pass to Big River Roadhouse Primary Trail (AHRS MCG-124). 

The Resource Inventory for the CMP (BLM 1982) describes the physiographic province crossed by this 

segment as the Kuskokwim Lowlands. The trail generally parallels the South Fork of the Kuskokwim 

River and is located on a nearly level plain with occasional river, creek, bog, and lake crossings. A large 

wildland fire burned over much of this area in 1977, and the segment is commonly known as the Farewell 

Burn. 

Almost all of the area traversed by the trail has shallow soils or permafrost. Winter precipitation levels 

and the amount of snow on the ground typically increase from the south to the north. Vegetation is made 

up of mosses, shrubs, wetland/bog plants, black spruce, and paper birch interspersed in a mosaic pattern 

in the area traversed by the trail. Much of the growth is relatively small, representing sub-Arctic regrowth 

since the 1977 wildfire in the area. 

With little significant adjacent topography, views from the trail are generally of changes in vegetation in 

the foreground to middleground. Crossings of large frozen lakes and bogs on the north end of this trail 

segment provide the most expansive views. 

The Farewell Burn trail segment, a contributing segment of MCG-124, is eligible for the NRHP under 

Criteria A, for its significant associations with events that have made a significant contribution to the 

settlement history of Alaska and broader patterns of American history, and under Criteria C, for important 

construction and design features that distinguish it from other gold-rush era winter trails. The period of 

significance is 1900-1942. The remaining length of MCG-124 has not yet been evaluated for NRHP 

eligibility (BLM 2017c). 

One historic roadhouse site is located on BLM-managed public lands on this segment. Otherwise, the 

Farewell Burn segment, along with adjoining segments outside of BLM-managed public lands, is 

uninhabited. The nearest community is Nikolai, approximately 10 trail miles from the north boundary of 

this segment. The nearest community to the south is Knik and is approximately 200 trail miles distant. 

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The trail in the Farewell Burn is cleared of vegetation to an approximate width of 5 feet. Vegetation in the 

treadway is made up of low-growing shrubs that are “mechanically pruned” annually by the passage of 

winter traffic on the trail. The summer trail surface is otherwise undisturbed, grows between knee and 

waist high, and does not show any signs (such as rutting and erosion) of the passage of summer OHVs. In 

the winter, most of the vegetation disappears into the snow-packed trail treadway. 

Other than the cleared corridor for the Iditarod Trail, there are no manmade features (e.g., power lines, 

transportation corridors, buildings, or cleared areas) along, visible from, or near the Farewell Burn 

segment. There are no sources of artificial light along this segment, making this segment an outstanding 

‘dark sky’ resource area.

In the early 1990s, the BLM established a new public shelter cabin near the east end of this segment (Bear 

Creek) and installed a steel trail bridge over the year-round ice-free crossing at the Sullivan River. 

The Farewell Burn trail segment is adjoined by State lands and State trail easement on the south end and 

Native corporation lands with a public transportation (ANCSA Section 17[b]) easement for the trail on 

the north end. 

Most use of the Farewell Burn segment is associated with trail-based competitive events, such as the 

Iditarod Sled Dog Race, Iron Dog, Iditarod Invitational Ultramarathon, and Iditasport, with lesser 

amounts occurring for trapping, subsistence, permitted bison hunts, and casual winter recreation. Virtually 

no use occurs during the summer, as the predominance of wetlands and lack of airstrips or large lakes 

prevent overland access and airborne and floatplane visits. 

Kaltag Portage Segment 

The other Primary Route segment managed by the BLM in the planning area is part of the prehistoric and 

historic overland route between the Yukon River at Kaltag and Norton Sound at Unalakleet. This segment 

was named the Kaltag to Unalakleet Primary Trail in the CMP (BLM 1986c) and is sometimes referred to 

as the “Kaltag Portage.” The BLM manages approximately 35 miles of this 77-mile segment. The Kaltag 

Portage comprises three discrete AHRS sites (UKT-044, NPB-057, and NUL-065) that are recognized 

together as a component of the INHT. 

The physiographic province crossed by the Kaltag Portage segment is the Nulato Hills. Moderately steep, 

rounded mountains form a broad, U-shaped valley through which the route passes. Winter precipitation 

decreases from east to west, with the most snow falling between Tripod Flat and Old Woman Creek. Soils 

are shallow throughout the area and in many cases are underlain by permafrost. Due to the flat 

topography, in the valley bottom outside of mountainous areas, the area is poorly drained and often 

characterized as wetlands. 

Between Tripod Flat (the eastern edge of this segment) to Old Woman Creek, the route is mostly forested 

by black spruce and some tamarack, along with occasional bog and tussock-tundra grasses and sedges. 

Much of this segment of the trail was burnt over in the 2015 Old Woman Fire, which, as a low- to 

medium-intensity fire, appears to have killed most of the black spruce within the fire perimeter but did not 

significantly affect the ground cover. 

The trail between Tripod Flat and Old Woman is cleared of vegetation to an approximate width of 7 feet. 

Vegetation in the treadway is made up of low-growing shrubs and sedges that are “pruned” annually by 

the passage of winter traffic on the trail. The summer trail surface is otherwise undisturbed, growing 

between ankle and knee height, and does not show any signs (such as rutting and erosion) of the passage 

of summer OHVs. In the winter, most of the vegetation disappears into the snow-packed trail treadway. 

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Section 4. Special Designations Appendix M: BSWI Affected Environment Report 

From Old Woman Creek to the Chiroskey River (the west end of BLM’s Kaltag Portage segment), the 

width of the Unalakleet River valley increases significantly. The trail crosses broad, flat tundra and bogs 

of low-growing shrubs and tussocks, and intermittently makes perpendicular crossings of taller 

vegetation, such as black and white spruce, tamarack, and willow along bands of riparian areas. 

The distance between these riparian crossings and the intervening tundra is usually between two and five 

miles. This area is significantly affected by wind, with the snowpack typically transported and redeposited 

by the frequent winds. 

Where the trail crosses the tussock tundra west of Old Woman, repeated use of the trail has altered the 

vegetation within the treadway. Repeated snowmobile passage on a single alignment has resulted in a 

slight linear depression or rut along the trail, which is typically “in-filled” by wind-transported snow. 

Although providing some protection to underlying vegetation, the resulting snowpack and altered thermal 

and moisture regimes are accompanied by subtle changes in vegetation. The summer trail alignment is 

otherwise undisturbed and does not show any signs (such as rutting and erosion) of the passage of 

summer OHVs, with vegetation growing between ankle and knee height. The effects of trail use through 

the riparian vegetation in the western half of this segment are similar to the effects described for the 

eastern half (Tripod Flats to Old Woman Creek). 

Views from along the trail are broad and expansive. Tree line on the low mountains along the route, 

especially on the western half, is barely above the valley floor; therefore, outstanding views are found 

throughout the segment. 

The Kaltag Portage trail segment is eligible for the NRHP under Criterion A for its significant association 

as a winter transportation and mail delivery route and for association with the Serum Run of 1925. The 

trail segment is also eligible under Criterion C for its important construction and design features that 

distinguish it as a gold-rush era winter trail. The period of significance is 1900-1942 (BLM 2017c). A 

number of NRHP-eligible prehistoric and historic sites and landforms are found on BLM-managed public 

lands in this segment, including Old Woman Mountain, which is one of the most well-known landforms 

on the entire INHT. Old Woman Mountain was used historically as an observation post for hunters, as its 

central location in the Unalakleet Valley provides outstanding views of the adjacent mountain highlands 

and river bottoms. On clear winter days, ridges located 30 miles distant are plainly visible from the peak. 

The summit of Old Woman Mountain is easily accessed both in summer from Old Woman Creek and in 

winter from the INHT, which passes directly below the north side of the peak. 

The Ten Mile Cabin Site (NOB-033) is the remains of a former log shelter cabin site developed by the 

Alaska Road Commission along the Kaltag Portage, approximately 40 miles from Unalakleet and 31 

miles from Kaltag. The cabin served as a rest stop for gold miners and mail carriers passing between the 

Alaskan interior and western coast. The site is eligible for the NRHP under Criterion A for its significance 

as a functional component of the INHT, and for its association with the Alaska Road Commission and 

Territorial Board of Road Commissioners to establish and maintain infrastructure in the Alaska Territory. 

The site is also eligible under Criterion D as a preserved archaeological site (BLM 2017c). 

The Kaltag Portage segment is uninhabited, although a number of small private fishing cabins located on 

Native allotments dot the Unalakleet Wild and Scenic River to the north and west of the segment (outside 

of BLM-managed public lands). These cabins are not visible from the trail and are not connected by 

visibly marked side trails. These cabins are used mainly in the summer for subsistence purposes, with 

summer access provided by river boat (rather than overland). 

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Other than the cleared corridor for the Iditarod Trail, there are no manmade features (e.g., power lines, 

transportation corridors, buildings, or cleared areas) along, visible from, or near the Kaltag Portage 

segment, including from the summit of Old Woman Mountain. There are no sources of artificial light 

along this segment of trail, making this segment an outstanding ‘dark sky’ resource area.

Native corporation lands and State lands adjoin the trail at both ends, with the trail located on public 

transportation easements on these adjacent lands. The eastern portion of the segment between Tripod Flat 

and Old Woman Creek is mostly located within the boundaries of the Unalakleet Wild and Scenic River, 

which the BLM also manages. 

In the 1980s and 1990s, the BLM established two public shelter cabins on this segment and a short steel 

bridge across the creek near the Tripod Flat shelter cabin, and in the past decade, marked treeless 

segments of the trail (west of Old Woman Mountain) with tripods, reflectors, and waymarking distance 

signs. The nearest community to the Tripod Flat shelter cabin is Kaltag at 26 trail miles. The nearest 

community to the Old Woman shelter cabin is Unalakleet at 35 trail miles. 

Trail use on the Kaltag Portage segment is split between local and regional use for transportation, 

subsistence, trapping and casual recreation, and trail-based competitive events. Among regional resident 

trail users, the BLM public shelter cabins are very heavily used, with three quarters of all reported trail 

users for this segment visiting one or more cabin (Fix 2011). 

Virtually no trail use occurs on the Kaltag Portage segment during the summer due to lack of overland 

surface transportation improvements, although hearty Arctic adventurers occasionally traverse the route 

by foot in summer. Some river boat travelers may travel upriver beyond Old Woman Creek and 

incidentally use short segments of the trail along the Unalakleet Wild River Corridor. Log jams and low 

water frequently prevent access above Old Woman Creek. 

Bonanza Creek Segment 

A 7-mile segment of the Takotna-Flat Primary Trail is currently managed by the BLM, is a CSU, and is 

eligible as National Conservation Lands, but is selected by the State of Alaska for conveyance under the 

statehood act. The segment is approximately 15 air miles east of the ghost-town of Flat, is in the 

northeast-southwest upper Bonanza Creek, and includes the confluence of Ruby Creek. This segment is 

referred to as the “Bonanza Creek segment” in this document. 

Four historic roadhouses and safety cabins were in this area, all of which had collapsed at the time of 

inventory for the 1986 CMP. The area is extremely remote by contemporary standards, is not accessible 

except overland in the winter or by helicopter in the summer and sees little human use of any kind. The 

only visible human features on the landscape are faint traces of narrow cleared corridors for the overland 

winter trail between Takotna and Flat. 

Anvik-Shageluk-Iditarod Segment 

The next major BLM-managed segment of the INHT within the planning area is 13 miles of the 

uninhabited 65-mile Connecting Trail alignment between Anvik and Shageluk and the abandoned Iditarod 

townsite. This segment leads to the 120-mile uninhabited trail to Takotna and McGrath. In 1987, the 

Secretary of the Interior added the Anvik-Shageluk-Iditarod segment to the INHT System. Use of the 

segment is very light, except in odd-numbered years, when the Iditarod Sled Dog Race and the Iditarod 

Invitational Ultramarathon traverse this segment. Due to a lack of snow and concern for participant 

safety, this route was not used by the Iditarod Sled Dog Race between 2013 and 2018. In 2009, the BLM 

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Section 4. Special Designations Appendix M: BSWI Affected Environment Report 

partnered with a variety of local and State stakeholders and built a new shelter cabin on State lands 

approximately 10 miles east of BLM-managed lands at the trail crossing of the Big Yetna River. 

Rohn Site 

Another INHT-related site managed by the BLM within the planning area is Rohn Air Navigation Site. 

For the past century, Rohn has been the site of the only habitable public shelter between Rainy Pass 

Lodge, 25 air miles to the east, and Nikolai, 60 air miles to the north. The site consists of 400 acres of 

upland forest at the confluence of the South Fork Kuskokwim River and the Tatina River. Built facilities 

include a 1,200-foot unmaintained gravel airstrip, the Primary Trail of the INHT and a segment of 

Connecting Trail, and the historic Rohn Public Shelter Cabin. The public shelter cabin is the oldest 

historically intact structure open for public use and managed by the BLM on the entire trail. 

The first roadhouse was established at Rohn in 1910. It was used throughout the Iditarod gold rush until it 

burned down in 1924. Subsequently, a new cabin was built and survived until it was washed away by the 

Tatina River in 1984. In the late 1930s, the 400-acre site was withdrawn for public use by the U.S. 

Department of Interior for the development of an emergency airstrip and shelter cabin by the Civil 

Aeronautical Administration. At that time, the Civilian Conservation Corps built what is today known as 

the Rohn Public Shelter Cabin. 

Today, the Rohn Public Shelter Cabin is one of the most well-known cabins on the INHT, having been 

used for over 40 years as the first checkpoint for Iditarod Sled Dog Racers north of the Alaska Range. The 

shelter cabin and airstrip are also used as a checkpoint on the Irondog Race and frequently as a base camp 

in late summer for sheep hunters. The 400-acre site also houses a set of automatic, Internet-based weather 

monitoring cameras, installed and maintained by the Federal Aviation Administration, which provide 

real-time images of weather conditions over the adjacent Alaska Range. Due to the historic significance 

of Rohn, the site is eligible for and managed (per BLM policy) as if it were listed on the NRHP, in order 

to protect its historic values. 

Flat (Abandoned Townsite) 

As one of the largest intact ghost towns in Alaska, the Flat mining town and area, 80 miles southwest of 

McGrath, is one of the most significant historic areas associated with the entire INHT System. Flat was 

the source of almost all of the gold carried on the historic Iditarod Trail and was the reason both the town 

and the trail of the same name were established and used in the early 1900s. 

Per BLM Alaska Technical Report 60 (Kurtak et al. 2010), the Flat area (including Chicken Mountain) 

has high locatable mineral potential. Historically, the Flat area ranks as the fourth-highest gold-producing 

area in Alaska, and Flat Creek is the highest-producing drainage (650,000 ounces gold) in the planning 

area. 

Dredge mining began in the Flat area in 1914 and continued until 1966. Since then, the population 

dwindled until there were no year-round residents by the end of the twentieth century. Active mining still 

takes place on a few unpatented, active claims with operators accessing the area seasonally by the 6,000-

foot runway in the Flat valley. (The Flat airstrip, built on mining tailings, is the only airfield within 

hundreds of square miles capable of handling large, multi-engine fixed-wing freight aircraft.) 

Four rectangular survey townships encompassing 144 square miles have been transferred to Doyon, Ltd., 

a regional Native corporation, as part of their entitlement under the ANCSA. Doyon, Ltd. owns all surface 

and subsurface lands in this block, except for the active, unpatented federal mining claims in the area. On 

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active, unpatented federal mining claims, the mining claimant has the right of use of the subsurface estate, 

with the BLM in the role as the manager of the surface estate during the time of active mining claimant 

occupancy. 

When an active federal mining claim is abandoned and voided, it becomes the responsibility of the BLM 

to transfer the claim and complete the surrounding conveyance and, if necessary, remove any 

contamination before the transfer is made. The segments of the INHT located on active, unpatented 

federal mining claims are managed by the BLM. The amount of contamination in the historic town site 

has never been assessed and is unknown. 

Twenty-nine miles of road are found in the area, with many of the segments co-located with the INHT 

route. A number of segments are located on lands currently managed by the BLM. Altogether, 13.3 miles 

of the INHT Primary Trail and 33.6 miles of INHT Side/Connecting Trail are located within the 

townships in the Flat area transferred to Doyon, Ltd. Almost 5 miles of the INHT system are located on 

active, unpatented federal mining claims (3 miles of Primary Trail and 1.82 miles of Connecting Trail), 

meaning that these segments are managed by the BLM. 

The entire historic town site, which comprises approximately 180 acres, is eligible for the NRHP. The 

over 100 structures and two intact dredges located in the area are significantly deteriorating due to 

weathering. The structures are approaching the point of not being suitable for the most minimal of historic 

preservation, historic stabilization in place (which makes minor improvements that allow a structure to 

withstand weathering). As is, the town’s historic resources are subject to pilferage, as has been

documented in the past decade at the historic Iditarod townsite. 

If the site was stabilized and ownership, public access, and maintenance issues were resolved, the area 

could provide outstanding public education and historic research opportunities, such as has provided for 

at stabilized historic abandoned towns such as Rhyolite, Nevada, and Bodie, California. 

4.2.5 Resource Changes: Trends and Forecasts 

Natural Processes Affecting Trail Resources 

The primary natural phenomena directly affecting trail resources are erosion, wildfire, and changes to the 

length and intensity of winter weather. A number of historic roadhouses and shelter cabins originally 

located near waterways are either vulnerable to, or have been washed away by, shifting river and creek 

beds. 

Wildfire is a natural part of the biologic regime for the area crossed by the trail. As a result, historic 

structures, historic trail landforms, and contemporary public facilities are vulnerable to loss from wildfire. 

The season, frequency, and intensity of wildfires in the planning area appear to be increasing (BLM GIS 

2016; Chapin et al. 2010), exacerbated by record-setting low precipitation winters in the past ten years 

(Hinzman et al. 2006). 

Within the past seven years, a number of large, intense wildfires have threatened some of the trail’s most 

significant resources, and, in one case, destroyed a historic roadhouse. It is now not unheard of for fires to 

start in the winter and/or overwinter due to dry conditions. The 2009 Post River Fire started in March of 

that year (possibly human caused), burnt over 10 miles of trail, and likely overwintered into 2010. 

Renamed as the Turquoise Lake Fire in 2010, 27 miles of the trail and the historic Pioneer Roadhouse site 

were burnt over by an extremely hot fire that destroyed both surface vegetation and soil and created 

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Section 4. Special Designations Appendix M: BSWI Affected Environment Report 

dangerous trail use conditions. As a result, expensive trail clearing efforts by trail supporters were 

undertaken to make the route usable and safe. 

In 2015, 20 miles of the trail were burnt over by the Iditarod River Fire, and, without active fire 

suppression response by the Alaska Fire Service and Alaska Division of Forestry, both the historic towns 

of Iditarod and Flat would have been destroyed. The same year, 15 miles of trail were burnt over by the 

Old Woman Fire on the Kaltag Portage segment in an area that previously had rarely seen lightningcaused wildfire. In the Old Woman Fire, active fire suppression was required to save the BLM Tripod 

Flat Public Shelter Cabin. In 2016, the BLM’s Bear Creek Public Shelter Cabin on the Farewell Burn 

segment would have been lost to a lightning-caused wildfire burning within 1,400 feet of the cabin if not 

for the response of the Alaska Division of Forestry. 

A significant shortening of the winter travel season on the trail appears to have occurred in the last 15 

years. Typically, the trail travel season (with enough below-freezing days to freeze waterways for 

snowmobile use and to provide precipitation in the form of snow) could be expected to begin usually by 

December of each winter and extend through mid-April. Frozen waterways provide solid winter bridges 

and routes through country that requires a boat or is otherwise impassable. In addition, a number of onland segments of the INHT in the planning area are “bridged” by and rely on frozen waterways to provide 

a continuous trail. 

In recent years, late freeze-ups have become more common, with larger rivers in the planning area (i.e., 

Yukon and Kuskokwim) freezing and then thawing late in the year or remaining unfrozen in some places 

throughout the winter. In response, trails have been rerouted onto land routes, and a number of traildependent sled dog and snowmobile races have been postponed, rerouted, or canceled. While detailed 

records are not available to indicate trends, deaths and near-death experiences to winter waterway 

travelers are a regular occurrence within the planning area. 

Mid-winter rain events have also become more common, along with significant decreases in precipitation 

in the form of snow. The diminished snowpack melts quicker than typical snowpacks in the lengthening 

days of spring. Unalakleet receives 13.5 hours of daylight, not including twilight, on March 30. As a 

result, the winter trail travel season has been ending by late March, compared with the more typical 

break-up of winter conditions in mid-April. 

Human Effects on Trail Resources 

The BLM-managed segments of the INHT in the planning area, including adjacent viewsheds, are almost 

entirely unaffected by human-induced land uses, such as resource extraction, energy generation, 

transmission, forestry, or transportation projects. The existing (public) structures and land uses found 

along the trail and its viewshed were developed for the purposes of, and are consistent with the scale and 

history of human use of, the INHT. 

The continued modification of vegetation in the form of an actively used and cleared trail travelway is 

consistent with the historic human use of the trail. While experiencing some modification to species type, 

contemporary Iditarod Trail tread vegetation is undisturbed and does not show any signs (such as rutting 

and erosion) of summer OHV passage. In the winter, most of the vegetation disappears into the snowpacked trail treadway. 

Casual public use along the trail usually coexists with competitive events and permitted events. This has 

the effect of increasing public observation of events and also reducing the wilderness-like setting along 

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Appendix M: BSWI Affected Environment Report Section 4. Special Designations 

the trail during these events. The BLM Rohn Public Shelter Cabin is used as an event checkpoint for a 

number of trail-based events. 

On an intermittent basis, the BLM receives requests to run modified highway vehicles on BLM-managed 

segments of the trail, often as part of a media-driven “stunts” to cross some part of the winter north 

country in a particular vehicle. Such use would require significant widening of existing trail corridors, and 

could result in rutting of the winter snowpack in a manner that could present a significant hazard to other 

trail users. (The inner tire width of typical highway vehicles is slightly less than average width of a 

snowmobile or dogsled. Attempting to drive a snowmobile or dogsled on top of the “snow median strip”

between the two ruts is dangerous, as it is easy to fall into one of the ruts, and in the case of the 

snowmobile, have it roll on top of the driver.) For these reasons, the BLM does not approve of such uses 

along the trail. 

With diminishing annual snow, local planning area residents are increasingly using OHVs year-round to 

drive on frozen tundra or waterways, as well as community roads. The OHVs used are either unmodified 

or have after-market attachments such as ‘track-sets’ for each drive wheel. Such OHVs also have the 

potential to create a significant hazard via the creation of parallel ruts to other trail users who rely on a 

single-lane packed treadway. Because almost all segments of the BLM-managed trail are located far from 

local communities, this use has not presented a problem to date, but will be monitored. 

The introduction of nonnative, invasive vegetation along the trail is another documented effect of human 

use of the trail. Starting in the late 1980s, the use of straw as dog bedding became a common practice at 

Iditarod Sleddog Race checkpoints, including at the BLM’s Rohn Public Shelter Cabin. With the 

hundreds of bales of straw imported to Rohn annually came invasive weed seeds. The invasive weeds 

established at Rohn and a few other shelter cabins. The BLM has inventoried the extent of invasive 

colonization along the BLM segments of the INHT, undertaken control efforts, and is monitoring the 

effectiveness of such efforts (Flagstad and Cortes-Burns 2010; Greenstein 2013). The BLM now requires 

the use of certified weed-free straw as part of permit requirements for use of BLM facilities and 

immediate removal or destruction (by fire) after its use. 

Trail Management 

Approximately 62 miles of the congressionally designated primary trail is located on BLM-managed 

lands within the planning area, including 20 miles in the area known as the Farewell Burn, 35 miles 

between Unalakleet and Kaltag, and 7 miles in the Bonanza Creek area. The contemporary and the 

historic alignment of the trail are closely co-located in the Farewell Burn segment. 

On the Kaltag Portage segment between Unalakleet and Kaltag, the contemporary alignment of the trail 

wanders on and off of the historic alignment, reflecting contemporary overland trail routing decisions, but 

the two alignments are generally located within one-quarter mile or less from each other and are usually 

co-located at terrain “pinch points” or the location of now-historic structures. 

No attempt has been made to conclusively identify the location of the historic alignment on BLMmanaged lands on the Kaltag Portage, as the NTSA provides for the use of contemporary alignments in 

the place of historic alignments when advantageous to contemporary circumstances. 

To deal with the issue of the wandering trail alignment relative to the historic and contemporary 

alignment issue and year-to-year differences, the CMP (BLM 1986c) recommended the designation of 

management corridors for both Primary and Connecting/Side Trails. The purpose is to provide adequate 

space for route variations, while maintaining the values of the lands for which the trail was established 

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Section 4. Special Designations Appendix M: BSWI Affected Environment Report 

and preventing incompatible land uses from impacting the values of the trail. Since the 1986 CMP, 

conditions in the area have changed and those discussed in the CMP are out of date. 

The CMP (BLM 1986c) recommends a corridor in the Farewell Burn segment of 100 feet (for non-BLMmanaged lands) to 1,000 feet (for BLM-managed lands), and on the Kaltag Portage segment a minimum 

of 1,000 feet. (The width of the corridor is centered on the contemporary trail treadway, with 500 feet on 

either side of centerline.) 

Formal rulemaking or implementation of a policy on BLM-managed lands within the planning area for 

the withdrawal and/or delineation of a management corridor specifically for the INHT has not occurred to 

date. 

Of the 35 miles of the Kaltag Portage segment on BLM-managed lands, approximately 20 miles are 

located within the boundaries of lands withdrawn under ANILCA for the Unalakleet Wild and Scenic 

River. The WSR designation protects a river’s outstandingly remarkable values and free-flowing 

character, protects existing uses of the river, prohibits federally licensed dams, and establishes a onequarter-mile protected corridor on both sides of the river. It is within these corridor boundaries that 20 

miles of the Kaltag Portage segment of the INHT is located (although portions of the recommended 

1,000-foot plus trail corridor are outside of the boundaries of the river corridor). 

The entire INHT Kaltag Portage segment centerline is located within the proposed Unalakleet River 

ACEC (BLM 2018b). Portions of the recommended 1,000-foot plus trail corridor are outside of the 

ACEC. 

The BLM-managed public lands at the Farewell Burn segment are closed to mineral entry, with the 

exception of metalliferous metals, under PLO 5180, stemming from Section 17(d)(1) of ANCSA. Lands 

within the Unalakleet Wild River Corridor are closed to all mineral entry. BLM-managed lands to the 

south of the Unalakleet Wild River Corridor (PLO 5184 and 5173) are also closed to mineral entry 

(BSWI Draft RMP/EIS, Map 3.3.5-1). 

Section 207 of the Alaska Land Transfer Acceleration Act (P.L. 108-452) directed a review and report to 

Congress of withdrawal orders made pursuant to Section 17(d)(1) of the ANCSA. The report 

recommended that approximately 95 percent of the Section 17(d)(1) withdrawals be lifted but 

recommended acreage of withdrawals overlapping WSRs and the Trans-Alaska Pipeline be retained. This 

analysis did not include the INHT, a conservation system unit under ANILCA similar to WSRs. 

The INHT Primary Trail on BLM-managed lands (both inside and outside the planning area) is a unit of 

BLM’s National Conservation Lands throughout the country. Established administratively in 2000 and 

then by law in the Federal Omnibus Public Lands Management Act of 2009, National Conservation 

Lands encompass 26 million acres of the BLM’s most spectacular lands and waters. 

The boundaries of National Trail National Conservation Lands units have not been established. In 

September 2012, the BLM issued a new policy requiring establishment of a NTMC for each National 

Trail managed by the agency. Per BLM Manual 6280 (BLM 2012c), delineation of a NTMC is a land 

allocation established through the BLM’s land use planning process (e.g., this document), pursuant to 

Section 202 of FLPMA, and Section 7(a)(2) of the NTSA (“rights-of-way”), for a BLM public land area 

of sufficient width within which to encompass National Trail resources, qualities, values, and associated 

settings and the primary use or uses that are present or to be restored, and to achieve and maintain the 

nature and purpose for which the trail was designated. 

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Appendix M: BSWI Affected Environment Report Section 4. Special Designations 

For the INHT Primary Trail segments on BLM-managed lands, the CMP (BLM 1986c) recommended a 

minimum of a 1,000-foot-wide management corridor. A 1,000-foot wide corridor would be inadequate to 

meet the BLM’s policy for the NTMC. This is because the NTMC should be based on the presence of the 

“resources, qualities, values and...settings” for which the trail was designated and should be based on 

“associated natural or manmade physical features in the following order of precedence: ridgelines, rivers, 

washes, and toe-of-the-slope, turning points such as peaks, buttes and geologic features; roads, primitive 

roads or routes, railroads, and lines of the Public Land Survey System. Measures such as footage, mileage 

and contour intervals shall be discouraged. If certainty in location of a corridor boundary may be an issue 

(e.g., in a case of flat or ill-defined ridgeline bordering an incompatible land status or usage), then lines of 

the Public Land Survey System shall be considered” (BLM 2012c). 

All BLM-managed lands within the planning area are undesignated for OHV use, meaning the entire 

planning area is open to OHV use. (This designation does not pertain to large cat-trains, which require 

pre-use permitting.) To date, BLM-managed segments of the INHT are largely unaltered by OHV use due 

to the INHT’s remoteness and a user preference for winter travel by snowmobile rather than OHV. OHV 

use is neither a traditional use nor a historic use of the INHT. 

4.3 Wild and Scenic Rivers 

4.3.1 Introduction 

This section describes laws, regulation, and policy and existing conditions for designated and eligible 

WSRs within the planning area. 

4.3.2 Laws, Regulations, and Policies 

The National Wild and Scenic Rivers Act (16 U.S.C. 1271-1287) was established to preserve certain 

rivers with outstanding natural, cultural, and recreational values in a free-flowing condition for the 

enjoyment of present and future generations. Section 5(d) (1) of the National Wild and Scenic Rivers Act 

requires that the BLM and other federal agencies inventory streams on public lands to determine their 

eligibility and suitability to be components of the National System. 

ANILCA (P.L. 96-487) classified and designated 65 miles of the upper portion of the Unalakleet River as 

a “wild” river and, subsequently, a component of the National System. In addition to river management 

provisions provided by the National Wild and Scenic Rivers Act, ANILCA provides for a 0.5-mile 

boundary on both sides of the river quarter-mile (average of 640 areas per river mile) protected corridor. 

BLM’s Manual 6400: Wild and Scenic Rivers – Policy and Program Direction for Identification, 

Evaluation, Planning, and Management (BLM 2012d) replaces Manual 8351 (Release 8-61) to provide 

policy, direction, and guidance for the identification, evaluation, planning, and management of eligible 

and suitable WSRs and the management of designated components of the National System (BLM 2012d). 

4.3.3 Resource Indicators 

The conditions that are established in the discussion below provide a baseline for WSRs, which the 

impact analysis will be based on. The following indicators, along with qualitative discussions, will be 

used to evaluate impacts associated with management decisions in the BSWI Draft RMP/EIS. 

The primary indicators of change to WSRs are as follows: 

• Impact to identified Outstandingly Remarkable Values (ORVs) 

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Section 4. Special Designations Appendix M: BSWI Affected Environment Report 

• Change in tentative or designated classification (wild, scenic, or recreational) 

• Change in water quality and free-flowing nature of the river corridor 

Land management decisions that could affect ORVs identified for the designated or eligible river and its 

tentative classification pertain to the following: 

• Land disposal 

• Locatable or salable minerals 

• ROW avoidance or exclusion areas 

• VRM designations 

• Grazing 

• Special-status species management 

• Special designations, such as ACECs or HVWs 

• Fire suppression 

• Commercial Woodland harvest 

• Overland summer or winter trails and other areas open to casual and/or subsistence OHV use 

• Subsistence use 

• State-regulated game management units 

4.3.4 Current Conditions 

Current Management Direction 

Current management of river resources is currently through the SWMFP. The SWMFP identifies the 

Unalakleet as a WSR and excludes the WSR corridor from oil and gas leasing and other types of entries 

(BLM 1981). Management direction for the Unalakleet Wild River Corridor is provided in the ANILCA 

and Unalakleet National Wild River Management Plan (BLM 1983); management actions are specified in 

that plan for subsistence, facilities, visitor management, surface transportation, publicity, private lands 

(native allotments), fisheries habitat management, local involvement, navigability, fire management, and 

cultural resources. See BSWI Draft RMP/EIS, Map 3.4.3-1 for WSRs in the planning area. 

Designated Rivers 

The upper 83 river miles of the Unalakleet Wild River Corridor are designated as “wild” and managed by

the BLM per the Unalakleet Wild and Scenic River Management Plan (BLM 1983). This wild river is free 

of impoundments, inaccessible by trail in the summer months and accessible in the winter by 

snowmobile, with primitive watersheds and shorelines, and unpolluted waters. Twelve Native allotments 

are located along the shoreline within the lower limits of the designated corridor, which are mainly used 

as subsistence fish camps. No ORVs were identified for the Unalakleet Wild River Corridor; however, the 

BLM manages the Unalakleet Wild River Corridor to preserve the environment and the ecosystems of the 

river, protect free-flowing character and water quality, provide high-quality primitive recreation 

opportunities, maintain wildlife/wildlands-oriented use, and protect historic and archaeological values 

(BLM 1983). 

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Three organized and permitted dogsled races occur on the INHT, where the trail parallels the river within 

the designated WSR corridor. Other winter casual use activities within the river corridor include 

snowmobiling, dog mushing, ice fishing, hunting, and trapping. The Unalakleet Wild River Corridor 

supports such summer activities as fishing, boating, and camping. Typical visitation occurs July through 

mid-September; however, summer visitation on the river is low compared to other more accessible 

designated WSRs in Alaska. One fishing lodge is located downstream of the BLM-managed WSR 

corridor; however, outboard fishing boats associated with the fishing lodge do not typically travel 

upstream to the WSR corridor (BLM 2015a). 

The Unalakleet's smooth waters can be easily traversed by raft or canoe, providing visitors an opportunity 

for solitude. Float trips from the confluence of the Unalakleet and the Old Woman Rivers to the mouth 

(approximately 62 river miles) require an average of five days. Visitors use the many gravel bars along 

the way for camping, fishing, and spotting wildlife. Due to its remote location, upriver access is difficult 

without a motorized boat (BLM 2015a). 

The Unalakleet Wild River Corridor contains all five species of Pacific salmon, Dolly Varden, char, and 

arctic grayling. The ADF&G regulates sport fishing within the WSR corridor. Unalakleet River Chinook 

salmon were listed as a stock of yield concern in 2004 (Kent and Bergstrom 2009). Currently, Unalakleet 

River Chinook salmon are also considered to be in a period of low productivity, and the Alaska Board of 

Fisheries has designated Unalakleet River Chinook salmon a stock of yield concern (Kent and Bergstrom 

2009). Additionally, Arctic grayling populations in the Unalakleet River are particularly susceptible to 

fishing pressure due to their proximity to communities (BLM 2015a). 

Alaska Natives rely upon the resources of the Unalakleet Wild River Corridor to support their subsistence 

lifestyle. FM2201 permits are issued by the BLM to federally qualified subsistence users in Unalakleet. 

For FM2201, federal public lands are closed to the harvest of moose except by residents of Unalakleet. 

Moose are an important subsistence species for the residents of local villages, particularly the Village of 

Unalakleet, and are managed under ANILCA on federal lands, and for sustained yields by ADF&G (BLM 

2018b). Cooperation and coordination with the ADF&G is needed to manage the concurrent and 

collocated State hunt (RM841). The BLM Anchorage Field Office has the authority to close the season in 

consultation with ADF&G (BLM 2015a). 

Eligible Rivers 

The BSWI WSR Eligibility Study (BLM 2018e) summarizes the eligibility determinations for 255 

waterways within the planning area. A total of 237 waterways were found ineligible and dropped from 

further study. Eighteen waterways were found eligible and were assigned a tentative classification of 

wild, scenic, or recreational by the BLM. Rivers identified as eligible would continue to be managed per 

guidelines provided in BLM Manual 6400 (BLM 2012d). These guidelines would protect free-flowing 

condition, water quality, wild river classification, and ORVs. Table 4.3.4-1 summarizes the eligibility 

determinations and tentative classifications for these rivers. The Yukon River is also included within the 

National Rivers Inventory list. 

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Section 4. Special Designations Appendix M: BSWI Affected Environment Report 

Table 4.3.4-1. Eligibility Determinations of 18 Rivers Located in the Planning Area 

Watercourse 

Approximate 

Total Length 

(miles) 

Approximate 

Length on 

BLM Lands 

(miles) 

Outstandingly 

Remarkable 

Value(s) Region of Comparison 

Anvik River 150 119 Fish, Cultural Yukon River 

Bear Creek (Nikolai) 51 41 Fish, Historic Kuskokwim River 

Big River 137 35 Fish Kuskokwim River 

Blackwater Creek 67 12 Fish Kuskokwim River 

Canyon Creek 16 16 Fish Yukon River 

Middle Fork Kuskokwim River 131 52 Fish Yukon River 

North Fork Unalakleet River 48 48 Fish Unalakleet River 

Otter Creek (Anvik) 35 35 Fish Yukon River 

Otter Creek (Tuluksak) 27 5 Fish Yukon River 

Pitka Fork Middle Fork 

Kuskokwim River 92 62 Fish, Historic Kuskokwim River watershed 

Salmon River (Nikolai) 35 21 Fish, Historic Regional. INHT; Kuskokwim 

River 

Sheep Creek 61 36 Fish Kuskokwim River 

Sullivan Creek 22 22 Fish; Historic Regional. INHT; Kuskokwim 

River 

Swift River (Anvik) 32 31 Fish Kuskokwim River 

Tatlawiksuk River 81 17 Fish Kuskokwim River 

Theodore Creek 15 15 Fish Yukon River 

Yellow River 72 70 Fish Yukon River 

Yukon River 1291 13 Cultural Yukon River 

4.3.5 Resource Changes: Trends and Forecasts 

Because of the remoteness of the planning area, the designated wild Unalakleet Wild River Corridor 

remains stable, with no existing plans or pressure for increased access to the WSR that could affect its 

classification as a wild river. Likewise, the corridor continues to be used for primitive recreation 

opportunities, including recreation boating and the Iditarod Race. Historic and archeological values, 

wildlife/wildlands use and water quality remains stable, again largely due to the remoteness of the WSR 

corridor. 

Regarding the environment and ecosystems, Unalakleet River Chinook salmon were listed as a stock of 

yield concern in 2004 (Kent and Bergstrom 2009). Moose populations within the Unalakleet watershed 

are at historically low levels, however, slowly increasing with intensive population management 

coordinated by State and federal agencies (BLM 2015a). 

4-24 
 

 

 

Appendix M: BSWI Affected Environment Report Section 5. Social and Economic Conditions 

Section 5. Social and Economic Conditions 

5.1 Socioeconomics, Environmental Justice, and BLM Support for BSWI 

Communities 

5.1.1 Laws, Regulations, and Policies 

Multiple statutes, regulations, executive orders, and agency direction identify the general requirement for 

the application of economic and social evaluation in support of BLM planning and decision making. 

These include, but are not limited to, NEPA (83 Stat. 852; 42 USC 4321, 4331-4335, 4341-4347), 

FLPMA (P.L. 94-579; 90 Stat. 2744; 43 USC 1701), and ANILCA (P.L. 96-487; 94 Stat. 2371; 16 USC). 

These laws are described elsewhere in this document and are not repeated here. 

EO 12898, Federal Actions to Address Environmental Justice in Minority Populations and Low-income 

Populations, requires that federal agencies identify and address any disproportionately high and adverse 

human health or environmental effects of their programs, policies, and activities on minority and lowincome populations. 

The BLM’s IM No. 2013-131 describes when and how to consider nonmarket values when preparing 

NEPA analyses for BLM resource management planning and other decision-making. The IM directs BLM 

managers to use estimates of nonmarket environmental values in NEPA analysis supporting planning and 

other decision-making where relevant and feasible, and to include at least a qualitative description of the 

most relevant nonmarket values for the affected environment and the impacts of alternatives in NEPA 

analyses. 

Guidance for evaluating environmental justice issues in land use planning is included in Appendix D of 

the BLM planning handbook (BLM 2005). Environmental justice involves the fair treatment and 

meaningful involvement of all people regardless of race, color, national origin, or income with respect to 

the development, implementation, and enforcement of environmental laws, regulations, and policies. Fair 

treatment means that no group of people, including racial, ethnic, or socio-economic group should bear a 

disproportionate share of the adverse environmental consequences resulting from industrial, municipal, 

and commercial operations or the execution of federal, State, local, and tribal programs and policies. 

In addition to determining if its proposed actions will adversely and disproportionally impact minority 

populations, low-income communities, and tribes, the BLM has established environmental justice 

principles that include promoting and providing opportunities for full involvement of minority 

populations, low-income communities, and tribes in BLM decisions that affect their lives, livelihoods, 

and health. Where disproportionately high adverse impacts are anticipated, the BLM will work with local 

community groups/associations, governments, and tribal leaders to determine if land disposition and/or 

acquisition policies affect real estate values and real income of minority and low income communities, 

and Tribes. 

CEQ guidelines for evaluating the potential environmental effects of projects require specific 

identification of minority populations when either: (1) a minority population exceeds 50 percent of the 

population of the affected area; or (2) a minority population represents a meaningfully greater increment 

of the affected population than of the population of some other appropriate geographic unit as a whole. 

Black/African American, Hispanic, Asian and Pacific Islander, American Indian, Alaska Native, Aleut, 

and other non-White persons are defined as minority populations. 

5-1 
Section 5. Social and Economic Conditions Appendix M: BSWI Affected Environment Report 

5.1.2 Resource Indicators for Economic Conditions 

The baseline conditions that are established in the discussions below provide a baseline for social and 

economic conditions-related values, which the impact analysis will be based on. The following indicators, 

along with qualitative discussions, will be used to evaluate impacts associated with management 

decisions in the BSWI Draft RMP/EIS. 

Non-Market Values 

• Acres of HVWs, WSR corridors, and ACECs 

• Acres of caribou corridor management 

• Acres of Innoko Bottoms Priority Wildlife Habitat Area management 

• Acres of land managed to preserve wilderness characteristics 

• Acres of land within 15 miles of villages closed to commercial hunting 

• SRP allocation limitations for guide-outfitter hunting 

• Authorization of commercial use of shelters/cabins 

• Acres of motorized travel by season and vehicle type for subsistence purposes 

Market Values 

• SRP evaluation of guide-outfitters permittees consideration of community relationships 

• Acres of land within 15 miles of villages closed to commercial hunting 

• Acres of land withdrawn from locatable minerals or closed to leasable or salable mineral 

development 

• Acres of land available for subsistence woodland harvest, and permit requirements 

5.1.3 Resource Indicators for Social Conditions 

The conditions that are established in the discussions below provide a baseline for social conditionsrelated values, which the impact analysis will be based on. The following indicators, along with 

qualitative discussions, will be used to evaluate impacts associated with management decisions in the 

BSWI Draft RMP/EIS. 

• Level of protection for subsistence species and habitats (i.e., greater, less, or the same). This 

overall rating was developed using the impact analyses from Water Resources, Lands with 

Wilderness Characteristics, and ACECs. 

• Level of access to subsistence resources (i.e., greater, less, or the same). This overall rating was 

developed using the impact analyses from Travel and Transportation and Forestry and Woodland 

Products. 

• Level of potential conflict with sport hunters and other users (i.e., greater, less, or the same). This 

overall rating was developed using the impact analyses from Recreation and Visitor Services and 

Travel and Transportation. 

• Level of coordination and collaboration with communities (i.e., greater, less, or the same). This 

overall rating was developed using the descriptions in the BSWI Draft RMP/EIS section on 

Support for BSWI Communities, including level of coordination with BSWI communities, level 

5-2 
Appendix M: BSWI Affected Environment Report Section 5. Social and Economic Conditions 

of monitoring of coordination efforts, and level of information to be collected about community 

subsistence uses and landscape meanings. 

• The global rating for economic effects, both market and non-market, based on the Economic 

Conditions analysis above. Effects on market opportunities, which provide potential for jobs, 

income, or reduced expenses, are a major component of life in bush villages. Effects on nonmarket resource values are also crucial to subsistence and village lifestyles. 

• The rating for effects on environmental justice populations (i.e., greater, less, or the same) was 

developed using information from the other Economic Conditions and Social Conditions 

indicators and effects analyses. 

5.1.4 Current Conditions for Socioeconomics 

This section describes associated social and economic conditions, first at a broader Census Area scale and 

then at the community scale. Alaska does not have counties but is divided into boroughs. Where there are 

no boroughs, data are referenced from federally designated Census Areas. The planning area contains 

portions of five Census Areas: Bethel, Nome, Kusilvak (formerly Wade Hampton), Yukon-Koyukuk, and 

Dillingham. For the purposes of socioeconomic analyses, the Dillingham Census Area is excluded; the 

northern portion of the Dillingham Census Area overlaps with the planning area, but there are no 

communities or BLM-managed lands in that overlap area. While BLM-managed public lands are often 

located relatively far from communities, they provide resources, travel corridors, and subsistence and 

livelihood opportunities for nearly all the main villages. Socioeconomic regions are shown in BSWI Draft 

RMP/EIS, Map 3.5.1-1. 

The four Census Areas contain many communities that are well outside the planning area and not 

connected to BLM-managed lands. For example, the Yukon-Koyukuk Census Area extends to the 

Canadian border. For that reason, it is important to focus on the communities that are more directly tied to 

the RMP planning area. Of the approximately 60 rural communities within the planning area, Lingle and 

others (2011) identified 25 villages and census-designated places in the vicinity of BLM-managed public 

land within or near the planning area, grouping them into six regions: Bering Sea, Yukon Delta, Lower 

Yukon, Lower Kuskokwim, Upper Kuskokwim, and Western Interior. These areas also correspond well 

with Game Management Units designated by ADF&G, which will be used for some analyses. To describe 

socioeconomic conditions in communities, Bethel is added because it is a major hub within the planning 

area, and Lime Village is added because it is adjacent to BLM-managed lands in the southwestern part of 

the planning area (see BSWI Draft RMP/EIS, Map 1-2). 

Fifteen of these 27 communities are in the area served by the Calista Corporation, one of the 13 regional 

corporations established under the ANCSA in 1971. Four are served by Bering Straits Native 

Corporation, and eight by Doyon, Ltd. 

Social and economic conditions in Alaska are dynamic and may have changed since the data presented in 

the analysis were compiled and could change again. For example, a University of Alaska Anchorage 

economist in late 2016 suggested that Alaska may be entering or near a recession due to declines in oil 

prices and drops in Alaska development, and as reflected by indicators such as two straight months of 

declining employment, the state's first population drop since the recession in 1987-88, and a $1.9 billion 

drop in State capital spending over the past three years (Anchorage Daily News 2016). The State of 

Alaska Department of Labor and Workforce Development reported that average monthly employment in 

the first six months of 2016 was down 1.6 percent, compared to those months in 2015 (ADLWD 2016). 

5-3 
 

 

 

 

 

 

 

 

Section 5. Social and Economic Conditions Appendix M: BSWI Affected Environment Report 

Demographic Characteristics 

Planning Area. A socioeconomic overview of the four Census Areas produced from the Economic 

Profile System (Headwaters Economics 20134

) provides a snapshot of this broad swath of Alaska and 

illustrates some differences between this area and the state as a whole. For these descriptions, the numbers 

presented are for all four Census Areas combined. 

From 2001 to 2011, population in the four Census Areas increased from 38,754 to 40,590. The increase 

was due to natural change (births minus deaths) rather than in-migration (people moving into the Census 

Areas). Although the rate of change was not the same every year, the average annual increase due to 

natural change was 722 people a year, compared to the average annual out- migration of 506 people per 

year, resulting in a net population increase of about 212 people a year. The population increase of about 5 

percent from 2000 to 2011 was lower than for the State of Alaska’s population during the same period (15 

percent). 

Alaska Department of Labor and Workforce Development (2012) population projections for the 2015-

2035 period estimate that the population will increase in three of the Census Areas, although at different 

rates (Bethel Census Area just over a 1 percent increase every 5 years, Nome Census Area just under 1 

percent every five years, and Kusilvak about 1.5 percent every 5 years) while the Yukon-Koyukuk 

Census Area population will decrease by about 1 percent every 5 years over the 2015-2035 period. In all 

four Census Areas, net migration is projected to be negative (more people moving out than moving in) 

and any population increase is due to natural change (an increased ratio of births to deaths). As is the case 

nationally, the number of deaths in Alaska is expected to increase greatly over the projection period due 

to the aging of the “baby boom” generation (ADLWD 2012). 

The proportion of Alaska Natives in the four Census Areas was just under 80 percent, compared to less 

than 1 percent nationally for all Native Americans combined. Population projections are also made 

separately for Alaska Natives but only at the statewide level (ADLWD 2012). Alaska Natives have much 

higher mortality rates than other races in the United States, but also much higher than average fertility 

rates. The Alaska Native population statewide is expected to increase steadily through 2035, from 

122,480 in 2010 to 159,633 in 2035, and the proportion of Alaska Natives in the general population is 

expected to increase slightly, from 17.1 percent (2010) to 17.4 percent in 2035. As is the case with the 

general population, the proportion of the Alaska Native population over 65 is projected to increase, nearly 

doubling from 6.5 percent in 2010 to 12.2 percent in 2035. 

About 80 percent of the people living in the four Census Areas age 25 or over had high school degrees, 

only slightly lower than the 85 percent nationally. However, the proportion of people with bachelor’s 

degrees or higher level of education was 12 percent in the four Census Areas, compared to 28 percent 

nationally. 

Communities. Select demographic and social characteristics of the 27 communities are described in 

Table 5.1.4-1. Most are second class cities, with seven unincorporated villages (which the U.S. Bureau of 

the Census refers to as Census-Designated Places) and one first class city (St. Mary’s).5 Nine are in the 

4 This system uses data from the 2010 U.S. Census and the American Community Survey, conducted between 2007-2011. 

5 Alaska has three different classifications of city governments: home-rule; first-class; and second-class cities. A community must 

have at least 400 permanent residents to form a home-rule or first-class city; 115 of Alaska’s 144 cities are defined as secondclass. Each category of city has duties and powers defined by state law. For example, second-class cities are allowed, but not 

required, to exercise planning, platting, and land use regulation duties, but they are not allowed to provide public education. For 

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Appendix M: BSWI Affected Environment Report Section 5. Social and Economic Conditions 

Bethel Census Area, eight in Yukon-Koyukuk, six in Kusilvak, and four in Nome. The communities 

range in size from 23 (Red Devil) to 6,080 (Bethel), with eight having a 2010 population under 100, 12 

between 100 and 500, and seven over 500. Between 1990 and 2010, 11 communities increased in 

population, 11 decreased, and five stayed roughly the same size. 

Nearly all of the communities are predominantly Alaska Native, with 15 having a population in 2010 that 

was over 90 percent Alaska Native and another seven over 80 percent. These data are for people who 

reported in the census that they were one race, which in most cases was the vast majority of the 

population. When adding in the number of people who reported they were two or more races, one of 

which was Alaska Native, the total proportion of Alaska Natives increased by more than 5 percent in only 

three communities (McGrath, Takotna, and Red Devil). 

In 16 of the communities, 75 percent of the population over age 25 had a high school degree, and in 10 

communities, 10 percent or more of the population had a bachelor’s degree or higher. 

The number of housing units is generally related to population size, and the percentage of vacant units is 

generally low. Some of the housing units are vacant because they are only seasonally occupied. The 

proportion of houses that have complete plumbing facilities (hot and cold piped water, a bathtub or 

shower, and a flush toilet) ranges from zero in Lime Village and Shageluk to 98 percent in Unalakleet, 

with an average of 62 percent. These compare to the Alaska average of about 88 percent and the national 

average of 97 percent. 

As reported by the Department of Community and Regional Affairs, the other municipal facilities and 

utilities vary widely, with the larger communities providing more facilities; this information was not 

reported for the unincorporated communities. All the communities had schools, butin three the schools 

were inactive in 2010, including in the two smallest planning area communities. School districts, which 

also add to sustained employment, are located in several of the larger communities: Aniak, Bethel, 

Mountain Village, Unalakleet, Saint Mary’s, and McGrath. 

In 2009−2010, the Lower Yukon School District, which has schools in several communities within the 

planning area, conducted a community dynamics survey to gain information that would help foster and 

maintain effective school-community relations (BLM 2015a). 

The response rate was low and about two-thirds of those responding were school district staff members 

and one-quarter were parents of school-age children. Results suggested that respondents believe that 

community leaders occasionally seek opportunities to collaborate with community members, and 

occasionally respond to and seek resources that support the social, emotional, and physical health of the 

community, although leaders are perceived as frequently or extensively providing and maintaining 

services such as running water and sewage disposal to and from homes. Community members were seen 

as frequently encouraging participation in community cultural events and seasonal activities and 

emphasizing cultural awareness to promote a positive community climate. Schools were viewed as 

frequently establishing effective means of communication between homes and schools, while family 

support for children as life-long learners was viewed as occasional. 

additional information, see: 

https://www.commerce.alaska.gov/web/Portals/4/pub/2015%20%20LOCAL%20GOVERNMENT%20IN%20ALASKA.pdf 

5-5 
 

 

 

 

Section 5. Social and Economic Conditions Appendix M: BSWI Affected Environment Report 

Employment and Income 

Planning Area. The planning area supports just over 15,000 jobs in the private and government sectors 

(Headwaters Economics 2013). Within the 7,566 private sector jobs, most (6,170) were services-related 

jobs, which include a wide range of sectors such as trade, transportation and utilities; information; 

financial activities; professional and business services; education and health services; and leisure and 

hospitality. Average annual wages across these service sectors varied widely, from a low of about 

$15,000 in leisure and hospitality jobs to a high of about $51,000 in education and health services and 

information, with an overall annual average of about $40,000. A smaller number of jobs (646) were in 

non-services- related sectors such as natural resources and mining, construction, and manufacturing. The 

non- service sector jobs varied in average wage by sector but averaged about $71,000 a year. 

In 2012, government provided about 7,800 jobs in the four Census Areas, the vast majority (6,800) being 

local government jobs that averaged about $31,000 in annual salary; of the remainder, about 75 percent 

were state jobs paying about $68,000 a year, and 25 percent were federal jobs paying about $50,000 a 

year. The percentage of government jobs in the four Census Areas (40 percent) was higher than the 

proportion statewide (24 percent), showing the reliance on local government jobs in particular in 

communities in those areas. In the four Census Areas, average earnings per job, per capita income, and 

average annual wages for service, non- service, and government jobs are all considerably lower than they 

are for the state as a whole. 

These 15,000+ private and government sector jobs do not include proprietors (self-employed). In 

comparison, in 2011, an estimated 4,700 individuals were self-employed in the four Census Areas. 

Although there are still fewer proprietors than wage and salary employees, the proprietor component of 

employment is growing at a faster rate. 

The proportion of households receiving public assistance in the 27 communities ranged from 0 to 100 

percent, with an average of 63 percent. The percent of persons living in poverty in the communities 

ranged from 8 percent in Bethel and 10 percent in Red Devil up to 80 percent in Stony River and 81 

percent in Nikolai, with an average of 27 percent across all 27 communities. 

Unemployment rates in the four Census Areas have been consistently high, increasing from 10 percent in 

2000 to 15.3 percent in 2012. This is considerably higher than the 7 percent unemployment rate in Alaska 

as a whole in 2011. Even these relatively high rates may be conservative because the Alaska Department 

of Labor's definition of unemployment excludes people who have not looked for work in the previous 

four-week period. In rural, remote areas, high rates of discouraged workers may not result from people 

not seeking work, but because no work is available during much of the year. This “discouraged worker” 

effect is apparent in many rural Alaskan villages (Association of Village Council Presidents 2014). 

Another characteristic of the planning area is the seasonality and part-time nature of many work activities; 

of labor; only 30 percent of the workers in the planning area worked 50-52 weeks per year (Headwaters 

Economics 2013, using American Community Survey data from 2007-2011), compared to 55 percent of 

the workers nationally. 

Poverty levels within the four Census Areas are higher than for the United States as a whole. The 

proportion of people below poverty is 23 percent for the area compared to 14 percent for the United 

States, and the comparable numbers for families below poverty are 20 percent for the area and 10 percent 

for the United States (Headwaters Economics 2013). A much higher proportion of households received 

cash public assistance as part of their income (17 percent) than the U.S. average (3 percent) and the same 

was true for the proportion of households receiving Supplemental Nutrition Assistance Program (food 

stamps), 33 percent in the four Census Areas compared to 10 percent nationally. 

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Appendix M: BSWI Affected Environment Report Section 5. Social and Economic Conditions 

Table 5.1.4-1. Social Conditions in Planning Area Communities Region1

Bering Sea 

City/ Village

Kaltag 

Type2

2nd class city YukonKoyukuk Census Area2 240 Population 19902 230 Population 20002 190 Population 20102 92 Percent Alaska Native2 87 Percent of People 25 and over High 

School Graduate3 

12 Percent of People 25 and Over with 

Bachelor’s Degree or Higher3 

87 Housing Units2 17 Number Housing Units Vacant2 65 Percent Occupied Housing Units 

with Complete Plumbing Facilities4 

Municipal Facilities and Utilities 2 

Piped Water, Piped Sewer, Washeteria, Electric (AVEC), Landfill, Health Clinic, Volunteer 

Fire, Fire Hall, Takathlee Tondin Kuskino Community Hall, Roads, Boat Haul, Sawmill, Gravel 

Sales, Equipment Rental 

P-12, 28 Schools, number of students 2 

Shaktoolik 2nd class city Nome 178 230 251 96 88 6 70 6 88 Piped Water (summer), Watering Points (winter), Piped Sewer, Washeteria, Electric (AVEC), 

Landfill/Incinerator, Health Clinic, Police, Volunteer Fire, Teen Center, Roads, Building 

Rental, Equipment Rental 

P-12, 83 

Stebbins 2nd class city Nome 400 547 556 95 76 8 153 19 12 Washeteria, Electric (AVEC), Refuse Plywood Bins, Landfill, Health Clinic, Police, Airport 

(State Contract), City Hall, Roads, Pull Tabs, Building Rentals, Equipment Rentals, 

Honeybucket Bins, Watering Point at the Washeteria 

P-12, 195 

Unalakleet 2nd class city Nome 714 747 681 77 84 17 268 43 98 Piped Water, Piped Sewer, Refuse Collection, Baler, Landfill, Police and State-funded Public 

Safety Officer (VPSO), Volunteer Fire, Dock, Boat Haul-out, Ticasuk Library, Bingo/Pull Tabs, 

Alcohol/Drug Hotline 

P-12, 175 

Saint 

Michael 

2nd class city Nome 295 368 401 92 91 11 117 21 84 Piped Water, Piped Sewer, Honeybucket Hauling, Washeteria, Electric (AVEC), Health Clinic, 

Police, Volunteer Fire, Search and Rescue, Roads, Bingo, Dock, Equipment and Truck 

Rentals 

P-12, 179 

Lower 

Kuskokwim 

Aniak 2nd class city Bethel 540 572 501 69 91 10 214 48 84 Piped Sewer, Landfill, Library, Aniak Volunteer Fire Dept., Animal Control, Roads, Bingo, Pull 

Tabs, State-funded Public Safety Officer (VPSO), Search and Rescue 

P-6, 96; 

7-12, 59 

Lower 

Kalskag 

2nd class city Bethel 291 267 282 92 74 15 82 7 55 Piped Water and Sewer, Volunteer Fire, Community Hall, Roads, Bingo, Landfill 1-8, 33; 

6-12, 62 

Kalskag 2nd class city Bethel 172 230 210 81 83 8 74 14 80 Watering Point, Piped Sewer, (YKHC RUC), Electric (AVEC), Health Clinic, Public Safety 

Office (Currently not funded), Dock, Roads (Currently not funded), Bulk Fuel Facility and 

Operation, AVEC Operators. 

Elementary, 

46 

Bethel 2nd class city Bethel 4,674 5,471 6,080 65 90 23 2,364 468 96 Piped Water, Water Delivery, Piped Sewer, Tank Haul, Refuse Collection, Landfill, Recycling 

Center, Dock/Port, Police, Fire/EMS/Ambulance, Roads, Ice Roads, Teen/Youth Center, 

Senior Center (Adult Day Care), Senior Transportation, Library, Bingo/Gaming, Parks and 

Recreation, Planning, Animal Control, Business Licenses, Braund Building, Job Training, 

Motor Vehicle Registration (State DMV contract), Cultural Center with an Art Guild, Regional 

Dispatch Center, Cemetery, Skate Park, Baseball Fields, Harbor/Port, Transit; Remove: 

Recycling, Senior Center, Bingo/Gaming, Animal Control, Job Training, Motor Vehicle 

Registration 

6 schools, 

1,383 

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Section 5. Social and Economic Conditions Appendix M: BSWI Affected Environment Report Region1

Yukon Delta 

City/ Village

Marshall 

Type2

2nd class city Kusilvak Census Area2 273 Population 19902 349 Population 20002 414 Population 20102 95 Percent Alaska Native2 74 Percent of 

People 25 and 

over High 

School Graduate3 

9 Percent of 

People 25 and 

Over with 

Bachelor’s 

Degree or 

Higher3 

108 Housing Units2 8 Number Housing Units Vacant2 76 Percent Occupied Housing Units 

with Complete Plumbing Facilities4 

Municipal Facilities and Utilities 2 

Piped Water, Watering Point, Piped Sewer, Electric (AVEC), Health Clinic, Refuse Collection, 

Landfill, Police and State-funded Public Safety Officer (VPSO), Volunteer Fire, Public Safety 

Building, Post Office (federal contract), Roads, Bingo/Pull Tabs, Head Start, Equipment 

Rental 

P-12, 144 Schools, number of students 2 

Mountain 

Village 

2nd class city Kusilvak 674 755 815 92 71 9 211 27 77 Water/Sewer, Bingo/Pull Tabs, Community Hall, Equipment Rental, AVEC, Teen Center, 

ATCO Unit - Nightly Rental Unit 

P-12, 253 

Pilot Station 2nd class city Kusilvak 463 550 568 98 75 5 137 16 83 Piped Water, Piped Sewer, Refuse Collection, Landfill, Electric (AVEC), Dock, Volunteer Fire, 

Public Safety Facility, Library, Fuel Sales and Delivery, Gravel Sales, Cable TV, Bingo 

P-12, 177 

Pitkas Point Unincorporated Kusilvak 135 125 109 97 71 4 37 6 8 N/A P-12 

(inactive), 

10 

Russian 

Mission 

2nd class city Kusilvak 246 296 312 96 80 8 74 1 81 Piped Water, Piped Sewer, Electric, Health Clinic, Public Safety Building, Volunteer Fire, 

Bingo, and Dock. 

P-12, 117 

Saint 

Mary's 

1st class city Kusilvak 441 500 507 92 85 20 209 58 88 Piped Water, Watering Point, Piped Sewer, Honeybucket Hauling, Electric (AVEC), Refuse 

Collection, Landfill, Police, Volunteer Fire, Search and Rescue, Port/Dock, Gravel Sales, 

Roads, Parks and Recreation, Kumeluvik Building, Equipment Rental, Schools 

P-12, 196 

Upper 

Kuskokwim 

Crooked 

Creek 

Unincorporated Bethel 136 107 105 84 58 0 47 9 19% N/A P-12, 19 

Red Devil Unincorporated Bethel 53 48 23 43 (58 in combination with 

one or more other races) 

64 0 23 11 50% N/A P12,inactive 

Sleetmute Unincorporated Bethel 106 100 86 77 65 16 49 13 61 N/A P-12, 22 

Stony River Unincorporated Bethel 51 61 54 83 69 0 26 6 23 N/A K-12, 9 

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Appendix M: BSWI Affected Environment Report Section 5. Social and Economic Conditions Region1

Lower Yukon 

City/ Village

Anvik 

Type2

2nd class city YukonKoyukuk Census Area2 82 Population 19902 104 Population 20002 85 Population 20102 93 Percent Alaska Native2 70 Percent of 

People 25 and 

over High 

School Graduate3 

6 Percent of 

People 25 and 

Over with 

Bachelor’s 

Degree or 

Higher3 

46 Housing Units2 13 Number Housing Units Vacant2 92 Percent Occupied Housing Units 

with Complete Plumbing Facilities4 

Municipal Facilities and Utilities 2 

Watering Point, Piped Sewage, Washeteria, Electric (AVEC), Landfill, Health Clinic, 

Volunteer Fire Department, Fire Station, Roads, Equipment Rental, Building Rental. 

P-12, 24 Schools, number of students 2 

Grayling 2nd class city YukonKoyukuk 208 194 194 87 57 3 63 8 72 Piped Water, Piped Sewer, Washeteria, Electric (AVEC), Landfill, Health Clinic, Post Office 

(federal contract), Volunteer Fire, Dock, Bingo, Roads 

P-12, 38 

Holy Cross 2nd class city YukonKoyukuk 277 227 178 92 80 0 86 22 74 Piped Water, Watering Point, Piped Sewer, Washeteria, Electric (AVEC), Landfill, Health 

Clinic, Volunteer Fire, Dock, Community Hall, Roads, Bingo/Pull Tabs 

P-12, 43 

Shageluk 2nd class city YukonKoyukuk 139 129 83 90 75 5 53 17 0 Watering Point, Washeteria, Electric (AVEC), Landfill, Volunteer Fire, Post Office (federal 

contract), City Hall, Clinic, City Housing 

P-12, 13 

Western 

Interior 

McGrath 2nd class city YukonKoyukuk 528 401 346 37 (46 in combination with 

one or more other races) 

97 27 195 48 87 Piped Water, Piped Sewer, Washeteria, Public Showers and Rest Facility, Landfill, Volunteer 

Fire, Roads, Log Haul-Out, Boat Launch, Captain Snow Center, UAF Interior 

Aleutians/McGrath Center, State-funded Public Safety Officer (VPSO), Fish and Wildlife 

Protection Officer (State Troopers), Anderson Park, Volunteer Ambulance, and Search and 

Rescue. 

Correspondence 

K-12, 33; P12, 49 

Nikolai 2nd class city YukonKoyukuk 109 100 94 81 73 11 48 11 48 Sewer, Landfill, Fuel Sales, Electric P-12, 16 

Takotna Unincorporated YukonKoyukuk 38 50 52 23 (38 in combination with 

one or more other races) 

79 0 41 19 62 N/A P-12, 11 

Lime 

Village 

Unincorporated Bethel 42 46 29 93 47 13 27 16 0 N/A P-12, 

inactive 

Sources: 

1 Lingle et al. 2011 (Bethel and Lime Village added) 

2 ADCCED 2012 

3 Headwaters Economics 2013 

4 ADLWD 2011a 

Notes: For data reported as percentages, consider the total number of people included; for example, in a small village, 4 percent of the employed workers could be just one person. 

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Section 5. Social and Economic Conditions Appendix M: BSWI Affected Environment Report 

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Appendix M: BSWI Affected Environment Report Section 5. Social and Economic Conditions 

The proportion of school-aged children in families receiving public assistance through Temporary 

Assistance, Medicaid, or Supplemental Nutrition Assistance Program (food stamps), is 70 percent or 

higher in most school districts overlapping the planning area, compared to about 33 percent of the 

students in Anchorage schools (Institute for Social and Economic Research 2012). 

Communities. Per capita income varies from $4,320 in Stony River and $6,798 in Nikolai to $36,000 in 

Red Devil and $33,671 in McGrath. The average per capita income across all communities was $15,410. 

Another measure of income is median household income, the number at which half of the household 

incomes fall above and half fall below. Median household income varies from $14,643 in Anvik to 

$91,302 in Bethel, with an average of $40,306. 

Table 5.1.4-2 shows the number of people employed in the community, and the number of people who 

filed for unemployment insurance. The ratio of these two numbers ranged from 0.17 in Bethel to 0.57 in 

Sleetmute, with an average across communities of 0.34. These compare to a statewide average of 0.11 in 

2015. 

The proportion of households receiving public assistance in the 27 communities ranged from 0 to 100 

percent, with an average of 63 percent. The percent of persons living in poverty in the communities 

ranged from 8 percent in Bethel and 10 percent in Red Devil up to 80 percent in Stony River and 81 

percent in Nikolai, with an average of 27 percent across all 27 communities. 

Most of the communities rely on local government as a major source of jobs; the percent of workers 

employed by local government ranged from 20 percent in Bethel to 73 percent in Pitkas Point, with an 

average of 55 percent across all communities. A very small proportion of workers in the communities 

were employed in: natural resources and mining; construction; leisure and hospitality; or State 

government. The percentage employed in trade, transportation and utilities varied widely, from 2 percent 

in Lower Kalskag to 62 percent in Red Devil. The percentage employed in educational and health services 

also varied widely, from less than 5 percent in several communities to 29 percent in Bethel and 33 percent 

in Holy Cross. Note that these percentages are based on the number of workers in the community; in a 

small village, 4 percent of the employed workers could be just one person. 

The role of commercial fishing as an industry and employer also varies across the communities but is a 

crucial component in many, as reflected by the number of people having a commercial fishing license or 

crew permit (Table 5.1.4-2). Six of the communities are in the Western Alaska Community Development 

Quota program established in 1992 by the North Pacific Fishery Management Council. The Community 

Development Quota program was developed to ensure that the isolated and economically depressed 

Bering Sea and Aleutian Island communities could participate in the Bering Sea fisheries. A recent review 

of this program (BLM 2015a) concluded that the Yukon Delta Fisheries Development Association 

“experienced positive growth in most decennial review measurement items including socioeconomic 

conditions, financial performance, workforce development, and implementation of community 

development plans.” A number of the communities have few or no residents who hold either a 

commercial fishing license or crew permit. 

Economic contributions to communities from subsistence activities is discussed in Section 5.2, 

Subsistence. 

Cost of Living 

Cost of living in the planning area is higher than averages for other places in Alaska and much higher 

than for the United States as a whole (ADCCED 2017; Association of Village Council Presidents 2014). 

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Section 5. Social and Economic Conditions Appendix M: BSWI Affected Environment Report 

The Cooperative Extension Service Food Cost Survey conducted regularly by the University of Alaska 

Fairbanks found that in March 2012, food costs for a family of four in Bethel were 192 percent of what 

they would be in Anchorage (https://www.uaf.edu/ces/hhfd/fcs/). Costs were comparably high in Grayling 

(193 percent) and even higher in Anvik (206 percent), and McGrath (224 percent). 

High fuel cost is another key factor that has socioeconomic effects throughout the planning area. Higher 

fuel prices ripple through village lifestyles many ways, including increasing the cost of store-bought 

foods through transportation costs and storage costs. The high cost of heating schools can affect the 

financial feasibility of continuing to offer educational programs in remote communities (Association of 

Village Council Presidents 2014). Subsistence activity gets more expensive because of higher fuel costs 

for snowmobiles, four wheelers, and motorboats, while high food prices have increased the need for 

subsistence as a food source. The increased reliance on subsistence as a source of food, coupled with 

greatly increased costs of getting to the fish, moose, or caribou, and a poor commercial fishing season, are 

problems in many villages. 

Although average Alaska heating fuel and gasoline prices are slightly lower than their peak in the summer 

of 2008, the statewide average cost of heating fuel has increased 65 percent and the statewide average 

cost of gasoline has increased 59 percent since 2005. In July 2013, retail prices for heating fuel #1 and 

gasoline were collected from 100 select communities across Alaska (ADCCED 2013). 

Communities were selected from throughout the eight Department of Commerce, Community, and 

Economic Development Alaska regions (Northern, Gulf Coast, Interior, Northwest, Southwest, Western, 

South Central, and Southeast). The planning area overlaps with portions of the northern and southwestern 

regions, but more so with the western region, which reported the highest average retail costs for both 

heating fuel ($6.58 per gallon, compared to a statewide price of $5.74) and gasoline ($6.94 per gallon, 

compared to the statewide average of $6.09). All of these prices were considerably higher than the 

national averages of $4.01 for heating fuel and $3.63 for gasoline. 

The price for a gallon of #1 heating oil in July 2013, ranged from a low of $5.00 in Grayling to a high of 

$7.46 in McGrath. Retail price for a gallon of gasoline ranged from $5.81 in St. Michael to $8.03 in Pilot 

Station. Note that numbers were not available for some of the communities because they were not 

included in the 100 surveyed at the time. 

All communities in the planning area rely on diesel for power and are serviced by nine utility companies. 

The residential electrical rate ranges from 0.17 per kilowatt-hour in Bethel to 0.90 per kilowatt-hour in 

Lime Village. Many villages are served by the Alaska Village Electric Coop at a rate of 0.22 per kilowatthour, and several by Middle Kuskokwim Electric at 0.48 per kilowatt-hour (kwh). These effective 

residential rates are much lower than they would be without the Alaska Energy Authority's Power Cost 

Equalization program, which provides economic assistance to customers in rural areas of Alaska to 

compensate for the high kwh charges for electricity. Rates in 2012 for Anchorage were about 0.11/kwh. 

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Appendix M: BSWI Affected Environment Report Section 5. Social and Economic Conditions 

Table 5.1.4-2. Economic Characteristics in Planning Area Communities Region 1 City/Village Population (2010) Per capita income 2 Median household income 2 Percent households with public assistance income 3 Percent persons in poverty 2 Effective residential electrical rate per kwh 8

2013 retail price/gallon, heating oil #1 72013 retail price/gallon gasoline 7 Number of residents employed 5 Unemployment insurance claimants 5 Ratio of # residents withunemployment claims to # employed Percent employed in Natural Resources and Mining 5 Percent employed inConstruction 5 Percent employed in Trade, Transportation and Utilities 5 Percent employed in Professional and Business Services 5 Percent employed in Educational and Health Services 5 Percent employed in Leisure andHospitality 5 Percent employed in StateGovernment 5 Percent employed in Local Government 5 Percent employed in Other 5 Number with commercial fishingpermits, crew licenses in 2010 6Community Development Quota participant 2 

Bering Sea Kaltag 190 14,103 23,000 60 25 0.22 5.74 6 99 31 0.31 3 5 12 1 11 1 66 1 9,12 No 

Shaktoolik 250 12,803 26,667 43 28 0.22 NA NA 108 38 0.35 2 2 14 2 14 NA 1 66 NA 42,32 Yes 

Stebbins 556 8,938 33,462 100 28 0.22 7.22 7.47 244 88 0.36 NA 3 6 2 (financial activities) 9 1 NA 64 15 20,9 Yes 

Unalakleet 681 19,919 47,500 33 15 0.2 6.3 6.3 383 86 0.36 1 3 26 2 (includes financial 6 NA 3 58 0.5 101,62 Yes 

Saint Michael 401 13,348 34,821 55 29 0.22 6.95 5.81 179 66 0.37 0 3 (plus 2 in 

manufacturing) 

10 1 (financial) 14 2 1 68 NA 14,9 Yes 

Lower 

Kuskokwim 

Aniak 501 22,010 60,673 38 12 0.28 NA NA 280 82 0.29 1 3 (plus 1 in 

manufacturing) 

23 7 (plus 5 in financial and 

5 in information) 

11 NA 5 34 5 9,1 No 

Lower Kalskag 282 11,637 44,643 74 17 0.22 NA NA 130 46 0.35 2 NA 2 3 (plus 2 in financial) 5 1 NA 70 13 0,1 No 

Kalskag 210 15,655 45,938 76 22 0.22 6.75 6.75 98 43 0.44 1 4 (plus 1 in 

manufacturing) 

3 2 (plus 2 information 

and 13 financial) 

7 1 NA 54 11 1,0 No 

Bethel 6,080 29,261 91,302 22 8 0.17 6.02 6.85 2,718 466 0.17 1 1 (plus 1 in 

manufacturing) 

19 2 (plus 7 in financial and 

1 in information) 

29 2 10 20 6 189,127 No 

Yukon Delta Marshall 414 12,183 38,333 98 12 0.22 5.74 6.94 177 84 0.47 NA 3 (plus 1 

manufacturing) 

9 6 financial, 1 information 3 NA 6 65 7 39,45 No 

Mountain 

Village 

815 12,650 47,000 95 21 0.22 7.31 6.21 380 150 0.39 1 3 (plus 9 in 

manufacturing) 

12 1 in and information 

financial 

7 1 1 62 4 76,71 Yes 

Pilot Station 568 13,762 41,250 75 18 0.22 7.32 8.03 258 98 0.38 1 1 

(manufacturing) 

10 2 (plus 6 in financial) 5 1 1 64 9 54,62 No 

Pitkas Point 109 10,671 41,563 85 33 0.22 NA NA 44 19 0.43 NA 4 

(manufacturing) 

11 2 (financial) 1 1 NA 73 4 0,0 No 

Russian 

Mission 

312 11,225 43,750 100 30 0.22 5.75 6.2 173 60 0.35 1 1 13 5 (plus 13 financial and 

1 information) 

6 12 1 44 5 15,17 No 

Saint Mary's 507 15,307 38,162 50 15 0.22 NA NA 285 119 0.42 1 1 (plus 3 in 

manufacturing) 

19 1 (plus 16 in financial 

and 1 information) 

8 4 3 39 6 72,81 No 

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Section 5. Social and Economic Conditions Appendix M: BSWI Affected Environment Report Region 1 City/Village Population (2010) Per capita income 2 Median household income 2 Percent households with public assistance income 3 Percent persons in poverty 2 Effective residential electrical rate per kwh 8 2013 retail price/gallon, heating oil #1 7 2013 retail price/gallon gasoline 7 Number of residents employed 5 Unemployment insurance claimants 5 Ratio of # residents with unemployment claims to # employed Percent employed in Natural Resources and Mining 5 Percent employed in Construction 5 Percent employed in Trade, Transportation and Utilities 5 Percent employed in Professional and Business Services 5 Percent employed in Educational and Health Services 5 Percent employed in Leisure and Hospitality 5 Percent employed in State Government 5 Percent employed in Local Government 5 Percent employed in Other 5 Number with commercial fishing permits, crew licenses in 2010 6 Community Development Quota participant 2 

Upper 

Kuskokwim 

Crooked 

Creek 

105 11,540 29,688 100 20 0.48 NA NA 72 21 0.29 NA NA 4 11 (plus 12 in financial) 7 NA NA 64 1 0,3 No 

Red Devil 23 36,000 28,333 0 10 0.48 NA NA 8 0 NA NA 12 

(manufacturing) 

62 25 

(financial) 

NA NA NA NA NA 0,0 No 

Sleetmute 86 22,259 24,750 65 19 0.48 7.25 7.9 47 27 0.57 NA NA 17 4 (2 

financial) 

6 4 NA 66 NA 1,0 No 

Stony River 54 4,320 17,679 38 80 0.48 NA NA 24 2 0.08 NA 2 

(manufacturing) 

4 12 (plus 4 financial) 4 NA NA 58 8 0,0 No 

Lower Yukon Anvik 85 10,981 14,643 69 29 0.22 6 6.5 49 13 0.27 6 NA 14 1 (information) 18 2 NA 57 NA 11,0 No 

Grayling 194 8,619 27,500 100 24 0.22 5 6 90 33 0.37 1 2 

(manufacturing) 

9 1 (financial) 22 NA 1 56 8 

(unknown) 

31,1 Yes 

Holy Cross 178 16,014 35,500 86 32 0.22 7.15 7.35 94 27 0.29 6 1 

(plus 1 manufacturing) 

4 3 (financial) 33 3 NA 47 1 9,0 No 

Shageluk 83 12,415 31,250 77 14 0.22 NA NA 39 12 0.31 5 NA 5 3 (plus 10 financial) 15 NA NA 61 NA 1,1 No 

Western Interior McGrath 346 33,671 69,821 12 13 0.17 7.46 7.45 176 34 0.19 6 4 13 3 (plus 1 financial and 1 

information) 

10 10 14 37 1 1,0 No 

Nikolai 94 6,798 17,708 86 81 0.25 NA NA 44 14 0.32 14 2 4 2 

(information) 

18 NA NA 57 2 

(unknown) 

0,0 No 

Takotna 52 8,765 60,833 75 58 0.44 NA NA 26 12 0.46 NA 23 31 4 (plus 8 information) 8 4 NA 23 NA 0,0 No 

Lime Village 29 21,214 72,500 0 32 0.9 NA NA 10 2 0.2 NA NA 10 10 (plus 10 financial) NA NA NA 70 NA 0,0 No 

1 Lingle et al. 2011 (Bethel and Lime Village added) 

2 ADCCED 2012 

3 Headwaters Economics 2013 

4 ADLWD 2011a 

5 ADLWD 2011b 

6 ACFEC 2010 

7 ADCCED 2013 

8 AEA 2016c 

Notes: For data reported as percentages, consider the total number of people included; for example, in a small village, 4 percent of the employed workers could be just oneperson. 

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Appendix M: BSWI Affected Environment Report Section 5. Social and Economic Conditions 

5.1.5 Current Conditions for Environmental Justice 

Low-Income Populations 

Low-income populations in an affected area are identified using the statistical poverty thresholds from the 

Bureau of the Census data, per CEQ guidelines. In the United States as a whole, a total of 14.3 percent of 

the population lives below the poverty level; the comparable estimate for Alaska was lower, at 9.5 percent 

(http://quickfacts.census.gov/qfd/states/02000.html). For the BSWI RMP, any community that is greater 

than the national average of 14.3 percent in terms of the number of individuals below the poverty rate will 

be considered a low-income community. As a result, 21 of the 27 communities within the planning area 

are considered low-income. 

Minority Populations 

Nearly every community in the planning area has a population that is more than 50 percent Alaska Native, 

for the people who, in the 2010 Census, reported that they were one race. Only Red Devil, McGrath, and 

Takotna do not reach the 50 percent level. However, when adding in the number of people who reported 

they were two or more races, one of which was Alaska Native, then Red Devil reaches 58 percent Native, 

adding it to the list of communities where environmental justice is a concern. Takotna has a poverty level 

(58 percent) that far exceeds the national average, so it is already a community where environmental 

justice is a concern. That leaves McGrath, which reaches 46 percent Native when adding in the number of 

people who reported they were two or more races, one of which was Alaska Native. McGrath’s poverty

level (13 percent) is just a percentage point below the national average, so in combination with its 

substantial Native population, it does not make sense to exclude it from environmental justice 

considerations. In summary, all of the 27 communities will be considered subject to environmental justice 

guidance and analysis. 

5.1.6 BLM Support for Planning Area Communities 

The primary way that the BLM supports communities in the planning area is through its management of 

subsistence resources, habitat, and access (see Section 5.2, Subsistence). While much of this management 

direction is common to all alternatives because it is required by ANILCA and other laws, policies, and 

regulations, BLM management also contributes through the actions and directions contained in the 

resource management plans. These actions support communities a variety of ways, and also contribute to 

community resiliency, an important function especially across the arctic, which faces multiple and 

simultaneous social and environmental stressors (Arctic Council 2013). 

Section 5.2 of this document describes sociocultural systems and the contribution of resources and uses 

on BLM-managed public lands to subsistence lifestyles. The discussion to follow below does not repeat 

these findings. Instead, this section describes the other ways that management of resources and 

opportunities on BLM-managed public lands help to support BSWI communities, focusing on the role of 

BLM management in commercial activity and the cash economy in the planning area. The planning area 

is remote, with limited opportunities for commercial development. 

Each of the following subsections describes a resource area and includes relevant quotes or summaries of 

community resident comments received during scoping or community review of the preliminary 

alternatives. These comments should not be viewed as a community consensus; as pointed out at the 

Russian Mission scoping meeting, “There are 12 of us here at this meeting and what we share with you

may not represent how everyone in our community feels.” However, these comments illustrate the range 

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Section 5. Social and Economic Conditions Appendix M: BSWI Affected Environment Report 

of community residents’ values and how they relate to BLM-managed lands and desired future 

conditions. The complete disclosure of comments received on the BSWI RMP/EIS process are found in 

the Bering Sea – Western Interior Resource Management Plan Scoping Summary Report (BLM 2014d) 

and the Bering Sea – Western Interior Resource Management Plan Preliminary Alternatives Comment 

Summary Report (BLM 2015c). 

Recreation 

The remoteness of the planning area limits opportunities for outdoor recreation on BLM-managed public 

lands. The lack of transportation infrastructure and developed recreation facilities limit tourism and its 

associated economic activity. However, as of 2016, there are 18 special recreation permitted operations 

on BLM-managed public lands in the planning area, including guided hunting, competitive events, and 

tour groups. 

Guided hunting is estimated to support approximately 2,200 jobs and $35 million in labor income in 

Alaska (McDowell Group 2014a). The vast majority of the estimated 3,200 annual guided hunters are not 

Alaska residents (McDowell Group 2014a). Their expenditures introduce “new money” to the Alaska 

economy – money that would be unlikely to be spent in the state in the absence of big game hunting 

opportunities. 

However, much of the money spent on guided hunts on BLM-managed public lands contributes to 

economic activity in towns and cities outside of the planning area. Guided hunts typically originate 

outside the planning area, with supplies for the trips purchased in Anchorage or other commercial centers. 

Fuel will sometimes be purchased in villages within the planning area. Additionally, assistant guides and 

other staff are sometimes hired from small communities (McDowell Group 2014a). Local hiring of guides 

and support staff provides one of few opportunities to engage in commerce in the villages. Aside from 

direct economic contributions, guided hunters often donate game meat to rural communities (McDowell 

Group 2014a). 

Special recreation permits also allow for competitive events in the planning area, including the Iditarod 

Trail Sled Dog Race. The Iditarod race draws more than 14,000 people each year. The race contributes to 

economic activity in communities along the Iditarod race route. Race organizers, competitors, spectators, 

volunteers, and members of the media spend money at Alaska businesses for flights, lodging, food, and 

fuel. However, many of these expenditures occur outside the planning area. Precise estimates of the 

economic contributions of the Iditarod Trail Sled Dog Race and other competitive events (e.g., Iron Dog, 

Norton Sound 450, Ultra Sport, and Iditarod International) are not available given existing information. 

During scoping, community members in Lower Kalskag expressed interest in offering guided tours to 

visitors/tourists to visit a village and learn about rural village life, offer tours of the surroundings, to see 

wildlife and birds, possibly developing some type of ecotourism that would likely occur on lands close to 

the village (Native corporation-owned or USFWS-owned). Residents in Aniak said that currently, 

outfitters and guides who operate in the area take from the communities and compete for resources but do 

not return to the communities or utilize local hire, and a written comment received requested that that the 

BLM stop sport fishermen from operating jetboats over spawning habitat. A Russian Mission resident 

said, “We see Supercubs land in town with big moose racks tied to the plane and no meat to pass to the 

village.” A comment from Grayling suggested a lack of desire in getting meat from trophy hunters 

“because they don’t take good care of their meat and it usually hangs for too long.”

At the meeting on preliminary alternatives in Holy Cross, the BLM heard that increases in hunting from 

sport hunters (guided or independent) are causing impacts to limited subsistence resources. The 

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Appendix M: BSWI Affected Environment Report Section 5. Social and Economic Conditions 

community would like to see a broad exclusion zone, not around the community, but buffering around the 

corporation lands surrounding the community. At the Kaltag preliminary alternatives meeting, it was 

pointed out that one resident is a registered sport hunting guide, providing a source of local employment. 

Nulato residents reported seeing a lot of guide activity in their area. They are concerned about 

unpermitted guides on nearby refuge lands and impacts to subsistence hunting. Unalakleet residents 

expressed concern over guiding activities during king salmon season and conflicts with subsistence. 

Mining 

The history of mining in Alaska dates to the 1800s (ADCCED 2017). Mineral production continues to 

contribute to economic activity throughout the state. The planning area produces gold, silver, copper, and 

mercury. Much of the production of locatable minerals occur off BLM-managed public lands in the 

planning area. There are three active placer mines and one active lode mine within the planning area on 

BLM-managed public lands. 

Placer mines are typically small-scale employers, with an average of four workers per active placer mine 

(McDowell Group 2014b). Consequently, the three active placer mines on BLM-managed public lands in 

the planning area are estimated to directly employ about 12 workers, which is one percent of Alaska’s 

estimated placer industry (McDowell Group 2014b). In addition to direct employment, placer mine 

operators spend money on fuel, equipment, and supplies. However, given limited infrastructure and the 

high cost of goods in the planning area, many of these expenditures likely occur outside of the planning 

area (i.e., in Anchorage). 

Due to the low value of mineral materials and high transportation costs, mineral materials (e.g., sand and 

gravel) are in highest demand near villages and along transportation corridors. Most lands that meet these 

criteria have been previously conveyed. Therefore, the majority of mineral material sales in the planning 

area occur on State and Native lands. 

No leasable minerals occur in economic quantities in the planning area. 

During scoping and preliminary alternative development meetings, planning area residents expressed a 

wide range of sentiments associated with mining activity. Aniak residents mentioned that granite/hardrock potential north of or near-to Aniak could be used for river rip-rap, roads, dikes, and other purposes; 

residents of Russian Mission and other villages also expressed a need for gravel and rock. At the Aniak, 

Chuathbaluk, and Russian Mission meetings, concern was expressed over impacts of past mining, 

including toxic substances entering the waterways. It was hoped that lessons learned from the Red Devil 

and other mines would inform stipulations, terms, and conditions on future mining activities. 

A Bethel resident noted that the proposed Donlin Gold Mine is increasing interest in mining in the area; 

another comment suggested that withdrawals should be left as they are until more user groups are heard 

from. Residents in Bethel and other communities had questions about existing withdrawal locations and 

about the BLM’s ability to attach stipulations to future mining activity to avoid impacts to subsistence 

resources. At Unalakleet and other meetings, there was concern over private companies obtaining the 

benefits from mining development, while local residents are subject to the adverse impacts. 

An elder in Chuathbaluk noted that there are mixed feelings on mining, “leaning more towards 

development; if done right, watched and monitored. The young people today do not have access to the 

same resources we used to have and they need the income more.” Another Chuathbaluk resident 

expressed “concern for when the mining resource runs out and we no longer get money or jobs from the 

mining company. I don’t want to be left with nothing in the long term.” At Crooked Creek, the proposed 

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Section 5. Social and Economic Conditions Appendix M: BSWI Affected Environment Report 

Donlin Gold Mine was supported by some because it would bring jobs and hope for the future, in 

particular for the young men in the community; this was coupled with concern that mining could impact 

waterways and that increased plane and boat traffic could disrupt wildlife. 

At several meetings, residents noted that locally important (but not commercial scale) resources were 

present that were not on maps; although some of these were not in BLM-managed public lands they could 

be required for access. At the McGrath meeting on preliminary alternatives, a resident noted that energy 

supply and energy costs are of concern to the community, which had investigated commercial peat in the 

area years ago, but concluded it was not economical to develop. At a Kaltag meeting, two areas of coal 

near Kaltag were described, one an outcropping at 9-Mile near Nulato and the other about 25 miles south 

of Nulato. A community member described how he gathered a few buckets of this coal and tried to burn it 

in his stove, without success. At the Kalskag and Lower Kalskag meetings, residents expressed concern 

over the impacts of placer mining and other activities that would affect spawning areas, and said that 

reclamation was essential if any disruption was allowed. 

Timber and Forest Products 

Limited infrastructure and low timber quality mean that forestry is not an economic driver in the planning 

area. A commercial timber harvest has not occurred on BLM-managed public lands in the planning area 

since the early 2000s (BLM 2015a). Additionally, demand for “free use” permits for wood products in the 

planning area is also weak. Wood products removed from the planning area are mostly to satisfy local 

demand, particularly for home heating (BLM 2015a). Therefore, wood product removal from BLMmanaged public lands in the planning area does not currently measurably contribute to economic activity 

in the communities. 

Woody biomass has the potential to contribute to the development of biomass heating projects in the 

planning area. Biomass heating projects are being implemented across Alaska. However, most BLMmanaged public lands in the planning area are not immediately adjacent to communities. As a result, 

woody biomass to support heating projects is more likely to be removed from State and Native lands 

closer to communities. 

During scoping and preliminary alternative development meetings, nearly every community provided 

comments on this resource area, reflecting the importance of timber and forest products to communities. 

Aniak residents said that BLM-managed public lands on either side of the Kuskokwim at Stony River are 

important sources of dimensional wood and firewood, as are areas up the Holitna River and the Stony 

River, which are sufficient quality for milling dimensional lumber. Bethel residents value BLM-managed 

public lands between Marshall and Russian Mission along the Yukon as important sources of firewood, 

but recognize that logging has potential to affect spawning grounds (i.e., the runoff from cleared areas). 

Chuathbaluk residents noted there is an existing mill across the river from Chuathbaluk that used to 

operate with wood harvested from upriver. The operator supplied all the villages between Stony River and 

Kalskag with lumber, including slabs for all smokehouses on the river. 

During scoping, Grayling residents said there are about seven sawmills in town, which get all of their 

logs/wood from the river and river banks, which is not BLM-managed land. However, they are interested 

in any logging opportunities on BLM lands close to the river, and also are one of many communities 

interested in biomass production, although they likely would not get wood from BLM lands. Russian 

Mission residents use BLM-managed public lands west of Russian Mission for berry picking and wood 

cutting, among other uses. McGrath residents suggested that the block of BLM land southeast of McGrath 

does not have much firewood. 

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Appendix M: BSWI Affected Environment Report Section 5. Social and Economic Conditions 

Residents of Holy Cross, and many other villages, asked about the $10 charge by the BLM for 

commercial firewood use, and about the BLM permits required for personal use. The BLM prefers the 

permit system to help track how the lands are being used by local residents. Residents are not used to 

getting permits for non-commercial levels of wood, so some may not even know they need to, and it is 

difficult to know where exactly whose land you are on and the associated regulations. At Grayling, 

Bethel, and other communities, there was concern over how permits for house logs would be obtained and 

monitored. Kalskag residents wondered what the point of getting a permit is if they do not know where 

BLM-managed lands are, and how and where to get the permit. 

Lower Kalskag residents added that permits would be burdensome for the people that live off the land and 

normally go to get wood. However, residents would only have to pay for firewood permits only if they 

were taking it to sell, and only if they were cutting greater than 10 cords. Russian Mission suggested that 

there could be a map attached to the permit so people know whose lands they are on. Crooked Creek 

residents expressed opposition to the idea of requiring a permit (including TKC permits), saying it would 

lead to harassment and tickets. Kaltag residents said the community is interested in biomass energy and 

there are sawmills in Kaltag, but most trees on nearby BLM-managed public lands are black spruce that is 

not marketable or suitable for biomass. 

BLM-managed public land across the river from Chuathbaluk/south and east of Chuathbaluk was 

described by residents as very important for wood gathering: “100 percent of Chuathbaluk gets wood in 

this area, dead standing swamp kill.” A Chuathbaluk resident expressed concern over permitting for berry

picking: “We have adapted to permits for moose hunting, and we could adapt for berry picking. I believe

that the tribe can have a strong voice with corporation lands. We could say we are not willing to adapt to 

the permitting process within our area. I think about my son who may have to apply for a permit to go 

berry picking if he has to go farther out to BLM lands in the future.” Grayling residents said the BLMmanaged public lands north and northwest of Grayling were important for berry picking (and for future 

potential caribou hunting if the caribou ever migrate back this way). 

Nulato residents were less concerned, saying they harvest most of their wood from the river corridor, and 

it would be a couple tanks of gas and more burdensome to gather wood on BLM-managed public land. 

Among Unalakleet residents present at the review of preliminary alternatives, discussion regarding 

firewood permits was mixed, with some people in favor of the idea and others opposed. If permits were to 

be required, several residents advocated for local staffing, in cooperation with the tribe or corporation. 

Grazing 

Reindeer are the only livestock that may be grazed on BLM-managed public lands in the planning area. In 

the past, reindeer grazing has occurred in the northwestern portions of the planning area on the Seward 

Peninsula. However, as of 2016, there are no active domestic reindeer herds on BLM-managed public 

lands in the planning area. Reindeer grazing can serve as both a subsistence and entrepreneurial activity. 

Cash income from the sale of reindeer meat and velvet antler can supplement a herder’s subsistence 

activities. A 2005 study estimated that reindeer grazing across the Seward Peninsula produced 

approximately $395,000 from 198,000 pounds of meat sales and $387,000 from 23,000 pounds of velvet 

antler sales in 2000 (Carlson 2005; all prices 2000 U.S. dollars). 

In many communities, opportunities for reindeer grazing were not raised as an issue; in Grayling and 

Aniak, for example it was suggested there is no local interest. Kaltag residents suggested they do not have 

a big interest in reindeer grazing, partly because the Western Arctic Caribou Herd inhabits this area; 

residents have not seen them for a few years, but they have been there. One resident wanted to “leave the 

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Section 5. Social and Economic Conditions Appendix M: BSWI Affected Environment Report 

door open: We do not know of anyone here interested in reindeer herding, but it may be a good thing to 

consider.” Lower Kalskag residents said reindeer herding occurred historically in the area and there is 

interest in future opportunities; similarly, in Unalakleet, people were considering herding reindeer for a 

meat supply. Chuathbaluk residents said that many reindeer herds/herders were in the region before but 

herders just stopped, and domestic animals left to mingle in with wild herds. Residents did not know of 

anyone interested in reindeer herding, but thought it should be open for consideration. 

Infrastructure 

The planning area is largely roadless and the villages within it are isolated (Association of Village 

Council Presidents 2014). BLM-managed public lands in the planning area support limited infrastructure 

development through ROWs, leases, permits, and easements. Infrastructure is essential for economic 

activity – the movement of goods and people, communications, energy transmission, and recreational 

enjoyment of public lands. The planning area’s lack of infrastructure is an impediment to economic 

development. BLM land use authorizations in the planning area include an airport lease, recreation leases, 

and ROWs for roads, power transmission, pipelines, and communication sites. BLM-managed public 

lands in the planning area are typically distant from human settlement and the existing roads in the 

planning area are almost exclusively on lands other than those managed by the BLM. As described in the 

Travel and Transportation Management section, the Western Alaska Access Planning Study (i.e., the road 

to Nome) and the Yukon-Kuskokwim Energy Corridor Plan (which would provide road access between 

the two rivers and allow freight to be shipped down Yukon from Fairbanks) are potential transportation 

corridors under review by the State of Alaska that could cross BLM-managed public lands within the 

planning area. Scoping comments received about the Y-K corridor project demonstrated both support 

because it could allow cheaper heating fuel to be shipped from Fairbanks and concern about increased 

competition for subsistence resources. 

Some trail systems on BLM-managed public lands link up with trails on lands closer to communities. 

Many communities expressed concern over possible roads being planned for the area and encouraged the 

BLM to carefully consider effects on subsistence activities. For example, in Holy Cross opposition was 

expressed to the proposed development of a road from Paimiut Slough to the Kalskag area, due to 

potential increases in access to important subsistence use areas. Nearly every community had many 

comments on trails and travel management, with most oriented toward protection of subsistence access 

and opportunities. 

At the Aniak meeting on preliminary alternatives, a commenter said that it is good to teach younger 

generations skills. It was described how Chuathbaluk is trying to start something similar to the cultural 

camp in Kalskag, but they do not have a camp site identified, and that perhaps the camp site could be on 

BLM-managed public lands. It was also suggested at the Aniak meeting that communications sites, 

towers, and turbines typically do not interfere with access to historical trails. Several communities said 

they were interested in constructing shelter cabins for safety and support of subsistence activities. At Holy 

Cross and Crooked Creek, residents supported the placement of cell towers on BLM-managed public land 

(if needed) because they enhance public safety. 

BLM Operations 

The BLM Anchorage Field Office spends money on employee salaries, equipment, supplies, and 

contracts. BLM operational expenditures contribute to businesses in natural resource-related sectors. 

Additionally, BLM employees spend their salaries on a variety of goods and services, including housing, 

fuel, transportation, and food. While much of this money is spent on goods and services in the Anchorage 

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Appendix M: BSWI Affected Environment Report Section 5. Social and Economic Conditions 

area, some of the BLM’s budget expenditures contribute to economic activity in BSWI communities. For

example, wildland firefighting crews provide summer employment opportunities for people who live in 

villages/communities in the planning area. Village/community members have expressed the importance of 

wildland firefighting crews to summer employment opportunities in BSWI communities. 

Nonmarket Values 

The BLM IM No. 2013-131 describes when and how to consider nonmarket values when preparing 

NEPA analyses for BLM resource management planning and other decision-making. The IM directs 

BLM managers and to use estimates of nonmarket environmental values in NEPA analysis supporting 

planning and other decision-making where relevant and feasible, and to include at least a qualitative 

description of the most relevant nonmarket values for the affected environment and the impacts of 

alternatives in NEPA analyses. 

Nonmarket values reflect the benefits individuals attribute to uses (both active and passive) of natural 

resources or to the existence of particular ecological conditions, including the full range of ecosystem 

goods and services that do not involve market transactions and therefore lack prices. 

Examples of nonmarket benefits people receive from BLM-managed public lands include recreation 

experiences, subsistence opportunities, free-flowing rivers, open space, and the value to non-users of 

simply knowing that vast areas of Alaska exist in a natural state. It is desirable to describe nonmarket 

values so that resource management considers all relevant economic values, not merely those that are easy 

to quantify. Utilizing nonmarket values provides a more complete picture of the consequences of a 

proposed activity than market data alone would allow. 

One way the BLM protects nonmarket resources crucial to BSWI communities is through the designation 

and management of ACECs, which are “areas within the public lands where special management 

attention is required (when such areas are developed or used or where no development is required) to 

protect and prevent irreparable damage to important historic, cultural, or scenic values, fish and wildlife 

resources or other natural systems or processes, or to protect life and safety from natural hazards.”

As part of the BSWI RMP planning process, the BLM solicited proposals for new ACECs from the 

public. As part of the BSWI RMP planning process, the BLM solicited proposals for new ACECs from 

the public. The BLM evaluated 30 areas, including 11 existing and 19 nominated ACECs. Of the 30 areas 

that were evaluated, 17 areas met both the relevance and importance criteria for further consideration. 

Eleven of these 17 were nominated areas. New ACECs were nominated by many area communities and 

residents, including the Georgetown Tribal Council, a McGrath resident, Grayling IRA Tribal Council, 

Anvik Tribal Council, Native Village of Unalakleet, Koyukuk Tribal Council, and Nulato Tribal Council 

(BLM 2018b). 

Subsistence, food security, and public welfare were common reasons for people living in BSWI 

communities to propose ACECs and the associated special protections accorded to fish, cultural, and 

wildlife resources. These values reflect not only planning area sociocultural systems but the primary way 

in which residents believe that BLM-managed public lands can help support their communities. 

For example, the proposed Sheefish Spawning Area ACEC (BLM 2018b) was nominated to protect the 

only identified sheefish spawning area on the entire Kuskokwim River. As described in the ACEC 

nomination, “Sheefish are a culturally significant fish species along the Kuskokwim River; they are 

harvested for subsistence use by many, especially in the middle and upper river. Sheefish are often caught 

before salmon in the spring, and offer an opportunity for fresh fish early in the season.” Sheefish also are 

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Section 5. Social and Economic Conditions Appendix M: BSWI Affected Environment Report 

targeted by sport fishers in streams and tributaries within the Kuskokwim River drainage. The ACEC 

would encompass an area where over 80 percent of the sheefish spawning in the Kuskokwim River 

spawn, including a 15.5 mile section of the Big River near BLM-managed public lands. 

As another example, the Grayling IRA Tribal Council-nominated the proposed Grayling Area Habitat 

ACEC because it is “essential for maintaining species diversity for subsistence resources... (and) 

provides important habitat supporting subsistence resources crucial to the people of the Grayling 

community.”

Community Coordination 

A Kalskag resident said, “Your vision statement is very urban. Wilderness is our home. We are the fourth 

world. We are not rural; we are in bush Alaska. People in urban areas make [resource management plans] 

without living out here. Agencies that come out here that tell us how to live. If you really want to 

understand our subsistence way of life, you have to live out here, and use those experiences for the rest of 

your life.” Residents of Bethel felt that not enough time was provided for scoping and preparing scoping 

comments, and that communities had not been asked what works best for them (timing-wise). They noted 

that March through May, before breakup, are “ideal” for public meetings. 

Residents of Unalakleet said “We need to identify indigenous traditional use for subsistence to be mapped 

for each community, showing historic and customary indigenous use. We need to keep this context for the 

next 20 years, the life of this plan... We need to have consultation as a policy for any programs that are 

enforced, consultation with the tribe and corporation to develop working relationships, to make sure the 

land is able to support the living creatures. We are custodians of the land. Make sure we pass on this land 

to the next generation, it is what we have.” 

Unalakleet meeting attendees wanted the BLM to “consider local organizations, in addition to ADF&G 

and the USFWS, for population inventory monitoring or fish monitoring. There are local organizations 

that do projects within our river already. Norton Sound Economic Development Corporation (NSEDC) is 

very active in monitoring fish populations. More and more, the state is pulling out of rivers because they 

do not have the money to monitor rivers. BLM should work with tribe or Native Corporation. Within 

Norton Sound and the whole Seward Peninsula, NSEDC spends equivalent to the state on fisheries 

management.”

When performing fieldwork in the planning area, BLM staff typically overnight in local communities and 

pay visits to tribal and village council offices, often to discuss upcoming subsistence hunts, or to talk with 

residents while in town about field activities in the area. BLM also travels annually to Aniak and 

Unalakleet to issue federal subsistence moose hunting permits, typically staying two to three days. When 

field projects involve boats, snowmobiles, or aircraft, BLM frequently coordinates with tribal offices to 

determine the availability and purchase of fuel and determine payment methods before staff arrives in the 

village. This is typical for projects along the Kuskokwim River for example when boat fuel is needed in 

several village locations, or when a project involving aircraft is based in a village and arrangements have 

to be made to set up a remote fuel site if commercial fuel is unavailable. While in the communities, BLM 

staff occasionally receives questions about cleanup of abandoned mines, such as Kolmakof and Red 

Devil, related to potential contamination of subsistence food resources (e.g., fish in the Kuskokwim 

River). 

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Appendix M: BSWI Affected Environment Report Section 5. Social and Economic Conditions 

5.2 Subsistence 

5.2.1 Introduction 

Subsistence in Alaska is the traditional way of life for many residents of the state and is central to the 

customs and traditions of many cultural groups. Subsistence resources are the fish, wildlife and plant 

species used by Alaskans to provide food, clothing, shelter, and fuel, and for producing artwork and other 

customary uses. A subsistence lifestyle is the harvest of wild resources in a traditional way that includes 

seasonal timing, use areas and processing, distribution and consumption of the harvests. ANILCA §803 

states: “As used in this Act, the term "subsistence uses" means the customary and traditional uses by rural 

Alaska residents of wild renewable resources for direct personal or family consumption as food, shelter, 

fuel, clothing, tools, or transportation; for the making and selling of handicraft articles out of nonedible 

byproducts of fish and wildlife resources taken for personal or family consumption, for barter, or sharing 

for personal or family consumption; and for customary trade. For the purposes of this section, the term--

(1) "family" means all persons related by blood, marriage, or adoption, or any person living 

within the household on a permanent basis; and 

(2) "barter" means the exchange of fish or wildlife or their parts, taken for subsistence uses--

(A) for other fish or game or their parts; or 

(B) for other food or for nonedible items other than money if the exchange is of a limited and 

noncommercial nature.”

Subsistence is an integral part of the rural mixed economic system. The combination of subsistence and 

commercial wage activities provides the economic basis for rural community life. Analysis conducted by 

Wolfe and Walker (1987) indicates that subsistence harvests are a prominent part of the economy and 

social welfare of most rural Alaska regions. Federally qualified subsistence users are residents of the State 

of Alaska, as defined in 50 CFR 100.4, and whose primary, permanent home is within an area determined 

to be rural by the Federal Subsistence Board through the process in 50 CFR 100.15 (BLM 2015a). 

Indigenous peoples have been using the natural resources in their surroundings to meet their subsistence 

needs for centuries. In the planning area, as is true for Alaska’s vast rural areas, these uses are passed on 

through traditions and informal institutions that survive today in the subsistence way of life. These 

practices are not static, but rather, they change over time, continually adapting to the changing social and 

ecological conditions of the present (BLM 2015a). 

Subsistence resources are highly valued and are central to the economies, customs, and traditions of many 

families and communities in Alaska. Customs and traditions include sharing and distribution networks, 

ceremonial activities, the handing down of traditional knowledge, cooperative hunting, fishing, gathering, 

handling, preparation, and preservation of harvested resources. Subsistence fishing, hunting, and 

gathering activities are also important methods for achieving food security in all of the rural communities 

in the planning area. The planning area’s residents participate in a mixed subsistence-cash economy 

(Kurtak et al. 2010). With little cash available for store-bought items, subsistence hunting, fishing, and 

gathering is a major part of life in rural Alaska, often governed by both State and federal institutions, and 

yet informed by informal institutions and local traditions (BLM 2015a). 

There are three Alaska Native cultural groups in the planning area divided into several linguistic groups. 

These Alaska Native groups are the Yup’ik, Athabascan (or Dené), and Inupiat. The Athabaskan territory

within the planning area encompasses the Deg Xinag, Holikachuk, Koyukon, Upper Kuskokwim, and 

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Section 5. Social and Economic Conditions Appendix M: BSWI Affected Environment Report 

Dena’ina linguistic reach (BLM 2015a). The Yup’ik people comprise the western half of the planning 

area. The Athabaskans comprise the eastern half of the planning area. There are four distinct linguistic 

subgroups within the planning area: the Deg Xinag, Holikachuk, Koyukon, Upper Kuskokwim, and 

Dena’ina. Historically the Dena’ina were a ranked society with a redistributive economic system. The 

Inupiat are found in the north of the planning area, mostly in Unalakleet and nearby coastal areas (BLM 

2015a). 

5.2.2 Laws, Regulations, and Policies 

Modern formal institutions such as the Federal Subsistence Board and the Alaska Boards of Game and 

Fish have generally superseded the traditional hunting and fishing institutions. The Federal Subsistence 

Board oversees the Federal Subsistence Management Program, which operates under Title VIII of the 

ANILCA (P.L. 96-487) and codified in 50 CFR 100. ANILCA section 804 states, “the taking on public 

lands of fish and wildlife for non-wasteful subsistence uses shall be accorded priority over the taking on 

such lands of fish and wildlife for other purposes.” 50 CFR 100.19 states that “The Board may restrict, 

close, or reopen the taking of fish and wildlife for non-subsistence uses on public lands when necessary to 

assure the continued viability of a particular fish or wildlife population, to continue subsistence uses of a 

fish and wildlife population, or for reasons of public safety or administration.” ANILCA section 803 

defines “subsistence uses” as “the customary and traditional uses by rural Alaska residents of wild, 

renewable resources for direct personal or family consumption as food, shelter, fuel, clothing, tools, or 

transportation; for the making and selling of handicraft articles out of inedible byproducts of fish and 

wildlife resources taken for personal or family consumption; for barter or sharing for personal or family 

consumption; and for customary trade.”

The State of Alaska differs from the federal government in their interpretation of subsistence uses and 

rural priority. Under State law, subsistence use means: “the noncommercial, customary and traditional 

uses of wild, renewable resources by a resident domiciled in a rural area of the state for direct personal or 

family consumption, such as food, shelter, fuel, clothing, tools, or transportation; for the making and 

selling of handicraft articles out of non-edible by-products of the fish and wildlife resources taken for 

personal or family consumption; and for customary trade, barter, or sharing for personal or family 

consumption” (AS 16,05.940[32]). Although several attempts were made to align the State and federal 

rural element to subsistence preference, the Alaska Supreme Court concluded that the preferential 

allocation of subsistence resources to rural user groups was unconstitutional (McDowell v. State, 785 

P.2d 1, 9 [Alaska 1989]). Consequently, there are two separate regulatory regimes (State and federal) for 

hunting and fishing in Alaska. 

The planning area encompasses, wholly or in part, Units 18, 19A, 19B, 19C, 19D, 20C, 21A, 21D, 21E, 

and 22A (BSWI Draft RMP/EIS, Map 3.5.2-1). The BLM Anchorage Field Office currently manages 

several federal subsistence hunts in the planning area (BSWI Draft RMP/EIS, Map 3.5.2-1). Each year, 

the USFWS Office of Subsistence Management publishes a set of federal hunting/trapping and fishing 

regulations in the CFR. If there is a positive customary and traditional use determination for a subsistence 

resource by specific communities or areas, those communities and areas have a federal subsistence 

priority for that specific species in that unit. If the Federal Subsistence Board has not determined any 

customary or traditional use for a wildlife or fish population in a unit, then all rural residents of Alaska 

may harvest fish or wildlife from that population. 

Federal hunting seasons are open for several important wildlife species. Federally qualified subsistence 

users can also hunt with a State hunting permit on federal lands. However, where there is a need to 

prioritize the use of a subsistence resource among rural residents, the Federal Subsistence Board conducts 

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Appendix M: BSWI Affected Environment Report Section 5. Social and Economic Conditions 

a Section 804 analysis of ANILCA. The result of the analysis identifies to whom a subsistence priority 

should be provided, typically with a list of the included rural villages. Federal lands can be closed to the 

harvest of subsistence resources except by federally qualified rural residents identified in the Section 804 

analysis result. 

Current federal subsistence hunting and fishing regulations can be found in 50 CFR 100.25-28 and at the 

DOI Federal Subsistence Management Program website. Current State hunting and fishing regulations 

can be found in Title 5, AAC and on the ADF&G website. 

One of the most important things to villages in the planning area is the preservation of hunting and fishing 

for future generations (Lingle et al. 2011). To this end, the BLM is required to provide adequate access to 

subsistence resources in the planning area. One way that the BLM provides adequate access to 

subsistence resources in the planning area is via the required ANILCA section 810 analysis for proposed 

land use actions on BLM-managed public lands that undergo the NEPA process. Current management 

supports the continued subsistence effects analysis of proposed actions on BLM lands. 

The BLM also cooperates with other federal agencies in the management of federal subsistence hunts on 

USFWS lands within the planning area. Additionally, the BLM cooperates with the activities of the 

ADF&G within the planning area; because, as mentioned above, federally qualified subsistence users can 

and do regularly obtain State hunting permits in addition to federal subsistence permits. The BLM 

Anchorage Field Office issues federal subsistence moose hunting permits for hunts FM2201 (GMU 22A) 

and assists the Innoko NWR for the federal subsistence moose hunt FM2104 in the Paimute Slough 

portion of Unit 21E (BLM 2015a). 

FM2104 permits are issued to federally qualified subsistence users in Aniak, Chuathbaluk, Kalskag, 

Lower Kalskag, and Russian Mission in early February for this hunt that is open February 15 to March 

15. A BLM employee travels to the villages to issue these permits. Cooperation and coordination with the 

Innoko NWR is needed because a concurrent hunt, FM2105, occurs to the north of FM2104 hunt area. 

These two hunts share a common harvest quota from which a certain portion is allotted for harvest in 

FM2104 (BLM 2015a). Although BLM assists the USFWS with issuing federal permits, the Innoko 

NWR has in-season authority for moose hunts in GMU 21E. 

FM2201 permits are issued to federally qualified subsistence users in Unalakleet in early August for this 

hunt that is open August 15 to September 14. A BLM employee travels to Unalakleet to issue these 

permits. Cooperation and coordination with the ADF&G is needed because a State hunt, RM841, occurs 

in the same unit (Unit 22A) with an overlapping season. For FM2201, federal public lands are closed to 

the harvest of moose except by residents of Unalakleet. The BLM Anchorage Field Office has the 

authority to close the season in consultation with ADF&G (BLM 2015a). 

FM1901 permits are issued to federally qualified subsistence users in Aniak, Chuathbaluk, Crooked 

Creek, Lower Kalskag, Upper Kalskag, and Tuluksak for GMU 19A. The Yukon Delta NWR manager, in 

cooperation with the BLM, issues federal subsistence hunting permits for this hunt that is open September 

1 to September 20. The federal permits for this hunt are issued in coordination with the State Tier I hunt, 

TM680 (BLM 2015a). 

The BLM supports continued protection of access for federally qualified subsistence users to resources 

including those requiring federal subsistence permits. The BLM administers ANILCA subsistence 

processes and participates in formal subsistence management meetings as discussed in the following 

paragraphs (BLM 2015a). 

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Section 5. Social and Economic Conditions Appendix M: BSWI Affected Environment Report 

The BLM also continues to conduct ANILCA section 810 analysis of all proposed actions on BLMmanaged public lands. When a project is proposed on BLM lands, the project is analyzed under the NEPA 

process. In Alaska, each NEPA analysis is required to have a separate analysis under ANILCA section 

810. ANILCA section 810 stipulates that federal agencies “shall evaluate the effect of such use, 

occupancy, or disposition on subsistence uses and needs, the availability of other lands for the purposes 

sought to be achieved, and other alternatives, which would reduce or eliminate the use, occupancy, or 

disposition of public lands needed for subsistence purposes.” Those projects with potentially large or 

controversial effects on subsistence uses and needs may be subject to public subsistence hearings (BLM 

2015a). 

The NWRs and NPS units in the planning area that were created or expanded by ANILCA (16 U.S.C. 

410hh–3233, 43 U.S.C. 1602–-1784) are managed by the USFWS and NPS, respectively, and these lands 

will not be covered by the Draft BSWI RMP. Management of subsurface estate within USFWS lands is 

managed by the BLM under the MLA (30 U.S.C. 201(a)). 

ANILCA Section 304(c) is addressed in Mineral Occurrence and Development Potential Report for 

Leasable Minerals within the Bering Sea – Western Interior Planning Area (BLM 2015), will be 

addressed a case-by-case basis, and will not be covered by the Draft BSWI RMP. Similarly, any prior 

existing mining claims administered by the BLM in USFWS or NPS lands will be addressed on a caseby-case basis and will not be covered by the Draft BSWI RMP. A BLM subsistence biologist often 

attends Federal Subsistence Regional Advisory Council (RAC) meetings. These RACs include the 

Western Interior RAC, the Seward Peninsula RAC, the Yukon-Kuskokwim Delta RAC and the Northwest 

Arctic RAC. The councils are briefed and their comments solicited on BLM projects within and adjacent 

to the planning area as well as on projects on BLM-managed public lands that undergo the NEPA analysis 

(BLM 2015a). A recent paper by Brooks and Bartley (2016) describes an interpretive analysis of 

qualitative interviews with Yup’ik residents on the Yukon-Kuskokwim Delta. The authors suggest how 

understanding and improvements in cultural awareness could be made between stakeholders and agencies 

representatives by “more frequent and higher quality interactions and relationships.” The authors 

conclude that this would lead to a process that is more culturally appropriate and more meaningful 

collaborative management between different cultures (Brooks and Bartley 2016). 

5.2.3 Resource Indicators 

The conditions that are established in the discussions below provide a baseline for subsistence-related 

values, which the impact analysis will be based on. The following indicators, along with qualitative 

discussions, will be used to evaluate impacts associated with management decisions in the BSWI Draft 

RMP/EIS: 

• Distribution and abundance of subsistence resources within the planning area 

• Current and past use of resources within the planning area 

• Subsistence closures 

5.2.4 Current Conditions 

Resources Harvested and Subsistence Harvest Levels 

Major subsistence activities throughout the planning area include the hunting of birds, caribou, and 

moose; fishing; trapping; harvesting of plants and berries; and logging for firewood and housing. A 

subsistence resource may be used for a number of different purposes. For example, the moose meat is 

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Appendix M: BSWI Affected Environment Report Section 5. Social and Economic Conditions 

often preserved for consumption, while the skins are made into ceremonial drums and other handicrafts 

that may be sold for supplemental income (BLM 2015a). 

The range and density of fish and wildlife populations vary across the planning area. Therefore, hunting 

effort varies across the region. A more detailed discussion of fish and wildlife populations in the planning 

area is covered in the wildlife and fisheries sections. Data in this section has been complied largely from 

reports by ADF&G Division of Subsistence and ADF&G Community Profile Database. This is 

considered the best available data on subsistence at the community level and describes subsistence 

resources, levels of participation in subsistence activities, harvest levels and data on the sharing of these 

resources. It is important to remember that the types of data collected vary according to the study and 

years that the studies occurred. Data presented in Table 5.2.4-1 and Table 5.2.4-2 describe the harvest 

information by community that is available for the planning area. 

Subsistence Use Patterns 

Communities within the planning area use large portions of the area and subunits to harvest resources for 

subsistence uses, with overlapping use areas between communities. Map 3.5.2-1 of the BSWI Draft 

RMP/EIS shows approximate Subsistence Use Areas for Yukon River Communities, and Kuskokwim 

River Communities, and the Norton Sound/Unalakleet Wild River Area communities in the planning area. 

Hunting and gathering of subsistence resources, including land and marine mammals, fish, birds, and 

vegetation/berries follows a seasonal round that varies from year to year and from community to 

community based on local traditional knowledge and observations of resources, river and weather 

conditions, and migratory patterns. Harvesting of subsistence resources tends to follow a general pattern 

of recurring use during specific seasons annually. State and federal hunting regulations have contributed 

to further changes in seasonal rounds by creating open and closed seasons for harvest of fish and wildlife 

resources. Rural residents continue to harvest fish, wildlife, and vegetation resources as a major part of 

their diet (BLM 2016b). 

The river communities within the planning area tend to harvest larger numbers of fish (primarily salmon), 

whereas other communities harvest more moose, caribou and non-salmon fish. The communities along 

the Kuskokwim and Yukon Rivers tend to report higher levels of fish and moose as comprising a larger 

part of the overall subsistence harvest. Over the last decade, the weak salmon runs in the Yukon River 

have led communities to increase the harvest of non-salmon fish (Harkness et al. 2012). 

Residents in the Upper Kuskokwim River regional communities (e.g., Takotna, McGrath, Nikolai, Telida) 

of the planning area share a natural similar environment and resource base in terms of harvest and have a 

long tradition of using a pattern of multiple species of salmon, non-salmon fish, large and small land 

mammals, birds, edible and medicinal plants and firewood for heating (Ikuta et al. 2014). In the Upper 

Kuskokwim River communities, a large percentage of the wild food harvest is from large land mammals 

instead of fish (Ikuta et al. 2014). Use patterns of the Lower Kuskokwim River Communities (Akiak, 

Napakiak, Napaskiak) tend to have higher rates of edible pounds per capita harvest of salmon and nonsalmon fish in terms of subregional averages (Ikuta et al. 2014). 

Data collected for three Yukon River communities (Anvik, Grayling, Russian Mission) by Ikuta et al. 

(2014) describes the differences and the interconnectedness in the use patterns and relationships between 

the two river drainages. Differences in harvest patterns were noted by their defined geographic 

subregions. 

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Section 5. Social and Economic Conditions Appendix M: BSWI Affected Environment Report 

Table 5.2.4-1. Yukon River Area Communities, Pounds of Resources Harvested by Community 

Community 

Reference 

Year 

All 

resources 

in Pounds Salmon** 

Non-Salmon 

Fish 

Large Land 

Mammals 

Small Land 

Mammals 

Marine 

Mammals 

Birds and 

Eggs Vegetation 

Anvik 2011 390.92 231.78 34.79 90.00 19.32 0.0 12.81 2.2 

Grayling 2011 245.78 121.86 37.36 58.73 15.38 0 7.89 4.55 

Holy Cross 1990 633.68 121.18 80.93 0 68.57 0 28.51 12.65 

Kaltag 1985 ND 665.4 ND ND ND ND ND ND 

Marshall 2010 393.23 194.32 93.32 71.95 5.80 5.90 13.72 8.23 

Nulato 2012 238.67 108.35 25.71 85.51 9.30 0.0 2.43 7.34 

Russian Mission 2011 329.18 110.41 89.4 107.46 4.42 3.23 9.47 4.70 

Shageluk 1990 445.25 157.87 141.43 126.06 8.22 0.0 9.08 2.58 

Source: ADF&G 2016k 

ND = No data 

Table 5.2.4-2. Kuskokwim River Area Communities Villages, Pounds of Resources Harvested by Community 

Community 

Reference 

Year 

All 

Resources in 

Pounds Salmon** 

Non-Salmon 

Fish 

Large Land 

Mammals 

Small Land 

Mammals 

Marine 

Mammals 

Birds and 

Eggs Vegetation 

Aniak 2009 306.3 190.04 49.58 41.18 3.16 2.10 0.0 5.76 

Bethel 2012 168 68.75 33.34 43.34 1.09 3.22 9.66 8.68 

Crooked Creek 2009 245.41 171.06 29.18 25.47 6.78 0.0 0.0 10.86 

Chuathbaluk 2009 244 158.98 20.01 40.89 7.96 0.0 2.53 13.68 

Lime Village 2007 935.5 555.80 49.88 259.97 17.15 0.0 0.0 48.2 

Lower Kalskag 2009 186.72 98.63 0.0 35.35 3.28 0.0 0.0 12.6 

Kalskag (Upper 

Kalskag) 2009 345.08 198.80 48.30 46.36 7.86 0.0 0.0 36.24 

McGrath 2011 236.45 66.0 25.62 115.0 11.26 0.0 9.08 14.2 

Nikolai 2011 499.35 131.0 75.90 247.2 14.60 0.0 24.4 9.8 

Sleetmute 2009 405.23 277.10 53.90 43.90 15.08 0.0 5.35 10.53 

Stony River 2009 532.51 365.99 92.43 20.26 38.68 0.0 0.0 9.79 

Source: ADF&G 2016j 

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Appendix M: BSWI Affected Environment Report Section 5. Social and Economic Conditions 

Russian Mission is a mostly Central Yu’pik community and the most upriver village on the Lower Yukon 

Drainage whereas Anvik and Grayling are Deg Hit’an and Holikachuk Athabascan communities that are 

located in the Lower Middle Yukon River in an area that is referred to as the “GASH” and is a subregion 

that borders the Lower Yukon Subregion. While these communities differ culturally their harvest patterns 

are similar and comparable to Kuskokwim River communities with a heavy reliance on large land 

mammals (primarily moose) and salmon. 

Extensive sharing networks between the Kuskokwim and Yukon River communities have been observed 

(Ikuta et al. 2014). Sharing among the communities within the planning area of subsistence resources has 

been reported at high rates through food exchange networks. The community of McGrath reported (Ikuta 

et al. 2014) that sharing relationships occur with at least five other communities. Households in Aniak 

were reported to share with six Lower and lower Middle Yukon communities. The sharing of resources 

between the communities of the two river drainages connects and interconnects the communities, and the 

use areas overlap. Overlap in the area at Russian Mission and Paimuit Slough includes the lower reaches 

of Unit 21E and is likely influenced by the harvest of moose and non-salmon fish. Moose population 

declines in the Central Kuskokwim area in Unit 19A have led to an increase if harvest use in the Unit 21E 

area by Kuskokwim River residents (Ikuta et al. 2014). 

Subsistence Use Areas 

There is limited data available for places or areas significant to and for subsistence use in the planning 

area. Studies investigating patterns of use; such as seasonal cycles, use areas, and resources harvested 

have been conducted by ADF&G Division of Subsistence and other agencies and organizations. Available 

data are mainly included in technical reports by ADF&G Division of Subsistence but are limited in scope 

and may be reflective only of use areas during a specific time or may represent historic use areas. The 

lack of data for a community is not an indication that subsistence harvests lack importance in the area. 

Not all species are included in the ADF&G surveys and only a few communities in the state are surveyed 

each year. The discussion of harvest information in the following sections is supplemented by information 

available from more recent ADF&G technical papers and publicly available information. Because 

resource distribution and subsistence use areas change over time information on subsistence use areas 

gathered during the scoping period, alternatives outreach and ACEC nominations are important 

supplements. Information from the ACEC Summary Report (BLM 2018b) regarding harvest use areas has 

been incorporated where available. Where appropriate the use of place names are those used by local 

people and these may not be consistent. 

The following sections discuss subsistence use areas for communities within the planning area. The 

discussion is organized by river drainage within the planning area. It is important to note that the lack of 

data for a community is not an indication that subsistence harvests lack importance in the area. 

Yukon River Drainage Area Communities 

Anvik 

Anvik is located on the Yukon River with a population of approximately 85 people. In March of 2012 

researchers surveyed 24 of 32 eligible households in this community. The data was expanded for eight 

unsurveyed households and the estimated total harvest of wild food for the year 2011 was 34,001 edible 

pounds with an average household harvest of 1,075 pounds at 391 pounds per capita (Ikuta et al. 2014). 

Salmon (Chinook, summer chum, coho and fall chum) represented 59 percent of the total wild food 

harvest for the year 2011 with Chinook salmon being the most harvested species in the total community 

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Section 5. Social and Economic Conditions Appendix M: BSWI Affected Environment Report 

harvest. Moose were the main large land mammals harvested (23 percent) and then other resources 

reported were beaver, whitefish, Northern Pike and sheefish. As noted by BLM in the ACEC Summary 

Report (BLM 2018b), rural residents along the Yukon River benefit from chum salmon spawned and 

reared in the Anvik River. As Chinook salmon numbers have declined in recent years, the significance of 

chum salmon from the Anvik River for food security has increased. These recent 2013 harvest numbers 

identify the importance of summer chum salmon, supported largely by the Anvik River, and the benefits 

to the subsistence and commercial fisheries of the lower Yukon River communities. The Anvik River 

watershed also supports moose habitat; habitat for all species of whitefish and cisco that spawn in the 

river; major sheefish spawning; and spawning and rearing habitat for all species of salmon. These food 

resources provide food security and public welfare to the Anvik community. The Anvik River is 

considered the largest single wild stock producer of summer chum salmon in the Yukon River drainage 

(Bergstrom et al. 1999). The Anvik watershed provides habitat for black bear, brown bear, caribou, wolf, 

wolverine and moose. Wood bison were introduced into the nearby Innoko Bottoms in March 2015. 

These species are important to subsistence users from the villages of Grayling Anvik, Shageluk, and Holy 

Cross, and are found throughout the region. 

Residents and subsistence hunters reported that they used an area of 302 square miles for harvesting. 

They reported that the majority of the harvest are was west of Anvik near the Anvik and Bonasila Rivers 

and rely on the Yukon River to travel to other resource harvest areas. Residents reported traveling to hunt 

for moose roughly 15 miles from the town and as far as 30 miles up the Anvik and Bonasila Rivers. It 

was also reported that hunting for moose and birds occurs on the Yukon River. Non-salmon fishing for 

burbot, Northern pike, sheefish and whitefish occurs in the areas close to the community. Trapping was 

reported to occur for small land mammals on both sides the Anvik (west of the community and along the 

north end of Garden Island and inland from the Yukon River (Ikuta et al. 2014). The Anvik Traditional 

Trapping Area also provides important caribou, moose, and furbearing animal habitat that support 

trapping that many people rely upon in the region (BLM 2018b). 

Grayling 

Grayling is located on the Yukon River. In 2012; the population was estimated at 212 people. Researchers 

from the ADF&G surveyed 41 of 55 households in the winter of 2012. Grayling residents harvested and 

estimated 52,094 pounds of wild foods, with an average household harvest of 947 pounds. The most 

widely used subsistence resources were salmon (Chinook and summer chum), land mammals (moose), 

non-salmon fish species, vegetation, and birds and eggs. More households reported using (98 percent) and 

harvesting (66 percent) Chinook salmon than any other fish species. Important fish subsistence species 

include coho, Chinook, pink, and chum salmon. These populations are relevant to the local subsistence 

users from the villages of Grayling Anvik, Shageluk, and Holy Cross. Moose were the most widely used 

(98 percent) and harvested (39 percent) of all land mammals The top ten resources harvested, in terms of 

edible weight, were Chinook salmon, summer chum salmon, fall chum salmon, moose, beaver, broad 

whitefish, sheefish, coho salmon, humpback whitefish, and northern pike Other species harvested by 

Grayling residents were several species of whitefish, vegetation, and black bear (Ikuta et al. 2014). Local 

plants and vegetation harvested and used for subsistence include wood (for heating and smoking fish) and 

berries and edible plants. 

Grayling residents have reported a harvest area of 1,164 square miles in the Yukon River drainage in 

2011. Much of the subsistence harvest activities pursued by Grayling residents occur along the river 

corridors and to the west of the community (Ikuta et al. 2014). The harvest areas for salmon, non-salmon 

fish and vegetation are located upriver from Grayling on the Yukon River, along the Innoko River, and 

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Appendix M: BSWI Affected Environment Report Section 5. Social and Economic Conditions 

Shageluk Slough. Moose are reported as hunted up and down the Yukon from the village and along the 

Innoko River. 

Holy Cross 

Holy Cross is located on the Yukon River with an estimated population in 2011 of 176 people (ADF&G 

2016j). Limited data are available for this community in the ADF&G Community Subsistence 

Information System with 1990 being the most recent data set. Subsistence harvests were reported at 634 

pounds (all resources) per person in Holy Cross with 63 households reporting data. Important subsistence 

fish species include coho, Chinook, pink, and chum salmon and whitefish. Black bear, brown bear, 

caribou, wolf, wolverine, lynx and moose are important land mammal resources. 

As described in the ACEC Summary Report (BLM 2018b), the Anvik watershed, the Bonasila River 

watershed, Anvik Traditional Trapping Area, provide habitat for black bear, brown bear, caribou, wolf, 

wolverine and moose. These species are important to subsistence users from the villages of Grayling 

Anvik, Shageluk, and Holy Cross, and are found throughout the region. Important fish subsistence species 

include coho, Chinook, pink, and chum salmon. Holy Cross Village noted in the ACEC Summary Report 

that community harvest watersheds included: Pike Lake for fishing, Ranger Lake to Reindeer Lake, 

Paimuit Slough for hunting, fishing, trapping. Moose and ducks are also hunted along the Innoko River. 

Kaltag 

Kaltag is located on the Yukon River with an estimated population in 2011 of 205 people (ADF&G 

2016j). Limited data are available for this community in the ADF&G Community Subsistence 

Information System with 1985 being the representative year. Subsistence harvests were reported at 597 

pounds (all resources) per person in Kaltag with 63 households reporting data. Important subsistence fish 

species included coho, Chinook and chum salmon. Black bear, brown bear, caribou, wolf, wolverine, lynx 

and moose are likely important land mammal resources for this village. The Kaltag Portage between 

Kaltag and Unalakleet has been an important travel and trade route for Alaska Natives for thousands of 

years as described in the ACEC Summary Report (BLM 2018b). 

Marshall 

Marshall is located on the Yukon River with an estimated population in 2011 of 407 people (ADF&G 

2016j). Limited data are available for this community in the ADF&G Community Subsistence 

Information System with 2010 being the representative year. Subsistence harvests were reported at 393.23 

pounds per person (all resources). Salmon was the primary reported fish harvested with 194.31 estimated 

pounds per capita, and non-salmon fish harvests were 93.31 per capita. Salmon harvest mainly consisted 

of summer and fall chum, coho, and Chinook salmon. Non-salmon fish included burbot, northern pike, 

sheefish, whitefish, and humpback whitefish. Large land mammals harvested were mostly moose, caribou 

and black bear. Small land mammals harvested were primarily beaver (ADF&G 2016j). Marine mammal 

harvests were bearded and spotted seal. 

Use Areas are mainly on the Yukon River. The Ohogamiut ACEC (BLM 2018b) area near Marshall was 

noted to have cultural and historic relevance to the community of Marshall. Traditional use of animals, 

fish, plants and wood from accessible lands and waters has been practiced by the indigenous people of 

Marshall in this region for thousands of years. The area provides habitat for black bear, brown bear, 

caribou, wolf, wolverine, lynx, and moose and more recently the reintroduced wood bison. These species 

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Section 5. Social and Economic Conditions Appendix M: BSWI Affected Environment Report 

are important to subsistence users from the villages of Grayling, Anvik, Shageluk, and Holy Cross, and 

are found throughout the region. 

Nulato 

Nulato is located on the Yukon River with an estimated population in 2011 of 275 people (ADF&G 

2016j). Limited data are available for this community in the ADF&G Community Subsistence 

Information System with 2010 being the representative year. Subsistence harvests were reported at 239 

pounds per person (all resources) Salmon was the primary reported fish harvested with 28,210 estimated 

pounds, mainly consisting of chum, coho, and Chinook salmon. Non-salmon fish included burbot, char, 

Dolly Varden, grayling, northern pike, sheefish, whitefish, cisco and least cisco, and humpback whitefish. 

Large land mammals harvested were mostly moose, caribou and black bear. Small land mammals 

harvested include snowshoe hare, beaver, lynx, muskrat, and porcupine (ADF&G 2016j). Use Areas are 

mainly on the Yukon River between the Koyukuk and Nowitna Rivers. During the preliminary 

alternatives public meeting in Nulato in 2015, one commenter noted that use areas included an area on the 

back side of the village closer to BLM-managed public land, where residents may pick berries, set a few 

trap lines, and harvest moose, caribou, ducks, beaver, wolves, and marten (BLM 2015c). The nearby 

Nulato River watershed provides habitat for moose, caribou, brown bear, wolf, and wolverine. These 

species are important to local subsistence users as well as providing opportunity for qualified subsistence 

users from Unalakleet and Shaktoolik (BLM 2018b). 

Russian Mission 

Russian Mission is located on the west bank of the Yukon River and in 2011 it was reported that Russian 

Mission had an estimated population of 402 people (Ikuta et al. 2014). In the winter of 2012, researchers 

from ADF&G surveyed 46 of 79 households in this community. Russian Mission’s estimated total harvest 

of wild foods was 132,289 pounds. This was reported as an average of 1,675 pounds per household. Fish 

composed over half of the community’s total harvest with 61 percent coming from both salmon and nonsalmon species. Chinook salmon represented the main the fish harvest (22 percent) and moose composed 

just over 31 percent of the total followed by Arctic lamprey (8 percent), Northern Pike (7 percent), 

summer chum salmon (7 percent) and other resources (25 percent) (Ikuta et al. 2014). Other resources 

harvested included various species of whitefish, coho and chum salmon, and burbot. Moose and black 

bear are the main large land mammal species harvested and represent 34 percent and 3 percent 

respectively of the estimated harvest (Ikuta et al. 2014). 

Harvest areas for Russian Mission reported a harvest area of 987 square miles in 2011 with the majority 

of salmon harvested on the mainstem of the Yukon River. Specific areas fished included an area of 20 

continuous miles on the main stem of the Yukon River with drift activity occurring from Roosevelt Island 

12 miles downstream from Russian Mission to Johnson Island 6 miles upstream from Russian Mission. 

Respondents in the 2011 study reported that their harvest areas are located away from the community 

both downstream and upstream and in areas that are distant from the community near Mountain Village in 

the Kuskokwim drainage. Harvest areas for non-salmon fish species and vegetation largely overlapped 

those of salmon along the Yukon River. Harvest areas for large land mammals (including moose and 

black bear) overlapped in a 62 mile area along the mainstem of the Yukon River. Harvest search areas 

were also reported as being along Mountain Creek north of the Yukon Rover and in the area new Portage 

Slough and Kulik Lake. Black bear were also hunted along Portage and Paimuit Sloughs (Ikuta et al. 

2014). 

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Appendix M: BSWI Affected Environment Report Section 5. Social and Economic Conditions 

Shageluk 

Shageluk is located on the Innoko River with an estimated population in 2011 of 83 people (ADF&G 

2016j). Limited data are available for this community in the ADF&G Community Subsistence 

Information System with 1990 being the representative year. Subsistence harvests were reported at 445.24 

pounds per person (all resources). Salmon (Chinook, chum salmon and summer chum) was the primary 

reported fish harvested with 157.86 estimated pounds per capita. Non-salmon fish harvests were 141.43 

per capita, mainly consisting of pike, whitefish and sheefish. Harvests of all whitefish species for 

Shageluk was reported in Brown et al. (2011) based of off household survey data by ADF&G in 2003 

observing that 15,783 pounds of were harvests at Shageluk. Whitefish are now considered to be the most 

heavily harvested non-salmon fish by residents (Brown et al. 2011). Large land mammals harvested were 

moose at 126.06 estimated pounds per capita and small land mammals harvested were primarily beaver 

and hare at 8.22 estimated pounds per capita (ADF&G 2016j). Birds and egg harvests were 9.07 

estimated pounds per capita and vegetation was 2.58 estimated pounds per capita. 

Brown et al. (2011) describes the main harvest areas as along the Innoko River area, which is used 

primarily by residents of Shageluk and also Grayling, who have ties to the Innoko through their residence 

in the historical village of Holikachuk upriver from Shageluk (Brown et al. 2005). Rates of sharing 

between Holy Cross, Grayling, Anvik and Shageluk are considered to be high. The proposed Grayling 

ACEC is considered an important subsistence fishery for species including coho, Chinook, pink, and 

chum salmon. These populations are relevant to the local subsistence users from the villages of Grayling 

Anvik, Shageluk, and Holy Cross. The proposed Holy Cross ACEC, Anvik Traditional Trapping Area 

ACEC, Bonasila River Watershed ACEC, and Anvik River Watershed ACEC are also considered areas 

that provided wildlife habitat for subsistence uses for black bear, brown bear, caribou, wolf, wolverine, 

lynx and moose. These species are important to subsistence users from the villages of Grayling, Anvik, 

Shageluk, Holy Cross, and Kuskokwim River area communities. 

Kuskokwim River Drainage Area Communities 

Aniak 

Aniak is located on the Kuskokwim River with the population (reported in 2009) at 501 people. In 2009, 

ADF&G researchers surveyed 141 of 170 households in Aniak and the data was expanded for the 29 

unsurveyed households. Survey data reported that the estimated total wild food harvest was 147,316 

pounds. The average household harvest was reported at 1,498 pounds. The species harvested and reported 

as used were fish (92 percent), vegetation (80 percent) and land mammals (76 percent). Forty-eight 

percent of households reported that they used birds and eggs. The largest percentage (82 percent) of the 

Aniak subsistence harvest in 2009 was salmon and non-salmon species. Fish species harvested included 

Chinook, chum, coho, and sockeye salmon; burbot; humpback whitefish; sheefish; unknown whitefish; 

and northern pike. Important fish subsistence species include coho, Chinook, pink, and chum salmon. 

Land mammals that were reported as harvested were moose and black bears, which contributed to 15 

percent to the total harvest, while vegetation contributed another 2 percent and marine mammals, birds 

and eggs supplied less than 1 percent (Brown et al. 2012). 

Harvest areas for Aniak that were noted in the 2009 survey were reported as using an area of 3,396 square 

miles. It should be noted that both the Kuskokwim and Aniak Rivers figure prominently in subsistence 

activities in terms of both harvest locations and transportation corridors. The households surveyed 

reported that they traveled up the Kuskokwim River as far as the mouth of the George River. The 

community reported that they traveled on the Aniak River, past the confluence of the Aniak, Salmon, and 

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Section 5. Social and Economic Conditions Appendix M: BSWI Affected Environment Report 

Kipchuk Rivers. The areas to the south and west of the community were reportedly used for hunting and 

fishing in the vicinity of Whitefish Lake and the Buckstock Mountains. Salmon were harvested in the 

mainstem of the Kuskokwim River in the areas east and west of the community. Other areas that are 

fished were along the Aniak River. Non-salmon fish species were reported as harvested along the Aniak 

River and Whitefish Lake. Moose, caribou and black bear are hunted over a wide area. Residents reported 

hunting moose to the north in Units 21A and 21E in the area towards Paimiut Slough and the Iditarod 

River drainage (Brown et al. 2012). 

Bethel 

Bethel is located on the Kuskokwim River, and in 2012, the population was reported as 6,113 people. As 

reported in 2012, the average per capita harvest was 168 pounds of wild food or 580 pounds per 

household. Available ADF&G data for household surveys that was reported in 2012 describes the 

harvests of 466 of 1,645 households in Bethel (ADF&G 2016j). The main species harvested and used 

included berries, moose, Chinook salmon, coho salmon, sockeye salmon, caribou, and chum salmon. 

ADF&G reported that over 50 percent of the households fished for salmon and non-salmon fish species 

and 30 percent harvested land mammals, 43 percent harvested birds and eggs, and 77 percent harvested 

vegetation such as berries or greens (Fall 2013). Salmon comprised 40 percent of the total harvest while 

26 percent was made up of land mammals, 20 percent non-salmon fish species, 6 percent birds and eggs, 

5 percent wild plants, 2 percent marine mammals, and less than 1 percent marine invertebrates. ADF&G 

reported that the harvest for salmon in 2012 were low because of the regulatory closures caused by poor 

returns. They noted that the data on total harvests collected in 2012 may not be representative when 

compared to years where there were no restrictions. 

Harvest areas reported by Bethel residents from data that was collected from harvest tickets and permits 

shows where Bethel residents have hunted for large land mammals. Residents have hunted primarily in 

Unit 18 for moose, caribou, and muskoxen. They reported that in Unit19, 20, and 21, they mainly hunted 

moose. The Kuskokwim River is the main fishing area for subsistence salmon fishing. While mapping of 

Bethel’s subsistence use area is very limited, Bethel residents have been reported to share food with other 

Kuskokwim River communities (Brown et al. 2012) and contribute to wild food harvesting and 

processing networks in central Kuskokwim River communities. 

Crooked Creek 

Crooked Creek is located on the Kuskokwim River and in 2010 had a reported population of 90. In April 

of 2010, ADF&G researchers surveyed 33 of 40 households, reporting from harvest during 2009. When 

they expanded the data for the 7 unsurveyed households, they determined that the estimated total harvest 

in 2009 was approximately 28,259 pounds and the average household harvest was reported at 706 pounds 

(Brown et al. 2012). Chinook, chum, coho, sheefish, and sockeye salmon accounted for 78 percent of the 

total subsistence harvest in 2009 (Brown et al. 2012) and the remaining 22 percent was comprised of 

moose (7 percent), black bear (3 percent) and beaver (3 percent). There were a variety of berries and other 

resources, such as birds, marine mammals, and marine invertebrates that were reported harvested by 

residents. 

The Crooked Creek harvest areas were reported as using a total of 1,245 square miles for harvest 

activities in 2009 (Brown et al. 2012) It should be noted that for this year (2009), residents reported that 

this area was not representative of their entire traditional harvest territory. They noted that their entire use 

area was broader but harvest use areas had been affected by regulations, environmental changes and local 

animal populations, as well as the price of gasoline. Residents reported that the closure of Unit 19A had 

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Appendix M: BSWI Affected Environment Report Section 5. Social and Economic Conditions 

affected moose hunts in the areas above the George River and the Holitna and Hoholitna basins (Brown et 

al. 2012). They reported hunting moose instead further down river and in the Bonanza flats and Donlin 

Creek areas (Brown et al. 2012). 

Land mammals that were hunted included moose, caribou, bears, and small furbearers harvested over a 

large area that included the mainstem of the Kuskokwim River and its tributaries both downstream and 

upstream from the village of Crooked Creek. It was observed that the hunting areas for many land 

mammal species overlapped. Crooked Creek hunters said that they hunted for moose on the mainstem of 

the Kuskokwim River to as far as Lower Kalskag. They also reported hunting in areas far upriver at the 

George River. The Kuskokwim River tributaries used for moose hunting were the Holitna, Hoholitna and 

George Rivers. Black bear was hunted and harvested primarily along Crooked Creek and in the 

Oskawalik River drainage (Brown et al. 2012). 

Salmon were harvested mainly in the mainstem of the Kuskokwim River from just below the mouth of 

the Oskawalik River upstream to the mouth of George River. The heaviest fishing was reported to take 

place along the Great Bend. Non-salmon fish species were reported as harvested in the mainstem of the 

Kuskokwim River. Arctic Grayling were reported as harvested in the George River and in Crooked 

Creek, near the confluence of Crooked Creek itself and the Kuskokwim River. Sheefish were harvested in 

the spring primarily in the Great Bend in front of the village (Brown et al. 2012). Harvest areas for berries 

and plants took place both near the community and in areas within a day’s travel by boat. There were 

harvest locations reported in the Canoe Hills area and in the hills directly across the Kuskokwim River 

from the community of Crooked Creek. Residents reported traveling by boat downstream to an area 

between the Oskawalik River and Napaimute, and then also as far upstream as midway between the 

George River and the community of Red Devil (Brown et al. 2012). Trapping areas at the George River 

Area and the Oskawalik River were reported as popular use areas as well. 

Chuathbaluk 

Chuathbaluk is located on the Kuskokwim River. In 2009, the estimated population was 122 people. In 

2010, ADF&G researchers surveyed 30 of the 36 households in Chuathbaluk. They then expanded the 

data set for the six unsurveyed households Chuathbaluk’s estimated total harvest was reported as 29,874 

pounds. The average household harvest was determined to be 829 pounds. Fish were reported as the most 

widely used resource category (97 percent) followed by vegetation (87 percent), land mammals (80 

percent), and birds and eggs (57 percent). It was reported that over 60 percent of the total harvest was 

composed salmon with Chinook being the main species harvested and also sockeye, coho, and chum 

salmon. Moose represented 13 percent of the total harvest but was used by over 70 percent of households 

as reported in the survey. Additional resources harvested included beaver, smelt, sheefish, black bear, and 

caribou. Caribou harvests were very low in the survey year, with only four total harvested. 

Harvest areas for Chuathbaluk were reported to be in an area of 982 square miles. The land use areas were 

reported to be primarily at the mainstem of the Kuskokwim, Aniak and Holokuk Rivers, as well as 

Victoria and Suter creeks (Brown et al. 2012). Salmon fishing was reported as in a location that was 

limited to an area 5 miles upriver of Chuathbaluk and to 6 miles below on the mainstem of the 

Kuskokwim River. Salmon fishing also occurred near Napaimute and in Aniak Slough. Whitefish, 

rainbow/steelhead trout harvest locations were reported as similar to those harvest areas used for salmon. 

Chuathbaluk residents reported that harvest areas extended over a wide area for hunting of moose, 

caribou, and black bear. Caribou were harvested to the southwest of Aniak and to the east of Whitefish 

Lake. Black bear were reported as being hunted on the north and south banks of the Kuskokwim River in 

an area that was upriver of Napaimute. Moose hunting occurred along the river corridor in Unit 19A and s 

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Section 5. Social and Economic Conditions Appendix M: BSWI Affected Environment Report 

in the Holokuk River drainage, the Russian Mountains, Suter Creek and the Kolamokof (Brown et al. 

2012). 

Kalskag 

Kalskag is located on the Kuskokwim River with an estimated population in 2011 of 219 people 

(ADF&G 2016j). Limited data are available for this community in the ADF&G Community Subsistence 

Information System with 2009 being the representative year. Subsistence harvests were reported at 345 

pounds per person (all resources) in Kalskag. Important subsistence fish species included coho, Chinook 

and chum salmon, and whitefish. Moose are the primary land mammal resource harvested for this village. 

Lime Village 

Lime Village is located on the Stony River with an estimated population in 2011 of 22 people (ADF&G 

2016j). Limited data are available for this community in the ADF&G Community Subsistence 

Information System with 2007 being the representative year. Subsistence harvests were reported at 935 

pounds per person (all resources) in Lime Village. Important subsistence fish species included coho, 

Chinook, sockeye and chum salmon, and non-salmon fish included pike, whitefish, and grayling. Black 

bear, caribou, and moose are important land mammal resources for this village. 

Lower Kalskag 

Lower Kalskag is located on the Kuskokwim River with an estimated population in 2011 of 287 people 

(ADF&G 2016j). Limited data are available for this community in the ADF&G Community Subsistence 

Information System with 2009 being the representative year. Subsistence harvests were reported at 187 

pounds per person (all resources) in Lower Kalskag. Important subsistence fish species included coho, 

Chinook and chum salmon, and whitefish. Moose are important land mammal resources that are harvested 

and used by this village. 

McGrath 

McGrath is located on the Kuskokwim River with an estimated population in 2011 of 341 people 

(ADF&G 2016j). Limited data are available for this community in the ADF&G Community Subsistence 

Information System with 2011 being the representative year. Subsistence harvests were reported at 236 

pounds per person (all resources) in McGrath. Important subsistence fish species were coho, Chinook, 

coho, and chum salmon, non-salmon fish included pike and sheefish. Moose are the most important land 

mammal resource for this village. Black bear, brown bear, plains bison, caribou, moose Dall sheep, wolf 

and wolverine are species, which are important to rural subsistence users from the villages of McGrath, 

Takotna and Nikolai (BLM 2018b). 

Use areas that were described in 2011 by McGrath residents reported using an area of 3,857 square miles 

for subsistence. The harvest areas were reported along the Kuskokwim River from the mouth of the Swift 

Fork roughly 80 miles upstream from the community to the community of Stony Rover (Ikuta et al. 

2014). Residents also reported that they used the areas near the community and the tributaries including 

the Takotna Rover, Fourth of July Creek, Nixon Fork, Carl Creek, and the Stony River as harvest areas. 

Drift gillnets sites were on the lower portions of the Big River and Pitka Fork, which are tributaries of the 

Middle Fork located about 25 miles upriver from McGrath. Drift net fishing occurred 10 miles up each of 

these rivers and drift gillnet fishing was occurring near the village of Stony Rover (Ikuta et al. 2014). 

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Appendix M: BSWI Affected Environment Report Section 5. Social and Economic Conditions 

Large land mammal hunting for moose, black bear, brown bear and caribou occurs over a large portion of 

lands with hunting areas for species overlapping. Users in McGrath reported that they hunted along the 

Kuskokwim from Stony River to upstream of the mouth of the Swift Fork River, which is 88 miles from 

McGrath. They also reported traveling more than 50 river miles up the Nixon Fork and on the Takotna 

River from McGrath to roughly 50 miles upstream from the community of Takotna itself. Overland travel 

by snowmobile to the upper tributaries of the Yukon River occurred to the northwest of McGrath (Ikuta et 

al. 2014). Some hunting also occurs near the Innoko River 60 miles northeast of McGrath and towards the 

South Fork of the Kuskokwim River, which is 70 miles southwest of McGrath. Small mammal hunting 

occurs within a 60 mile diameter of the community. Bird hunting is reported to occur on the Kuskokwim 

River for roughly 25 miles downstream m and upstream for about 80 miles to the mouth of the Swift 

Fork. Berry harvest occurs mainly on the road near McGrath and along the river. 

The sheefish spawning area near McGrath was noted to be an important are for McGrath harvesters (BLM 

2018b). A 2012 ADF&G report on sheefish spawning grounds on the Kuskokwim River provides detailed 

information about spawning areas documented on the Kuskokwim River (Stuby 2012). The report shows 

three spawning locations on the Kuskokwim River for sheefish, located on the Tonzona, Middle Fork and 

Big River, all located in the upper Kuskokwim River and of these locations; there are BLM-managed 

public lands near the Big River. The greatest use of sheefish in the Kuskokwim River drainage has been 

for subsistence (Stuby 2012). 

Nikolai 

Nikolai is an Athabascan community located on the south fork of the Kuskokwim River. In 2011, the 

estimated population was 117 people. In January 2012, researchers from the ADF&G surveyed 26 of 39 

households in Nikolai with questions on the survey pertained to harvests obtained in 2011. Expanding for 

the 13 unsurveyed households, Nikolai’s estimated total harvest in 2011 was approximately 58,416 

pounds with an average household harvest of 1,498 pounds and the average harvest per person reported at 

499 pounds (Ikuta et al. 2014). The main species harvested and used were large land mammals (moose at 

47 percent) Chinook salmon, Northern pike (5 percent), coho salmon (4 percent) and sheefish (4 percent) 

with other resources being chum salmon, whitefish, black bear, beaver, and Bering cisco (Ikuta et al. 

2014.) Fish species reported to make up that largest percentage of the wild foods harvest. All households 

in the survey reported using moose, while 73 percent reported using Chinook salmon, 80 percent reported 

using berries and 73 percent reported using a fresh water fish species. Some 65 percent of households 

surveyed said they harvested a large land mammal and 58 percent said they harvested a moose. All of the 

households participating in the study reported harvesting vegetation and 65 percent reported harvesting 

fish. 

Use Areas that were described in 2011 by Nikolai residents reported using an area of 757 square miles for 

subsistence. Residents reported that harvest areas for most subsistence resources overlapped and their 

traditional territory and includes a very large area encompassing most of the major tributaries of the 

Upper Kuskokwim drainage. The Upper Kuskokwim River and its tributaries were the main search and 

harvest locations and transportation corridors used to reach harvest areas (Ikuta et al. 2014). Non-salmon 

fishing occurred in areas similar to salmon fishing on the South Fork of the Kuskokwim downstream 

from the community and on the tributaries of the Big River. Households reported searching for moose 

primarily around the village, along the South Fork of the Kuskokwim River downstream from Nikolai, 

the Salmon River, and the North Fork of the Kuskokwim almost to Telida. Caribou, moose, as well as 

black and brown bear were also hunted along the South Fork of the Kuskokwim River and the upper 

reaches of Windy Fork of the Kuskokwim into the foothills of the Alaska Range (Ikuta et al. 2014). 

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Section 5. Social and Economic Conditions Appendix M: BSWI Affected Environment Report 

Most Nikolai residents fished for Chinook salmon along the Salmon River, Pitka’s Fork near Medfra, the 

North Fork of the Kuskokwim, and Blackwater Creek. Whitefish harvest locations are almost limitless in 

the area around Nikolai and residents spoke of harvesting whitefish in numerous locations almost year 

around. Pike are another important resource that was widely available throughout the area (Ikuta et al. 

2014). 

Sleetmute 

Sleetmute is located on the Kuskokwim River and in 2010; the population was reported as 86 people. In 

2010, ADF&G conducted household surveys and 32 of 37 households participated and reported on their 

harvest activities during 2009 (Brown et al. 2012). The data was then expanded for five unsurveyed 

households. Survey data from 2009 estimated a total harvest in 2009 with approximately 36,547 pounds 

with an average per household harvest of 988 pounds. Species harvested and reported used included 

salmon (used by 91 percent of households); whitefish (84 percent); and large land mammals (63 percent), 

including moose (56 percent) (Brown et al. 2012). Residents reported that their harvest and use of moose 

was higher than in the past and several residents reported that prior to moose hunting being closed in Unit 

19A, moose were the primary subsistence resource in the village (Brown et al. 2012). Moose accounted 

for an additional 9 percent of the total harvest and other land mammals harvested were beaver and black 

bear. Sleetmute residents reported that beaver were harvested mainly for their meat instead of their pelts. 

Salmon accounted for an estimated 68 percent of the total harvest. Other non-salmon fish resources 

harvested included sheefish, northern pike, and Arctic grayling (Brown et al. 2012). Edible plants that 

were harvested included blueberries, high bush cranberries, currants, wild rhubarb, rose hips, and 

Hudson’s Bay tea (Brown et al. 2012).

The harvest areas as reported in 2009 by Sleetmute residents comprised of a total of 1,712 square miles. 

Residents reported that the majority of resources were harvested within a 20-mile radius of the 

community. Some residents noted that they also traveled up to 100 miles or more in search of wild food. 

The hunting areas for moose, black bear, and caribou were reported in areas that overlapped and included 

the Kuskokwim River corridor and tributaries that were the Holitna, Hoholitna, and Swift river corridors, 

the drainage of Titnuk Creek, and the area near the Door Mountains near the upper reaches of the 

Hoholitna River. Fishing areas are reported as being close to the community and driftnet and set net 

fishing sites are in the direct vicinity of the town (Brown et al. 2012). Residents reported that their 

driftnets and setnets were used downriver from the village whereas setnets were used at the mouth of the 

Holitna River, and slightly upriver from the village. Residents also reported fishing up the Holitna and 

Stony Rivers. 

Stony River 

Stony River is located on the Kuskokwim River, with a reported population of 42 in 2010. In March 

2010, ADF&G researchers surveyed 12 of 20 households in Stony River. They expanded the data for 

eight unsurveyed households. The estimated total harvest in 2009 was approximately 33,726 pounds. An 

average per household harvest of 1,686 pounds was reported. Fish was the main species that was 

harvested. Survey data indicated that ninety-two percent of households said they used land mammals and 

edible plants, and 75 percent of households reported that they harvested birds and eggs. Fifty eight 

percent of households said they harvested fish, 50 percent reported harvesting land mammals, 83 percent 

harvested vegetation, and 67 percent reported that they had harvested birds (Brown et al. 2012). Chinook 

salmon was the main salmon species harvested and salmon comprised 68 percent of the total community 

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Appendix M: BSWI Affected Environment Report Section 5. Social and Economic Conditions 

harvest. Fish were the largest category of wild resource harvested in terms of edible pounds (86 percent of 

the total community harvest), followed by land mammals, edible plants, and birds (Brown et al. 2012). 

Harvest areas that were reported as used by residents of Stony River included an area of 487 square miles. 

Residents reported that moose were hunted along the eastern border of Unit 19A and in the western 

portion of Unit 19D covering a small area that is down river from the community and portions of the 

Swift River, Tatlawiksuk River, and Kuskokwim River. Small land mammals harvest areas for beaver and 

marten were north of Stony River and upriver from the village (Brown et al. 2012). Salmon fishing areas 

are concentrated along the main stem of the Kuskokwim River with some families reporting that they 

travel up the Stony River to fish. Non-salmon fishing areas are down river from Stony River village and 

near the junction of the Kuskokwim and Stony Rivers (Brown et al. 2012). 

Norton Sound/Unalakleet Wild River Area 

Unalakleet 

The community of Unalakleet is located on the Unalakleet River, with an estimated population in 2011 of 

692 people (ADF&G 2016j). Limited data are available for this community in the ADF&G Community 

Subsistence Information System, with 1995 being the representative year and only migratory bird harvest 

data available reported at 9 pounds per person. 

The Unalakleet River watershed provides habitat for moose, caribou, brown bear, wolf, wolverine, which 

are species that are important to local subsistence users. This is an area where the people of Unalakleet 

have traditionally fished and hunted; it has cultural significance. The proposed Unalakleet River 

Watershed ACEC contains several significant cultural resources. The Kaltag Portage has been an 

important travel and trade route for Alaska Natives for thousands of years. Moose populations within the 

Unalakleet watershed are at historically low levels but are slowly increasing with intensive population 

management coordinated by State and federal agencies, including BLM. Moose are an important 

subsistence species for the residents of local villages, particularly the Village of Unalakleet, and are 

managed under ANILCA on federal lands, and for sustained yields by ADF&G (BLM 2018b). 

Chinook and coho salmon returning to the Unalakleet River constitute the bulk of the Unalakleet 

subsistence harvest and ADF&G has quantified Chinook and coho salmon subsistence harvests in the area 

since 1961 (Soong et al. 2008). The Unalakleet River watershed is actively fished and hunted for 

subsistence uses and needs by federally qualified rural residents. The decline of Chinook salmon 

population in recent years has elevated the significance of other salmon species for subsistence uses and 

needs. 

The North River supports important subsistence and sport fishing for non-residents and residents of the 

village of Unalakleet. Resident fish are also present including Dolly Varden, Arctic char, and whitefish 

High quality salmon spawning beds have been identified in the North River (BLM 2018b). The North 

River watershed provides habitat for moose, caribou, brown bear, wolf, and wolverine. These species are 

important to local subsistence users, as well as local guides and outfitters that provide services to resident 

and non-resident sport hunters, providing benefit to the local economy as well as providing opportunity 

for qualified subsistence users from Unalakleet and Shaktoolik. The Nulato River watershed provides 

habitat for moose, caribou, brown bear, wolf, and wolverine. These species are important to local 

subsistence users, as well as local guides and outfitters that provide services to resident and non-resident 

sport hunters, providing benefit to the local economy as well as providing opportunity for qualified 

subsistence users from Unalakleet and Shaktoolik (BLM 2018b). 

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Section 5. Social and Economic Conditions Appendix M: BSWI Affected Environment Report 

Egavik Creek and its watershed provides important caribou and moose habitat; all species of whitefish 

and cisco spawn in this river; the river is also a major spawning area for whitefish; and an important 

spawning area for all species of salmon. This is an area where the people of Unalakleet have traditionally 

fished and hunted; it has cultural significance. The proposed Egavik Creek Watershed ACEC has relevant 

values for an important spawning area for four species of Pacific Salmon and whitefish. These species 

have important subsistence value to the people of Unalakleet identifying them as a relevant value. This 

watershed provides habitat for black bear, brown bear, caribou, wolf, wolverine lynx and moose 

important to users from the villages of Unalakleet and Shaktoolik and are found throughout the region. 

The surrounding land is important for subsistence access, hunting, and calving/wintering grounds for 

moose and caribou. The Golsovia River watershed provides important caribou and moose habitat; all 

species of whitefish and cisco spawn in this river; the river is also a major spawning area for whitefish; 

and an important spawning area for all species of salmon. Extend the existing ACEC to include all areas 

of the Unalakleet River watershed (BLM 2018b). 

5.2.5 Non-Market Values of Subsistence Resources and Activities 

Hunting and gathering of fish, wildlife, and vegetative resources have values that extend beyond 

economic worth. For many communities, hunting and gathering have shaped the culture and tradition of 

the people and the customs have been shared through generations. Customary trade and sharing within 

and between families is important to the ongoing relationships with neighbors inside and outside of the 

planning areas. Movements and timing of activities occur on seasonal rounds, dictated by availability of 

resources; and more recently by hunting, fishing, and trapping regulations, and employment and school 

schedules (Case 1986 in BLM 2018b). 

The customs and traditions within and between the planning subunits are rich and varied. These customs 

and traditions have been passed from generation to generation, yet they continue to change in response to 

technology, resource availability, and regulations. 

5.2.6 Resource Changes: Trends and Forecasts 

Climate change and associated effects such as accelerated spread of invasive species, changes in habitat 

character and quality, and changes in plant and animal species distribution and abundance are likely to 

affect the availability of subsistence resources. However, currently available research cannot confidently 

predict how individual species will respond to projected climatic changes in the planning area. 

Additionally, climate change will affect travel access to subsistence species populations in a manner 

similar to its effects on trails and roads. 

5.3 Hazardous Materials and Health and Human Safety 

5.3.1 Introduction 

This section describes the laws, regulations and policies related to hazardous materials and health and 

human safety, as well as the resource indicators that will be used to evaluate impacts to hazardous 

materials and health and human safety. The section also includes a discussion of the current condition of 

abandoned mines, hazardous materials, and public safety within the project area and trends in resource 

uses and conditions that may affect hazardous materials and public safety within the project area in the 

future. 

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Appendix M: BSWI Affected Environment Report Section 5. Social and Economic Conditions 

5.3.2 Laws, Regulations, and Policies 

Numerous regulations and laws govern environmental protection, including but not limited to the 

following legislation. The Resource Conservation and Recovery Act (RCRA), Title 40 of the CFR, parts 

239 through 282 and the CERCLA–Superfund govern how toxic substances that have been released into 

the environment are managed and remediated. 

The CWA (40 CFR, Subchapters D, N, and O) is designed to manage discharge of hazardous substances 

into all waters and eliminate potential threats to the environment from those releases. Governance of toxic 

substances not included under RCRA or CERCLA are covered by the CWA Toxic Substance Control Act 

(TSCA; 15 U.S.C. 53); Federal Insecticide, Fungicide, and Rodenticide Act (7 U.S.C. 6); Department of 

Transportation (49 CFR), and the National Contingency Plan. 

Asbestos clean-up and disposal management on BLM-managed public lands is managed by the Asbestos 

Hazard Emergency Act and the Asbestos School Hazard Abatement Reauthorization Act and are intended 

to minimize impacts to those that live in the vicinity of possible asbestos containing structures. 

Several pieces of legislation are in place to monitor air quality and ensure that industry and other potential 

large-scale polluters follow policy. These are the NESHAP, Section 112 of the CAA, 40 CFR Subchapter 

C. 

The following BLM mandates are designed to provide guidance: the BLM Handbook H-1703-1, 

CERCLA Response Actions Handbook; BLM Handbook H-2000-1, Pre-Acquisition Environmental Site 

Assessments; and BLM Handbook H-2000-2, Environmental Site Assessments for Disposal of Real 

Property. 

Additionally, the following CFR and AAC chapters govern worker safety and waste management 

protocols: the Occupational Health and Safety Administration (29 CFR) and Title 18 AAC Chapters 60 –

Solid Waste Management, 70 – Water Quality Standards, 72 – Waste Water Disposal, 75 – Oil and 

Hazardous Substances Pollution Control, 78 – Underground Storage Tanks, 80 – Drinking Water and 90 –

Pesticide Control. 

5.3.3 Resource Indicators 

The conditions that are established in the discussions below provide a baseline for hazardous materials 

and health and human safety-related values, which the impact analysis will be based on. The following 

indicators, along with qualitative discussions, will be used to evaluate impacts associated with 

management decisions in the BSWI Draft RMP/EIS: 

• Permit application, monitoring, and closeout 

• Amount of land that is publicly accessible from transportation channels and methods such as 

trails and OHV and snowmobile routes 

• Areas, including location and size, that have been identified and managed as being subject to 

surface-disturbing activities 

• Number of ROW authorizations, grants, and leases that have been issued 

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Section 5. Social and Economic Conditions Appendix M: BSWI Affected Environment Report 

5.3.4 Current Conditions 

Abandoned Mines 

The planning area has a few areas of concern generated by historic mining activities and current placer 

mining. Past mining operations included the use of numerous hazardous substances, which were 

improperly stored and disposed of. A variety of petroleum, oil and lubricants, waste drums, explosive 

materials, acids, caustics, equipment parts, possible military surplus items, and household trash can be 

found on some of the known sites. Chemical hazards are not the only concern with Abandoned Mine 

Land (AML) sites; physical hazards may also exist. 

A list of known AML sites has been complied. These sites consist of current claims on BLM-managed 

public lands and historic sites of concern. Upon discovery of physical or environmental hazards at mine 

sites, temporary safety measures are implemented to warn the public of the risks associated with the site. 

A site assessment is performed to determine the extent of the hazards and the remediation required. 

Hazardous Management Resource and Restoration program and the AML program work together to 

remediate sites of concern. The Hazardous Management Resource and Restoration program covers the 

cleanup of hazardous materials and the AML program covers the remaining site cleanup (BLM 2018f). 

Abandoned Mines on BLM-Managed Public Lands 

The following two abandoned mines within the planning area occur on BLM-managed public lands (BLM 

2018f): 

Red Devil Mine 

Red Devil Mine is located on the south bank of the Kuskokwim River, 1.5 miles upstream from the 

village of Red Devil and 8 miles downstream from Sleetmute. The mine is accessed from the Kuskokwim 

River or by aircraft via Red Devil airstrip. The lands encompassing Red Devil Mine are selected for 

conveyance to TKC (surface estate) and the Calista Corporation (subsurface estate) as part of the 

Sleetmute Village Townsite selection under ANCSA (BLM 2018g). 

Mining occurred at the site from 1933 until 1971, yielding approximately 35,000 2.5-quart flasks of 

mercury. Operating under the 1872 mining laws, mine operators conducted extensive underground and 

surface mining, and disposed of mine tailings and processing wastes at the site. By the mid-1980s, the 

mine’s block of unpatented federal mine claims were declared “Abandoned and Void” and the site had 

fallen into ruin (BLM 2018g). 

The BLM began addressing hazardous materials and physical safety hazards at the site in 1987. Initial 

efforts focused on removing the remaining processing chemicals, PCBs in transformers, and backfilling 

open mine shafts and adits. In 2002, the derelict mine buildings and mercury production facilities were 

demolished and buried in onsite landfills. Beginning in 2003, BLM has addressed multiple fuel spills 

discovered around the site. Cleanup of spilled fuel from the mine’s aboveground fuel storage tanks was

completed as a project under the American Recovery and Reinvestment Act. BLM continues to 

investigate and cleanup additional old fuel spills around the property as they are discovered. This site is 

also listed on the ADEC Contaminated Sites Database and is listed in the “Contaminated Sites of 

Concern” section below as it is located on BLM-managed public lands. 

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Appendix M: BSWI Affected Environment Report Section 5. Social and Economic Conditions 

Kolmakof Mine Site 

The Kolmakof Mine Site (KMS) is an abandoned cinnabar mine on the north bank of the Kuskokwim 

River. The site is located approximately 19.5 miles east of Aniak and approximately 10 miles west of 

Napaimute, Alaska. It is thought that the Kolmakof cinnabar deposit was first discovered by Russian 

explorers in about 1838, making it one of Alaska’s earliest mineral discoveries. A distinguishing 

characteristic of the deposit is that it is located within a high bluff overlooking the Kuskokwim River; 

natural erosion action of the river causes cinnabar to become exposed to view by travelers on the river and 

pieces of fresh cinnabar can be easily collected from the river bank (BLM 2018h). 

All of the buildings and equipment found at the KMS by the time the claims were closed date from the 

1940s and later, most being property of the R&H Mining Company, which operated the KMS mining 

claims from 1965 until closure. The most aggressive mining at the KMS occurred during R&H’s time; 

they brought in a large bulldozer and used explosives to blast away rock at the top of the bluff to expose 

and break free cinnabar. The miners hand-sorted cinnabar pieces from the rubble, and then cleared the 

debris from the open pit by pushing it over the bluff. A ball mill was employed to crush the ore and a 

flotation circuit was brought in to further concentrate/purify the cinnabar. R&H conducted some testing of 

retorting mercury on-site, but because the price of mercury was in steep decline retorting on-site did not 

get past small-scale testing. The last known production of cinnabar occurred in 1970, and the last claims 

were abandoned and void by 1993 (BLM 2018h). 

BLM conducted a CERCLA Environmental Engineering and Cost Analysis for the site from 2008 

through 2012, with a Removal Action Memorandum (RAM) signed in May 2013. Since then, BLM has 

achieved all cleanup/removal objectives of the RAM except at the former mercury retorting area. 

Cinnabar impacted soil there will continue to be removed and properly disposed of off-site as the annual 

federal budget process makes funding available. 

Hazardous Materials 

Hazardous materials are used throughout the planning area. Every community, every commercial activity, 

and nearly all recreational and casual use activities use hazardous materials to some degree. Petroleum oil 

is the most common hazardous material present, although mining wastes, asbestos, lead-based paint, and 

chemicals such as solvents are also present. Tens to hundreds of thousands gallons of oil are stored and 

used at every community and large commercial enterprise. Smaller amounts (i.e., 50–250 gallons 

typically) are stored and used at nearly every residence. Recreational and casual users almost always use 

oil in amounts ranging from less than a gallon to hundreds of gallons to power outboard engines, 

chainsaws, small aircraft, camp stoves, and lanterns. The BLM expends a large amount of resources 

requiring users of public land to properly manage hazardous materials, with a significant portion of that 

going to characterization and cleanup of improperly managed oil; abandoned or orphan leaking drums 

consume considerable management resources. 

The BLM’s Hazard Management and Resource Restoration program provides a framework for hazardous 

materials management. Federal and State environmental laws and regulations govern the storage, 

handling, disposal and release of hazardous materials. 

The goals of the BLM’s Hazard Management and Resource Restoration program are: 

• To protect public health, safety and environmental resources by minimizing environmental 

contamination and hazards on public land and BLM facilities. 

• To comply with federal and State hazardous materials management laws and regulations. 

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Section 5. Social and Economic Conditions Appendix M: BSWI Affected Environment Report 

• To maintain the health of ecosystems through assessment, cleanup, correction, and restoration of 

contaminated sites and other hazards. 

• To manage hazards and hazardous materials-related risks, costs and liabilities. 

• To integrate environmental protection and compliance with all environmental statutes into all 

BLM activities (BLM 2018i). 

Contaminated Sites of Concern 

According the ADEC Contaminated Sites Database (Nov 2016), there are 289 contaminated sites listed 

within the entire planning area. This includes listings predominantly for fuels, but also includes, on a 

much more limited basis, PCBs, pesticides, solvents and abandoned mines and their associated wastes. Of 

the 289 listed sites, 140 are considered Active, 96 are considered Clean up Complete, 41 sites are 

considered Clean-up Complete with Institutional Controls, and the remaining 12 are considered 

Informational only (ADEC 2016e). A total of two of these sites exist on BLM-managed public lands 

within the planning area and both are considered Active. The two sites occurring on BLM lands are 

described below: 

Red Devil Mine – File Number 2442.38.001, EPA CERCLIS ID AKD980495618): Mercury and arsenic 

are present in tailings piles, and free mercury is present in site soils associated with a large mercury 

processing (retorting) operation that ceased operation in the early 1970s. Petroleum hydrocarbons are 

present in various locations associated with maintenance shops. Other contaminants associated with 

mercury mining are also present. The approximately 10-acre main processing area is managed by BLM 

and has been a focus of remedial efforts for several years. This site is also described above in the 

“Abandoned Mine” section.

Kolmakof Mine Site – (File Number 2404.38.014, EPA CERCLIS ID AKN001002949): Tailings, ore, 

soil, and sediment contain mercury above soil cleanup levels. Surface water in a creek that runs adjacent 

to the site did not contain detectable levels of mercury, but sediment samples from the creek bed 

contained mercury up to 89 ppm. The tailings pile was dumped on the bank of the Kuskokwim River. 

Groundwater and river sediment have not been characterized (ADEC 2016e). This site is also described 

above in the “Abandoned Mine” section.

Remediation of Contaminated Sites 

The BLM's policy regarding remediation of contaminated sites begins with identifying potentially 

responsible parties (PRPs) who may be liable for hazardous substance releases affecting BLM-managed 

public lands and resources. If PRPs have not been identified, or are unable to assist with remediation, the 

BLM evaluates the effects to the environment and creates a priority list for remediation. The nature and 

amount of suspected contamination determines the regulatory requirements, involvement of federal and/or 

State regulatory agencies, and other requirements for the site investigation and potential cleanup actions. 

The BLM Manual Handbook H-2000-1 discusses pre- acquisition Environmental Site Assessments. The 

main purpose of this process is to allow BLM to qualify for protection from CERCLA liability when 

acquiring an ownership interest in real property. The Pre-Acquisition Environmental Site Assessment 

breakdown is as follows: 

1. Level 1 – Pre-Acquisition Liability Survey – This screening level analysis is the basis for 

determining whether a full Phase I Environmental Site Assessment will be required for a particular 

parcel. This step is used when the likelihood of contamination is low. 

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Appendix M: BSWI Affected Environment Report Section 5. Social and Economic Conditions 

2. Level 2 – Phase I Environmental Site Assessment – In the event that Level 1 analysis indicates that 

there is the potential for contamination or RECs being present onsite, a Phase I Environmental Site 

Assessment is completed to applicable standards (ASTM E1527 or ASTM E2247-08). This stage also 

identifies other wastes onsite, such as solid wastes, hazards, and any other issues not readily obtained 

in realty documentation. 

3. Level 3 – Phase II Site Investigation – In the event that significant potential for RECs is apparent, a 

site investigation will be performed. During this stage, analytical sampling is conducted and 

delineation work is completed to determine the nature and extent of onsite contamination. The Phase 

II investigation follows the ASTM E1903 Standard Guide for Environmental Site Assessments. 

4. Level 4 – Phase III Cleanup – In the event that contamination identified during Phase II work 

occurs above applicable cleanup criteria, a cleanup action will be taken, with proper approvals. This 

stage involves full site characterization and cleanup. 

Note that this process primarily involves CERCLA sites. Remediation of contaminated sites that are 

under state primacy are handled at that level. 

Public Safety 

The planning area is extremely remote and difficult to access. BLM-managed public lands within the 

planning area are generally far from villages and reached by the public mainly by snowmobile, dogsled, 

or boat. The BLM currently employs one ranger to oversee the entirety of the Anchorage Field Office, 

which includes the BSWI, Bay, Kobuk-Seward, and Ring of Fire planning areas. 

The mission of the Anchorage Field Office Law Enforcement program is to ensure the protection of the 

visiting public and BLM employees, and to prevent and investigate damage to and unauthorized use of 

public lands and resources, and to ensure compliance with federal laws and regulation on public land in 

keeping with the agency-wide mission of sustaining the health, diversity, and productivity of our public 

lands for the use and enjoyment of present and future generations. 

The Anchorage Field Office’s primary law enforcement priorities within the planning area are: 

• Public safety; 

• Prevention of irreversible damage to public lands and resources; 

• Discovery and investigation of unauthorized use and occupancy on BLM-managed public lands 

(particularly when conveyance is delayed as a result of the occupancy); and 

• Establishment of a routine BLM law enforcement presence in rural villages that neighbor public 

lands. 

To access most of the BLM-managed public lands in the planning area, the ranger pilots a Cessna 206 

maintained by the DOI Aviation Directorate. The degree to which the ranger flies this airplane is made on 

a flight-by-flight basis considering management, budget, and law enforcement parameters. Risk 

management analysis is continuously conducted to evaluate each law enforcement mission, particularly 

aerial patrols. 

The major public safety issue for the BLM within the planning area is search and rescue for members of 

the public who become lost, disoriented, or disabled on public lands. The BLM has taken efforts to 

protect public safety during harsh winter conditions through building safety cabins along the Iditarod 

Trail and visibly marking the extent of the trail. 

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Section 5. Social and Economic Conditions Appendix M: BSWI Affected Environment Report 

Major law enforcement issues throughout the planning area include the illegal transportation of alcohol, 

drunk driving, assault, sexual abuse, unauthorized dumping, and unauthorized commercial uses. These 

crimes are prevalent in villages throughout the planning area because of the lack of employment and 

opportunity available in many rural villages. 

Alaska State Troopers have primary law enforcement responsibility within the planning area. The BLM’s 

jurisdiction is limited to the public lands. One State Trooper may be responsible for as many as ten 

villages. Village Police Officers may be located in large towns within the planning area. Village Public 

Safety Officers are funded by Alaskan Native Tribes and are given limited law enforcement authority; 

however, they are not allowed to carry firearms. The State Troopers’ role within these villages is to 

oversee the Village Police Officers and the Village Public Safety Officers, and to respond to crimes that 

are beyond the Village Police Officers’ or Village Public Safety Officers’ capability.

5.3.5 Resource Changes: Trends and Forecasts 

Upon discovery of physical or environmental hazards or hazardous materials, temporary safety measures 

are implemented to warn the public of the risks associated with the site. A site assessment is performed to 

determine the extent of the hazards and the remediation required. 

If areas within the planning area sustain higher levels of visitation, or recreation activities or resource uses 

change, public safety issues may also change and would be assessed as new trends in safety emerge. 

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Appendix M: BSWI Affected Environment Report Section 6. Reference List 

Section 6. Reference List 

ACCS (Alaska Center for Conservation Science). 2015. Monitoring & controlling invasive plants at Rohn 

Cabin: 2014 update. Alaska Natural Heritage Program, University of Alaska Anchorage. 

Anchorage, AK. 20 p. 

ACFEC (Alaska Commercial Fisheries Entry Commission). 2010. Permit database for 2010. Available at 

http://www.cfec.state.ak.us/cpbycen/2010/Mnu.htm. 

ACHP (Advisory Council on Historic Preservation). 2011. Native American Traditional Cultural 

Landscapes Action Plan. Washington, D.C. 

ACHP. 2012a. Traditional Cultural Landscapes in the Section 106 Review Process. Washington, D.C. 

ACHP. 2012b. Native Traditional Cultural Landscapes and the Section 106 Review Process: Questions 

and Answers. Washington D.C. 

ACIA (Arctic Climate Impact Assessment). 2005. Arctic Climate Impact Assessment Scientific Report. 

Cambridge University Press, MA. https://www.amap.no/documents/doc/arctic-arctic-climateimpact-assessment/796 

Ackerman, R.A. 1979. Southwestern Alaska Archeological Survey: Akhlun-Kuskokwim Mountains. A 

final research report to the National Geographic Society. Grant No. 80749. 

Ackerman, R.A. 1996. Cave 1, Lime Hills. In: American Beginnings, edited by F.H. West. University of 

Chicago Press, Chicago. 

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Available at: http://reindeer.salrm.uaf.edu/about_reindeer/#Description (accessed October 24, 

2016). 

USACE (U.S. Army Corps of Engineers). 2015. Donlin Gold Project, Draft Environmental Impact 

Statement, November. Available at: http://donlingoldeis.com/EISDocuments.aspx. 

USDA (U.S. Department of Agriculture). 1979. Exploratory Soil Survey of Alaska. Soil Conservation 

Service. 

USDA. 2008. Soil Survey of Western Interior Rivers Area, Alaska. Michael Mungoven, Natural 

Resources Conservation Service and United States Department of Agriculture, 2008. 

USDA. 2018. Spruce Beetle. Available at: https://www.fs.usda.gov/detailfull/r10/forestgrasslandhealth/?cid=FSEPRD536861&width=full#Historic%20Activity (accessed October 31, 

2018). 

USDA (U.S. Department of Agriculture–Forest Service), U.S. Department of the Interior, Bureau of Land 

Management, National Park Service, U.S. Fish and Wildlife Service, and Bureau of Indian 

Affairs. 2009. Guidance for the Implementation of Federal Wildland Fire Management Policy. 

February 13. Available at: http://www.nifc.gov/policies/policies_documents/GIFWFMP.pdf. 

U.S. Forest Service. 2004. National Strategy and Implementation Plan for Invasive Species Management. 

FS-805. Washington, DC. 24 p. 

U.S. Forest Service. 2015. Forest Health Conditions in Alaska – 2015: A Forest Health Protection Report. 

R10-PR-38. Anchorage, AK. 90 p. 

U.S. Forest Service, National Park Service, and U.S. Fish and Wildlife Service. 2010. Federal Land 

Managers’ Air Quality Related Values Work Group (FLAG): Phase I Report—Revised (2010). 

Natural Resource Report NPS/NRPC/NRR—2010/232. National Park Service, Denver, Colorado. 

USFWS (U.S. Fish and Wildlife Service). 2004. Land Conservation Plan for Yukon Delta National 

Wildlife Refuge. Bethel, Alaska September 2004. 

USFWS. 2015. Waterfowl Population Status, 2015. U.S. Department of the Interior, Washington, DC. 

USFWS. 2016. American Peregrine Falcon - Species Profile. Available at: 

https://ecos.fws.gov/ecp0/profile/speciesProfile?spcode=B01H. 

6-24 
 

 

 

Appendix M: BSWI Affected Environment Report Section 6. Reference List 

USGS (U.S. Geological Survey). 2003. Geological Studies of Mercury by the U.S. Geological Survey. 

USGS Circular 1248, edited by J.E. Gray. 35 p. 

USGS. 2008. Alaska Resource Data Files (ARDF). Available at: http://ardf.wr.usgs.gov. 

USGS. 2016. Changing arctic ecosystems initiative, Alaska Science Center. Anchorage, AK. 

Van Wagner, C.E. 1988. The historical pattern of annual area burned in Canada. Forestry Chronicle, 64, 

182-185. 

Viereck, L.A. 1983. The Effects of Fire in Black Spruce Ecosystems of Alaska and Northern Canada. In: 

Wein, Ross W.; MacLean, David A., Editors. The role of fire in northern circumpolar 

ecosystems. New York: John Wiley and Sons Ltd.:201-220. 

Viereck, L.A., Dyrness, C.T., Batten, A.R., and Wenzlick, K.J. 1992. The Alaska vegetation 

classification. Gen. Tech. Rep. PNW-GTR-286. Portland, OR: U.S. Department of Agriculture, 

Forest Service, Pacific Northwest Research Station. 278 p. 

Volney, W.J.A., and R.A. Fleming. 2000. Climate change and impacts of boreal forest insects. 

Agriculture Ecosystems and Environment, 82(1-3), 283-294. doi:10.1016/S0167-8809(00)00232 

Wahrhaftig, Clyde. 1965. Physiographic divisions of Alaska: U.S. Geological Survey Professional Paper 

482, 52 p., 6 sheets, scale 1:2,500,000. 

Weber, P.K. 1986. Downstream effects of placer mining in the Birch Creek basin, Alaska. Alaska Dept. 

of Fish and Game. Juneau, AK. 21 pp. 

Weber, P.K., and R. Post. 1985. Aquatic habitat assessments in mined and unmined portions of the Birch 

Creek watershed. Alaska Dept. of Fish and Game. Juneau, AK. 65 pp. 

WEC (World Energy Council). 2001. Survey of Energy Resources published by the World Energy 

Council. 

West, E.W., and U. Swain. 1999. Surface activity and structure of a hydrothermically-heated maternity 

colony of the Little Brown Bat, Myotis lucifugus, in Alaska. Canadian Field-Naturalist 113:425-

429. 

Western Arctic Caribou Herd Working Group. 2011. Western Arctic Caribou Herd Cooperative 

Management Plan- revised December 2011. Nome Alaska. 47 pp. 

White, C.M., and D.A. Boyce, Jr. 1978. A profile of various rivers and their raptor populations in western 

Alaska 1977. Technical Report 01, Bureau of Land Management, Anchorage, Alaska. 

Whitaker, J.O. Jr., and B. Lawhead. 1992. Foods of Myotis lucifugus in a maternity colony in central 

Alaska. J. Mammalogy. 73:646-648. 

Whitlock. 2016. Personal communication between James Whitlock, BLM and Luke Hoffman, AECOM 

on October 28, 2016 regarding placer operations within the BSWI planning area. 

Wiedmer, Michael. 2002. Lower Kenai Peninsula summer off-road vehicle trail stream crossings. Alaska 

Department of Fish and Game (Draft Report). 

Wiggins, D.A., D.W. Holt and S.M. Leasure. 2006. Short-eared Owl (Asio flammeus), The Birds of North 

America Online (A. Poole, Ed.). Ithaca: Cornell Lab of Ornithology; Available from the Birds of 

North America Online: http://bna.birds.cornell.edu/bna/species/062 doi:10.2173/bna.62. 

Wilkinson, T. 2001. On the beaten path. National Parks 75(3-4): 34-38. 

Wolfe, R.J. and R.J. Walker.1987. Subsistence economies in Alaska: productivity, geography, and 

development impacts. Arctic Anthropology 24(2): 56-81. 

6-25 
 

 

Section 6. Reference List Appendix M: BSWI Affected Environment Report 

Woolington, J.D. 2011. Caribou management report, Units 9B, 17, 18 south and 19A and 19B. Pages 11-

32 in P. Harper, editor. Caribou management report of survey and inventory activities 1 July 

2008−30 June 2010. Alaska Department of Fish and Game. Juneau, Alaska. Available at 

http://www.ADF&G.alaska.gov/index.cfm?ADF&G=wildliferesearch.smr20154. 

WRCC (Western Regional Climate Center). 2016a. Climate of Alaska. Available at: 

https://wrcc.dri.edu/Climate/narrative_ak.php (website copyright date 2016, accessed October 25, 

2016). 

WRCC. 2016b. Climate Summaries. Available at: https://wrcc.dri.edu/summary/climsmak.html (website 

copyright date 2016, accessed October 25, 2016). 

Yeend, W., P.H. Stauffer, and J.W. Hendley. 1998. Rivers of gold – placer mining in Alaska. U.S. 

Department of the Interior, U. S. Geological Survey, Fact Sheet 058-98. 

Young, Jr., D.D., C.L. McIntyre, P.J. Bente, T.R. McCabe, and R.E. Ambrose. 1995. Nesting by Golden 

Eagles on the north slope of the Brooks Range in northeastern Alaska. J. Field Ornithol. 66:373-

379. 

Zhang, Ning and Robert Blodgett. 2003. Alaska Paleontology Database. Available at: 

www.alaskafossil.org. 

6-26 
Appendix M-1: BLM Alaska Sensitive Species 

United States Department of the Interior 

BUREAU OF LAND MANAGEMENT 

Alaska State Office 

222 West Seventh A venue, # 13 

Anchorage, Alaska 99513-7504 

http://www.blm.gov/ak 

TAKE PRIDE• 

INAMERICA 

In Reply Refer To: 

6840 (931) P 

May 18, 2010 

Instruction Memorandum No. AK-2010-018 

Expires: 9/30/2011 

To: District Managers, AFS Manager, DSD - Division of Lands, 

Office of Pipeline Monitoring 

From: State Director 

Subject: BLM-Alaska Revised Sensitive Species Lists 

Program Area: Special Status Species 

Purpose: This Instruction Memorandum transmits the revised sensitive animal and plant lists 

for BLM-Alaska, and discloses the process used to develop the lists. 

Policy/Action: Attachment 1 identifies 24 animals and 50 plants for sensitive species 

designation. As directed by BLM Manual 6840, the lists encompass federal candidate and 

proposed species, species that have been de-listed from the Endangered Species Act (ESA) 

during the past five years, and other species or distinct population segments that meet specific 

manual criteria. The 6840 Manual eligibility criteria and the locally-developed process to apply 

the criteria are consolidated in Attachment 2. 

Data to inform the designations were obtained from both external and internal sources. External 

sources included several agencies and organizations responsible for identifying, tracking or 

managing species of concern, such as the Alaska Natural Heritage Program (ANHP), the Alaska 

Department of Fish and Game, the U.S. Fish and Wildlife Service, and Boreal Partners in Flight. 

Internal sources were primarily biologists and other resource specialists at the state and field 

levels. Spatial data on species occurrences were used when available to determine species 

overlap with BLM lands; when such data were incomplete or not available, inferences were 

made based on both general distribution patterns and habitat availability. 

Bureau sensitive species and their habitats must be addressed during the National Environmental 

Policy Act (NEPA) planning process. This includes both land use and implementation-level 

planning efforts. Where appropriate, land use plans shall be sufficiently detailed to identify and 

resolve conflicts without deferring to implementation-level planning. Where that has not been 

achieved, project-level planning should consider site-specific management practices that would 

mitigate negative effects and promote species conservation. The intent is to minimize or 





Appendix M-1: BLM Alaska Sensitive Species 
United States Department of the Interior 

BUREAU OF LAND MANAGEMENT 

Alaska State Office 

222 West Seventh A venue, # 13 

 

Anchorage, Alaska 99513-7504 

http://www.blm.gov/ak 

In Reply Refer To: 

6840 (931) P 

May 18, 2010 

Instruction Memorandum No. AK-2010-018 

Expires: 9/30/2011 

To: District Managers, AFS Manager, DSD - Division of Lands, 

Office of Pipeline Monitoring 

From: State Director 

Subject: BLM-Alaska Revised Sensitive Species Lists 

Program Area: Special Status Species 

Purpose: This Instruction Memorandum transmits the revised sensitive animal and plant lists 

for SLM-Alaska, and discloses the process used to develop the lists. 

Policy/Action: Attachment 1 identifies 24 animals and 50 plants for sensitive species 

designation. As directed by BLM Manual 6840, the lists encompass federal candidate and 

proposed species, species that have been de-listed from the Endangered Species Act (ESA) 

during the past five years, and other species or distinct population segments that meet specific 

manual criteria. The 6840 Manual eligibility criteria and the locally-developed process to apply 

the criteria are consolidated in Attachment 2. 

Data to inform the designations were obtained from both external and internal sources. External 

sources included several agencies and organizations responsible for identifying, tracking or 

managing species of concern, such as the Alaska Natural Heritage Program (ANHP), the Alaska 

Department of Fish and Game, the U.S. Fish and Wildlife Service, and Boreal Partners in Flight. 

Internal sources were primarily biologists and other resource specialists at the state and fi eld 

levels. Spatial data on species occurrences were used when available to determine species 

overlap with BLM lands; when such data were incomplete or not available, inferences were 

made based on both general distribution patterns and habitat availability. 

Bureau sensitive species and their habitats must be addressed during the National Environmental 

Policy Act (NEPA) planning process. This includes both land use and implementation-level 

planning efforts. Where appropriate, land use plans shall be sufficiently detailed to identify and 

resolve conflicts without deferring to implementation-level planning. Where that has not been 

achieved, project-level planning should consider site-specific management practices that would 

mitigate negative effects and promote species conservation. The intent is to minimize or 



Attachment 3 

BLM-Alaska Watch Lists 

sensitive species selection process identified several species for which data were insufficient to 

fy the 6840 Manual eligibility criteria, but otherwise indicated reason to re-evaluate their status 

Le future. These species are hereby termed "watch species," as they may warrant additional data 

!ction to more accurately determine their status. The watch species are not sensitive species, they 

wt subject to the sensitive species policy, and they have no implied relevance to the NEPA 

,ess. Instead, these species should be emphasized for additional inventory, monitoring, or 

arch efforts, as funding and time allow. Furthermore, they should be re-evaluated during 

equent sensitive species revision efforts. 

: watch species exhibit one or more of the following characteristics: 

, Insufficient or contradictory data exists to reasonably assess population or habitat trends 

, Regional adaptations are expressed that may ultimately be determined by the scientific 

community as distinctive and important for overall species conservation 

, Potential threats to the species are poorly understood 

, Species are rare and do not occur within several kilometers ofBLM land, but potential 

habitat may exist on BLM land. 

Watch List- Animals 

Scientific Name Common Name 

Gavia stellata Red-throated Loon 

Tryngites subruficollis Buff-breasted Sandpiper 

Bird Limosa haemastica Hudsonian Godwit 

Limosa lapponica Bar -tailed Godwit 

Dendroica townsendi Townsend's Warbler 

Catharus minimus Gray-cheeked Thrush 

Fish Oncorhynchus keta 

Oncorhynchus tshawytscha 

Chum Salmon (Clear Creek) 

Chinook Salmon (Beaver Creek) 

Insect Oeneis alpina Eskimo Arctic 

Watch List - Plants 

Scientific Name Common Name 

Avhra~us eschscholtzianus 

Arenaria longipedunculata Low Sandwort 

Beckwithia :;;lacialis Alaskansis Alaskan Glacier Buttercup 

Boechera lemmonii (Arabis lemmonii) 

Cardamine microphylla blaisdellii 

Cardamine microphylla microphylla Small-leaf Bittercress 

Carex heleonastes Hudson Bay Sedge 

Carex laxa 

Cerastium regelii Regel's Chickweed 

Attachment 3-1 

Appendix N: Supplemental Impact Analysis Information 
Appendix N: Supplemental Impact Analysis Information Table of Contents 

Table of Contents 

Section 1. Introduction .......................................................................................................................... 1-1 

1.1 Analytical Assumptions........................................................................................................... 1-1 

1.2 General Methodology for Analyzing Impacts.......................................................................... 1-2 

1.3 Consideration of Noise Impacts at the Planning Level............................................................ 1-2 

1.4 Incomplete or Unavailable Information................................................................................... 1-3 

Section 2. Cumulative Impacts ............................................................................................................. 2-1 

2.1 Cumulative Analysis Methodology ......................................................................................... 2-1 

2.2 Past, Present, and Reasonably Foreseeable Future Actions..................................................... 2-2 

2.2.1 Past and Present Land Use and Activities................................................................... 2-2 

2.2.2 Reasonably Foreseeable Future Land Use and Actions.............................................. 2-7 

Section 3. Supplemental Impact Analysis............................................................................................ 3-1 

3.1 Fisheries ................................................................................................................................... 3-1 

3.1.1 Summary..................................................................................................................... 3-1 

3.1.2 Methods of Analysis................................................................................................... 3-1 

3.1.3 Effects Analysis.......................................................................................................... 3-8 

3.2 Vegetation.............................................................................................................................. 3-42 

3.2.1 Summary................................................................................................................... 3-42 

3.2.2 Methods of Analysis................................................................................................. 3-42 

3.2.3 Effects Analysis........................................................................................................ 3-44 

3.3 Wildlife and Special Status Species....................................................................................... 3-66 

3.3.1 Summary................................................................................................................... 3-66 

3.3.2 Methods of Analysis................................................................................................. 3-66 

3.3.3 Effects Analysis........................................................................................................ 3-71 

3.4 Cultural Resources............................................................................................................... 3-112 

3.4.1 Summary................................................................................................................. 3-112 

3.4.2 Methods of Analysis............................................................................................... 3-112 

3.4.3 Effects Analysis...................................................................................................... 3-114 

3.5 Locatable and Salable Minerals ........................................................................................... 3-136 

3.5.1 Summary................................................................................................................. 3-136 

3.5.2 Methods of Analysis............................................................................................... 3-136 

3.5.3 Nature and Types of Effects ................................................................................... 3-137 

3.5.4 Effects Analysis...................................................................................................... 3-138 

3.6 Lands and Realty.................................................................................................................. 3-149 

3.6.1 Summary................................................................................................................. 3-149 

i 
Table of Contents Appendix N: Supplemental Impact Analysis Information 

3.6.2 Methods of Analysis............................................................................................... 3-149 

3.6.3 Potential Effects and Indicators.............................................................................. 3-149 

3.6.4 Effects Analysis...................................................................................................... 3-151 

3.7 Areas of Critical Environmental Concern............................................................................ 3-176 

3.7.1 Summary................................................................................................................. 3-176 

3.7.2 Methods of Analysis............................................................................................... 3-176 

3.7.3 Effects Analysis...................................................................................................... 3-179 

3.8 National Trails ..................................................................................................................... 3-201 

3.8.1 Summary................................................................................................................. 3-201 

3.8.2 Methods of Analysis............................................................................................... 3-201 

3.8.3 Effects Analysis...................................................................................................... 3-204 

3.9 Wild and Scenic Rivers........................................................................................................ 3-228 

3.9.1 Summary................................................................................................................. 3-228 

3.9.2 Methods of Analysis............................................................................................... 3-229 

3.9.3 Effects Analysis...................................................................................................... 3-231 

3.10 Support for BSWI Communities.......................................................................................... 3-259 

3.10.1 Economic Conditions.............................................................................................. 3-259 

3.10.2 Social Conditions.................................................................................................... 3-278 

3.11 Subsistence........................................................................................................................... 3-289 

3.11.1 Summary................................................................................................................. 3-289 

3.11.2 Methods of Analysis............................................................................................... 3-289 

3.11.3 Effects Analysis...................................................................................................... 3-293 

Section 4. References ............................................................................................................................. 4-1 

ii 
Appendix N: Supplemental Impact Analysis Information Table of Contents 

List of Tables 

Table 2.2.2-1: High Locatable Mineral Potential in the Planning Area................................................... 2-10 

Table 3.1.1-1: Ranking Summary of Alternatives by Management Action and Indicator ........................ 3-1 

Table 3.1.2-1: Summary of Effects to Fisheries Resource by Management Action.................................. 3-6 

Table 3.1.3-1: River Miles/Waterbody Acreage by ROW Management Status and Stream 

Classification: Alternatives B, C, and D........................................................................ 3-11 

Table 3.1.3-2: Summary of Stream Miles and Acres of Waterbodies by Alternative for ROW 

Combined by NHD Region for the Planning Area ........................................................ 3-13 

Table 3.1.3-3: Commercial Woodland Miles/Acres by Closed, Permittable, and Permitted 

Streams/Waterbodies: Alternatives A, B, C, and D....................................................... 3-18 

Table 3.1.3-4: Summary of Stream Miles and Acres of Waterbodies by all Alternatives for 

Commercial Woodlands Combined by NHD Region for the Planning Area ................ 3-20 

Table 3.1.3-5: Areas Open/Closed to Grazing by Miles/Acres of Streams: Alternatives A, B, C, 

and D.............................................................................................................................. 3-24 

Table 3.1.3-6: Summary of Stream Miles and Acres of Waterbodies by Alternatives for Grazing 

Combined by NHD Region for the Planning Area ........................................................ 3-26 

Table 3.1.3-7: Summary of Stream Miles and Acres of Waterbodies by Alternatives for Locatable 

and Salable Combined by NHD Region for the Planning Area..................................... 3-29 

Table 3.1.3-8: Summary of Stream Miles and Acres of Waterbodies by Action Alternative for 

Transportation and Travel Combined by NHD Region for the Planning Area.............. 3-33 

Table 3.1.3-9: Cumulative Effects Analysis for Fisheries Resources...................................................... 3-41 

Table 3.2.2-1: Summary of Effects to Vegetation by Management Action............................................. 3-43 

Table 3.2.3-1: Cumulative Effects Analysis for Vegetation.................................................................... 3-65 

Table 3.3.2-1: Summary of Effects to Wildlife by Management Action................................................. 3-68 

Table 3.3.3-1. Extent of Wildlife Management Actions under Alternative B......................................... 3-79 

Table 3.3.3-2: Extent of Wildlife Management Actions under Alternative C......................................... 3-80 

Table 3.3.3-3: Extent of Wildlife Management Actions under Alternative D......................................... 3-81 

Table 3.3.3-4: Available Disposals, Acquisitions, and Exchanges under Alternative B, by 

Indicator......................................................................................................................... 3-98 

Table 3.3.3-5: Available Disposals, Acquisitions, and Exchanges under Alternative C, by 

Indicator......................................................................................................................... 3-99 

Table 3.3.3-6: Available Disposals, Acquisitions, and Exchanges under Alternative D, by 

Indicator....................................................................................................................... 3-100 

Table 3.3.3-7: Cumulative Effects Analysis for Wildlife and Special Status Species........................... 3-111 

Table 3.4.2-1: Types of Effects to Cultural Resources.......................................................................... 3-114 

Table 3.4.3-1: Cumulative Effects Analysis for Cultural Resources ..................................................... 3-135 

Table 3.5.3-1: Summary of Effects to Locatable and Salable Minerals ................................................ 3-137 

Table 3.5.4-1: Cumulative Effects Analysis for Locatable and Salable Minerals................................. 3-148 

Table 3.6.3-1: Summary of Effects to Lands and Realty by Management Action ................................ 3-150 

Table 3.6.4-1: Alternative A ACECs Affecting Lands and Realty........................................................ 3-164 

iii 
Table of Contents Appendix N: Supplemental Impact Analysis Information 

Table 3.6.4-2: Alternative B ACECs Affecting Lands and Realty........................................................ 3-168 

Table 3.6.4-3: Cumulative Effects Analysis for Lands and Realty........................................................ 3-175 

Table 3.7.2-1: Summary of Effects to ACECs by Management Action................................................ 3-177 

Table 3.7.3-1: Potential Beneficial or Adverse Impacts on Potential ACECs....................................... 3-180 

Table 3.7.3-2: Cumulative Effects Analysis for ACECs ....................................................................... 3-200 

Table 3.8.2-1: Effects and Indicators for National Trails ...................................................................... 3-202 

Table 3.8.3-1: Potential Effects on the INHT ........................................................................................ 3-205 

Table 3.8.3-2: Cumulative Effects Analysis for the INHT.................................................................... 3-227 

Table 3.9.2-1: Rivers Identified as Eligible (Alternative A) and Recommended as Suitable 

(Alternative B) within the Planning Area .................................................................... 3-229 

Table 3.9.2-2: Summary of Effects to Wild and Scenic Rivers by Management Action ...................... 3-230 

Table 3.9.3-1: WSR Intersections with Proposed HVWs (all alternatives)........................................... 3-233 

Table 3.9.3-2: Suitable WSR Intersections with Proposed HVWs (Alternative B)............................... 3-235 

Table 3.9.3-3: WSR Intersections with VRM actions............................................................................ 3-237 

Table 3.9.3-4: WSR Intersections with ROW Actions.......................................................................... 3-247 

Table 3.9.3-5: WSR Intersections with ACECs..................................................................................... 3-250 

Table 3.9.3-6: Intersections of Eligible WSRs with Existing ACECs (Alternative A) ......................... 3-251 

Table 3.9.3-7: Suitable WSR Intersections with Potential ACECs (Alternative B).............................. 3-251 

Table 3.9.3-8: Cumulative Effects Analysis for Wild and Scenic Rivers.............................................. 3-258 

Table 3.10.1-1: Summary of Effects to Economic Conditions by Management Action ....................... 3-260 

Table 3.10.2-1: River Miles of HVW by Alternative ............................................................................ 3-265 

Table 3.10.2-2: Wildlife Habitat for Important Subsistence Game Species.......................................... 3-266 

Table 3.10.2-3: Acres identified by Alternative as Open to Mineral Entry........................................... 3-268 

Table 3.10.2-4: Special Recreation Permit Measures Affecting Non-Market Values........................... 3-269 

Table 3.10.2-5: Acres of Land Open for Subsistence and Personal Use ............................................... 3-271 

Table 3.10.2-6: Summer and Winter Subsistence Travel Designations................................................. 3-272 

Table 3.10.2-7: Acres of ACECs by Alternative ................................................................................... 3-273 

Table 3.10.2-8: Acres of New Wild and Scenic River Corridors by Alternative .................................. 3-274 

Table 3.10.3-1: Summary of Effects to Social Conditions by Management Action.............................. 3-279 

Table 3.10.3-2: Expected Change from Existing Conditions under All Alternatives............................ 3-281 

Table 3.10.3-3: Incremental Cumulative Impact to Economic and Social Conditions.......................... 3-288 

Table 3.11.2-1: Summary of Effects to Subsistence by Management Action ....................................... 3-291 

Table 3.11.3-1: Extent of Wildlife Management Actions Influencing Subsistence under 

Alternative B................................................................................................................ 3-300 

Table 3.11.3-2: Extent of Wildlife Management Actions Influencing Subsistence under 

Alternative C................................................................................................................ 3-302 

Table 3.11.3-3: Extent of Wildlife Management Actions Influencing Subsistence under 

Alternative D................................................................................................................ 3-303 

iv 
Appendix N: Supplemental Impact Analysis Information Table of Contents 

Table 3.11.3-4: Overland Travel Restrictions for Subsistence and Casual Use Proposed under 

Alternative B................................................................................................................ 3-322 

Table 3.11.3-5: Overland Travel Restrictions for Subsistence and Casual Use Proposed under 

Alternative C................................................................................................................ 3-323 

Table 3.11.3-6: Overland Travel Restrictions for Subsistence and Casual Use Proposed under 

Alternative D................................................................................................................ 3-323 

Table 3.11.3-7: Cumulative Effects Analysis for Subsistence............................................................... 3-331 

List of Figures 

Figure 3.1.2-1: Watershed Boundaries and Hydrography ......................................................................... 3-2 

Figure 3.1.2-2: Anadromous Waters and Spawning Habitat ..................................................................... 3-3 

Figure 3.1.2-3: Streams within Medium and High Areas of Mineral Potential (HUC 6).......................... 3-4 

Figure 3.10.2-1: U.S. Average Monthly Prices for Crude Oil and Heating Oil, 2000-2017 ................. 3-276 

v 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Appendix N: Supplemental Impact Analysis Information Section 1. Introduction 

Section 1. Introduction 

This document presents the direct, indirect, and cumulative environmental, social, and economic impacts 

on the human and natural environment that are expected to result from implementing the alternatives 

presented in Chapter 2 of the Bering Sea-Western Interior (BSWI) Draft Resource Management Plan 

(RMP)/Environmental Impact Statement (EIS). Irretrievable or irreversible commitment of resources and 

unavoidable adverse impacts are presented at the end of the report. 

Impact analyses and conclusions are based on interdisciplinary team knowledge of the BSWI Planning 

Area (planning area) and resources, information provided by experts in the Bureau of Land Management 

(BLM), other agencies’ monitoring data, and information contained in pertinent literature. The baseline 

used for the impact analysis is the existing condition or management situation, as described in Chapter 3 

of the BSWI Draft RMP/EIS. Analysis assumptions have also been developed to help guide the 

determination of effects. Assumptions that apply to impact analyses for all resources, resource uses, and 

special designations are included in Section 1.1 below. Additionally, assumptions specific to each 

resource, resource use, or special designation are described in the respective impact section. 

The BSWI Draft RMP/EIS provides a broad management framework over the 13.4-million-acre planning 

area and does not include specifics on actual developments or implementation-level planning. Because the 

BSWI Draft RMP/EIS provides a broad management framework and exact locations of development or 

management are not specified, the analysis in this report presents best estimates of impacts. Impacts are 

quantified to the extent practical with available data and all reported acreages throughout this report are 

approximate. In the absence of quantitative data, best professional judgment provides the basis for the 

impact analysis. Because of the broad scope, impact analysis of planning-level decisions is speculative 

with respect to projecting specific activities and therefore would be performed on a project-specific basis. 

Subsequent documents tiered to this RMP would generally contain a greater level of detail and would be 

subject to the National Environmental Policy Act (NEPA) analysis and compliance process. 

1.1 Analytical Assumptions 

Several assumptions were made to facilitate the estimation of the effects of the alternatives. These 

assumptions are made only for the purpose of analysis and do not represent potential RMP decisions. The 

following are general assumptions applicable to all resource categories. Any specific resource 

assumptions are provided under the “Assumptions” subheading for that resource. 

• Sufficient funding and BLM personnel will be available for implementing the final decision. 

• Implementing actions from any of the RMP alternatives will comply with all valid existing rights, 

federal regulations, BLM policies, Alaska National Interest Lands Conservation Act (ANILCA), 

State laws and regulations, and other requirements. 

• Implementation-level actions necessary to execute the land use plan-level decisions in the RMP 

will be subject to further environmental review, including compliance with NEPA, as appropriate. 

• Acres open to potential development (grazing, mineral development, commercial forestry) would 

influence the amount of development that would occur over the life of the RMP. However, the 

number of acres open to development is not directly proportional to the number of acres that 

would actually be developed under each alternative, because it is unlikely that all acres open to 

development would be developed due to the remoteness of the project area and lack of 

1-1 
 

 

 

 

 

 

 

 

 

 

 

 

Section 1. Introduction Appendix N: Supplemental Impact Analysis Information 

infrastructure (i.e., roads). Actual development will be influenced by economic drivers and 

ecological conditions. 

• The functional capability of all developments will be maintained. 

• The discussion of impacts is based on the best available data. Knowledge of the planning area and 

professional judgment, based on observation and analysis of conditions and responses in similar 

areas, are used to infer environmental impacts where data are limited. 

• Acreage figures and other numbers used in the analyses are approximate projections for 

comparative and analytic purposes only. Readers should not infer that they reflect exact 

measurements or precise calculations. 

1.2 General Methodology for Analyzing Impacts 

Direct, indirect, and cumulative impacts are considered in this effects analysis. The effects analysis was 

performed consistent with direction provided in Title 40 Code of Federal Regulations (CFR) 1502.16, 

Considering Cumulative Effects under the National Policy Act (CEQ 1997); BLM National 

Environmental Policy Act Handbook H-1790-1 (BLM 2008); Council on Environmental Quality (CEQ) 

NEPA regulations for incomplete or unavailable information dated April 25, 1986, in Federal Register 

51(80); and Executive Memo to all federal agencies dated January 24, 2005, regarding Guidance on the 

Consideration of Past Actions in Cumulative Effects Analysis (CEQ 2005). 

• Direct impacts are caused by an action or implementation of an alternative and occur at the same 

time and place. 

• Indirect impacts result from implementing an action or alternative and are later in time or farther 

removed in distance but are still reasonably foreseeable. 

• Cumulative effects are defined in Section 2, “Cumulative Impacts.” 

Effects are quantified where possible using geographic information system (GIS) analysis. In the absence 

of quantitative data, best professional judgment was used to describe impacts in qualitative terms. 

Management actions that would have the same impacts for all alternatives are described together. 

However, more emphasis is placed on management actions that would result in different impacts among 

the alternatives to provide the reader with an understanding of the range of impacts that could result, 

depending on the alternative selected. Only management actions with potential impacts are described. The 

standard definitions for terms referring to impact duration that are used in the effects analysis are as 

follows, unless otherwise stated: 

• Temporary impact: The impact would occur during or immediately after implementation of the 

action and may occur intermittently. Duration of temporary impacts would be 1 year or less and 

could be beneficial or adverse. 

• Short-term impact: The impact would occur during or immediately after implementation of the 

action and could be beneficial or adverse (e.g., during the first 5 years of the RMP). 

• Long-term impact: The impact could last for several years or more and could be beneficial or 

adverse (e.g., beyond the first 5 years of the RMP). 

1.3 Consideration of Noise Impacts at the Planning Level 

Changes to noise levels, noise-producing activities, and associated impacts throughout the planning area 

would depend on actual activities and projects implemented in the planning area. Therefore, a detailed 

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Appendix N: Supplemental Impact Analysis Information Section 1. Introduction 

noise analysis is not included in this EIS and instead would be performed at the project level. 

Management actions being evaluated in this RMP that would have impacts on noise are primarily related 

to mining activity, vehicular use (including recreation), and construction activity. The alternatives 

evaluated in this EIS include areas where these noise-producing activities could occur based on allowable 

uses and the level of restrictions associated with each alternative. Information about potential noiseproducing activities in the planning area was used to provide a high-level discussion of potential changes 

to noise levels and noise-producing activities to resources, resource uses, and special designations that 

could be affected by noise. 

1.4 Incomplete or Unavailable Information 

CEQ established implementing regulations for NEPA requiring that a federal agency identify relevant 

information that may be incomplete or unavailable for an evaluation of reasonably foreseeable significant 

adverse effects in an EIS (40 CFR 1502.22). The best available information pertinent to the decisions to 

be made was used in developing the Draft RMP/EIS. Considerable effort has been taken to acquire and 

convert resource data into digital format for use in the plan—both from BLM sources and from outside 

sources. However, certain information was unavailable when developing the RMP/EIS and is disclosed 

under the “Incomplete or Unavailable Information” subheading for the respective resource. 

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Appendix N: Supplemental Impact Analysis Information Section 2. Cumulative Impacts 

Section 2. Cumulative Impacts 

The CEQ regulations implementing NEPA define cumulative impacts as “...[T]he impact on the 

environment which results from the incremental impact of the action when added to other past, present, or 

reasonably foreseeable future actions regardless of what agency (federal or non-federal) or person 

undertakes such actions. Cumulative impacts can result from minor but collectively significant actions 

taking place over a period of time” (40 CFR 1508.7). 

2.1 Cumulative Analysis Methodology 

Because of the programmatic nature of an RMP, this cumulative effects analysis methodology is broad 

and generalized to address potential effects that could occur from a reasonably foreseeable management 

scenario combined with other reasonably foreseeable activities or projects. The cumulative effects 

analysis evaluates the projected trends and forecasts of each resource, resource use, or special designation 

that could result from the RMP. To understand the RMP’s influence on cumulative effects, trends and 

forecasts are identified in consideration of: 

• Past and present actions (synonymous with the affected environment, described in the BSWI 

Draft RMP/EIS Appendix M); 

• Reasonably foreseeable actions along with past and present actions (this is also representative of 

Alternative A); and 

• Each RMP action alternative along with past, present, and reasonably foreseeable future actions. 

As a result of this analysis, trends and forecasts for each resource, resource use, or special designation are 

identified to fit within one of the following four categories: 

• No contribution to resource trend 

• Stabilizes existing trend 

• Continues existing trend 

• Counters existing trend 

This analysis provides a broad understanding of how each alternative would influence the cumulative 

effects, or trends and forecasts, for each resource, resource use, or special designation in the same 

geographic area. If the resource trend is projected to change as a result of any action alternative, that 

constitutes a cumulative impact. The impact could be adverse or beneficial, depending on the direction of 

the change. 

The following factors were considered in the cumulative impact assessment: 

• Federal, nonfederal, and private actions 

• Potential for synergistic interaction among or between effects 

• Potential for effects across political and administrative boundaries 

• Other spatial and temporal characteristics of each affected resource 

• Comparative scale of cumulative impacts across alternatives 

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Section 2. Cumulative Impacts Appendix N: Supplemental Impact Analysis Information 

• Climate change 

• Identified planning issues 

2.2 Past, Present, and Reasonably Foreseeable Future Actions 

The following sections describe activities that were considered in the cumulative effects analysis. 

2.2.1 Past and Present Land Use and Activities 

Relevant past and present actions are those that have influenced the current condition of the resources in 

the planning area. These actions, described below, have been identified based on review of the planning 

issues; agency records, including existing decisions and formal proposals; and non-federal actions on 

lands not managed by the BLM. 

Land Use 

The planning area and much of the surrounding lands are characterized by large tracts of undisturbed 

ecosystems that support a variety of native wildlife and fish species. Past and present land use and 

activities within the planning area are summarized below and provide the basis for analysis of cumulative 

effects. 

Although this RMP/EIS does not address lands that are not managed by the BLM, including State of 

Alaska lands, Alaska Native Claims Settlement Act (ANCSA) Native corporation lands, National Park 

Service (NPS) lands, U.S. Fish and Wildlife Service (USFWS) lands, private lands, and Native 

allotments, past and present (as well as reasonable foreseeable future actions) land use for all lands within 

the planning area has influenced or has the potential to influence the current condition of the resources in 

the planning area and is therefore considered in the cumulative effects analysis. Impacts from such actions 

include right-of-way (ROW) establishment, lease sales, and surface occupancy. Management of 

subsurface estate within USFWS lands is administered by the BLM under the Mineral Leasing Act of 

1920. ANILCA section 304(c) is addressed in the Mineral Occurrence and Development Potential Report 

for Leasable Minerals within the planning area (BLM 2015a). Conservation System Units (CSUs) and 

other land tracts established by ANILCA will be addressed on a case-by-case basis and are not subject to 

this plan, with the exception of the Unalakleet Wild River Corridor. Similarly, any prior existing mining 

claims administered by the BLM within USFWS or NPS lands will be addressed on a case-by-case basis. 

BLM Land 

Past and current land use on BLM-managed land in the planning area, including the Iditarod National 

Historic Trail (INHT), is considered for the cumulative effects analysis. This information is described in 

detail in the BSWI Draft RMP/EIS, Appendix M. These are lands that will most likely be retained in 

long-term federal ownership. These lands, which constitute 10,727,251 acres, or approximately 

17 percent of the planning area, are not selected by the State of Alaska or by Native corporations. An 

additional 2,594,941 (approximately 4 percent of the planning area) and 144,284 acres (less than 1 

percent of the planning area) are selected by the State of Alaska and Native corporations, respectively. 

Selected lands are in BLM management until interim conveyed or tentatively approved. 

National Wildlife Refuges 

The Yukon Delta National Wildlife Refuge (NWR) and the Innoko Unit of the Innoko NWR fall within 

the planning area. These refuges were established in 1980 by ANILCA with the following management 

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Appendix N: Supplemental Impact Analysis Information Section 2. Cumulative Impacts 

goals: 1) to conserve fish and wildlife populations and their habitats in their natural diversity; 2) to fulfill 

the international treaty obligations of the United States with respect to fish and wildlife and their habitats; 

3) to provide the opportunity for continued subsistence uses by local residents; and 4) to ensure adequate 

water quantity and quality necessary to meet refuge purposes. Activities taking place on the refuges 

include hunting, fishing, recreational use, and subsistence harvest, as well as research and management 

activities. Residents of adjacent villages on the lower Innoko and Yukon Rivers harvest the land’s fish 

and wildlife resources (USFWS 1988). Fish and fall hunting camps are still in use today up and down 

rivers of the Innoko region. Indigenous people known as the Yup’ik and Cup’ik Eskimos and 

Athabaskans inhabit the Yukon Delta NWR and rely heavily on local natural resources. 

Historically, 77 lode and placer mining claims were located within the Yukon Delta NWR, mostly in the 

Kilbuck Mountains in the southeastern quarter of the refuge. Currently, no active mining claims or valid 

oil and gas leases are located on refuge lands. Fifty-nine pending oil and gas lease applications are on file 

with the BLM for the Yukon Delta NWR. All but one were filed in 1968, but leases were never issued. 

The lease applications were “grandfathered in” under the authority of the Federal Onshore Oil and Gas 

Leasing Reform Act of 1987 (101 Stat. 1330-256, 259) (BLM 2015a). 

National Park Service Lands 

One NPS Unit, Lake Clark National Park and Preserve, reaches into the southeastern portion of the 

planning area, constituting approximately 1.0 percent of the planning area. The 4-million-acre Lake Clark 

National Park and Preserve was established in 1980 by ANILCA. Approximately 2,572,000 acres of the 

park is designated wilderness. The stated purpose of Lake Clark National Park and Preserve is to “protect 

a region of dynamic geologic and ecological processes that create scenic mountain landscapes, unaltered 

watersheds supporting Bristol Bay red salmon, and habitats for wilderness dependent populations of fish 

and wildlife, vital to 10,000 years of human history” (NPS 2009). Subsistence activities by local rural 

residents and those who live on private land within the park and preserve boundaries include hunting, 

trapping, fishing, and timber harvest. Recreational and sport uses of the Lake Clark area are those 

commonly associated with Alaskan wilderness activities such as hunting, fishing, trapping, river running, 

hiking, photography, and wilderness camping. Sport fishing is allowed throughout the park and preserve, 

but sport hunting and trapping are confined to the national preserve. Visitor access is by commercial and 

privately operated airplanes and boats. The use of off-road vehicles for other than subsistence activities is 

prohibited on federal lands within the park and preserve. 

Management of the park and preserve is guided by a portfolio of management plans, including a 

foundation statement (NPS 2009), a general management plan amendment (NPS 2014) and draft land 

protection plan (NPS 2013). The guiding principle of land protection plans is to ensure the protection of 

each unit of the national park system consistent with the stated purposes for which the unit was created 

and administered. 

Nine patented mining claims total 51.2 acres within the Lake Clark Park and Preserve boundary. Park and 

preserve lands are no longer available for new mineral entry and location (NPS 2013). 

State Lands 

The planning area includes roughly 18.1 million acres of State lands and 2.6 million acres of BLM lands 

that have been selected by the State (approximately 21 and 4 percent of the planning area, respectively). 

The BLM continues to manage lands selected by the State of Alaska that have not yet been conveyed. 

Lands that have already been conveyed to the State of Alaska constitute approximately 29 percent of the 

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Section 2. Cumulative Impacts Appendix N: Supplemental Impact Analysis Information 

planning area. State lands in the planning area are managed under guidelines outlined in the specific 

Alaska Department of Natural Resources (ADNR) area plans, such as the Kuskokwim Area Plan (ADNR 

1988) and Tanana Basin Area Plan (ADNR 1991). The State lands are managed for multiple uses, with 

priorities varying according to the resource values for particular subunits. Primary land uses include 

forestry, agriculture, minerals management, recreation, fish and wildlife habitat, heritage resources, 

recreation and tourism, settlement, public access, transportation, and low-value resource management. 

Wood-Tikchik State Park reaches into the southern boundary of the planning area. The park is a 

1.6-million-acre area that was established to protect fish and wildlife populations and to support 

traditional subsistence and recreational activities. Traditional activities in the park include subsistence 

fishing, hunting, and trapping, as well as recreational fishing and hunting. The number of recreational 

wilderness-travel activities in the park has grown and includes kayaking, river floating, hiking, and some 

mountain climbing. The park management plan (ADNR 2002) designates the upper Tikchik Lakes and 

Kulik/Grant lakes as “Wilderness”, designates most of the remainder of the park “Natural Area”, and 

designates the Agulowak River and Lake Aleknagik State Recreation Site as “Recreational 

Development.” 

Native Lands 

The planning area includes lands conveyed to village and regional Native corporations (approximately 

16 percent of the planning area) and lands acquired by Alaska Natives under the Alaska Native Allotment 

Act of 1906 and the Native Townsite Act of 1926 (approximately 440,000 acres, or 1 percent of the 

planning area). 

Over 50 village corporations and five regional corporations (Doyon, Limited, Calista Corporation, Cook 

Inlet Region Incorporated, Bering Straits Native Corporation, and NANA Regional Corporation) have a 

nexus to the planning area. Management objectives for regional corporation lands within the planning 

area are focused on protection of traditional shareholder uses and responsible economic development of 

resources. Throughout much of the twentieth century, mining provided an economic basis for 

shareholders. Placer gold mining supported several settlements, including Iditarod, Marshall, and Nyac. 

Currently, placer gold production continues on a small scale and is an important source of revenue for 

shareholders. Illustrative of regional corporation objectives to support responsible development is 

NANA’s historic involvement with the Red Dog mine (north of the planning area). 

Exploration and baseline studies for the Donlin Gold Project, located in the Calista Region near Crooked 

Creek, have been ongoing since 1995. This mineral resource site is located on surface land owned by the 

Kuskokwim Corporation (TKC), and Calista Corporation owns the subsurface land. Donlin Gold LLC, a 

limited liability company jointly owned by Barrick Gold U.S. Inc. and NovaGold Resources Alaska, Inc., 

received key permits on August 13, 2018, for development of the Donlin Gold Project, an open pit 

hardrock mine near the village of Crooked Creek, including ROW permit approval from BLM. More 

information is included below under “Future Land Uses” (NovaGold 2018). 

Military Lands 

Military lands constitute less than 0.1 percent of the planning area. If military lands are released and 

returned to BLM management during the life of the plan, direction contained in this RMP/EIS would 

apply. Generally, military use of lands in the planning area was during the Cold War era following World 

War II was tied to the communication, navigation, and radar needs of the time. Most military installations 

have been decommissioned, and little present use exists. 

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Appendix N: Supplemental Impact Analysis Information Section 2. Cumulative Impacts 

Past and Present Activities 

Oil, Gas, Coal, and Geothermal Leasing and Exploration 

The most current report analyzing leasable mineral resource potential within the planning area for this 

RMP is the Mineral Occurrence and Development Potential Report – Leasable Minerals Bering SeaWestern Interior Resource Management Plan (BLM 2015a). Fluid mineral occurrence and development 

potential in the planning area is primarily associated with coal and coal bed natural gas, oil and gas, peat, 

and geothermal resources. The following is a summary of findings from this report on past and present 

activities. 

Coal 

The areas that contain coal within the planning area have been divided into one field and five districts: 

Farewell (Little Tonzona) Coal Field and the Windy Fork, Middle Fork, Cheeneetnuk, Big River, and 

Nelson Island Districts (BSWI Draft RMP/EIS, Map 3.3.4-1). The majority of the coal in the planning 

area is tertiary-aged and subbituminous. Known coal mineral resources are limited to a few thin coal beds 

on Nelson and Nunivak Islands, but these are considered noncommercial. Modest amounts of coal from 

Windy Fork have been used by trappers, prospectors, and big game hunters for local home heating 

applications. Coal was also noted to have been mined at Flat and used for home heating until the 1930s. 

Some limited coal exploration of the Little Tonzona River coal deposits occurred in the 1980s for Doyon, 

Ltd. However, this field has no substantial past production. 

Oil and Gas 

Oil and gas basins in the planning area include Bethel, Galena, Holitna, Innoko, Minchumina, and Yukon 

Delta Basins. Historically, several geophysical surveys (e.g., airborne magnetic surveys, gravity surveys, 

and reflection seismic surveys) have been conducted in the region, and one exploratory well was drilled in 

the Bethel Basin (Napatuk Creek No. 1) in the early 1960s, which was abandoned as a dry hole. No 

additional exploratory wells have been drilled in the area, and no recent federal oil and gas leasing has 

taken place. 

Pending Oil and Gas Leases 

Fifty-nine pending oil and gas Pre-Reform Act lease offers within the planning area were filed in the late 

1960s, all within the boundary of the Yukon Delta NWR. These pending lease offers were subsequently 

suspended by Public Land Orders (PLOs) and remain unavailable for oil and gas leasing. 

Geothermal 

Two geothermal springs are documented within the planning area: Ophir Hot Springs and Chuilnuk Hot 

Springs. The only spring that is currently being used as a source of energy is the hot spring occurrence 

near Ophir Creek. 

Mineral Exploration and Mining 

The most current report analyzing locatable and salable mineral resource potential within the planning 

area for this RMP is the Mineral Occurrence and Development Potential Report – Locatable and Salable 

Minerals Bering Sea-Western Interior Resource Management Plan (Kurtak et al. 2017). The following is a 

summary of findings from this report on past and present activities specific to this resource. Distribution 

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Section 2. Cumulative Impacts Appendix N: Supplemental Impact Analysis Information 

of mineral occurrences within the planning area is illustrated in BSWI Draft RMP/EIS, Map 3.3.3-1, and 

is generally concentrated in upland portions of the planning area and lowlands in the immediate vicinity 

of these uplands where placer deposits occur. 

The planning area has a long and colorful mining history, dating back to the late 1830s when Russian 

traders discovered mercury-bearing minerals along the Kuskokwim River near Aniak. Gold was 

discovered in the Flat area in 1908, driving one of the last great gold rushes in Alaska. Documented 

mineral production within the planning area totals 3.2 million ounces of gold, 151,750 ounces of silver, 

2.1 million pounds of copper, and 41,767 flasks of mercury. The Iditarod Mining District, which includes 

the Flat area, ranks third in placer gold production in Alaska (Kurtak et al. 2017). 

The planning area contains 453 documented mineral occurrences (BSWI Draft RMP/EIS, Map 3.3.3-1) 

and 2,480 mining claims, with 207 of those under federal management. Mineral occurrences include 

placer gold, gold-bearing quartz veins, copper-gold skarns, and silica-carbonate mercury deposits. In 

2015, there were 19 active placer mines and one active lode mine. Currently, less than 1 percent of the 

total acres taken up by mining claims and prospecting sites in the planning area are under federal 

management. The majority of the mining and mineral exploration is taking place on State of Alaska, 

Native corporation, or private lands (Kurtak et al. 2017). 

Twelve separate companies or individuals (11 open pit placers and one hard rock mine) were estimated to 

be producing metals (predominantly gold) in the planning area in 2014. Additionally, the Donlin Gold 

Project near Crooked Creek is an advanced stage exploration project (Kurtak et al.2017). On August 13, 

2018, the US Army Corps of Engineers (Corps) and BLM issued a joint Federal Record of Decision 

(ROD), along with the Clean Water Act Section 404/Rivers and Harbors Act Section 10 permit and the 

Offer to Lease for the pipeline ROW at Donlin Gold. The project is currently seeking State permit 

approval for initial mine startup (NovaGold 2018). 

The primary mineral material commodities used within the planning area are crushed rock and sand and 

gravel. Thirteen material sites were reported to be active in 2008 in Southwest Alaska, which includes the 

planning area. Sand and gravel are used in construction and road maintenance. Currently, the BLM does 

not have any requests to develop sand and gravel on BLM-managed land in the planning area, as local 

demands are being met by sand and gravel producers located on private or State-owned lands. This status 

is unlikely to change in the near future due to lack of appropriate BLM-managed land in the vicinity of 

population centers that require sand and gravel (Kurtak et al. 2017). 

Forest Resources Use 

Forest resources within the planning area have historically provided materials for sheltering and heating. 

House logs and local sawmills have been used to construct housing, lodges, and commercial buildings 

throughout the area. Firewood is a staple of the subsistence lifestyle for heating and, in some instances, 

cooking. BLM forests, although generally farther from communities than non-BLM lands, still may play a 

role in the long-term supply of wood—especially those BLM lands near rivers that can assist in wood 

transport. Most villages have portable sawmills to produce building materials or repair materials locally, 

and one full sawmill located in Chuathbaluk has produced building materials for use in the Kuskokwim 

Basin. There has been recent interest from some villages in the use of biomass for heating buildings or 

communities; these projects could eventually expand to include power generation. 

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Appendix N: Supplemental Impact Analysis Information Section 2. Cumulative Impacts 

Development of Infrastructure for Communities 

Sixty-five rural communities are found within the planning area. Based on 2010 data from the U.S. 

Census Bureau for these communities, the population of the planning area is approximately 25,000 (U.S. 

Census 2010). The largest population center is Bethel, located in the southwest portion of the planning 

area, with a population of 6,080 (U.S. Census 2010b). Very few roads pass through the planning area; the 

longest is a 43-mile gravel road that connects Sterling Landing on the Kuskokwim River with the historic 

mining community of Ophir on the Innoko River. A handful of short roads serving local communities, or 

remaining from past human activities, also exist. Almost all of these existing roads in the planning area 

are located on lands managed by entities other than the BLM. 

Military Activities 

Very little additional military use and activities are anticipated within the planning area. The limited 

amount of existing use will likely decline. 

Research, Monitoring, and Land Management 

Research, monitoring, and land management are frequent activities on non-BLM lands in the planning 

area. Specifically, fixed-wing aircraft and helicopters are used to transport personnel and equipment and 

to conduct surveys. Remote areas are also accessed by boats during the summer and snowmobile during 

winter to conduct research, monitoring, and other land management activities. 

Recreation and Subsistence 

Recreational and subsistence use is the most prevalent land use in the planning area. The undeveloped 

nature of the planning area, the existence of unique historical features such as the INHT, and the presence 

of surrounding NWRs provide opportunities for unique outdoor recreational opportunities, including 

guided hunting, fishing, eco-tourism, and organized events such as the Iditarod Sled Dog Race and the 

Iron Dog Snowmobile Race. Subsistence fishing and hunting are important for the economies and 

cultures of many families and communities in Alaska, especially for rural families who depend on 

subsistence hunting and fishing as sources of nutrition and cultural practices. Subsistence use occurs 

under both federal subsistence regulations and State general fishing, hunting, and subsistence regulations. 

The Alaska Department of Fish and Game (ADF&G) reports statewide harvest for 2014 as follows: 

0.9 percent—subsistence food harvested by Alaska residents (about 33.8 million pounds); 0.2 percent— 

personal use fishing and hunting under general regulations by Alaskans; 0.4 percent—sport fishing and 

hunting; 98.5 percent—commercial fisheries (ADF&G 2014). 

2.2.2 Reasonably Foreseeable Future Land Use and Actions 

The term “reasonably foreseeable future action” is used in concert with the CEQ definitions of indirect 

and cumulative effects, but the term itself is not further defined. Most regulations that refer to “reasonably 

foreseeable” do not define the meaning of the words but do provide guidance on the term. For this 

analysis, reasonably foreseeable future actions are those actions that are external to the proposed action 

and likely (or reasonably certain) to occur, although they may be subject to a degree of uncertainty, within 

the next 15 to 25 years. Typically, they are based on documents such as existing plans, permit 

applications, and fiscal appropriations. 

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Future Land Use 

BLM Lands 

Alternative land use scenarios for BLM-managed land in the planning area are described in Chapter 2 of 

the BSWI Draft RMP/EIS. Conveyance of lands to the State of Alaska and Native corporations is 

ongoing. On a statewide basis, about 98 percent of the Native conveyances and 95 percent of the State 

conveyances have been completed. 

Donlin Gold LLC, a limited liability company jointly owned by Barrick Gold U.S. Inc. and NovaGold 

Resources Alaska, Inc., received key permits on August 13, 2018, for development of the Donlin Gold 

Project, an open pit hardrock mine near the village of Crooked Creek., including ROW permit approval 

from BLM. The ROW Grant has a term of 30 years. Construction has not yet begun, and Donlin Gold 

LLC has 8 years from August 13, 2018, to complete construction. 

The Donlin Gold Mine Project includes development and operation of an open pit mine, mine facilities, 

and a port site, as well as ancillary facilities such as airstrips, access roads, material sites, and a 

connecting 14-inch-diameter, 316-mile-long natural gas pipeline. The pipeline would cross 97 miles of 

largely remote and undisturbed BLM-managed land. The total footprint for the temporary 150-foot 

construction ROW and ancillary facilities on BLM land is 2,329 acres. The total footprint for the 51-foot 

operations and maintenance ROW on BLM land is 601 acres. The proposed project would require 3 to 

4 years to construct, followed by an active mine life of approximately 27 years. After the end of the 

Operations Phase, the mine site facilities, port facilities, and the pipeline would be closed and reclaimed 

as required by permit conditions. The ROW Grant includes stipulations to reduce impacts to the 

environment. 

National Wildlife Refuges 

Conservation plans are in place for the refuges that guide management principles for a span of 15 years. 

The Yukon Delta plan was prepared in 2004 (USFWS 2008) and the revised Innoko plan was prepared in 

2008 (USFWS 2008). This analysis assumes that management of the Yukon Delta and Innoko NWRs 

would continue as it has during recent decades and as outlined in the current conservation plans (USFWS 

1988, 2008). Approximately 1.3 million acres (comprising 35 percent of the refuge) southeast of the 

Innoko River is designated Wilderness. Two wilderness areas (Andreafsky Wilderness and Nunivak 

Wilderness) are designated inside the Yukon Delta NWR, totaling approximately 1.9 million acres. 

Limited activities are allowed in designated wilderness areas. Wilderness characteristics would be 

preserved on the majority of the refuge lands that are not designated as wilderness. Development and 

exploration activities could occur on Native and privately owned lands within the refuge boundaries. 

While oil and gas development is not reasonably foreseeable on the refuge lands due to low potential, 

some exploration from Native corporation lands and private land owners within the refuge boundaries 

could occur. Decisions to allow exploration on refuge lands would be made on a case-by-case basis. 

These activities would require a Special Use Permit with site-specific stipulations to ensure compatibility 

with refuge purposes and consistency with comprehensive conservation plan management objectives. 

National Park Service Lands 

This analysis assumes that the current management direction for the Lake Clark National Park and 

Preserve would continue. As outlined in the General Management Plan amendment (NPS 2014) and Lake 

Clark National Park and Preserve Draft Land Protection Plan (NPS 2013), the NPS intends to manage the 

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Appendix N: Supplemental Impact Analysis Information Section 2. Cumulative Impacts 

park to maintain its natural and cultural resource values and maintain and enhance public understanding 

and enjoyment of these values. 

Park and preserve lands are no longer available for new mineral entry and location. Mining could occur 

on private lands, including Native corporation lands, within the park and preserve boundaries. 

Additionally, State mineral claims may currently be filed anywhere on State lands inside the unit (the 

submerged lands beneath the navigable lakes and rivers). As outlined in the Lake Clark National Park and 

Preserve Draft Land Protection Plan (NPS 2013), the NPS recommends that the State close the beds of 

navigable waters to new mineral entry, extraction of oil and gas, and sand and gravel resources, and will 

apply to the State for these closures. The NPS will also pursue cooperative agreements with the State for 

the management of lands under navigable waterbodies (shorelands). 

Mineral development and operation of the existing mining claims within the park boundary could 

continue. Development of these claims would need to comply with the Mining in the Parks Act. NPS 

(2013) identifies the Johnson River as the area of the park most likely to see future mining. 

State Lands 

State lands would continue under multiple use management, with uses prioritized to conserve valuable 

resources in some areas while allowing resource use in other areas. As much as possible, State lands are 

managed so that uses are compatible with land use on adjoining federal lands. Land use for recreation, 

subsistence, and tourism may increase as local, state, and national populations grow. 

One example of anticipated State of Alaska permitting in the planning area is for the proposed Donlin 

Gold Mine Project’s ancillary facilities that would be constructed on State lands, such as material sites 

and portions of the natural gas pipeline ROW. Project details are listed above in the section “BLM 

Lands.” Significant progress has been made to advance state permitting for the Donlin Gold Mine Project, 

including issuance of the State air quality and Alaska Pollutant Discharge Elimination System wastewater 

discharge permits (NovaGold 2018). The State of Alaska would benefit financially from the project’s 

mining license and corporate income taxes. 

Native Lands 

Economic development of resources is a reasonably foreseeable use of Native-owned lands within the 

planning area. The Donlin Gold Project, described above in the section “BLM Lands,” also includes land 

leased from Calista Native Corporation, which holds the subsurface (mineral) estate for ANCSA lands in 

the project area. A surface use agreement with TKC, the village corporation that owns the surface land, 

grants surface use rights to lands that TKC holds at the mine site. The proposed project would provide an 

economic boost to the Yukon-Kuskokwim region while helping residents financially sustain a lifestyle 

with cultural traditions of fishing, hunting, and gathering. The Yukon-Kuskokwim region is one of the 

most economically depressed regions in Alaska and the U.S. as a whole. Job and economic opportunities 

are limited. The proposed project would generate up to 3,000 jobs during construction and 800 to 1,400 

jobs during operation and give hiring preference to Calista and TKC shareholders, spouses, and 

descendants. Production royalties would be paid to Calista Corporation with distribution to other ANCSA 

corporations, and TKC would construct and operate the upriver port (Jungjuk). Additionally, the project 

proponent has performed numerous community investments and corporate giving in the region to date and 

are planned to continue into the future. 

2-9 
 

 

 

 

 

 

 

 

 

Section 2. Cumulative Impacts Appendix N: Supplemental Impact Analysis Information 

Future Activities 

Oil and Gas, Coal, and Geothermal Leasing and Exploration 

The development potential for leasable mineral resources, such as coal, coal bed natural gas, oil and gas, 

geothermal, peat, and coalbed natural gas, in the planning area is low (BLM 2015a). The expense of 

developing some of these resources and the lack of roads or railroads connecting the planning area to the 

rest of the state would also likely preclude small and large-scale development in the foreseeable future. 

Prospective oil and gas basins in the region of the planning area include the Holitna, Bethel, and 

Minchumina Basins, along with the Yukon Delta. There are 59 pending oil and gas Pre-Reform Act lease 

offers within the planning area, all within the boundary of the Yukon Delta NWR and, therefore, have 

been suspended due to their being within the refuge. No additional oil and gas lease offers may be filed 

until the land selection process that the State and various Alaska Native entities are undertaking is 

complete. The BLM will continue its adjudicative role on prior existing rights under the mining laws and 

process dispositions under the mineral leasing laws or material sales. Some areas of known coal (leasable) 

mineral potential exist, but there has been little interest in developing it to date. 

Mineral Exploration and Mining 

A total of 101 areas within the planning area are considered to have high locatable mineral potential 

(LMP), including a number of areas that fall within BLM-managed land and are covered by federal 

mining claims. These include the Nixon Fork Mine area, Flat-Chicken Mountain area, Ophir Creek 

drainage (Kilbuck Mountains), and the Nyac (Shamrock Creek) area. Additional areas of interest include 

the high LMP areas on State-selected lands near the Little Creek (west of Donlin), Oskawalik, Julian 

Creek, and the Granite-Willow Creek areas. Future mineral exploration and mining activities have the 

potential to occur in these areas and could have impacts on BLM-managed land extending outside the 

mining claim boundaries (Kurtak et al. 2017). See discussion of the Donlin Gold Project above in the 

section “BLM Lands.” Table 2.2.2-1 details the high LMP areas in the planning area as identified in 

Kurtak et al. (2017). 

Table 2.2.2-1: High Locatable Mineral Potential in the Planning Area 

District Name Production Status Deposit Type Land Status 

Aniak 

Canyon Creek Past producer Placer Au-PGE State 

Cripple Creek Producer Placer Au-PGE State 

Eureka Creek Past producer Past producer Past producer 

Gemuk Mtn No production Au-polymetallic State 

Kisa No production Felsic-dike-hosted qtz 

veinlets State 

Marvel Creek Producer Placer Au-PGE State 

Nyac Placer Producer Placer Au-PGE Calista Corp./ BLM 

Nyac Lode No production Plutonic-hosted cu-au 

polymetallic Calista Corp. 

Ophir Creek No production Placer Au-PGE BLM 

Russian Mtns No production Polymetallic veins Calista Corp. 

Georgetown 

Donlin Creek (Ruby 

Gulch) 

Producer Placer Au-PGE Calista Corp. 

Donlin Creek (Lewis Producer Placer Au-PGE Calista Corp. 

2-10 
 

Appendix N: Supplemental Impact Analysis Information Section 2. Cumulative Impacts 

District Name Production Status Deposit Type Land Status 

Gulch) 

Donlin Creek Lode No production Felsic-dike-hosted qtz 

veinlets 

Calista Corp. 

Fortyseven Creek Past producer Placer Au-PGE State 

Granite-Willow Creeks Producer Placer Au-PGE State 

Julian Creek Producer Placer Au-PGE State 

Mountain Top Past producer Silica-carbonate Hg State 

Oskawalik River No production Polymetallic replacement 

deposits and veins 

State 

Red Devil Past producer Silica-carbonate Hg BLM 

Murry Gulch Past producer Placer Au-PGE State 

Taylor Creek Past producer Placer Au-PGE State 

Iditarod 

Chicken Mtn-Flat No production Plutonic-hosted Cu-Au 

polymetallic 

Doyon Ltd 

Decourcy Mtn Past producer Silica-carbonate Hg Calista Corp. 

Flat Creek Past producer Placer Au-PGE BLM 

Golden Horn Mine Past producer Plutonic-hosted Cu-Au 

polymetallic 

State 

Little Creek No production Placer Au-PGE State 

Otter Creek Past producer Placer Au-PGE BLM 

Prince Creek Past producer Placer Au-PGE BLM 

Willow Creek Past producer Placer-Au-PGE BLM 

Little Creek Producer Placer Au-PGE Patented 

Innoko 

Beaver Mtns (Cirque) No production Polymetallic vein State 

Boob Creek-Mt Hurst Past producer Placer Au-PGE State 

Colorado Creek Past producer Placer Au-PGE State 

Cripple Creek Past producer Placer Au-PGE State 

Ester Creek Past producer Placer Au-PGE State 

Esperanto Creek Past producer Placer Au-PGE State 

Ganes Creek (Lower) Past producer Placer Au-PGE Patented 

Ganes Creek (Upper) Producer Placer Au-PGE Patented/State 

Innoko River (Lower) Past producer Placer Au-PGE State 

Montana Creek Producer Placer Au-PGE State 

Moore Creek Producer Placer Au-PGE State 

Yankee Creek (Lower) Past producer Placer Au-PGE Doyon Ltd. 

Yankee Creek (Upper) Producer Placer Au-PGE Patented/ Doyon Ltd./ 

State 

Win No production Sn-polymetallic veins State 

Marshall 

Buster Creek Past producer Placer Au-PGE Patented 

Stuyahok - Flat Creek No production Felsic-dike-hosted qtz 

veinlets 

Calista Corp. 

Willow Creek Past producer Placer Au-PGE Calista 

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Section 2. Cumulative Impacts Appendix N: Supplemental Impact Analysis Information 

District Name Production Status Deposit Type Land Status 

McGrath 

Bowser No production Zn-Pb skarn deposits State 

Broken Shovel No production Plutonic-hosted Cu-Au 

polymetallic 

State 

Candle Creek Producer Placer Au-PGE State/ Doyon Ltd. 

Eagle Creek Past producer Placer Au-PGE State 

Nixon Fork Mine Producer Cu skarn deposits BLM/ 

Doyon Ltd. 

Roberts Pgm No production Noril'sk Cu-Ni-PGE State 

Sheep Creek No production Polymetallic replacement 

deposits and veins 

Doyon Ltd. 

Terra Producer Low-sulfide Au-quartz 

veins 

State 

Tin Creek No production Zn-Pb skarn deposits Doyon Ltd. 

Vinasale No production Plutonic-hosted Cu-Au 

polymetallic 

Doyon Ltd. 

Tonzona Reef Ridge No production Southeast Missouri Pb-Zn Doyon Ltd. 

Source: Kurtak et al. (2017) 

Notes: 

AU = gold 

BLM = Bureau of Land Management 

Cu = copper 

Hg = mercury 

Ni = nickel 

Pb = lead 

PGE = platinum group element 

qtz = quartz 

Sn = tin 

Zn = zinc 

Sand and Gravel 

Future demand for additional sand and gravel will be driven by development in the planning area, such as 

the proposed Donlin Gold Project pipeline that would cross 97 miles of BLM lands. 

Peat 

It is possible that villages and individuals in the planning area could develop peat as a resource for smallscale energy and heat generation. Development of this type is unlikely on BLM-managed land due to the 

low potential for fuel grade peat to occur in accessible areas of the planning area. A study performed in 

2007 by Barrick Gold United States Inc. assessing peat deposits in two study areas within the planning 

area found the peat in both study areas to existing in permafrost (BLM 2015a). Additionally, most 

villages in the planning area have enough land to harvest peat on their own or from adjacent State lands 

with fewer restrictions and less required infrastructure due to proximity. Additional discussion of peat 

resources can be found in BSWI Draft RMP/EIS, Appendix M. 

Infrastructure and Communities 

Potential transportation corridors are under review by the State of Alaska and include two road and ROW 

corridors, the Western Alaska Access Planning Study (“Road to Nome” Fairbanks–Nome route) and the 

Yukon-Kuskokwim Energy Corridor Plan (with a terminus at Paimiute Slough on the Yukon River and 

near the Kalskags on the Kuskokwim River), both of which propose to cross BLM-managed land within 

the planning area. The Western Alaska Access Planning Study has evaluated three routes, including the 

preferred Yukon River Corridor, to connect the Nome-Council Road to the existing road system in the 

Fairbanks area. The proposed final stage of the Yukon River Corridor is between the villages of Koyuk 

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Appendix N: Supplemental Impact Analysis Information Section 2. Cumulative Impacts 

and Nulato and would cross BLM-managed land in the Nulato Hills region of the planning area. The 

Yukon-Kuskokwim Energy Corridor Plan evaluated overland transport routes in the Portage Mountains 

area to connect the Yukon and Kuskokwim Rivers for fuel and freight transport purposes. The studied 

routes would cross BLM-managed land from Paimute Slough on the Yukon River to the northeast of the 

Upper and Lower Kalskag as well as other Kuskokwim River communities. 

Projects that have been studied but not considered as a reasonably foreseeable future action for the time 

frame of the impact analysis include the following: 

• Yukon-Kuskokwim Transportation Corridor – This project was proposed by the Association of 

Village Council Presidents (funded through a State of Alaska general fund appropriation) and is 

in the planning phase focusing on completion of subsistence and cultural resource studies, public 

outreach, identifying potential barge improvement projects, and beginning the corridor 

preservation process. The project is estimated to be practical to construct between 2028 and 2038 

(Association of Village Council Presidents 2018a, 2018b). 

• Road to Nome – A proposed highway from the Interior to Western Alaska was studied by the 

Alaska Department of Transportation in the past (study completed in 2011) but has not advanced 

beyond conceptual design. One route studied would connect the Elliott Highway near Manley Hot 

Springs to the end of the Nome-Council Highway. No definite sources of funding for the project 

have been identified, and it is not currently identified in an Alaska Statewide Long Range 

Transportation Plan. 

State Lands 

Activities on State lands and for State-managed resources will continue and increase in proportion to 

population growth and tourism. The mission of the ADF&G is to protect, maintain, and improve the fish, 

game, and aquatic resources of the state and manage their use and development in the best interest of the 

economy and the well-being of the people of the state, consistent with the sustained yield principle 

(ADF&G 2018). Education, nongame management and research, and wildlife viewing opportunities are 

expected to increase. Future actions will address human-wildlife conflicts, subsistence management, and 

predator management. 

Research, Monitoring, and Land Management 

Research, monitoring, and land management will continue on federal, State, and Native lands. Remote 

areas will continue to be accessed by fixed-wing aircraft, helicopters, boats, and snowmobiles, depending 

on season. 

Subsistence and Recreation 

Past recreation, sport hunting and fishing activities, and traditional subsistence practices are expected to 

continue. Past uses of the INHT are also expected to continue. Recent funding has supported trail 

improvements such as shelter cabins. Land use for recreation, subsistence, and tourism may increase as 

local, state, and national populations grow. However, due to the undeveloped nature and limited access to 

BLM lands in the planning area, recreation, subsistence, and tourism on BLM lands is expected to be 

stable with no more than a 5 to 10 percent increase over the next 15 to 25 years. 

Climate Change 

The following climate warming scenarios are likely in the planning area, based on the Rapid Ecoregional 

Assessment and the National Climate Assessment and are considered in the cumulative effects analysis: 

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Section 2. Cumulative Impacts Appendix N: Supplemental Impact Analysis Information 

• Increased temperatures 

• Permafrost thaw (The only areas in the planning area expected to retain permafrost to a depth of 

one meter [which is the most influential on vegetation and surface conditions] in the future, aside 

from isolated pockets, are in the Nulato Hills region.) 

• Decreased snow cover (albedo effect), subnivean species impacts 

• Increased wildland fire intensity, size, and frequency 

• Increase in NNIS presence/spread 

• Later freeze-up dates (river ice) 

• Sea level rise (salt intrusion, transportation changes) 

There is less agreement from researchers on the following two climate warming scenarios. There is 

empirical evidence of these already occurring, although the magnitude and rate are expected to increase in 

the future. 

• Shrub encroachment 

• Spruce trees replaced with aspen/birch hardwood trees 

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Appendix N: Supplemental Impact Analysis Information Section 3. Supplemental Impact Analysis 

Section 3. Supplemental Impact Analysis 

3.1 Fisheries 

3.1.1 Summary 

Table 3.1.1-1 summarizes the management actions, indicators, and ranking of the alternatives as they 

pertain to fish and aquatic resources. Fish and aquatic resources would be primarily affected by surfacedisturbing activities such as placer mining, timber harvest, infrastructure development, or grazing, etc., 

which can alter stream channels, remove or damage riparian vegetation, or result in soil erosion and 

increased sedimentation to fish and aquatic habitat. The level of impact would depend on the success and 

adequacy of protective measures (i.e., BMPs). Numerous effects can be expected to occur at differing 

magnitudes, extents, and durations, and in different contexts. These effects would be evaluated in greater 

detail on a project-specific basis. Rankings for Climate Change, NNIS, and Wildland Fire are not 

included in the table because they ranked the same between alternatives. A detailed analysis of all 

management actions is provided in subsequent sections. The ranking of alternatives in Table 3.1.1-1 is 

also a relative comparison of the degree to which the alternatives are consistent with DOI’s National 

Priorities, particularly to create a conservation stewardship legacy and to sustainably develop our energy 

and natural resources (DOI 2018). 

Table 3.1.1-1: Ranking Summary of Alternatives by Management Action and Indicator 

Management Action Indicator 

Alternative Ranking

(Most to Least Protective) 

Water Resources and Fisheries Stream miles / acres available B, C, D, A 

Forestry and Woodland Products Acres open, closed, or restricted for harvest B, A, C, D 

Grazing Acres open or closed to grazing B, C, A, D 

Minerals Management Acres and stream miles / acres open, closed, or NSO B, A, C, D 

Travel/Transportation Steam miles and waterbody acres restricted B, C, D, A 

ACECs Acres of designated ACECs B, A, C, D 

Summary B, A, C, D 

3.1.2 Methods of Analysis 

Potential impacts on aquatic resources, fish, and special status fish from each alternative are based on 

interdisciplinary team knowledge of the resources and the planning area and information gathered from 

the public during the planning process. Assessment of potential fish and aquatic resource impacts are 

discussed at the landscape level within the planning area. The exact values (miles of streams/acres of 

waterbodies) associated with each action cannot be determined quantitatively and would be addressed on 

a case-by-case basis in future projects and actions. River and stream (miles), and waterbody (i.e., 

lakes/ponds; acres) metrics identified in the following analyses are based on data provided from the 

National Hydrography Data (NHD) set (https://nhd.usgs.gov/NHD_High_Resolution.html). This data set 

is divided into watersheds for the planning area (Figures 3.1.2-1 through 3.1.2-3) based on the Hydrologic 

Unit Code (HUC 4 or HUC 6) data set and is generated containing one or more of the following features: 

watersheds, rivers, streams, lakes, and ponds. 

3-1 
Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

Figure 3.1.2-1: Watershed Boundaries and Hydrography 

3-2 
Appendix N: Supplemental Impact Analysis Information Section 3. Supplemental Impact Analysis 

Figure 3.1.2-2: Anadromous Waters and Spawning Habitat 

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Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

Figure 3.1.2-3: Streams within Medium and High Areas of Mineral Potential (HUC 6) 

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Appendix N: Supplemental Impact Analysis Information Section 3. Supplemental Impact Analysis 

Figure 3.1.2-1 shows HUC 4/Level 2 watersheds within the planning area, rivers and streams on BLMmanaged lands (32,931 miles), and waterbodies (lakes and ponds) on BLM-managed lands (53,796 

acres). The figure also shows BLM-managed lands. Four watersheds intersect the planning area: 

Northwest Alaska, which includes Unalakleet and the very northwest portion of the planning area; Lower 

Yukon River, which includes most of the north half of the Yukon Delta NWR and the Innoko NWR; 

Southwest Alaska, which includes a large portion of the southern and eastern planning area, including 

Bethel, Aniak, and McGrath; and Middle Yukon River, which includes a very small piece of the planning 

area in the northeast at Lake Minchumina. Rivers labeled on the map include the Kateel River, North 

River, Unalakleet River, Yukon River, Innoko River, Anvik River, Kuskokwim River, and Swift River. 

No waterbodies are apparent on the figure. 

Figure 3.1.2-2 depicts the anadromous waters and spawning streams and waterbodies on BLM-managed 

lands. The figure also shows the watersheds and BLM-managed lands. Anadromous spawning streams are 

concentrated in the northwest portion of the planning area and in the area between the Lower Yukon and 

Innoko NWRs west of the Yukon River, and are scattered elsewhere on BLM-managed lands. 

Anadromous streams are more prevalent throughout BLM-managed lands. No anadromous waterbodies 

or anadromous spawning waterbodies are apparent on the map. 

There are approximately 170,358 miles of streams and rivers and 3.92 million acres of lakes and ponds 

within the planning area, and 17,962 miles of streams and 414,967 acres of lakes and ponds have been 

cataloged as important for the spawning, rearing, and migration of anadromous fish (Johnson and 

Litchfield 2016 a–c). Approximately 24 percent (33,932 miles) of all streams and 1 percent (53,798 acres) 

of pond/lake habitats in the planning area occur on BLM-managed public lands. Calculations of potential 

impacts to streams and waterbodies presented in this section are based on the streams and waterbodies 

(33,932 miles and 53,798 acres, respectively) located on BLM-managed public lands. 

Stream miles and waterbody acres are either summarized in categories by HUC 4 or HUC 6 watershed or 

as Anadromous Waters or they are summarized in total without category breaks in the BLM-managed 

lands within the planning area. Information presented in the tables associated with each resource 

management action section should be viewed as planning-level data. Stream mile and waterbody acreage 

totals are limited in precision by the resolution of the source data; however, the data allow for the relative 

comparison of impacts across alternatives. Categories may have overlapping streams and waterbodies as 

they may be subsets of another data set; therefore, the sums of these categories may not accurately reflect 

the sums of the total stream miles and waterbody acres. 

Depending on the resource being analyzed, the rivers, streams, lakes, and ponds are either summarized 

across the entire planning area or divided into four regions on BLM-managed lands (Figure 3.1.2-1) based 

on the HUC 4 watershed data set. For HUC 4, the regions/watersheds are as follows: 

• Northwest Alaska – North and Unalakleet Rivers and waterbodies are present within this region. 

• Lower Yukon River – Yukon, Innoko, and Anvik Rivers and waterbodies are present within this 

region. 

• Middle Yukon River – Portions of the Kuskokwim River and waterbodies are present within this 

region. 

• Southwest Alaska – Kuskokwim and Swift Rivers and waterbodies are present within this region. 

For identifying areas of high and medium mineral potential, HUC 6 regions/watersheds were reviewed. 

HUC 6 regions follow the same boundaries as HUC 4 but are further broken down into additional 

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Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

watersheds; these data are shown on Figure 3.1.2-3. Figure 3.1.2-3 shows areas of medium and high 

LMP, as well as HUC 6/Level 3 and HUC 4/Level 2 watershed boundaries. The figure also shows BLMmanaged lands. Nearly all areas of medium and high mineral potential are the eastern half of the planning 

area and most are in the Southwest Alaska watershed, with concentrations in higher elevation areas 

associated with the Alaska Range and the Kuskokwim and Ahklun Mountains. 

Potential Effects and Indicators 

The major activities that could affect fish habitat and aquatic productivity within the planning area are 

those activities with potential to cause surface disturbances near streams or waterbodies or occur within 

areas of influence for these streams or waterbodies. Activities with the highest potential to affect fish 

production include placer mining, hard rock mining, and gravel mining within or near important fish 

habitats; timber harvests near important fish habitats; and stream crossings by roads, trails, and utility 

corridors in or near important fish habitats. Stream crossings with potential to impact fish production 

include culverts and bridges, ice bridges, fords used by heavy- and light-duty equipment (such as OHVs), 

and trench-buried utility crossings. Activities and stream crossings that occur within particularly sensitive 

habitats, such as spawning and overwintering habitats, or those that could preclude or inhibit fish access 

to those habitats, have the highest potential to impact fish productivity. 

The level of impact would depend on the magnitude and extent of the disturbance, as well as the success 

and adequacy of compliance to the mining regulations and reclamation compliance. Notwithstanding the 

alternatives and management actions considered, numerous effects can be expected to occur on multiple 

variables and at differing magnitudes and extents. These effects are summarized in Table 3.1.2-1 and not 

repeated in subsequent management action sections. The effects are based on impact indicators identified 

below (stream miles and waterbody acres affected) and characterized based on the management actions 

associated with each alternative. Specific proposals for development and surface-disturbing activities 

would be evaluated in greater detail on a project-specific basis. 

The potential for and level of impact on fish and aquatic resources is influenced by numerous factors, 

including management decisions allowing for surface-disturbing activities, combined with the success and 

adequacy of protective measures, such as maintaining riparian vegetation in proper functioning condition 

and the application of mineral withdrawals, BMPs, and reclamation procedures. 

Table 3.1.2-1: Summary of Effects to Fisheries Resource by Management Action 

Types of Effects Management Actions Indicators 

Development and associated surface disturbance 

within the 100-year floodplain could potentially 

increase sediment loading in streams, alter stream 

processes, and degrade fish habitat. 

• Water Resources and Fisheries 

Decisions 

• Lands and Realty Decisions, 

including ROW avoidance and 

exclusion 

• Stream miles ROW open, 

avoidance, or exclusion areas 

• Waterbodies acreage within ROW 

open, avoidance, or exclusion 

areas 

Timber harvest and associated surface 

disturbance could potentially increase sediment 

loading in streams, alter stream processes, and 

degrade fish habitat. 

• Forest and Woodland Harvest 

Decisions 

• Stream miles within commercial 

woodlands closed, permittable, and 

permitted for harvesting 

• Waterbodies acreage within 

commercial woodlands closed, 

permittable, and permitted for 

harvesting 

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Appendix N: Supplemental Impact Analysis Information Section 3. Supplemental Impact Analysis 

Types of Effects Management Actions Indicators 

Changes to stream processes and water quality 

from grazing activities could eliminate riparian 

habitats, altering watershed vegetation 

characteristics, and increasing nitrogen inputs to 

the aquatic environment. 

• Livestock Grazing Decisions • Stream miles within areas open 

and closed to grazing 

• Waterbodies acreage within areas 

open and closed to grazing 

Mining within streams and within watersheds could 

alter stream processes and fish habitat directly by 

affecting riparian function such as removal of 

pools, overwintering areas, destroying spawning 

beds, and impacting short- and long-term water 

quality. 

• Minerals Decisions • Acres open to locatable, salable, 

and leasable minerals 

Stream crossings at ROW intersections for roads, • Lands and Realty Decisions, • Linear miles of potential 

trails, and/or utility corridors could increase including ROW avoidance and stream/acres of potential pond/lake 

sedimentation, affect fish passage, and alter fish exclusion habitat potentially affected 

habitat directly or indirectly by affecting riparian 

function, and/or access to fish habitat. • Recreation and Visitor Services 

Decisions 

• Linear miles of documented 

anadromous stream/acres of 

Concentrated recreational use could increase 

nutrient inputs to streams and can alter aquatic 

productivity either beneficially or adversely. 

• Transportation and Travel 

Management Decisions 

documented anadromous 

pond/lake habitat potentially 

affected, including all documented 

Summer stream crossings with ATVs and UTVs anadromous fish spawning habitats 

could create localized degradation of fish habitat potentially affected 

and affect fish passage. 

Winter stream crossings with UTVs can affect 

sensitive fish overwintering habitat (including eggs 

of summer/fall spawning species). 

Designation of ACECs would indirectly reduce 

potential effects on fisheries by reducing potential 

development and associated stream alteration by 

increasing protective management prescriptions 

for such areas. 

• Designation of ACECs • Acres of designated ACECs 

Assumptions 

The following assumptions were used to assess effects associated with fisheries: 

• Development associated with mining, timber harvest, and development activities that trigger 

stream crossings and water withdrawal, would occur in areas suitable for resource extraction 

and/or development, as allowed by the RMP for a given watershed/drainage. 

• Specific measures of change (e.g., total dissolved solids, stream hydrogeomorphics, fish 

population estimates, etc.) were not sufficient to adequately use as landscape-level indicators for 

this evaluation. 

• Assessment, Inventory, and Monitoring (AIM) metrics will be addressed qualitatively as the 

means to ensure consistency with the alternatives in the analysis; however, for analysis purposes, 

detailed metrics were unavailable. 

• Healthy riparian areas are essential for properly functioning aquatic ecosystems. Improvements or 

protection of riparian habitats would directly/indirectly improve or protect aquatic habitats and 

fisheries. Adverse impacts to riparian habitats would directly and indirectly degrade aquatic 

habitats and fisheries. 

• Emphasis on and management opportunities for maintenance or improvement of fish habitat 

conditions would occur in designated ACECs and high-value watersheds (HVWs). 

• Not all anadromous streams or extent of anadromy has been documented within the planning 

area. 

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Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

• The lifting of 17(d)(1) mineral withdrawals in areas with high mineral potential could result in an 

increased number of placer mining operations with the potential to adversely affect fish and 

aquatic resources. 

The effects analysis for fisheries is limited due to incomplete or unavailable information, but is based 

primarily on evaluation of the following: 

• Analysis by BLM using ADF&G Anadromous Waters Catalog and Freshwater Fish Inventory 

(AFFI) data. 

• Agency (e.g., BLM, USFWS) reports on fish studies in the area. Studies identifying spawning 

and overwintering habitats for anadromous and resident fish species classified by BLM as 

sensitive. 

• GIS databases showing fish distributions in the planning area–GIS map overlaying withdrawal 

management decisions on HVWs by alternative, ACECs by alternative, and Anadromous 

Waters Catalog overlay. 

Standard Operating Procedures and Best Management Practices 

The impact analyses below consider SOP and BMP that could be implemented by the BLM. A 

comprehensive list of SOPs/BMPs pertaining to fisheries is provided in the BSWI RMP/EIS. 

3.1.3 Effects Analysis 

Proposed management of the following resources, resource uses, and programs will not be analyzed 

further at the present time, given their limited potential to impact fish and aquatic habitats, but may need 

to be analyzed further during specific project development: 

• Air Quality and AQRVs 

• Soils 

• NNIS 

• Wildland Fire 

• Cultural Resources 

• Paleontological Resources 

• Visual Resources 

• Lands with Wilderness Characteristics 

• Recreation and Visitor Services 

• National Trails 

• WSRs 

• Support for BSWI Communities 

• Subsistence 

• Hazardous Materials and Health and Human Safety 

The following types of effects are common to all action alternatives, though the potential amount and 

distribution of such effects may vary by alternative. 

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Appendix N: Supplemental Impact Analysis Information Section 3. Supplemental Impact Analysis 

• The direct effects from allowing any type of specific development would vary depending upon 

the amount and extent of area open, the activity allowed, and the level/application of BMPs 

implemented. The duration of these effects would also vary and would be assessed on a case-bycase basis for each specific project. 

• BMPs that protect streams and associated habitats would mitigate adverse impacts and could 

provide beneficial effects and would include avoidance of known spawning/rearing habitat and 

timeframes for fish migrations and spawning/rearing within the region. 

• Direct effects from any development or surface-disturbing activities that have the potential to 

occur include, but are not limited to, the following: 

o Permanent/temporary loss of fish habitat 

o Increased sedimentation/turbidity 

o Reduction of fish habitat 

o Reduction of riparian habitat 

o Loss of and/or access to realized or potential fish migration/spawning/rearing habitat 

o Reduction in water quality/quantity 

o Reduction in water flow/availability 

o Increased/decreased water temperatures 

• Indirect effects could result from the direct effects and include the following: 

o Permanent/temporary loss of fish habitat 

o Restricted access to areas recognized as fish spawning habitats 

o Increased sedimentation/turbidity 

o Reduction in water quality/quantity 

o Reduction in water flow/availability 

o Increase/decrease in water temperature 

o Potential for all direct effects to have impacts in downstream reaches of the areas of any 

development. 

Fisheries: Effects from Water Resources and Fisheries Management Actions 

Potential impacts from the following management topics were considered: 

• Designated HVW 

• Proposed HVWs 

• Locatable Mining 

As described previously, the 100-year floodplain is the area inundated by the 100-year flood or the 1 

percent annual exceedance probability flood. It is the flood event that has a 1 percent chance of being 

equaled or exceeded in any single year. It is often mistakenly thought of as the flood that occurs every 

100 years. In actuality, if one has a project located within the 100-year floodplain and the project life is 

expected to be 30 years, it would have a 25 percent chance of experiencing flood damage due to a 100-

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Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

year flood. For a project with an anticipated life of 15 years, the chance of incurring flood damage due to 

a 100-year flood would be 14 percent. 

The 100-year floodplain is difficult to accurately map without extensive ground surveys. On-the-ground 

surveys conducted within the planning area typically employ the Freeboard Approach, which is based on 

the current 1 percent annual chance flood elevation with the addition of freeboard to account for 

uncertainties in future conditions (see: Guidelines of Implementing EO 11988, Floodplain management; 

October 2015) to determine the horizontal floodplain. With this approach, the BLM uses three times 

maximum bankfull depth as an estimate of the 100-year floodplain. 

Given the difficulty of remotely mapping the 100-year floodplain and the desire to convey the intent of 

the various management alternatives to the reader, riparian buffer distances are used in the RMP as 

proxies for the 100-year floodplain. Buffer distances are given as a distance from bankfull elevation and 

are dependent on stream order. Buffer distances apply to each side of the stream, as follows: 

Stream Order Buffer Distance (feet) Acres 

1st and 2nd 100 593,569 

3rd 500 407,038 

4th and 5th 1,000 761,680 

6th, 7th, and 8th 1,500 110,147 

Because HVW decisions define where ROW avoidance areas would be established, information regarding 

ROW management by alternative is presented in this section. Table 3.1.3-1 presents the lengths and areas 

of streams and areas of waterbodies affected by ROW management status and stream classification for 

Alternatives B, C, and D for each region. Table 3.1.3-2 presents summary information for all regions 

combined. 

Effects under Alternative A 

Development in the 100-year Floodplain 

• The numbers of acres/miles of streams that lie within the 100-year floodplain vary by drainage. 

Under this alternative, there are no specific restrictions preventing development of these 

acres/streams at this time. The BLM must consider protecting the floodplains on a case-by-case 

basis. 

• Development of these areas can alter stream processes and affect water quality and quantity, 

potentially degrading or modifying fish habitat at the area of development within the region. 

o Direct impacts could be short or long term and have the potential to include increased 

turbidity and sedimentation, reduced flow, increased water temperatures, and reduction in 

access by migrating fish to spawning/rearing habitat. Stream reaches within these areas could 

recover over time. 

o Direct impacts could be lessened through BMPs, which could alter times of development to 

avoid times of migration, spawning, and rearing of fish species. 

o Indirect impacts could be similar to direct impacts, could be short or long term, but would 

occur further downstream from the development or surface disturbance. 

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Appendix N: Supplemental Impact Analysis Information Section 3. Supplemental Impact Analysis 

Table 3.1.3-1: River Miles/Waterbody Acreage by ROW Management Status and Stream Classification: Alternatives B, C, and D 

Open to ROW ROW Avoidance 

Row 

Avoidance for 

Linear Realty

Actions ROW Exclusion 

ROW Permitted on a Caseby-Case Basis 

Alt. B Alt. C Alt. D Alt. B Alt. C Alt. D Alt. C Alt. B Alt. C Alt. D Alt. B Alt. C Alt. D 

Lower Yukon River Streams [miles] (% of stream miles on BLM-managed land) 

Anadromous 

Waters 

Spawning 

Streams 

4 (<1) 4 (<1) 29 (<1) 627 (2) 865 (3) 949 (3) 109 (<1) 347 (1) - - - - -

Anadromous 

Waters 

Streams 

29 (<1) 187 (<1) 369 (1) 1,307 (4) 1,522 (5) 1,581 (5) 242 (1) 615 (2) - - - - -

NHD Streams 3,161 (10) 5,229 

(16) 8,340 (25) 9,833 (30) 8,958 (27) 7,367 (22) 1,526 (10) 2,720 (8) - - - - 7 (<1) 

Middle Yukon River Streams [miles] (% of stream miles on BLM-managed land) 

Anadromous 

Waters 

Streams 

- 3 (<1) 3 (<1) 3 (<1) - - - - - - - - -

NHD Streams 3 (<1) 29 (<1) 29 (<1) 26 (<1) - - - - - - - - -

Northwest Alaska Streams [miles] (% of stream miles on BLM-managed land) 

Anadromous 

Waters 

Spawning 

Streams 

- - - 96 (<1) 163 (<1) 163 (<1) - 67 (<1) - - - - -

Anadromous 

Waters 

Streams 

<1 (<1) 35 (<1) 72 (<1) 383 (1) 568 (2) 493 (2) - 219 (1) - - - - 37 (<1) 

NHD Streams 1,489 (5) 2,174 (7) 3,311 (10) 3,709 (11) 4,187 (13) 2,810 (9) - 1,164 (4) - - - - 240 (1) 

Southwest Alaska Streams [miles] (% of stream miles on BLM-managed land) 

Anadromous 

Waters 

Spawning 

Streams 

1 (<1) 2 (<1) 34 (<1) 242 (1) 356 (1) 323 (1) - 116 (<1) - - - - 1 (<1) 

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Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

Open to ROW ROW Avoidance 

Row 

Avoidance for 

Linear Realty

Actions ROW Exclusion 

ROW Permitted on a Caseby-Case Basis 

Alt. B Alt. C Alt. D Alt. B Alt. C Alt. D Alt. C Alt. B Alt. C Alt. D Alt. B Alt. C Alt. D 

Anadromous 

Waters 

Streams 

14 (<1) 315 (1) 648 (2) 1,160 (4) 1,126 (3) 792 (2) - 267 (1) - - - - 1 (<1) 

NHD Streams 1,802 (5) 4,553 

(14) 7,472 (23) 8,319 (25) 6,275 (19) 3,341 (10) - 706 (2) - - - - 15 (<1) 

Lower Yukon River Waterbodies [acres] (% of waterbody acres on BLM-managed land) 

Anadromous 

Water 

(Lakes/Ponds) 

<1 (<1) <1 (<1) <1 (<1) - - 34 (<1) 34 (<1) 34 (<1) - - - - -

NHD 

Waterbodies 6,293 (12) 14,431 (27) 

17,006 

(32) 12,973 (24) 7,056 (13) 9,975 (19) 5,494 (10) 7,716 (14) - - - - -

Middle Yukon River Waterbodies [acres] (% of waterbody acres on BLM-managed land) 

NHD 

Waterbodies - 57 (<1) 57 (<1) 57 (<1) - - - - - - - -

Northwest Alaska Waterbodies [acres] (% of waterbody acres on BLM-managed land) 

NHD 

Waterbodies 1,804 (3) 2,411 (5) 2,829 (5) 552 (1) 1,860 (3) 1,156 (2) - 1,913 (4) - - - - 286 (1) 

Southwest Alaska Waterbodies [acres] (% of waterbody acres on BLM-managed land) 

Anadromous 

Water 

(Lakes/Ponds) 

<1 (<1) <1 (<1) <1 (<1) - - - - - - - - - -

NHD 

Waterbodies 5,650 (11) 14,117 

(26) 

17,077 

(32) 15,939 (30) 8,371 (16) 5,354 (10) - 899 (2) - - - - 56 (<1) 

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Appendix N: Supplemental Impact Analysis Information Section 3. Supplemental Impact Analysis 

Table 3.1.3-2: Summary of Stream Miles and Acres of Waterbodies by Alternative for ROW

Combined by NHD Region for the Planning Area 

All Four Regions

(Lower Yukon, Middle Yukon,

Northwest Alaska, Southwest Alaska) 

Alternative1 

B C D 

Streams [miles] (% of stream miles on BLM-managed land) 

ROW – Open 6,454 (20) 11,985 (36) 19,151 (58) 

ROW – Avoidance 21,887 (66) 19,420 (59) 13,518 (41) 

ROW – Avoidance for Linear Realty Actions - 1,526 (5) -

ROW – Exclusion 4,590 (14) - -

ROW – Permitted on a Case-by-Case Basis - - 262 (1) 

Waterbodies [acres] (% of waterbody acres on BLM-managed lands) 

ROW – Open 13,748 (26) 31,015 (58) 36,969 (69) 

ROW – Avoidance 29,520 (55) 17,287 (32) 16,486 (31) 

ROW – Avoidance for Linear Realty Actions - 5,494 (10) -

ROW – Exclusion 10,528 (20) - -

ROW – Permitted on a Case-by-Case Basis - - 341 (1) 

Note: 

1 There are no current management decisions identified for Alternative A. 

Designated HVW Criteria and Proposed HVWs 

• Currently, there are no criteria for identification of HVWs or proposed HVWs under this 

alternative. 

o Direct/indirect effects under this alternative would be highly variable and depend on the type 

of activities/authorizations permitted. All activities have the potential to alter stream 

processes and degrade fish habitat. The duration of these impacts would also be highly 

variable and dependent upon the activity and the BMPs that are implemented. Any BMP that 

protects the streams and associated habitats would be valuable and would include avoidance 

of known spawning habitat and migration/spawning time periods. 

Locatable Mining 

• Currently, the number of miles/acres of waterbodies open to mining varies by mining activity and 

by region within high and medium LMP areas (see Table 3.1.3-7). 

• Under Alternative A, there is a 300-foot occupancy setback on the Lower Kateel, Tag, and Gisasa 

Rivers and tributaries to the Nulato and Ray Rivers and Squaw Creek. The number of acres this 

represents is not currently available. This setback would provide some protection to riparian and 

aquatic habitats and fish from surface-disturbing activities. 

• Mineral extraction within streams and watersheds could alter stream processes and fish habitat 

directly by removing pools and overwintering areas, destroying spawning beds, and impacting 

short- and long-term water quality. Locatable mineral development has the potential to affect 

about 85 miles of streams (less than 1 percent of streams in the planning area on BLM-managed 

lands) and 6 acres of other waterbodies (less than 1 percent of other waterbodies in the planning 

area on BLM-managed lands) in lands with high LMP and about 524 miles of streams (about 

2 percent of streams in the planning area on BLM-managed plan) and 706 acres of other 

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Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

waterbodies (about 1 percent of other waterbodies in the planning area on BLM-managed land) in 

medium LMP. 

• Under this alternative, the “known” anadromous/spawning streams are protected; however, there 

are an unknown percentage of undocumented streams that could be impacted directly. These 

direct impacts could include total removal of spawning habitat, increased turbidity and 

sedimentation, and loss of access to other known habitats upstream of an area which became 

mineable. These impacts, depending on severity, could be short or long term. 

Effects Common to All Action Alternatives 

See the “Effects Analysis” section above for potential direct/indirect effects common to all actions. 

Potential impacts from Alternative A are quantified above in terms of the indicators selected for 

comparing alternatives. While the types of impacts are similar for all alternatives, the intensity, duration 

and magnitude differ by alternative. 

Effects under Alternative B 

Designated HVWs Criteria 

• Criteria for identifying HVWs under this alternative include ARVs, protection of areas of 

sufficient size to ensure hydrologic connectivity and landscape resiliency, and watersheds with 

High, Medium-high, and Medium resource values. Metrics associated with miles/acres of fish 

spawning/rearing habitat would be project specific and addressed as needed. 

• See the “Effects Analysis” section above for potential direct/indirect effects common to all 

actions. 

Proposed HVWs 

• High resource value = 12,982 stream miles (about 39 percent of stream miles on BLM-managed 

lands); 4,891,935 acres 

• Medium-High resource value = 1,906 stream miles (about 6 percent of stream miles on BLMmanaged lands); 668,706 acres 

• Medium resource value = 6,494 stream miles (about 20 percent of stream miles on BLMmanaged lands); 2,733,412 acres 

• All management actions specific to HVWs would apply to streams and corridors identified in the 

100-year floodplain. 

• Management actions within HVWs, including appropriate buffers (BSWI Draft RMP/EIS, Map 

2-2), would extensively limit surface-disturbing activities from minerals, travel management, and 

realty management actions including ROW, which would result in fewer impacts on water quality 

and fish and aquatic habitat compared to other alternatives. 

• See the “Effects Analysis” section above for potential direct/indirect effects common to all 

actions. 

Locatable Mining 

• For fish-bearing streams, the disturbance-restriction buffer would be the 100-year floodplain area. 

Subject to valid existing rights, no surface-disturbing activities or permanent structures would be 

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Appendix N: Supplemental Impact Analysis Information Section 3. Supplemental Impact Analysis 

allowed within these buffer areas. Recovery of riparian vegetation and an upward trend of 

recovery would be realized within 5 years. 

• Mineral extraction within streams and within watersheds could alter stream processes and fish 

habitat directly by removing pools and overwintering areas, destroying spawning beds, and 

impacting short- and long-term water quality. Under Alternative B, locatable mineral 

development has the potential to affect about 40 miles of streams (less than 1 percent of streams 

in the planning area on BLM-managed lands) and about 1 acre of other waterbodies (less than 

1 percent of other water bodies in the planning area on BLM-managed lands) in high LMP areas 

and approximately 369 miles of streams (about 1 percent of streams in the planning area on 

BLM-managed lands) and 608 acres of other waterbodies (about 1 percent of other waterbodies in 

the planning area on BLM-managed lands) in medium LMP areas (see Table 3.1.3-7) 

• For mine site reclamation, the recovery of riparian vegetation and an upward trend would be 

realized within 5 years. 

• Operator is required to submit a plan for preventing nonnative invasive species (NNIS) 

infestations as a result of their mining operation. 

• All permitted mining operations would be required to implement 100 percent water recycle 

systems (zero discharge) and may be required to use a settling pond liner based on site specific 

conditions, where possible. 

• See the “Effects Analysis” section above for potential direct/indirect effects common to all 

actions. 

Effects under Alternative C 

See the “Effects Analysis” section above for potential direct/indirect effects common to all actions. 

Designated HVW Criteria 

• Criteria for identifying HVWs under this alternative include watersheds with High and Mediumhigh ARVs. Metrics associated with miles/acres of fish spawning/rearing habitat would be project 

specific and addressed as needed. 

• Proposed HVWs 

• High resource value = 12,982 stream miles (about 39 percent): 4,891,935 acres 

• Medium-high resource value = 1,906 stream miles (about 6 percent): 668,706 acres 

• All management actions specific to HVWs would apply to streams and corridors identified in the 

100-year floodplain 

• Any management action within HVWs apply to these values including appropriate buffers (BSWI 

Draft RMP/EIS, Map 2-3) 

• See the “Effects Analysis” section above for potential direct/indirect effects common to all 

actions. 

Locatable Mining 

• For fish-bearing streams, the disturbance-restriction buffer would be the 100-year floodplain area. 

Subject to valid existing rights, no surface-disturbing activities or permanent structures would be 

allowed within these buffer areas. Recovery of riparian vegetation and an upward trend of 

recovery would be realized within 5 years. 

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Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

• Alternative C would open areas to locatable minerals and would have the potential to affect 

almost 92 miles of streams (less than 1 percent of streams in the planning area on BLM-managed 

lands) and 6 acres of other waterbodies (less than 1 percent) in lands with high LMP. There 

would be no stream miles or acres of waterbodies withdrawn from locatable mineral extraction in 

high LMP areas. Alternative C would open areas to locatable minerals and have the potential to 

affect about 1,082 miles of streams (3 percent of streams in the planning area on BLM-managed 

lands) and 1,033 acres of waterbodies (2 percent) in medium LMP areas. There would be no 

stream miles and no acres of waterbodies withdrawn from locatable mineral extraction in medium 

LMP areas (see Table 3.1.3-7). 

• For mine site reclamation, the recovery of riparian vegetation and an upward trend would be 

realized within 5 years. 

• If NNIS are found, a comprehensive NNIS plan will be developed to address monitoring, 

prevention, and abatement. 

• Operations would be required to obtain Individual Mixing Zone permits under the APDES if they 

anticipate discharges or if the site characteristics limit recycle capacity/potential 

Effects under Alternative D 

Designated HVW Criteria 

• Criteria for identifying HVWs under this alternative include watersheds with High ARVs. 

Metrics associated with miles/acres of fish spawning/rearing habitat would be project specific and 

addressed as needed. Metrics related to mining actions can be found within the “Fisheries: 

Locatable, Salable, and Leasing Management Actions” section. 

• Alternative D provides the least protection of fish and aquatic resources of all the alternatives. 

• See the “Effects Analysis” section above for potential direct/indirect effects common to all 

actions. 

Proposed HVWs 

• High resource value = 12,982 river miles (about 39 percent): 4,891,935 acres 

• All management actions specific to HVWs would apply to streams and corridors identified in the 

100-year floodplain 

• Any management action within HVWs applies to these values including appropriate buffers 

(BSWI Draft RMP/EIS, Map 2-4). 

• Alternative D would provide the least amount of protection for fish and aquatic resources. 

• See the “Effects Analysis” section above for potential direct/indirect effects common to all 

actions. 

Locatable Mining 

• For plans of operations, development of the stream reclamation objectives would rely 

substantially upon the characterization of stream potential as determined from the baseline 

environmental information provided by the operator. 

• Alternative D provides the least amount of protection for fish and aquatic resources and relies on 

the operator to characterize the potential of streams for reclamation. Regulations require that 

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Appendix N: Supplemental Impact Analysis Information Section 3. Supplemental Impact Analysis 

operators use the technology and practices that will meet performance standards. Deliberate 

design, use of specific construction techniques, and riparian transplants have demonstrated 

success in the rehabilitation of fisheries habitat. 

• Mineral extraction within streams and watersheds could alter stream processes and fish habitat 

directly by removing pools and overwintering areas, destroying spawning beds, and impacting 

short- and long-term water quality. Alternative D would open areas to locatable minerals and 

would have the potential to affect almost 92 miles of streams (less than 1 percent of streams in the 

planning area on BLM-managed lands) and 6 acres of other waterbodies (less than 1 percent of 

other water bodies in the planning area on BLM-managed lands) in lands with high LMP. As with 

Alternative C, Alternative D would withdraw no stream miles or acres of waterbodies from 

locatable mineral development in high LMP areas. Alternative D have the same potential impacts 

to stream miles and acres of waterbodies as Alternative C, except it would withdraw zero acres of 

waterbodies from locatable mineral development in areas of medium LMP (see Table 3.1.3-7). 

• See the “Effects Analysis” section above for potential direct/indirect effects common to all 

actions. 

Summary 

In summary, Alternative B, compared to the other alternatives, provides the most restrictive management 

for streams/acres of waterbodies, with the least amount available for development or disturbance that 

could impact fish and aquatic resources. Table 3.1.3-1 and Table 3.1.3-2 provide a summary of the stream 

miles and acres of waterbodies within ROW status categories related to this resource. The numbers of 

miles of streams and/or acres of waterbodies where ROWs would be allowed, avoided, or excluded 

represent the potential for protecting aquatic habitat by alternative for the other actions presented above. 

These results show that the alternatives can be ranked in order based on the potential to protect aquatic 

resources: B, C, and D, followed by the No Action Alternative (A). 

Fisheries: Effects from Forestry and Woodland Products Management Actions 

In addition to management actions common to all action alternatives, potential impacts from the 

following management topics were considered: 

• Permitted Commercial Woodlands Harvesting Areas 

• Personal Use and Subsistence Woodland Harvest Areas 

• Woodland Harvest in HVWs 

• Woodland Harvest in the INHT NTMC 

• Woodland Harvest in ACEC 

• Forestry BMPs for Casual Use 

Table 3.1.3-3 presents the lengths and areas of streams and waterbodies affected by commercial 

woodlands harvesting management status and stream classification for Alternatives A, B, C, and D for 

each region, and Table 3.1.3-4 presents summary information for all regions combined. 

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Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

Table 3.1.3-3: Commercial Woodland Miles/Acres by Closed, Permittable, and Permitted Streams/Waterbodies: Alternatives A, B, C, 

and D 

Closed Permittable Permitted 

Alt. A Alt. B Alt. C Alt. A Alt. B Alt. C Alt. D Alt. A Alt. B Alt. C Alt. D 

Streams [miles] (percent of stream miles on BLM-managed lands) 

Lower Yukon River 

Anadromous Waters 

Spawning Streams 

138 (<1) 972 (3) - 716 (2) - 971 (3) - 123 (<1) 6 (<1) 6 (<1) 977 (3) 

Anadromous Waters 

Streams 

240 (1) 1,815 (6) - 1,490 (5) 7 (<1) 1,632 (5) 7 (<1) 220 (1) 129 (<1) 319 (1) 1,943 (6) 

NHD Streams 1,563 (5) 11,184 (34) - 12,622 38) 17 (<1) 8,469 (26) 18 (<1) 1,530 (5) 4,514 (14) 7,245 (22) 15,696 (48) 

Middle Yukon River 

Anadromous Waters 

Streams 

- 2 (<1) - 3 (<1) - - - - <1 (<1) 3 (<1) 3 (<1) 

NHD Streams - 26 (<1) - 29 (<1) - - - - 3 (<1) 29 (<1) 29 (<1) 

Northwest Alaska 

Anadromous Waters 

Spawning Streams 

46 (<1) 163 (1) 6 (<1) 118 (<1) - 157 (<1) - - - - 163 (1) 

Anadromous Waters 

Streams 

- 602 (2) 74 (<1) 428 (1) - 469 (1) - <1 (<1) <1 (<1) 59 (<1) 603 (2) 

NHD Streams 1,406 (4) 4,681 (14) 204 (<1) 3,458 (11) 38 (<1) 3,907 (12) 64 (<1) - 1,643 (5) 2,250 (7) 6,297 (19) 

Southwest Alaska 

Anadromous Waters 

Spawning Streams 

- 355 (1) - 358 (1) - 354 (1) - - 4 (<1) 5 (<1) 358 (1) 

Anadromous Waters 

Streams 

- 1,413 (4) - 1,441 (4) - 916 (3) - - 28 (<1) 525 (2) 1,441 (4) 

NHD Streams - 8,093 (25) - 10,828 (33) - 4,230 (13) - - 2,734 (8) 6,598 (20) 10,828 (33) 

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Appendix N: Supplemental Impact Analysis Information Section 3. Supplemental Impact Analysis 

Closed Permittable Permitted 

Alt. A Alt. B Alt. C Alt. A Alt. B Alt. C Alt. D Alt. A Alt. B Alt. C Alt. D 

Waterbodies [acres] (percent of waterbody acres on BLM-managed lands) 

Lower Yukon River 

Anadromous Water 

(Lakes/Ponds) 

- 34 (<1) - 34 (<1) - 34 (<1) - - <1 (<1) <1 (<1) 34 (<1) 

NHD Waterbodies - 5,720 (11) - - 17 (<1) 3,702 (7) - - 21,244 (39) 23,279 (43) -

Middle Yukon River 

NHD Waterbodies - 42 (<1) - 57 (<1) - - - - 15 (<1) 57 (<1) 57 (<1) 

Northwest Alaska 

NHD Waterbodies 38 (<1) 1,459 (3) 131 (<1) 2,939 (5) 39 (<1) 1,362 (3) 39 (<1) 1,293 (2) 2,277 (4) 2,777 (5) 4,231 (8) 

Southwest Alaska 

Anadromous 

Spawning Habitat 

(Lakes/Ponds) 

- - - <1 (<1) - - - - <1 (<1) <1 (<1) <1 (<1) 

Anadromous Waters 

(Lakes/Ponds) 

- - - <1 (<1) - - - - <1 (<1) <1 (<1) <1 (<1) 

NHD Waterbodies - 13,375 (25) - 22,488 (42) - 3,951 (7) - - 9,133 (17) 18,537 (34) 22,488 (42) 

Note: 

1

Closed data were only generated for Alternatives A, B, and C. 

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Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

Table 3.1.3-4: Summary of Stream Miles and Acres of Waterbodies by all Alternatives for 

Commercial Woodlands Combined by NHD Region for the Planning Area 

All Four Regions

(Lower Yukon, Middle Yukon, Northwest Alaska,

Southwest Alaska) 

Alternative 

A B C D 

Stream [miles] (percent of stream miles on BLM-managed lands) 

Commercial – Closed 2,969 (9) 23,984 (73) 204 (1) -

Commercial – Permittable 26,963 (82) 54 (<1) 16,605 (50) 82 (<1) 

Commercial – Permitted 3,000 (9) 8,893 (27) 16,122 (49) 32,850 (>99) 

Waterbodies [acres] (percent of waterbody acres on BLM-managed 

lands) 

Commercial – Closed 372 (1) 20,596 (38) 131 (<1) -

Commercial – Permittable 51,225 (95) 56 (<1) 9,015 (17) 56 (<1) 

Commercial – Permitted 2,199 (4) 33,145 (62) 44,650 (83) 53,740 (>99) 

Effects under Alternative A 

Permitted Commercial Woodlands Harvesting Areas 

• Current management plans allow subsistence and commercial harvest in most areas with 

permitting. Specific miles/acres of streams/waterbodies for closed/permittable/permitted 

commercial woodlands can be found in Table 3.1.3-3 and are summarized in Table 3.1.3-4. 

• Permits issued on a case-by-case basis for house logs, poles, and firewood. 

o There are no subsistence or commercial forestry harvests within eight Research Natural Areas 

(RNAs). Specifics for management of these harvests are summarized in BSWI Draft 

RMP/EIS, Chapter 2. 

Forestry BMPs for Casual Use 

• Permits issued on a case-by-case basis for house logs, poles, and firewood. 

There are no current management directions for Woodland Harvest in HVWs, INHT NTMCs, and 

ACECs, and no subsistence or commercial forestry within eight RNAs. 

Effects Common to All Action Alternatives 

• See the “Effects Analysis” section above for potential direct/indirect effects to fisheries common 

to all actions. 

Effects under Alternative B 

Permitted Commercial Woodlands Harvesting Areas 

• Timber sale operations would not be allowed within the 100-year floodplain of perennial rivers 

and streams. 

• All types of commercial woodland harvest would be permitted by the BLM on all BLM-managed 

lands in the planning area described below unless they are within the Unalakleet Wild River 

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Appendix N: Supplemental Impact Analysis Information Section 3. Supplemental Impact Analysis 

Corridor, ACECs, lands managed for wilderness characteristics as a priority, or the INHT NTMC, 

or the 100-year floodplain within an HVW. 

o Areas within 15 miles of a river are open for commercial woodland harvest. 

o Areas within 25 miles of a community are open for commercial woodland harvest. 

o Burned areas outside of the areas above are open for commercial woodland harvest. 

• Permits would be granted outside these areas on a case-by-case basis dependent on resource 

concerns. 

Woodland Harvest in HVWs 

• The 100-year floodplain within HVWs would be closed to commercial woodland harvest; nonsubsistence house log harvest prohibited. 

• The INHT NTMC would be closed to woodland harvest. 

Woodland Harvest in ACEC 

• Closed to commercial woodland harvest; non-subsistence house log harvest prohibited. 

Forestry BMPs for Casual Use 

• Timber sales are not allowed within the 100-year floodplain of perennial rivers and streams. 

• House log harvests are not allowed within the riparian zone of perennial streams. 

Table 3.1.3-3 presents stream mile and waterbody acreages for closed, permittable, and permitted by 

stream classification for commercial woodlands management actions for Alternatives A, B, and C. 

Effects under Alternative C 

Permitted Commercial Woodlands Harvesting Areas 

• Timber sale operations would not be allowed within the 100-year floodplain of perennial rivers 

and streams. 

• All types of commercial woodland harvest would be permitted by the BLM on all BLM-managed 

public lands described below unless they are within the Unalakleet Wild River Corridor (Table 

3.1.3-3 and Table 3.1.3-2). 

o Areas within 15 miles of a river are open for commercial woodland harvest. 

o All areas within 25 miles of a community are open for subsistence, and personal use 

woodland harvest. 

o All burned areas outside of the areas above are open for subsistence and personal use 

woodland harvest (includes mushrooms, berries, bark, and other forest products). 

• Permits would be granted on a case-by-case basis for HVWs, areas identified as important for 

cultural or fish resources, and other areas outside of those listed in the bullets above. 

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Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

Woodland Harvest in HVWs 

• Commercial woodland harvest in HVWs would be determined on a case-by-case basis depending 

on watershed health. 

Woodland Harvest in the INHT NTMC 

• These areas are open to commercial harvest on a case-by-case basis. 

Woodland Harvest in ACEC 

• There are no management plans for this alternative. See the section “Effects Common to All 

Action Alternatives” for Forestry and Woodland Products above. 

Forestry BMPs for Casual Use 

• House log harvests are not allowed within the riparian zone of perennial streams. 

Effects under Alternative D 

Permitted Commercial Woodlands Harvesting Areas 

• Commercial woodland harvest would be permitted by the BLM on all BLM-managed public 

lands described below. 

o Areas within 15 miles of a river are open for commercial woodland harvest 

o Areas within 25 miles of a community are open for commercial woodland harvest. 

o Burned areas outside of the areas above are open for commercial woodland harvest. 

• Permits would be granted outside these areas on a case-by-case basis dependent on resource 

concerns. 

• Table 3.1.3-3 has information for miles of streams and acres of waterbodies permitted and 

permittable for commercial harvest. 

Woodland Harvest in HVWs 

• Permits issued in HVWs on a case-by-case basis. 

Woodland Harvest in the INHT NTMC 

• These areas are open to commercial harvest. 

Woodland Harvest in ACEC 

• There are no management plans for this alternative – see the section “Effects Common to All 

Action Alternatives” for Forestry and Woodland Products above. 

Forestry BMPs for Casual Use 

• Same as Alternative C – except that house log harvest is allowed within riparian zone of perennial 

streams. 

• See the “Effects Analysis” section for potential direct/indirect effects common to all actions. 

3-22 
 

 

 

 

 

 

 

 

 

Appendix N: Supplemental Impact Analysis Information Section 3. Supplemental Impact Analysis 

Fisheries: Effects from Grazing Management Actions 

In addition to management actions common to all action alternatives, potential impacts from the 

following management topics were considered: 

• Areas Potentially Open to Grazing 

• Areas Closed to Grazing 

• Fees and Permits 

• Utilization 

Grazing of any type has potential to alter stream dynamics and thereby reduce the realized fish and 

aquatic habitat present within these regions. See Effects Analysis (Methods of Analysis) for potential 

Direct/Indirect effects common to all actions. 

Table 3.1.3-5 presents the lengths of streams and areas of waterbodies affected by grazing management 

status and stream classification for Alternatives A, B, C, and D for each region. Table 3.1.3-6 presents 

summary information for all regions combined. 

Effects under Alternative A 

Areas Open/Closed to Grazing 

• BLM policy has been to provide grazing leases for domestic livestock including reindeer and 

musk oxen where feasible. Where range is available, and a need exists for seasonal grazing, this 

policy may be maintained. Currently, there are 32,292 miles of streams and 53,798 acres of 

waterbodies where grazing may occur (Table 3.1.3-4). 

• Alternative A excludes the Unalakleet and Anvik Rivers and their major tributaries from grazing 

leases to protect important fisheries resources within these drainages. 

• See the “Effects Analysis” section for potential direct/indirect effects common to all actions. 

Grazing Management Plans 

• Current management plans do not specify requirement for Grazing Management Plan. 

Fees and Permits 

• There are no current management directives regarding fees or permits. 

Utilization 

• There are no current management directives. 

Effects Common to All Action Alternatives 

• See the “Effects Analysis” section for potential direct/indirect effects common to all actions. 

3-23 
 

 

 

 

 

 

 

 

Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

Table 3.1.3-5: Areas Open/Closed to Grazing by Miles/Acres of Streams: Alternatives A, B, C, and D 

Areas Closed to 

Grazing until 

Standards are 

Developed1 Closed to Grazing2 Potentially Open to Grazing3 

Alt. C Alt. A Alt. B Alt. C Alt. A Alt. C Alt. D 

Stream [miles] (percent of stream miles on BLM-managed lands) 

Lower Yukon River 

Anadromous 

Waters Spawning 

Streams 886 (3) 130 (<1) 977 (3) 87 (<1) 857 (3) 4 (<1) 977 (3) 

Anadromous 

Waters Streams 1,484 (5) 183 (1) 1,951 (6) 184 (1) 1,767 (5) 283 (<1) 1,951 (6) 

NHD Streams 7,690 (23) 428 (1) 15,714 (48) 612 (2) 15,286 (7) 7,412 (23) 15,714 (47) 

Middle Yukon River 

Anadromous 

Waters Streams -

-

3 (<1) 

-

3 (<1) 

3 (<1) 

3 (<1) 

NHD Streams - - 29 (<1) - 29 () 29 (<1) 29 (<1) 

Northwest Alaska 

Anadromous 

Waters Spawning 

Streams 131 (<1) 6 (<1) 163 (<1) 32 (<1) 157 (<1) 

-

163 (<1) 

Anadromous 

Waters Streams 361 (1) 74 (<1) 603 (2) 169 (1) 529 (2) 

72 (<1) 

603 (2) 

NHD Streams 2,321 (7) 209 (<1) 6,361 (19) 729 (2) 6,152 (19) 3,311 (10) 6,361 (19) 

Southwest Alaska 

Anadromous 

Waters Spawning 

Streams 320 (1) 

-

358 (1) 29 (<1) 358 (1) 9 (<1) 358 (1) 

Anadromous 

Waters Streams 856 (3) 

-

1,441 (4) 34 (<1) 1,441 (4) 551 (2) 1,441 (4) 

NHD Streams 3,824 (12) - 10,828 (33) 108 (<1) 10,828 (33) 6,896 (21) 10,828 (33) 

3-24 
 

 

 

 

 

 

Appendix N: Supplemental Impact Analysis Information Section 3. Supplemental Impact Analysis 

Areas Closed to 

Grazing until 

Standards are 

Developed1 Closed to Grazing2 Potentially Open to Grazing3 

Alt. C Alt. A Alt. B Alt. C Alt. A Alt. C Alt. D 

Waterbodies [acres] (percent of waterbody acres on BLM-managed lands) 

Lower Yukon River 

Anadromous Water 

(Lakes/Ponds) 

34 (<1) -

33.86 (0.06) - 33.86 (0.06) <1 (<1) 33.86 (0.06) 

NHD Waterbodies 6,158 (11) 219 (<1) 26,982 (50) 15 (<1) 26,762 (50) 20,809 (39) 26,982 (50) 

Middle Yukon River 

NHD Waterbodies - 57 (<1) - 57 (<1) 57 (<1) 57 (<1) 

Northwest Alaska 

NHD Waterbodies 517 (1) 131 (<1) 4,270 (8) 925 (2) 4,139 (8) 2,829 (5) 4,270 (8) 

Southwest Alaska 

Anadromous 

Spawning Habitat 

(Lakes/Ponds) -

-

<1 (<1) 

-

<1 (<1) 

<1 (<1) 

<1 (<1) 

Anadromous 

Waters 

(Lakes/Ponds) -

-

<1 (<1) 

-

<1 (<1) 

<1 (<1) 

<1 (<1) 

NHD Waterbodies 5,705 (11) - 22,488 (42) 325 (1) 22,488 (42) 16,458 (31) 22,488 (42) 

Notes: 

1

Areas Closed to Grazing until Standards are Developed only apply to Alternative C. 

2

Closed to Grazing data were generated for Alternatives A, B, and C. No areas closed to grazing under Alternative D. 

3

Open to Grazing data were generated for Alternatives A, C, and D. No areas open to grazing under Alternative B. 

3-25 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

Table 3.1.3-6: Summary of Stream Miles and Acres of Waterbodies by Alternatives for Grazing 

Combined by NHD Region for the Planning Area 

All Four Regions

(Lower Yukon, Middle Yukon, Northwest Alaska,

Southwest Alaska) 

Alternative 

A B C D 

Stream [miles] (percent of stream miles on BLM-managed lands) 

Grazing – Closed 639 (2) 32,932 (100) 1,449 (4) -

Grazing – Potentially Open on a Case-by-Case Basis 32,294 (98) 17,648 (54) 32,932 (100) 

Grazing – Areas Closed to Grazing until Standards are 

Developed 13,835 (42) 

Waterbodies [acres] (percent of waterbody acres on BLMmanaged lands) 

Grazing – Closed 352 (1) 53,798 (100) 1,264 (2) -

Grazing – Potentially Open on a Case-by-Case Basis 53,446 (99) - 40,152 (75) 53,798 (100) 

Grazing – Areas Closed to Grazing until Standards are 

Developed - - 12,380 (23) -

Effects under Alternative B 

• This alternative has all BLM lands closed to grazing of any type and is the most restrictive of all 

alternatives. Therefore, Alternative B is the most protective of fish and aquatic resources and 

represents approximately 32,932 miles of streams (100 percent) and 53,798 acres of waterbodies 

(100 percent) (Table 3.1.3-4). 

• See the “Effects Analysis” section for potential direct/indirect effects common to all actions. 

Effects under Alternative C 

Areas Open/Closed to Grazing 

• Grazing would only be permitted in areas where ecological conditions can support that grazing. 

This would be determined at the site-specific level and analyzed through implementation-level 

NEPA analyses. 

• Nulato River watershed, Unalakleet Wild River Corridor, and INHT NTMC would be closed to 

grazing. 

• HVWs would be closed to grazing until grazing standards and guidelines for riparian vegetation 

health are developed, then grazing in HVWs would be determined on a case-by-case basis. 

• New applications submitted under the 1937 Reindeer Industry Act and the Alaska Livestock 

Grazing Act of 1927 would be considered on a case-by-case basis. New applications submitted 

under the 1937 Reindeer Industry Act would be considered if the applicant can: (1) provide a 

management plan which includes management objectives and how the applicant would ensure 

separation between domestic and wild animals and (2) conduct all land health monitoring 

activities as determined appropriate by the BLM AO. 

• Under this alternative, there are approximately 17,648 miles of streams (about 54 percent) and 

40,152 acres of waterbodies (about 75 percent) where grazing would be allowed on a case-bycase basis, with an additional 13,835 miles of streams (about 42 percent) and 12,380 acres of 

other waterbodies (about 23 percent) that could be opened to grazing once standards are 

developed (Table 3.1.3-4). 

3-26 
 

 

 

Appendix N: Supplemental Impact Analysis Information Section 3. Supplemental Impact Analysis 

• See the “Effects Analysis” section for potential direct/indirect effects common to all actions. 

Grazing Management Plans 

• Proposed grazing operations must submit a grazing permit application that includes a 

comprehensive Grazing Management Plan or a Range Conservation Plan. 

Fees and Permits 

• New applications submitted under the 1937 Reindeer Industry Act would be considered if the 

applicant can: (1) provide a detailed Operations Plan which includes management objectives and 

how the applicant would ensure separation between domestic and wild animals, (2) conduct all 

land health monitoring activities as determined appropriate by the BLM AO, and (3) provide 

assurance that their Business Plan has considered the markets and cost of operations for their 

proposed operation. 

• Herd crossing permit applications would be addressed per direction in 43 CFR 4300.80 for 

proposals to move livestock across BLM-managed lands in the planning area, lands that are 

currently not administered under an existing grazing permit. 

• Permitted grazing would require satellite collars/ tracking devices on at least one animal for herds 

of up to 75 or less and at least two collars for herds larger than 75 animals. These data would be 

immediately available to the BLM upon request, and the BLM would be provided with annual 

reports showing location(s) of the herd throughout the year. 

• See the “Effects Analysis” section for potential direct/indirect effects common to all actions. 

Utilization Monitoring 

• Grazing operations would be administered to a maximum utilization threshold of Grazed Class 4 

(50–75 percent of primary forage species utilized). This utilization would be revised if scientific 

research indicates a different level of utilization is necessary to maintain rangeland health. 

• The Alaska Grazed Class Method (AGCM) would be used for monitoring permitted reindeer 

herds to determine utilization and lichen abundance. 

• The BLM would monitor range utilization and herd location(s) every 3 years, at a minimum, or 

more frequently if deemed necessary for permit compliance. 

• See the “Effects Analysis” section for potential direct/indirect effects common to all actions. 

Effects under Alternative D 

Areas Open/Closed to Grazing 

• No areas would be closed to grazing. 

• New applications submitted under the 1937 Reindeer Industry Act and the Alaska Livestock 

Grazing Act of 1927 would be considered in the planning area on a case-by-case basis. 

• Grazing would only be permitted in areas where ecological conditions can support that grazing. 

This would be determined at the site-specific level and analyzed through implementation-level 

NEPA analyses. 

• Grazing would be allowed in HVWs, but only where ecological conditions can support that 

grazing. 

3-27 
 

 

 

 

 

 

Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

• Grazing would be permitted in the Unalakleet Wild River Corridor and the INHT NTMC only if 

it is determined that the proposed permitted grazing is consistent with maintenance of the 

outstandingly remarkable values for which the Unalakleet Wild River Corridor was designated 

and the historical and cultural setting of the INHT NTMC. 

• Grazing permits would be authorized on a case-by-case basis by the AO according to the BLM 

Alaska Grazing Policy. 

• Under this alternative, there are 32,932 miles of streams (100 percent) and 53,798 acres of 

waterbodies (100 percent) where grazing would be possible on a case-by-case basis (Table 

3.1.3-4). 

• See the “Effects Analysis” section for potential direct/indirect effects common to all actions. 

Grazing Management Plans 

• No requirement for a Grazing Management Plan or a Range Conservation Plan when applying for 

a grazing permit. 

Fees and Permits 

• New applications submitted under the 1937 Reindeer Industry Act and the Alaska Livestock 

Grazing Act of 1927 would be considered in the planning area on a case-by-case basis. 

• Grazing fees and permit terms would be determined during promulgation of regulations to guide 

the implementation of the Alaska Livestock Grazing Act of 1927. 

• Herd crossing permit applications would be addressed as per direction in 43 CFR 4300.80 for 

proposals to move livestock across BLM-managed public lands, lands that are currently not 

administered under an existing grazing permit. 

Utilization 

• Grazing operations would be administered to a maximum utilization threshold of Grazed Class 4 

(50–75 percent of primary forage species utilized). This utilization would be revised if scientific 

research indicates a different level of utilization is necessary to maintain rangeland health. 

• The AGCM would be used for monitoring permitted reindeer herds to determine utilization and 

lichen abundance. 

• The BLM would monitor range utilization and herd location(s) every 3 years, at a minimum, or 

more frequently if deemed necessary for permit compliance. 

• See the “Effects Analysis” section for potential direct/indirect effects common to all actions. 

Summary 

In summary, Alternative B is the most protective of access to grazing habitat and therefore most 

protective of aquatic habitat. This is followed by Alternative C and Alternative A and is based on the 

amount of habitat that is open/closed and/or restricts caribou grazing. Alternative D opens all areas within 

the planning area to grazing and therefore is the least protective of all alternatives; however, under 

Alternative D, allowing or restricting grazing would occur on a case-by-case basis. 

3-28 
 

 

 

 

Appendix N: Supplemental Impact Analysis Information Section 3. Supplemental Impact Analysis 

Fisheries: Effects from Locatable, Salable, and Leasable Minerals Management Actions 

In addition to management actions common to all action alternatives, potential impacts from the 

following management topics were considered: 

• Surface-Disturbing Activities 

• Minerals Decisions within HVWs 

Table 3.1.3-7 presents the lengths and areas of non-HVW and HVW streams and waterbodies affected by 

locatable and salable management status and stream classification for Alternatives A, B, C, and D for 

each HUC 6 watershed within areas of high and medium LMP. Impacts from leasable mineral 

development are unlikely due to low potential in the planning area. 

Table 3.1.3-7: Summary of Stream Miles and Acres of Waterbodies by Alternatives for Locatable 

and Salable Combined by NHD Region for the Planning Area 

All Regions

(Lower Kuskokwim, Melozitna RiverYukon River, Outlet Yukon River, 

Upper Kuskokwim – HUC 6 Data) Alternative 

A B C D 

STREAMS Stream miles (percent of stream miles on BLM-managed lands) 

Locatable – Total Open 609 (2) 409 (1) 1,173 (4) 1,173 (4) 

High 85 (<1) 40 (<1) 92 (<1) 92 (<1) 

Medium 524 (2) 369 (1) 1,082 (3) 1,082 (3) 

Locatable – Total Withdrawn 565 (2) 764 (2) - -

High 7 (<1) 52 (<1) - -

Medium 558 (2) 712 (2) - -

WATERBODIES Acres (percent of waterbody acres on BLM-managed lands) 

Locatable – Total Open 712 (1) 609 (1) 1,038 (2) 1,040 (2) 

High 6 (<1) 1 (<1) 6 (<1) 6 (<1) 

Medium 706 (1) 608 (1) 1,033 (2) 1,033 (2) 

Locatable – Total Withdrawn 328 (1) 430 (1) - -

High 0 (0) 5 (<1) - -

Medium 328 (1) 425 (1) - -

STREAMS Stream miles (percent of stream miles on BLM-managed lands) 

Salable – Total Open 609 (2) 409 (1) 738 (2) 1,173 (4) 

High 85 (<1) 40 (<1) 79 (<1) 92 (3) 

Medium 524 (2) 369 (1) 659 (12) 1,082 (3) 

Salable – Total Closed 565 (2) 764 (2) - -

High 7 (<1) 52 (<1) - -

Medium 558 (2) 712 (2) - -

Salable – Total Open on a Case-bycase Basis - - 436 (1) -

High - - 13 (<1) -

3-29 
 

 

 

 

 

Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

All Regions

(Lower Kuskokwim, Melozitna RiverYukon River, Outlet Yukon River, 

Upper Kuskokwim – HUC 6 Data) Alternative 

A B C D 

Medium - - 423 (1) -

WATERBODIES Acres (percent of waterbody acres on BLM-managed lands) 

Salable – Total Open 712 (1) 609 (1) 658 (1) 1,040 (2) 

High 6 (1) 1 (<1) 1 (<1) 6 (<1) 

Medium 706 (1) 608 (1)) 656 (1) 1,033 (2) 

Salable – Total Closed 328 (1) 430 (1) -

High - 5 (<1) -

Medium 328 (1) 425 (1) -

Salable – Total Open on a Case-bycase Basis -

-

382 (1) -

High - - 5 (<1) -

Medium - - 377 (1) -

Effects under Alternative A 

Surface-Disturbing Activities 

• The objective of this alternative is to protect all crucial salmon spawning beds from adverse 

impacts of mineral location and development. There are no metrics provided to estimate how the 

objective will be evaluated. 

Minerals Decisions within HVWs 

• There are currently no metrics for comparison for HVWs under this alternative. 

• SWMFP directs the BLM to mitigate fisheries conflicts in fisheries-based ACECs by use of 

seasonal restrictions, area withdrawals, and other measures. 

Effects Common to All Action Alternatives 

• See the “Effects Analysis” section for potential direct/indirect effects common to all actions. 

Effects under Alternative B 

Surface-disturbing Activities 

• For the entire planning area (exception would be locatable mineral development and permitted 

activities by other agencies [e.g., ADF&G]), for fish-bearing streams the disturbance buffer 

would be the 100-year floodplain – no surface-disturbing activities or permanent structures would 

be allowed within these buffers. Buffers and therefore the totals miles of streams would vary 

depending on stream order. Therefore, metrics for this alternative would be calculated on a caseby-case basis. 

• See the “Effects Analysis” section for potential direct/indirect effects common to all actions. 

3-30 
 

 

 

Appendix N: Supplemental Impact Analysis Information Section 3. Supplemental Impact Analysis 

Minerals Decisions within HVWs 

• Closed Locatable/Salable 

o 24,712 miles (82 percent) of streams and 38,068 acres (71 percent) of waterbodies are 

withdrawn due to existing withdrawals retained or proposed new withdrawals or closed to 

salable mineral development, respectively (Table 3.1.3-7). 

• Withdrawn from locatable mineral entry due to existing withdrawals retained or proposed new 

withdrawals. 

• No suction dredging on the non-navigable waterways within HVWs. 

• See the “Effects Analysis” section for potential direct/indirect effects common to all actions. 

Effects under Alternative C 

Surface-disturbing Activities 

• Within HVWs (exception would be locatable mineral development and permitted activities by 

other agencies [e.g., ADF&G]) and subsistence users for permitted camps within HVWs, for fishbearing streams, the disturbance buffer would be the 100-year floodplain; no surface-disturbing 

activities or permanent structures would be allowed within these buffers. Buffers and therefore 

the total miles of streams would vary depending on stream order. Therefore, metrics for this 

alternative would be calculated on a case-by-case basis. Areas open/closed to mining activities 

within high and medium LMP areas are provided in Table 3.1.3-7. 

• See the “Effects Analysis” section for potential direct/indirect effects common to all actions. 

Minerals Decisions within HVWs 

• Open to locatable mineral entry and open to salable mineral development, case-by-case (Table 

3.1.3-7). 

• See the “Effects Analysis” section for potential direct/indirect effects common to all actions. 

Effects under Alternative D 

Surface-disturbing Activities 

• Surface-disturbing activities or permanent structures would be allowed within the 100-year 

floodplain of perennial and fish-bearing streams if permittees can demonstrate these activities 

would not substantively impact floodplain function and would be decided on a case-by-case basis. 

• See the “Effects Analysis” section for potential direct/indirect effects common to all actions. 

Minerals Decisions within HVWs 

• Open to salable mineral entry (Table 3.1.3-7). 

• Suction dredging is permitted within non-navigable waterways on a case-by-case basis. 

• Areas are open to locatable mineral entry. 

• See the “Effects Analysis” section for potential direct/indirect effects common to all actions. 

3-31 
 

 

 

 

 

 

Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

Fisheries: Effects from Travel and Transportation Management 

In addition to management actions common to all action alternatives, potential impacts from the 

following management topics were considered: 

• Travel and Transportation Management within HVWs 

• Fish Passage Design Requirement/Standard 

• River Crossing BMPs 

Table 3.1.3-4 presents travel and transportation alternatives by lengths and areas of streams and 

waterbodies for Alternatives B, C, and D for each region. 

Effects under Alternative A 

• There are no current travel designations with the exception of the Unalakleet Wild River 

Corridor, which does not allow casual or subsistence OHV use. 

• See the “Effects Analysis” section for potential direct/indirect effects common to all actions. 

Effects Common to All Action Alternatives 

• See the “Effects Analysis” section for potential direct/indirect effects common to all actions. 

Effects under Alternative B 

OHV Designation = Limited (Table 3.1.3-4) 

• Travel decisions vary throughout the planning area for the INHT NTMC, Lands with Wilderness 

Characteristics TMA, and Unalakleet Wild River Corridor. 

• Alternative B would have fewer acres open to subsistence and casual use than Alternatives C and 

D (Table 3.1.3-4). 

• This alternative increases restrictions on travel and transportation and provides the most 

protection for fish and aquatic resources of all the alternatives. 

Fish Passage Design Requirement/Standard 

• At least 3 years of hydrologic and fish data would be collected prior to construction of any 

proposed stream crossing whose structure is designed to occur, wholly or partially, below the 

stream’s OHWM. 

River Crossing BMPs 

• Except for approved crossings and approved locatable mine plans and Notice Level Operations, 

alteration of the banks of a waterway and floodplains would be avoided. If they cannot be 

avoided, BMPs will be used to reduce impacts; cut plugs or similar means will be used to restore 

stream banks. Waterways include natural features with sufficient water to create riparian habitat 

such as rivers, streams, deep and shallow lakes, tundra ponds, and shallow-water tracks (swales) 

in permafrost areas. Clearing of riparian vegetation along the riparian zone would be avoided 

whenever possible. Movement of equipment through riparian vegetation would be avoided 

whenever possible. All actions would be compliant with Executive Orders 11990 and 11988. 

3-32 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Appendix N: Supplemental Impact Analysis Information Section 3. Supplemental Impact Analysis 

Effects under Alternative C 

OHV Designation = Limited (Table 3.1.3-8) 

• Travel decisions vary throughout the planning area for the INHT NTMC, Lands with Wilderness 

Characteristics TMA, and Unalakleet Wild River Corridor. 

• Alternative C would have more acres open to subsistence and casual use than Alternative B and 

fewer than Alternative D (Table 3.1.3-8). 

• Work in coordination with the State of Alaska to designate stream crossing routes; these routes 

would be designated within the 100-year floodplain. 

• See the “Effects Analysis” section for potential direct/indirect effects common to all actions. 

Table 3.1.3-8: Summary of Stream Miles and Acres of Waterbodies by Action Alternative for 

Transportation and Travel Combined by NHD Region for the Planning Area 

All Subunits 

(Lower Yukon, Middle Yukon, Northwest Alaska,

Southwest Alaska) 

Alternative1 

B C D 

Stream [miles] (percent of stream miles on BLM-managed lands) 

Travel – Lands with Wilderness Characteristics 666 (2) - -

Travel – Summer Casual OHV Limited 31,367 (95) 32,293 (98) 204 (1) 

Travel – Open to Summer Subsistence Overland OHV 

Travel 

- 32,293 (98) -

Travel – Summer Casual OHV Prohibited 1,565 (5) 639 (2) 639 (2) 

Travel – Summer Subsistence OHV Limited 871 (3) - 639 (2) 

Travel – Summer Subsistence OHV Prohibited 694 (2) 639 (2) -

Travel – Winter Casual Snowmobiles 32,931 (100) 7,133 (22) 639 (2) 

Travel – Winter Subsistence Snowmobiles 9,989 (30) 7,133 (22) 639 (2) 

Travel – Summer OHV Subsistence Allowed 31,367 (95) 32,293 (98) 32,087 (97) 

Travel – Summer OHV Subsistence Denied 1,565 (5) 844 (3) 844 (3) 

Travel – Winter Subsistence – Allowed 32,265 (98) 32,931 (100) 32,931 (100) 

Travel – Winter Subsistence – Prohibited 666 (2) - -

Waterbodies [acres] (percent of waterbody acres on BLM-managed 

lands) 

Travel – INHT 1,298 (2) 1,250 (2) 1,250 (2) 

Travel – Lands with Wilderness Characteristics 2,878 (5) - -

Travel – Summer Casual OHV Limited 49,623 (92) 52,678 (98) 131 (<1) 

Travel – Summer Casual OHV Prohibited 4,175 (8) 1,118 (2) 1,118 (2) 

Travel – Summer Subsistence OHV Limited 3,009 (6) - 1,118 (2) 

Travel – Summer Subsistence OHV Prohibited 1,167 (2) 1,118 (2 -

Travel – Winter Casual Snowmobiles 53,796 (100) 6,301 (12) 1,118 (2) 

Travel – Winter Subsistence Snowmobiles 15,929 (30) 6,301 (12) 1,118 (2) 

3-33 
 

 

 

 

 

 

 

 

 

Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

All Subunits 

(Lower Yukon, Middle Yukon, Northwest Alaska,

Southwest Alaska) 

Alternative1 

B C D 

Travel – Summer OHV Subsistence Allowed 49,621 (93) 52,678 (98) 52,547 (99) 

Travel – Summer OHV Subsistence Denied 4,175 (8) 1,250 (2) 1,250 (2) 

Travel – Winter Subsistence – Allowed 50,918 (95) 53,796 (100) 53,796 (100) 

Travel – Winter Subsistence – Prohibited 2,878 (5) - -

Note: 

1 There are no current management decisions identified for Alternative A. 

Fish Passage Design Requirement/Standard 

• Determinations on required data collection to support implementation of these BMPs would be 

made on a case-by-case basis. 

River Crossing BMPs 

• Same as Alternative B. 

Effects under Alternative D 

OHV Designation = Limited (Table 3.1.3-8) 

• Travel decisions vary throughout the planning area for the INHT NTMC, Lands with Wilderness 

Characteristics TMA, and Unalakleet Wild River Corridor. 

• Alternative D would have more acres open to subsistence and casual use than Alternative B and C 

(Table 3.1.3-8). 

• Work in coordination with the State of Alaska to designate stream crossing routes; these routes 

would be designated within the 100-year floodplain. 

Fish Passage Design Requirement/Standard 

• Same as Alternative C. 

River Crossing BMPs 

• Determinations of when permitted activities can alter the banks of a waterway would be made on 

a case-by-case basis by the AO. 

Fisheries: Effects from Areas of Critical Environmental Concern Management Actions 

Potential impacts from the following management topics were considered: 

• Anvik River Watershed ACEC 

• Gisasa River ACEC 

• Inglutalik River ACEC 

• Kateel River ACEC 

• Nulato River ACEC 

3-34 
 

 

 

 

 

 

 

 

Appendix N: Supplemental Impact Analysis Information Section 3. Supplemental Impact Analysis 

• Shaktoolik River ACEC 

• Sheefish ACEC 

• Swift River Whitefish Spawning ACEC 

• Ungalik River ACEC 

• North River ACEC 

• Unalakleet River Watershed ACEC 

Within the ACECs of the planning area, the potential for impacts (direct and/or indirect) are directly 

related to the activities proposed. These potential impacts are summarized early in this section, under the 

heading “Effects Analysis.” The differences within alternatives presented below are based on acres 

designated as ACECs. Within any ACEC, further analyses would be required to determine fish and 

aquatic habitat (i.e., miles of streams or acres of lakes) for each specific project or activity proposed. 

Alternative A would maintain the current ACEC designations on BLM lands; there would be no changes 

to current ACECs or the addition of new ACECs. Alternative B has the most total acreage designated as 

ACECs in the planning area (29 percent) compared with Alternative A (14 percent). Alternative B would 

be the most restrictive, leading to fewer potential adverse impacts on fisheries resources. 

Effects under Alternative A 

Anvik River ACEC – 114,386 acres 

• Fisheries are the primary relevance and importance (BLM 1981a). 

Gisasa River ACEC – 278,055 acres 

• Fisheries are the primary relevance and importance. 

• Consider the protection of riparian habitat in all aspects of projects on BLM lands. 

• Objective – maintain aquatic habitat which supports populations of fish in the planning area. 

Inglutalik River ACEC – 71,713 acres 

• Fisheries are the primary relevance and importance. 

• Consider the protection of riparian habitat in all aspects of projects on BLM lands. 

• Objective – maintain aquatic habitat which supports populations of fish in the planning area. 

Kateel River ACEC – 568,083 acres 

• Fisheries are the primary relevance and importance. 

• Consider the protection of riparian habitat in all aspects of projects on BLM lands. 

• Objective – maintain aquatic habitat which supports populations of fish in the planning area. 

Nulato River ACEC 

• Not managed as an ACEC. 

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Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

• Maintain the water quality of watersheds on BLM-managed lands in the planning area in 

compliance with the Alaska Water Quality Standards. 

• Perfect legal water rights to the water resource on public lands in support of BLM programs and 

in compliance with the Alaska Water Use Act. Protect existing water rights of the United States. 

Shaktoolik River ACEC – 192,591 acres 

• Fisheries are the primary relevance and importance. 

• Consider the protection of riparian habitat in all aspects of projects on BLM lands. 

• Objective – maintain aquatic habitat which supports populations of fish in the planning area. 

Ungalik River ACEC – 112,719 acres 

• Fisheries are the primary relevance and importance. 

North River ACEC – 132,200 acres 

• Fisheries are the primary relevance and importance. 

Unalakleet River Watershed ACEC 

• Not managed as an ACEC. 

Effects Common to All Action Alternatives 

• See the “Effects Analysis” section for potential direct/indirect effects common to all actions. 

Effects under Alternative B 

Anvik River Watershed ACEC – 248,867 acres 

• Fisheries are the primary relevance and importance value. 

• Any proposal to use or develop the lands, waters, or resources within the 100-year floodplain of 

active stream channels must demonstrate to the satisfaction of the AO that such use or 

development: 

o Would not adversely alter the condition and ecological function of aquatic and riparian 

systems by impacting water quality, stream flow, velocity, ground water hydrology, channel 

connectivity, channel form, material recruitment, substrate composition, energy (food) flow, 

and riparian function; and 

o Would not diminish the quality and diversity of habitats needed to sustain the production of 

fish and wildlife populations at their natural potential. 

Gisasa River ACEC - 278,241 

• Fisheries are the primary relevance and importance. 

• Any proposal to use or develop the lands, waters, or resources within the 100-year floodplain of 

active stream channels must demonstrate to the satisfaction of the AO that such use or 

development: 

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Appendix N: Supplemental Impact Analysis Information Section 3. Supplemental Impact Analysis 

o Would not adversely alter the condition and ecological function of aquatic and riparian 

systems by impacting water quality, stream flow, velocity, ground water hydrology, channel 

connectivity, channel form, material recruitment, substrate composition, energy (food) flow, 

and riparian function; and 

o Would not diminish the quality and diversity of habitats needed to sustain the production of 

fish and wildlife populations at their natural potential. 

Inglutalik River ACEC - 70,888 acres 

• Fisheries are the primary relevance and importance. 

• Any proposal to use or develop the lands, waters, or resources within the 100-year floodplain of 

active stream channels must demonstrate to the satisfaction of the AO that such use or 

development: 

o Would not adversely alter the condition and ecological function of aquatic and riparian 

systems by impacting water quality, stream flow, velocity, ground water hydrology, channel 

connectivity, channel form, material recruitment, substrate composition, energy (food) flow, 

and riparian function; and 

o Would not diminish the quality and diversity of habitats needed to sustain the production of 

fish and wildlife populations at their natural potential. 

Kateel River ACEC - 692,659 acres 

• Fisheries are the primary relevance and importance. 

• Any proposal to use or develop the lands, waters, or resources within the 100-year floodplain of 

active stream channels must demonstrate to the satisfaction of the AO that such use or 

development: 

o Would not adversely alter the condition and ecological function of aquatic and riparian 

systems by impacting water quality, stream flow, velocity, ground water hydrology, channel 

connectivity, channel form, material recruitment, substrate composition, energy (food) flow, 

and riparian function; and 

o Would not diminish the quality and diversity of habitats needed to sustain the production of 

fish and wildlife populations at their natural potential. 

Nulato River ACEC - 344,182 acres 

• Fisheries are the primary relevance and importance. 

• Nulato River ACEC would encompass 649 acres of land within the existing North River ACEC 

boundary and 868 acres within the existing drainages of the Unalakleet ACEC boundary. 

• Any proposal to use or develop the lands, waters, or resources within the 100-year floodplain of 

active stream channels must demonstrate to the satisfaction of the AO that such use or 

development: 

o Would not adversely alter the condition and ecological function of aquatic and riparian 

systems by impacting water quality, stream flow, velocity, ground water hydrology, channel 

connectivity, channel form, material recruitment, substrate composition, energy (food) flow, 

and riparian function; and 

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Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

o Would not diminish the quality and diversity of habitats needed to sustain the production of 

fish and wildlife populations at their natural potential. 

Shaktoolik River ACEC - 191,067 acres 

• Fisheries are the primary relevance and importance. 

• Would encompass 1,621 acres of land within the existing North River ACEC boundary. 

• Any proposal to use or develop the lands, waters, or resources within 300 feet or within the 100-

year floodplain (whichever is greater) of the banks of active stream channels must demonstrate to 

the satisfaction of the AO that such use or development: 

o Would not adversely alter the condition and ecological function of aquatic and riparian 

systems by impacting water quality, stream flow, velocity, ground water hydrology, channel 

connectivity, channel form, material recruitment, substrate composition, energy (food) flow, 

and riparian function; and 

o Would not diminish the quality and diversity of habitats needed to sustain the production of 

fish and wildlife populations at their natural potential. 

Sheefish ACEC – 696,901 acres 

• Fisheries and cultural resources are the primary relevance and importance. 

• Coordinate with State of Alaska in the annual monitoring of potential Sheefish spawning rivers 

within the boundary of the Sheefish ACEC. For those rivers identified as supporting spawning 

sheefish, the following management actions would apply within a quarter mile on each side (from 

OHWM) of the reaches with known active spawning. 

• Any proposal to use or develop the lands, waters, or resources within the 100-year floodplain of 

active stream channels must demonstrate to the satisfaction of the AO that such use or 

development: 

o Would not adversely alter the condition and ecological function of aquatic and riparian 

systems by impacting water quality, stream flow, velocity, ground water hydrology, channel 

connectivity, channel form, material recruitment, substrate composition, energy (food) flow, 

and riparian function; and 

o Would not diminish the quality and diversity of habitats needed to sustain the production of 

fish and wildlife populations at their natural potential. 

Swift River Whitefish Spawning ACEC – 220,032 acres 

• Fisheries are the primary relevance and importance. 

• Any proposal to use or develop the lands, waters, or resources within the 100-year floodplain of 

active stream channels must demonstrate to the satisfaction of the AO that such use or 

development: 

o Would not adversely alter the condition and ecological function of aquatic and riparian 

systems by impacting water quality, stream flow, velocity, ground water hydrology, channel 

connectivity, channel form, material recruitment, substrate composition, energy (food) flow, 

and riparian function; and 

o Would not diminish the quality and diversity of habitats needed to sustain the production of 

fish and wildlife populations at their natural potential. 

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Appendix N: Supplemental Impact Analysis Information Section 3. Supplemental Impact Analysis 

Ungalik River ACEC - 113,454 acres 

• Fisheries are the primary relevance and importance. 

North River ACEC 

• Not managed as an ACEC. 

• 64,885 acres within the existing North River ACEC boundary would no longer be managed as an 

ACEC. 

Unalakleet River Watershed ACEC - 733,995 acres 

• Fisheries and cultural resources are the primary relevance and importance. 

• Unalakleet River Watershed ACEC would encompass 299,968 acres of land within the existing 

Drainages of the Unalakleet ACEC boundary and 65,046 acres within the existing North River 

ACEC boundary. 

• Any proposal to use or develop the lands, waters, or resources within 300 feet or within the 100-

year floodplain (whichever is greater) of the banks of active stream channels must demonstrate to 

the satisfaction of the AO that such use or development: 

o Would not adversely alter the condition and ecological function of aquatic and riparian 

systems by impacting water quality, stream flow, velocity, ground water hydrology, channel 

connectivity, channel form, material recruitment, substrate composition, energy (food) flow, 

and riparian function; and 

o Would not diminish the quality and diversity of habitats needed to sustain the production of 

fish and wildlife populations at their natural potential. 

Effects under Alternative C 

• There are no ACEC management plans under this alternative. See the “Effects Analysis” section 

for potential direct/indirect effects common to all actions. 

Effects under Alternative D 

• There are no ACEC management plans under this alternative. See the “Effects Analysis” section 

for potential direct/indirect effects common to all actions. 

Summary 

In summary, Alternative B would provide the most acres designated as an ACEC which would help 

minimize impacts to fisheries by limiting development near waterbodies and requiring projects to meet 

standards that avoid impacts to streams and aquatic habitat. Under Alternative A, fewer acres would be 

designated as ACECs than under Alternative B. Alternatives C and D remove all management of ACECs, 

including current management of established ACECs. 

Fisheries: Effects from Climate Change 

According to the Scenarios Network for Alaska and Arctic Planning, 50-year modeled surface water 

temperature may increase in some watersheds or decrease in other areas where more ice melt is occurring. 

Other potential changes as a result of climate change could include the following: 

• Water flow increase or decrease 

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Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

• Sedimentation from thawing permafrost and changes related to peak-flow events 

• Lake bed drying 

• Invasive species introduction due to changing condition 

• Changes to the occurrence, quantity, distribution, movement, and quality of water affecting fish 

production and survival 

Potential effects from climate change under all alternatives are unknown and would be determined on a 

case-by-case basis once future projects are evaluated. There are no management actions under any 

alternatives that would counteract impacts from climate change on fisheries. 

Fisheries: Cumulative Effects 

Table 3.1.3-9 summarizes the results of the cumulative effects analysis for fisheries for all alternatives. 

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Appendix N: Supplemental Impact Analysis Information Section 3. Supplemental Impact Analysis 

Table 3.1.3-9: Cumulative Effects Analysis for Fisheries Resources 

Trends and Forecasts of 

Fisheries in Consideration of 

Past and Present Actions 

Trends and Forecasts of 

Fisheries Resources in 

Consideration of Past, 

Present, and Reasonably

Foreseeable Future Actions 

(Alternative A) 

Trends and Forecasts of 

Fisheries Resources in 

Consideration of Past, Present, 

and Reasonably Foreseeable 

Future Actions 

(Alternative B) 

Trends and Forecasts of 

Fisheries Resources in 

Consideration of Past, Present, 

and Reasonably Foreseeable 

Future Actions 

(Alternative C) 

Trends and Forecasts of 

Fisheries Resources in 

Consideration of Past, Present, 

and Reasonably Foreseeable 

Future Actions 

(Alternative D) 

Based on past commercial, The No Action Alternative Alternative B consistently limits The effectiveness of Alternative C Alternative D consistently allows 

subsistence, and personal use represents the status quo. Any access or requires substantially to protect fish and aquatic more development with less 

fisheries harvest data, resident activities or actions that could more requirements to gain access resources is essentially an regulation, decreases protected 

fish production is generally degrade or remove fish and for development. The inclusion of intermediary between Alternative habitat, and opens more areas to 

forecast to remain stable in the aquatic habitat could result in larger and more numerous HVWs B (least impactful) and Alternative potentially degrade fish and 

planning area. The forecasted substantial impacts to the and ACECs would minimize and D (potentially most impactful) with aquatic resource habitat. There 

extent of disturbances to resource, such as the Donlin prevent impacts to aquatic respect to acreage of impacts. would be no ACECs considered 

habitat is expected to remain Gold Project. However, current species to maintain healthy The inclusion of a greater number under this alternative that could 

minimal throughout the forecasts do not show large populations. The inclusion of the of HVWs would minimize and provide habitat protection for 

majority of the watersheds in increases in development Sheefish ACEC and Swift River prevent impacts to fisheries aquatic species— specifically 

the planning area. Activities throughout the planning area Whitefish Spawning ACEC would habitat and allow aquatic species important subsistence species like 

that occur within the planning such that the fisheries resource provide protective measures for to maintain healthy populations; chum, Chinook salmon, sheefish, 

area that have the highest would remain stabilized overall. aquatic habitats for sheefish and however, Alternative C would or whitefish—that could be 

potential to affect fish Trend: No contribution to whitefish that rely on these allow more surface-disturbing realized through the 

production include placer existing trend (remain existing habitats. activities that could affect fisheries implementation of ACECs. 

mining, hard rock mining, stabilized) Trend: Counters existing trend habitat than Alternative B. There Furthermore, the substantial 

gravel mining, timber harvests, (improving) would be no ACECs considered decrease of areas considered 

and stream crossings of roads, under this alternative that would protected under HVWs further 

trails, and utility corridors in provide habitat protection for compounds the potential for future 

important fish habitats. aquatic species—specifically, cumulative impacts. 

Impacts from these potential important subsistence species Trend: Counters existing trend 

activities are unknown, though such as chum and Chinook (degrading) 

not expected to substantially salmon, sheefish, or whitefish. 

increase in the near future. BMPs, SOPs, and detailed 

Trend: Stabilized reclamation requirements 

included under Alternative C 

would help to maintain fish habitat 

and healthy populations. 

Trend: Counters existing trend 

(improving but at a lesser rate 

than Alternative B) 

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Section 3. Supplemental Impacts Analysis Appendix N: Supplemental Impact Analysis Information 

3.2 Vegetation 

3.2.1 Summary 

Vegetation is an important component of land-based resources and resource uses. Management actions for 

many resources, resource uses, and special designations on BLM-managed lands in the planning area 

have the potential to affect vegetation and special status species (SSS) flora either through direct or 

indirect impacts or by implementing protections that eliminate or reduce the magnitude of these impacts. 

Direct and indirect impacts would include impacts of both short- and long-term duration. These impacts 

could result in changes to plant community composition and/or plant characteristics (e.g., vigor, 

fecundity, and biomass) over short- and long-term timeframes. 

The three action alternatives would result in varying ranges in magnitude and extent of potential impacts 

or potential protections for vegetation and SSS flora. Management under Alternative B would be most 

protective of vegetation and SSS flora, as restrictions on resource uses would be the most stringent, and 

the magnitude and extent of requirements for protection and restoration of vegetation would be the 

greatest. Alternative D would provide the least amount of additional protections to vegetation and SSS 

flora, and Alternative C would provide a level of protection that would be intermediate between 

Alternative B and Alternative D. Management of vegetation under the alternatives would be consistent 

with BLM priorities for conserving land and water and utilizing natural resources. 

3.2.2 Methods of Analysis 

Analysis of impacts to vegetation is based on quantification of acreages that are available or unavailable 

to management actions that could result in direct or indirect impacts to vegetation. Qualitative 

descriptions of potential direct or indirect impacts to vegetation are presented in the “Effects Common to 

All Action Alternatives” subsections for each resource, resource use, or special designation analysis 

section. 

Potential Effects and Indicators 

Vegetation and SSS flora are affected by actions that temporarily or permanently remove or damage 

individual plants or plant communities. Removal of vegetation would occur with any surface-disturbing 

action, such as minerals extraction, commercial woodland harvest, certain fire or fuels treatments, or with 

high-intensity grazing. If SSS flora occurs in these areas, these species could also be removed or 

damaged. Damage to individual plants (i.e., crushing, removal or breaking of leaves or branches, damage 

to roots, etc.), could occur with non-surface-disturbing actions such as certain types of minerals actions, 

personal use/subsistence woodland harvest, fire and fuels treatments, OHV use, or livestock grazing). 

Land disposals could lead to fewer protections for vegetation and SSS flora in disposed areas. Removal of 

or damage to vegetation may change vegetation cover and composition over the short or long term. This 

would result in cascading ecosystem effects such as changes in habitat suitability for wildlife species, 

changes to soil erosion potential, decreased livestock grazing suitability, and increased potential for 

colonization and spread of nonnative invasive plants (these effects are discussed in the analysis sections 

for these resources). Reclamation of vegetation in disturbed areas required as part of certain management 

actions would generally minimize impacts to vegetation communities, though the ability of reclamation to 

mitigate surface-disturbing actions would depend on project-specific reclamation requirements, site 

characteristics, and reclamation methods. Actions that could remove or damage plants could be restricted 

by certain resource protections, such as NSO minerals development, exclusions for surface-disturbing 

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Appendix N: Supplemental Impact Analysis Information Section 3. Supplemental Impact Analysis 

minerals actions or commercial woodland harvest, VRM Class I and II designations, WSR protection 

areas, ROW exclusion and avoidance areas, and designation of the INHT NTMC. 

A list of SSS flora in the planning area is presented in Appendix M of the BSWI Draft RMP/EIS. 

Potential impacts to vegetation and SSS flora, management actions relevant to these impacts, and analysis 

impact indicators are presented in Table 3.2.2-1. 

Table 3.2.2-1: Summary of Effects to Vegetation by Management Action 

Types of Effects Management Actions Indicators 

Surface disturbance due to minerals extraction 

and woodland harvest would remove 

vegetation. Vegetation may also be damaged 

incidentally as the result of non-surfacedisturbing minerals actions and woodland 

harvest activities through vegetation crushing or 

damage to individual plants. 

• Minerals Decisions 

• Woodland Harvest Decisions 

• Acres open to locatable, salable, 

and leasable minerals 

• Acres open to woodland harvest 

Fire and fuels treatments may require removal • Fire and Fuels Treatment • Potential for removal or 

of vegetation communities, which would result in Management Decisions degradation of vegetation 

localized, major impacts to vegetation; however, communities associated with fire 

treatments would be implemented with the goal and fuels treatments (qualitative 

of minimizing the impacts of wildland fires on discussion) 

vegetation and other resources. 

OHV use could degrade vegetation along • Vegetation Management • Acres open to OHV use 

overland travel routes through crushing, Decisions 

removal, and soil disturbance. • Transportation and Travel 

Management Decisions 

• Lands Managed for Wilderness 

Characteristics TMA 

Livestock grazing would result in removal of • Livestock Grazing Management • Acres open to livestock grazing 

lichen and vascular plants, trampling, Decisions 

transportation of plant propagules, and soil 

disturbance that could alter habitat conditions for 

vegetation species, including SSS flora. These 

impacts could result in changes to vegetation 

community composition in grazed areas. 

Land disposals could lead to fewer protections 

for vegetation and SSS flora, which may result 

in degradation of these resources over time. 

• Disposals • Acres of BLM-managed lands 

identified for acquisition, retention, 

or disposal 

Conditions of vegetative communities and SSS • Vegetation Management Actions • Acres within buffers for surfaceflora habitat could be improved through 

avoidance of surface-disturbing actions, 

monitoring, restoration and mitigation, and/or 

• Minerals Decisions 

• Woodland Harvest Decisions 

disturbing BLM-permitted activities 

• Total VRM Class acreages 

adherence to cited standards associated with 

management actions for vegetation and other 

resources. 

• VRM Class Designations 

• Buffers for Surface-Disturbing 

BLM-Permitted Activities 

• Acres of BLM-managed surface 

ownership affected by ROW 

restrictions (i.e., avoidance or 

exclusion areas) 

• Lands with Wilderness 

Characteristics Management 

• ACEC Designations 

• Lands and Realty Withdrawals 

• ROW Exclusion and Avoidance 

Areas 

• Transportation and Travel 

Management Decisions 

• Designation of the INHT NTMC 

• Acres affected by land withdrawals 

• Acres affected by ACEC 

designations 

• Extent of vegetation communities 

identified for avoidance of surfacedisturbing actions, monitoring, 

reclamation, restoration and 

mitigation, and/or adherence to 

cited standards associated with 

other resource uses or 

designations 

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Section 3. Supplemental Impacts Analysis Appendix N: Supplemental Impact Analysis Information 

Assumptions 

The following assumptions were used to assess effects associated with vegetation. 

• Future human development proposals would be appropriately distributed in different vegetation 

community types in proportion to the abundance of those habitat types under the baseline 

conditions. 

• Adaptive management tools would be implemented to test, evaluate, and adjust the assumptions, 

objectives, actions, and subsequent on-the-ground results from the implementation of RMP 

decisions. This strategy would provide resource managers with the flexibility to respond quickly 

and effectively to changing resource and user conditions. 

Standard Operating Procedures and Best Management Practices 

The impact analysis below considers the SOPs and BMPs that could be implemented by the BLM. A 

comprehensive list of SOPs/BMPs pertaining to vegetation is provided in the BSWI RMP/EIS. 

3.2.3 Effects Analysis 

Management actions proposed for the following resources, resource uses, and special designations would 

not result in effects to vegetation: 

• Air Quality and AQRVs 

• Water Resources and Fisheries 

• Cultural Resources 

• Paleontological Resources 

• WSRs 

• Support for BSWI Communities 

• Hazardous Materials and Health and Human Safety 

Vegetation: Effects from Soils Management Actions 

In addition to management actions common to all action alternatives, potential impacts from the 

following management topics were considered: 

• ROW Decisions 

• Floodplains and Springs 

In general, actions that minimize impacts to soils, such as by reduction in direct disturbance and 

minimization of erosion, also directly and indirectly minimize impacts to vegetation. 

Effects under Alternative A 

Restrictions for surface-disturbing actions in the vicinity of floodplains and springs would simultaneously 

minimize impacts to vegetation in these areas, though no specific restrictions for impacts in these areas 

are listed in existing management plans. 

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Appendix N: Supplemental Impact Analysis Information Section 3. Supplemental Impact Analysis 

Effects Common to All Action Alternatives 

Actions to reduce impacts to permafrost areas under all alternatives would simultaneously reduce impacts 

to vegetation. Requirements for minimization of surface disturbance and reclamation or restoration after 

surface-disturbing activities would also reduce vegetation removal and/or mitigate impacts of vegetation 

removal. Minimization of disturbance to riparian communities as an erosion control measure would 

minimize impacts to vegetation in these areas. Coordinating with USFWS to sustain and strengthen 

landscape-level ecosystem resiliency through managing connectivity of neighboring NWRs would also 

minimize potential impacts to vegetation from surface-disturbing actions. 

Effects under Alternative B 

Permafrost areas would be ROW exclusion areas, which would eliminate potential removal or damage of 

vegetation due to ROW activities in these areas. Restrictions of surface-disturbing activities within 100-

year floodplains and within 100 feet of natural springs would eliminate potential removal or damage of 

vegetation due to surface-disturbing activities in these areas. 

Effects under Alternative C 

Permafrost areas would be ROW avoidance areas, which would reduce potential removal or damage of 

vegetation due to ROW activities in these areas, though some impacts could still occur if avoidance is not 

possible. Permitting of surface-disturbing activities in the vicinity of floodplains and natural springs on a 

case-by-case basis could allow some minimization of impacts to vegetation in these areas. 

Effects under Alternative D 

ROW authorization in permafrost areas on a case-by-case basis could allow some minimization of 

impacts to vegetation in these areas. 

Vegetation: Effects from Vegetation Management Actions 

In addition to management actions common to all action alternatives, potential impacts from the 

following management topics were considered: 

• SSS Flora and Lichen Areas (Caribou Habitat) – Travel Management Decisions 

• BLM-Permitted Surface Disturbance 

• Seeding and Planting for Reclamation or Restoration 

Vegetation management actions would generally minimize impacts of surface-disturbing actions on 

vegetation communities and SSS flora and their habitats. The BLM would continue to protect SSS flora in 

accordance with BLM Manual 6840 under all alternatives. 

Effects under Alternative A 

Existing land use plans provide some restrictions for surface-disturbing actions in floodplains, wetlands, 

riparian areas, threatened and endangered plant habitat, and caribou habitat (lichen-rich areas) and 

provide guidance for sustainable yield of forest resources that would minimize impacts of these actions on 

vegetation communities and SSS flora. Restrictions are inconsistent between plan areas and do not 

provide specific actions. 

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Section 3. Supplemental Impacts Analysis Appendix N: Supplemental Impact Analysis Information 

Effects Common to All Action Alternatives 

Conservation and maintenance of areas near NWRs and connectivity corridors would minimize impacts 

of surface-disturbing actions on vegetation in these areas. Implementation of a monitoring plan for 

vegetation, including rare ecosystems, would benefit vegetation by identifying areas appropriate for rapid 

restoration response actions in identified degraded areas. Prioritization of restoration and mitigation in 

riparian zones, lichen-rich habitat, SSS flora habitat (including BLM sensitive plant species habitat or rare 

ecosystems), HVWs, and areas with potential for permafrost degradation would reduce impacts from 

other actions in these areas. Rerouting, restoring, hardening, or closing unauthorized OHV trails 

(especially in wetlands or permafrost areas) would reduce further impacts in these areas and provide 

opportunities for reestablishment of vegetation. 

Requirements for reclamation in surface disturbance areas and burned areas would generally minimize 

impacts to vegetation communities from these actions or events, as some degree of vegetation 

reestablishment would occur after disturbance (with specifics developed during individual project 

permitting). Avoidance of ROW authorization in tundra areas; requirements for preservation of tundra 

mats, vegetative mats, and topsoil for use in reclamation; and specific reclamation cover requirements 

would reduce long-term impacts to vegetation in areas subject to surface disturbance. Utilizing existing 

roads and trails where feasible would minimize direct loss of vegetation from construction of new roads 

and trails. Avoiding the use of heavy equipment and overland travel in snow-free months and avoidance 

of creation of new roads and trails in wetlands and floodplains would minimize the adverse effects of 

these actions on vegetation, particularly in tundra areas and wetlands. 

Effects under Alternative B 

OHV use limitations, trail relocation, trail hardening, or trail closure implemented to reduce or eliminate 

degradation to SSS flora habitats (including dwarf shrub and lichen habitats [approximately 2,711,156 

acres; or 20 percent of BLM-managed land in the planning area] or sparse vegetation types 

[approximately 139 acres; less than 1 percent of BLM-managed land in the planning area]) would protect 

vegetation in these areas from further degradation. Survey requirements in SSS flora habitat and 300-foot 

avoidance buffers would protect SSS flora and other vegetation in these areas. Approximately 65 acres of 

BLM-managed land in the planning area (less than 1 percent) are within 300 feet of known locations of 

BLM sensitive plant species; additional acreages would be protected if new populations were located 

during project-specific surveys. Avoiding limestone or serpentine geologic substrate areas could also 

provide protections for SSS flora and other vegetation that occur on these features. 

Requirements for use of native and ecologically adapted species (i.e., species that are well-suited to the 

ecological conditions of an area) for reclamation or restoration are likely to reduce impacts to vegetation 

(in terms of changes to community composition and function) from surface-disturbing activities or fire in 

reclaimed or restored areas. 

Effects under Alternative C 

Under Alternative C, OHV use limitations in SSS flora habitats (including dwarf shrub and lichen 

habitats or sparse vegetation types) would be the same as under Alternative B. Survey requirements in 

SSS flora habitat and 100-foot setback buffers would minimize or eliminate impacts to SSS flora and 

other vegetation in these areas. Approximately 7 acres of BLM-managed land (less than 1 percent) are 

within 100 feet of known locations of BLM sensitive plant species; restrictions would be implemented on 

additional acreages if new populations are located during project-specific surveys. 

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Appendix N: Supplemental Impact Analysis Information Section 3. Supplemental Impact Analysis 

Requirements for use of native and ecologically adapted species where available for reclamation or 

restoration would preserve the integrity of vegetation communities in reclaimed or restored areas, thereby 

reducing impacts to vegetation from surface-disturbing activities or fire. The allowed use of nonnative 

seed and propagules where native species are not available or unable to establish could result in changes 

to vegetation community composition and function as compared to pre-disturbance or pre-fire conditions. 

Overall, protection for SSS flora and other vegetation would be lower than under Alternative B. 

Effects under Alternative D 

No OHV use limitations would be implemented in SSS flora habitats and lichen areas if these areas 

become degraded by OHV use and therefore these areas could be subject to further degradation. Survey 

requirements in SSS flora habitat and case-by-case avoidance and minimization measures could minimize 

some impacts to SSS flora and other vegetation in these areas. Requirements that propagules used in 

restoration or reclamation be suited to existing climatic condition and ecosystem function could increase 

the success of disturbed area revegetation, though restoration could result in changes to vegetation 

community composition and function as compared to pre-disturbance or pre-fire conditions. Overall, 

minimization of impacts to SSS flora and other vegetation from surface-disturbing actions would be 

lower for Alternative D than under the other action alternatives. 

Vegetation: Effects from Wildlife Management Actions 

In addition to management actions common to all action alternatives, potential impacts from the 

following management topics were considered: 

• Caribou and Moose 

• Innoko Bottoms Priority Wildlife Habitat Area 

• Connectivity Corridors 

• Migratory Bird 

• Raptor 

In general, measures that reduce impacts of surface-disturbing activities in wildlife habitat would 

simultaneously reduce impacts in the vegetation that composes this habitat. The BLM would continue to 

manage habitat for special status wildlife species as directed by national or State policy or through 

conservation agreements under all alternatives. 

Effects under Alternative A 

Continued implementation of protections for wildlife species (predominantly Endangered Species Act 

[ESA]-listed species, BLM sensitive species, rare habitats, subsistence resources, and migratory birds and 

their habitats) would also reduce impacts of surface-disturbing actions on vegetation and SSS flora in 

areas of habitat for these species. Restrictions of impacts on wildlife under Alternative A, and thus, 

associated minimization of impacts on vegetation and SSS flora, are less extensive and less specific than 

under the action alternatives. 

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Section 3. Supplemental Impacts Analysis Appendix N: Supplemental Impact Analysis Information 

Effects Common to All Action Alternatives 

Under all action alternatives, management actions and BMPs/SOPs to minimize impacts on wildlife 

species and their habitats from surface-disturbing actions would also minimize impacts on vegetation and 

SSS flora in these areas. 

Effects under Alternative B 

Restrictions of impacts on vegetation that would occur in association with restrictions of impacts on 

wildlife species and their habitats would be the most extensive under this alternative. Management under 

Alternative B would provide the greatest extent and magnitude of minimization of impacts to caribou and 

moose calving and wintering habitats, the Innoko Bottoms Priority Wildlife Habitat Area, connectivity 

corridors, riparian habitat, raptor nesting habitat, and other migratory bird habitat that would minimize 

impacts from various surface-disturbing actions. As such, concurrent minimization of impacts to 

vegetation would be highest under this alternative. 

Effects under Alternative C 

Restrictions of impacts on vegetation that would occur in association with restrictions of impacts on 

wildlife species and their habitats would be less extensive than under Alternative B, as minimization of 

impacts in caribou and moose calving and wintering habitats, the Innoko Bottoms Priority Wildlife 

Habitat Area, connectivity corridors, riparian habitat, raptor nesting habitat, and other migratory bird 

habitat would be less stringent. However, minimization of impacts would still be more extensive than 

under Alternatives A and D. 

Effects under Alternative D 

The management under Alternative D would provide the lowest extent and magnitude of minimization of 

impacts to wildlife and SSS, as it would have the fewest restrictions on resource uses and would minimize 

impacts from surface-disturbing actions within the smallest extent of habitat. As such, concurrent impacts 

to vegetation would be greatest under this alternative. 

Vegetation: Effects from Nonnative Invasive Species Management Actions 

There are no alternative-specific management actions for this resource; therefore, impacts from 

Alternatives B, C, and D are discussed in combination below. 

Effects under Alternative A 

NNIS, including noxious weeds, would continue to be managed under State and federal laws and policy. 

Effects Common to All Action Alternatives 

As under Alternative A, NNIS, including noxious weeds, would continue to be managed under State and 

federal laws and policy. Additional NNIS control and eradication measures required for actions on BLM 

lands would minimize the establishment and spread of NNIS infestations. These measures would provide 

more stringent NNIS management and therefore minimize the impact of these species on vegetation and 

SSS flora to a greater degree than under Alternative A. 

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Appendix N: Supplemental Impact Analysis Information Section 3. Supplemental Impact Analysis 

Vegetation: Effects from Wildland Fire Management Actions 

There are no alternative-specific management actions for this resource; therefore, impacts from 

Alternatives B, C, and D are discussed in combination below. 

Effects under Alternative A 

Limited use of wildland fire and fuels treatments would continue to occur in order to meet resource 

objectives, including those for vegetation management. Wildland fire and fuels treatments, when they 

occur, would adversely impact vegetation in the local area over the short term but would also reduce the 

potential spread of catastrophic wildland fires, thereby minimizing the effects of these fires on vegetation. 

Wildland fire and fuels treatments would also support maintenance of appropriate vegetation community 

successional stages, which would reduce potential negative impacts of wildland fires on vegetation in the 

planning area and increase the health of vegetation communities over the long term. 

Effects Common to All Action Alternatives 

Impacts of wildland fire and fuels treatments would be the same as under Alternative A. 

Revegetation actions (including for fire recovery) would be employed with varying requirements under 

the action alternatives, as analyzed in Vegetation: Effects from Vegetation Management Actions. 

Vegetation: Effects from Visual Resources Management Actions 

In addition to management actions common to all action alternatives, potential impacts from the 

following management topics were considered: 

• VRM Class I 

• VRM Class II 

• VRM Class III 

• VRM Class IV 

In general, VRM designation provides some level of minimization of impacts from certain actions on 

vegetation in designated areas. 

Effects under Alternative A 

The Unalakleet Wild River Corridor would continue to be designated as VRM Class I and impacts to 

vegetation in these areas associated with implementation of transportation or utility projects or 

authorizations of other ROWs would continue to be minimized or eliminated. No other areas would be 

assigned VRM designations. 

Effects Common to All Action Alternatives 

Under all action alternatives, existing vegetation would be retained as much as possible when 

implementing proposed actions, and disturbed areas would be restored or reclaimed as closely as possible 

to previous conditions. These requirements would minimize impacts to vegetation communities and SSS 

flora habitats as compared to Alternative A. 

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Section 3. Supplemental Impacts Analysis Appendix N: Supplemental Impact Analysis Information 

Effects under Alternative B 

VRM designations under this alternative would restrict changes to characteristic landscapes in most of the 

planning area to within the range of natural ecological changes (VRM Class I; approximately 1,335,771 

acres or 10 percent of BLM-managed lands in the planning area) or low-level changes (VRM Class II; 

approximately 6,490,087 acres or 48 percent of BLM-managed lands in the planning area). Smaller areas 

would be designated where moderate changes (VRM Class III; approximately 3,516,066 acres or 

26 percent of BLM-managed lands in the planning area) and high-level changes (VRM Class IV; 

approximately 2,123,971 acres or 16 percent BLM-managed lands in the planning area) to the 

characteristic landscape are allowed. As such, VRM-associated impacts to vegetation in the planning area 

would be less extensive than under all other alternatives. 

Effects under Alternative C 

VRM designations under this alternative would designate 46,953 acres (less than 1 percent of the 

planning area) as VRM Class I where changes to characteristic landscapes would be restricted to within 

the range of natural ecological changes and 2,766,229 acres (21 percent of BLM-managed lands in the 

planning area) as VRM Class II where low levels of change would be allowed. Moderate change would 

be allowed (VRM Class III) over approximately 6,095,778 acres or 42 percent of BLM-managed lands in 

the planning area, and high-level change (VRM Class IV) over approximately 4,556,934 acres or 

34 percent of BLM-managed lands in the planning area. VRM designations under this alternative would 

result in a greater degree of impacts to vegetation than under Alternative B. 

Effects under Alternative D 

VRM designations under this alternative would designate 46,953 acres (less than 1 percent of the 

planning area) as VRM Class I where changes to characteristic landscapes would be restricted to within 

the range of natural ecological changes and 679,553 acres (5 percent of BLM-managed lands in the 

planning area) as VRM Class II where low levels of change would be allowed. Moderate visual change 

(VRM Class III) would be allowed over approximately 6,140,235 acres or 46 percent of BLM-managed 

lands in the planning area, and high-level change (VRM Class IV) over approximately 6,599,152 acres or 

49 percent of BLM-managed lands in the planning area. VRM designations under this alternative would 

result in a greater degree of impacts to vegetation than under Alternative B or C. 

Vegetation: Effects from Lands with Wilderness Characteristics Management Actions 

In addition to management actions common to all action alternatives, potential impacts from the 

following management topics were considered: 

• Acres and Areas Managed to Protect Wilderness Characteristics as a Priority Over Other 

Resource Values and Multiple Uses 

• Acres and Areas Managed to Emphasize Other Resource Values and Multiple Uses While 

Applying Management Restrictions to Reduce Impacts on Wilderness Characteristics 

In general, lands managed according to the above two designations would avoid or minimize impacts to 

vegetation to some level. 

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Appendix N: Supplemental Impact Analysis Information Section 3. Supplemental Impact Analysis 

Effects under Alternative A 

Under Alternative A, no specific objectives are outlined for protection of wilderness characteristics that 

would minimize impacts to vegetation, though maintenance of an area’s existing natural conditions 

(which would include vegetation communities and SSS flora habitats) is stated as a goal under the 

SWMFP. 

Effects Common to All Action Alternatives 

There are no effects common to all action alternatives, because areas managed for wilderness 

characteristics as a priority are only identified under Alternative B. The alternatives would vary in terms 

of area of lands managed for wilderness characteristics, area of lands managed to emphasize resource 

values and multiple uses, and the extent and magnitude of management restrictions in these areas that 

could reduce the potential for impacts to vegetation from various land uses. 

Effects under Alternative B 

Under Alternative B, approximately 277,489 acres (2 percent of BLM lands in the planning area) would 

be managed to protect wilderness characteristics as a priority and would reduce the potential for impacts 

to vegetation and SSS flora in these areas through restrictions on OHV use, wood cutting, and mineral 

entry and surface occupancy. These restrictions would be more specific and enforceable than goals 

outlined for wilderness areas under Alternative A. 

Most of BLM-managed lands in the planning area (approximately 12,040,490 acres; 89 percent) would be 

managed to emphasize other resource values and multiple uses while applying management restrictions to 

reduce impacts on wilderness characteristics. Potential impacts to vegetation in the remaining BLMmanaged lands in the planning area could occur in association with any management decisions beyond 

basic State and federal regulations. 

Effects under Alternative C 

The nature and type of effects under this alternative would be the same as described under Alternative B, 

though no areas would be managed for wilderness characteristics as a priority. Approximately 8,105,942 

acres (60 percent) would be managed to emphasize other resource values and multiple uses while 

applying management restrictions to reduce impacts on wilderness characteristics. Potential impacts to 

vegetation in the remaining approximately 5,360,168 acres (40 percent) would not be minimized in 

association with any management decisions beyond basic State and federal regulations. Overall, 

protection for vegetation in association with lands with wilderness characteristics protection areas would 

be lower under this alternative than under Alternative B. 

Effects under Alternative D 

Under Alternative D, no land would be identified as lands managed for wilderness characteristics as a 

priority or managed to emphasize other resource values and multiple uses while applying management 

restrictions to reduce impacts on wilderness characteristics. Similar to Alternative A, there would be no 

beneficial effects to vegetation associated with management pertaining to lands with wilderness 

characteristics. 

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Section 3. Supplemental Impacts Analysis Appendix N: Supplemental Impact Analysis Information 

Vegetation: Effects from Forestry and Woodland Products Management Actions 

In addition to management actions common to all action alternatives, potential impacts from the 

following management topics were considered: 

• Permitted Commercial Woodland Harvesting Areas 

• Personal Use and Subsistence Woodland Harvest Areas 

• Woodland Harvest in HVWs 

• Woodland Harvest in the INHT NTMC 

• Woodland Harvest in ACECs 

• Forestry BMPs for Commercial Activities 

Vegetation can be directly impacted by woodland harvest actions by removal of individual plants or parts 

of plants, crushing, or large-scale removal of forests, or indirect impacts through human movement 

through an area (e.g., soil disturbance, transportation of NNIS and other plant propagules in a way that 

alters species ranges and/or vegetation community compositions). Higher intensity impacts would occur 

as a result of commercial harvest, which may remove all vegetation and disturb soils. Lower intensity 

impacts would occur with personal use and subsistence woodland harvest, which would generally remove 

smaller amounts of vegetation and have less of an impact on soils. 

Effects under Alternative A 

Under Alternative A, most of the planning area (approximately 10,237,555 acres or about 76 percent of 

the planning area) would be open to commercial harvest permits on a case-by-case basis and 

approximately 1,644,588 acres (about 12 percent of the planning area) would be open for commercial 

harvest. Allowing for flexibility in restrictions would retain accessibility for commercial harvest. For 

subsistence and casual uses, all 13,465,894 acres of BLM-managed land in the planning area would be 

available on a case-by-case basis, allowing for continued access for house log and fuel wood harvesting. 

As such, impacts to vegetation from all types of woodland harvest on vegetation would be the most 

extensive under this alternative. 

Effects Common to All Action Alternatives 

Requirements to minimize the effects of harvest action on vegetation and SSS flora include requiring 

timber harvest to occur during the winter, requiring surveys for sensitive species (including SSS flora) for 

surface-disturbing harvest actions, and restoration of disturbed areas. These actions would minimize 

impacts to vegetation and SSS flora associated with harvest activities to a greater degree than under 

Alternative A. 

Effects under Alternative B 

Under Alternative B, approximately 8,418,904 acres (63 percent of the planning area) would be available 

for commercial woodland harvest and an additional 29,829 (less than 1 percent of the planning area) 

would be available for commercial woodland harvest on a case-by-case basis. Timber sale operations and 

woodland harvest would not be allowed within the 100-year floodplain of perennial rivers and streams. 

All 13,465,894 acres of BLM-managed land in the planning area would be open to subsistence and 

personal use gathering of woodland product, though permits would be required when gathering more than 

that required for incidental use. Non-subsistence house log harvest would also be prohibited in site3-52 
 

 

 

 

 

 

 

 

 

 

Appendix N: Supplemental Impact Analysis Information Section 3. Supplemental Impact Analysis 

specific areas to protect sensitive resources such as in HVWs, the riparian zone of perennial streams, and 

some ACECs (total of approximately 9,332,481 acres or 69 percent of the planning area). As a result, 

associated impacts to vegetation due to commercial, subsistence, or personal use woodland harvest would 

be less extensive and of a lower magnitude than under Alternative A. 

Effects under Alternative C 

Under Alternative C, 9,811,727 acres (about 73 percent of the planning area) would be open to 

commercial woodland harvest by permit with an additional 3,607,214 acres (about 27 percent of the 

planning area) available on a case-by-case basis. Timber sale operations would not be allowed within the 

100-year floodplain of perennial rivers and streams. Although the number of acres closed to harvest 

would be greater than under Alternative A, classifying a larger area as available for harvest, rather than on 

a case-by-case basis, could increase easily accessible acres for commercial harvest. Subsistence use 

gathering of products would not require a permit in most of the planning area (13,423,449 acres, nearly 

the entire planning area), thus increasing ease of access for subsistence use. Personal use gathering of 

woodland product would require a permit but would be available, providing flexibility. Non-subsistence 

house log harvest would be prohibited on 3,044,073 acres (or about 23 percent of the planning area), 

providing site-specific restrictions on harvest. Restrictions for woodland harvesting would be lower under 

this alternative than Alternative B, which could allow for greater direct and indirect impacts to vegetation 

due to harvest activities. 

Effects under Alternative D 

Under Alternative D, commercial harvest area would include 13,423,449 acres (nearly 100 percent of the 

planning area), maximizing the number of accessible acres for harvest. Personal use and subsistence 

gathering would not require a permit, providing maximum acres accessible for those uses. As restrictions 

for woodland harvesting would be lower under this alternative than all other alternatives, the greatest 

potential direct and indirect vegetation impacts could occur due to harvest activities. 

Vegetation: Effects from Grazing Management Actions 

In addition to management actions common to all action alternatives, potential impacts from the 

following management topics were considered: 

• Areas Open/Closed to Grazing 

• Utilization 

Impacts to vegetation from domestic livestock (reindeer) grazing include removal of lichen and biomass 

of other plants, trampling, transportation of plant propagules, and soil disturbance. Reindeer grazing also 

modifies composition of vegetation communities in complex ways based on community type and local 

topography (Pajunen et al. 2008). Requirements such as those for conducting rangeland health 

assessments to determine compliance with Alaska Land Health Standards would be applied under all 

alternatives to reduce impacts to vegetation in permitted grazed areas. 

Effects under Alternative A 

A total of approximately 13,304,555 acres of BLM-managed land in the planning area (about 99 percent) 

would potentially be open to grazing, and vegetation in these areas could be subject to grazing impacts. 

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Section 3. Supplemental Impacts Analysis Appendix N: Supplemental Impact Analysis Information 

No specific utilization levels are assigned; therefore, it is not possible to quantify specific impacts to 

vegetation due to grazing under this alternative. 

Effects under Alternative B 

BLM-managed lands in the planning area would be closed to domestic livestock grazing; therefore, 

impacts to vegetation from livestock grazing would not occur. 

Effects under Alternative C 

Domestic livestock grazing would be permitted in areas determined to have ecological conditions that 

support grazing within approximately 7,742,975 acres (about 58 percent) of BLM-managed lands in the 

planning area. Grazing would result in some impacts to vegetation due to forage utilization, trampling, 

transportation of plant propagules, and soil disturbance. Forage utilization would be managed at a 

maximum threshold of Grazing Class 4 (50–75 percent of lichen utilized), which could result in visible 

reductions in lichen cover, though not enough to inhibit regeneration (Swanson and Barker 1992). 

Restricting grazing in areas with important fish and watershed values in the Nulato River watershed, the 

Unalakleet Wild River Corridor, the INHT NTMC, and HVWs (allowed on a case-by-case basis only 

after riparian standards are developed) would protect vegetation in these areas from the effects of 

domestic livestock grazing. Impacts to vegetation under this alternative would be greater than under 

Alternative B, which would not permit livestock grazing. Comprehensive Grazing Management Plans or 

Range Conservation Plans required to be developed and submitted with permit applications would specify 

practices and mitigations to minimize impacts to vegetation. 

Effects under Alternative D 

Effects would be similar to those described under Alternative C, though grazing could be permitted on a 

case-by-case basis over the entire planning area, and therefore could affect a larger geographic extent. 

Livestock grazing would not be excluded from the Nulato River watershed, the Unalakleet Wild River 

Corridor, the INHT NTMC, and HVWs unless it is determined that the proposed permitted grazing is 

inconsistent with maintenance of the values for which these areas were designated or recognized as 

important. Forage utilization would be managed at a maximum threshold of Grazing Class 5 (75 to 

100 percent of lichen utilized), which could result in visible trampling, craters, and reductions in lichen 

cover, though not enough to inhibit regeneration (Swanson and Barker 1992). Overall, impacts to 

vegetation under this alternative due to livestock grazing would be greater than under Alternative B or C, 

as greater acreages would be available for livestock grazing and proposed utilization thresholds would be 

higher. 

Vegetation: Effects from Locatable and Salable Minerals Management Actions 

In addition to management actions common to all action alternatives, potential impacts from the 

following management topics were considered: 

• Locatable Mineral Withdrawals 

• Salable Mineral Withdrawals 

Impacts to vegetation from mineral exploration, location, development, and extraction would include 

complete removal of plants in surface disturbance areas, as well as indirect impacts such as ecosystem 

degradation due to increased dust creation and deposition, increased erosion and changes to erosional 

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Appendix N: Supplemental Impact Analysis Information Section 3. Supplemental Impact Analysis 

patterns, and increased fragmentation of vegetation communities and habitat for SSS flora. Closing or 

withdrawing areas to locatable and/or salable mineral withdrawals would occur to varying degrees under 

the alternatives. In general, closing or withdrawing areas from minerals actions would eliminate effects to 

vegetation associated with these types of actions. 

Effects under Alternative A 

Under Alternative A, impacts to vegetation from locatable and salable mineral development could occur 

on 8,661,406 acres (about 64 percent of BLM-managed land in the planning area) which would remain 

open to both locatable and salable mineral development. However, impacts would be most likely to occur 

on the 294,325 acres of medium or high LMP (about 2 percent) that would remain open to mineral entry. 

Effects Common to All Action Alternatives 

Reclamation or restoration would be required in areas subject to surface disturbance, which would 

minimize some of the effects of these actions on vegetation communities. No specific SOPs or BMPs 

relate to vegetation management in lands that are authorized for locatable or salable minerals actions, 

though it is required that authorized projects are designed and located to minimize development 

footprints, which would reduce direct and indirect impacts to vegetation. 

Effects under Alternative B 

Under Alternative B, impacts to vegetation from locatable and salable mineral development could occur 

on 3,623,397 acres (about 27 percent of BLM-managed land in the planning area) which would remain 

open to both locatable and salable mineral development. However, impacts would be most likely to occur 

on the 202,610 acres of medium or high LMP (about 2 percent) that would remain open to mineral entry. 

Therefore, Alternative B would result in the smallest extent (acreage) of impacts to vegetation and SSS 

flora as compared to other alternatives. 

Effects under Alternative C 

Under Alternative C, impacts to vegetation from locatable mineral development could occur on 

13,418,941 acres (over 99 percent of BLM-managed land in the planning area) and 13,1823,85 acres 

(about 98 percent of BLM-managed land in the planning area) which would remain open to locatable 

mineral development and salable mineral development (including on a case-by-case basis). All areas of 

medium or high LMP would be open locatable mineral entry, and therefore impacts to vegetation (as 

described above) could occur in association with minerals entry activities in these areas. Management 

under Alternative C could result in greater impacts to vegetation than under Alternatives A and B due to 

the lack of acres withdrawn in medium or high LMP. 

Effects under Alternative D 

Impacts to vegetation under Alternative D would be the same as under Alternative C. 

Vegetation: Effects from Leasable Minerals Management Actions 

In addition to management actions common to all action alternatives, potential impacts from the 

following management topics were considered: 

• Areas Identified as Closed to Leasing and Open to NSO Leasing 

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Section 3. Supplemental Impacts Analysis Appendix N: Supplemental Impact Analysis Information 

As with locatable and salable minerals, impacts to vegetation from standard stipulation leasable minerals 

actions would include complete removal of plants in surface disturbance areas, as well as indirect impacts 

such as ecosystem degradation due to increased dust creation and deposition, increased erosion and 

changes to erosional patterns, and increased fragmentation of vegetation communities and habitat for SSS 

flora. 

Effects under Alternative A 

The entire planning area would be open to oil and gas leasing unless already closed under other legal or 

regulatory requirements, such as peregrine falcon nesting habitat in the Unalakleet River drainage, raptor 

nesting areas in the Anvik River drainage, and various other areas with stipulations for protection of 

wildlife and other resources. Vegetation and SSS flora in areas open to oil and gas leasing could be 

impacted as described in the following subsection. 

Effects Common to All Action Alternatives 

Vegetation in areas open to leasable minerals actions could experience direct and indirect effects. 

Reclamation or restoration of vegetation in areas subject to soil disturbance would minimize some of the 

potential effects on vegetation in these areas. No specific SOPs or BMPs relate to vegetation management 

in lands that are authorized for leasable minerals actions, though it is required that authorized projects are 

designed and located to minimize development footprints, which would reduce direct and indirect impacts 

to vegetation. 

Effects under Alternative B 

Under Alternative B, 2,517,414 acres (19 percent of BLM-managed land in the planning area) would be 

open to leasing subject to standard stipulations which is less than the other alternatives. Therefore, 

management under Alternative B would allow the lowest amount of impacts to vegetation and SSS flora 

from the effects of minerals leasing under all alternatives. 

Effects under Alternative C 

Under Alternative C, approximately 6,594,906 acres of BLM-managed lands in the planning area (49 

percent) would be open to leasing subject to standard stipulations; therefore, management under 

Alternative C would allow a greater degree of potential impacts to vegetation than under Alternative B. 

Effects under Alternative D 

Under Alternative D, approximately 13,177,785 acres of BLM-managed lands in the planning area (98 

percent) would be open to leasing subject to standard stipulations; therefore, management under 

Alternative D would allow the greatest degree of potential impacts to vegetation of all action alternatives. 

Vegetation: Effects from Lands and Realty Management Actions 

In addition to management actions common to all action alternatives, potential impacts from the 

following management topics were considered: 

• ANCSA 17(d)(1) Withdrawals 

• FLPMA Withdrawals 

• Locatable and Leasable Mineral Withdrawals 

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Appendix N: Supplemental Impact Analysis Information Section 3. Supplemental Impact Analysis 

• FLPMA ROW Exclusion and Avoidance Areas 

• Wind Energy Development 

• Permits and Leases 

Authorization of ROWs could occur to varying degrees under the alternatives. ROW authorizations may 

result in a range of impacts to vegetation (including SSS flora populations and habitat), including 

temporary vegetation clearing and revegetation, crushing or permanent removal of vegetation (such as 

with construction of roads or facilities), or indirect impacts such as dust deposition. Impacts to vegetation 

would not occur in ROW exclusion areas and may not occur or would be minimized in avoidance areas. 

Disposal of lands would occur to varying degrees under the alternatives. The effects of disposals or 

exchanges of land on vegetation vary by the resources present in that land and the reason for the disposal 

or exchange but could range from no impact to permanent removal of vegetation. These impacts would 

not occur in areas unavailable for exchange or disposal. 

Effects under Alternative A 

Vegetation in the approximately 13,465,894 acres of land available for ROW authorization on a case-bycase basis (100 percent of BLM-managed lands in the planning area) could be impacted by ROW actions. 

Effects Common to All Action Alternatives 

Authorizations of ROWs and disposals of land could happen to varying extents for land under the action 

alternatives. No specific SOPs or BMPs relate to vegetation management in lands that are authorized as 

ROWs or subject to disposals, though it is required that authorized projects are designed and located to 

minimize development footprints, which would reduce direct and indirect impacts to vegetation. 

Effects under Alternative B 

Under Alternative B, vegetation in the approximately 3,176,977 acres of land open to ROW location 

(24 percent of BLM-managed lands in the planning area) could be impacted by ROW actions. Overall, 

management under Alternative B would result in the smallest degree of potential impacts to vegetation 

and SSS flora from ROW actions under the alternatives. 

Effects under Alternative C 

Under Alternative C, vegetation in the approximately 5,820,362 acres of land open to ROW location 

(43 percent of BLM-managed lands in the planning area) could be impacted by ROW actions. Overall, 

management under Alternative C would result in a greater degree of potential impacts to vegetation than 

under Alternative B. 

Effects under Alternative D 

Under Alternative D, vegetation in the approximately 8,234,323 acres of land open to ROW location 

(61 percent of BLM-managed lands in the planning area) and the additional 100,644 acres of land where 

ROW could be permitted on a case-by-case basis (less than 1 percent of BLM-managed lands in the 

planning area) could be impacted by ROW actions. Management under Alternative D would result in the 

greater degree of potential impacts to vegetation under the action alternatives. 

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Section 3. Supplemental Impacts Analysis Appendix N: Supplemental Impact Analysis Information 

Vegetation: Effects from Recreation and Visitor Services Management Actions 

There are no alternative-specific management actions that pertain to impacts to vegetation from recreation 

and visitor services; therefore, impacts from Alternatives B, C, and D are discussed in combination 

below. 

Effects under Alternative A 

Recreation in the planning area has the potential to impact vegetation via trampling by recreators. 

Trampling could occur in any vegetated area, including off-trail locations. The effects of trampling on 

vegetation (ranging from no effect to mortality of individual plants) depend on a variety of factors (e.g., 

type of vegetation, type of soil, frequency of trampling). The potential for adverse effects of trampling on 

vegetation could increase with increasing recreation use in the planning area over time. 

Effects Common to All Action Alternatives 

Impacts of recreation and visitor services management under all action alternatives would be the same as 

under Alternative A. 

Vegetation: Effects from Travel and Transportation Management Actions 

In addition to management actions common to all action alternatives, potential impacts from the 

following management topics were considered: 

• Vegetation and Wildlife Travel Management 

• All BSWI Lands Not Designated as Conservation System Units or Sensitive Resource Areas 

• Unalakleet Wild River Corridor Travel Management Decisions 

• INHT NTMC TMA 

• Rohn Site Travel Decisions 

• Lands Managed for Wilderness Characteristics TMA 

• Travel Management in ACECs 

OHV use can result in direct and indirect impacts to vegetation and SSS flora. Direct impacts may include 

crushing or removal of individual plants, and indirect impacts may include soil compaction, increased 

potential for soil erosion and sedimentation of waterways, increased potential for human-caused wildland 

fires, increased potential for transportation of plant propagules, and fragmentation of vegetation 

communities or habitat for SSS flora. Direct and indirect impacts to vegetation from OHVs would be 

minimized in areas where OHV is limited or prohibited. 

Effects under Alternative A 

Under Alternative A, no areas would be subject to OHV use limitations or prohibitions with the exception 

of the Unalakleet Wild River Corridor, which does not allow casual OHV use; therefore, vegetation 

throughout the planning area could be impacted by OHV use. 

Effects Common to All Action Alternatives 

Areas where OHV is limited or prohibited would vary under the alternatives. 

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Appendix N: Supplemental Impact Analysis Information Section 3. Supplemental Impact Analysis 

Effects under Alternative B 

Under Alternative B, the following OHV restrictions would apply: 

• Summer casual OHV access would be prohibited on approximately 565,955 acres (4 percent of 

BLM-managed lands in the planning area) 

• Summer subsistence OHV access would be prohibited on approximately 241,512 acres (2 percent 

of BLM-managed lands in the planning area) 

• Summer casual OHV access would be limited to existing trails on approximately 12,899,939 

acres (96 percent of BLM-managed lands in the planning area) 

• Summer subsistence OHV access would be limited to existing trails on approximately 324,443 

acres (2 percent of BLM-managed lands in the planning area) 

• Winter casual use would be restricted to snowmobiles only on approximately 13,465,894 acres 

(100 percent of BLM-managed lands in the planning area) 

• Winter subsistence use would be restricted to snowmobiles only on approximately 4,243,914 

acres (32 percent of BLM-managed lands in the planning area) 

Under Alternative B, the largest extent of lands would be subject to limitations or prohibitions of OHV 

use, and as such, this alternative would result in the smallest degree and extent of impacts to vegetation 

and SSS flora due to OHV use. Additionally, OHV use limitations or trail relocation, hardening, or 

closures would be implemented if monitoring shows degradation of SSS flora or lichen areas due to OHV 

use. Implementation of these measures would eliminate further impacts to vegetation in these areas. 

Effects under Alternative C 

Under Alternative C, the following OHV restrictions would apply: 

• Summer casual and subsistence OHV access would be prohibited on approximately 225,925 acres 

(2 percent of BLM-managed lands in the planning area) 

• Summer casual OHV access would be limited to existing trails on approximately 13,239,969 

acres (98 percent of BLM-managed lands in the planning area) 

• Summer subsistence OHV access would not be limited to existing trails on any BLM-managed 

lands in the planning area 

• Winter casual and subsistence use would be restricted to snowmobiles only on approximately 

3,097,798 acres (23 percent of BLM-managed lands in the planning area) 

The extent of lands subject to OHV use limitations or prohibitions would be smaller than under 

Alternative B; therefore, potential impacts to vegetation would be higher than under Alternative B. 

Requirements for OHV use limitations or trail relocation, hardening, or closures to address OHV-related 

degradation of SSS flora or lichen areas would be the same as under Alternative B. 

Effects under Alternative D 

Under Alternative D, the following OHV restrictions would apply: 

• Summer casual OHV access would be prohibited on approximately 225,925 acres (2 percent of 

BLM-managed lands in the planning area) 

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Section 3. Supplemental Impacts Analysis Appendix N: Supplemental Impact Analysis Information 

• Summer subsistence OHV access would not be prohibited on any BLM-managed lands in the 

planning area 

• Summer casual OHV access would be limited to existing trails on approximately 46,953 acres 

(less than 1 percent of BLM-managed lands in the planning area) 

• Summer subsistence OHV access would be limited to existing trails on approximately 225,925 

acres (2 percent of BLM-managed lands in the planning area) 

• Winter casual and subsistence use would be restricted to snowmobiles only on approximately 

225,925 acres (2 percent of BLM-managed lands in the planning area) 

The extent of lands subject to OHV use limitations or prohibitions would be the smallest of all the 

alternatives. Additionally, no measures to address OHV-related degradation of SSS flora or lichen areas 

would be required under this alternative. As such, potential impacts to vegetation due to travel and 

transportation management actions would be more extensive than under Alternatives B and C. 

Vegetation: Effects from Areas of Critical Environmental Concern Management Actions 

Potential impacts from the following management topics were considered: 

• Anvik Traditional Trapping Area ACEC 

• Anvik River Watershed ACEC 

• Gisasa River ACEC 

• Inglutalik River ACEC 

• Kateel River ACEC 

• Nulato River ACEC 

• Shaktoolik River ACEC 

• Sheefish ACEC 

• Swift River Whitefish Spawning ACEC 

• Tagagawik River ACEC 

• Ungalik River ACEC 

• Unalakleet River ACEC 

Designation of ACECs for protection of identified values (i.e., fisheries and/or cultural resources) would 

generally benefit adjacent vegetation through the prohibition of actions that could result in irreparable 

damage to these values. 

Effects under Alternative A 

Under Alternative A, approximately 1,884,376 acres of BLM-managed lands in the planning area (14 

percent) would continue to be managed as ACECs and impacts to vegetation in these areas would 

continue to be prohibited or minimized in association with protection of identified values within 

established ACECs. 

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Appendix N: Supplemental Impact Analysis Information Section 3. Supplemental Impact Analysis 

Effects Common to All Action Alternatives 

Varying sizes of ACECs would be designated under the action alternatives. 

Effects under Alternative B 

The greatest extent of ACECs would be designated under Alternative B (approximately 3,912,698 acres 

or 24 percent of BLM-managed land in the planning area); as such, impacts to vegetation would be 

prohibited or minimized in association with protections of fisheries and/or cultural resources. 

Effects under Alternative C 

As no ACECs would be designated under this alternative, impacts to vegetation would not be prohibited 

or minimized in association with protections of other resources that would occur with ACEC designation. 

Effects under Alternative D 

Impacts under Alternative D would be the same as under Alternative C. 

Vegetation: Effects from National Trails Management Actions 

In addition to management actions common to all action alternatives, potential impacts from the 

following management topics were considered: 

• INHT NTMC 

• VRM Decisions in the INHT NTMC Viewshed 

• FLPMA Withdrawals 

• Mineral Decisions in the INHT NTMC 

• Surface-Disturbing Activities and Other Realty Decisions 

• Forestry and Woodland Decisions in the INHT NTMC 

• Grazing Decisions in the INHT NTMC 

In general, designation of national trails corridors would minimize impacts to vegetation in these areas by 

prohibiting or limiting various impacts that could occur without trail designation, such as ROW 

authorization, commercial woodland harvest, livestock grazing, and minerals extraction. 

Effects under Alternative A 

Under Alternative A, the INHT NTMC would not be designated, and vegetation in this area could be 

impacted by various activities that could occur without trail designation. 

Effects Common to All Action Alternatives 

The INHT NTMC would be established, and certain surface-disturbing actions would be prohibited or 

limited within the corridor for this trail. These prohibitions or limitations vary by alternative and are 

associated with VRM designations, restrictions for surface-disturbing activities, woodland harvest, and 

grazing. 

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Section 3. Supplemental Impacts Analysis Appendix N: Supplemental Impact Analysis Information 

Effects under Alternative B 

Vegetation in the approximately 288,466-acre INHT NTMC (2 percent of BLM-managed lands in the 

planning area) would not be impacted by surface disturbance due to minerals exploration and 

development and ROW actions unless these uses would not conflict with the nature and purpose of the 

INHT. Commercial woodland harvest would be excluded in the INHT NTMC, which would also 

eliminate associated impacts to vegetation in these areas. Overall, designation of the INHT NTMC under 

this alternative would reduce impacts to vegetation from surface-disturbing activities in the trail corridor 

to the greatest degree of the alternatives. 

Effects under Alternative C 

Vegetation in the approximately 273,242-acre INHT NTMC (2 percent of BLM-managed lands in the 

planning area) could be subject to surface-disturbing impacts of minerals development (except leasable 

development) or ROW development if these uses are determined not visible or not in conflict with the 

nature and purpose of the INHT. Grazing-associated impacts to vegetation that would occur in other areas 

under this alternative would not occur in the INHT NTMC. Vegetation in the INHT NTMC could be 

impacted by commercial woodland harvest if authorized. Overall, designation of the INHT NTMC and 

associated management under this alternative would result in a lesser degree of minimization of impacts 

to vegetation than under Alternative B. 

Effects under Alternative D 

Vegetation in the approximately 273,242-acre INHT NTMC (2 percent of BLM-managed lands in the 

planning area) could be subject to surface-disturbing impacts of minerals development (including leasable 

development) or ROW development unless these uses would conflict with the nature and purpose of the 

INHT. Vegetation in the INHT NTMC would be subject to impacts from livestock grazing and woodland 

harvest. Overall, designation of the INHT NTMC and associated management under this alternative 

would result in the least degree of minimization of impacts to vegetation in this area than under other 

action alternatives. 

Vegetation: Effects from Climate Change 

This section presents analysis of how management actions would counteract cumulative climate change 

impacts to vegetation and SSS flora. Impacts to vegetation in the planning area as a result of anticipated 

climate change could be due to any of the following effects, or complex interactions thereof: 

• Increased temperatures 

• Permafrost thaw 

• Decreased snow cover (albedo effect), subnivean species impacts 

• Increased wildland fire intensity, size, and frequency 

• Increase in NNIS introduction or spread 

• Later freeze-up dates (river ice) 

• Sea level rise (salt intrusion, transportation changes) 

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Appendix N: Supplemental Impact Analysis Information Section 3. Supplemental Impact Analysis 

Generally, actions that protect or restore degraded vegetation could minimize effects of climate change on 

vegetation and other resources. Reclamation, restoration, or protection of vegetated areas would minimize 

the effects of climate change through such mechanisms as: 

• Sequestering carbon or allowing continued carbon sequestration 

• Protecting sensitive soils and permafrost 

• Maintaining or reestablishing habitat connectivity, including for SSS flora species 

Restoration actions that take changing environmental conditions into consideration are likely to be more 

successful in the long term and beneficial in terms of counteracting the cumulative effects of climate 

change on vegetation. Actions such as identifying the most appropriate species lists for revegetation (e.g., 

selecting for adaptability and genetic diversity in seeded/planted species) or locations for restoration 

projects using projected climate envelopes increase the beneficial value and long-term success of restored 

areas (Harris et al. 2006). Additionally, restoration actions that incorporate projected climate change 

information may be most beneficial in minimizing loss of vegetation species and habitat that are 

vulnerable to changing climate conditions. 

Effects under Alternative A 

No current management direction for reclamation or restoration related to climate change effects exists; 

therefore, the potential for restoration or protection of vegetation to counteract the cumulative effects of 

climate change would be minimal. Restoration actions that could occur under this alternative would not 

be required to adhere to standards for vegetation suitability to projected climate conditions and therefore 

the long-term success of reclamation or restoration efforts may be lower than under the action 

alternatives. 

Effects Common to All Action Alternatives 

Restoration or reclamation actions would be required for surface-disturbing activities under all action 

alternatives. Under all action alternatives, the BLM would use various monitoring and models to evaluate 

potential changes in vegetative communities and to adjust the identified management actions to shift with 

any changes in cover type. This adaptive management approach would help counteract cumulative 

climate change impacts. 

Effects under Alternative B 

Provisions for the reclamation, restoration, or protection of vegetation under the various resources and 

resource uses are highest under Alternative B. Reclamation or restoration actions would be required to use 

native species and adhere to standards for selecting seed sources based on adaptability to climate 

conditions and desired (future) ecosystem function, which would consider changing climate conditions. 

As such, this alternative would be the most beneficial in terms of counteracting the cumulative effects of 

climate change on vegetation. 

Effects under Alternative C 

Provisions for the reclamation, restoration, or protection of vegetation under the various resources and 

resource uses are less extensive than under Alternative B. Reclamation or restoration actions would be 

required to adhere to standards for selecting seed sources based on suitability to current climate 

conditions and desired (future) ecosystem function, though the use of native species would not be 

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Section 3. Supplemental Impacts Analysis Appendix N: Supplemental Impact Analysis Information 

mandated in all situations. As such, this alternative may be less beneficial in terms of counteracting the 

cumulative effects of climate change on vegetation than Alternative B. 

Effects under Alternative D 

Provisions for reclamation, restoration, or protection of vegetation under the various resources and 

resource uses would be the least extensive under Alternative D. Reclamation or restoration actions would 

be required to utilize species that are applicable for existing climatic condition and ecosystem function 

but would not be required to be suitable for desired (future) ecosystem function. Therefore, this 

alternative would be the least beneficial of the action items in terms of counteracting the cumulative 

effects of climate change on vegetation. 

Vegetation: Cumulative Effects 

Table 3.2.3-1 summarizes the results of the cumulative effects analysis for vegetation for all alternatives. 

Cumulative adverse effects on vegetation under the action alternatives would generally be less and 

beneficial effects greater than under Alternative A because of the increased restrictions under Alternatives 

B, C, and D. Cumulative effects under Alternative B would generally be less adverse and more beneficial 

than under the other alternatives. The degree of adverse incremental impact or benefit to vegetation is 

related to the relative levels of protections afforded under the various management alternatives. 

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Appendix N: Supplemental Impact Analysis Information Section 3. Supplemental Impact Analysis 

Table 3.2.3-1: Cumulative Effects Analysis for Vegetation 

Trends and Forecasts of 

Vegetation in Consideration of 

Past and Present Actions 

Trends and Forecasts of 

Vegetation in Consideration of 

Past, Present, and Reasonably

Foreseeable Future Actions 

(Alternative A) 

Trends and Forecasts of 

Vegetation in Consideration of 

Past, Present, and Reasonably

Foreseeable Future Actions 

(Alternative B) 

Trends and Forecasts of 

Vegetation in Consideration of 

Past, Present, and Reasonably

Foreseeable Future Actions 

(Alternative C) 

Trends and Forecasts of 

Vegetation in Consideration of 

Past, Present, and Reasonably

Foreseeable Future Actions 

(Alternative D) 

Vegetation communities in the Due to continued adherence to Continued adherence to State Continued adherence to State Continued adherence to State and 

planning area are maintaining State and federal regulations and federal regulations as well and federal regulations as well federal regulations as well as 

proper functioning condition. such as requirements for project- as the greatest restrictions to the as some restrictions to the some restrictions to the extents of 

Trends for special status plant 

species are unknown. 

Trend: No Change. 

specific NEPA analysis, impacts 

to SSS flora and vegetation 

communities are likely to be 

limited, though impacts are still 

extents of surface-disturbing 

actions would protect vegetation 

and SSS flora species and 

habitats to a greater extent than 

extents of surface-disturbing 

actions would protect vegetation 

and SSS flora species and 

habitats, though protections 

surface-disturbing actions would 

protect vegetation and SSS flora, 

though protections would be less 

extensive and potential surfacelikely to occur due to increasing all other alternatives, though would be less extensive and disturbing actions would be more 

resource use in the planning minimal impacts to vegetation potential surface-disturbing extensive than under Alternative B 

area. Construction and operation and SSS flora are still likely to actions would be more extensive or C. 

of the Donlin Gold Project would 

be expected to increase impacts 

to vegetation and SSS flora within 

the planning area, within the 

footprint of the Donlin Gold 

Project transportation corridor 

and mine site. The Donlin Gold 

Project construction and 

occur. 

Trend: Counter the existing

trend by resulting in increased

impacts to vegetation and SSS 

flora over time, though 

impacts would be less than 

under all other alternatives. 

than under Alternative B. 

Trend: Counter the existing

trend by resulting in increased

impacts to vegetation and SSS 

flora over time. 

Trend: Counter the existing

trend by resulting in increased

impacts to vegetation and SSS 

flora over time. 

operation would result in removal 

of vegetation for access and 

operations infrastructure and may 

impact habitat that supports SSS. 

Trend: Counter the existing

trend by resulting in increased

impacts to vegetation and SSS 

flora over time. 

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Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

3.3 Wildlife and Special Status Species 

3.3.1 Summary 

All resource uses on BLM-managed lands in the planning area have the potential to impact wildlife and 

SSS. Therefore, management actions for all resource uses also have the potential to affect wildlife or 

SSS to some extent and magnitude. Additionally, because wildlife habitat occurs over all of the planning 

area and is often interrelated with other resources, management actions and BMPs/SOPs specifically for 

other resources often have an incidental effect on wildlife and SSS or their habitat. Management actions 

that protect wildlife and SSS and their habitat are consistent with BLM priorities for conserving land and 

water (DOI 2018). All three action alternatives would provide additional protections and management 

actions for wildlife and SSS, including adaptive management to address climate change and watershedlevel cumulative impact analysis for proposed surface-disturbing activities. The management under 

Alternative B would provide the greatest extent and magnitude of protections to wildlife and SSS, 

followed by Alternative C. Alternative D would provide the lowest extent and magnitude of additional 

protections to wildlife and SSS, as it would have the fewest restrictions on most resource uses and would 

protect the least amount of habitat. Additionally, the BLM would not manage connectivity corridors 

under Alternative D, which would eliminate one aspect of long-term landscape level planning for 

wildlife and SSS. The BLM would continue to manage SSS wildlife species according to BLM Manual 

6840 under all alternatives. 

3.3.2 Methods of Analysis 

The direct and indirect impacts of management actions on wildlife and SSS resources may vary widely 

and are difficult to quantify without site-specific information on species and habitats present and the 

baseline condition of habitats and populations. Seasonal considerations are also important, as actions 

may affect wildlife to a greater or lesser degree depending on if they occur during the breeding season, 

migration or hibernation periods, periods when greater numbers of individuals may be present, periods 

when food or other habitat elements are scarce, or periods when vegetation and other habitat components 

are least resilient. 

Because of the large number of wildlife species in the planning area, this analysis focuses on key 

habitats and species and addresses the quantity and quality of available habitat, habitat connectivity and 

the degree to which habitat is fragmented, and what habitat protections and use restrictions would occur 

under each alternative. The quantitative analysis of alternatives focuses on species and habitats for which 

information is available (moose, caribou, bison, muskox, riparian areas) and on areas within the planning 

area where land uses with the greatest potential to impact wildlife (mineral development, ROWs, 

commercial forest harvest) are likely to occur. Additional qualitative descriptions are also included as 

appropriate. The impact analysis discusses applicable management actions for each resource and 

resource use and identifies whether they would result in the possible destruction, degradation, or 

modification of wildlife and SSS habitat, or would minimize these impacts from resource uses in the 

planning area. Habitat connectivity and landscape-level management through protection of connectivity 

corridors are discussed where pertinent. 

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Appendix N: Supplemental Impact Analysis Information Section 3. Supplemental Impact Analysis 

Potential Effects and Indicators 

Potential impacts to wildlife and SSS on BLM-managed lands in the planning area include disturbance, 

displacement, mortality, or injury of individuals; alteration, elimination, or fragmentation of habitat; 

reduction in availability of food and water; interference with breeding; reduction in reproductive success; 

and increased susceptibility to predation, among other possible impact mechanisms. Activities that 

involve surface disturbance, such as mineral development, can alter the structure, composition, and 

productivity of vegetation communities, which provide the foundation of wildlife habitats. Mineral 

development can also lead to new roads with the potential to fragment wildlife habitat and impede 

migration and other types of movement by species like moose, caribou, and bison. However, mining 

shafts and adits may provide habitat for bats. Mineral development is also associated with noise and 

human activity that may affect wildlife behavior and breeding success. Seismic surveys may impact 

wildlife habitat by removing vegetation and potentially creating new summer and winter OHV routes. 

Exploration can harm small mammals and nesting birds and can temporarily displace larger mammals 

such as caribou. 

Removal of forest and woodland products can modify habitats of forest-dwelling species by reducing the 

components of wildlife physical habitat and food sources. Domestic reindeer grazing has the potential to 

reduce available winter forage for caribou and may result in impacts to populations through inbreeding 

and transmission of disease. OHV use can degrade wildlife habitats through surface disturbance, crush 

nests and small terrestrial species, and lead to the creation of new trails that can cause an increase in 

human use. OHVs may also introduce NNIS, which could adversely impact wildlife habitat. ROW 

development can lead to habitat loss, degradation, and fragmentation through vegetation removal over 

long linear areas. 

Management actions for wildlife and other resources and resource uses can affect wildlife by either 

allowing resource uses with the potential to impact wildlife and SSS and their habitat within the planning 

area or by implementing restrictions on those resource uses that prevent or reduce impacts to wildlife in 

certain areas. Based on the resource uses with the greatest potential to impact wildlife and SSS, 

management actions for mineral decisions, travel management, ROW, and commercial woodland harvest 

would have the greatest potential to affect wildlife and SSS. Management to create connectivity 

corridors to facilitate wildlife movement across the landscape would also have a high potential to affect 

wildlife and SSS. Management for other resources uses would have a lesser potential to affect wildlife 

and SSS. 

Table 3.3.2-1 summarizes the types of effects by management actions and the indicators used to compare 

the differences among alternatives. 

Assumptions 

The following assumptions were made to assess effects on wildlife and SSS: 

• Although wildlife and SSS may occur throughout the entire planning area, there are areas of 

higher concentration and/or higher value habitat within the planning area, such as riparian areas, 

Audubon Important Bird Areas, and the Innoko Bottoms area. Management actions in these 

areas may have a greater effect on wildlife compared to actions outside these areas. 

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Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

Table 3.3.2-1: Summary of Effects to Wildlife by Management Action 

Types of Effects Management Actions Indicators 

Potential changes in wildlife habitat use and • Connectivity Corridors • Areas where land uses that could 

migration patterns could result from land use 

development in the planning area, such as mineral • Mineral Decisions result in adverse impacts to wildlife 

habitat connectivity between known 

development, surface development, and ROW. • ROW decisions and/or protected habitat are not 

Such actions could result in the addition of • Travel and transportation permitted, as measured by 

structures (and potential lighting), vegetation management decisions number, size (acres), and/or 

removal (in ROW), and increased human location of connectivity corridor(s) 

presence. These habitat alterations could affect and the management measures 

the use of these areas for wildlife movement. associated with these geographic 

Connectivity corridors could limit these adverse areas (e.g., mineral entry, ROW). 

impacts by not allowing activities that could 

fragment habitat, particularly between known 

and/or otherwise protected habitat (e.g., NWRs). 

Human presence, vehicles, and surface-disturbing • Mineral decisions • Riparian areas (defined as areas 

activities associated with mineral development 

could result in habitat loss and/or disturbance to • ROW decisions within 300 feet of streams) in the 

planning area. 

migratory birds and other wildlife in riparian areas. 

Management actions that prohibit or limit mineral 

• Development in the 100-year 

floodplain • Riparian areas open to locatable 

and salable mineral development in 

development in riparian areas would reduce the • Mineral decisions within HVWs areas of medium to high mineral 

potential for adverse effects to the suite of species potential, as measured by overlap 

that use these habitats by removing the actions of riparian areas with areas of 

that cause the impacts or reducing their medium to high mineral potential. 

magnitude or extent. 

Noise, movement, and vegetation disturbance • Surface- and non-surface- • Areas where land uses that could 

from human presence, motorized vehicles, disturbing activity buffers result in adverse impacts to nesting 

aircraft, construction, and other activities 

associated with various resource uses in the • Permanent structures raptors are not permitted, as 

measured by the management 

vicinity of raptor nests can disturb breeding raptors • Campsite buffers measures associated with these 

and reduce reproductive success. • Aircraft use buffers geographic areas. 

Buffers around nesting raptors would limit the • Motorized ground vehicle use potential for adverse impacts by reducing noise buffers 

and human disturbance near nests. • Construction buffers 

OHV use, surface disturbance, commercial 

woodland harvest, and other human actions 

associated with various resource uses could 

impact wildlife and SSS through disturbance, and 

loss, degradation, and fragmentation of wildlife 

habitat. 

Management actions that prohibit or limit these 

human actions would reduce the potential for 

adverse effects by removing the human actions or 

reducing their magnitude and extent. 

• Mineral decisions 

• Commercial woodland harvest 

• ROW decisions 

• Travel decisions 

• Acres of the planning area in 

which there are no restrictions on 

mineral development, commercial 

woodland harvest, ROWs, and 

OHV use. 

• Acres of the planning area in 

which there are no restrictions on 

mineral development, commercial 

woodland harvest, ROWs, and 

OHV use, that overlap riparian 

areas; caribou, moose, wood 

bison, and muskox ranges; 

Audubon Important Bird Areas; 

and Innoko Bottoms. 

Changes in the effectiveness of wildlife habitat • Caribou and moose • Acres of the planning area 

management could result in a reduction or 

improvement of wildlife habitat quality on BLM 

lands by removing or adding protections that 

• Innoko Bottoms Priority Wildlife 

Habitat Area 

covered by protections that target 

key wildlife habitat: connectivity 

corridors, Innoko Bottoms, riparian 

target key wildlife habitats. • Connectivity corridors 

• Migratory birds 

• Raptors 

areas, caribou and moose calving 

and wintering areas, moose and 

caribou crucial winter habitat 

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Appendix N: Supplemental Impact Analysis Information Section 3. Supplemental Impact Analysis 

Types of Effects Management Actions Indicators 

Land status changes could result in increases in 

or loss of wildlife and SSS habitat managed by the 

BLM. Acquisitions, particularly of high-value 

habitat, can benefit wildlife by creating more 

contiguous blocks of habitat for management 

purposes. Disposals can fragment management of 

habitat and may impact wildlife if management by 

the new landowner is less protective of wildlife. 

Exchanges involve both acquiring land and 

disposing other lands in a transaction involving the 

BLM and another land owner. As such, an 

exchange can have beneficial or detrimental 

impacts for wildlife and high-value habitat. 

• Land acquisitions 

• Land exchanges and disposals 

•

• Acres of land acquisitions, 

disposals, and exchanges in the 

planning area. 

• Acres of land acquisitions, 

disposals, and exchanges that 

overlap riparian areas, the Innoko 

Bottoms Priority Wildlife Habitat 

Area, Audubon Important Bird 

Areas, caribou and moose calving 

and wintering areas, potential 

caribou migration habitat, wood 

bison range, and muskox range. 

Limiting or prohibiting OHV use would reduce the • Travel and transportation • Riparian areas protected as HVWs 

potential for impacts to wildlife and SSS from management decisions within that overlap caribou, moose, wood 

disturbance, habitat degradation, or direct HVWs bison, and muskox ranges; 

mortality to wildlife from vehicle-wildlife collisions. • SSS flora and lichen areas 

(caribou habitat) – travel 

Audubon Important Bird Areas; and 

Innoko Bottoms. 

management decisions • Acres of the planning area within 

• Unalakleet Wild River Corridor 

travel management decisions 

TMAs and the management 

measures associated with these 

geographic areas. • INHT NTMC TMA • • Lands managed for wilderness 

characteristics TMA – travel 

decisions 

Specific protections for lichens would reduce the • SSS flora and lichen areas • Acres of caribou habitat in planning 

potential for impacts to caribou from degradation (caribou habitat) – travel area with limitations on OHV use. 

caused by OHV use, as lichens are a key winter management decisions 

forage species. 

Limitations within TMAs would reduce the 

potential for loss, degradation, and fragmentation 

of wildlife and SSS habitats by limiting OHV use to 

certain areas or specific trails. 

• INHT TMA – OHV limitations 

• Lands with wilderness 

characteristics TMA – OHV 

limitations 

• Acres of the planning area within 

TMAs and the management 

measures associated with these 

geographic areas. 

Areas designated as VRM Class I or II would • VRM actions • Acres of VRM Class I and II. 

include limitations on vegetation manipulation that 

reduce the potential for impacts to wildlife species 

and SSS using that habitat. 

• Acres of VRM Class I and II that 

overlap riparian areas; caribou, 

moose, wood bison, and muskox 

ranges; Audubon Important Bird 

Areas; and Innoko Bottoms. 

Management of land for wilderness characteristics • Lands managed for wilderness • Acres of lands managed for 

as a priority would reduce the potential for impacts characteristics management wilderness characteristics. 

to wildlife and SSS within those areas because it 

would include measures to limit OHV use, facility 

development, wood harvest, and mineral 

development. 

actions • Acres of lands managed for 

wilderness characteristics that 

overlap riparian areas; caribou, 

moose, wood bison, and muskox 

ranges; Audubon Important Bird 

Areas; and Innoko Bottoms 

Designation of areas as ACECs would reduce the • ACEC designations • Acres of lands designated as 

potential for impacts to wildlife and SSS within ACECs. 

those areas because it would include measures 

that limit ROWs, commercial woodland harvest, 

mineral and other development, and OHV use, as 

well as additional management to prevent impacts 

to wildlife habitats. 

• Acres of lands designated as 

ACECs that overlap riparian areas; 

caribou, moose, wood bison, and 

muskox ranges; Audubon 

Important Bird Areas; and Innoko 

Bottoms. 

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Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

Types of Effects Management Actions Indicators 

Measures to protect WSR corridors would reduce 

the potential for impacts to wildlife and SSS within 

those areas, as they would include measures that 

limit development and vehicle/human disturbance 

in these areas. 

• Travel management decisions 

• UAS uses 

• Acres of land within WSR corridors. 

• Acres of lands within WSR 

corridors that overlap riparian 

areas; caribou, moose, wood 

bison, and muskox ranges; 

Audubon Important Bird Areas; and 

Innoko Bottoms. 

Seasonal use restrictions would reduce the 

potential for impacts to moose, caribou, and birds 

by preventing construction disturbances that might 

interfere with breeding or winter foraging of moose 

and caribou and by limiting/prohibiting activities 

that alter nesting habitat and disturb birds during 

the nesting season. 

• Caribou and moose – seasonal 

use restrictions 

• Migratory birds – surfacedisturbing activity 

• Acres of caribou and moose habitat 

covered by seasonal use 

restrictions. 

• Acres of migratory bird habitat 

covered by seasonal use 

restrictions 

• The BLM is primarily responsible for managing habitats. State and federal wildlife management 

agencies (e.g., ADF&G, USFWS) oversee management of wildlife species, although the BLM is 

the season manager for wildlife populations on federal lands for a subsistence priority. This 

analysis focuses on impacts to wildlife habitats. 

• Disturbance impacts to wildlife are evaluated by comparison to current management practices in 

the planning area; management actions proposed under the action alternatives that would reduce 

the potential for adverse impacts, whereas reduced protection compared to current management 

may increase the potential for adverse impacts. 

• Natural and prescribed fires are tools used to manage vegetative communities and can result in 

short-term adverse impacts with long-term beneficial impacts to wildlife and wildlife habitats. 

• Management actions aimed at benefiting specific wildlife species or groups (e.g., moose, 

caribou, raptors, migratory birds) can have adverse or beneficial impacts on other wildlife 

species or groups. 

• Wildlife is currently using the proposed connectivity corridors for movement and would 

continue to do so. 

• The BLM will use the best available information, management and conservation plans, and other 

research and related directives, as appropriate, to guide wildlife habitat management on BLMmanaged lands in the planning area. 

For many wildlife and SSS species, information on specific areas of occurrence and population size and 

trends is incomplete or unavailable. Therefore, the effects analysis for wildlife and SSS focuses on 

important wildlife habitats for which information is available. These include caribou calving and 

wintering habitat, moose calving and wintering habitat, Audubon Important Bird Areas, the Innoko 

Bottoms area, muskox range, and wood bison range. Riparian areas are also considered, although they 

have not been mapped for the planning area. Therefore, the quantitative analysis for riparian areas is 

based on river miles, which gives an approximate location of riparian areas, but not their complete 

coverage. 

Standard Operating Procedures and Best Management Practices 

The impact analysis below takes into account the SOPs and BMPs that could be implemented by the 

BLM, shown in the BSWI RMP/EIS. 

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Appendix N: Supplemental Impact Analysis Information Section 3. Supplemental Impact Analysis 

3.3.3 Effects Analysis 

Management actions proposed for the following resources, resource uses, and special designations would 

not result in effects to wildlife and are therefore not analyzed: 

• Paleontological Resources 

• Support for BSWI Communities 

Wildlife and Special Status Species: Effects from Air Quality and Air Quality-related 

Values Management Actions 

Air quality has the potential to affect animal health or the habitat quality of wildlife and SSS. In the 

planning area, these impacts are generally associated with short-term generation of dust, smoke, or other 

air pollution (e.g., mercury contamination from dust generated in mines). 

There are no alternative-specific management actions for this resource; therefore, impacts from 

Alternatives B, C, and D are described in combination below. 

Effects under Alternative A 

Under Alternative A, the BLM would continue to comply with all applicable regulations and standards 

for air quality, which would continue to keep impacts to wildlife and SSS from air quality short-term, 

localized, and negligible to minor. There would be no change in the indicators for this resource. 

Effects Common to All Action Alternatives 

Actions to improve or prevent degradation of air quality, particularly in and near VRM Class I and 

Class II areas, sensitive areas, sensitive receptors, urban interface areas, NLCS units, and areas that 

contain sensitive resources, would reduce the potential for localized air quality-related impacts to 

wildlife and SSS in these areas. Dust abatement activities and actions to stabilize transportation ROWs 

could result in short-term disturbance to wildlife in the vicinity of affected areas, but these impacts 

would be minor and localized. Under all action alternatives, the BLM would implement BMPs to reduce 

emission of GHGs. These actions would have a negligible effect on wildlife from an air quality 

standpoint but could help reduce the impacts of climate change. There would be no change in the 

indicators for this resource as a result of management pertaining to air quality. 

Wildlife and Special Status Species: Effects from Soils Management Actions 

In addition to management actions common to all action alternatives, potential impacts from the 

following management topics were considered: 

• Soil Survey 

• Floodplains and Springs 

Soils provide a component of wildlife and SSS habitat, as soil type and soil function influence plant 

productivity and vegetation cover types. Soils are also an important habitat component for burrowing 

mammals. Soil fauna perform important roles in ecosystem function, such as nutrient cycling, infusion of 

organic matter, and components of the food web. Because soil disturbance has a localized effect on 

wildlife and SSS habitat by removing vegetation and potentially damaging nests and underground 

burrows, management actions related to soils may have an incidental effect on wildlife and SSS. 

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Effects under Alternative A 

Under Alternative A, the BLM would continue to consider potential impacts to natural resources when 

permitting soil-disturbing activities. The BLM would use soil surveys to obtain information in support of 

recommendations pertaining to certain resource uses. However, there would be no specific threshold of 

activity that would trigger a requirement for a soil survey, and potential impacts to wildlife or SSS would 

not be a consideration. 

Effects Common to All Action Alternatives 

Under all action alternatives, SOPs and BMPs to reduce or prevent erosion, compaction, and other types 

of soil degradation could also help reduce impacts to wildlife and SSS habitat in the areas receiving this 

protection by preventing disturbance and habitat degradation. These benefits would be localized and 

minor. The cumulative impacts analysis for all surface-disturbing activities and collaboration with 

USFWS would provide a landscape-level planning tool that would also help reduce the potential for 

impacts to wildlife and SSS by requiring a landscape-level assessment of all surface disturbances, which 

help prevent widespread loss or fragmentation of wildlife and SSS habitat. 

As described below, the alternatives would vary primarily in terms of the magnitude and extent of 

restrictions on surface-disturbing BLM-permitted activities and the amount of information about soil 

obtained prior to these activities. 

Effects under Alternative B 

Under Alternative B, the requirement for soil surveys for all surface-disturbing BLM-permitted activities 

would allow the BLM to reduce impacts to fragile soils and would result in more successful reclamation 

of disturbed sites. In localized areas, this management would reduce the potential for impacts to wildlife 

and SSS through avoidance of sensitive habitats and quicker recovery of degraded habitats. The greatest 

potential for reduction in impacts to habitat and ground-dwelling wildlife and SSS from surfacedisturbing activities would occur within floodplains and near springs (where species such as wood frog, 

moose, mink, and riparian-associated bird species occur), as management actions would prohibit surfacedisturbing activities within 100 feet of a natural spring and require that surface-disturbing activities 

within the 100-year floodplain include detailed reclamation plans. The reduction in potential impacts to 

soils from management actions would be larger in magnitude and more extensive in area than under 

Alternative A. 

Effects under Alternative C 

Under Alternative C, management pertaining to surface-disturbing activities would result in slightly less 

reduction in the potential for impacts to wildlife and SSS from surface-disturbing activities than the 

management under Alternative B. Because soil surveys would provide less detailed information than 

under Alternative B, and restrictions on surface-disturbing BLM-permitted activities in floodplains and 

near springs would be determined on a case-by-case basis rather than as a requirement for all activities, 

the extent of wildlife habitat in which impacts would be avoided would be less than, but of a similar 

magnitude to, the extent under Alternative B. Overall, the effectiveness of soil management actions to 

reduce the potential for impacts to wildlife and SSS under Alternative C would be of a similar magnitude 

to that under Alternative B, with management actions affecting wildlife and SSS over a similar 

geographic extent. 

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Appendix N: Supplemental Impact Analysis Information Section 3. Supplemental Impact Analysis 

Effects under Alternative D 

Under Alternative D, some management actions pertaining to surface-disturbing activities would have a 

lower potential to reduce impacts to wildlife and SSS from surface-disturbing activities than those under 

Alternatives B and C, but other management actions would have a similar effect on wildlife and SSS. 

Overall, the ability of soil management actions under Alternative D to reduce the potential for impacts to 

wildlife and SSS would be of a similar but lower magnitude compared to that under Alternatives B and 

C, and management actions would affect wildlife and SSS over a similar but smaller geographic extent. 

Wildlife and Special Status Species: Effects from Water Resources and Fisheries 

Management Actions 

In addition to management actions common to all action alternatives, potential impacts from the 

following management topics were considered: 

• Proposed HVWs 

• Locatable Mining 

• Surface-Disturbing Activities 

• Forestry and Woodland Decisions within HVWs 

• Minerals Decisions within HVWs 

Lakes and streams and their associated riparian areas and floodplains provide important habitat for a 

large variety of wildlife in the planning area, including SSS, as described in Appendix M of the BSWI 

Draft RMP/EIS. Additionally, fish and other aquatic species provide a source of food for wildlife, such 

as bears, river otters, and waterfowl. Therefore, management actions for water resources and fisheries 

may also affect wildlife and SSS that use these habitats. 

Effects under Alternative A 

Under Alternative A, the BLM would continue to meet all applicable laws, regulations, and policies 

pertaining to surface water and groundwater quality and quantity. The BLM would continue to consider 

protection of floodplains and crucial salmon spawning habitat when implementing actions, which would 

reduce the potential for impacts to wildlife and SSS that use these habitats from habitat loss or 

degradation due to surface-disturbing activities, human disturbance, and reduction in salmon and other 

aquatic prey species. This alternative includes minimal management direction, but does include 

prescriptions for mining, such as 300-foot occupancy setbacks in certain rivers and tributary streams and 

closure of certain areas, which are intended to prevent pollution of key fishery areas and protect 

spawning areas. The geographic extent of management actions under Alternative A would be less than 

under the action alternatives, as HVWs would not be defined or designated. Therefore, the amount of 

wildlife and SSS protected by water resources and fisheries habitat management actions would also be 

less than under the action alternatives. 

Effects Common to All Action Alternatives 

Under all action alternatives, the BLM would implement numerous BMPs/SOPs designed to limit 

impacts to water quality, achieve proper functioning condition of stream channels and riparian zones, 

maintain or restore hydrological conditions, maintain sufficient quantities of surface water and 

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Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

groundwater to support wildlife, and maintain vegetation and riparian buffers around water bodies. 

These BMPs/SOPs would help prevent impacts to wildlife and SSS that use these habitats from 

disturbance and habitat degradation. Under all action alternatives, the BLM would complete a 

watershed-level cumulative impact analysis of all disturbances as a part of permitting for most surfacedisturbing activities. This activity would allow the BLM to better manage wildlife habitats at the 

watershed scale, as the BLM would coordinate and share information with USFWS and manage for 

connectivity of neighboring NWRs. Permanent structures and disturbance over 5 acres would be avoided 

within the 100-year floodplain, and locatable mining activities would include measures to rehabilitate 

wildlife and reestablish vegetation which would minimize long-term impacts to wildlife from locatable 

mineral activity. 

The alternatives would vary in terms of the extent of riparian and floodplain habitat designated as HVWs 

and in the magnitude of management restrictions in HVWs, floodplains, ACECs, and WSRs. 

Effects under Alternative B 

Under Alternative B, 21,382 river miles (65 percent of total river miles on BLM-managed lands within 

the planning area) would be designated as HVWs and, as such, would be subject to management actions 

that could reduce impacts to wildlife and SSS and their habitat from commercial woodland harvest, 

mineral development, and OHV use. Closing 100-year floodplains within these HVWs to commercial 

woodland harvest, withdrawing them from locatable mineral entry, closing them to salable and leasable 

minerals, and implementing some restrictions on OHV use would reduce loss, degradation, and 

fragmentation of habitat, mortality, and reduced reproductive success associated with human disturbance 

for wildlife and SSS that inhabit riparian areas associated with these HVWs, likely including numerous 

migratory birds. Additionally, HVW designations intersect other high-value wildlife habitats, including 

caribou calving habitat (41,577 acres; 26 percent)1

 and wintering habitat (6,100,853 acres; 60 percent), 

moose calving habitat (158,756 acres; 42 percent) and wintering habitat (592,802 acres; 66 percent), 

Audubon Important Bird Areas (246,510 acres; 78 percent), the Innoko Bottoms area (97,049 acres; 

41 percent), muskox range (1,733,656 acres; 53 percent), and wood bison range (2,589,336 acres; 

70 percent). Therefore, a variety of important wildlife habitats would have a reduction in potential 

impacts from various land uses as a result of management associated with HVW designations under 

Alternative B. 

Alternative B would designate the largest geographic area as HVWs and would provide the greatest 

magnitude of reduction in potential impacts to wildlife and SSS, compared to the other alternatives. This 

alternative would have the least potential for impacts to numerous wildlife species that inhabit or forage 

in riparian areas, such as moose, mink, wood frogs, bears, and BLM sensitive bird species (e.g., 

blackpoll warbler, trumpeter swan, emperor goose, olive-sided flycatcher, and rusty blackbird), as well 

as other species with habitat that occurs in HVWs, including caribou, muskox, and wood bison. 

Effects under Alternative C 

Under Alternative C, 14,888 river miles (45 percent of total river miles on BLM-managed lands within 

the planning area) would be designated as HVWs and subject to associated management actions, which 

is 20 percent less than under Alternative B. Therefore, management that would minimize impacts to 

1 Percentage of total acreage of high-value wildlife habitat type present on BLM-managed lands in the planning area. 

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Appendix N: Supplemental Impact Analysis Information Section 3. Supplemental Impact Analysis 

riparian wildlife and SSS would occur over a smaller geographic area than under Alternative B. Under 

Alternative C, HVW designations intersect caribou calving habitat (11,838 acres; 7 percent) and 

wintering habitat (4,196,187; 40 percent), moose calving habitat (84,886 acres; 22 percent) and 

wintering habitat (414,705 acres; 46 percent), Audubon Important Bird Areas (217,358 acres; 

69 percent), the Innoko Bottoms area (51,195 acres; 22 percent), muskox range (1,318,562 acres; 

40 percent), and wood bison range (1,856,906 acre; 50 percent). These are the same important wildlife 

habitats that would be affected by HVW management actions under Alternative B, but for a smaller 

geographic area. Additionally, the magnitude of reduction in potential impacts to wildlife and SSS would 

be less, as management actions pertaining to OHV use would be less protective than those under 

Alternative B, and these areas would be open to locatable entry, commercial woodland harvest on a caseby-case basis, and salable mineral development on a case-by-case basis. 

Effects under Alternative D 

Under Alternative D, 12,982 river miles (39 percent of total river miles on BLM-managed lands within 

the planning area) would be designated as HVWs and subject to associated management actions, which 

is 26 percent less than under Alternative B and 6 percent less than under Alternative C. Therefore, 

riparian wildlife and SSS over a smaller geographic area would benefit from reduced potential for 

impacts from commercial woodland harvest, mineral development, and OHV use than under 

Alternatives B and C. Under Alternative D, HVW designations would intersect the same important 

wildlife habitats as under Alternatives B and C, but the size of this overlap would be less for all but 

Audubon Important Bird Areas, which would be the same as under Alternative B. Differences between 

Alternatives B and C would include caribou calving habitat (9,716 acres; 6 percent) and wintering 

habitat (3,757,392 acres; 37 percent), moose calving habitat (46,622 acres; 12 percent) and wintering 

habitat (369,974 acres; 41 percent), the Innoko Bottoms area (12,939 acres; 5 percent), muskox range 

(1,306,339 acres; 40 percent), and wood bison range (1,458,393 acres; 39 percent). Additionally, the 

magnitude of reduction in potential impacts to wildlife and SSS would be less, as management actions 

pertaining to commercial harvest, OHV use, and mineral decisions would be less protective than under 

Alternatives B and C. Under Alternative D, these less restrictive management actions could result in a 

greater potential for injury/mortality, disturbance, habitat loss, degradation, and fragmentation for 

riparian wildlife and SSS than management under Alternatives B and C. 

Wildlife and Special Status Species: Effects from Vegetation Management Actions 

In addition to management actions common to all action alternatives, potential impacts from the 

following management topics were considered: 

• SSS Flora and Lichen Areas 

• BLM-permitted Surface Disturbance 

• Seeding and Planting Reclamation/Restoration 

Because vegetation provides the basic foundation of wildlife habitat, vegetation management would also 

affect wildlife and SSS. Actions to maintain certain vegetation types would benefit wildlife and SSS that 

use habitats associated with those vegetation types. Additionally, actions to protect special status plant 

species could help reduce potential impacts to wildlife and SSS that co-occur in the same habitats. In the 

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Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

planning area, these habitats predominantly include dwarf shrub habitats, sparsely vegetated areas, and 

persistently snow-covered areas. 

Effects under Alternative A 

Under Alternative A, the BLM would follow all federal regulations to protect threatened and endangered 

plant species (none currently in planning area) and internal BLM guidance to protect sensitive species, 

which would continue to result in a localized and minor reduction in the potential for impacts to wildlife 

and SSS in the vicinity of sensitive plant populations from permitted activities on BLM-managed lands. 

No additional management actions specific to vegetation or special status plants would be implemented 

in the planning area that would affect wildlife and SSS and their habitat. 

Effects Common to All Action Alternatives 

Under all action alternatives, vegetation management that focuses on landscape resiliency, maintenance 

of connectivity corridors, monitoring of rare ecosystems, and restoration of degraded habitats (such as 

riparian areas and lichen-rich habitat) would provide a landscape-level benefit to wildlife and SSS in the 

planning area and could increase the amount or suitability of habitat in certain areas. Actions to 

minimize the footprint of BLM-permitted surface-disturbing activities, limit the magnitude or duration of 

impacts, and preserve vegetation would reduce the potential for associated wildlife and SSS habitat loss 

and fragmentation in the development areas. 

The action alternatives would vary primarily in terms of travel management decisions in SSS flora areas 

and caribou habitat areas and in requirements for native plant species use in reclamation and restoration 

of disturbed areas. 

Effects under Alternative B 

Under Alternative B, monitoring of dwarf shrub, lichen, or sparse vegetation types (6,511,856 acres or 

48 percent of the planning area) and potential travel management actions for OHV use would limit direct 

disturbance of wildlife and SSS that use these habitats, such as Alaskan hare and caribou, and would also 

limit habitat degradation and fragmentation associated with surface disturbance and creation of trails. 

Additional actions to protect special status plant species from BLM-permitted surface-disturbing 

activities would provide a minor and localized reduction in the potential for impacts to wildlife and SSS 

habitats, limited to the area within 300 feet of special status plant populations. Based on the known 

locations of these populations, this management would affect a small amount of wildlife in dwarf shrub 

habitats, sparsely vegetated areas, and persistently snow-covered areas. The management action that 

requires use of native seed and propagules in reclamation/restoration would provide a minor, localized 

reduction in the potential for long-term degradation of habitats used by wildlife and SSS that require 

native plant species and would also reduce the risk of habitat degradation caused by the spread of 

invasive plants beyond the reclamation area. 

Effects under Alternative C 

The effect of vegetation management actions on wildlife and SSS under Alternative C would be similar, 

but not identical, to Alternative B. The reduction in potential impacts to wildlife and SSS in dwarf shrub, 

lichen, or sparse vegetation types from management actions would be the same as under Alternative B. 

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Additional actions to protect special status plant species from BLM-permitted surface-disturbing 

activities would be limited to a smaller area than under Alternative B (within 100 feet of special status 

plant populations). Therefore, localized reduction in potential for impacts to wildlife and SSS would be 

smaller in geographic extent than under Alternative B and would still be minor. Overall, the magnitude 

and extent of reduced potential for impacts to wildlife and SSS would be slightly less than under 

Alternative B. 

Effects under Alternative D 

Alternative D would provide the lowest reduction in potential impacts to wildlife and SSS from surfacedisturbing activities compared to Alternatives B and C, because travel management restrictions that 

would protect wildlife by limiting disturbance would not apply in dwarf shrub, lichen, or sparse 

vegetation habitat types. The management action pertaining to surface disturbance in the vicinity of SSS 

would also be less protective and would be less effective in reducing impacts to wildlife and SSS locally. 

Because there would be no requirement to use native species during reclamation/restoration, the 

potential for adverse impacts to wildlife and SSS that require habitat with native plant species would be 

greater than under Alternatives C and D, as reclamation actions could lead to the spread of invasive 

species in the disturbance area and adjacent habitat. There would be no minor, localized reduction in the 

potential for impacts to wildlife and SSS in the vicinity of sensitive plant populations associated with 

buffers around special status plant species. 

Wildlife and Special Status Species: Effects from Wildlife Management Actions 

In addition to management actions common to all action alternatives, potential impacts from the 

following management topics were considered: 

• Caribou and Moose 

• Innoko Bottoms Priority Wildlife Habitat Area 

• Connectivity Corridors 

• Migratory Birds 

• Raptors 

Management actions designed to meet goals and objectives for wildlife and SSS would benefit target 

species and habitats, as well as other species that use the same habitats. Landscape-scale actions that 

focus on resilience and maintenance of connectivity corridors would tend to benefit most wildlife and 

SSS in the planning area. 

Effects under Alternative A 

Under Alternative A, the BLM would continue to follow all laws, regulations, and policies, which 

predominantly pertain to listed species, sensitive species, unique habitats, subsistence resources, and 

migratory birds. The BLM would consider impacts to wildlife and SSS when evaluating actions in the 

planning area that may have the potential to affect these resources and would implement mitigation as 

needed on a case-by-case basis. Alternative A includes additional management pertaining to peregrine 

falcons and other raptors, including seasonal buffer zones around active peregrine nests for oil, gas, and 

mining activities and designation of 91,520 acres as ACECs to protect crucial riparian habitat for 

peregrine falcons. Under Alternative A, the BLM would also consider caribou and moose in its 

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management of resource uses in the planning area, although no specific management actions are 

identified. This alternative would not include management direction for the Innoko Bottoms Priority 

Wildlife Habitat Area, and the BLM would not manage connectivity corridors for passage between 

NWRs. Therefore, this alternative could have a long-term impact on migration and other species 

movement across the landscape if future development occurs in areas where it will fragment species 

ranges and reduce habitat connectivity. However, the proposed connectivity corridors under 

Alternatives B and C occur in areas that do not have medium or high LMP, so future development may 

have a low impact on migration under this alternative even without the corridors. 

Effects Common to All Action Alternatives 

All action alternatives would include management considerations that focus on ESA-listed species, BLM 

sensitive species, caribou, moose, muskox, Dall sheep, mountain goats, migratory birds, raptors, bats, 

wood bison, and pollinators. Under all action alternatives, the BLM would ensure coordination with 

ADF&G on predator control planning and reporting. Additionally, the BLM would use adaptive 

management that considers climate change and shifts in habitat or timing of crucial portions of species’ 

life cycles. The BLM would also implement numerous BMPs/SOPs designed to protect sensitive species 

and habitats, including buffer requirements, design features, seasonal restrictions, aircraft height 

restrictions, and location restrictions for activities with the potential to impact species and habitats of 

management concern from habitat loss, degradation, and fragmentation; noise and human disturbance; 

spread of diseases; and direct harm of individuals. 

The alternatives would vary in terms of the timing, extent, and magnitude of restrictions on mineral 

activities; construction, vegetation clearing, and surface-disturbing activities in caribou and moose 

habitat and riparian areas; the extent of land receiving additional protections through designation as the 

Innoko Bottoms Priority Wildlife Habitat Area; and the number of connectivity corridors that the BLM 

would manage to protect wildlife movement between two NWRs. 

Effects under Alternative B 

Management actions under Alternative B would provide the highest magnitude and greatest extent of 

reduction in potential impacts to wildlife and SSS. Management actions would target important species 

and habitats in the planning area. The geographic extent of these actions is summarized in Table 3.2.3-1, 

although in many cases these areas overlap. Note that these tables do not take into account management 

for other resources or resources uses that may also provide protections to wildlife. 

The geographic extent of protective wildlife management actions under Alternative B would be greater 

than under Alternatives C and D. In addition to the species and habitats targeted by these management 

actions, the associated portions of the planning area also include habitat used by other important species, 

such as wood bison and muskox. Therefore, management actions under this alternative would also help 

reduce the potential for impacts to these species. 

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Appendix N: Supplemental Impact Analysis Information Section 3. Supplemental Impact Analysis 

Table 3.3.3-1. Extent of Wildlife Management Actions under Alternative B 

Species/Habitat 

Geographic Extent on BLM-managed

Lands in Planning Area Associated Management Actions 

Caribou and moose calving 

and wintering habitats 

10,251,780 acres 

(76 percent) 

Mineral development, seasonal use restrictions 

Innoko Bottoms Priority Wildlife 

Habitat Area 

236,556 acres 

(2 percent) 

Mineral development, surface-disturbing activities, 

ROW exclusion, casual use airboats/hovercraft 

Connectivity Corridors Two corridors totaling 845,670 acres 

(6 percent) 

Mineral development, surface-disturbing activities, 

ROW exclusion areas, casual use 

airboats/hovercraft 

River Miles 32,931 miles ROW avoidance, mineral development 

Raptor nesting habitat Not quantified Seasonal restrictions, buffers 

Other migratory bird habitat Not quantified Surface-disturbing activity – seasonal restrictions 

In caribou and moose calving and wintering habitats, a designation of NSO for leasable minerals and 

seasonal use restrictions on construction would reduce the potential for disturbance during crucial 

periods and would reduce the potential for habitat loss, degradation, and fragmentation from surface 

disturbance associated with leasable minerals. This management would reduce impacts to wildlife and 

SSS over a large portion of the planning area (76 percent). However, because leasable potential in the 

planning area is very low, the effects to wildlife and SSS from the leasable mineral management would 

be minor. 

The management actions listed in Table 3.3.3-1would affect wildlife and SSS in the Innoko Bottoms 

Priority Wildlife Habitat Area and two proposed connectivity corridors (North Connectivity Corridor 

and South Connectivity Corridor—see BSWI Draft RMP/EIS, Map 3.2.7-3). These actions include: 

• withdrawal of these areas from locatable mineral entry (includes retained existing withdrawals 

and new proposed withdrawals), 

• designation as NSO for leasable development, 

• designation as closed to salable development, 

• designation as NSO for surface-disturbing BLM-permitted activities, 

• designation as ROW exclusion areas, and 

• restrictions on casual use airboats and hovercraft. 

These management actions would reduce disturbance to wildlife and reduce the potential for loss, 

degradation, and fragmentation of these key habitats. Connectivity corridors are designed to sustain and 

maximize abundance and landscape-scale biodiversity by maintaining general habitat connectivity, 

minimizing habitat fragmentation and loss, and avoiding or mitigating barriers to wildlife movement 

within the corridors (Magness et al. 2018). The corridors are expected to benefit a wide range of species. 

The South Connectivity Corridor includes a portion of the Innoko Bottoms area, where a variety of 

wildlife species occur, including waterfowl, moose, and wood bison. The North Connectivity Corridor 

includes a portion of the winter range of the Western Arctic Caribou Herd; this corridor would allow for 

movement of caribou in this herd near the southern end of their range. Creating two connectivity 

corridors between the Innoko and Yukon Delta NWRs allows for landscape connectivity at multiple 

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Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

locations, provides more options for movement, and benefits a greater number of wildlife than a single 

connectivity corridor. 

Classifying riparian areas as ROW avoidance areas and prohibiting mineral leasing in riparian areas 

would reduce disturbance and habitat impacts to migratory birds and other species over approximately 

17 percent of BLM-managed lands in the planning area. Additionally, seasonal restrictions in migratory 

bird habitat would help minimize vegetation alteration, habitat destruction, and auditory disturbance to 

nesting birds, which could reduce the potential for mortality or reduced reproductive success. BLM 

sensitive species that management actions may affect include blackpoll warbler, trumpeter swan, 

emperor goose, olive-sided flycatcher, and rusty blackbird. 

For priority raptors (peregrine falcon, gyrfalcon, golden eagle, and bald eagle), implementing nestingseason buffers for surface- and non-surface-disturbing activities, permanent structures, campsites, 

aircraft, and human activities would help minimize disturbance to nesting raptors that could result in 

reduced reproductive success. 

Effects under Alternative C 

Under Alternative C, protections for wildlife and SSS from management actions would be of slightly 

lower magnitude and smaller geographic extent than those under Alternative B (Table 3.3.3-2). 

Table 3.3.3-2: Extent of Wildlife Management Actions under Alternative C 

Species/Habitat 

Geographic Extent on BLMManaged Lands in Planning Area Associated Management Actions 

Caribou and moose calving 

habitat 

540,896 acres 

(4 percent) 

Mineral development, seasonal use restrictions 

Innoko Bottoms Priority 

Wildlife Habitat Area 

236,556 acres 

(2 percent) 

ROW avoidance, airboats/hovercraft 

Connectivity Corridors 1 corridor 

576,038 acres 

(4 percent) 

surface-disturbing activities, ROW avoidance, 

airboats/hovercraft, case by case salable mineral 

development 

River Miles 32,931 miles ROW avoidance, mineral development 

Raptor nesting habitat Not quantified Seasonal restrictions, buffers 

Other migratory bird habitat Not quantified Surface-disturbing activity – seasonal restrictions 

For caribou and moose, the management actions pertaining to leasable minerals and construction would 

apply only to calving habitat. Therefore, while disturbances to caribou and moose would be reduced 

during the breeding period, they could occur in crucial winter habitat areas, potentially causing increased 

energy expenditures and stresses on wintering populations, which could result in decreased survivorship. 

This management would reduce potential impacts to wildlife over only 4 percent of the planning, a much 

smaller geographic extent (72 percent less) than under Alternative B. Under Alternative C, there would 

be fewer management actions for the Innoko Bottoms Priority Wildlife Habitat Area than under 

Alternative B; the area would be open to locatable development and surface-disturbing BLM-permitted 

activities and would be a ROW avoidance area rather than exclusion area. Therefore, in this area 

management actions would offer less reduction in potential impacts to wildlife and SSS from 

disturbance, habitat loss, and fragmentation from mineral development and ROWs. Restrictions on 

casual use airboats and hovercraft would be the same as under Alternative B, so there would be no 

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difference as far as potential reductions in auditory disturbance to wildlife and SSS from these types of 

vehicles/boats. 

Management actions for connectivity corridors under Alternative C would be less restrictive for 

locatable and salable mineral development (which would be allowed) than those under Alternative B. 

Additionally, the BLM would manage one connectivity corridor, the South Connectivity Corridor, rather 

than the two proposed under Alternative B. This alternative would maintain the long-term benefits to 

wildlife movement in the Innoko Bottoms area that were discussed for the South Connectivity Corridor 

under Alternative B but would not provide the same management benefits in the area identified as the 

North Connectivity Corridor, which intersects the range of the Western Arctic Caribou Herd. One 

connectivity corridor would still allow for landscape connectivity between the Innoko and Yukon Delta 

NWRs, but would offer fewer options for movement across the landscape and would potentially benefit 

less wildlife than Alternative B. Because neither proposed connectivity corridor under Alternative B 

occurs in an area of medium or high LMP, the probability of future development in key movement areas 

may be low and having only one corridor under Alternative C may not have a sizable difference on 

wildlife movement and habitat connectivity. Without information regarding the existing migration routes 

in the vicinity of the two corridors, it is difficult to assess the impacts of one location compared to 

another. It is also difficult to evaluate the effectiveness of the proposed management actions without 

knowing how existing migration may be currently affected by the types of activities that would be 

restricted. However, in general, having one corridor rather than two may increase the distance wildlife 

would have to travel to reach the corridor and could lead to decreased resources such as forage and 

increased predation along a sole corridor. 

Alternative C would have the same management actions for migratory birds as Alternative B and 

therefore the same type, magnitude, and extent of impacts. Management actions for raptors would be 

similar to Alternative C, although slightly less defined with respect to surface- and non-surfacedisturbing activities within 1 mile of raptor nests. 

Effects under Alternative D 

Alternative D would offer fewer management actions to reduce impacts to wildlife and SSS than 

Alternatives B and C (Table 3.3.3-3). 

Table 3.3.3-3: Extent of Wildlife Management Actions under Alternative D 

Species/Habitat 

Geographic Extent on BLMManaged Lands in Planning Area Associated Management Actions 

Innoko Bottoms Priority 

Wildlife Habitat Area 

236,556 acres 

(2 percent) 

Mineral development, seasonal use restrictions, ROW 

avoidance 

Riparian habitat 32,931 miles Case by case 

Raptor nesting habitat No information Case by case, buffers 

Other migratory bird habitat No information Surface-disturbing activity – case by case 

The geographic extent of management actions for wildlife would be less than under Alternatives B and 

C. Similar to Alternative A, the BLM would not manage connectivity corridors under Alternative D. 

However, the proposed connectivity corridors under Alternatives B and C occur in areas that do not have 

medium or high LMP, so future development may have a low impact on migration under this alternative 

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Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

even without the corridors. There would be fewer management actions to reduce the potential for 

impacts to caribou and moose, particularly during the winter use period, during which there would be no 

additional management actions beyond those described for all action alternatives in Section 2.7.5 of the 

BSWI Draft RMP/EIS and the BMPs also listed in that document. For the Innoko Bottoms Priority 

Wildlife Habitat Area, management actions pertaining to mineral decisions and ROWs would be the 

same as those under Alternative C, and the reduced potential for impacts to wildlife and SSS from 

disturbance and habitat loss and fragmentation from mineral development and ROWs would also be the 

same. However, unlike Alternatives B and C, there would be no restrictions on casual use airboats and 

hovercraft and therefore the potential for impacts to waterbirds and other species from associated 

disturbance would be greater under Alternative D. Because restrictions and mitigations for migratory 

birds would be determined on a case-by-case basis, it is difficult to assess the difference as far as impacts 

to migratory birds relative to other alternatives. Similarly, for raptors, the need for buffers around raptor 

nests associated with permanent structures, aircraft use, human activities motorized ground vehicles, and 

construction would be determined on a case-by-case basis, so it is difficult to assess the difference as far 

as impacts to nesting raptors relative to other alternatives. Permits for surface-disturbing activities would 

require pre-work raptor nesting surveys, but there would be no associated buffer; therefore, the potential 

for associated disturbance to raptors would be greater under Alternative D than under Alternatives B and 

C. Campsite buffers would only apply to authorized agency and construction campsites, but would be the 

same as those under Alternatives B and C. Therefore, the potential for noise disturbance to nesting 

raptors from this type of campsite would be less than under Alternatives B and C. 

Wildlife and Special Status Species: Effects from Nonnative Invasive Species Management 

Actions 

There are no alternative-specific management actions for this resource; therefore, impacts from 

Alternatives B, C, and D are described in combination below. 

Effects under Alternative A 

Under Alternative A, the BLM would follow all laws, regulations, and policies pertaining to use of 

nonnative species and management of noxious weeds and other NNIS. Management actions to minimize 

the introduction and spread of NNIS would prevent the long-term degradation of wildlife and SSS 

habitats in the planning area. These effects would be limited to areas where infestations of NNIS 

presently occur or are likely to occur in the future. Use of vegetation treatments could have localized 

adverse short-term impacts on wildlife and SSS habitats by removing vegetation used for cover and food 

and other habitat elements, but treatments would follow all required measures designed to protect SSS 

and their habitats (such as herbicide buffers). 

Effects Common to All Action Alternatives 

Management under the action alternatives would be similar to that under Alternative A, with a similar 

effect on wildlife and SSS habitats. The only difference would be better defined management actions 

under the action alternatives, which may result in more effective control of NNIS and better long-term 

protection of wildlife and SSS habitats. Control and eradication of NNIS would occur within the 

planning area as described in SOPs, BMPs, and management actions for various resources and resource 

uses, which would help prevent the degradation of wildlife habitats through the spread of NNIS. Under 

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the action alternatives, monitoring locations and extents of NNIS infestations and shifting management 

priorities and eradication efforts to target changes caused by climate change would allow the BLM to 

better control and manage NNIS populations and prevent future large-scale degradation of wildlife 

habitats. There would be no change to the indicators for wildlife and SSS as a result of management 

actions under the action alternatives. 

Wildlife and Special Status Species: Effects from Wildland Fire Management Actions 

There are no alternative-specific management actions for this resource; therefore, impacts from 

Alternatives B, C, and D are described in combination below. 

Effects under Alternative A 

Under Alternative A, the BLM would continue to follow all laws, regulations, and guidance pertaining to 

wildland fire management and would follow the applicable BLM wildland fire management direction for 

the planning area. While there are no specific management actions stipulated under this alternative, 

managing wildland fire in the planning area according to the goals and objectives identified in the 2005 

Land Use Plan Amendment Environmental Assessment for Wildland Fire and Fuels Management for 

Alaska (BLM 2005) would reduce the risk of human-caused fires in the planning area and associated 

short- and long-term impacts to wildlife and SSS habitat through direct mortality and loss or alteration of 

habitat. Emergency Stabilization and Rehabilitation (ES&R) plans would help rehabilitate wildlife and 

SSS habitat following burns, which could reduce the intensity and duration of impacts from fire. Use of 

wildland fire to meet wildlife management objectives would also benefit wildlife and SSS habitat. These 

actions would not change the amount of wildlife habitat in the planning area but could minimize shortand long-term reductions in late-successional habitat types in certain areas. However, fire suppression 

actions may result in a deviation from the natural fire regime, which may affect wildlife and SSS habitat. 

This alternative does not specify the amount of BLM-managed land in the planning area that is protected 

from fire or allowed to burn. The amount of wildlife habitat allowed to burn may increase or decrease, 

depending on where natural wildland fires occur and what wildlife and SSS habitats are present in those 

areas. 

Effects under All Action Alternatives 

Wildland fire management under the action alternatives would be similar to that under Alternative A, 

although there would be BMPs/SOPs and additional management actions implemented that may help 

reduce impacts to wildlife and SSS and their habitat from wildland fire. These actions include measures 

to prevent impacts to wildlife and SSS from wildland fire suppression efforts, fuel breaks, and ES&R 

activities. Avoiding fire-fighting overflights within 1,500 feet of known occupied raptor nests would 

minimize associated disturbance to raptors but would not affect the amount of raptor nesting habitat in 

the planning area. Additionally, the BLM would monitor and measure the interactions between climate 

change, wildland fire, and resource objectives (including wildlife), and would adapt fire management 

strategies as necessary to protect resources, including high-value wildlife habitats. Strategies that pertain 

to lichen forage to changes in fire regime could allow the BLM to better manage caribou winter habitat 

in the long term. 

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Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

Wildlife and Special Status Species: Effects from Cultural Resources Management Actions 

In addition to management actions common to all action alternatives, potential impacts from the 

following management topics were considered: 

• Decisions Pertaining to the INHT NTMC (also see the National Trails section) 

Management actions for cultural resources may provide incidental protection of wildlife and SSS habitat 

in areas that contain identified cultural resources by minimizing impacts associated with surface 

disturbance, erosion, and vegetation loss in these areas. 

Effects under Alternative A 

The BLM would continue to meet all applicable laws, regulations, and policies that pertain to cultural 

resources, which could minimize potential impacts to wildlife and SSS from surface-disturbing and other 

activities in areas where cultural resources are present. 

Effects Common to All Action Alternatives 

All action alternatives would include additional management actions and SOPs/BMPs for cultural 

resources that could provide greater reduction in the potential for impacts to wildlife and SSS from 

surface-disturbing activities in localized areas. Establishment of the INHT NTMC under the action 

alternatives would likely focus reductions in potential impacts to wildlife and SSS in this corridor. 

The alternatives would vary in terms of land area within the INHT NTMC, but there would be little 

difference as far as effect to wildlife and SSS. 

Effects under Alternative B 

Under Alternative B, the BLM would designate the INHT NTMC on 288,466 acres (2 percent) of BLMmanaged lands in the planning area, with protections that could reduce potential impacts to wildlife and 

SSS and their habitat along this corridor from various land uses. Under this alternative, the INHT would 

overlap riparian areas (associated with 898 river miles; 3 percent of total river miles on BLM-managed 

lands within the planning area), caribou wintering habitat (250,947 acres; 2 percent), moose calving 

habitat (15,106 acres; 4 percent) and wintering habitat (125,776 acres; 14 percent), and muskox range 

(8,094 acres; less than 1 percent). There could be reduced potential impacts in these important wildlife 

habitats as a result of INHT NTMC management. 

Effects under Alternative C 

Under Alternative C, the INHT NTMC would consist of 273,242 acres (2 percent) of BLM-managed 

lands in the planning area, which would provide protections to wildlife and SSS and their habitat over a 

slightly smaller area than under Alternative B. Under this alternative, the INHT would overlap the same 

types of important wildlife habitat as under Alternative B, with slightly smaller areas of overlap for 

some. Areas of overlap would include riparian areas (associated with 844 river miles; 3 percent of total 

river miles on BLM-managed lands within the planning area), caribou wintering habitat (247,796 acres; 

2 percent), moose calving habitat (10,438 acres; 3 percent) and wintering habitat (123,405 acres; 

14 percent), and muskox range (8,094 acres; less than 1 percent). The geographic extent of reduced 

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potential for impacts to wildlife and SSS associated with INHT NTMC management would be less than, 

but of the same order of magnitude, as that under Alternative B. 

Effects under Alternative D 

Effects on wildlife and SSS under Alternative D would be identical to effects under Alternative C. 

Wildlife and Special Status Species: Effects from Visual Resources Management Actions 

In addition to management actions common to all action alternatives, potential impacts from the 

following management topics were considered: 

• Total VRM Class Acreages: VRM Class I and II 

Visual resources management can affect wildlife and special status resources in areas where 

management applies. In general, management of VRM Class I and II-designated areas allows for fewer 

intrusions to the landscape, which results in fewer short- and long-term impacts to wildlife habitat in 

these areas associated with development of structures, surface-disturbing activities, and other human 

activities. 

Effects under Alternative A 

Under Alternative A, the BLM would continue to manage wild and scenic sections of the Unalakleet 

Wild River Corridor as VRM Class I. No VRM Class II-designated areas are specified under current 

management plans. Wildlife and SSS habitats in 46,953 acres of VRM Class I areas (less than 1 percent 

of BLM-managed lands in the planning area) could be affected from these designations by reduced 

potential for impacts from land uses that are considered visual intrusions. VRM Class I designations 

overlap a relatively small amount of riparian area (associated with 204 river miles; less than 1 percent of 

total river miles on BLM-managed lands within the planning area), caribou wintering habitat (46,953 

acres; less than 1 percent), and moose wintering habitat (30,021 acres; 3 percent), and a negligible 

amount (less than 5 acres of 3,295,578 total acres) of muskox range. These and other wildlife habitats 

over the same limited geographic extent would have a reduction in potential impacts as a result of VRM 

management. 

Effects Common to All Action Alternatives 

Under the action alternatives, BMPs/SOPs for reclamation of landscapes, restoration of native habitats, 

and restoration of waterways and riparian areas in VRM Class I and II-designated areas would reduce 

the potential for impacts to wildlife and SSS habitats in these areas from development of structures, 

surface-disturbing activities, and other human activities. These actions would affect a variety of habitat 

types. The alternatives would vary in terms of land area classified as VRM Class I and II-designated 

areas. 

Effects under Alternative B 

Under Alternative B, 7,825,858 acres (58 percent) of BLM-managed lands in the planning area would be 

VRM Class I and II VRM designated areas. This alternative would affect wildlife and SSS habitat over a 

larger area than under Alternatives A, C, and D. VRM Class I and II designations under this alternative 

would overlap riparian areas (associated with 20,329 river miles; 62 percent of total river miles on BLM3-85 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

managed lands within the planning area), caribou calving habitat (4,197 acres; 3 percent) and wintering 

habitat (5,536,887 acres; 54 percent), moose calving habitat (347,806 acres; 91 percent) and wintering 

habitat (693,711; 78 percent), the Innoko Bottoms Area (235,501 acres; greater than 99 percent), 

Audubon Important Bird Areas (314,297 acres; greater than 99 percent), muskox range (1,407,690 acres; 

43 percent) and wood bison range (2,689,039 acres; 73 percent). Therefore, it is expected that there 

would be a reduction in potential impacts to these wildlife habitats from intrusive land uses as a result of 

VRM management under this alternative. 

Effects under Alternative C 

Under Alternative C, 46,953 acres (less than 1 percent) would be VRM Class I-designated areas and 

2,766,229 acres (21 percent) of BLM-managed lands in the planning area would be VRM Class IIdesignated areas. This alternative would affect wildlife and SSS habitat over a smaller area than under 

Alternative B, but over a larger area than under Alternatives A and D. VRM Class I and II designations 

under this alternative overlap riparian areas (associated with 6,968 river miles; 21 percent of total river 

miles on BLM-managed lands within the planning area), caribou wintering habitat (1,996,606 acres; 19 

percent), moose calving habitat (161,356 acres; 42 percent) and wintering habitat (377,529 acres; 42 

percent), the Innoko Bottoms Area (126,129 acres; 53 percent), muskox range (783,545 acres; 24 

percent), and wood bison range (680,266 acres; 18 percent). While management actions for VRM would 

affect the same types of important wildlife habitat areas as Alternative B, with the exception of Audubon 

Important Bird Areas, the geographic extent of each of these habitats overlapping VRM Class I or II 

designations would be less than under Alternative B. 

Effects under Alternative D 

Under Alternative D, 46,953 acres (less than 1 percent) would be VRM Class I-designated areas and 

679,553 acres (5 percent) of BLM-managed lands in the planning area would be VRM Class IIdesignated areas. This alternative would affect wildlife and SSS habitat over a smaller area than under 

Alternatives B and C, but over a larger area than under Alternative A. VRM Class I and II designations 

under this alternative overlap riparian areas (associated with 1,985 river miles; 6 percent of total river 

miles on BLM-managed lands within the planning area), caribou wintering habitat (557,171 acres; 

5 percent), moose calving habitat (33,687 acres; 9 percent) and wintering habitat (167,383 acres; 

19 percent), and muskox range (73,749 acres; 2 percent). Management actions for VRM would affect 

fewer important wildlife habitat areas than under Alternatives B and C, and the geographic extent of 

each habitat overlapping VRM Class I or II designations would be less than under Alternatives B and C. 

Wildlife and Special Status Species: Effects from Lands with Wilderness Characteristics 

Management Actions 

In addition to management actions common to all action alternatives, potential impacts from the 

following management topics were considered: 

• Acres Managed to Protect Wilderness Characteristics as a Priority Over Other Resource Values 

and Multiple Uses 

• Acres Managed to Emphasize Other Resource Values and Multiple Uses While Applying 

Management Restrictions to Reduce Impacts on Wilderness Characteristics 

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Appendix N: Supplemental Impact Analysis Information Section 3. Supplemental Impact Analysis 

Effects under Alternative A 

Wilderness characteristics are not addressed under Alternative A. Therefore, there would be no effects to 

wildlife and SSS associated with management pertaining to lands with wilderness characteristics. 

Effects Common to All Action Alternatives 

There are no effects common to all action alternatives, because areas managed for wilderness 

characteristics as a priority are only identified under Alternative B. 

The alternatives would vary in terms of area of lands managed for wilderness characteristics, area of 

lands managed to emphasize resource values and multiple uses, and the extent and magnitude of 

management restrictions in these areas that could reduce the potential for impacts to wildlife from 

various land uses. 

Effects under Alternative B 

Under Alternative B, 277,489 acres (2 percent of BLM-managed lands in the planning area) would be 

identified as lands managed for wilderness characteristics as a priority. Management restrictions to 

reduce impacts on wilderness characteristics in these areas would also limit disturbance to wildlife and 

SSS and degradation of habitats from land uses such as OHV use, facility construction, wood cutting and 

other forms of vegetation manipulation, and some types of mineral development. Additionally, actions to 

monitor and assess climate change impacts on current wildlife corridors and allocations for lands 

managed for wilderness characteristics based on predicted shifts in wildlife corridors would benefit 

wildlife and SSS habitat by preserving movement corridors over the long term. Lands managed for 

wilderness characteristics as a priority under this alternative would overlap riparian areas (associated 

with 666 river miles; 2 percent of total river miles on BLM-managed lands within the planning area), 

caribou wintering habitat (180,158 acres; 2 percent), and moose calving habitat (18,757 acres; 5 percent) 

and wintering habitat (26,100 acres; 3 percent). Therefore, it is expected that there would be a reduction 

in potential impacts to these wildlife habitats from various land uses as a result of wilderness 

management under this alternative. 

Additionally, the BLM would manage 12,040,490 acres (89 percent of BLM-managed lands in the 

planning area) to emphasize other resource values and multiple uses while applying management 

restrictions to reduce impacts on wilderness characteristics. This management would also reduce the 

potential for impacts to wildlife and SSS that are associated with lands with wilderness characteristics 

from various land uses, but to a lesser degree than lands managed for wilderness characteristics as a 

priority, because land uses with the potential to impact wildlife would be allowed in these areas. Lands 

managed to emphasize other resource values and multiple uses while applying management restrictions 

to reduce impacts on wilderness characteristics under this alternative would overlap a wider range of 

important wildlife habitat areas, although the magnitude of effects as far as reduced potential for impacts 

would be lower. This management category would affect riparian areas (associated with 29,716 river 

miles; 90 percent of total river miles on BLM-managed lands within the planning area), caribou calving 

habitat (160,096 acres; 100 percent) and wintering habitat (8,956,098 acres; 87 percent), moose calving 

habitat (362,042 acres; 95 percent) and wintering habitat (868,707 acres; 97 percent), Audubon 

Important Bird Areas (314,297 acres; greater than 99 percent), the Innoko Bottoms area (236,556 acres; 

100 percent), muskox range (3,289,736 acres; greater than 99 percent), and wood bison range (3,362,942 

acres; 91 percent). 

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Effects under Alternative C 

Under Alternative C, no land would be identified as lands managed for wilderness characteristics as a 

priority, and 8,105,979 acres (60 percent of BLM-managed lands in the planning area) would be 

managed to emphasize other resource values and multiple uses while applying management restrictions 

to reduce impacts on wilderness characteristics. This management would also reduce the potential for 

wildlife and SSS in these areas from various land uses, but to a lesser degree than under Alternative B. 

Important wildlife habitats that overlap this land management designation would be the same as those 

under Alternative B, with either the same or lower geographic extent of overlap. This management 

category would affect riparian areas (associated with 20,640 river miles; 63 percent of total river miles 

on BLM-managed lands within the planning area), caribou calving habitat (160,096 acres; 100 percent) 

and wintering habitat (5,881,286 acres; 57 percent), moose calving habitat (304,906 acres; 34 percent) 

and wintering habitat (717,457; 80 percent), Audubon Important Bird Areas (217,545 acres; 69 percent), 

the Innoko Bottoms area (236,555 acres; 100 percent), muskox range (2,053,738; 62 percent), and wood 

bison range (2,418,190 acres; 65 percent). Management under this alternative would have the potential to 

reduce impact to wildlife and SSS in these important habitat areas from various land uses. However, 

reduced impacts associated with use restrictions and wildlife corridor planning would not occur under 

this alternative. 

Effects under Alternative D 

Under Alternative D, no land would be identified as lands managed for wilderness characteristics as a 

priority or managed to emphasize other resource values and multiple uses while applying management 

restrictions to reduce impacts on wilderness characteristics. Similar to Alternative A, there would be no 

effects to wildlife and SSS associated with management pertaining to lands with wilderness 

characteristics. 

Wildlife and Special Status Species: Effects from Forestry and Woodland Products 

Management Actions 

In addition to management actions common to all action alternatives, potential impacts from the 

following management topics were considered: 

• Permitted Commercial Woodland Harvesting Areas 

• Personal Use and Subsistence Woodland Harvest Areas 

• Forestry BMPs for Commercial Activities 

Removal of forest and woodland products from BLM-managed lands in the planning area has the 

potential to modify habitats of forest-dwelling wildlife and SSS, such as lynx, brown and black bear, 

marten, and forest birds. Forests and woodlands make up approximately 35 percent of the planning area. 

Removal of both living and dead forest products from these areas can reduce components of wildlife 

physical habitat (such as nesting trees and branches and vegetation used for cover) and food sources 

(such as berries, seeds, and lichens). The magnitude and extent of the impact depends on the amount of 

habitat removed and the availability of these habitat components in nearby areas. 

Effects under Alternative A 

Commercial harvest of forest and woodland products in the planning area is currently limited but could 

increase with increasing demand. Under Alternative A, 1,644,588 acres (12 percent of BLM-managed 

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Appendix N: Supplemental Impact Analysis Information Section 3. Supplemental Impact Analysis 

lands in the planning area) would continue to be open to commercial harvest, with permits granted on a 

case-by-case basis for 10,237,555 acres (76 percent). A total of 1,583,751 acres (12 percent) would be 

closed to commercial harvest. Under current management, impacts to wildlife would be limited in extent 

to areas where forest and woodland products removal occurs, and crucial wildlife habitat would be 

protected. Important wildlife habitats most likely to be affected by permitted vegetation removal are 

those that occur in areas open to commercial harvest, which include riparian areas (associated with 3,000 

river miles; 9 percent), caribou wintering habitat (1,644,569 acres; 16 percent), and muskox range 

(1,576,235 acres; 48 percent of total habitat present). Subsistence harvest would continue to be common 

in areas around communities and could affect wildlife and SSS habitat in these areas. Forests and 

woodlands over the entire planning area would continue to be open to personal use and subsistence 

woodland harvest, with permits for certain products issued on a case-by-case basis. 

Effects Common to All Action Alternatives 

Management actions and BMPs/SOP would include considerations for wildlife when planning forest 

products harvest, surveys for sensitive resources prior to surface-disturbing activities, and labeling 

wildlife trees, among others. Actions to reduce impacts to other resources, such as lands managed for 

wilderness characteristics, could also help reduce impacts to wildlife and SSS that occur in these areas, 

relative to Alternative A. 

The action alternatives would vary in terms of area of land in which personal and commercial woodland 

harvest is allowed and the type and amount of harvest allowed in these areas. 

Effects under Alternative B 

Under Alternative B, the total acres of wildlife and SSS habitat that could be impacted by removal of 

forest and woodland products would be less than under Alternative A because a larger area (8,418,904 

acres; 63 percent of BLM-managed lands in the planning area) would be closed to commercial woodland 

harvest. However, the areas that would be open to commercial woodland harvest would overlap a larger 

variety and a greater extent of important wildlife habitats than under Alternative A: riparian areas 

(associated with 8,534 river miles; 26 percent of total river miles on BLM-managed lands within the 

planning area), caribou calving habitat (152,078 acres 95 percent) and wintering habitat (5,821,005 

acres; 54 percent), moose calving habitat (283,561 acres; 74 percent) and wintering habitat (438,198; 

49 percent), Audubon Important Bird Areas (272,578 acres; 86 percent), the Innoko Bottoms area 

(202,988 acres; 86 percent), muskox range (1,047,863 acres; 31 percent), and wood bison range 

(2,882,497 acres; 61 percent). Potential impacts to wildlife in these areas would be reduced through 

considerations for wildlife discussed under Effects Common to All Action Alternatives. Only a small 

portion of BLM-managed lands in the planning area (29,853 acres; less than 1 percent) would have 

permits for commercial harvest granted on a case-by-case basis. 

Personal use and subsistence woodland harvest would be designated over 42,445 acres (3 percent of the 

planning area) in the vicinity of streams, communities, and burned areas, and permits would be required 

for harvest in these areas. These management actions could help reduce impacts to wildlife and SSS 

from removal of habitat features, although areas of greatest impact—areas around communities—would 

likely be the same as those under Alternative A 

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Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

Effects under Alternative C 

Under Alternative C, the total acres of wildlife and SSS habitat that could be impacted by removal of 

forest and woodland projects would be greater than under Alternatives A and B, with only 46,953 acres 

(less than 1 percent of BLM-managed lands in the planning area) closed to commercial woodland 

harvest and 9,811,727 acres (73 percent) open to commercial harvest. Permits for commercial harvest on 

a case-by-case basis would occur on 3,607,214 acres (27 percent). Additionally, areas that would be 

open to commercial woodland harvest would overlap a larger extent of important wildlife habitats than 

under Alternatives A and B: riparian areas (associated with 16,122 river miles; 49 percent of total river 

miles on BLM-managed lands within the planning area), caribou calving habitat (158,602; 99 percent) 

and wintering habitat (6,516,009 acres; 67 percent), moose calving habitat (325,506 acres; 85 percent) 

and wintering habitat (549,357 acres; 61 percent), Audubon Important Bird Areas (276,474 acres; 87 

percent), the Innoko Bottoms area (209,795 acres; 89 percent), muskox range (1,428,102 acres; 43 

percent) and wood bison range (2,995,404 acres; 81 percent). Similar to Alternative B, potential impacts 

to wildlife in these areas would be reduced through considerations for wildlife discussed under Effects 

Common to All Action Alternatives. 

Management actions under Alternative C would have fewer restrictions on personal use and subsistence 

harvest that could reduce impacts to wildlife and SSS, as the amount of harvest requiring a permit would 

increase. However, this alternative would otherwise be similar to Alternative B, with the same acres and 

locations of personal use and subsistence woodland harvest areas. 

Effects under Alternative D 

Under Alternative D the potential for impacts to wildlife and SSS habitat from removal of forest and 

woodland products would be greater than under Alternatives A through C, as almost the entire the 

planning area (13,423,449 acres; nearly 100 percent) would potentially be open to commercial woodland 

harvest, and no areas would be closed to commercial woodland harvest. Permits for commercial harvest 

on a case-by-case basis would occur on 42,445 acres (less than 1 percent). Additionally, areas that would 

be open to commercial woodland harvest would overlap a larger extent of important wildlife habitats 

than under Alternatives A through C: riparian areas (associated with 32,850 river miles; greater than 99 

percent of total river miles on BLM-managed lands within the planning area), caribou calving habitat 

(160,096 acres; 100 percent) and wintering habitat (9,752,211 acres; 95 percent), moose calving habitat 

(374,631 acres; 98 percent) and wintering habitat (888,640 acres; 99 percent), Audubon Important Bird 

Areas (314,373 acres; 100 percent), the Innoko Bottoms area (236,556 acres; 100 percent), muskox 

range (3,269,799 acres; 99 percent ) and wood bison range (3,686,168 acres; greater than 99 percent). 

Similar to Alternatives B and C, potential impacts to wildlife in these areas would be reduced through 

considerations for wildlife discussed under Effects Common to All Action Alternatives. 

Potential impacts to wildlife from subsistence use harvest and personal use gathering of firewood would 

be greatest under this alternative, as permits would not be required for subsistence use harvest or 

personal use gathering of firewood, and all of the planning area would potentially be available for 

personal use and subsistence woodland harvest. 

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Wildlife and Special Status Species: Effects from Grazing Management Actions 

In addition to management actions common to all action alternatives, potential impacts from the 

following management topics were considered: 

• Areas Open/Closed to Grazing 

• Utilization 

• Grazing Management Plan 

Effects under Alternative A 

Under Alternative A, the BLM would continue to provide grazing leases for seasonal grazing of 

domestic livestock, in accordance with applicable laws, regulations, and policies. There is one permitted 

reindeer grazing range in the planning area, and it is predicted that interest in reindeer grazing will 

increase. Domestic reindeer grazing has the potential to impact caribou habitat by reducing available 

winter forage and may result in impacts to populations through inbreeding and transmission of disease. 

Disease may also be transmitted to Dall sheep, mountain goats, and muskox. Reindeer grazing may 

provide a food source for predators such as grizzly bear. Under Alternative A, these adverse effects 

would be minor and limited to areas where domestic grazing occurs. At present, this would affect a 

negligible amount of caribou and moose calving and wintering areas and crucial winter habitat in the 

planning area, but the extent would increase with demand for grazing leases. Management under 

Alternative A would allow for grazing of domestic livestock only where compatible with other 

resources, which would minimize impacts to wildlife and SSS habitats. This alternative would also 

exclude grazing leases along the Unalakleet and Anvik Rivers and their major tributaries, which would 

prevent impacts to wildlife and SSS habitats in these areas. 

Effects under Alternative B 

Under Alternative B, all BLM-managed lands in the planning area would be closed to grazing, which 

would eliminate the grazing-related impacts on caribou and other wildlife species and their habitat 

discussed under Alternative A. 

Effects under Alternative C 

Under Alternative C, the area of wildlife and SSS habitat affected by grazing would depend on future 

interest in grazing leases, but the potential for impacts to wildlife and SSS from grazing would be greater 

than under Alternative B because a much smaller portion of the planning area would be closed to grazing 

(617, 422 acres; 5 percent of BLM-managed lands within the planning area). Exclusion of grazing in 

these areas could reduce the potential for impacts locally to predominantly riparian-dwelling wildlife and 

SSS. Additionally, closure of HVWs to grazing until grazing standards for riparian vegetation health are 

developed, and then permitting grazing in these areas on a case-by-case basis, would reduce the potential 

for impacts to riparian wildlife and SSS habitat over an additional 5,105,497 acres (38 percent). In the 

remainder of BLM-managed lands in the planning area, grazing would be permitted only in areas where 

ecological conditions can support grazing (meaning areas with least 20 percent lichen cover). Where 

grazing occurs, utilization of 50 to 75 percent of primary forage species could cause localized alteration 

of wildlife and SSS habitat through reduction in forage species, which could reduce wildlife abundance 

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Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

and biodiversity in the area. In known caribou habitat, grazing would be permitted on a case-by-case 

basis, and the BLM would impose permit requirements designed to reduce conflicts with caribou and 

protect the health of the land in grazed areas in accordance with Alaska Land Health Standards. These 

actions would help reduce impacts to wildlife habitat in caribou and moose calving and wintering areas 

and crucial winter habitat in the planning area. The requirement for development of a comprehensive 

Grazing Management Plan or a Range Conservation Plan with permit applications would help reduce 

long-term impacts to wildlife and SSS habitat in grazed areas. 

Effects under Alternative D 

Under Alternative D, the potential for impacts to wildlife and SSS from grazing would be higher than 

under Alternatives B and C, as all BLM-managed lands in the planning area would potentially be open to 

grazing on a case-by-case basis, and utilization of 75–100 percent of primary forage species would be 

permitted. Alteration of wildlife and SSS habitat from removal of vegetation in grazed areas would be 

greater than under Alternatives B and C. However, similar to Alternative C, grazing would be permitted 

only in areas where ecological conditions can support grazing. The area of wildlife and SSS habitat 

affected by grazing would depend on future interest in grazing leases. Because there would be no 

requirement for a Grazing Management Plan or a Range Conservation Plan when applying for a grazing 

permit, the potential for long-term impacts to wildlife and SSS habitat in grazed areas would be greater 

than under Alternative C. 

Wildlife and Special Status Species: Effects from Locatable and Salable Minerals 

Management Actions 

In addition to management actions common to all action alternatives, potential impacts from the 

following management topics were considered: 

• Locatable Mineral Withdrawals 

• Areas Closed to Salable Minerals 

Locatable and salable minerals management affects wildlife and SSS because development of mineral 

sites results in a loss of wildlife habitat, and there is generally long-term surface disturbance, noise, and 

human activity at these sites for as long as they remain open and active. Associated access roads may 

result in loss and fragmentation of wildlife and SSS habitat. Mining activities may cause localized 

degradation of important components of wildlife habitat, through contamination of air quality, water, and 

soil. Mining shafts and adits and associated buildings may provide habitat for bats. 

Effects under Alternative A 

Under Alternative A, 4,804,488 acres (36 percent) of BLM-managed lands in the planning area would 

continue to be withdrawn from locatable minerals and closed to salable minerals, including withdrawals 

to protect crucial peregrine falcon habitat and other resource values. There would be no impacts to 

wildlife or SSS from mineral development in these areas. The remainder of BLM-managed lands in the 

planning area (8,661,406 acres; 64 percent) would be open to both locatable and salable mineral 

development. Wildlife and SSS and habitat in these areas could potentially be impacted by future 

mineral development, as described in the previous paragraph. Based on predicted future mineral 

development in the planning area, wildlife and SSS habitats occurring in areas open to locatable 

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Appendix N: Supplemental Impact Analysis Information Section 3. Supplemental Impact Analysis 

development with medium to high mineral development are the most likely to be impacted. Under 

Alternative A, these high potential impacts areas total 294,325 acres (2 percent of BLM-managed lands 

in the planning area) and include the following important wildlife habitat areas: riparian areas 

(associated with 609 river miles; 2 percent of total river miles on BLM-managed lands within the 

planning area), caribou wintering habitat (14,001 acres; less than 1 percent), moose wintering habitat 

(294,325 acres; 33 percent), and a small amount of wood bison range (8,402 acres; less than 1 percent). 

Under Alternative A, the number of adits and mine buildings under BLM management with the potential 

to provide bat habitat would increase as the number of mines increases in the planning area. This effect 

cannot be quantified because growth would be related to demand and economic drivers that cannot be 

predicted. An increase in the number of mines would cause impacts to other wildlife habitats in the mine 

area. 

Effects Common to All Action Alternatives 

Under all action alternatives, WSR corridors would continue to be withdrawn from mineral entry. This 

management would provide protection from habitat loss and other impacts to wildlife and SSS 

associated with mineral development in these areas. Additionally, BMPs/SOPs to protect wildlife and 

other natural resources would help reduce long-term impacts to wildlife and SSS habitat in the planning 

area. Specifically, these actions would minimize mineral development and extraction in stream and river 

channels, deltas, wetlands, riparian zones, active floodplains, lakes, and habitat crucial to local fish and 

wildlife populations, which would help prevent impacts to associated wildlife and SSS. BMPs/SOPs 

would also include measures to minimize degradation of these habitats and expedite reclamation of 

disturbed areas. These measures would help reduce the level of impact to wildlife habitats in areas that 

remain open to locatable and salable mineral development. 

The alternatives would vary in terms of land open to locatable and salable mineral development, and 

land withdrawn from locatable minerals and closed to salable minerals. 

Effects under Alternative B 

Under Alternative B, 9,842,497 acres (73 percent) of BLM-managed lands in the planning area would be 

withdrawn from locatable minerals (retained existing withdrawals as well as new proposed withdrawals) 

and closed to salable minerals in order to protect resource values, which is more than double the amount 

under Alternative A. Therefore, management under this alternative would reduce the potential for 

impacts to wildlife and SSS habitat from mineral development over a larger geographic extent than 

current management. Additionally, because less of the planning area (202,610 acres; 2 percent) would be 

open to locatable mineral development in areas of medium to high mineral potential, the extent of 

impacts to wildlife from mineral development would potentially be less than under Alternative A. Areas 

with the highest potential for impacts to wildlife and SSS would include the following important wildlife 

habitat areas: riparian areas (associated with 409 river miles; 1 percent of total river miles on BLMmanaged lands within the planning area), caribou wintering habitat (133,467 acres; 1 percent), and small 

amounts of moose wintering habitat (8,230 acres; 1 percent), moose calving habitat (5,414 acres; 1 

percent), and wood bison range (4,693 acres; less than 1 percent). While the wildlife habitats most likely 

to be affected would be similar to those under Alternative A, they would include less moose wintering 

habitat and more caribou wintering habitat and moose calving habitat. 

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Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

New mines and associated buildings and associated bat habitat would only occur in areas open to 

locatable and salable mineral development. Because less of the planning area would be available for this 

resource use, there may be fewer new mines and buildings as compared to Alternative A, although 

demand for minerals would still likely be the biggest factor in determining the amount of new mineral 

development. 

Effects under Alternative C 

Under Alternative C, the extent of BLM-managed lands that would be withdrawn from locatable 

minerals (46,953 acres; less than 1 percent of BLM-managed lands in the planning area) and closed to 

salable minerals (283,509 acres; 2 percent) would be less than under Alternatives A and B. Therefore, 

the potential for impacts to wildlife and SSS would be greater. More of the planning area (565,488 acres; 

4 percent) would be open to locatable mineral development in areas of medium to high mineral potential 

than under Alternatives A and B, and would include the following important wildlife habitat areas: 

riparian areas (associated with 1,173 river miles; 4 percent of total river miles on BLM-managed lands 

within the planning area), caribou wintering habitat (403,146 acres; 4 percent), and small amounts of 

moose wintering habitat (16,404 acres; 2 percent), moose calving habitat (5,529 acres; 1 percent) and 

wood bison range (9,672 acres; less than 1 percent). These are generally the same types of important 

wildlife habitats as those under Alternative A and B but the extent of overlap with areas open to 

locatable development that have a high potential for future mineral development would be greater than 

under Alternatives A and B. Therefore, the potential for impacts to important wildlife habitats from 

mineral development would be greater than under Alternatives A and B. 

Similar to Alternatives A and B, the number of new mines and associated buildings that provide habitat 

for bats would likely increase, dependent on future demand for minerals, but would not occur in portions 

of the planning area closed to development. 

Effects under Alternative D 

Under Alternative D, the extent of BLM-managed lands in the planning area that would be withdrawn 

from locatable minerals and closed to salable minerals would be identical to that under Alternative C. 

The potential for impacts to wildlife and SSS would be similar to that under Alternative C, but would 

likely be greater because the case-by-case category for allowing salable development would not apply 

under Alternative D. The portion of the planning area that would be open to locatable mineral 

development in areas of medium to high mineral potential would be identical to that under Alternative C 

and would also include the same types and extent of important wildlife habitat. Overall, based on land 

area open to mineral development the potential for impacts to wildlife and SSS and their habitats would 

be greater than under Alternatives A and B, and similar to those under Alternative C. 

Similar to Alternatives A, B, and C, the number of new mines and associated buildings that provide 

habitat for bats would likely increase, dependent on future demand for minerals, but would not occur in 

portions of the planning area closed to development. New mines and associated buildings would have 

the potential to occur over more of the planning area than under the other alternatives based on areas 

open to development. 

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Wildlife and Special Status Species: Effects from Leasable Minerals Management Actions 

In addition to management actions common to all action alternatives, potential impacts from the 

following management topics were considered: 

• Areas Closed to Leasing 

• NSO Leasable Designation 

Activities associated with leasable minerals have the potential to affect wildlife and SSS habitat through 

habitat loss, degradation, and disturbance. Noise and human activity at these sites may affect wildlife 

behavior and breeding success. Seismic surveys may have long-term effects on habitat by removing 

vegetation and potentially creating new summer and winter OHV routes, which can disturb wildlife and 

fragment habitat. Exploration can harm small mammals and nesting birds and can temporarily displace 

larger mammals such as caribou. Because there is a low development potential for leasable mineral 

resources in the planning area, impacts to wildlife and habitat are also likely to be low, although demand 

could change in the future. 

Effects under Alternative A 

Management under Alternative A would continue to include closures and protective stipulations in 

certain areas that would reduce impacts to wildlife and SSS from leasable mineral activity in the 

planning area. A total of 5,202,221 acres (39 percent) of BLM-managed lands in the planning area would 

be closed to leasing, and 17,521 acres (less than 1 percent) would be designated as NSO leasable. 

Additionally, there would be special stipulations for grizzly/brown bear denning areas and raptor nesting 

areas over a small portion of the INHT (unquantified), which would help reduce impacts to these species 

from leasable mineral actions. Overall, the geographic extent of wildlife habitat covered by management 

that would help reduce impacts to wildlife from impacts associated with leasable minerals would be less 

than under the action alternatives, although the geographic extent of land completely closed to leasing 

would be greater than under Alternatives C and D. 

Effects Common to All Action Alternatives 

All action alternatives would include stipulations that provide protections to wildlife and SSS. While 

numerous stipulations would reduce impacts to wildlife and SSS by protecting resources, there would 

also be stipulations specific to SSS, Dall sheep habitat, caribou calving/postcalving habitat, raptor nests, 

trumpeter swans, high-value moose habitat, and active bald eagle nests. These stipulations would help 

minimize loss of caribou and moose calving and wintering areas, moose and caribou crucial winter 

habitat, Dall sheep habitat, raptor nesting habitat, and migratory bird habitat in the event of mineral 

leasing in these areas. 

The alternatives would vary in terms of areas of land further protected by being closed to leasing, 

designated as NSO leasable, or open, subject to special stipulations leasing. 

Effects under Alternative B 

Alternative B would increase the proportion of the planning area designated as NSO leasable to 

1,597,599 acres (12 percent of BLM-managed lands in the planning area) and would increase the land 

area closed to leasing to 9,350,881 acres (69 percent). The area of BLM-managed lands in the planning 

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area open to leasing subject to standard stipulations would be 2,517,414 acres (19 percent), which is less 

than under Alternatives A, C, and D. Under this alternative, wildlife and SSS habitats over less of the 

planning area could be subject to impacts associated with leasable minerals activity, and more of the 

planning area would have a designation that would have highly restrictive lease stipulations necessary to 

minimize impacts to resources, including wildlife and SSS. 

Effects under Alternative C 

Under Alternative C, the area designated as NSO leasable (6,824, 035 acres; 51 percent) and closed to 

leasing (46,953 acres; less than 1 percent) would be less than under Alternative B, and 6,594,906 acres 

(49 percent) would be open to leasing with standard stipulations. Therefore, this alternative would be 

less likely to reduce impacts to wildlife and SSS from mineral leasing than Alternative B. 

Effects under Alternative D 

Under Alternative D the proportion of the planning area closed to leasing would be identical to that 

under Alternative C. However, the proportion of the planning area designated as NSO leasable (236,556 

acres; 2 percent) would be less than under Alternative B and C, and the proportion designated as open to 

leasing subject to standard stipulations (13,182,385 acres; 98 percent) would be the greatest out of all the 

alternatives. The reduction in impacts to wildlife and SSS from management actions pertaining to 

leasable mineral designations/stipulations would be of lower magnitude and smaller extent than those 

under Alternatives A, B and C. 

Wildlife and Special Status Species: Effects from Lands and Realty Management Actions 

In addition to management actions common to all action alternatives, potential impacts from the 

following management topics were considered: 

• ROW Exclusion and Avoidance Areas 

• Permits and Leases 

• Land Acquisitions 

• Exchanges and Disposals 

Potential impacts on wildlife and SSS habitat from lands and realty management include habitat loss, 

fragmentation, and degradation; disturbance of or direct mortality to individuals; and loss of species 

diversity from ROW development and other permitted facilities. Permits and leases are often associated 

with human uses that increase human presence, which may increase stress on wildlife during breeding, 

migration, and wintering periods. Land acquisitions may benefit wildlife and SSS by increasing the acres 

of wildlife habitat in the planning area, including sensitive or key habitats, and creating more contiguous 

blocks of habitat for management purposes. Conversely, land disposals would reduce the amount of 

habitat under BLM management. Land withdrawals have the potential to benefit wildlife and SSS if they 

close BLM-managed lands in the planning area to activities with the potential to impact species and their 

habitat. Land status changes could result in increases in or loss of wildlife and SSS habitat managed by 

the BLM. Acquisitions, particularly of high-value habitat, can benefit wildlife by creating more 

contiguous blocks of habitat for management purposes. Disposals can fragment management of habitat 

and may impact wildlife if management by the new landowner is less protective of wildlife. Exchanges 

involve both acquiring land and disposing other lands in transactions involving the BLM and another 

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Appendix N: Supplemental Impact Analysis Information Section 3. Supplemental Impact Analysis 

land owner. As such, an exchange can have beneficial or detrimental impacts for wildlife and high-value 

habitat. Habitat value and wildlife impacts are considerations of any decision to go forward with a land 

exchange. 

Effects under Alternative A 

Under Alternative A, all existing ANCSA 17(d)(1) withdrawals would be in place, affecting 12,559,533 

acres (93 percent) of the planning area. Alternative A does not provide additional management guidance 

for lands and realty that would affect wildlife and SSS or their habitats. No ROW exclusion or avoidance 

areas would be identified. Therefore, future ROW development could occur in important wildlife and 

SSS habitats throughout the planning area, potentially leading to habitat loss and degradation, and 

fragmenting habitats or affecting wildlife movements across the landscape. No proposed land 

acquisitions or disposals have been proposed under this alternative that would change the amount of 

wildlife habitats on BLM-managed lands in the planning area. 

Effects Common to All Action Alternatives 

Under all action alternatives, the BLM would implement actions to consolidate land management that 

could affect the amount of wildlife and SSS habitat in the planning area. The BLM would consider 

objectives to protect wildlife and SSS habitat and reduce habitat fragmentation when making decisions 

about land disposal, exchange, and acquisition. Additionally, the BLM would attempt to co-locate linear 

projects within existing ROWs and would require ROWs to provide for unimpeded caribou passage in 

all caribou connectivity corridors or where crucial winter habitat exists. Additional SOPs/BMPs 

designed to protect wetlands and streams/water quality and reduce the establishment and spread of NNIS 

would provide additional protections to wildlife and SSS from actions associated with lands and realty. 

The alternatives would vary in terms of acreage of ROW exclusion and avoidance areas, and in acreage 

of wildlife habitat that is proposed for disposal, exchange, and acquisition. 

Effects under Alternative B 

Identification of ROW exclusion and avoidance areas under Alternative B would help minimize habitat 

fragmentation and degradation in these areas. ROW exclusion areas would occur on 1,464,069 acres 

(11 percent) of BLM-managed lands in the planning area and would include important wildlife habitat, 

such as the Innoko Bottoms Priority Wildlife Habitat Area, Northern and South Connectivity Corridors, 

and the Unalakleet Wild River Corridor. ROW avoidance areas would occur on an additional 8,824,848 

acres (66 percent) and would provide some protections to additional areas, including ecosystems that 

may include rare wildlife habitats. For permits and leases, restrictions on where trapping/subsistence 

cabins can occur (e.g., in relation to riparian areas and in lands managed for wilderness character) would 

have a limited effect on wildlife, as they would reduce impacts in these locations but would still be 

located elsewhere. Areas with the greatest potential for habitat loss, degradation, and fragmentation from 

development of ROWs would be areas outside of ROW exclusion and avoidance areas. Important 

wildlife habitats with the greatest potential to be affected by ROW development include caribou calving 

habitat (84,657 acres; 53 percent) and wintering habitat (2,173,376 acres; 21 percent), moose calving 

habitat (48,746 acres; 13 percent) and wintering habitat (93,264 acres; 10 percent), Audubon Important 

Bird Areas (44,074 acres; 14 percent), muskox range (843,052 acres; 26 percent), and wood bison range 

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(736,928 acres; 20 percent). The potential for impacts to important wildlife habitats from ROW 

development would be less than under Alternative B. 

Under Alternative B, the BLM would pursue opportunities to acquire lands within the INHT NTMC, 

which could result in an increase in wildlife habitat in the planning area. Under this alternative, 342,360 

acres (3 percent) of BLM-managed lands in the planning area are available for exchange, which could 

reduce the current amount of wildlife habitat on BLM-managed lands in the planning area by a small 

amount (3,278 acres). However, these losses would be offset by wildlife habitat acquired in the 

exchanges. Table 3.3.3-4 provides a breakdown of available disposals, acquisitions, and exchanges under 

Alternative B that would affect BLM management of important wildlife habitat in the planning area. 

While land exchanges represent possible reductions in the high-value wildlife habitats managed by the 

BLM within the planning area, there could also be increases in high-value wildlife habitats associated 

with exchanges. 

Table 3.3.3-4: Available Disposals, Acquisitions, and Exchanges under Alternative B, by Indicator 

Indicator 

Acres/Miles Available 

for Disposal or 

Exchange 

Acres/Miles Available 

for Acquisition 

Acres/Miles Available 

for Exchange Only 

Acres of Wildlife Habitat, (essentially the 

entire planning area) 

0 acres 339,082 acres 342,360 acres 

Streams (with associated riparian areas) 0 miles 770 miles 802 miles 

Caribou Calving Habitat 0 acres 0 acres 0 acres 

Caribou Wintering Habitat 0 acres 138,558 acres 222,074 acres 

Moose Calving Habitat 0 acres 11,884 acres 64,663 acres 

Moose Wintering Habitat 0 acres 23,517 acres 79,179 acres 

Innoko Bottoms Priority Wildlife Habitat 

Area 

0 acres 20,417 acres 17,280 acres 

Audubon Important Bird Areas 0 acres 0 acres 0 acres 

Muskox Range 0 acres 0 acres 0 acres 

Wood Bison Range 0 acres 214,058 acres 63,668 acres 

Effects under Alternative C 

Alternative C would have a greater risk for habitat fragmentation and degradation than Alternative B, 

because there would be no ROW exclusion areas. Additionally, a smaller portion of the planning area 

(7,069,494 acres; 52 percent) would be identified as ROW avoidance area, and ROW avoidance areas in 

the connectivity corridor would only be for linear realty actions. Areas outside of ROW avoidance areas, 

with the greatest potential for habitat loss, degradation, and fragmentation from development of ROWs 

would include caribou calving habitat (112,609 acres; 70 percent) and wintering habitat (4,182,673 

acres; 41 percent), moose calving habitat (107,684 acres; 28 percent) and wintering habitat (216,665 

acres; 24 percent), Audubon Important Bird Areas (87,447 acres; 28 percent), muskox range (1,361,245 

acres; 41 percent), and wood bison range (1,231,414 acres; 33 percent). These are the same important 

wildlife habitats as those with the greatest potential to be impacted under Alternative B, but the 

geographic extent of their overlap with areas outside of ROW avoidance areas would be much higher 

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under Alternative C. Therefore, the potential for impacts to important wildlife habitats from ROW 

development would be greater than under Alternative B, but less than under Alternative A. 

Under Alternative C, potential increases in wildlife habitat under BLM management, including highvalue wildlife habitats, would be identical to those under Alternative B (Table 3.3.3-5). Potential effects 

on wildlife habitat associated with disposals and exchanges would likely be similar to those under 

Alternative B, although the total land area in this category is slightly higher. Similar to Alternative B, 

there could be reductions or increases in high-value wildlife habitats managed by the BLM as a result of 

land exchanges under Alternative C. 

As with Alternative B, these actions would not affect wildlife and SSS habitat in lands with wilderness 

characteristics being managed as a priority or connectivity corridors. Overall, this alternative would have 

a larger adverse impact on wildlife habitat, and potentially SSS habitat, than Alternative B. 

Table 3.3.3-5: Available Disposals, Acquisitions, and Exchanges under Alternative C, by Indicator 

Indicator 

Acres/Miles Available 

for Disposal or 

Exchange 

Acres/Miles Available 

for Acquisition 

Acres/Miles Available 

for Exchange Only 

Acres of Wildlife Habitat, (essentially the 

entire planning area) 

0 acres 339,082 acres 356,942 acres 

Streams (with associated riparian areas) 0 miles 770 miles 841 miles 

Caribou Calving Habitat 0 acres 0 acres 0 acres 

Caribou Wintering Habitat 0 acres 138,558 acres 223,847 acres 

Moose Calving Habitat 0 acres 11,884 acres 64,623 acres 

Moose Wintering Habitat 0 acres 23,517 acres 86,522 acres 

Innoko Bottoms Priority Wildlife Habitat 

Area 

0 acres 20,417 acres 17,280 acres 

Audubon Important Bird Areas 0 acres 0 acres 17,530 acres 

Muskox Range 0 acres 0 acres 0 acres 

Wood Bison Range 0 acres 214,058 acres 63,877 acres 

Effects under Alternative D 

Alternative D would have a greater risk for wildlife and SSS habitat fragmentation and degradation than 

Alternatives B and C, because there would be no ROW exclusion areas, and the acreage of ROW 

avoidance areas would be the lowest of all the action alternatives (5,130,927 acres; 37 percent). Areas 

outside of ROW avoidance areas, and outside of areas where ROWs would be permitted on a case-bycase basis, would have the greatest potential for habitat loss, degradation, and fragmentation from 

development of ROWs. These areas would include riparian areas (associated with 19,151 river miles; 58 

percent of total river miles on BLM-managed lands within the planning area), caribou calving habitat 

(150,380 acres; 94 percent) and wintering habitat (5,924,308 acres; 58 percent), moose calving habitat 

(130,740 acres; 34 percent) and wintering habitat (282,198 acres; 32 percent), Audubon Important Bird 

Areas (97,014 acres; 31 percent), muskox range (1,988,298 acres; 60 percent), and wood bison range 

(2,011,664 acres; 54 percent). Unlike under Alternatives B and C, riparian areas would not be ROW 

avoidance areas, so species that utilize these habitats would have a higher risk of impacts associated with 

ROW development. The other important wildlife habitats with the greatest potential to be impacted are 

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the same as those under Alternatives B and C, but the geographic extent of their overlap with areas open 

to ROWs would be larger under Alternative D. Therefore, the potential for impacts to important wildlife 

habitats from ROW development would be greater than under Alternatives B and C, but less than under 

Alternative A. 

Realty actions under Alternative D would have a greater potential to reduce the amount of wildlife 

habitat managed by the BLM than Alternatives B and C. Because the BLM would not pursue 

opportunities to acquire public land, there would be no potential increase in wildlife habitat. 

Additionally, 451,173 acres (3 percent) would be available for disposal or exchange, which could result 

in the loss of wildlife habitat managed by the BLM with no habitat gained in return (Table 3.3.3-6), and 

there would be no restriction on areas that could be considered for disposal. Based on potential disposals 

and exchanges under Alternative D, there could potentially be greater reductions in high-value wildlife 

habitat than under Alternatives A, B, and C. Overall, this alternative would have the potential for a 

greater adverse impact on wildlife habitat than the other alternatives. 

Table 3.3.3-6: Available Disposals, Acquisitions, and Exchanges under Alternative D, by Indicator 

Indicator 

Acres/Miles Available 

for Disposal or 

Exchange 

Acres/Miles Available 

for Acquisition 

Acres/Miles Available 

for Exchange Only 

Acres of Wildlife Habitat (essentially the 

entire planning area) 

451,173 acres 0 acres 0 acres 

Streams (with associated riparian areas) 1,056 miles 0 miles 0 miles 

Caribou Calving Habitat 0 acres 0 acres 0 acres 

Caribou Wintering Habitat 238,535 acres 0 acres 0 acres 

Moose Calving Habitat 127,925 acres 0 acres 0 acres 

Moose Wintering Habitat 278,504 acres 0 acres 0 acres 

Innoko Bottoms Priority Wildlife Habitat 

Area 

74,594 acres 0 acres 0 acres 

Audubon Important Bird Areas 17,530 acres 0 acres 0 acres 

Muskox Range 0 acres 0 acres 0 acres 

Wood Bison Range 143,421 acres 0 acres 0 acres 

Wildlife and Special Status Species: Effects from Recreation and Visitor Services 

Management Actions 

In addition to management actions common to all action alternatives, potential impacts from the 

following management topics were considered: 

• INHT SRMA 

• BSWI ERMA – OHV 

• Unalakleet Wild River Corridor – Travel Decisions 

Recreation can affect wildlife in the planning area by introducing humans into remote areas. The 

presence of motorized vehicles and humans can disturb wildlife, potentially resulting in increased energy 

expenditure due to short- and long-term avoidance of the activity, which can potentially lead to reduced 

reproductive success and increased susceptibility to disease and predation. Disturbance from recreation 

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Appendix N: Supplemental Impact Analysis Information Section 3. Supplemental Impact Analysis 

may also reduce an area’s suitability as nesting or calving habitat. Wildlife may habituate to human 

presence, which could increase the risk of injury or mortality from human-wildlife interactions. 

Recreation may also result in degradation or loss of habitat, although there are no recreation facilities in 

the planning area where concentrated recreation use is likely to occur. OHV use can degrade wildlife 

habitats through surface disturbance (particularly when soils are not frozen), crush nests and small 

terrestrial species, and lead to the creation of new trails, which can increase the amount of area disturbed. 

OHVs may also introduce NNIS, which could adversely impact wildlife habitat. OHVs can also cause 

direct mortality to subnivean species and damage their habitats. Most recreation in the planning area 

occurs along the INHT corridor, and wildlife and SSS in this area are the most likely to be affected. 

Hunting and fishing have a direct impact on wildlife through mortality and reduction in prey species, 

although because game populations are managed by ADF&G, these impacts are not the focus of this 

analysis. Recreational berry picking may affect grizzly bears, migratory birds, and other species by 

resulting in a localized reduction in availability of this food source. 

There are no alternative-specific management actions for this resource; therefore, impacts from 

Alternatives B, C, and D are described in combination below. 

Effects under Alternative A 

Under Alternative A, there would be no specific management actions pertaining to recreation that would 

affect wildlife and SSS. Under current management, the effects described in the previous paragraph 

would have the potential to occur throughout the planning area wherever recreation occurs. 

Effects Common to All Action Alternatives 

Under all action alternatives, the BLM would implement management actions that apply to the primary 

recreational use areas in the planning area: the INHT SRMA, the BSWI ERMA, and the Unalakleet Wild 

River Corridor. Recreation management would have the potential to affect wildlife and SSS and habitat 

in these areas by influencing the amount of associated human presence and habitat disturbance. As a 

result of their designation as recreational use areas, the proposed management would allow the BLM to 

reduce the impacts that recreation may have on wildlife habitats, as described further in the following 

sections. The BLM would also implement SOPs/BMPs that would help protect streams, water quality, 

wetlands, and floodplains, as well as associated wildlife and SSS. 

Under all action alternatives, the entire planning area would be managed as SRMA or ERMA. More 

specifics on impacts associated with OHV use are included in the section “Wildlife and Special Status 

Species: Effects from Travel and Transportation Management Actions.” 

Wildlife and Special Status Species: Effects from Travel and Transportation Management 

Actions 

In addition to management actions common to all action alternatives, potential impacts from the 

following management topics were considered: 

• Vegetation and Wildlife Travel Management 

• Travel Management Decisions (all) 

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Effects under Alternative A 

Under Alternative A, BLM-managed lands in the planning area would continue to be managed as 

undesignated, allowing OHV and over-snow vehicle cross-country use with the exception of the 

Unalakleet Wild River Corridor, which does not allow casual OHV use. OHV use can result in loss or 

degradation of wildlife habitat from physical disturbance, can lead to loss of habitat through wildlife 

avoidance of the area, and can potentially fragment habitat if new trails are created. Use of OHVs and 

other vehicles is also associated with noise that has the potential to affect the behavior and breeding 

success of nearby wildlife and SSS. 

Effects Common to All Action Alternatives 

Under all action alternatives, designating all of BLM-managed lands in the planning area as “Limited” 

would reduce the potential for loss, degradation, and fragmentation of wildlife habitats, as OHV use 

would be limited to certain areas or specific trails. Additionally, implementing travel management 

planning would allow the BLM to develop a travel network that meets the needs of subsistence and other 

users while considering potential impacts to wildlife and SSS habitat in the planning area. 

The alternatives would vary in terms of area of land within TMAs and the types of restrictions on OHV 

use in these areas and in caribou habitat areas. 

Effects under Alternative B 

Under Alternative B, 565,955 acres (4 percent) of BLM-managed lands in the planning area would be 

within TMAs. Within these areas, there would be additional prohibitions or restrictions on OHV use, 

such as prohibiting summer casual and subsistence OHV access or limiting these uses to existing trails. 

These actions would help prevent degradation of habitat and creation of new trails that might fragment 

habitat, as the risk for these impacts would be greatest during the summer when the ground is thawed. 

The geographic extent of TMAs under this alternative is the largest of all the action alternatives. 

Travel management decisions in caribou habitat under this alternative would include development of 

management actions if there is evidence of habitat degradation, including OHV use limitations, trail 

relocation, trail hardening, or trail closure. These actions would help reduce impacts to habitat used by 

caribou and other wildlife and SSS. In the Innoko Bottoms Priority Wildlife Habitat Area, restrictions on 

airboats and hovercraft would reduce disturbance impacts to wildlife and SSS and their habitats, 

including priority raptor nests. 

Effects under Alternative C 

Under Alternative C, 273,242 acres (2 percent) of BLM-managed lands the planning area would be 

within TMAs, which is half the area under Alternative B. Additionally, prohibitions and restrictions on 

OHV use in these areas would be less protective than under Alternative B. Therefore, the magnitude and 

extent of impacts to wildlife and SSS and their habitats from OHV use would potentially be greater than 

under Alternative B. Management actions in caribou habitat and the Innoko Bottoms Priority Wildlife 

Habitat Area and associated effects on wildlife would be identical to those under Alternative B. 

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Effects under Alternative D 

Under Alternative D, the portion of BLM-managed lands in the planning area within TMAs would be 

identical to the portion under Alternative C. However, prohibitions and restrictions on OHV use in these 

areas would be less protective than under Alternative C. Therefore, the magnitude of impacts to wildlife 

and SSS and their habitats from OHV use would potentially be greater than under Alternatives B and C. 

There would be no additional travel management for caribou habitat and the Innoko Bottoms Priority 

Wildlife Habitat Area, so disturbance impacts to wildlife and SSS in these areas would not be reduced as 

they would be under Alternatives B and C. 

Wildlife and Special Status Species: Effects from Areas of Critical Environmental 

Concern Management Actions 

In addition to management actions common to all action alternatives, potential impacts from the 

following management topics were considered: 

• ACEC Designations 

Generally, special management areas such as ACECs result in increased protection of wildlife and SSS 

and long-term improvement or maintenance of habitat quality as a result of special management and use 

restrictions in these areas. 

The alternatives would vary in terms of land area within designated ACECs. 

Effects under Alternative A 

Under Alternative A, 1,884,376 acres (14 percent) of BLM-managed lands in the planning area would be 

designated as ACECs. Management actions that predominantly pertain to water resources, fisheries, and 

forests and woodlands would reduce the potential for impacts to wildlife and SSS in these areas from 

human disturbance and habitat loss, degradation, and fragmentation associated with various resource 

uses. Existing ACEC designations overlap riparian areas (associated with 4,086 river miles; 12 percent 

of total river miles on BLM-managed lands within the planning area), caribou wintering habitat 

(1,858,841 acres; 18 percent), moose wintering habitat (151,362 acres; 17 percent), the Innoko Bottoms 

area (798 acres; less than 1 percent), muskox range (1,492,578 acres; 45 percent) and wood bison range 

(181,473 acres; 5 percent). For these and other wildlife over the same geographic extent, ACEC 

management actions would reduce the potential for impacts from various resource uses. 

Effects Common to All Action Alternatives 

There are no effects common to all action alternatives. 

Effects under Alternative B 

Under Alternative B, 3,912,698 acres (29 percent) of BLM-managed lands in the planning area would be 

designated as ACECs, which is more than double the area under Alternative A. The BLM would 

implement BMPs/SOPs in ACECs that would provide additional protections to wildlife in these areas. 

These BMPs/SOPs include actions to reduce the potential for impacts to caribou, Dall sheep, and priority 

raptor species and their habitats during crucial periods. Additionally, management actions that benefit 

wildlife and SSS would occur over a larger area than under Alternative A. ACEC designations under this 

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alternative overlap riparian areas (associated with 9,202 river miles; 28 percent of total river miles on 

BLM-managed lands within the planning area), caribou wintering habitat (3,710,592 acres; 36 percent); 

moose calving habitat (49,963 acres; 13 percent) and wintering habitat (693,711 acres; 78 percent), the 

Innoko Bottoms Area (21,366 acres; 9 percent), Audubon Important Bird Areas (4,687 acres; 1 percent), 

muskox range (2,207,220 acres; 67 percent) and wood bison range (438,082 acres; 12 percent). In these 

areas, ACEC management under Alternative B would reduce potential impacts to these wildlife habitats 

from human disturbance and habitat loss, degradation, and fragmentation associated with various 

resource uses. The geographic extent of important wildlife habitats affected would be greater than under 

Alternative A. 

Effects under Alternative C 

Under Alternative C, there would be no ACECs designated in the planning area. However; Alternative C 

would still apply some management actions to areas with identified fish and cultural R&Is that would 

also minimize impacts to wildlife and SSS. Such as ROW avoidance areas and NSO for mineral leasing 

and externally proposed structures. 

Effects under Alternative D 

Under Alternative C, there would be no ACECs designated in the planning area. Alternative D would not 

apply any specific management to areas with identified fish and cultural R&Is and would have impacts 

of greater magnitude and geographic extent to wildlife and SSS than Alternative B and C. 

Wildlife and Special Status Species: Effects from National Trails Management Actions 

In addition to management actions common to all action alternatives, potential impacts from the 

following management topics were considered: 

• INHT NTMC 

The INHT supports habitats used by wildlife and SSS. This trail is a focal area for recreation and is 

associated with increased human presence and motorized uses that have the potential to impact wildlife 

and SSS. While national trails management generally does not pertain to wildlife, it may help reduce the 

potential for impacts wildlife and SSS or their habitats from various land uses. 

Effects under Alternative A 

Under Alternative A, the INHT would not be designated as a NTMC and would not be subject to 

associated management. However, the BLM would continue to implement management actions for the 

INHT that are designed to reduce surface disturbance from other resources uses, including minerals, 

forestry and woodland products, and livestock grazing. These actions could reduce the potential for 

impacts to wildlife and SSS in the INHT area from these resource uses. 

Effects Common to All Action Alternatives 

Under all action alternatives, effects to wildlife and SSS from disturbance and habitat degradation 

associated with use of the INHT would be similar to those under Alternative A. However, the BLM 

would establish the INHT NTMC in the planning area. This designation would include additional 

management with prescriptions such as exclusion from coal leasing, noise restrictions, and a “Limited” 

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travel management designation. Additionally, the BLM would implement BMPs/SOPs to limit the 

spread of NNIS, which could result in minor, typically localized benefits to wildlife and SSS. 

The alternatives would vary in terms of acreage designated as the INHT NTMC. 

Effects under Alternative B 

Under Alternative B, designation of the INHT NTMC on 288,466 acres (2 percent) of BLM-managed 

lands in the planning area could reduce the potential for impacts to wildlife and SSS and their habitats 

over this small portion of the planning area, with slightly reduced impacts relative to Alternative A. 

Effects under Alternative C 

Under Alternative C, the INHT NTMC would consist of 273,242 acres (2 percent) of BLM-managed 

lands in the planning area. Therefore, the portion of the planning area in which potential impacts to 

wildlife and SSS and their habitats from use of the INHT could be reduced would be similar to, but 

slightly smaller than, that under Alternative B. 

Effects under Alternative D 

Effects under Alternative D would be identical to effects under Alternative C because the INHT NTMC 

would be the same size. 

Wildlife and Special Status Species: Effects from Wild and Scenic Rivers Management 

Actions 

In addition to management actions common to all action alternatives, potential impacts from the 

following management topics were considered: 

• Travel Management Decisions 

• UAS Uses 

WSR corridors provide habitat for wildlife and SSS that use stream and riparian habitats. Management to 

preserve the outstanding natural, cultural, and recreational values in a free-flowing condition promotes 

wildlife habitat health in these areas. However, human disturbance associated with recreational use of 

these areas may disturb wildlife and SSS. 

Effects under Alternative A 

The only designated WSR corridor under Alternative A would be the Unalakleet Wild River Corridor, 

which covers 46,953 acres (less than 1 percent) of BLM-managed lands the planning area. Management 

direction to preserve the environment of the river and river corridor in a natural, primitive condition 

would limit impacts to riparian wildlife and SSS in this area, including a variety of migratory birds. 

Alternative A does not include management direction regarding use of UASs or travel management 

decisions that would pertain to wildlife and SSS or their habitat in WSRs. Additionally, 18 river 

segments (378,073 acres; 3 percent) have been identified as eligible. In accordance with BLM Manual 

6400, projects on BLM-managed lands within the eligible river corridor or on lands that are adjacent to 

or border eligible rivers must consider guidelines to protect outstandingly remarkable values (ORVs) 

from activities such as locatable, salable, and leasable mineral development; transportation and 

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Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

motorized travel; ROW authorization; recreation; wildlife and fish projects; and livestock grazing, which 

could reduce impacts to wildlife and their habitats within those eligible river corridors from these 

resource uses, if implemented. 

Effects Common to All Action Alternatives 

All action alternatives would include additional management actions in WSR corridors that may reduce 

impacts to wildlife and SSS from various resource uses, such as acquiring additional lands within 

designated WSR corridors, which would potentially increase the amount of protected wildlife and SSS 

habitat, prohibiting or restricting development and some types of uses in these areas with the potential to 

degrade or fragment habitats, and minimizing noise intrusions that could disturb nesting birds and other 

wildlife and SSS. 

The alternatives would vary in terms of area of land within WSR corridors and in the magnitude of 

management restrictions pertaining to OHVs and UASs in these areas. 

Effects under Alternative B 

Under Alternative B, the Unalakleet Wild River Corridor would remain in place. An additional 378,073 

acres (3 percent) have been recommended as suitable for WSR designation. Under Alternative B, the 

Unalakleet Wild River Corridor and all corridors recommended as suitable would be subject to 

management actions that could reduce impacts to wildlife from various land uses, as described under 

Effects Common to All Action Alternatives. Because Alternative B provides actual protections for the 

378,073 acres of rivers recommended as suitable, compared with the guidelines that would be considered 

for those same 378,073 acres determined eligible, Alternative B would have a greater potential to reduce 

impacts to wildlife from resource uses in these areas compared with Alternative A. Additionally, this 

alternative includes travel management decisions that would limit OHV use in designated and eligible 

WSR corridors, which would reduce associated disturbance and habitat degradation. Restrictions on 

some uses of UASs could also reduce disturbance to wildlife and SSS (predominantly birds). 

Effects under Alternative C 

Under Alternative C, 46,953 acres (less than 1 percent) of BLM-managed lands in the planning area 

would be within WSR corridors (Unalakleet Wild River Corridor), which is identical to the acreage 

under Alternative A and less than that under Alternative B. Travel management decisions and 

restrictions and management pertaining to UASs, which would be similar to those under Alternative B, 

would provide a similar reduction of potential impacts to wildlife and SSS from resource uses in these 

areas, but the geographic extent of these effects would be less than under Alternative B. 

Effects under Alternative D 

Under Alternative D, the land area within WSR corridors (Unalakleet Wild River Corridor) would be 

identical to the area under Alternatives A and C. Compared to Alternatives B and C, management 

pertaining to travel management and UASs would be less restrictive (e.g., takeoff and landing of casual 

use UASs would be allowed in the WSR corridor) and would have slightly less ability to reduce impacts 

to wildlife and SSS from resource uses in these areas. 

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Wildlife and Special Status Species: Effects from Hazardous Materials and Health and 

Human Safety Management Actions 

Wildlife and SSS may be affected by the same factors that present risks to human health and safety. 

Releases of hazardous materials into the environment have the potential to degrade habitat by affecting 

water quality, soil productivity, and other habitat components. Exposure of wildlife to hazardous 

materials through dermal contact or ingestion of water, plant materials, or prey items contaminated by 

toxic substances can lead to mortality or reduced reproductive success. Presence of hazardous materials 

in the environment may also lead to bioconcentration via the food chain. These impacts generally would 

have the greatest impact on wildlife and SSS present in the release area, but could migrate beyond the 

release site, particularly if they are released into water or bioaccumulated by prey species. 

Abandoned mine shafts and adits are areas of concern regarding hazardous materials safety in the 

planning area. However, they also provide habitat for bats. Therefore, closure of these areas could cause 

a loss of bat habitat, unless the mines are closed in a manner that allows access for bats. 

Effects under Alternative A 

Under Alternative A, the BLM would continue to meet all applicable laws, regulations, and policies 

pertaining to use and storage of hazardous materials, cleanup of spills, and remediation of contaminated 

sites, among others. The BLM would also continue to implement its Hazard Management and Resource 

Restoration program. These ongoing actions would reduce the potential for impacts to wildlife and SSS 

in areas where hazardous materials are used or stored and would help improve or restore habitat in 

contaminated sites. Cleanup of the Red Devil Mine and the Kolmakof Mine Site would continue, 

resulting in an improvement in wildlife and SSS habitat in these areas. 

Effects Common to All Action Alternatives 

The action alternatives would include numerous SOPs/BMPs pertaining to hazardous materials and 

wastes that are designed to reduce the risk of releases into the environment, particularly in riparian zones 

and in the vicinity of waterbodies. These measures would reduce the risk of habitat degradation and 

exposure of wildlife to hazardous materials. Effects would be greatest in areas where hazardous 

materials are used or stored. 

The alternatives would vary in terms of management actions in areas where complete cleanup of 

hazardous material spills is not possible. 

Effects under Alternative B 

The one difference between Alternative B and the other action alternatives is that the BLM would 

require use of alternative power or fuel for energy generation at facilities where complete cleanup of 

hazardous material spills is not possible and would retrofit existing facilities in these areas as a 

component of the permit/lease/ROW renewal. This management action would reduce the potential for 

impacts to wildlife and SSS and their habitat in these areas by reducing the potential that petroleum and 

other fuels would be released into the environment. The extent of areas where complete cleanup of 

hazardous material spills is not possible would not change under Alternative B, but risks would be 

minimized in these areas. 

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Effects under Alternative C 

Alternative C would be similar to Alternative B, except that there would be no requirement to retrofit 

existing facilities to use alternative power or fuel. Therefore, there would be no associated reduction in 

the potential for impacts to wildlife and SSS in the vicinity of existing facilities. The extent of areas 

where complete cleanup of hazardous material spills is not possible would be the same as under 

Alternatives A and B. 

Effects under Alternative D 

Under Alternative D, there would be no management pertaining to use of alternative power or fuel for 

energy generation at facilities in areas where complete cleanup is not possible. Therefore, risks to 

wildlife and SSS in these areas would be the same as under Alternative A, but with the SOPs and BMPs 

discussed under Effects Common to All Action Alternatives in place under Alternative D, which would 

reduce the risk of habitat degradation and exposure of wildlife to hazardous materials. The extent of 

areas where complete cleanup of hazardous material spills is not possible would be the same as under 

Alternatives A, B, and C. 

Wildlife and Special Status Species: Effects from Climate Change 

Climate change in the planning area has the potential to impact wildlife and SSS by causing changes in 

vegetation communities and therefore wildlife habitat types and by causing direct mortality from 

entrapments, a result of increased temperatures, permafrost thaw, decreased snow cover, sea level rise, 

and later freeze-up dates. For some species, habitat availability and value may increase (e.g., trumpeter 

swan) and for other species, habitat is likely to decrease (e.g., wetland species). Climate change may also 

result in loss or degradation of habitats by contributing to the establishment and spread of NNIS and by 

causing an increase in the intensity, size, and frequency of wildland fire. However, increased wildland 

fire frequency could benefit some species, such as moose, by increasing availability of forage species. 

Key life cycle periods (such as breeding seasons) and migration periods may shift in response to climate 

change. Outbreaks of parasites and disease are also expected to increase in presence and impact. 

Effects under Alternative A 

Under Alternative A, the BLM would not implement adaptive management or actions to predict and plan 

for future changes in wildlife distribution and crucial periods. The BLM would continue to meet all 

applicable laws, regulations, and policies, which would include requirements to minimize impacts to 

SSS and migratory birds and would consider objectives for improving or maintaining wildlife habitat in 

its management approach. 

Effects Common to All Action Alternatives 

Under all action alternatives, the BLM would consider climate change and future changes to the 

planning area that have the potential to affect wildlife in its adaptive management approach. Climate 

change impacts would be considered in project approval and funding and in project design and 

operation. Adaptive management for vegetation would include modeling to predict changes in vegetation 

cover types, which would also guide adaptive management for wildlife. Adaptive management would 

also include the ability to shift proposed timing restrictions to adapt to changes in wildlife and SSS 

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crucial periods, such as nesting or calving. This management approach would help counteract some, but 

not all, cumulative climate change impacts to wildlife and SSS and their habitats. 

The action alternatives would vary in terms of number of landscape connectivity corridors, and 

cumulative management actions associated with various resources and resource uses that could provide 

additional benefits to wildlife. 

Effects under Alternative B 

Alternative B would have the greatest effect on wildlife and SSS by creating two connectivity corridors 

that would maintain landscape connectivity between the Innoko and Yukon Delta NWRs and allow for 

future movement of wildlife and SSS in response to changing conditions associated with climate change. 

The combined effect of additional management actions for multiple resources and resource uses under 

this alternative, as described throughout the wildlife effects analysis, could provide some additional 

protections in certain habitat types in the planning area that may help counteract climate change impacts 

to wildlife and SSS in these areas and help maintain their function as wildlife movement corridors. 

Restrictions on development and other actions in riparian areas and within floodplains could help 

counteract climate change impacts to wildlife and SSS in these habitats by reducing the potential for 

impacts to wildlife and SSS from resource uses. In areas with special designations, such as ACECs, 

lands with wilderness characteristics, and WSRs, management restrictions that reduce impacts to wildlife 

and SSS may also help counteract climate change impacts to wildlife and SSS. 

Effects under Alternative C 

Under Alternative C, the BLM would establish one connectivity corridor, which would maintain 

landscape connectivity and allow for future movement of wildlife, but would provide fewer options for 

movement between the Innoko and Yukon Delta NWRs than Alternative B. The cumulative effect of 

additional management actions for multiple resources and resource uses under this alternative would be 

less than under Alternative B but could still include a reduction in impacts to wildlife and SSS occurring 

in areas where the additional management applies. Overall, this alternative would be less effective in 

counteracting cumulative climate change impacts than Alternative B. 

Effects under Alternative D 

Under Alternative D, the BLM would not establish any connectivity corridors for wildlife and SSS in the 

planning area. While the BLM would continue to implement adaptive management, it would not manage 

corridors to maintain landscape connectivity in the planning area, and wildlife movement across the 

landscape could be impeded by future development, although there are no medium or high mineral 

potential areas located between the two national wildlife refuges. There would also be fewer additional 

management actions that could reduce potential impacts to wildlife and SSS in certain areas and habitat 

types, compared to Alternatives B and C. Overall, management actions designed to counteract 

cumulative climate change impacts under Alternative D would be less effective than those under 

Alternatives B and C, but more effective than those under Alternative A. 

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Wildlife and Special Status Species: Cumulative Effects 

Table 3.3.3-7 summarizes the results of the cumulative impacts analysis for wildlife and SSS and their 

habitats for all alternatives. 

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Table 3.3.3-7: Cumulative Effects Analysis for Wildlife and Special Status Species 

Trends and Forecasts of 

Wildlife and Special Status

Species in Consideration of

Past and Present Actions 

Trends and Forecasts of 

Wildlife and Special Status 

Species in Consideration of 

Past, Present, and 

Reasonably Foreseeable 

Future Actions 

(Alternative A) 

Trends and Forecasts of 

Wildlife and Special Status 

Species in Consideration of

Past, Present, and 

Reasonably Foreseeable

Future Actions 

(Alternative B) 

Trends and Forecasts of 

Wildlife and Special Status 

Species in Consideration of

Past, Present, and Reasonably

Foreseeable Future Actions 

(Alternative C) 

Trends and Forecasts of Wildlife and 

Special Status Species in Consideration 

of Past, Present, and Reasonably

Foreseeable Future Actions 

(Alternative D) 

Wildlife populations appear to 

be fluctuating within what is 

likely a natural range but are 

variable by species. Both the 

western Arctic and the 

Mulchatna Caribou herds are in 

decline. The other small nonmigratory herds near the 

Kuskokwim River are stable or 

declining. Other species 

populations appear stable, such 

as Alaskan hare and many 

furbearers. Other populations 

may be increasing, such as 

plains bison, brown bear, black 

bear, and peregrine falcon. 

Other populations may be 

decreasing, such as muskox, 

Dall sheep, olive-sided 

flycatcher, and other migratory 

birds. For other species, such 

as lynx, red fox, and little brown 

bat, current trends are not 

known. Migratory bird species 

appear to be experiencing 

declines associated with 

impacts on winter ranges or 

migration routes outside of 

Alaska. 

Trend: No change overall for

habitat but degrading for

some species and improving

for others. 

Reasonably foreseeable future 

actions with the greatest 

potential to affect wildlife and 

SSS, based on likelihood of 

occurrence or predicted 

increases from current levels, 

include the Donlin Gold Project, 

other mineral exploration and 

mining and development of 

transportation corridors. While 

reasonably foreseeable future 

actions generally would have 

localized impacts on wildlife and 

SSS habitats, climate change 

would continue to alter habitats 

throughout the planning area, 

and cumulative impacts to 

certain populations or species 

could occur if key habitats are 

degraded or fragmented. Under 

this alternative, adherence to 

existing regulations and internal 

BLM guidance would continue 

to help prevent impacts to 

sensitive species and habitats. 

Trend: Existing trends would 

continue, with no trend 

overall, but degrading for

some species and improving 

for others. With increased 

development in the planning

area, species with affected

habitat may experience a 

trend of increased 

degradation or lessened

improvement. 

Management under 

Alternative B would include 

BMPs/SOPs and additional 

restrictions that would provide 

localized protection to wildlife 

and SSS and habitats. 

Management specifically 

designed to prevent cumulative 

impacts to wildlife and SSS, 

including cumulative 

management decisions, 

adaptive management, and 

establishment of two 

connectivity corridors, would 

help offset landscape-level 

impacts to wildlife habitats. 

Trend: Improving. It is

expected that implementing

Alternative B would result in 

an improved trend for most

wildlife and SSS. For species

with habitat or populations

that are degrading, this 

alternative would lessen the 

rate of degradation or

stabilize or counter the 

existing trend. For species

with habitat or populations

that are improving, this 

alternative would allow the 

improvement to continue at

a similar or greater rate. 

Management under Alternative C 

would include BMPs/SOPs and 

additional restrictions to provide 

localized protection to wildlife and 

SSS and habitats, but to a lesser 

degree than under Alternative B. 

More decisions would be on a 

case-by-case basis than under 

Alternative B. Management 

specifically designed to prevent 

cumulative impacts to wildlife and 

SSS, including cumulative 

management decisions, adaptive 

management, and establishment 

of one connectivity corridor, 

would help offset landscape-level 

impacts to wildlife habitats. 

Trend: Varies between species. 

It is expected that

implementing Alternative C 

would result in an improved

trend for most wildlife and 

SSS. For species with habitat 

or populations that are

degrading, the degradation 

may continue but at a lesser

rate and could be stabilized. 

For forest and woodland 

species and species in areas of

medium to high mineral

development potential, there

could be a trend of increased 

degradation or lessened

improvement. For species with

habitat or populations that are 

improving, this alternative

would allow the improvement

to continue at a similar or 

greater rate. 

Management under Alternative D would 

include BMPs/SOPs and additional 

restrictions to provide localized protection to 

wildlife and SSS and habitats, but to a 

lesser degree than under Alternative B and 

for most resources to a lesser degree than 

under Alternative C. Many decisions would 

be made on a case-by-case basis, similar 

to Alternative A. Alternative D would include 

cumulative management decisions and 

adaptive management, but no connectivity 

corridors. In most cases, management 

would be somewhat more protective than 

under Alternative A. However, Alternative D 

would allow more unmanaged commercial 

woodland harvest and mineral 

development, which would have the 

potential to impact forest and woodlanddwelling wildlife, and wildlife occurring in 

areas of medium to high mineral potential to 

a greater degree than Alternative A. 

Trend: Varies between stable or 

declining. For forest and woodland 

species and species in areas of medium

to high mineral development potential,

trends could degrade as a result of the 

cumulative effects of future 

development, climate change, and

fragmentation of habitats. These species 

would experience a trend of increased 

degradation or lessened improvement. 

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3.4 Cultural Resources 

3.4.1 Summary 

This section describes the effect on cultural from proposed management actions of other resources and 

resources uses. Potential impacts derived from decisions regarding National Trail designations are 

described in Section 3.8. However, historic sites associated with the INHT are briefly mentioned in this 

section where appropriate, as there are certain defined management alternatives that have particular 

outcomes regarding these specific resources. 

The planning area contains evidence of prehistoric and historic land use. Much of what is known about 

the cultural resources has been identified through project-specific surveys and literature reviews that 

covered larger portions of the planning area. There are several categories of cultural resources identified, 

and some, such as Traditional Cultural Properties (TCPs), Sacred Sites, or cultural landscapes, may not 

always have physical manifestations or tightly defined geographic boundaries. There are places of 

traditional importance in the planning area, but no formally defined TCPs or cultural landscapes have 

been identified. Alternative B generally provides a higher level of protection for cultural resources and 

therefore potential effects would be of lesser magnitude and geographic extent than Alternatives C and D. 

Management actions that provide beneficial impacts to cultural resources are consistent with DOI’s 

mission to fulfil trust responsibilities and other legal requirements (DOI 2018). 

3.4.2 Methods of Analysis 

Addressing the impacts on cultural resources includes a review of the known resources in the planning 

area (Appendix M of the BSWI Draft RMP/EIS) that was then overlain with an understanding of the laws 

pertinent to determining and managing adverse effects on these resources. The information about known 

resources of the regulations used in evaluating impacts were then compared with each type of 

management action under each alternative to develop the analysis of actions that may affect known (and 

potentially discoverable) cultural resources. 

Potential Effects and Indicators 

Actions that affect cultural resources can be categorized as direct and indirect, with any surface-disturbing 

activities having the potential to impact these resources. Direct impacts could result from any proposed 

management action that would involve surface- or subsurface-disturbing activities that may result in 

damaging, destroying, or displacing artifacts, features, objects, structures, and buildings, or adversely 

affecting cultural landscapes, including TCPs. Direct impacts to cultural resources may also include 

construction of modern facilities that are out of character with historic settings or other management 

decisions that directly alter any of the aspects of integrity that are determined essential in conveying a 

particular resource’s significance. These disturbances can permanently destroy artifacts and features, 

historic architectural resources, or spatial relationships among multiple features and can ruin the 

interpretive value and significance of that resource. 

Indirect effects on cultural resources may involve any actions that change the character of a cultural 

resources site and alter the property’s use or the physical features that contribute to its significance. These 

actions can include introduction of visual, atmospheric, or audible elements that diminish the aspects of 

integrity deemed essential in conveying the site’s significance. For example, development of oil or 

alternative energy facilities in the planning area could result in placing modern features on an otherwise 

natural landscape previously devoid of human-made structures, but which could still diminish the visual 

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setting of a significant cultural resource. Relatedly, any action that results in the potential for increased 

land use and access would increase the chance of site looting or inadvertent destruction of cultural 

resources. Transfer of land from BLM management may also indirectly affect cultural resources by 

removing the federal or State regulatory processes that serve protect them. Actions that may result in 

landscape reclamation would likely restore natural settings and may have beneficial impacts especially if 

they more closely resemble the prior historic setting. However, actions taken to achieve reclamation may 

lead to direct or indirect effects, particularly during the inadvertent discovery of new resources. 

Conversely, beneficial actions are those that protect more land from development and further use thereby 

conserving the cultural resources in those areas. Beneficial impacts may also arise from actions specific to 

identifying and evaluating more cultural resource sites or land use designations that promote cultural 

resource values over other land uses. Table 3.4.2-1 summarizes the types of effects that can generally 

occur to cultural resources. 

Assumptions 

The cultural resource impacts analysis rests on the primary assumption that federal actions that require the 

identification, evaluation, and consideration of adverse effects and the appropriate mitigation of those 

effects on cultural resources will remain in effect. Nearly all implementation actions will undergo sitespecific analysis regarding the potential impacts on cultural resources before authorization. If adverse 

effects are identified, mitigation measures, including avoidance, would be assessed and implemented to 

minimize effects. 

Overall, actions associated with other resources that result in removal of lands from surface-disturbing 

activities would result in beneficial impacts (less chance of disturbance) to any resources that might be 

present. Conversely, actions that result in the potential for more surface-disturbing activities would result 

in increasing the probability of adverse effects on cultural resources. Impacts to cultural resources such as 

historic structures and Alaska Native sacred sites may result from management decisions from nonsurface-disturbing activities that create auditory and/or visual effects. Impacts to Alaska Native traditional 

sites may result from management decisions that restrict traditional access or use of such sites. 

The primary limiting factor of this analysis is that much of the planning area has not been surveyed for 

cultural resources, resulting in large tracts of land where quantifying resources and identifying impacts 

from site-specific actions is not possible. Therefore, this analysis does not attempt to quantify number of 

sites affected by specific actions, but rather focuses on resources and management actions under the 

assumption that there is potential for sites to exist across the landscape. The analysis also assumes that 

cultural resource sites have physical manifestations in the form of objects, artifacts, features, and 

geographic boundaries. Sacred sites and TCPs may exist across the landscape; analysis of these site types, 

effects on them, and appropriate mitigation, are best managed on a case-by-case basis. 

Standard Operating Procedures and Best Management Practices 

The impact analysis below considers the SOPs and BMPs that could be implemented by the BLM. A 

comprehensive list of SOPs/BMPs pertaining to cultural resources is provided in the BSWI RMP/EIS. 

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Table 3.4.2-1: Types of Effects to Cultural Resources 

Types of Effects Management Actions Indicators 

Surface-disturbing activity can result in direct and • Increasing land use that • Acres with no or limited land use 

indirect effects to cultural resources. These values development actions restrictions that server to limit surface 

activities include but are not limited to actions for involving surface-disturbing disturbance and protect cultural 

mineral development, timber harvesting, fire activities over conservation resources 

management and wildland fires, OHV use, and 

hazardous material cleanup. Effects can be 

demolition or destruction of cultural remains 

• Hazardous Material Cleanup 

Decisions 

• Acres open to OHV travel, timber use, 

mineral development, and so forth 

(direct) or creating access to areas with cultural • Areas subject to hazardous material 

resources that result in looting, vandalism, or cleanup 

inadvertent destruction of these resources 

(indirect). 

Removal of existing protections for cultural • Land transfer out of federal or • Acres of BLM-managed lands identified 

resources can result in adverse impacts to these State management removes for acquisition, retention, or disposal 

resources. For example, Section 106 may not 

apply to resources that are removed from federal 

ability to use existing 

legislation and policy to • Acres affected by land withdrawals 

ownership or archaeological investigations may no protect cultural resources • Acres subject to particular permitting 

longer require permitting and curation of artifacts. 

The lack of permitting or Section 106 review 

means that direct or indirect effects would not be 

considered prior to an action, and cultural 

resources could be destroyed or damaged as a 

result. 

• Decisions resulting in less 

restrictive permitting 

requirements prior to 

commencing activity may lead 

to impacts on cultural 

resources 

stipulations for land use 

Designating areas to promote cultural resource • Land designations (e.g., • More or fewer acres with land use 

protection values or further enhancing protections ACECs, WSRs, National restrictions that server to limit surface 

of known sites would advance preservation and Register Nominations) that disturbance and protect cultural 

public outreach about cultural resources. promote scientific use and 

natural resource conservation 

values over other land uses 

resources or result in further resource 

identification 

Indirect effects (e.g., visual, atmospheric, • Land designations that do not • Acres with particular VRM designations 

subsequent erosion, increased access) consider visual resource near known sites, particularly the INHT 

management classifications in NTMC 

areas of known sites 

(particularly historic buildings 

and trails) 

• Acres with no or limited (less restrictive) 

land use designations regarding 

development uses 

• Actions that introduce the 

potential for new visual 

elements in otherwise natural 

landscapes 

• Establishment of ROW, 

recreation facilities, and other 

actions that result in 

increased populations and 

use of an area 

3.4.3 Effects Analysis 

A variety of management actions related to resources and resource uses have the potential to adversely 

and directly or indirectly impact cultural resources. Any management action that preserves more land, 

and/or restricts land use (e.g., exclusion of areas such as connectivity corridors from mineral 

development) would have less potential for impacts than the action alternatives with fewer land use 

restrictions. 

Proposed management of the following resources, resource use areas, or programs would have no 

anticipated effects for all alternatives and are not analyzed further: 

• Air Quality and AQRVs 

• Soils 

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• Water Resources and Fisheries 

• Vegetation 

• Wildlife 

• NNIS 

• Paleontological Resources 

Any management action that has the potential to result in surface disturbance, increased land use and 

access, or the introduction of new visual, auditory, or atmospheric elements has the potential to impact 

and adversely affect cultural resources. This analysis targets specific management actions by alternative 

that could have these impacts. 

Cultural Resources: Effects from Wildland Fire Management Actions 

There are no alternative-specific management actions for this resource; therefore, impacts from 

Alternatives B, C, and D are described in combination below. 

Effects under Alternative A 

Under Alternative A, wildland fire management objectives include protection of significant of cultural 

sites. However, some wildland fire management activities would involve surface disturbance and could 

impact cultural resources. 

Effects Common to All Action Alternatives 

The following wildland fire management actions have the potential to impact and adversely affect cultural 

resources: 

• Wildfire and Fuels Management 

• Suppression Repair and ES&R 

Each of these management actions involves surface-disturbing activities and wildland fire itself can 

directly impact both surface and near-surface resources. Impacts can occur when historic structures burn 

down, heat-sensitive artifacts are destroyed, or tree-throws of burned trees disturb archaeological 

deposits. Suppression activities, such as mobilizing heavy equipment and cutting fire lines and fuel 

breaks, can directly and permanently impact these resources by crushing artifacts or disturbing site 

features with primitive roads. Additionally, use of fire retardants during fire suppression activities could 

also affect cultural resources, possibly affecting their radiocarbon dating. Indirect effects may include 

providing easier access to previously isolated areas and removing vegetation screening that would allow 

for improved visibility of cultural resources artifacts and features, which could result in increased looting 

or site vandalism. Wildland fire and burn areas may also result in indirect visual impacts on sites where 

setting and feeling are important in conveying significance. Both historic buildings/structures and 

prehistoric artifacts may be more visible post-burn. 

Management actions under each alternative would prioritize avoidance and minimization of impacts on 

known cultural resources, such as targeting fuel reduction actions in areas with known cultural resources 

or near historic buildings and structures associated with the INHT. Cultural resource evaluations would be 

required prior to such actions, and minimum impact suppression techniques would be used. Avoiding and 

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minimizing impacts on cultural resources is an identified supporting objective to reduce adverse effects of 

wildland fire management activities. These actions would help minimize the destruction of cultural 

resources by better preventing damage to vehicular travel and surface-disturbing activities that could 

result from fire suppression actions. 

Cultural Resources: Effects from Cultural Resources Management Actions 

There are no action alternative-specific management actions for this resource; therefore, impacts from 

Alternatives B, C, and D are described in combination below. 

Effects under Alternative A 

Alternative A generally reiterates that Section 106 compliance is required and does not include additional 

management actions to protect cultural resources. 

Effects Common to All Action Alternatives 

The management actions common to all action alternatives would be largely beneficial. Under all action 

alternatives, there would be more acres surveyed, sites identified, and resources protected compared to 

Alternative A. More sites would also be designated for scientific use (except INHT trail segments) and 

other sites would be considered for public use. High priority areas for survey and protection would be 

identified under each alternative, and all authorizations for land use would continue to comply with 

Section 106 of the National Historic Preservation Act of 1966 (NHPA). Potential impacts to significant 

resources from emergency and planned fire-related actions would be avoided or minimized to the 

maximum extent possible. 

Cultural Resources: Effects from Visual Resources Management Actions 

In addition to management actions common to all action alternatives, potential impacts from the 

following management topics were considered: 

• INHT (Main Trail) and Iditarod-Anvik Connecting Trail 

• Community of Flat 

• ACECs 

Effects under Alternative A 

Effects under Alternative A on cultural resources are primarily related to the designations of VRM classes 

in a 15-mile buffer zone around the community of Flat. Alternative A does not provide any management 

direction, which may result in indirect impacts to the community’s setting resulting from new 

construction that is not consistent with BMPs aimed at reducing and minimizing visual impacts from new 

projects in the planning area. The new construction may disrupt site lines or diminish the historic feeling 

by adding an incongruous and modern building into an otherwise historic setting. This action may result 

in increased opportunity for adverse effects on the setting and feeling of this historic community. 

Similarly, no current management direction for ACECs with respect to visual resource management is 

provided under Alternative A. This lack of VRM classifications in the ACES could also result in indirect 

visual impacts on cultural resources at those locations. 

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Effects Common to All Action Alternatives 

Effects common to all action alternatives may indirectly and positively affect cultural resources. For 

example, application of the visual management BMPs for all actions will serve to indirectly reduce 

impacts on cultural resources where setting is an important quality in conveying the resource’s 

significance. The utilization of curvilinear or topographic sloping, retaining existing formations and 

vegetation, blending new structures into the surrounding environment, avoiding fall line cuts and linear 

alignments, and required restoration/reclamation all serve to preserve or enhance the natural setting and 

limit indirect adverse visual impacts. Visual intrusions on historic and natural landscape viewsheds would 

be reduced by these actions. Indirect visual effects are more common to consider for historic builtenvironment resources, particularly when the setting, feeling, and location are essential for conveying 

significance. 

Effects under Alternative B 

Alternative B proposes a VRM Class II designation for the 15-mile buffer around Flat. This action would 

have fewer impacts from visual intrusions of new projects near the historic community compared to any 

other alternative because it has the largest geographic scope and highest VRM class designation compared 

to the other alternatives. This limits the potential for indirect visual impacts on cultural resources. 

More land is assigned to ACECs meeting relevance and importance criteria for cultural resources under 

Alternative B than under Alternative A, C, or D. Increased acreage of VRM Class II for the ACECs for 

cultural resources total 13 percent of the planning area under this alternative, which reduces the likelihood 

of adverse effects to the setting and feeling of cultural resources in these areas. This represents more 

acreage in a higher designation (VRM Class II) status that would minimize impacts on cultural resources 

in those areas by being more restrictive on the extent and type of new development. 

Effects under Alternative C 

Alternative C proposes a VRM Class III designation for the 15-mile buffer around Flat. This action would 

result in more impacts than Alternative B (lower VRM designation) but fewer than Alternative D. VRM 

Class III allows a moderate level of change to the characteristic landscape, which could potentially result 

in adverse impacts to the historic community at Flat, depending on the nature and type of the 

development. Alternative C would have the potential to result in more indirect effects to cultural 

resources from visual impacts than Alternative B, because it would increase the likelihood of introducing 

new visual elements into the landscape that adversely affect the setting and feeling of cultural resources in 

those areas. 

Effects under Alternative D 

Alternative D proposes a VRM Class IV designation for the 15-mile buffer around Flat. VRM Class IV 

allows a high level of change to the characteristic landscape, which would have the potential to result in 

adverse effects of higher magnitude and extent than Alternatives B and C. It allows for more visually 

intrusive elements to be introduced into the landscape that could impact the setting and feeling of cultural 

resources in those locations. Alternative D would have a greater potential to result in visual intrusions 

from new projects near the historic community at Flat, compared with Alternatives B and C. 

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No ACECs are proposed under Alternative D, which may result in the opportunity for more indirect 

impacts on cultural resources compared with Alternatives A and B. Collectively, Alternative D would 

designate approximately 49 percent of the planning area as VRM Class IV. This action would increase the 

likelihood of adverse effects and indirect visual impacts on cultural resources in the planning area by 

allowing for the potential of new visual elements into areas where setting and feeling are important 

qualities to cultural resource significance, compared with Alternative B and C. 

Cultural Resources: Effects from Lands with Wilderness Characteristics Management 

Actions 

In addition to management actions common to all action alternatives, potential impacts from the 

following management topics were considered: 

• Lands managed to protect wilderness characteristics as a priority over other resources values and 

multiple uses 

• Lands managed to emphasize other resource values and multiple uses while applying 

management restrictions to reduce impacts on wilderness characteristics 

• Lands managed to emphasize other resource values and multiple uses as a priority over protecting 

wilderness characteristics 

Effects under Alternative A 

Actions under Alternative A do not address wilderness characteristics within the planning area. The 

SWMFP aims to maintain natural conditions and opportunities for solitude but does not offer specific 

management of lands with wilderness characteristics. Direct and indirect impacts on cultural resources 

under Alternative A are more likely to occur as there are no defined wilderness areas that would limit 

development in those areas. BMPs would still apply to proposed actions in these areas even without 

specific wilderness status. 

Effects under Alternative B 

Alternative B would have the lowest potential for adverse impacts on cultural resources. Alternative B 

would manage roughly 2 percent of the planning area for lands with wilderness characteristics as a 

priority. These lands would be designated as VRM Class II, prohibit cross-country casual OHV use, and 

limit summer OHV subsistence use to existing trails, which would limit adverse effects on cultural 

resources in those areas by reducing the opportunity for direct effects on areas across a larger acreage. 

Indirect effects would also be limited by actions related to new facility design where native materials are 

used, which would reduce adverse visual impacts. Acquisition of non-BLM lands and retention of 

wilderness lands to consolidate holdings and improve management of natural values or primitive settings 

would also be beneficial for cultural resources, as would the prohibition of actions that may cause direct 

or indirect effects, such as limiting commercial or personal-use wood cutting and closing areas to salable 

mineral development. 

Alternative B would manage approximately 89 percent of the planning area to emphasize other resource 

values and multiple uses while applying management restrictions to reduce impacts on wilderness 

characteristics. Under this management direction, actions such as leasable and locatable withdrawals 

would remain permissible, but buffer zones would be established around the INHT at Kaltag Portage, 

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Farewell Burn, and Rohn. Buffer zones and other restrictions protect against surface-disturbing actions 

that could damage or destroy cultural resources. NSO provisions would be included at these locations, 

reducing the potential for direct and indirect effects on the INHT and related resources. The remaining 

9 percent of the planning area would not provide any specific management for cultural resources 

associated with lands with wilderness characteristics. 

Effects under Alternative C 

Alternative C would not manage any lands with wilderness characteristics as a priority. Alternative C 

would manage roughly 60 percent of the planning area to emphasize other resource values and multiple 

uses while applying management restrictions to reduce impacts on wilderness characteristics, compared to 

89 percent under Alternative B. Impacts to cultural resources would be the same as under Alternative B, 

although to a lesser geographic extent (fewer acres of lands with wilderness characteristics considered), 

thereby resulting in higher potential for impacts to cultural resources than Alternative B. 

Effects under Alternative D 

Alternative D would have the highest potential for impacts on cultural resources, as no lands would be 

managed for wilderness characteristics. There are no buffers or other activity exclusions that would serve 

to limit or eliminate the potential for direct or indirect impacts on the INHT and associated sites or other 

cultural resources in the planning area 

Cultural Resources: Effects from Forestry and Woodland Products Management Actions 

In addition to management actions common to all action alternatives, potential impacts from the 

following management topics were considered: 

• Permitted Commercial Woodland Harvesting Areas 

• Personal Use and Subsistence Woodland Harvest Areas 

• Woodland Harvest in the INHT NTMC 

• Woodland Harvest in ACECs 

• Forestry BMPs for Commercial Activities 

Effects under Alternative A 

Alternative A management actions related to providing for sustained yields of forest resources and 

continuation of present use levels could directly and indirectly effect cultural resources. Timber 

harvesting and associated activities, such as constructing timber roads, mobilizing forestry equipment, 

and cutting trees, disturbs the ground surface and can lead to the destruction and damage of cultural 

resources. Pre-suppression efforts can also damage sites. These adverse effects are mitigated in part by 

requiring a permit, which triggers Section 106 of the NHPA, but no special provisions for cultural 

resources are defined in Alternative A for permitted commercial woodland harvesting. 

A similar pattern applies to impacts resulting from personal use and subsistence woodland harvest areas, 

though the extent (fewer acres subject to harvest) and intensity (more dispersed harvests) are less than 

commercial timbering. Personal use still represents an action that can impact cultural resources, but again 

effects would be minimal in comparison to commercial activity 

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Effects Common to All Action Alternatives 

Forestry and woodland products management actions include surface-disturbing activities that have the 

potential to adversely affect cultural resources by directly destroying them, or by resulting in visual 

landscape changes that adversely alter the viewshed, which might be an important component of a historic 

site. The actions common to all alternatives serve to reduce and minimize effects on cultural resources by 

requiring case-by-case surveys of harvest activity locations for sensitive resources in the planning area. 

All commercial harvesting would require a permit, and the permitted activity would trigger Section 106 of 

the NHPA. 

Effects under Alternative B 

Commercial woodland harvest management under Alternative B minimizes impacts to cultural resources. 

Harvesting in the INHT NTMC is prohibited in this alternative, which results in less potential for direct or 

indirect effects on that resource and associated buildings, structures, and sites. Lands within the 

Unalakleet Wild River Corridor, 100-year floodplains within HVWs, ACECs, and lands managed for 

wilderness characteristics as a priority would also be excluded from harvesting. Areas within 15 miles of 

rivers and 25 miles of communities, as well as burned areas, remain open for commercial woodland 

harvest by permit, so direct and indirect effects remain possible under this alternative. These riverine 

locations and areas near communities are also typically the highest potential areas for the identification of 

cultural resources maintaining the likelihood of adverse effects from commercial operations on cultural 

resources near rivers and communities. This alternative offers the most land excluded from commercial 

harvest and avoids and minimizes impacts on cultural resources in those areas. 

Effects under Alternative C 

Direct and indirect effects of commercial woodland harvest under Alternative C are more likely than 

under Alternative B because more land would be available for harvest. In particular, commercial 

woodland harvest would be permitted in the INHT NTMC, raising the potential for direct and indirect 

effects (particularly visual impacts) on the INHT and associated historic sites under Alternative C. 

Effects under Alternative D 

Alternative D has the highest potential for direct and indirect effects from commercial woodland harvest 

in comparison to the other alternatives. Subsistence study/exchange withdrawals closed to commercial 

sales under Alternative A would be open for permittable commercial woodland harvest under 

Alternative D. Relatedly, all of the planning area would be open to personal use and subsistence 

woodland harvest without a permit. More acreage is available under Alternative D for timber harvest, 

which represents the largest geographic area where surface-disturbing activities could result in the 

destruction of cultural resource or lead to substantial landscape-level visual changes that may impact the 

visual setting and feeling of particular cultural sites. 

Cultural Resources: Effects from Grazing Management Actions 

In addition to management actions common to all action alternatives, potential impacts from the 

following management topics were considered: 

• Areas Open/Closed to Grazing 

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• Areas Closed to Grazing 

Effects under Alternative A 

Under Alternative A, areas within the planning area that overlap with the previous SWMFP planning area 

would remain open to grazing where feasible. There are no specific considerations for the impacts on 

cultural resources, though site-specific inventories would be performed to determine needs for surface 

protections. Cultural resources can be trampled by grazing (direct effect) or damaged by increased erosion 

due to vegetation removal (indirect effect). Construction of support structures and fencing may also 

directly damage or destroy cultural resources 

Effects under Alternative B 

Alternative B would close all BLM-managed land in the planning area to grazing, resulting in no impacts 

to cultural resources under this alternative as the types of activities that could affect resources are not 

permissible. 

Effects under Alternative C 

Alternative C would allow grazing where ecological conditions allow, which includes areas with at least 

20 percent lichen cover. While impacts to archaeological resources remain possible from trampling and 

erosion or the construction of support structures, the NEPA analysis would identify impacts on any 

identified resources in the grazing permit area. 

Alternative C closes areas with important fish and watershed values in the Nulato River watershed, the 

Unalakleet Wild River Corridor, and the INHT NTMC to grazing. These closures would eliminate the 

potential for impacts on cultural resources in those locations. 

Additionally, under Alternative C, management actions would ensure surface-disturbing rangeland 

improvements would be subject to applicable site surveys, OHV limitations for TMAs would apply to 

grazing unless otherwise authorized by the AO, Comprehensive Grazing Management Plans would be 

required, and rangeland improvements (e.g., line cabins, corrals) would not be allowed in areas managed 

as NSO for permanent structures associated with surface-disturbing activities. These actions would reduce 

the potential for impacts on cultural resources by limiting the surface-disturbing activities and subsequent 

increased erosion that could destroy resources. 

Effects under Alternative D 

Alternative D includes similar protections and management actions to reduce impacts as Alternative C. 

However, Alternative D specifically allows for grazing in the INHT NTMC only if it does not affect the 

historical and cultural setting of that specific resource. Other areas would still be open to grazing on a 

case-by-case basis and subject to NEPA analysis. 

No areas would be closed to grazing under Alternative D, which would result in higher potential for direct 

and indirect effects resulting from trampling and erosion when compared with the other alternatives. 

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Cultural Resources: Effects from Locatable and Salable Minerals Management Actions 

In addition to management actions common to all action alternatives, potential impacts from the 

following management topics were considered: 

• Locatable Minerals 

• Salable Minerals 

Effects under Alternative A 

Under Alternative A, roughly 294,325 acres of high and medium mineral potential would continue to be 

open to mineral development. Alternative A has 91,714 more acres open to locatable mineral 

development that has medium or high mineral potential than Alternative B. However, it has 271,163 

fewer acres of medium or high LMP that would be open than Alternative C and D. Therefore, Alternative 

A has the potential to have more impacts to cultural resources than Alternative B, but less than 

Alternatives C and D. Mining developments may result in direct site destruction through activities such as 

mineral excavation, construction of roads and building pads, or changing water courses and leading to 

increased erosion. 

Effects Common to All Action Alternatives 

Mineral material sales have the potential to directly and indirectly impact cultural resources through 

damage and destruction of those resources from development or indirect effects associated with 

alterations to the visual characteristics that may be important aspects of certain cultural resources. Many 

of the high or medium probability areas for locatable and saleable mineral deposits are proximate to 

historic mining sites. The historic use of the area for mining and the resultant cultural resources associated 

with those activities are more susceptible to damage and destruction from current mining activity because 

of this collocation. This is particularly the case with the INHT and some communities in the planning area 

(e.g., Flat, Iditarod, Ophir) that date to the historic mining era. Mining activities are often longer duration 

uses (multiple years vs. a few weeks) and introduce more people into the area, which further increases the 

opportunity for direct and indirect effects on cultural resources as a result of site vandalism on inadvertent 

destruction from new vehicle or pedestrian traffic. Placer mining also involves larger areas of surfacedisturbing activities and is typically along creeks and rivers. Size and location, when considered with the 

high-probability locations of historic and prehistoric sites, represents an increased potential for adverse 

effects on cultural resources at these locations. There is a high potential that mining actions involving 

surface disturbance, such as dredging, sluicing, and excavating can directly destroy or damage resources. 

Lands where mining is proposed would be subject to existing processes and permitting requirements to 

consider impacts on cultural resources. While representing a small portion of the overall BLM-managed 

lands in the planning area (4 percent), the potential for impacts on historic and prehistoric sites in high 

and medium potential areas remains. 

Effects under Alternative B 

Alternative B would have the fewest acreage open to locatable mineral development and salable mineral 

development. Alternative B would open 202,610 acres of medium or high mineral potential from mineral 

development, which is less than any other alternative. Therefore, Alternative B would have fewer impacts 

to cultural resources associated with mineral development activities than any other alternative. 

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Effects under Alternative C 

Alternative C has the same acreage open to locatable mineral development and salable mineral 

development as Alternative D; although approximately half of the area open to salable development is 

open on a case-by-case basis so the likelihood of development and associated impacts in those areas are 

less than areas strictly identified as open. This is because areas open on a case-by-case basis would be 

subject to site-specific decisions and analysis. However, Alternative C would be open to locatable mineral 

development in all areas of medium or high mineral potential on BLM-managed land in the planning area; 

the same as Alternative D but more than Alternatives A and B. Alternative C would have higher potential 

impacts to cultural resources from mineral activity than Alternatives A or B. 

Effects under Alternative D 

Alternative D would have more acreage open to locatable mineral development and salable mineral 

development than Alternative B but similar to Alternative C as described above. It would have the highest 

potential to impact cultural resources from mineral activity than any other alternative since salable 

mineral development, and associated impacts would have a higher likelihood to occur under 

Alternative D as described above. 

Cultural Resources: Effects from Leasable Minerals Management Actions 

In addition to management actions common to all action alternatives, potential impacts from the 

following management topic were considered: 

• Leasable Minerals 

• Areas Identified as Closed to Leasing and Open to NSO Leasing 

Effects under Alternative A 

Under Alternative A, existing actions would continue, with limited exclusions. There is a specific 

exclusion for the portion of the INHT in the Lime Village block to protect the integrity of the trail and 

associated historic sites. 

Effects Common to All Action Alternatives 

The development of leasable minerals holds the potential to directly and indirectly impact cultural 

resources through damage and destruction of those resources from development or indirect alterations to 

the visual characteristics that may be important aspects of a resource’s historic significance, such as the 

INHT. The entire planning area is open to leasable minerals actions. All actions would be subject to 

NEPA and NHPA analysis, which would identify and mitigate impacts to some level to cultural resources 

on a case-by-case basis. Overall, while the potential for leasable minerals remains low over the entire 

planning area, potential for impacts on cultural resources do remain wherever the actions may occur. 

Effects under Alternative B 

Under Alternative B, approximately 9,350,881 (69 percent) acres would be closed to mineral leasing, 

1,597,599 acres (12 percent) would be open to mineral leasing subject to NSO, and about 2,517,414 acres 

(19 percent) would be open to leasing subject to standard stipulations. Impacts to cultural resources would 

be avoided in areas closed to mineral leasing because surface disturbance would not occur here. For areas 

open subject to NSO, impacts would be minimized and avoided due to highly restrictive lease 

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stipulations. However, directional drilling could occur, if technologically and economically feasible, 

which could damage or destroy sub-surface resources. The INHT would be closed to mineral leasing. 

More acreage is closed to mineral leasing under Alternative B than any other alternative, resulting in a 

smaller geographic extent where impacts are possible. 

Effects under Alternative C 

Under Alternative C, roughly 46,953 acres (<1 percent) would be closed to mineral leasing, 

approximately 6,824,035 acres (51 percent) would be open to mineral leasing subject to NSO, and about 

6,594,906 acres (49 percent) would be open to leasing subject to standard stipulations. Alternative C 

would have a higher potential to affect cultural resources from leasable mineral activity than 

Alternative B because it would have fewer areas closed or subject to highly restrictive lease stipulations 

and would also include more areas where only standard terms and conditions would be required. More 

restrictive lease applications allow for a more detailed review for resources of concern in the lease areas. 

The INHT NTMC would be open subject to NSO. 

Effects under Alternative D 

Under Alternative D, roughly 46,953 acres (<1 percent) would be closed to mineral leasing, 241,155 acres 

(2 percent) would be open to mineral leasing subject to NSO, and 13,177,785 acres (98 percent) would be 

open to leasing subject to standard stipulations. Alternative D would have the highest potential to affect 

cultural resources from leasable mineral activity than Alternatives B and C because it would have fewer 

acres closed or subject to highly restriction lease stipulations and would include the most acres where 

only standard terms and conditions would be required. The INHT NTMC would be open subject to 

standard stipulations and could be damaged or destroyed by construction or infrastructure development 

and indirect effects related to the introduction of new visual elements that could diminish the historic 

setting and feeling. 

Cultural Resources: Effects from Lands and Realty Management Actions 

In addition to management actions common to all action alternatives, potential impacts from the 

following management topics were considered: 

• Retention or Revocation of Land Withdrawals 

• Land Tenure Decisions for the INHT 

• Occupancy Leases 

• ROW Exclusion and Avoidance Areas 

• Land Acquisition and Disposals 

Effects under Alternative A 

Generally, Alternative A provides no direction regarding lands and realty management actions. The 

SWMFP states that some historic sites within the INHT may be suitable for renovation and adaptive use, 

but that permanent occupancy would be discouraged, resulting in the potential for direct and adverse 

impacts to these sites, as new construction or reuse of historic sites may diminish the qualities of those 

sites that make them historically significant. Section 106 processes would apply in terms of 

considerations for renovations and adaptive uses. The SWMFP also includes objectives for land disposal 

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to provide for the continuing adjustment of land ownership to make each agency’s lands as manageable as 

possible. These management actions present the potential for adverse effects to cultural resources because 

they may result in the removal of land from BLM management. Without federal management, the laws 

and policies that guide the consideration of impacts on cultural sites would no longer apply, and resources 

could be looted, collected, vandalized, or destroyed. 

Effects Common to All Action Alternatives 

The authorization of new ROWs may result in new surface-disturbing activities that would directly and 

adversely impact cultural resources by construction and improvements within the ROW that could lead to 

destruction of cultural resources. There is also the potential for indirect effects. New access to areas made 

possible through new ROWs that were previously inaccessible may result in increased use of an area and 

subject sites there to intentional or unintentional impacts such as looting or trampling. 

Land transfers out of federal management would result in the removal of federal regulations protecting 

cultural resources. Transfers to the State of Alaska retain some level of protections under State law, and 

there are agreements between BLM and the State, such as the Programmatic Agreement Under the 

National Historic Preservation Act for Land Transfers to the State of Alaska, that govern the 

consideration of impacts resultant from land conveyance. If lands are transferred to private entities or 

Native corporations, municipalities, or individuals, no such protections or considerations would be 

retained, and the potential for impacts due to lack of oversight on cultural resources increases. 

All action alternatives proposed revoking land withdrawals that may subsequently lead to lower levels of 

protections on resources within the withdrawal areas being revoked, as these lands would be open to other 

uses (e.g., mineral leasing) with their effects previously noted. 

Effects under Alternative B 

Alternative B represents the lowest potential for adverse effects on cultural resources. The BLM would 

establish a 1,000-foot-wide buffer around the INHT in Farewell Burn and Kaltag Portage that would 

withdraw it from salable, locatable, and leasable minerals, avoiding direct or indirect visual impacts from 

mineral development on sites in those areas. The withdrawal would also include the Bear Creek Cabin 

and access trail and the entire Rohn parcel. All lands in the INHT NTMC would be retained by BLM. 

Alternative B also includes ROW exclusion areas and avoidance areas that would serve to protect cultural 

resources; the INHT NTMC would be excluded from new ROWs and wind energy development, and 

occupancy leases would be more restrictive, such as not allowing cabins within 300 feet of riparian areas. 

This would lower the number of people in particular areas and decrease the opportunity for indirect 

effects related to vandalism or looting. The BLM would pursue opportunities to acquire land in the INHT 

NTMC. Areas available for land exchange would be limited and exclude lands managed for wilderness 

characteristics as a priority, ACECs, and connectivity corridors. Collectively, these actions would reduce 

the potential for direct and indirect effects on cultural resources by maximizing acreage in the planning 

area with restricted land uses and lowering the acreage available for development. 

Effects under Alternative C 

Alternative C offers similar management decisions as Alternative B. For example, the BLM would 

continue to retain current lands and pursue land acquisitions within the INHT NTMC. A FLPMA 

withdrawal would be established on a 1,000-foot-wide buffer around the INHT in Farewell Burn and 

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Kaltag Portage; however, the determination on whether the FLPMA withdrawal would include salable, 

leasable, and/or locatable minerals would be determined when the withdrawal is proposed. The 

withdrawal would also include the Bear Creek Cabin and access trail and the entire Rohn parcel, as with 

Alternative B. There are no ROW exclusion areas, and the INHT NTMC would be managed as a ROW 

avoidance area, a less protected status than an exclusion area. Only slightly more acreage would be 

available for exchange in Alternative C (roughly 356,942 acres; 3 percent) compared with Alternative B 

(roughly 342,360 acres; 3 percent). This alternative represents a higher likelihood for direct and indirect 

adverse impacts on cultural resources than Alternative B, but less likelihood than Alternatives A and D 

based on the acreage subject to the various land use designations that would limit surface-disturbing 

effects. 

Effects under Alternative D 

Alternative D includes management decisions with the highest likelihood of direct and indirect adverse 

effects on cultural resources. There would be no ROW exclusion areas, and the avoidance areas are 

substantially less than in the other action alternatives. ROWs would be authorized in the INHT NTMC if 

consistent with the historic values for which the corridor is managed. Permits and leases are less 

restrictive, no lands would be pursued for acquisition, and more lands would be available for disposal or 

exchange than those available for exchange under Alternative B and C. In effect, more acreage is 

available under Alternative D for uses that involve surface-disturbing activities and there are less 

resource-specific considerations for the INHT and associated historic sites. 

Cultural Resources: Effects from Recreation and Visitor Services Management Actions 

Effects under Alternative A 

Under Alternative A, impacts to cultural resources could result from intentional or unintentional 

trampling, looting, or vandalism of sites by visitors. Due to the lack of recreation facilities in the planning 

area, the potential for impacts to cultural resources from recreation management remains low under this 

alternative. 

Effects Common to All Action Alternatives 

Many of the effects of recreation and visitor services apply directly to the use of the INHT NTMC, and 

those effects are covered in more detail in Section 3.8, “National Trails.” Effects common to all action 

alternatives have the potential to directly or indirectly cause adverse impacts on cultural resources. Much 

of the recreation activity in the planning area, including the activity conduction under SRPs, involves 

overland travel via plane, OHV, or snowmobile. The impacts of recreation activity vary based on the 

method of transportation used. Direct effects can occur from the construction of new facilities (e.g., 

airstrips), signage, and trail improvements to support recreation and public access. Recreation facilities 

are also often located in areas of known prehistoric and historic sites, increasing the potential for adverse 

effects on these resources at or near developed recreation sites. Any increase in access may result in 

damage to cultural sites by increasing accessibility and use in given areas, which can lead to intentional, 

or unintentional trampling, looting, or vandalism of sites by visitors. Litter, multiple camp locations, 

braided trails, and the presence of more people all represent activities that can indirectly affect the setting, 

feeling, and other aspects important to the significance of historic and prehistoric sites in an area. More 

people also increases the possibility for inadvertent fire damage resulting from uncontrolled fires started 

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by campfires. Effects of these actions would be minimized in part by prohibiting users from constructing 

permanent and semi-permanent tent platforms, camp sites, and hunting blinds unless permit approved. 

Generally, management decisions at the recreation unit level address items such as the permitting required 

for users, length of stay, number of allowable persons, and managing multi-use conflict. Decisions about 

density and intensity of allowable use have the potential to increase or decrease potential effects to 

cultural resources in particular areas, as do decisions about transportation allowed for particular recreation 

activities. 

Effects under Alternative B 

Recreation along the INHT would be managed within the INHT SRMA to achieve desired outcomes, 

benefits, and setting, thereby reducing the potential for direct and indirect effects. Managing Community 

Focus Zones (CFZs) to promote subsistence use will limit use within these areas, thereby limiting 

potential for destruction, looting, or inadvertent damage to cultural resources in those areas. There would 

be a 3-day stay limit on public shelter cabins for casual use, and only use of dead or downed trees would 

be allowed for wood stoves in the cabin, which would preserve the integrity of the setting. 

Effects under Alternative C 

Impacts to cultural resources from recreation management decisions would be the same as Alternative B. 

Effects under Alternative D 

Under Alternative D, there would be no CFZs and no restrictions on woodcutting for use in stoves. 

Therefore, Alternative D would provide less protection to cultural resources, including the INHT, than 

Alternative B and C. 

Cultural Resources: Effects from Travel and Transportation Management Actions 

In addition to management actions common to all action alternatives, potential impacts from the 

following management topics were considered: 

• All Lands Not Managed as TMAs or Conservation System Units 

• Unalakleet Wild River Corridor Travel Management Decisions 

• INHT NTMC TMA 

• Rohn Site Travel Decisions 

• Lands Managed for Wilderness Characteristics TMA 

• Travel Management in ACECs 

Effects under Alternative A 

Under Alternative A, the entire planning area is managed as “undesignated” with the exception of the 

Unalakleet Wild River Corridor which does not allow casual OHV use. Therefore, impacts to cultural 

resources from erosion and surface disturbance from OHV use would have a greater potential to impact 

cultural resources in the vast majority of the planning area. 

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Effects Common to All Action Alternatives 

Management decisions common to all alternatives for motorized travel (e.g., OHVs, snowmobiles) help 

reduce the potential for direct and indirect impacts on cultural resources and in some cases have beneficial 

outcomes. For example, areas known to have high OHV use would be prioritized for natural and cultural 

resources surveys to assess levels of destruction or erosion on these resources. This action would lead to 

increases in acres surveyed, more acres subject to probability analysis of sites, increased number of sites 

identified and evaluated, and improved understanding of resource types and locations in the planning 

area. Similarly, the majority of BLM-managed lands in the planning area would be designated as 

“limited” for motorized travel, which reduces the potential for adverse effects related to erosion along 

trails. Much of the planning area is seldom accessed, so impacts on cultural sites would be generally 

limited to the areas identified for regular use. While much access occurs in winter, which naturally 

reduces impacts to surface and near-surface sites, fall and spring use of OHVs is also common, which has 

a much higher potential to affect cultural resources. Maintaining areas as “limited” would keep OHVs on 

existing routes and minimize the potential to damage cultural resources. Importantly, most of the planning 

area has not been surveyed for cultural resources. Existing routes in limited areas and in areas where 

cross-country travel is allowed may contain cultural resources that are already being impacted by these 

uses. 

Pedestrian use would not be prohibited throughout the entire planning area. This action may result in 

effects on cultural resources, such as inadvertent trampling, but given the limited acreage that would be 

traveled by foot within the entirety of the planning area, these impacts would be minor. 

Effects under Alternative B 

Erosion and surface disturbance from cross-country summer travel could impact cultural resources. Under 

Alternative B, casual OHV use and subsistence OHV use would be prohibited for roughly 565,955 acres 

(4 percent) and 241,512 acres (<2 percent), respectively. OHV access would be limited to existing trails 

on approximately 12,899,939 acres (96 percent) for casual use and about 324,443 acres (3 percent) for 

subsistence use, which would protect cultural resources by limiting vehicular travel to previously 

disturbed areas with existing trails. Additionally, the INHT NTMC would be managed as a TMA, which 

would prohibit both casual and subsistence cross-country OHV use, thereby better protecting cultural 

resources from increased traffic and volumes of people that could result in destruction of sites and 

features. More acreage is protected from surface-disturbing activity under Alternative B than the other 

alternatives. 

Effects under Alternative C 

Under Alternative C, OHV use and subsistence casual OHV use would be prohibited for approximately 

225,925 acres (2 percent). OHV access would be limited to existing trails on roughly 13,239,969 acres 

(98 percent) for casual use and no acres for subsistence use. Additionally, the INHT NTMC would be 

managed as a TMA and have the same management as Alternative B. Overall, Alternative C would have 

fewer acres with restrictions to OHV cross-country travel than Alternative B and more potential for 

impacts to cultural resources. 

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Effects under Alternative D 

Under Alternative D, casual cross-country OHV use would be prohibited for approximately 225,925 acres 

(2 percent); subsistence use would not be prohibited. OHV access would be limited to existing trails on 

roughly 46,953 acres for casual use and about 225,925 acres (2 percent) for subsistence use. Additionally, 

the INHT NTMC would be managed as a TMA, which would prohibit casual OHV use and only allow 

subsistence OHV use on existing trails. Overall, Alternative D would have fewer acres with restrictions to 

OHV cross-country travel than Alternatives B and C and more potential for impacts to cultural resources. 

Cultural Resources: Effects from Areas of Critical Environmental Concern Management 

Actions 

Designation of ACECs provides management actions that protect cultural R&Is and reduces potential 

impacts on cultural resources. Uses within ACECs are purposefully limited specifically to protect and 

prevent irreparable damage to important historic, cultural, or scenic values. 

Potential impacts from the following management topics were considered: 

• ACEC Actions by Alternative – Cultural Resource Management Decisions 

Effects under Alternative A 

Alternative A would maintain the current ACEC designations on BLM lands; there would be no changes 

to current ACECs or the addition of new ACECs. Alternative A generally prescribes a cultural resource 

survey prior to BLM-permitted activities in ACECs, which helps minimize impacts on identified 

resources. The Drainages of the Unalakleet ACEC is the only existing ACEC with defined relevant and 

important cultural values. This roughly 403,378-acre area would benefit from cultural resource surveys to 

protect relevant and important cultural values. 

Effects under Alternative B 

Alternative B has the most total acreage designated as ACECs in the planning area (29 percent) compared 

with Alternative A (14 percent) and Alternative C and D (both 0 percent). Alternative B would best 

protect cultural resources within those ACECs. Alternative B includes four potential ACECs that meet the 

relevance and importance criteria for cultural resources and have specific cultural resource management 

decisions described for them. These include the Anvik Traditional Trapping Area ACEC, the Sheefish 

ACEC, the Tagagawik River ACEC, and the Unalakleet River Watershed ACEC. Alternative B would 

avoid and minimize impacts to more acreage in ACECs than the other alternatives, and the new 

designations have cultural resource-specific values that would be promoted with these designations. 

ACECs would be managed as NSO for any externally proposed structures. This would lead to more acres 

where impacts from surface-disturbing activity would be avoided that might destroy or damage cultural 

resources, or an increase in the number of sites identified through survey work in the ACECs. Newly 

identified sites could then be better managed and protected and would otherwise likely not have been 

identified without the ACEC designation. 

Effects under Alternative C 

Alternative C does not have any acreage managed as ACECs and thus along with Alternative D has the 

highest likelihood of direct and indirect effects on cultural resources as it has the fewest acres designated 

for this use. 

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Effects under Alternative D 

Alternative D does not have any acreage managed as ACECs and would have the same impacts as 

Alternative C. 

Cultural Resources: Effects from National Trails Management Actions 

Each action alternative (B, C, and D) would establish the INHT NTMC within the planning area; 

however, the acres for those areas vary by alternative. The status of the INHT NTMC and its size affect 

the impacts on cultural resources. More acreage in the INHT NTMC would minimize and avoid impacts 

on cultural resources in more areas, and fewer acres would increase the potential for adverse impacts to 

sites not in the NTMC. 

Effects under Alternative A 

The INHT NTMC would not be designated under Alternative A. The INHT would continue to be 

managed to maintain its integrity and associated historic and cultural sites in compliance with the 

National Trails System Act and the INHT Comprehensive Management Plan (BLM 1981b). 

Effects Common to All Action Alternatives 

Management actions for the national trails prescribe the creation of the INHT NTMC, which includes 

three geographic areas at Farewell Burn, Kaltag Portage, and Rohn. The creation of the INHT NTMC 

provides beneficial impacts on cultural resources. Use activities that might affect the INHT and associated 

historic features and/or structures are restricted in this scenario. For example, coal leases would not be 

issued on federal lands within the National System of Trails, and new audible and atmospheric effects 

would not exceed current levels in the NTMC. Actions that may result in new audible and atmospheric 

effects would be limited to those that cause short-term, minimal impacts to the INHT. Reservations for 

the INHT would be made if land conveyance to another entity occurs, and other activities such as winter 

subsistence OHV use would be prohibited. Standing structures, such as the public shelters and historic 

roadhouses along the INHT NTMC, would be prioritized for fire protection. Collectively, these 

management actions reduce the likelihood of adverse impacts on the INHT and associated cultural 

resources. Each alternative provides for the same acreage for the Kaltag Portage portion of the NTMC 

and offers the same level of protection for that culturally significant route and any other cultural resources 

in that geography. 

Effects under Alternative B 

Under Alternative B, there are a total of approximately 288,466 acres (2 percent) established as INHT 

NTMC within the planning area. This includes the Farwell Burn (46,951 acres), the Kaltag Portage 

(241,512 acres), and the Rohn (363 acres) sections of the trail. These sections account for more acreage 

than would be designated under Alternatives C or D. Alternative B represents the least likely to have 

adverse effects on cultural resources as it protects the most acreage within the NTMC and limits uses that 

could have an adverse impact on the trail or associated cultural resources. 

Effects under Alternative C 

Alternative C designates slightly less acres (273,242; 2 percent) than Alternative B, and the difference is 

at the Farewell Burn area, which is 31,367 acres under Alternative C. This alternative is more likely to 

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have adverse impacts on cultural resources as slightly less land is designated within the NTMC protected 

area. Those impacts would be limited to the Farewell Burn area. 

Effects under Alternative D 

Alternative D is the same as C. 

Cultural Resources: Effects from Wild and Scenic Rivers Management Actions 

In addition to management actions common to all action alternatives, potential impacts from the 

following management topics were considered: 

• Improvements within the Unalakleet Wild River Corridor 

Effects under Alternative A 

Under Alternative A, the Unalakleet Wild River Corridor would remain and 18 river segments (roughly 

222,584 acres) have been identified as eligible for WSR designation. The Unalakleet National Wild River 

Management Plan (BLM 1983) includes an objective to ensure preservation of historic and archeological 

values. Additionally, Action 11.1 of the plan states that inventories will be conducted prior to surfacedisturbing projects and will be oriented toward finding sites representative of early prehistoric occupation 

and sites representing the theme of transportation and trade. According to BLM Manual 6400, projects on 

BLM-managed lands within the river corridor or on lands that are adjacent to or border eligible rivers 

must consider guidelines to protect ORVs for activities such as locatable, salable, and leasable mineral 

development; transportation and motorized travel; ROW authorization; recreation; and livestock grazing, 

which could protect cultural resources from associated surface-disturbing activities or increased erosion 

resulting from these activities. 

Effects Common to All Action Alternatives 

Similar to the designations of ACECs in the planning area, increased acreages designated as WSR 

throughout the planning area will minimize the likelihood of direct or indirect effects on cultural 

resources by designating more acreage under a protected status. There is less potential for management 

actions that involve surface-disturbing activities that could destroy cultural resources. The major variance 

between the alternatives is how many rivers are designated as WSR and what other permitting and use 

restrictions are managed within designated WSR areas. Management actions and associated impacts 

related to travel management, visual resource management and improvements, and UAS uses would be 

minimized within WSR corridors. 

Effects under Alternative B 

Under Alternative B, the Unalakleet Wild River Corridor would remain in place. Additionally, roughly 

332,176 acres (2 percent) have been proposed as suitable for WSR designation. Alternative B would have 

the lowest potential for adverse impacts on cultural resources because it protects the most acreage under a 

WSR designation that would in turn protect cultural resources in the corridors. 

Effects under Alternatives C and D 

Alternatives C and D would have higher potential for adverse impacts on cultural resources compared 

with Alternatives A and B, because only the Unalakleet Wild River Corridor would be a WSR corridor. 

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Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

There would be no noticeable difference between Alternatives C and D in terms of acreage designated; 

both alternatives would protect fewer acres than Alternative B for this resource. As a result, more surfacedisturbing activities that could lead to site destruction are permissible under these two alternatives. 

Cultural Resources: Effects from Hazardous Materials and Health and Human Safety 

Management Actions 

There are no alternative-specific management actions for this resource; therefore, impacts from 

Alternatives B, C, and D are described in combination below. 

Effects under Alternative A 

Alternative A does not include any specific management actions that would impact cultural resources. 

Effects Common to All Action Alternatives 

Management actions for all alternatives include the BLM prioritizing cleanup of hazardous materials sites 

with eminent or existing discharge where that activity would affect cultural resources. This action has the 

beneficial effect of identifying more cultural resources in the planning area, completing additional survey 

for cultural resources, and defining methods of minimizing impacts on those resources. In some cases, 

hazardous materials may be present at historic sites related to mining or military activity. Clean up actions 

may adversely impact these sites. 

Cultural Resources: Effects from Support for BSWI Communities Management Actions 

In addition to management actions common to all action alternatives, potential impacts from the 

following management topics were considered: 

• Cultural Landscape Reports 

• Providing Assistance for Cultural Tourism 

Effects under Alternative A 

Alternative A includes the objective to protect and preserve cultural sites from damage or destruction 

based on the SWMFP under the management action of Cultural Landscape Reports. This action would 

have beneficial effects on cultural resources. This action relies on application of current federal law which 

aims to avoid or minimize effects on cultural resources. 

There is no management action for providing assistance with cultural tourism. 

Effects Common to All Action Alternatives 

Management actions related to the relocation of communities, use of timber for biomass projects, 

development of local energy sources, construction of emergency shelter cabins, and other actions that 

may involve surface-disturbing activities all have the potential to directly and indirectly adversely affect 

cultural resources. Generally, effects from BLM support for communities are minor. Specific impacts of 

OHV use, forestry management, and other topics addressed in actions common to all alternatives are 

addressed specifically in the resource-specific sections of this report. 

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Effects under Alternative B 

Alternative B specifically provides for the development of Cultural Landscape Reports in collaboration 

with local communities. This alternative would target two to three high priority villages for cultural 

landscape reports. This action represents beneficial impacts on cultural resources and would result in 

increased acreage surveyed for sites, increased number of sites identified, and a broader understanding of 

site types and frequencies within the communities identified for these reports. 

Alternative B provides opportunities for the BLM to support communities with cultural tourism based on 

BLM’s cooperation and collaboration with the American Indian Alaska Native Tourism Association 

(AIANTA). This action would have beneficial effects on the public outreach and understanding of Native 

heritage throughout the planning area. 

Effects under Alternative C 

Cultural Landscape Reports would be developed for four to six priority villages in the planning area under 

Alternative C. This action provides more beneficial impacts for cultural resources than Alternative A and 

Alternative B. Cultural tourism assistance is the same as under Alternative B. 

Effects under Alternative D 

Alternative D has the most potential for positive impacts on cultural resources, as the entire planning area 

would be reviewed for Cultural Landscapes. This action would add knowledge of sites beyond just select 

communities and have a planning area-wide beneficial impact on the knowledge of cultural resources and 

landscapes. 

More cultural tourism assistance is provided under Alternative D than Alternative A, as BLM would 

receive requests from BSWI communities, seek funding, and provide technical assistance to increase 

cultural tourism capacity. This alternative would provide more beneficial impacts on cultural resources 

when compared with Alternatives B and C. 

Cultural Resources: Effects from Climate Change 

Effects of climate change span all alternatives, including Alternative A. Cultural resources are subject to 

direct and indirect effects from climate change. The warming trends and impacts on permafrost thaw and 

increases in wildland fires can directly damage or destroy cultural resources, including historic structures 

and prehistoric sites. The same warming trends and increases in wildland fires can deepen the active solid 

layer. Deepening of the active layer absent erosional forces promotes decomposition and could adversely 

affect organic cultural materials. Where soils could experience higher rates of erosion, cultural resources 

could be indirectly impacted as adjacent lands are degraded and subject to more erosional forces and the 

rate of future erosion is expected to be faster and potentially more damaging. This is particularly true 

along coastal and river areas where melting is causing banks to slump into the water. Increased frequency 

of strong storms also increases shoreline erosion that could directly and adversely affect cultural 

resources. 

Effects under Alternative A 

Alternative A does not include any management actions that could counteract impacts from climate 

change on cultural resources. 

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Effects Common to all Action Alternatives 

Management actions under all action alternatives would include monitoring to prevent impacts to soils 

impaired by climate change and avoid permafrost areas, which would counteract some impacts to cultural 

resources in areas with impaired soils and erosion. 

Cultural Resources: Cumulative Effects 

Table 3.4.3-1 summarizes the results of the cumulative effects analysis for cultural resources for all 

alternatives. 

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Table 3.4.3-1: Cumulative Effects Analysis for Cultural Resources 

Trends and Forecasts of Cultural 

Resources in Consideration of 

Past and Present Actions 

Trends and Forecasts of 

Cultural Resources in 

Consideration of Past, Present, 

and Reasonably Foreseeable 

Future Actions 

(Alternative A) 

Trends and Forecasts of Cultural Resources 

in Consideration of Past, Present, and 

Reasonably Foreseeable Future Actions 

(Alternative B) 

Trends and Forecasts 

of Cultural Resources 

in Consideration of 

Past, Present, and 

Reasonably

Foreseeable Future 

Actions 

(Alternative C) 

Trends and Forecasts 

of Cultural Resources 

in Consideration of 

Past, Present, and 

Reasonably

Foreseeable Future 

Actions 

(Alternative D) 

Past and present actions in the Reasonably foreseeable future Cumulative impacts to cultural resources can Cumulative impacts Cumulative impacts 

planning are primarily related to actions that may affect cultural occur through incremental degradation of the and resource trend on and resource trend on 

historic mining throughout the resources are primarily related to overall resource base throughout the planning a planning area scale a planning area scale 

planning area in the Iditarod Mining the ongoing development of the area from any of the management actions and would be similar to would be the same as 

District and other areas. Increased Donlin Gold Project and the decisions that have the potential to impact Alternative B although Alternative B. Although 

population based on mining also potential for additional exploration cultural resources as described in this section. resource condition resource condition 

resulted in the accelerated use of and development of locatable While loss of one or two sites may have an would degrade at a would degrade at a 

natural resources to support the minerals in the planning area. immeasurably low impact on the entire resource slightly greater rate due slightly greater rate 

growing communities, particularly Many of the locatable minerals base, there would likely be ongoing activity to a higher level of than Alternatives B or 

forest resources used for are co-located with mining across the resource area that would cumulatively potential development. C because of a higher 

construction and heating. The 

increase in exploration and 

development of mines (and other 

resources) led to further 

infrastructure development, such as 

roads connecting population centers 

to mining areas and local roads and 

trails serving hunting and resource 

allocation for local communities. 

These actions created many of the 

cultural resources that are now being 

analyzed for impacts, such as historic 

mine remains and historic trails, like 

the INHT. These activities also likely 

resulted in adverse impacts on 

cultural resources, but the degree of 

these effects is not quantifiable. 

districts that contain sites, 

artifacts, objects, and features 

related to historic mining in the 

region. This type of development 

has the potential for direct and 

indirect impacts on cultural 

resources due to the inherent 

surface-disturbing nature of these 

activities. 

Infrastructure developments to 

communities also present a high 

potential for impacts on cultural 

resources. Any development of 

roads and other transportation 

routes would result in additional 

surface disturbance. This would 

include direct impacts on cultural 

and adversely affect the resource base. Cultural 

resources are non-renewable; once damaged, 

the information value of the sites could be 

severely or totally destroyed. Any resource or 

resource use that has been evaluated as 

causing direct or indirect impacts on cultural 

resources will contribute to the cumulative 

degradation of these resources over time. 

Impacts that may seem minor after only one 

individual occurrence can cumulatively lead to 

larger direct effects over time. For example, one 

individual visiting a historic cabin or walking 

through a prehistoric surface lithic scatter may 

appear to have no effect on that resource. 

However, repeated visits over time will likely 

result in destruction and loss of that resource. 

Site looting is another example of cumulative 

Trend: Resource 

condition would 

degrade but at a 

lesser rate than 

Alternative A and 

greater than 

Alternative B. 

level of potential 

development. 

Trend: Resource 

condition would 

degrade but at a 

lesser rate than 

Alternative A and 

greater rate than 

Alternatives B and C. 

Recreation and subsistence activities resources, and indirect impacts, site-specific impacts. One visitor may only take 

are the most prevalent current land such as visual impacts of a new one artifact, but over time, if each visitor takes 

use in the planning area. Use of the road corridor in an area that away a part of the site, long-term and irreversible 

INHT has increased over time and previously had no visible impacts may occur to that site. Resource uses, 

has contributed both to an increased development. The proposed such as recreation planning, that may result in 

knowledge of the trails historic ROW corridors are long and pass increased use of an area may inadvertently 

significance and to more direct and through areas known to contain cause long term effects on cultural resources. 

adverse effects on the trail and 

associated historic resources, such 

as shelter cabins and roadhouses. 

cultural resources. 

Trend: Degrade at a greater 

rate 

Trend: Resource condition would degrade

but at a lesser rate than Alternative A 

Trend: Degrading 

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3.5 Locatable and Salable Minerals 

3.5.1 Summary 

This section describes the potential impacts on the locatable and salable minerals resources in the 

planning area from six BLM management actions, climate change, and cumulative effects under 

Alternatives A through D. 

Under all of the action alternatives, some BLM-managed land in the planning area could be withdrawn 

from locatable mineral entry, subject to valid existing rights, or possibly closed to salable minerals 

development, and some existing mineral withdrawals would be revoked. Although current data from the 

2017 Mineral Potential Report indicates that locatable and salable minerals development is low in the 

planning area, efforts to increase the mineral potential knowledge of the area would align with the U.S. 

Department of Interior's goal of ensuring access to mineral resource (DOI 2018).Climate change could 

lead to permafrost thaw, glacial retreat, and altered water availability in the planning area. Permafrost 

thaw could adversely impact mining activities and overland travel by creating wetter surface areas and 

eroding water shorelines. Glacial retreat could expose additional areas with locatable and salable 

minerals. Changes to water availability could impact hazardous material controls at mine sites, dust 

abatement activities, and other mining activities. Impacts would last beyond the duration of the planning 

period. 

Under all alternatives, the management and use of locatable and salable minerals would be subject to and 

protected by the laws, regulations, and policies described in Appendix E of the BSWI Draft RMP/EIS. All 

action alternatives would be subject to requirements in Guidance on Reclamation Bonding for Plans and 

Notices on BLM Managed Lands in Alaska (AK IM-2015-001) (BLM 2015b). 

The demand for locatable and salable resources on BLM-managed land in the planning area are predicted 

to be low in the reasonably foreseeable future based on the relatively low LMP and the lack of demand 

and low economic feasibility of extracting salable materials. Therefore, the cumulative impact of the 

management decisions related to locatable and salable mineral resources combined with past, present, and 

reasonably foreseeable future actions would be small although some mineral resource exploration could 

be expected if and where long-standing withdrawals from mineral entry would be lifted. Salable mineral 

development on BLM-managed lands would be most likely to occur in association with projects that 

require these minerals for supporting infrastructure, such as access road development. 

3.5.2 Methods of Analysis 

This section describes the potential impacts on locatable and salable minerals in the planning area from 

the management actions for other resource and resource use programs. Where possible, the analysis uses 

quantitative data to describe impacts on locatable and salable minerals from management actions 

associated with other resources and resource use programs. Qualitative information is also used to support 

quantitatively based analysis or when numerical data do not exist. 

Impacts on locatable and salable minerals development would result from the withdrawal or closure of an 

area to mining development because the mineral resources in that area would not be able to be accessed 

and extracted. The withdrawal or closure represents an impact on the potential discovery, development, 

and use of these resources by decreasing the availability of mineral resources. 

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3.5.3 Nature and Types of Effects 

The alternatives would affect locatable mineral exploration and development by varying the amount of 

federal land under each alternative that would be withdrawn from mineral entry. Federal land that is 

withdrawn from mineral entry is not open to the location of mining claims and would prohibit future 

mineral exploration and development. Closing, segregating, or withdrawing lands to claim and 

subsequent development would reduce domestic production of our mineral needs and higher dependence 

on foreign sources of those minerals, reduced economic development on the regional and local levels, and 

loss of tax revenues to all levels of government that would have resulted from the development of the 

encompassed minerals. This effect is proportional to the degree that the lands withdrawn are practically 

valuable for locatable mineral development. 

Withdrawal or closing an area to mining development removes the possibility of mineral resources in that 

area from being accessed and extracted other than through valid existing rights. This represents an impact 

on the potential discovery, development, and use of those resources by decreasing the availability of 

mineral resources on federal mineral estate. 

The alternatives would affect salable mineral disposals by various limits on the amount of land available 

for disposal sites. The value of most salable minerals is closely tied to the proximity of the source to the 

final place of use which is the major consideration in the evaluation of salable mineral resources in this 

planning area. Closing areas to mineral material disposal would directly impact mineral materials by 

removing the possibility of mineral resources in that area from being accessed and extracted. 

The types of effects to locatable and salable minerals that could result from management actions, and the 

indicators used to evaluate them are shown in Table 3.5.3-1. 

Table 3.5.3-1: Summary of Effects to Locatable and Salable Minerals 

Types of Effects Management Actions Indicators 

Reduction of the land that is available for 

mineral resource activities would result in a 

reduction of the quantity of minerals 

available for extraction. 

• Locatable Mining and Minerals Decisions 

within HVWs, the INHT NTMC, and the 

Unalakleet Wild River Corridor 

• Locatable and salable minerals 

development decisions in wildlife habitat 

areas and connectivity corridors 

• Acres of land or river miles withdrawn 

from the total number of acres or river 

miles of locatable minerals identified in 

the planning area, when available. 

• Acres of land or river miles of salable 

minerals in the planning area closed to 

development, when available. 

Reduction in the number of qualified 

applicants to use the Alaska Statewide 

Bond Pool by changing the requirements 

for mining operations to qualify. 

• Requirements for reclamation bonding 

for on BLM Managed Lands 

• Number of operations able to maintain 

compliance without the assistance of the 

Alaska Statewide Bond Pool for 

reclamation. 

Assumptions 

The following assumptions were used in the assessment of the effects on locatable and salable minerals. 

• Existing mining claims with valid existing rights will not be affected by the proposed withdrawals 

or closures in the RMP. All others will be impacted. 

• SOPs and BMPs will be implemented. 

• There will be no major regulatory changes in federal or State statutes, regulations, policies, or 

guidance that govern exploration and development of minerals. 

• Surface-disturbing and other disruptive activities at authorized mining operations could continue. 

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• Mineral operations will be in compliance with all relevant federal, State, and local permits. 

• Mineral exploration and development may occur with valid existing rights. Otherwise, 

exploration and development will not occur in areas that are identified as withdrawn or closed to 

mineral entry except for those activities that are undertaken to better understand the geological 

setting and mineralization of the withdrawn lands to better inform long-term management 

decisions. Mine operators will implement the guidelines and requirements on placer mine 

reclamation, revegetation, and wildlife habitat rehabilitation for upland mines that are in the 

following BLM Instruction Memoranda: 

o Placer Mining Baseline Environmental Information Guidance and Reclamation Effectiveness 

Monitoring for Alaska Placer Mined Streams (IM-AK-2017-009) 

o Reclamation Effectiveness Monitoring Implementation Guide (AK IM-2017-010) 

o Revegetation and Wildlife Habitat Rehabilitation Criteria for Upland Mine Reclamation on 

BLM-Managed Lands in Alaska (IM-AK-2017-011) 

Standard Operating Procedures and Best Management Practices 

The impact analysis takes into account the SOPs and BMPs that could be implemented by the BLM. See 

the BSWI RMP/EIS for a list of the SOP and BMPs. 

3.5.4 Effects Analysis 

The locatable and salable minerals management actions that are proposed for the following resources, 

resource uses, and special designations would not result in effects to locatable and salable minerals: 

• Air Quality and AQRVs 

• Cultural Resources 

• Forestry and Woodland Products 

• Soils 

• Grazing 

• Hazardous Materials and Health and Human Safety 

• Leasable Minerals 

• Lands with Wilderness Characteristics 

• NNIS 

• Paleontological Resources 

• Recreation and Visitor Services 

• Support for BSWI Communities 

• Travel and Transportation 

• Vegetation 

• Visual Resources 

• Wildland Fire 

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Locatable and Salable Minerals: Effects from Water Resources and Fisheries Habitat 

Management Actions 

There are no water resources or fisheries habitat management actions common to all action alternatives 

that would impact locatable and salable minerals. 

Potential impacts from the following management topics were considered: 

• Minerals Decisions within HVWs 

• Locatable Mining 

Effects under Alternative A 

Under Alternative A, the continued management of BLM-managed land in the planning area would result 

in no additional withdrawals from locatable minerals or closures to salable mineral development 

associated with water resources and fisheries habitat management actions. The SWMFP would continue 

to direct the BLM to mitigate fishery conflicts in fisheries-based ACECs through the use of seasonal 

restrictions, area withdrawals, and other measures. Alternative A would have no effect on locatable and 

salable minerals beyond those that are already occurring. 

Effects under Alternative B 

Under Alternative B, HWVs would be withdrawn from locatable mineral entry and closed to salable 

mineral development (8,294,053 acres). Locatable withdrawals under Alternative B include existing 

withdrawals that would be retained as well as new proposed withdrawals. Of the HVWs, 2,776,883 acres 

are within existing PLOs that are withdrawn to locatable mineral entry. Therefore, Alternative B would 

result in up to an additional 5,517,170 acres of locatable mineral withdrawals compared to Alternative A. 

However, most of the HVWs are associated with tributaries to the Yukon River in the Anvik Mining 

District and do not include areas with medium or high LMP (areas with medium or high LMP are located 

primarily in the Aniak, Iditarod, McGrath, Innoko, and Ruby Mining Districts). Although salable 

minerals are likely to be present in closed areas, the demand for these salable minerals is low due to the 

long distance between source locations and population centers that would use the materials. However; 

there is some potential for salable mineral development if needed to support projects (such as access road 

development) that could occur outside of population centers. Additionally, there are few placer deposits in 

BLM-managed lands. 

The impact of HVW management decisions on locatable and salable minerals under Alternative B would 

be small. 

Effects under Alternative C 

Under Alternative C, HVWs would be open to saleable mineral development on a case-by-case basis and 

would remain open to locatable mineral entry unless other restrictions apply for other resource protections 

common to all alternatives. The case-by-case review under this alternative means that applications for 

salable mineral permits would be reviewed to evaluate alternative locations and consider impacts based 

on the specific location proposed. 

However, the impact of Alternative C on locatable minerals would be small because the areas with 

medium or high LMP are not in HVWs. Additionally, impacts to salable mineral development would also 

be small because the distance between salable mineral locations in the watersheds and population centers 

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that would use the materials is too great for cost-effective development. However, there is some potential 

for salable mineral development if needed to support projects that could occur outside of population 

centers. The case-by-case review in Alternative C does provide site specific review to mitigate impacts 

from salable mineral development if it were to occur. 

Effects under Alternative D 

Under Alternative D, like Alternative C, the 4,891,935 acres in HVWs would be open to locatable mineral 

entry. These acres would also be open to salable minerals development without the case-by-case review 

described in Alternative C. Of the HVWs, 1,214,021 acres are within existing PLOs that are withdrawn to 

mineral entry. Therefore, water resources and fisheries management of Alternative D would reduce the 

number of acres withdrawn from mineral entry by up to 1,214,021 acres. 

The impact of Alternative D on locatable minerals would be small because the areas with medium or high 

LMP are not in HVWs. Additionally, impacts to salable mineral development would also be small due to 

the same reasons listed under Alternative C. 

Locatable and Salable Minerals: Effects from Wildlife Management Actions 

There are wildlife management actions common to all action alternatives that would impact locatable and 

salable minerals. These include reclamation requirements following locatable and salable mineral 

development as well as any surface-disturbing activities within moose calving and wintering areas and 

caribou caving grounds. 

Potential impacts from the following management topics were considered: 

• Wildlife – Caribou and Moose 

• Innoko Bottoms Priority Wildlife Habitat Area 

• Connectivity Corridors 

• Migratory Birds 

Effects under Alternative A 

Under Alternative A, no existing management actions associated with wildlife would result in locatable 

minerals withdrawals or closures to salable mineral development on BLM-managed land in the planning 

area. 

Effects under Alternative B 

Under Alternative B, locatable and salable minerals development would be allowed in caribou and moose 

calving and wintering areas subject to the wildlife actions common to all alternatives. Seasonal 

restrictions on construction in moose and caribou calving habitat (May–June) and in crucial winter habitat 

areas (November–February) would apply. The seasonal restrictions may change based on changes in 

caribou or moose habitat use associated with climate change or other factors. 

Although BLM-managed land in the Innoko Bottoms Priority Wildlife Habitat Area would be withdrawn 

from locatable mineral entry and closed to salable mineral development under Alternative B, impacts 

would be small because no areas with medium or high LMP have been identified within the Innoko 

Bottoms Priority Wildlife Habitat Area. Additionally, the Innoko Bottoms Priority Wildlife Habitat Area 

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would be a ROW exclusion area so the likelihood of projects requiring salable minerals in the area would 

be small. 

Under Alternative B, 845,670 acres of BLM-managed land in the planning area would be withdrawn from 

locatable mineral entry and closed to salable mineral development to protect resources in and wildlife 

movement through the North and South Connectivity Corridors. Impacts would be small because no areas 

with medium or high LMP have been identified in the North and South Connectivity Corridors. 

Additionally, the North and South Connectivity Corridors would be ROW exclusion areas so the 

likelihood of projects requiring salable minerals in those areas would be small. 

Under Alternative B, migratory birds would be protected on BLM-managed land in the planning area by 

prohibiting mineral leasing in riparian areas. The restriction would affect primarily placer mining and 

sand and gravel mining operations. 

Effects under Alternative C 

Under Alternative C, locatable and salable minerals development would be allowed in caribou and moose 

calving and wintering areas subject to the wildlife actions common to all alternatives and the seasonal 

restriction on construction under Alternative B. The seasonal restriction may change based on changes in 

caribou or moose habitat use associated with climate change or other factors. 

BLM-managed land in the Innoko Bottoms Priority Wildlife Habitat Area and the South Connectivity 

Corridor would be open to locatable minerals development. The Innoko Bottoms Priority Habitat Area 

would be closed to salable minerals development and the South Connectivity Corridor would be open to 

salable mineral development on a case-by-case basis. Impacts to locatable minerals would be small 

because no areas with medium or high LMP have been identified in the Innoko Bottoms Priority Wildlife 

Habitat Area or the South Connectivity Corridor. Impacts to salable mineral development would also be 

small because demand depends upon proximity to the end use. 

Under Alternative C, the same protections to migratory birds that would affect locatable and salable 

mineral development would apply. 

The impact of Alternative C on locatable and salable minerals would be small. 

Effects under Alternative D 

Under Alternative D, as with Alternative C, locatable and salable minerals development would be allowed 

in caribou and moose calving and wintering areas subject to the wildlife actions common to all 

alternatives. No seasonal restrictions on construction would apply. 

Similar to Alternative C, BLM-managed land in the Innoko Bottoms Priority Wildlife Habitat Area would 

be open to locatable mineral development but closed to salable mineral development, 

Under Alternative D, the BLM would not manage any connectivity corridors and therefore there would be 

no associated minerals management actions for connectivity corridors. 

Under Alternative D, migratory birds would be protected from mineral development activities with 

appropriate avoidance and/or mitigation on a case-by-case basis to minimize impacts. 

The impact on locatable and salable minerals development from wildlife management actions under 

Alternative D would be small. 

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Locatable and Salable Minerals: Effects from Locatable and Salable Minerals 

Management Actions 

In addition to the management actions common to all action alternatives, potential impacts from the 

following management decisions were also considered: 

• Locatable Minerals 

• Bonding 

• Salable Minerals 

Effects under Alternative A 

As of December 2016, there were four active placer mines, one active lode mine, and two temporary 

placer mine closures on BLM-managed land in the planning area. 

The potential for future mineral exploration on BLM-managed land in the planning area is high due to the 

lack of information of the geological setting and mineralization potential of the area. Development of 

mineral resources in the planning area is low due to the lack of known economical deposits. The potential 

for future development of salable minerals (crushed rock, sand and gravel) on BLM-managed land in the 

planning area is also considered low because local demand for salable minerals is generally being met by 

nearby producers on private or State-owned lands. However, salable mineral development on BLMmanaged lands could occur in association with projects that require these minerals, such as road 

development. 

Under Alternative A, all lands in the planning area would be managed as undesignated. Under 

Alternative A, 4,804,488 acres would remain withdrawn from locatable mineral entry and closed to 

salable minerals development in the 13.5 million acres of BLM-managed land in the 62.3-million-acre 

planning area. There are 271,164 acres with medium to high LMP withdrawn, of which 6,354 acres are 

considered to have high LMP. 

No management direction related to the Alaska Statewide Bond Pool under Alternative A is currently 

identified. 

Effects Common to All Action Alternatives 

Under all of the action alternatives, some BLM-managed land in the planning area could be withdrawn 

from locatable mineral entry or possibly closed to salable minerals development. The Unalakleet Wild 

River Corridor would remain designated under all action alternatives, and there would continue to be no 

locatable or salable mineral activity allowed within the 46,953-acre corridor, Although the mineral 

potential of some of the planning area is low, the impacts of management actions associated with all the 

action alternatives could be moderate to high considering the potential for increased exploration and 

possible development of newly identified deposits. In areas such as the Nulato Hills, where there is little 

information about mineral potential, any restrictions would impact the potential for future exploration. All 

action alternatives would be subject to the requirements in Guidance on Reclamation Bonding for Plans 

and Notices on BLM Managed Lands in Alaska (IM-AK-2015-001). With the recent signing of the 

Donlin Gold EIS ROD, increased demand for gravel adjacent to the proposed natural gas pipeline route is 

highly likely, resulting in a potential increase in resource-related impacts. 

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Effects under Alternative B 

Under Alternative B, management actions associated with other resources discussed in this section would 

result in the withdrawal of 9,842,497 acres from locatable mineral entry (retained existing withdrawals 

and new proposed withdrawals) and the closure of 9,842,497 acres to salable minerals development in the 

13.5 million acres of BLM-managed land in the planning area. Under Alternative B, 362,878 acres with 

medium or high LMP would be withdrawn. The 362,878 acres equates to 8 percent of the medium or high 

LMP areas in the planning area but 64 percent of the medium or high LMP areas on the BLM-managed 

land in the planning area. The 362,878 acres includes 25.631 acres with high LMP and 337,247 acres with 

medium LMP. 

Because the potential for locatable and salable minerals development on BLM-managed land in the 

planning area is considered low, the impact of management actions associated with Alternative B would 

be small although the management actions would reduce incentives to further investigate lands for 

mineral potential. 

All existing and new mining operations would be bonded using an individual financial guarantee or other 

acceptable means as defined in 43 CFR 3809.500. Use of the Alaska Statewide Bond Pool would be 

restricted to operations that have a record of 5 or more years of successful reclamation of mined lands 

with no substantial compliance issues. Application of this requirement would be contingent on changes, 

modification, or supersedence of the 2015 and 2016 Reclamation Instruction Manuals. Bonding 

type/action would remain fully at the discretion of the AO. 

Effects under Alternative C 

Under Alternative C, management actions associated with other resources discussed in this section would 

result in the withdrawal of 46,943 acres from locatable mineral entry and the closure of 288,109 acres to 

salable minerals development in the 13.5 million acres of BLM-managed land in the planning area. Under 

Alternative C, no acres with medium to high LMP would be withdrawn; 522,825 acres of medium LMP 

and 42,663 acres of high LMP would be open to locatable mineral development. 

Because the potential for locatable and salable minerals development on BLM-managed land in the 

planning area is considered low, the impact of management actions associated with Alternative C would 

be small and less than Alternative B. Some additional geological investigation to better assess mineral 

potential could be expected because the limited amount of mineral resource information contributes to the 

low mineral potential assessment. This additional geologic and mineral potential information would align 

with the U.S. Department of the Interior’s goal of ensuring access to mineral resources (DOI 2018). 

All Notice- and Plan-level placer operations that meet the criteria that would make them subject to the 

2015 Reclamation Cost Estimate Instruction Manual would comply with all conditions in the manual. 

Otherwise, the Alaska Statewide Bond Pool may be accepted in accordance with 43 CFR 3809 and the 

BLM-ADNR Bond Pool Agreement. Bonding type/action would remain fully at the discretion of the AO. 

Effects under Alternative D 

Under Alternative D, management actions associated with other resources discussed in this section would 

result in the withdrawal of 46,953 acres from locatable mineral entry and the closure of 288,109 acres to 

salable minerals development in the 13.5 million acres of BLM-managed land in the planning area. Under 

Alternative D, no acres with medium or high LMP would be withdrawn. Like Alternative C, 522,825 

acres of medium LMP and 42,663 acres of high LMP would be open to locatable mineral development. 

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Alternative D would have the least impact to locatable and salable minerals compared to Alternatives B 

and C. Like Alternative C, some additional locatable mineral exploration could be expected to gather 

information to refine or confirm mineral potential assessments. 

All operations would have the option to use the Alaska Statewide Bond Pool unless excluded by the 

provisions in the BLM-ADNR Bond Pool Agreement. 

Locatable and Salable Minerals: Effects from Lands and Realty Action 

There are lands and realty management actions common to all action alternatives that would impact 

locatable and salable minerals. These include retained withdrawals for purposes managed by the DOD, 

FERC, FAA, and the BLM for specific purposes like rural airports. These withdrawals often close lands 

to mineral entry, although the restrictions can vary among the withdrawals depending upon the specific 

purposes of the withdrawals. 

Potential impacts from the following management topics were considered: 

• Decision to revoke ANCSA Section 17(d)(1) withdrawals. 

Effects under Alternative A 

Under Alternative A, no withdrawals would be revoked, and no new lands opened for mineral entry or 

salable mineral development. Under Alternative A, 264,810 acres of medium LMP and 6,354 acres of 

high LMP remain open for mineral entry. 

Effects under Alternative B 

Under Alternative B, ANCSA 17(d)(1) withdrawals totaling approximately 4,931,465 acres would be 

revoked. These actions when combined with other management actions described under Alternative B 

would allow 258,015 acres of medium LMP and 36,310 acres of high LMP on BLM-managed land in the 

planning area to be open for locatable mineral development. 

As with Alternatives C and D, the impacts to salable mineral develop remain small because salable 

minerals, unlike locatable minerals, have little economic or practical value unless the minerals occur close 

to the potential end use. 

Effects under Alternative C 

Existing ANCSA 17 (d)(1) withdrawals totaling approximately 13,461,531 acres would be revoked, 

opening lands to mineral entry or salable mineral development, 

These actions, when combined with other management actions described under Alternative C, would 

allow all 522,825 acres of medium LMP and 42,663 acres of high LMP on BLM-managed land in the 

planning area to be open to locatable mineral entry. The impacts to salable mineral development would be 

small because salable minerals have little economic or practical value unless the minerals occur close to 

the potential end use. 

Effects under Alternative D 

Under Alternative D, ANCSA 17(d)(1) withdrawals totaling approximately 13,461,531 acres would be 

revoked opening lands to mineral entry or salable mineral development, 

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The impact on locatable and salable minerals development from lands and realty management actions 

under Alternative D would be very similar to Alternative C as both alternatives would open all 522,825 

acres of medium LMP and 42,663 acres of high LMP on BLM-managed land to locatable mineral entry. 

Locatable and Salable Minerals: Effects from Areas of Critical Environmental Concern 

Management Actions 

The potential impacts from the management topics described below were considered. 

• Minerals Decisions 

Effects under Alternative A 

Under Alternative A, there would be 1,884,376 acres of BLM-managed land in the planning area that are 

managed as ACECs. Many of the existing ACECs would remain closed to mineral leasing and nonmetalliferous mineral entry because they are in existing PLOs that are withdrawn from such activity but 

would remain open to mining for metalliferous minerals. Minerals decisions for existing ACECs are 

discussed in Chapter 2, Table 2.2.2-1. Additional detail is also included in the ACEC report prepared for 

the planning area (BLM 2018). The acres of withdrawals and closures discussed in the section “Locatable 

and Salable Minerals: Effects from Locatable and Salable Minerals Management Actions” incorporate 

minerals decisions for ACECs. 

Effects under Alternative B 

All nominated ACECs, 3,912,698 acres, under Alternative B would be withdrawn from locatable mineral 

development and closed to salable mineral development. Because the potential for locatable and salable 

minerals development on BLM-managed land in the planning area is considered low, the impact of 

management actions associated with Alternative B would be small. 

Effects under Alternative C 

Under Alternative C, no land would be managed as ACECs. Therefore, there would be no impacts to 

locatable and salable minerals operations and development from ACEC management actions under 

Alternative C. 

Effects under Alternative D 

Under Alternative D, no land would be managed as ACECs. Therefore, there would be no impacts to 

locatable and salable minerals operations and development from ACEC management actions under 

Alternative D. 

Locatable and Salable Minerals: Effects from National Trails Management Actions 

There are no national trails management actions common to all action alternatives. Potential impacts from 

the following management topic were considered: 

• Minerals Decisions in the INHT NTMC 

Effects under Alternative A 

Under Alternative A, the INHT would not be designated an NTMC and no additional withdrawals from 

locatable mineral entry or closures to salable minerals development in areas adjacent to the trail would 

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occur. Existing guidelines in the SWMFP would continue to protect the federally managed portion of the 

INHT and associated historic sites from damage or disturbance due to other resources use. 

Effects under Alternative B 

Under Alternative B, 288,466 acres would be designated as the INHT NTMC to protect the federally 

managed portion of the INHT and associated historic sites from damage or disturbance due to other 

mineral resource use. The designation of the INHT NTMC would withdraw 288,466 acres from locatable 

mineral exploration and development and salable mineral development, and the INHT NTMC would be 

closed to seismic exploration. There are no acres with medium to high LMP within the INHT NTMC 

under Alternative B. 

Development plans for locatable and salable minerals would be authorized if the AO determines that 

direct and cumulative impacts associated with the action would not conflict with the nature and purpose 

of the INHT. 

Because the potential for locatable and salable minerals development on BLM-managed land in the 

planning area is considered low, the impact of management actions associated with Alternative B would 

be small. 

Effects under Alternative C 

Under Alternative C, 273,242 acres would be designated as the INHT NTMC. Unlike Alternative B, the 

INHT NTMC would be open to locatable mineral exploration and development and open for salable 

mineral development. Approximately 273,242 acres of the INHT NTMC would be closed to seismic 

exploration under Alternative C. There are no acres with medium to high LMP within the INHT NTMC 

under Alternative C. 

Development plans for locatable and salable minerals would be authorized as described for Alternative B. 

Because the potential for locatable and salable minerals development on BLM-managed land in the 

planning area is considered low, the impact of management actions associated with Alternative C would 

be small. 

Effects under Alternative D 

Under Alternative D, 273,242 acres would be designated as the INHT NTMC. Similar to Alternative C, 

the 273,242 acres within the INHT NTMC would be open to locatable mineral exploration and 

development and open for salable mineral development. There are no acres with medium to high LMP 

within the INHT NTMC under Alternative B. The INHT NTMC would be open for seismic exploration 

under Alternative D. Development plans for locatable and salable minerals would be authorized as 

described for Alternatives B and C. 

The impact of national trails management actions under Alternative C would be small. 

Locatable and Salable Minerals: Effects from Wild and Scenic Rivers Management Actions 

Effects under Alternative A 

Under Alternative A, the Unalakleet Wild River Corridor would remain (46,953 acres) and 18 river 

segments (331,120 acres) have been identified as eligible. There are no management actions specific to 

locatable and salable minerals for the Unalakleet Wild River Corridor or the 331,120 acres of eligible 

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WSR corridors. According to BLM Manual 6400, projects on BLM-managed lands within the river 

corridor or on lands that are adjacent to or border eligible rivers must consider guidelines to protect 

ORVs. There are no specific guidelines that prohibit locatable mineral development for the 331,120 acres 

of eligible WSR corridors; although through the use of BMPs activities would minimize surface 

disturbance, sedimentation and pollution, and visual impairment. Because all eligible WSR corridors are 

eligible wild rivers, new disposal of salable mineral material or the extension or renewal of existing 

contracts would be avoided if possible. Therefore, salable mineral activity would be limited within those 

eligible corridors. 

Effects Common to All Action Alternatives 

The Unalakleet Wild River Corridor would remain designated under all Action Alternatives and there 

would continue to be no locatable or salable mineral activity allowed within the 46,953-acre corridor. 

Because the potential for locatable and salable minerals development on BLM-managed land in the 

planning area is considered low, the impact of management actions associated with Alternative C would 

be small. 

Effects under Alternative B 

Under Alternative B, the 18 river corridors recommended as eligible Wild Rivers (331,120 acres) would 

not have any specific management actions for locatable and salable minerals. However, as with 

Alternative A, projects on BLM-managed lands within the river corridor or on lands that are adjacent to 

or border suitable rivers must consider guidelines to protect ORVs. These guidelines are the same as those 

described above under Alternative A; therefore, Alternative B would have the same potential impacts and 

limitations to locatable and salable mineral development as Alternative A. 

Effects under Alternative C and D 

Effects under Alternative C and D are described above under “Effects Common to All Action 

Alternatives.” 

Locatable and Salable Minerals: Effects from Climate Change 

Climate change could lead to permafrost thaw, glacial retreat, and altered water availability in the 

planning area. Permafrost thaw could adversely impact mining activities and overland travel by creating 

wetter surface areas and eroding water shorelines. Glacial retreat could expose additional areas with 

locatable and salable minerals. Changes to water availability could impact hazardous materials controls at 

mine sites, dust abatement activities, and other mine operations. The BLM would continue to work with 

permittees to monitor climate change impacts on mining and adjust individual plan requirements, as 

needed, to address any such impacts. 

Locatable and Salable Minerals: Cumulative Effects 

The results of the cumulative effects analysis for locatable and salable minerals are presented in Table 

3.5.4-1. 

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Table 3.5.4-1: Cumulative Effects Analysis for Locatable and Salable Minerals 

Trends and Forecasts of 

Locatable and Salable Minerals 

in Consideration of Past and 

Present Actions 

Trends and Forecasts of Locatable and 

Salable Minerals in Consideration of Past, 

Present, and Reasonably Foreseeable 

Future Actions (Alternative A) 

Trends and Forecasts of 

Locatable and Salable 

Minerals in 

Consideration of Past, 

Present, and Reasonably

Foreseeable Future 

Actions (Alternative B) 

Trends and Forecasts of 

Locatable and Salable Minerals in 

Consideration of Past, Present, 

and Reasonably Foreseeable 

Future Actions (Alternative C) 

Trends and Forecasts of 

Locatable and Salable Minerals 

in Consideration of Past, 

Present, and Reasonably

Foreseeable Future Actions 

(Alternative D) 

Although some attempts at mining 

started as early as the 1830s, there 

was no widespread mining for many 

decades. Most of it is concentrated 

in upland areas and lowlands in the 

immediate vicinity of the uplands. 

The planning area contains 2,480 

mining claims, of which 207 are 

under federal management. There 

are four active placer mines, one 

active lode mine, and two 

temporary placer mine closures on 

BLM-managed land in the planning 

area. 

Trend: Continues at a similar rate 

Less than 1 percent of the total acreage 

taken up by mining claims and prospecting 

sites in the planning area are under federal 

management. Exploration and mining on 

non-BLM-managed areas adjacent to BLM 

land (e.g., Donlin Gold Project) may 

necessitate management decisions to 

prevent unnecessary disturbance to BLMmanaged land in the planning area by ROW 

corridors, roads, and development on these 

adjacent lands. 

Trend: Degrades (requires active 

management by federal agencies) 

Same as Alternative A Very similar to Alternative A 

although there may a slight increase 

in staking claims or in developing 

mining operations with the small 

(approximately 6,000-acre increase 

of high LMP lands as compared to 

Alternative A. 

Very similar to Alternative A 

although there may a slight 

increase in staking claims or in 

developing mining operations with 

the small (approximately 6,000-

acre increase of high LMP lands 

as compared to Alternative A 

The majority of the mining and Because most of the mining and mineral Same as Alternative A If more lands in the planning area If more lands in the planning area 

mineral exploration is taking place exploration is not taking place on federal were open to mineral entry there were open to mineral entry there 

on lands owned by the State of lands and because of the lack of areas with could be expanded exploration and could be expanded exploration 

Alaska, Native Corporations, or high LMP on unencumbered BLM-managed mapping of the mineral potential of and mapping of the mineral 

other private lands. A total of 13 land in the planning area, there is likely to be unencumbered BLM land. Current potential of unencumbered BLM 

salable minerals production sites a low level of interest in staking claims or in understanding of the mineral land. Current understanding of 

were reported to be active in 2008 developing mining operations on potential of the BLM unencumbered the mineral potential of the BLM 

in Southwest Alaska, which unencumbered BLM-managed land in the land is currently low but the unencumbered land is currently 

includes the planning area. planning area for the reasonably foreseeable potential for new mining claims and low but the potential for new 

Trend: Continues at a similar rate future. 

Trend: No contribution 

development is moderate due to the 

potential for new unexplored lands 

being available. 

Trend: Potential contribution 

mining claims and development is 

moderate due to the potential for 

new unexplored lands being 

available. 

Trend: Potential contribution 

There are currently no pending Local demands are being met by sand and More areas would be More areas would be open to Same as Alternative C 

requests to develop sand and gravel producers on private or State-owned closed to salable mineral salable mineral development than 

gravel on BLM-managed land in the lands, which is unlikely to change in the near development than Alternative A. Although demand 

planning area. future due to lack of appropriate BLM- Alternative A so requests isn’t expected to increase 

Trend: Continues at a similar rate managed land in the planning area near 

population centers that require sand and 

gravel. However, there is some potential for 

salable mineral development if needed to 

support projects outside population centers. 

Trend: No contribution to resource trend 

to develop sand and gravel 

on BLM-managed land in 

the planning area would 

remain low. 

Trend: No contribution to 

resource trend. 

substantially, there could be an 

increase in requests to develop 

sand and gravel on BLM-managed 

land in the planning area to support 

projects requiring such resources. 

Trend: Potential contribution 

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3.6 Lands and Realty 

3.6.1 Summary 

Management actions that impact the lands and realty program are those that change the amount of BLMmanaged lands or that increase or decrease the BLM’s ability to accommodate demand for new land use 

authorizations (e.g., ROWs and leases). Conveyances to the State of Alaska and the ANCSA corporations 

will continue and will affect BLM long-term management when selections rights are rejected or 

relinquished, and the lands are not segregated from the public land laws by State and ANCSA selections. 

Alternative A would have the least impact on the BLM's ability to accommodate demand for new land use 

authorizations. Greater restrictions on land use authorizations under Alternative B would have a higher 

magnitude of impact on lands and realty than Alternative A. The identification of more lands for disposal 

or exchange under Alternative D could reduce the amount of BLM-managed lands compared to 

Alternative A, but land tenure adjustments can also increase management efficiency and benefit the lands 

and realty program by consolidating tracts and disposing of parcels that are costly and of little or no 

value. This supports the DOI’s mission to modernize organization and infrastructure for the next 100 

years by reducing administrative and regulatory burden (DOI 2018). Alternative B, compared to all other 

alternatives, would manage the largest portion of the planning area as ROW exclusion; many of those 

lands would be managed for avoidance under Alternative C. Alternative C is similar to Alternative A but 

has fewer restrictions on ROW areas and allows more flexibility for adaptive management and would 

revoke more existing withdrawals. Alternative D would impact lands and realty similarly to Alternative A 

but would revoke more withdrawals (as would Alternative C), which would directly impact land status in 

the planning area by changing ownership, if the revoked withdrawal areas are conveyed under ANCSA or 

the Statehood Act or disposed of by BLM. 

3.6.2 Methods of Analysis 

The nature and types of potential impacts on lands and realty from proposed actions under each 

alternative were based on data gathered during the planning process, the BLM interdisciplinary team’s 

knowledge of the resource, and input provided during the public scoping process. Where possible, this 

analysis uses quantitative data to describe impacts on lands and realty from proposed management actions 

associated with other resources and resource use. Qualitative information is also used to support 

quantitatively based analysis or where numerical data does not exist. In all cases, best professional 

judgment is used in evaluating effects on the lands and realty program. 

3.6.3 Potential Effects and Indicators 

The lands and realty program is affected by actions that change the land status in the planning area. This 

includes parcels of land that are conveyed, acquired, or disposed of during the planning period. 

Management actions that can influence land status are those that identify parcels for acquisition, retention, 

or disposal. These actions change the number of acres directly owned or managed by the BLM. Lands 

that are disposed of would no longer be subject to BLM management, limiting BLM’s ability to protect 

resources and accommodate future activities. 

Other changes in the lands and realty program occur when parcels are withdrawn, as described in 

Appendix M of the BSWI Draft RMP/EIS. The creation of new withdrawals, maintenance of existing 

withdrawals, or revocation of existing withdrawals would have implications on land use and resource 

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Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

protections, such as changing land status and limiting BLM’s ability to accommodate future resource 

extraction. 

Additionally, ROW exclusion and avoidance areas could limit economic opportunities and preclude the 

BLM from accommodating future ROW demands. 

The types of effects to lands and realty that could result from management actions and the indicators used 

to evaluate them are shown in Table 3.6.3-1. 

Table 3.6.3-1: Summary of Effects to Lands and Realty by Management Action 

Types of Effects Management Actions Indicators 

Land status changes could impact land • Land Tenure Decisions for the INHT • Acres of BLM-managed lands 

ownership by changing the number of NTMC and INHT SRMA identified for acquisition, retention, or 

acres directly owned or managed by the 

BLM. • Land Acquisition 

• Lands made available for lease or sale 

under the R&PP Act 

disposal 

• Acres affected by land withdrawals 

Lands that are disposed of would no longer • FLPMA Withdrawals • Acres of BLM-managed lands 

be subject to BLM management, limiting 

BLM’s ability to protect resources and 

accommodate future activities. 

• Land Tenure Decisions for the INHT 

NTMC 

• Disposals 

• Lands made available for lease or sale 

under the R&PP Act 

identified for acquisition, retention, or 

disposal 

• Acres affected by land withdrawals 

Creation of new withdrawals, maintenance • Buffers for Surface-disturbing BLM- • Acres or river miles affected by land 

of existing withdrawals, or revocation of permitted Activities withdrawals 

existing withdrawals would have 

implications on land use and resource • Minerals Decisions • Total VRM Class Acreages 

protections, such as changing land status • Lands with wilderness characteristics 

and limiting BLM’s ability to accommodate • PLOs Withdrawing Land Under the future resource extraction. Authority of ANCSA 17(d)(1) 

• Transportation and Travel Management 

Decisions 

• Lands Managed for Wilderness 

Characteristics TMA 

• Proposed WSRs 

ROW exclusion and avoidance areas could • Wildlife migration and connectivity • Acres of BLM-managed surface 

limit economic opportunities and preclude corridors ownership affected by ROW lease or 

the BLM from accommodating future ROW 

demands. • Lands with wilderness characteristics 

• ROW Exclusion and Avoidance Areas 

• Transportation and Travel Management 

Decisions 

• Lands Managed for Wilderness 

Characteristics TMA 

• Communications Sites ROW 

permit restrictions (i.e., avoidance or 

exclusion, no surface occupancy) 

• Acres or river miles open to locatable 

and leasable minerals, which may 

result in the need for lands and realty 

actions 

• Total VRM Class Acreages 

• Acres of ROW exclusion or avoidance 

areas 

Assumptions 

The following assumptions were used to assess effects associated with lands and realty: 

• Land status will change slightly over the course of the planning period as lands are conveyed. 

Analysis is based on the most current GIS land status data and most current master title plats. 

• ROW avoidance areas would only be impacted if no other ROW option was available. 

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• Changes in land use would be assessed under the specific resource being impacted. For the 

purpose of this analysis, this section only focuses on land status. 

• All land not specifically identified for disposal or exchange is classified for retention. 

• Retaining access to BLM-managed lands for public use and administrative purposes will continue 

to be a priority of the lands and realty program. 

• The BLM will continue to periodically review its withdrawals to see if they are still applicable 

and serve the BLM interests and whether the lands should be returned to the full spectrum of 

public land laws. Withdrawals held by other agencies would remain unless those other agencies 

requested a relinquishment. 

• Stipulations may be applied for ROW lease or permit approval at the project level. 

The effects analysis for lands and realty is limited due to incomplete or unavailable information, 

including: 

• Location and number of unauthorized trapping or subsistence cabins and other unauthorized 

structures. 

Standard Operating Procedures and Best Management Practices 

The impact analysis below takes into account the SOPs and BMPs that could be implemented by the 

BLM. A comprehensive list of SOPs/BMPs pertaining to lands and realty is provided in the BSWI 

RMP/EIS. 

3.6.4 Effects Analysis 

Management actions proposed for the following resources, resource uses, and special designations would 

not result in effects to lands and realty: 

• Air Quality and AQRVs 

• Soils 

• Vegetation 

• NNIS 

• Wildland Fire 

• Cultural Resources 

• Paleontological Resources 

• Grazing 

• Hazardous Materials and Health and Human Safety 

Lands and Realty: Effects from Water Resources and Fisheries Habitat Management 

Actions 

In addition to management actions common to all action alternatives, potential impacts from the 

following management topics were considered: 

• Minerals Decisions within HVWs 

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Effects under Alternative A 

Under Alternative A, some spawning habitat could be withdrawn (if greater than 5 acres) from mineral 

location and FLPMA sales and leases. These withdrawals include portions of the North Fork Unalakleet 

River, Kateel River, and the Gisasa River. These restrictions limit the BLM’s ability to accommodate 

future sales in these areas, which is a long-term direct impact. 

Effects Common to All Action Alternatives 

For all alternatives, permanent structures and disturbance greater than 5 acres would be avoided within 

the 100-year floodplain areas of streams. These restrictions would prevent BLM from addressing permits 

and leases requests in these areas, which may include permits for scientific work as well as permitting 

unauthorized structures or addressing public demand for leases and permits. 

Effects under Alternative B 

Under Alternative B, HVWs would be closed to salable minerals entry, closed to mineral leasing, and 

withdrawn from locatable mineral entry. If the recommended locatable withdrawal is not approved, 

locatable development would comply with all other management under this alternative. These restrictions 

would limit the BLM’s ability to accommodate future resource extraction in these areas, a long-term 

indirect impact, although impacts would be minimal because there is little to no known leasable mineral 

potential during the expected life of the plan. These restrictions could impact up to 21,382 river miles. 

Effects under Alternative C 

Under Alternative C, HVWs would be open to salable minerals entry on a case-by-case basis, NSO for 

leasable minerals, and open to locatable mineral entry. These restrictions would limit the BLM’s ability to 

accommodate future resource extraction in these areas, a long-term indirect impact, although impacts 

would be minimal because there is little to no known leasable mineral potential during the expected life of 

the plan. Locatable mineral entry opening would mean that more acres would be affected, and more 

permits issued. These restrictions could impact up to 14,888 river miles. 

Effects under Alternative D 

Under Alternative D, all 12,982 river miles within HVWs could be open to salable minerals entry, have 

standard stipulations for leasable minerals, and open to locatable mineral entry, with the same types of 

impacts as Alternative C. There would be no impact to lands and realty. 

Lands and Realty: Effects from Wildlife Actions 

In addition to management actions common to all action alternatives, potential impacts from the 

following management topics were considered: 

• Leasable Minerals 

• Locatable and Salable Minerals 

• Mineral Decisions 

• Connectivity Corridors 

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Effects under Alternative A 

For leasable minerals, impacts are currently mitigated through stipulations for seasonal use or NSO in 

crucial habitat areas. Additionally, no connectivity corridors would be managed. There would be no direct 

or indirect impact on lands and realty in the planning area. 

Effects Common to All Action Alternatives 

For all action alternatives, the Plan of Development for linear project ROWs must address caribou 

passage in all known caribou connectivity corridors. For areas other than the ROW avoidance areas 

specified under each alternative, applicants must provide scientifically defensible information to 

demonstrate that their proposed linear facility would not impede caribou migration to support the sitespecific NEPA analysis. This restriction would affect the location of potential ROWs in the planning area. 

Effects under Alternative B 

Alternative B would have more restrictions on land use and development, particularly mineral 

development, than Alternatives C and D. These restrictions limit the BLM’s ability to accommodate 

future resource extraction in these areas, which is a long-term direct impact to land use, but would not 

impact land status. 

To protect migratory birds, riparian areas would be ROW avoidance areas. These ROW avoidance areas 

may prevent BLM from issuing ROW in these areas, which may add to the economic costs of ROWs and 

may prevent BLM from addressing public proposals in these areas. 

Activities and development in caribou and moose calving and wintering habitats, the Innoko Bottoms 

Priority Wildlife Habitat Area, North and South Connectivity Corridors, and riparian areas would be 

limited by allowing only NSO for leasable minerals. The Innoko Bottoms Priority Wildlife Habitat Area 

and North and South Connectivity Corridors would also be NSO for BLM-permitted activities. (Note: all 

acres in HVWs are closed to mineral leasing,) The BLM would also pursue withdrawal from locatable 

mineral entry in the Innoko Bottoms Priority Wildlife Habitat Area and connectivity corridors. 

Effects under Alternative C 

Under Alternative C, there would be fewer restrictions on future resource extraction and surfacedisturbing activities and development than Alternative B. As with Alternative B, riparian areas would be 

ROW avoidance areas. 

For the Innoko Bottoms Priority Wildlife Habitat Area, restrictions for leasable and salable mineral 

development would be the same as under Alternative B, but the area would be open to locatable 

development. Salable mineral development for the South Connectivity Corridor would open on a case-bycase basis unlike Alternative B, and locatable mineral development would be allowed. The South 

Connectivity Corridor would also be a ROW avoidance area for linear ROWs. There would be no North 

Connectivity Corridor managed under Alternative C; therefore, that area would not have any development 

restrictions associated with wildlife management actions. 

There would be seasonal restrictions on leasable or salable operations in caribou calving habitat, and NSO 

for leasable minerals would also be allowed in caribou and moose calving and wintering habitats. 

Leases and permits dealing with occupancy (including trapping cabins) in CSUs and lands managed as 

wilderness would be done on a case-by-case basis, which increases BLM's ability to respond to public 

proposals compared to Alternative B. 

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Effects under Alternative D 

Alternative D would have fewer restrictions on land use and development than Alternatives B and C. 

Under Alternative D, mineral leasing would be allowed in calving and wintering habitats under standard 

stipulations, and locatable and salable minerals development would be allowed subject to management 

common to all alternatives. Avoidance or mitigation actions to minimize impacts on migratory birds 

would be determined on a case-by-case basis. There would be no impacts to lands and realty. Impacts 

from mineral decisions for the Innoko Bottoms Priority Wildlife Habitat Area would be the same as under 

Alternative C, and connectivity corridors would be managed the same as under Alternative A. Permits 

and leases would be allowed in wilderness areas and in CSUs on a case-by-case basis. The BLM's ability 

to issue such permits and leases allows for more opportunity to address public proposals for land use 

authorizations. 

Lands and Realty: Effects from Visual Resources Management Actions 

In addition to management actions common to all action alternatives, potential impacts from the 

following management topic were considered: 

• Total VRM Class Acreages 

Effects under Alternative A 

Alternative A would continue to manage parts of the planning area as VRM Class I or II (total number of 

acres is unspecified). New ROW development, particularly those for high-visibility features such as trails 

and pipeline ROWs, would conflict with VRM objectives in these areas and likely be approved only if relocated or designed to minimize impacts on desired visual resource conditions. 

Effects Common to All Action Alternatives 

Under all alternatives, the BLM would manage resource and resource uses consistent with applicable 

VRM class objectives. Objectives for VRM Class I and II, which respectively specify preservation and 

retention of existing landscape characteristics, would have a greater likelihood of limiting the location 

and/or applying mitigation measures to ROWs and other land use authorizations. Fewer restrictions 

would be likely in VRM Classes III and IV. 

Effects under Alternative B 

Alternative B would manage approximately 7,825,858 acres, or 58 percent, of the BLM-managed lands in 

the planning area, as VRM Class I or II, which would affect the location and types of land use 

authorizations allowed in those areas. The remainder of the planning area would be designated VRM 

Class III and IV. Objectives for VRM Class III and IV would support new or expanded ROW 

development within these areas, particularly within VRM Class IV areas. 

Effects under Alternative C 

Alternative C would manage approximately 2,818,182 acres, or 21 percent BLM-managed lands in the 

planning area as VRM Class I or II, which would affect the location and types of land use authorizations 

allowed in those areas. The remainder of the planning area would be designated as VRM Class III or IV. 

Alternative C would designate over twice as many acres of land managed as VRM Class III or IV and 

therefore more areas would be available to support expanded ROW development. 

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Effects under Alternative D 

Alternative D would manage approximately 725,506 acres, or 5 percent, of the BLM-managed lands in 

the planning area, as VRM Class I or II, which would affect the location and types of land use 

authorizations allowed in those areas. The remainder of the planning area would be designated as VRM 

Class III or IV. Alternative D would designate almost four times as many acres of land as VRM Class III 

or IV and therefore more areas would be available to support expanded ROW development than 

Alternative B or C. 

Lands and Realty: Effects from Lands with Wilderness Characteristics Management 

Actions 

In addition to management actions common to all action alternatives, potential impacts from the 

following management topic were considered: 

• Management of Lands with Wilderness Characteristics 

Effects under Alternative A 

Current management of lands with wilderness characteristics would not impact lands and realty. 

Effects Common to All Action Alternatives 

Under all action alternatives, the BLM would acquire non-BLM lands to consolidate and improve 

management of natural values or primitive settings, through exchange, willing sellers, or other suitable 

means. This requirement would directly affect the land status of the planning area. 

Additionally, the BLM would withdraw all allocated lands with wilderness characteristics lands from 

locatable mineral entry and close the areas to salable mineral permits and free use mineral material 

development. There would be NSO to leasable development with no exceptions, waivers, or 

modifications. These restrictions would limit the BLM’s ability to accommodate future sales in these 

areas, which is a long-term direct impact. 

Effects under Alternative B 

Management actions associated with lands with wilderness characteristics under Alternative B would 

impact land status more than under Alternatives C and D. The BLM would retain all areas managed for 

wilderness characteristics as a priority that are in BLM ownership, which may affect lands that are 

identified for disposal. Under Alternative B, approximately 277,489 acres (2 percent of BLM-managed 

lands in the planning area) would be managed for wilderness characteristics as a priority. Additionally, 

approximately 12,040,490 acres would be managed for wilderness characteristics for mid-level 

protections, meaning that they would be managed to emphasize other resource values and multiple uses 

while applying management restrictions to reduce impacts on wilderness characteristics. Although 

development restrictions are greater for Mid-Level Protection Areas than Low-Level Protection Areas, 

they would not affect land status or BLM’s ability to convey or dispose of those lands. Management of 

remaining lands in the planning area would emphasize other resource uses as a priority over wilderness 

characteristics, having no effect on land status or BLM’s ability to accommodate future resource 

extraction. 

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Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

Under Alternative B, approximately 294,053 acres would be managed as HVWs, included below in the 

discussion of ROW exclusion and avoidance areas in Effects from Lands and Realty Management 

Actions. The 100-year floodplain within HVWs would be closed to commercial woodland harvest. 

Effects under Alternative C 

There would be no lands managed for wilderness characteristics as a priority and approximately 

8,105,979 acres managed for wilderness characteristics for mid-level protections. Management of the 

remaining approximately 5,360,024 acres would emphasize other resource uses as a priority over 

wilderness characteristics, having no effect on land status or resource extraction. Alternative C would 

result in fewer impacts to land status and BLM’s ability to accommodate future resource extraction than 

Alternative B. 

Under Alternative C, approximately 5,560,642 acres would be managed as HVWs, included below in the 

discussion of ROW exclusion and avoidance areas in “Lands and Realty: Effects from Lands and Realty 

Management Actions.” 

Effects under Alternative D 

Under Alternative D, the entire planning area would be managed to emphasize other resource uses as a 

priority over wilderness characteristics, having no effect on land status or resource extraction. 

Alternative D would not impact land status and BLM’s ability to accommodate future resource extraction 

or address public demand for lands and realty actions. 

Lands and Realty: Effects from Forestry and Woodland Products 

Under all alternatives, certain activities for woodland harvest would require a personal use land use 

permit, commercial harvest woodland harvest permit, or other applicable land use permits under the 

forestry and woodland products programs. 

Lands and Realty: Effects from Locatable and Salable Minerals Management Actions 

Management actions associated with locatable and salable minerals, such areas proposed for withdrawal 

for locatable minerals and areas closed to salable minerals, would affect lands and realty. However, those 

management actions are included in the following management topics and described in those respective 

subsections: Water Resources and Fisheries, Wildlife, Lands with Wilderness Characteristics, ACECs, 

National Trails, and WSRs. 

Lands and Realty: Effects from Leasable Minerals Management Actions 

Lands currently under selection by the State of Alaska and Native corporations are segregated from 

mineral leasing to avoid potential encumbrances on selected lands prior to conveyance. 

Effects under Alternative A 

Alternative A would continue the current management of leasable minerals with a goal of providing 

opportunities for leases and sales on federal lands where environmentally feasible and where compatible 

with management objectives. Under Alternative A, the following areas, totaling 5,202,221 acres, would 

be closed to all mineral leasing. 

• Unalakleet Wild River Corridor withdrawal 

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• Eight RNAs 

• All subsistence withdrawal study areas (except linear withdrawals) 

• Withdrawal/Exchange lands 

• Existing PLOs 

This management action could indirectly impact the BLM’s ability to accommodate leasable development 

in the planning area. 

Effects Common to All Action Alternatives 

The following actions would be common to all alternatives and would guide where leasable mineral 

development would be allowed by BLM, indirectly affecting lands and realty in the planning area. 

• The entire planning area would be open to oil and gas leasing, but any locations proposed for 

withdrawal from locatable mineral entry would also be NSO for oil and gas. 

• All BLM-managed public lands within the planning area subject to leasing would open to coal 

exploration and study. 

• Oil shale and non-energy leasable minerals would be leased on a case-by-case basis. 

• Unless already closed, the entire planning area would be open to development of other leasable 

minerals/products (e.g., geothermal). Issuance of these mineral leases would be determined on a 

case-by-case basis. 

Management actions for other alternatives regarding leasable minerals are discussed in resource sections, 

as appropriate. 

Lands and Realty: Effects from Lands and Realty Management Actions 

In addition to management actions common to all action alternatives, potential impacts from the 

following management topics were considered: 

• PLOs Withdrawing Land Under the Authority of ANCSA 17(d)(1) 

• FLPMA Withdrawals 

• Land Tenure Decisions for the INHT NTMC 

• Locatable and Leasable Mineral Withdrawals (see section above) 

• FLPMA ROW Exclusion and Avoidance Areas 

• Wind Energy Development 

• Permits and Leases 

• Land Acquisition 

• Disposals 

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Effects under Alternative A 

No current management objectives are established by the BLM for FLPMA withdrawals, land tenure 

decisions for the INHT NTMC, ROW exclusion and avoidance areas, or wind energy development that 

would affect lands and realty. 

Alternative A would not identify any specific lands for disposal, acquisition, or exchange but would 

continue adjustment of land ownership boundaries and jurisdiction to make each agency’s lands as 

manageable as possible. This action could directly impact land status in the planning area by changing the 

number of acres directly owned or managed by the BLM. 

Regarding permits and leases under Alternative A, some historic sites within the ROW of the INHT may 

be suitable for use as trapping cabins under caretaker agreements, but permanent occupancy of historic 

sites would be discouraged. Structures used in conjunction with hunting, trapping, and fishing would be 

consistent with resource management principles. There would be no effects to lands and realty. 

There would be no effects to lands and realty under Alternative A unless there were to be acquisitions 

and/or disposals of land, which would have direct, long-term impacts to land status in the planning area. 

Effects Common to All Action Alternatives 

Under all action alternatives, lands would be made available for lease or sale to benefit local communities 

per the criteria for Recreation and Public Purposes (R&PP) Act (1926). The BLM would also consider 

specific lands for disposal, exchange, and acquisition as laid out in Section 2.8.16 of the BSWI Draft 

RMP/EIS. The BLM would only pursue acquisitions in the event there is a willing seller and available 

funds to support acquisition. All action alternatives include provisions for developing new ROWs or 

making changes to existing ROWs. Any lands disposed, exchanged, or acquired would directly impact the 

land status of the planning area. 

Land acquisition and disposal by the BLM ensures the effective administration of BLM lands and serves 

the public interest by consolidating land patterns, improving resource management, maintaining access to 

BLM-managed lands, and supporting community development on adjacent non-BLM-managed lands. 

Disposal of BLM-managed lands improves the effectiveness of BLM land management when disposed 

lands have little or no resource value and disposal would consolidate land patterns, improvement resource 

management on retained lands, and allow for community and/or agricultural development on adjacent 

non-BLM-managed lands. Any land exchange or disposition not specifically anticipated in this RMP 

would be supported by additional NEPA analysis on a case-by-case basis. 

Trespass limits the effectiveness of BLM land management and would be addressed on a case-by-case 

basis to resolve properly. Existing trespass cabins would be removed, put under permit, or turned into 

government administrative sites. These actions would be determined at the site-specific implementation 

level. 

The alternatives considered in the EIS may consider new withdrawals for specific purposes. These 

proposed new withdrawals may limit the BLM’s ability to address land and realty proposals in the future. 

Effects under Alternative B 

Under Alternative B, there would be approximately 9,795,543 acres of proposed FLPMA withdrawals, 

approximately 8,530,066 acres of existing ANCSA 17(d)(1) withdrawals that would be retained, and 

approximately 4,931,465 acres of existing ANCSA 17(d)(1) withdrawals that would be revoked. Because 

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withdrawals differ in their purpose and mechanism, there is overlap between proposed, retained, and 

revoked withdrawals. See Map 2-37 of the BSWI Draft RMP/EIS, which shows the complete withdrawal 

status for Alternative B. 

Under Alternative B, all lands within the INHT NTMC would be retained and would also be excluded 

from wind energy development. There would be no direct or indirect impacts to lands and realty except 

for not being able to respond to wind development proposals. 

Withdrawals Enacted Using the Authority of ANCSA (d)(1) 

Alternative B would revoke existing ANCSA 17(d)(1) withdrawals, except in those areas within HVWs, 

areas proposed for management of wilderness characteristics as a priority, and within a 1,000-foot-wide 

buffer centered on the existing INHT treadway at the Farewell Burn unit (2,732 acres) and the Kaltag 

Portage unit (1,897 acres). ANCSA 17(d)(1) withdrawals protecting these resources would be retained 

until a new withdrawal for the stated purpose is completed. Any revocation or retention of withdrawals 

could have direct impacts to the land status in the planning area. A complete list of current withdrawals 

can be found in Appendix M of the BSWI Draft RMP/EIS. 

FLPMA Withdrawals 

Alternative B would establish new FLPMA withdrawals to prohibit salable, locatable, and leasable 

minerals for on the existing INHT treadway at the Farewell Burn unit (2,732 acres), the Kaltag Portage 

unit (1,897 acres), and the Rohn Site (363 acres). Map 2-36 of the BSWI Draft RMP/EIS illustrates the 

location of these sites. There would be potential direct impacts to land use by limiting BLM’s ability to 

accommodate future resource extraction. 

FLPMA ROW Exclusion and Avoidance Areas 

Subject to valid existing rights, there would be approximately 1,464,069 acres of ROW exclusion areas 

and approximately 8,824,848 acres of FLPMA ROW avoidance areas under Alternative B. FLPMA ROW 

exclusion areas preclude BLM from accommodating future ROW demands in those areas, and FLPMA 

ROW avoidance areas limit BLM’s ability to do so, both resulting in long-term direct impacts. 

Permits and Leases 

Under Alternative B, occupancy leases or trapping/subsistence cabin permits would not be allowed within 

300 feet of riparian areas. Trapping cabins would not be permitted within 30 trail miles of ANCSA 14c(3) 

lands or a city. This distance may be altered based on identified resource damage or user conflict. No 

permits or leases would be granted for construction of structures within conservation system units and 

lands managed for wilderness characteristics as a priority. There would be a direct impact on BLM's 

ability to respond to public demand for leases and permits and to permit unauthorized structures in these 

areas. 

Disposals and Exchanges 

Under Alternative B, the same areas available for disposal under Alternative D would be available for 

exchange, except the following: 

• Lands with Wilderness Characteristics Managed as a Priority 

• ACECs 

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• Connectivity Corridors 

Under Alternative B, approximately 342,360 acres would be available for exchange, but not for disposal. 

Appendix F of the BSWI Draft RMP/EIS lists lands considered for exchange or disposal. These acres are 

estimated based on GIS data. Details on these parcels and their legal descriptions are found in 

Appendix F. Any exchanged lands would have direct impacts to the land status of the planning area. 

Criteria for land exchanges would be the same as for Alternative D disposals or exchanges (see below) 

but would exclude lands with wilderness characteristics managed as a priority, ACECs, and connectivity 

corridors. 

Effects under Alternative C 

Under Alternative C, there would be approximately 4,991 acres of proposed FLPMA withdrawals. All 

13,461,531 acres of existing ANCSA 17(d)(1) withdrawals would be revoked. Because withdrawals differ 

in their purpose and mechanism, there is overlap between proposed and revoked withdrawals. Map 2-38 

of the BSWI Draft RMP/EIS, shows the complete withdrawal status for Alternative C. 

As with Alternative B, under Alternative C all lands within the INHT NTMC would be retained and 

would also be excluded from wind energy development. There would be no direct or indirect impacts to 

lands and realty other than BLM's ability to respond to wind development proposals. 

Withdrawals Enacted Using the Authority of ANCSA 17(d)(1) 

Alternative C would revoke all ANCSA 17(d)(1) withdrawals. 

A complete list of current withdrawals based on based available data can be found in Appendix M of the 

BSWI Draft RMP/EIS, Table 3.5.4-4. 

FLPMA Withdrawals 

FLPMA withdrawals under Alternative C would have the same impacts as under Alternative B. 

FLPMA ROW Exclusion & Avoidance Areas 

Under Alternative C, there would be no ROW exclusion areas. Subject to valid existing rights, there 

would be approximately 7,069,494 acres of FLPMA ROW avoidance areas and 576,038 acres of ROW 

avoidance for linear ROWs (South Connectivity Corridor). Map 2-41, of the BSWI Draft RMP/EIS, 

shows all FLPMA ROW avoidance areas under Alternative C. FLPMA ROW avoidance areas could limit 

the BLM’s ability to accommodate future ROW demand in these areas, which would be a long-term, 

indirect impact. Alternative C would result in fewer limitations to future ROW demand than 

Alternative B. 

Permits and Leases 

Under Alternative C, the distance between occupancy leases such as trapping cabins would be determined 

on a case-by-case basis based on documented conflict. Granting of permits and leases in CSUs would be 

determined on a case-by-case basis based on the compatibility of the permits and leases with management 

goals of these areas and the requirements of ANILCA. 

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Disposals and Exchanges 

Under Alternative C, the same areas available for disposal under Alternative D would be available for 

exchange, except that parcels in ACECs and the South Connectivity Corridor and watersheds with 

important fish or cultural values. Under Alternative C, approximately 356,942 acres would be available 

for exchange but not for disposal. These acres are estimated based on GIS data. Appendix M of the BSWI 

Draft RMP/EIS lists lands considered for exchange or disposal. Details on these parcels and their legal 

descriptions are found in Appendix F. Any exchanged lands would have direct impacts on the land status 

of the planning area. 

Effects under Alternative D 

Under Alternative D, there would be 0 acres of proposed FLPMA withdrawals. All 13,461,531 acres of 

existing ANCSA 17(d)(1) withdrawals would be revoked. Map 2-39 of the BSWI Draft RMP/EIS shows 

the complete withdrawal status for Alternative D. 

There would be no specific management direction pertaining to wind development under Alternative D, 

and there would be no impact to lands and realty. 

Withdrawals Enacted Using the Authority of ANCSA 17(d)(1) 

Alternative D would revoke all ANCSA 17(d)(1) withdrawals, which would directly impact land status in 

the planning area. A complete list of current withdrawals based on best available data can be found in 

Appendix M of the BSWI Draft RMP/EIS. 

FLPMA Withdrawals 

FLPMA withdrawal for the 1,000-foot-wide buffer centered on the existing INHT treadway would not be 

pursued, and the area would remain NSO for locatable and leasable minerals and closed to salable mineral 

entry under Alternative D, which would not have any direct or indirect impacts to lands and realty. 

FLPMA ROW Exclusion and Avoidance Areas 

Under Alternative D, there would be no FLPMA ROW exclusion areas. Subject to valid existing rights, 

there would be approximately 5,130,927 acres of FLPMA ROW avoidance areas. Additionally, ROWs 

would be authorized on a case-by-case basis on approximately 100,644 acres within the planning area (in 

permafrost areas and the INHT NTMC). Map 2-42 of the BSWI Draft RMP/EIS shows all ROW 

avoidance areas under Alternative D. FLPMA ROW avoidance areas could limit the BLM’s ability to 

accommodate future ROW demand in these areas, which would be a long-term, indirect impact. In total, 

Alternative D would have approximately 8,234,323 acres open to ROW location within the planning area, 

approximately 2,413,961 acres more than Alternative C and approximately 5,024,620 acres more than 

Alternative B. 

Permits and Leases 

Under Alternative D, the distance between occupancy leases such as trapping cabins would be determined 

on a case-by-case basis at the implementation level. Granting of permits and leases in CSUs would be the 

same as under Alternative C. Permits and leases would be allowed in lands managed for wilderness 

characteristics. 

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Disposals and Exchanges 

The following categories of parcels in the planning area are available for exchanges or disposal: 

• Category 1 includes unselected land in BLM ownership adjacent to State or Native patented lands 

that are 1.5 townships (34,560 acres) or smaller that the BLM would consider for disposal. 

• Category 2 includes State or Native selected lands that are 1.5 townships (34,560 acres) or 

smaller that, if these selected lands remain in BLM ownership after the conveyance process, the 

BLM would consider for disposal. 

• Category 3 includes unselected lands in BLM ownership that are 1.5 townships (34,560 acres) or 

smaller that are adjacent to State or Native selected land that, if these selected lands are conveyed, 

the BLM would consider for disposal. 

Under Alternative D, approximately 451,173 acres would be available for exchanges or disposal. 

Alternative D differs from Alternative B and C in that lands are available for exchanges and disposals, 

whereas Alternative B and C identified lands only for exchange and not disposal, Table 3.5.4-3 in 

Appendix M of the BSWI Draft RMP/EIS lists lands considered for exchange or disposal. Details on 

these parcels and their legal descriptions are found in Appendix F of the BSWI Draft RMP/EIS. Any 

disposed lands would have long-term direct impacts on the land status of the planning area. 

Lands and Realty: Effects from Recreation and Visitor Services Management Actions 

In addition to management actions common to all action alternatives, potential impacts from the 

following management topic were considered: 

• INHT SRMA 

Effects under Alternative A 

There would continue to be no proposed activities that would restrict or promote lands and realty actions 

and therefore no effects from management of recreation and visitor services on lands and realty under 

Alternative A. 

Effects Common to All Action Alternatives 

Under all of the action alternatives, the INHT would be an SRMA. 

Effects under Alternative B 

Alternative B, the BLM would retain all lands within the INHT SRMA that are in BLM ownership, which 

may affect land status in the planning area. Under Alternative B, the INHT SRMA would be 

approximately 355,799 acres. 

Effects under Alternative C 

Under Alternative C, the BLM would retain all lands within the INHT SRMA that are in BLM ownership, 

which may affect land status in the planning area. Under Alternative C, the INHT SRMA would be 

approximately 340,574 acres. 

Effects under Alternative D 

Under Alternative D, effects would be the same as under Alternative C. 

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Lands and Realty: Effects from Travel and Transportation Management Actions 

In addition to management actions common to all action alternatives, potential impacts from the 

following management topics were considered: 

• Vegetation and Wildlife Travel Management 

• All BSWI Lands Not Designated as CSUs or Sensitive Resource Areas 

• Unalakleet Wild River Corridor Travel Management Decisions 

• INHT NTMC TMA 

• Rohn Site Travel Decisions 

• Lands Managed for Wilderness Characteristics TMA 

Effects under Alternative A 

Under Alternative A, there would be no lands in the planning area managed as designated TMAs. There 

would be no impacts to lands and realty under this alternative. 

Effects Common to All Action Alternatives 

Under all action alternatives, the majority of BLM-managed lands in the planning area would be 

designated as “Limited” to motorized travel. For overland travel by the public in limited designations, 

realty authorizations for travel over the limited designations may be necessary, which would require an 

authorization from the BLM and have a direct impact on the land and realty program. 

Effects under Alternative B 

Under Alternative B, if monitoring shows observable or quantifiable degradation of certain vegetation 

habitats due to OHV use, then appropriate management actions would be developed and implemented. 

The actions may include rerouting or closing unauthorized OHV trails to aid in restoring ecosystem 

health. This action could limit the BLM’s ability to accommodate future ROW demand in these areas, 

which would be a long-term, indirect impact. 

Under Alternative B, the BLM would develop travel management plans identifying travel routes and 

corridors between communities. There would be two TMAs: INHT NTMC TMA and Lands Managed for 

Wilderness Characteristics TMA. As a result of the travel management plans, there could be access 

provided via ROWs or easements for travel corridors. This management action would have a direct 

impact on land status in the planning area. There could also be areas of ROW restriction, limiting the 

BLM’s ability to accommodate future ROW demands in certain areas, which would be an indirect impact. 

Effects under Alternative C 

Impacts under Alternative C would be the same as under Alternative B, except the Lands Managed for 

Wilderness Characteristics TMA is not included in Alternative C. 

Effects under Alternative D 

Under Alternative D, there would be no limitations on OHV use and no limitations or restrictions on 

overland travel or casual use. There would be no impacts to lands and realty from travel management 

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Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

actions under Alternative D in lands not managed as TMAs or CSUs. Under Alternative D, impacts from 

travel management plans would be the same as identified under Alternative C. 

Lands and Realty: Effects from Areas of Critical Environmental Concern Management 

Actions 

Potential impacts from the following management topics were considered: 

• Lands and Realty Decisions 

• Minerals Decisions 

• Transportation and Travel Management Decisions 

• VRM Decisions 

Effects under Alternative A 

Alternative A would continue the current ACEC designations on BLM lands; there would be no changes 

to current ACECs or the addition of new ACECs. Therefore, there would be no changes to land status 

under Alternative A. The existing ACECs are listed below in Table 3.6.4-1. 

Table 3.6.4-1: Alternative A ACECs Affecting Lands and Realty 

ACEC Acres Lands and Realty Decisions 

Anvik River ACEC 114,386 The existing Anvik River ACEC occurs within lands withdrawn by PLO 5180. Portions of 

the ACEC not covered by this PLO are open to public land laws. PLO 5180 withdrew 

lands (subject to valid existing rights) from all forms of appropriation under the public 

land laws, including selections by the State of Alaska under the Alaska Statehood Act, 

from location and entry under existing mining laws (except locations for metalliferous 

minerals), and from leasing under the Mineral Leasing Act. The lands were reserved for 

study to determine the proper classification of the lands under ANILCA 17(d)(1). 

The lands are currently managed under the 1981 SWMFP and are open on a case-bycase basis to leases, permits, ROWs, and easements (BLM 1981a). 

Gisasa River ACEC 278,055 This ACEC occurs within lands withdrawn by PLO 5173 and PLO 5180, which withdraw 

lands from all forms of appropriation and from location, entry, and leasing of minerals. 

Prior to conveyances of selected lands, the Secretary of the Interior could administer the 

lands and make contracts, as well as grant leases, permits, ROWs, or easements. 

The lands are currently managed under the CYRMP (BLM 1986a) and are open on a 

case-by-case basis to permits, leases, ROWs, and easements, except for an identified 

300-foot NSO setback zone on the Gisasa River. 

Inglutalik ACEC 71,713 This ACEC occurs within lands withdrawn by PLO 5180, which withdrew lands from all 

forms of appropriation and from location, entry, and leasing of minerals. 

The lands are currently managed under the CYRMP (BLM 1986a) and are open on a 

case-by-case basis to permits, leases, ROWs, and easements. 

Kateel River ACEC 568,083 This ACEC occurs within lands withdrawn by PLO 5173, PLO 5179, PLO 5180, and 

PLO 5184, which withdraw lands from all forms of appropriation and from location, entry, 

and leasing of minerals. Prior to conveyances of selected lands, the Secretary of the 

Interior could administer the lands and make contracts, as well as grant leases, permits, 

ROWs, or easements. 

The lands are currently managed under the CYRMP (BLM 1986a) and are open on a 

case-by-case basis to permits, leases, ROWs, and easements, although FLPMA sales 

and leases are not allowed within a 300-foot setback zone on the Kateel River. 

Shaktoolik River ACEC 192,591 This ACEC occurs within lands withdrawn by PLO 5180, which withdrew lands from all 

forms of appropriation and from location, entry, and leasing of minerals. 

The lands are currently managed under the CYRMP (BLM 1986a) and are open on a 

case-by-case basis to permits, leases, ROWs, and easements. 

Ungalik River ACEC 112,719 ACEC occurs within lands withdrawn by PLO 5180, which withdraws lands from all 

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ACEC Acres Lands and Realty Decisions 

forms of appropriation and from location, entry, and leasing of minerals. 

The lands are currently managed under the CYRMP (BLM 1986a) and are open on a 

case-by-case basis to permits, leases, ROWs, and easements although FLPMA sales. 

Leases are not allowed within a 300-foot setback zone on the Kateel River. 

North River ACEC 132,200 The existing Drainages of the North River ACEC occur within lands withdrawn by PLO 

5180. PLO 5180 withdrew lands identified by legal description (subject to valid existing 

rights) from all forms of appropriation under the public land laws, including selections by 

the State of Alaska under the Alaska Statehood Act and from location and entry under 

the mining laws (except locations for metalliferous minerals) and from leasing under the 

Mineral Leasing Act. The lands were reserved for study to determine the proper 

classification of the lands under ANCSA section 17(d)(1). 

The lands are currently managed under the 1981 SWMFP and the 1986 CYRMP and 

are open on a case-by-case basis to permits, leases, ROWs, and easements, although 

FLPMA sales and leases are not allowed within a 300-foot North River corridor setback 

identified in the CYRMP. 

Drainages of the 403,378 The existing Drainages of the Unalakleet River ACEC occur within lands withdrawn by 

Unalakleet PLO 5180, PLO 5179, and PLO 5173. PLO 5180 withdrew lands identified by legal 

description (subject to valid existing rights) from all forms of appropriation under the 

public land laws, including selections by the State of Alaska under the Alaska Statehood 

Act and from location and entry under the mining laws (except locations for metalliferous 

minerals) and from leasing under the Mineral Leasing Act. The lands were reserved for 

study to determine the proper classification of the lands under ANCSA section 17(d)(1). 

PLO 5179 withdrew identified lands by legal description (subject to valid existing rights) 

from all forms of appropriation under the public land laws including selections by the 

State of Alaska under the Alaska Statehood Act and from location and entry under the 

mining laws (which includes locations for metalliferous minerals) and from leasing under 

the Mineral Leasing Act. PLO 5179 also withdrew the lands from selections by regional 

corporations under section 12 of ANCSA. The lands were reserved for study and 

possible recommendations to the Congress as additions or creation as a unit of the 

National Park, Forest, NWR, and National System. 

PLO 5173 withdrew lands identified by legal description (subject to valid existing rights) 

from all forms of appropriation under the public land laws, including selections by the 

State of Alaska under the Alaska Statehood Act and from location and entry under the 

mining laws and from leasing under the Mineral Leasing Act. The lands were reserved 

for selection by village corporations. Upon conclusion of village selections, the regional 

corporations could select the lands under Section 12 of ANCSA. Prior to conveyances, 

the Secretary of the Interior could administer the lands and make contracts, as well as 

grant leases, permits, ROWs, or easements. Applications for mineral leasing would be 

rejected until the PLO is modified or the lands appropriately classified to permit mineral 

leasing. 

Portions of this ACEC are not covered by the above withdrawals. Areas not covered by 

withdrawals are open to the full spectrum of the public land laws including mining and 

leasing. 

The lands are currently managed under the 1981 SWMFP, the 1986 CYRMP and the 

1983 Unalakleet River Management Plan and are open on a case-by-case basis to 

permits, leases, ROWs, and easements although FLPMA sales and leases are not 

allowed within that portion of the CYRMP in the Unalakleet Wild River Corridor and 300-

foot setback zones on the North Fork of the Unalakleet. 

Box River Treeline RNA 13,592 The existing Box River Treeline RNA occurs within lands withdrawn by PLO 5180. PLO 

5180 withdrew lands identified by legal description (subject to valid existing rights) from 

all forms of appropriation under the public land laws, including selections by the State of 

Alaska under the Alaska Statehood Act and from location and entry under the mining 

laws (except locations for metalliferous minerals) and from leasing under the Mineral 

Leasing Act. The lands were reserved for study to determine the proper classification of 

the lands under ANCSA section 17(d)(1). 

The lands are currently managed under the 1986 CYRMP and are open on a case-bycase basis to permits, leases, ROWs, and easements. 

Peregrine Falcon 

Nesting Habitat ACEC 

6,354 The existing Peregrine Falcon Nesting Habitat ACEC occurs within lands withdrawn by 

PLO 5184 and PLO 5179. A small portion of the ACEC is not covered by a PLO, and 

the lands are open to the public land laws. PLO 5184 withdrew lands (subject to valid 

existing rights) withdrawn by section 11 of the A from all forms of appropriation under 

the public land laws and from location and entry under the mining laws (which includes 

locations for metalliferous minerals) and from leasing under the Mineral Leasing Act. 

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Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

ACEC Acres Lands and Realty Decisions 

PLO 5184 also withdrew these lands from selections by the State of Alaska under the 

Alaska Statehood Act until 1975. PLO 5184 also allowed the Secretary of the Interior to 

administer the lands under applicable laws and regulations and granted the authority to 

enter contracts, as well as grant leases, permits, ROWs, or easements. 

PLO 5179 withdrew identified lands by legal description (subject to valid existing rights) 

from all forms of appropriation under the public land laws including selections by the 

State of Alaska under the Alaska Statehood Act and from location and entry under the 

mining laws (which includes locations for metalliferous minerals) and from leasing under 

the Mineral Leasing Act. PLO 5179 also withdrew the lands from selections by regional 

corporations under section 12 of ANCSA. The lands were reserved for study and 

possible recommendations to the Congress as additions or creation as a unit of the 

National Park, Forest, NWR, and National System. 

The lands are currently managed under the 1981 SWMFP and are open on a case-bycase basis to leases, permits, ROWs, and easements. 

Kuskokwim River 

Raptor Nesting Habitat 

ACEC 

4,896 The existing Kuskokwim River Raptor Nesting Habitat ACEC occurs within lands 

withdrawn by PLO 5184. PLO 5184 withdrew lands (subject to valid existing rights) 

withdrawn by section 11 of the ANCSA from all forms of appropriation under the public 

land laws and from location and entry under the mining laws (which includes locations 

for metalliferous minerals) and from leasing under the Mineral Leasing Act. PLO 5184 

also withdrew the lands from selections by the State of Alaska under the Alaska 

Statehood Act until 1975. The lands were reserved for study and review by the 

Secretary of the Interior for the purpose of the classification or reclassification of any 

lands not conveyed pursuant to ANCSA section 14. PLO 5184 also withdrew lands by 

section 11 of ANCSA lying between 58 degrees north and 64 degrees north latitude and 

161 degrees west longitude not withdrawn as any part of the NWR, subject to valid 

existing rights from all forms of appropriation under the public land laws, including 

selections by the State of Alaska under the Statehood Act and entry under the mining 

laws and from leasing under the Mineral Leasing Act. The lands were reserved for study 

and review by the Secretary of the Interior for the purpose of the classification or 

reclassification of any lands not conveyed pursuant to section 14 of the ANCSA. PLO 

5184 also allowed the Secretary of the Interior to administer the lands under applicable 

laws and regulations and granted the authority to enter contracts, as well as grant 

leases, permits, ROWs, or easements. 

The lands are currently managed under the 1981 SWMFP and are open on a case-bycase basis to leases, permits, ROWs, and easements. 

Total 1,884,376 

There are seven areas that are nominated for an ACEC under Alternatives B. The management of those 

areas under Alternative A would not change. These include the following: 

• The Anvik Traditional Trapping Area ACEC (nominated 21,366 acres). Lands are currently 

managed under the SWMFRP (BLM 1981a) and are open on a case-by-case basis to leases, 

permits, ROWs, and easements. Some parts occur within lands withdrawn by PLO 5184, which 

withdrew lands from all forms of appropriation and from location, entry, and leasing of minerals. 

Prior to conveyances of selected lands, the Secretary of the Interior could administer the lands 

and make contracts, as well as grant leases, permits, ROWs, or easements. 

• Anvik River Watershed ACEC (nominated 248,872 acres). Lands are currently managed under 

the SWMFRP and are open on a case-by-case basis to leases, permits, ROWs, and easements. 

Some parts occur within lands withdrawn by PLO 5180, which withdrew lands from all forms of 

appropriation under public laws and from location and entry under the mining laws. The lands 

were reserved for study to determine classification under Section 17(d)(1) of ANCSA. 

• Nulato River ACEC (nominated 344,183 acres). Lands are currently managed under the CYRMP 

(BLM 1986a) and are open on a case-by-case basis to permits, leases, ROWs, and easements. 

Some parts occur within lands withdrawn by PLO 5173, PLO 5180, and PLO 5184, which 

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Appendix N: Supplemental Impact Analysis Information Section 3: Supplemental Impact Analysis 

withdraw lands from all forms of appropriation and from location, entry, and leasing of minerals. 

Prior to conveyances of selected lands, the Secretary could administer the lands and make 

contracts, as well as grant leases, permits, ROWs, or easements. 

• Sheefish ACEC (nominated 696,902). Lands are currently managed under the SWMFP (BLM 

1981a) and are open on a case-by-case basis to permits, leases, ROWs, and easements. Some 

parts occur within lands withdrawn by PLO 5180, which withdrew lands from all forms of 

appropriation and from location, entry, and leasing of minerals. 

• Swift River Whitefish Spawning ACEC (nominated 220,032 acres). Lands are currently managed 

under the SWMFP (BLM 1981a) and are open on a case-by-case basis to leases, permits, ROWs, 

and easements. Some parts occur within lands withdrawn by PLO 5180 and PLO 5184, which 

withdraw lands from all forms of appropriation and from location, entry, and leasing of minerals. 

Prior to conveyances of selected lands, the Secretary could administer the lands and make 

contracts, as well as grant leases, permits, ROWs, or easements. 

• Tagawik River ACEC (nominated 301,044 acres). Lands are currently managed under the 

CYRMP (BLM 1986a) and are open on a case-by-case basis to permits, leases, ROWs, and 

easements. Some parts occur within lands withdrawn by PLO 5180, which withdrew lands from 

all forms of appropriation and from location, entry, and leasing of minerals. 

• Unalakleet River Watershed ACEC (nominated 733,995). Lands are currently managed under the 

SWMFP (BLM 1981a) and the CYRMP (BLM 1986a) and are open on a case-by-case basis to 

permits, leases, ROWs, and easements. Some parts occur on lands withdrawn by PLO 5180 and 

5184, which withdraw lands from all forms of appropriation and from location, entry, and leasing 

of minerals. Prior to conveyances of selected lands, the Secretary could administer the lands and 

make contracts, as well as grant leases, permits, ROWs, or easements. 

Effects under Alternative B 

Alternative B would include all the ACECs in Alternative A except for the North River ACEC, the 

Drainages of the Unalakleet ACEC, the Box River Treeline RNA, the Peregrine Falcon Nesting Habitat 

ACEC, and the Kuskokwim River Raptor Nesting Habitat. However, substantial acres within the existing 

Anvik River ACEC, North River ACEC, and Drainages of the Unalakleet ACEC are included in proposed 

ACECs under Alternative B and would be managed according to those management decisions (Table 

3.6.4-2). The Box River Treeline RNA, Peregrine Falcon Nesting Habitat ACEC, and the Kuskokwim 

River Raptor Nesting Habitat ACEC were not found to meet Relevance and Importance criteria in an 

analysis performed in 2016 (BLM 2018). Alternative B would also increase the acreage of some of the 

existing ACECs and, in some cases, include management decisions that would affect lands and realty. 

Table 3.6.4-2 summarizes all of the ACECs that would remain or be proposed under Alternatives B. 

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Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

Table 3.6.4-2: Alternative B ACECs Affecting Lands and Realty 

ACEC 

Alternative B 

Proposed Acres 

Existing

Acres Additional Lands and Realty Decisions under Alternative B 

Anvik Traditional 

Trapping Area ACEC 

21,366 N/A ROW avoidance area. 

Closed to salable minerals, would be closed to leasable minerals, 

and would be withdrawn from locatable mineral entry. 

Limits and/or restrictions on subsistence travel and casual use 

travel. 

Anvik River Watershed 

ACEC 

248,872 115,106 ROW avoidance area. 

Closed to salable minerals, would be closed to leasable minerals, 

and would be withdrawn from locatable mineral entry. 

Limits and/or restrictions on subsistence travel and casual use 

travel. 

Visual resources: Managed as VRM Class III. 

Includes 100,948 acres of the existing Anvik River ACEC. 

Gisasa River ACEC 278,247 278,057 ROW avoidance area. 

Closed to salable minerals, would be closed to leasable minerals, 

and would be withdrawn from locatable mineral entry. 

Limits and/or restrictions on subsistence travel and casual use 

travel. 

Visual resources: Managed as VRM Class III. 

Inglutalik ACEC 70,891 71,716 ROW avoidance area. 

Closed to salable minerals, would be closed to leasable minerals, 

and would be withdrawn from locatable mineral entry. 

Limits and/or restrictions on subsistence travel and casual use 

travel. 

Visual resources: Managed as VRM Class III. 

Kateel River ACEC 692,659 568,083 ROW avoidance area. 

Closed to salable minerals, would be closed to leasable minerals, 

and would be withdrawn from locatable mineral entry. 

Limits and/or restrictions on subsistence travel and casual use 

travel. 

Visual resources: Managed as VRM Class III. 

Nulato River ACEC 344,183 N/A ROW avoidance area within the ACEC upstream of the Village of 

Nulato. 

Closed to salable minerals, would be closed to leasable minerals, 

and would be withdrawn from locatable mineral entry. 

Limits and/or restrictions on subsistence travel and casual use 

travel. 

Visual resources: Managed as VRM Class III. 

Includes portions of the existing North River ACEC (649 acres) and 

Drainages of the Unalakleet ACEC (868 acres). 

Shaktoolik River ACEC 191,725 192,591 ROW avoidance area. 

Closed to salable minerals, would be closed to leasable minerals, 

and would be withdrawn from locatable mineral entry. 

Limits and/or restrictions on subsistence travel and casual use 

travel. 

Visual resources: Managed as VRM Class III. 

Includes 1,621 acres of the existing North River ACEC. 

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ACEC 

Alternative B 

Proposed Acres 

Existing

Acres Additional Lands and Realty Decisions under Alternative B 

Sheefish ACEC 696,902 N/A ROW avoidance area. 

Coordinate with the State of Alaska on potential land exchanges to 

obtain all HUC 6 watershed acreage along the Big River and 

Middle Fork of the Kuskokwim. 

Closed to salable minerals, would be closed to leasable minerals, 

and would be withdrawn from locatable mineral entry. 

Withdrawal from mineral entry portion of the Big River and the 

Middle Fork Kuskokwim River to include the river bed and a 1,000-

foot buffer on each side of bank full width. 

Total withdrawal would be 4,996 acres. 

Limits and/or restrictions on subsistence travel and casual use 

travel. 

Visual resources: Managed as VRM Class II. 

Swift River Whitefish 

Spawning ACEC 

220,032 N/A ROW avoidance area. 

Closed to salable minerals, would be closed to leasable minerals, 

and would be withdrawn from locatable mineral entry. 

Limits and/or restrictions on subsistence travel and casual use 

travel. 

Visual resources: Managed as VRM Class III. 

Tagagawik River ACEC 301,044 N/A ROW avoidance area. 

Closed to salable minerals, would be closed to leasable minerals, 

and would be withdrawn from locatable mineral entry. 

Limits and/or restrictions on subsistence travel and casual use 

travel. 

Visual resources: Managed as VRM Class II. 

Unalakleet River 

Watershed ACEC 

733,995 552,534 1 ROW avoidance area. 

Prioritize cooperation with the State of Alaska and Native Village of 

Unalakleet to develop coordinated strategy for management of the 

Unalakleet River corridor within the ACEC. 

Closed to salable minerals, would be closed to leasable minerals, 

and would be withdrawn from locatable mineral entry. 

Limits and/or restrictions on subsistence travel and casual use 

travel. 

Visual resources: Managed as VRM Class II. 

Includes portions of the existing North River ACEC (65,635 acres) 

and Drainages of the Unalakleet ACEC (299,968 acres). 

Ungalik River ACEC 113,455 112,719 ROW avoidance area. 

Closed to salable minerals, would be closed to leasable minerals, 

and would be withdrawn from locatable mineral entry. 

Limits and/or restrictions on subsistence travel and casual use 

travel. 

Visual resources: Managed as VRM Class III. 

Total 3,912,698 1,338,272 

1. The Unalakleet River Watershed ACEC is nominated under Alternative A, but not designated. 

All proposed ACECs under Alternative B would be managed as ROW avoidance areas, which would 

limit the BLM’s ability to accommodate future leasable development in these areas and limit BLM's 

ability to accommodate land use authorizations. 

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Any locations within the planning area proposed for withdrawal from locatable mineral entry would also 

be NSO for oil and gas. These restrictions would limit the BLM’s ability to accommodate future oil and 

gas development in these areas. 

Objectives for VRM Class II would have a greater likelihood of limiting the location and/or applying 

mitigation measures to ROWs and other land use authorizations. Fewer restrictions would be likely in 

VRM Class III. 

Effects under Alternative C 

Under Alternative C, the proposed ACEC restrictions on land and realty authorizations would be 

removed, thereby increasing BLM's ability to address land and realty demands from the public and reduce 

the economic burden of these proposals to meet ACEC limits on realty authorizations. Alternative C 

impacts are therefore the same as Alternative D with respect to ACEC management actions. 

Effects under Alternative D 

Under Alternative D, there would be no ACECs. The proposed ACEC restrictions on land and realty 

authorizations would be removed thereby increasing BLM's ability to address land and realty demands 

from the public and reduce the economic burden of these proposals to meet ACEC limits on realty 

authorizations. 

Lands and Realty: Effects from National Trails Management Actions 

In addition to management actions common to all action alternatives, potential impacts from the 

following management topics were considered: 

• INHT NTMC 

• Mineral Decisions in the INHT NTMC 

Effects under Alternative A 

Under Alternative A, the INHT would be managed to maintain the integrity of the INHT and associated 

historic and cultural sites in compliance with the National Trails System Act (1968) and the INHT 

Comprehensive Management Plan (BLM 1981b). 

Effects Common to All Action Alternatives 

Under all of the action alternatives, the BLM would establish an NTMC for the INHT within the planning 

area. The establishment of an NTMC could limit the BLM’s ability to accommodate future ROW demand 

in certain areas, which would be an indirect impact. The geographic areas comprising the INHT NTMC 

would consist of three geographically distinct areas: 

• Farewell Burn – located south of Nikolai 

• Kaltag Portage – located between Unalakleet and Kaltag 

• Rohn – located southeast of Nikolai 

Within the planning area, the BLM holds a National Trail System Act reservation for some INHT 

segments on blocks of land conveyed to the State of Alaska. These segments of trail would not be 

managed as part of the NTMC and would not be subject to the prescriptions described in this section. 

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Appendix N: Supplemental Impact Analysis Information Section 3: Supplemental Impact Analysis 

Similarly, these segments would not be managed as TMAs and/or for surface travel management, nor 

would they be managed as an SRMA. If the INHT is located within any lands where a withdrawal is 

revoked and if the State of Alaska or an ANCSA corporation desires conveyance of the parcels, at the 

time of any future conveyance, a reservation would be made for the INHT under the National Trails 

System Act. This would be a long-term, direct impact to the land status of the planning area. 

The INHT would be designated as a TMA for route designation during a travel management planning 

process as described above in the section “Lands and Realty: Effects from Travel and Transportation 

Management Actions.” Additionally, if casual or subsistence OHV use results in degradation of the 

resources or prevents effective trail maintenance, then this would be prohibited in affected areas. This 

restriction could limit the BLM’s ability to accommodate future ROW demand in these areas, which 

would be an indirect impact. 

There would be no coal leases issued within the National System of Trails. 

Effects under Alternative B 

Under Alternative B, the acres of the geographic areas comprising the INHT NTMC would be as follows: 

• Farewell Burn: 46,591 acres 

• Kaltag Portage: 241,512 acres 

• Rohn: 363 acres 

The INHT NTMC would be withdrawn and closed to mineral entry and for leasable and salable mineral 

development. Because there are no medium or high LMP areas within the INHT NTMC, this is not 

expected to have a noticeable impact on the BLM’s ability to accommodate leasable development in the 

planning area. 

To manage the INHT NTMC, FLPMA reservations issued to BLM for a 1,000-foot-wide corridor 

centered on the existing INHT centerline would be established as described above in the section “Lands 

and Realty: Effects from Travel and Transportation Management Actions.” 

Effects under Alternative C 

Under Alternative C, the acreage of the geographic areas comprising the INHT NTMC would be the same 

as in Alternative B, except for the Farewell Burn, which would be 31,367 acres. 

The INHT TNMC would be open for locatable mineral exploration and development, NSO for leasable 

development, and open for salable mineral development. There could be impacts to lands and realty from 

new leases and sales. 

To manage the INHT NTMC, FLPMA reservations issued to BLM for a 1,000-foot-wide corridor 

centered on the existing INHT centerline would be established as described above as described above in 

the section “Lands and Realty: Effects from Travel and Transportation Management Actions.” 

Effects under Alternative D 

The acreage of the geographic areas comprising the INHT NTMC under Alternative D would be the same 

as under Alternative C. 

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Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

The INHT TNMC would be open for locatable mineral exploration and development, open with standard 

stipulations for oil and gas leasing, and open for salable mineral development. There could be impacts to 

lands and realty from new leases and sales. 

Lands and Realty: Effects from Wild and Scenic Rivers Management Actions 

In addition to management actions common to all action alternatives, potential impacts from the 

following management topic were considered: 

• Proposed WSRs 

Effects under Alternative A 

Alternative A would continue the current management of the 46,953-acre Unalakleet Wild River Corridor 

and an additional 18 river segments (331,120 acres) have been identified as eligible. The 18 eligible river 

segments would continue to be managed for free-flowing condition, water quality, tentative classification, 

and ORVs per BLM Manual 6400 (BLM 2012). However, BLM Manual 6400 does not include any 

guidelines for withdrawals that would be applicable to the 18 eligible river segments. Therefore, there 

would be no effects to lands and realty from WSR management under Alternative A. 

Effects Common to All Action Alternatives 

Under all the action alternatives, the BLM would seek to acquire any Native allotments available from 

willing sellers within the designated wild river corridors. This action would directly impact the land status 

of the planning area. 

The BLM would also maintain the withdrawal from mineral entry within the WSR corridors, subject to 

valid existing rights. This action could indirectly impact the BLM’s ability to accommodate leasable 

development in the planning area. 

Effects under Alternative B 

Under Alternative B, 18 additional river corridors totaling approximately 331,120 acres are recommended 

as suitable for WSR designation. There would be no specific management actions related to lands and 

realty for the 18 river corridors recommended as suitable. The Unalakleet Wild River Corridor would be 

maintained. 

Effects under Alternative C 

Effects from WSR management would be the same as Alternative A. 

Effects under Alternative D 

Effects from WSR management would be the same as Alternative A. 

Lands and Realty: Effects from Support for BSWI Communities Management Actions 

In addition to management actions common to all action alternatives, potential impacts from the 

following management topic were considered: 

• Communications Sites ROW 

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Appendix N: Supplemental Impact Analysis Information Section 3: Supplemental Impact Analysis 

Effects under Alternative A 

Under Alternative A, communication sites are determined on a case-by-case basis. This action could have 

an indirect impact on land status in the planning area if there are additional utility ROW and leases 

required. 

Effects Common to All Action Alternatives 

Under all action alternatives, lands would be made available for lease or sale to benefit local communities 

under the R&PP Act. The determination to put land up for sale or lease would include objectives like 

expansion of communities and economic development as criteria for land disposal. The BLM would also 

consider providing opportunities for community relocation through the use of ROW grants, permitting, 

exchanges, R&PP lease or sale, leases, or other appropriate permitting actions as determined mutually 

beneficial for the community and the long-term sustainability of BLM-managed public lands. This action 

could have a long-term, direct impact on land status in the planning area. 

Additionally, the BLM would develop travel management plans identifying travel routes and corridors 

between communities. Actions would include designation of winter trails system and identification of 

other safety cabin locations on BLM lands that support inter-village travel, and winter trail system 

signage. New trails and travel corridors could have an indirect impact on lands and realty if new ROWs 

are established, impacting lands and realty in the planning area. 

Effects under Alternative B 

Alternative B would allow expanded use of existing microwave towers that would increase safety along 

inter-village travel routes with appropriate stipulations to ensure minimal environmental changes to 

existing sites. This action could have an indirect impact on lands and realty in the planning area if there 

are additional utility ROW and leases required. 

Effects under Alternative C 

Under Alternative C, communications sites would be allowed at strategic locations along inter-village 

winter travel route corridors to improve communication and safety. Locations would be determined on a 

case-by-case basis with appropriate required operating procedures and stipulations. This action could 

have an indirect impact on lands and realty in the planning area if there are additional utility ROW and 

leases required. No management actions were prescribed for existing communications towers under 

Alternative C. 

Effects under Alternative D 

Under Alternative D, communications sites would be identified on a case-by-case basis. The BLM would 

support development of cell phone towers and other communication infrastructure on BLM-managed 

lands in the planning area that would improve communication and internet connection for rural 

communities. This action could have an indirect impact on lands and realty in the planning area if there 

are additional utility ROW and leases required. No management actions were prescribed for existing 

communications towers under Alternative D. 

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Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

Lands and Realty: Effects from Climate Change 

This section presents the analysis of how management actions would counteract cumulative climate 

change impacts to lands and realty. Many of the impacts to lands and realty caused by climate change are 

reflected in the analysis of other resource sections due to the correlation between these resources and the 

indicators of lands and realty impacts. 

Effects under Alternative A 

There would be no impacts from climate change to lands and realty under this alternative. 

Effects Common to All Action Alternatives 

The BLM would consider providing opportunities for community relocation as a result of changing 

coastline from thawing permafrost, higher storm surge, or other effects of climate change. Opportunities 

would be through the use of ROW grants, permitting, exchanges, R&PP, leases, or other appropriate 

permitting actions as determined mutually beneficial for the community and the long-term sustainability 

of BLM-managed public lands in the planning area. This action could have a direct impact on land status 

in the planning area. There are alternative-specific effects that would counteract climate change impacts. 

Lands and Realty: Cumulative Effects 

Cumulative impacts on lands and realty are the result of past, present, and reasonably foreseeable future 

actions within and next to the planning area that increase or decrease demand for land tenure actions and 

land use authorizations. Table 3.6.4-3 summarizes the results of the cumulative effects analysis for lands 

and realty for all alternatives. 

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Appendix N: Supplemental Impact Analysis Information Section 3: Supplemental Impact Analysis 

Table 3.6.4-3: Cumulative Effects Analysis for Lands and Realty 

Trends and Forecasts 

of Lands and Realty in 

Consideration of Past 

and Present Actions 

Trends and Forecasts of Lands and Realty in Consideration of 

Past, Present, and Reasonably Foreseeable Future Actions 

(Alternative A) 

Trends and Forecasts 

of Lands and Realty in 

Consideration of Past, 

Present, and 

Reasonably

Foreseeable Future 

Actions 

(Alternative B) 

Trends and Forecasts 

of Lands and Realty in 

Consideration of Past, 

Present, and 

Reasonably

Foreseeable Future 

Actions 

(Alternative C) 

Trends and Forecasts 

of Lands and Realty

in Consideration of 

Past, Present, and 

Reasonably

Foreseeable Future 

Actions 

(Alternative D) 

Land status changes Conveyance of lands to the State and Native corporations is ongoing Alternative B would be Alternative C would be Alternative D would be 

slowly as lands that are and will continue until the process is complete. On a statewide basis, the same as Alternative the same as Alternative the same as Alternative 

selected by the State or about 98 percent of Native conveyances and 95 percent of State A regarding the status of A regarding the status of A regarding the status 

ANCSA corporations conveyances have been completed. Under Alternative A, this process land conveyance, other land conveyance, other of land conveyance, 

are conveyed out of would likely continue at the current rate. Additionally, the BLM and land status changes, land status changes, other land status 

BLM management and other landowners have, since conveyance began, exchanged, and overall land use; and overall land use; changes, and overall 

to the ownership of the withdrew, disposed of, and acquired land outside of the conveyance past, present, and past, present, and land use; past, present, 

selector. process. Reasonably foreseeable future actions are not anticipated to reasonably foreseeable reasonably foreseeable and reasonably 

influence the rate of land status changes within and next to the future actions would not future actions would not foreseeable future 

planning area. influence the rate of land influence the rate of land actions would not 

The development potential for leasable mineral resources, such as 

coal, coal bed natural gas, oil and gas, geothermal, peat, and coalbed 

natural gas in the planning area is low; however, these activities 

directly impact lands and realty through leases and mining claims. 

Past and present land uses, such as resource exploration and 

extraction, management of the INHT, community infrastructure, 

military activities, research and monitoring, recreation, and 

subsistence activities can all impact lands and realty if such actions 

include ROW establishment, lease sales, and transportation corridors. 

This RMP/EIS does not cover lands not administered by the BLM, 

including State, ANCSA Native corporation, other federal agencies, 

status changes within 

and next to the planning 

area. Therefore, 

Alternative B, in 

consideration of past, 

present, and reasonably 

foreseeable future 

actions, would continue 

the existing trend of land 

use. 

status changes within 

and next to the planning 

area. Alternative C, in 

consideration of past, 

present, and reasonably 

foreseeable future 

actions, would continue 

the existing trend of land 

use. 

influence the rate of 

land status changes 

within and next to the 

planning area. 

Alternative D, in 

consideration of past, 

present, and 

reasonably foreseeable 

future actions, would 

continue the existing 

trend of land use. 

private lands, and Native allotments. However, land use for all lands 

within the planning area can influence the current condition of the 

resources in the planning area. Impacts from such actions include 

ROW establishment, lease sales, and surface occupancy. Such 

impacts indirectly affect lands and realty in the planning area. 

Potential transportation corridors under review by the State include 

two road and ROW corridors, both of which would cross BLMmanaged land in the planning area. These activities would directly 

impact lands and realty in the planning area Reasonably foreseeable 

future actions are not anticipated to influence the rate of land use 

changes within the planning area. 

Therefore, Alternative A in consideration of past, present, and 

reasonably foreseeable future actions would continue the existing 

trend of land use. 

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Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

3.7 Areas of Critical Environmental Concern 

3.7.1 Summary 

This section describes the potential impacts from management actions on ACEC designations and their 

relevant and important values (R&Is) within the planning area. 

Alternative A includes the 11 existing ACECs in the planning area. In a 2016 evaluation, three of these 

(the Peregrine Falcon and Kuskokwim River Raptor Nesting Habitat ACECs and the Box River Treeline 

RNA ACEC) were found to no longer support “Importance” of their nominating values. Management 

actions differ among the existing ACECs and are currently enacted via regional land management plans 

and PLO withdrawals. Current protection of resource values is generally less strong than it would be 

under Alternative B. The exception to this is that the two, small nesting habitat ACECs would become 

undesignated under all action alternatives and would have no special management directives. The existing 

Anvik River, Box River Treeline RNA, Drainages of the Unalakleet, and North River ACECs are not 

included in any of the action alternatives, but most of their existing acreages are included in newly 

nominated ACECs under Alternative B; these are described in the relevant sections below. 

Alternative B would be most protective because it designates 5 existing and 7 newly nominated ACECs 

and includes management actions to minimize surface disturbance and other activities that could 

adversely affect fish and cultural resources in the ACECs. One exception is that Alternative B provides a 

lower prioritization of the creation of Cultural Landscape Reports (which include cultural, fish, and 

wildlife resources) compared to Alternatives C or D. A higher prioritization would provide qualitative 

beneficial effects to the understanding and documentation of cultural and fish resources in the ACECs. 

Alternative C would not designate ACECs, but some of the same management actions to protect fisheries 

and cultural values would be enacted in about 78 percent (3,044,746 acres) of Alternative B’s ACEC 

acreage through other management actions. 

No ACECs would be designated under Alternative D. This alternative would have more adverse impacts 

to cultural and fish resources from surface disturbance or visual impacts than the other alternatives. 

However, the creation of Cultural Landscape Reports would be prioritized most in this alternative, which 

would provide a qualitative beneficial impact to cultural and fish ACEC values by increasing 

understanding and documentation of cultural resource use. In some of the areas not designated as ACECs 

under Alternative D, VRM management actions from non-ACEC considerations would be more 

protective than under Alternative A. These include the designated Unalakleet Wild River Corridor, and 

the INHT and visual buffer of the INHT. 

3.7.2 Methods of Analysis 

For the purposes of this analysis, existing and nominated ACECs being considered for designation in this 

RMP are referred to as “potential ACECs.” The number of ACECs that would be designated under each 

alternative and their sizes differ, as do some of management actions for the designated ACECs. To 

account for this, the “designated” ACEC acreage rows of the summary table below include the size of the 

ACECs that would be designated in that alternative. The “undesignated” acreage rows show the size of 

the area affected by a management action that would be an ACEC under one of the other alternatives. 

These values do not include BLM-managed land not considered for ACEC designation. 

The analysis area used to analyze impacts on potential ACECs is BLM-managed land within the planning 

area. Impacts identified for ACECs are based on management action impacts to an ACEC’s relevant and 

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Appendix N: Supplemental Impact Analysis Information Section 3: Supplemental Impact Analysis 

important values (i.e., fisheries, cultural resources, or both; see Appendix J and Table 3.4.1-1 in Appendix 

M of the BSWI Draft RMP/EIS. Cumulative impacts analysis for fisheries resource values included ocean 

areas outside of the planning area, as most of the fish resource species of the ACECs are anadromous. 

The analysis considered both the types of uses allowed by management actions under each alternative, 

and the likely demand for the use and/or likely presence of the resource. For example, opening potential 

ACECs to reindeer grazing could increase surface disturbance and adversely affect fisheries and cultural 

resource values; however, the demand for this use is low, so the foreseeable effects are likely small. 

Nature and Types of Effects 

Cultural resources: All ACECs identified for relevant and important values for cultural resources 

ACECs except for the Tagagawik River pertain to the INHT. Management activities that permit surface 

disturbance from activities such as mineral or ROW development could adversely impact cultural 

resources by allowing land uses that could damage or destroy artifacts and/or cultural sites or alter 

landscape integrity. Managing areas as closed to mineral or ROW development, NSO for externally 

proposed structures, commercial woodland harvest, or as limited for travel within ACECs would protect 

these resources. 

Management actions that designate areas managed per VRM Class I or II beneficially impact relevant and 

important values for cultural resources by limiting surface disturbance and/or development that could 

affect landscape integrity or damage cultural artifacts. VRM management restrictions along the INHT and 

its proposed buffers are more protective than those designated for cultural ACECs; therefore, culturally 

relevant and important values would receive some beneficial impacts from VRM, even under 

Alternatives C and D where ACECs are not established. 

Fisheries resources: Management actions that restrict or regulate in-water and surface disturbance 

provide direct beneficial impacts to fishery resources by protecting spawning habitat and water quality. 

VRM actions can provide indirect beneficial impacts by limiting the extent of surface-disturbing 

activities. All of the ACECs, with the exception of Sheefish ACEC, occur in areas of low mineral 

potential so direct effects from mineral entry are unlikely. Under Alternative B, 528 acres of the Sheefish 

ACEC would intersect an area with medium mineral potential. 

Table 3.7.2-1 below summarizes the nature and types of beneficial or adverse effects that could occur to 

ACEC R&Is, the proposed management actions that could influence those effects, and the indicators used 

to measure the potential magnitude and extent of the effects. 

Table 3.7.2-1: Summary of Effects to ACECs by Management Action 

Types of Effects Management Actions Indicators 

Cultural: Surface disturbance and 

development could impact cultural and 

historical resources by altering landscape 

integrity and/or damaging or destructing 

cultural artifacts. 

• Minerals decisions 

• Transportation and travel decisions 

• Woodland and forest products 

decisions 

• Grazing decisions 

• Acres closed to mineral entry in 

medium-high potential mineral areas 

• Acres managed as limited for travel 

• Acres open to commercial timber 

harvest 

• Acres designated INHT NTMC 

• Acres managed as VRM Class I or II 

• Acres managed for ACEC 

• Acres managed for WSR 

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Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

Types of Effects Management Actions Indicators 

Cultural: Creation of cultural landscape • Cultural Resources Actions • Increased understanding and 

reports would beneficially impact ACEC 

cultural resources by improving the • BSWI Communities Actions documentation of cultural resources 

understanding and documentation of 

cultural resources in the planning area. 

Fisheries: Increased levels of surface • Water resource and fisheries habitat • Acres affected by land withdrawals and 

disturbance near waterways would actions level of mineral potential 

adversely impact fisheries resources by 

increasing the likelihood of sedimentation 

and subsequent reductions in water 

quality. 

• Mineral entry and leasing actions 

• Transportation and travel management 

actions 

• Land and realty ROW actions 

• Woodland and forest products actions 

• Grazing actions 

• Acres open to commercial woodland 

harvest and grazing, and demand for 

this use 

• Size and route restrictions for summer 

travel 

• Designation of ROW exclusion or 

avoidance areas 

Fisheries: Restrictions on the types and • Water resource and fisheries habitat • Acres affected by land withdrawals and 

locations of mineral leasing and entry actions level of mineral potential 

allowed in ACECs would beneficially 

impact fisheries by preventing in-stream 

habitat destruction; increased 

• Mineral entry and leasing actions 

• Transportation and travel management 

• Designation of ROW exclusion or 

avoidance areas 

sedimentation from surface disturbance actions 

near waterways, and increased likelihood • Land and realty ROW actions of hazardous materials releases to 

waterways. 

Fisheries: Creation of cultural landscape • BSWI Communities Actions • Increased understanding and 

reports would beneficially impact ACEC documentation of use of fishery 

fisheries resources by improving the resources 

understanding and documentation of 

fisheries resources in the planning area. 

Indicators 

Indicators used to evaluate impacts to ACECs are as follows: 

Acres open to various surface-disturbing activities along with likely demand for those activities (semi 

quantified). 

• Acreage is a quantitative indicator. All acreages should be considered approximate as they are 

GIS-derived and not surveyed. 

• Likely demand for or presence of a resource is a qualitative indicator. It is based on the current 

demand for resources or current understanding of where resources are located in the planning 

area. 

• Cultural resource understanding and documentation is a qualitative indicator. 

Assumptions 

The following assumptions were used to assess effects associated with ACECs: 

• Where ACECs are designated under an alternative, the relevant and important values of those 

ACECs are assumed to be more protected than in undesignated areas. 

• Although management actions for most resources and resource uses could have planning areawide application, ACEC management prescriptions apply only to those lands in each specific 

ACEC, as outlined. 

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Appendix N: Supplemental Impact Analysis Information Section 3: Supplemental Impact Analysis 

• Permitted activities are assumed not to impair the relevant and important values for which an 

ACEC is designated. The exception is locatable minerals: until withdrawn from mineral entry, a 

mining claim can be filed, and subsequent mining could impact relevant and important values of 

the ACEC. Specific impacts on relevant and important values would depend on the type of 

mineral entry activity and effectiveness of subsequent reclamation and its interaction (both 

spatially and temporally) with that value. With the exception of a small part of the potential 

Sheefish ACEC, all of the potential ACECs are located in areas of low mineral potential, where 

demand for entry and leasing is unlikely. 

• Impacts resulting from locatable minerals would be subject to 43 CFR 3809, intended to: 

1) prevent unnecessary or undue degradation of the land and reclaimed disturbed areas; and 

2) provide for maximum possible coordination with State agencies to avoid duplication and to 

ensure that operators prevent unnecessary or undue degradation of public lands. 

• Leasable mineral potential is low throughout the planning area. 

• Under all alternatives, the BLM would continue to require NHPA Section 106 consultation for 

any project that would impact cultural and historical sites, including those associated with the 

Anvik Traditional Trapping Area, Sheefish Spawning, Tagagawik River, and Unalakleet 

Watershed potential ACECs. 

• Under all alternatives, BLM and permitted projects would follow applicable State and federal 

laws, regulations, and planning documents to manage relevant and important values for fisheries 

and would continue Alaskan Native and public consultations to implement or revise management 

actions. These include federal protections, such as the Clean Water Act, the ESA, MagnusonStevens Fishery Conservation and Management Act and EFH; State Title 16 statutes such as the 

Anadromous Fish Act (AS 16.05.871-.901) and the Fishway or Fish Passage Act (AS 16.05.841); 

and management plans including the 1986 CYRMP, the 1981 SWMFP, and the 1983 Unalakleet 

Wild River Management Plan. 

Data Gaps 

The effects analysis for ACECs was not limited due to incomplete or unavailable information. All 

information necessary for analysis was available. Although not all impacts can be quantified where they 

pertain to the likely demand for a use or resource, or the benefit of improved cultural landscape 

understanding and documentation; these represent qualitative assessments rather than a data gap. 

Standard Operating Procedures and Best Management Practices 

The impact analysis below considers the SOPs and BMPs that could be implemented by the BLM. BMPs 

and SOPs for fisheries and cultural resources would also apply to ACECs as they would protect relevant 

and important values. A comprehensive list of SOPs/BMPs is provided in Appendix K of the BSWI Draft 

RMP/EIS. 

3.7.3 Effects Analysis 

Management actions proposed for the following resources, resource uses, and special designations would 

not result in effects on potential ACECs: 

• Air Quality and AQRVs 

• Climate Change 

• Vegetation 

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Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

• Wildlife 

• Non-native Invasive Species 

• Wildland Fire Management 

• Land with Wilderness Characteristics 

• Leasable Minerals 

• Recreation and Visitor Services 

• Support for BSWI Communities 

• Hazardous Materials and Health and Human Safety 

Table 3.7.3-1 summarizes acres of potential ACEC under various management decisions for each 

Alternative. Note that the “designated” ACEC acreage rows of the summary table include the size of the 

ACECs being considered for that alternative. The “undesignated” acreage rows show the size of potential 

ACEC not considered under that alternative. 

Table 3.7.3-1: Potential Beneficial or Adverse Impacts on Potential ACECs 

Management Action1 

Alternative2,3 

A B C D 

Anadromous Waters Streams (miles) 

Designated ACECs 819 1,566 0 0 

Undesignated ACECs4 820 0 1,566 1,566 

EFH Streams (miles)5 

Designated ACECs 783 1,530 0 0 

Undesignated ACECs4 820 0 1,530 1,530 

HVW (acres) 

Designated ACECs 0 2,874,270 

(21%) 

0 0 

Undesignated ACECs4 0 0 2,309,536 

(17%) 

2,286,612 

(17%) 

VRM Class I (acres) 

Designated ACECs 0 673,980 

(5%) 

0 0 

Undesignated ACECs4 0 0 45,633 

(<1%) 

45,633 

(<1%) 

VRM Class II (acres) 

Designated ACECs 0 1,775,448 

(13%) 

0 0 

Undesignated ACECs4 0 0 1,534,460 

(11%) 

406,915 

(3%) 

VRM Class III (acres) 

Designated ACECs 0 1,463,270 

(11%) 

0 0 

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Appendix N: Supplemental Impact Analysis Information Section 3: Supplemental Impact Analysis 

Management Action1 

Alternative2,3 

A B C D 

Undesignated ACECs4 0 0 1,879,235 

(14%) 

1,387,466 

(10%) 

VRM Class IV (acres) 

Designated ACECs 0 0 0 0 

Undesignated ACECs4 0 0 453,370 

(3%) 

2,072,680 

(15%) 

Open to Commercial Woodland Harvest (acres) 

Designated ACECs 0 0 0 0 

Undesignated ACECs4 770,187 

(6%) 

0 816,680 

(6%) 

3,900,106 

(29%) 

Commercial Woodland Harvest Permits Granted on Case-by-case Basis (acres) 

Designated ACECs 301,470 

(2%) 

0 0 0 

Undesignated ACECs4 1,454,640 

(11%) 

0 3,050,385 

(23%) 

12,592 

(<1%) 

Closed to Commercial Woodland Harvest (acres) 

Designated ACECs 1,596,497 

(12%) 

3,912,698 

(29%) 

0 0 

Undesignated ACECs4 12 

(<1%) 

0 45,633 

(<1%) 

0 

Unavailable for Grazing (acres) 

Designated ACECs 161,317 

(1%) 

3,912,698 

(29%) 

0 0 

Undesignated ACECs4 23 

(<1%) 

0 564,370 

(4%) 

0 

Recommended for Withdrawal from Locatable Mineral Entry (acres) 

Designated ACECs 227,647 

(2%) 

3,912,698 

(29%) 

0 0 

Undesignated ACECs4 452,264 

(3%) 

0 45,633 

(<1%) 

46,633 

(<1%) 

Salables: Closed to Mineral Materials Disposal (acres) 

Designated ACECs 227,647 

(2%) 

3,912,698 

(29%) 

0 0 

Undesignated ACECs4 452,264 

(3%) 

0 66,999 

(<1%) 

66,999 

(<1%) 

ROW Avoidance (acres) 

Designated ACECs 0 3,402,691 

(25%) 

0 0 

Undesignated ACECs4 0 0 3,161,071 

(23%) 

2,322,480 

(17%) 

ROW Avoidance for Linear Realty Actions (acres) 

Designated ACECs 0 0 0 0 

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Management Action1 

Alternative2,3 

A B C D 

Undesignated ACECs4 0 0 79,089 

(2%) 

0 

ROW Exclusion (acres) 

Designated ACECs 0 510,007 

(4%) 

0 0 

Undesignated ACECs4 0 0 0 0 

Travel and Transportation: Areas Open to Cross-Country Travel during Snow-Free Months 

Designated ACECs 1,884,376 

(14%) 

3,677,284 

(27%) 

0 0 

Undesignated ACECs4 2,224,839 

(17%) 

0 3,854,346 

(29%) 

3,854,346 

(29%) 

INHT NTMC (acres) 

Designated ACECs 0 235,414 

(2%) 

0 0 

Undesignated ACECs4 0 0 220,189 

(2%) 

220,189 

(2%) 

Total ACECs 

Designated ACECs6 1,884,376 

(14%) 

3,912,698 

(29%) 

0 0 

Fisheries value 1,873,126 

(14%) 

3,590,287 

(27%) 

0 0 

Cultural resources value 403,378 

(3%) 

1,753,306 

(13%) 

0 0 

Undesignated ACECs4 2,224,839 

(17%) 

0 3,912,698 

(29%) 

3,912,698 

(29%) 

Source: BLM GIS 2018 

Notes: 

1

All management actions are measures of the three indicators for all potential ACECs, except for Anadromous Waters Streams, 

EFH Streams, and HVW, which are only applicable to potential ACECs with the fisheries relevant and important value (and do 

not apply to potential ACECs with only the cultural resources value). 

2

ACEC boundaries between existing (Alternative A) and their counterparts in Alternatives B may differ because data used to 

delineate ACECs in Alternatives B differ slightly (at the scale of the planning area) from Alternative A. Alternatives B ACECs 

were delineated primarily using watershed boundaries, which has improved since Alternative A ACECs were delineated, 

resulting in some differences. 

3

Percentages represent the percent of BLM-managed land in the planning area, 13,465,894 acres. 

4

For purposes of this analysis, undesignated ACECs are considered the geographic boundaries within BLM-managed land in 

the planning area that were found to contain relevant and important values for fisheries, cultural resources, or both. These 

geographic areas are equal to the potential ACECs under Alternative B. 

5

EFH is a subset of, and overlaps with, Anadromous Waters. 

6

Acres of potential ACECs containing both fisheries and cultural resources values overlap. Some potential ACEC boundaries 

also overlap. 

The following sections discuss the effects of the alternatives to each potential ACEC. Where a particular 

management action is not discussed, it would have no or very limited effect on the potential ACEC. Also 

see Appendix J of the BSWI Draft RMP/EIS, Proposed Special Management for ACECs, for a detailed 

description of proposed special management for each potential ACEC under Alternative B. 

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Anvik Traditional Trapping Area ACEC 

Effects under Alternative A 

This area is not currently managed as an ACEC. No special management directive to protect cultural 

resources would occur under Alternative A. 

Effects Common to All Action Alternatives 

There are no effects common to all action alternatives for this ACEC. 

Effects under Alternative B 

Under Alternative B, 21,366 acres (100 percent of the potential ACEC; <1 percent of planning area) 

would be managed as VRM Class I due to the ACEC’s intersection with the INHT NTMC (thereby with 

the more restrictive VRM Class taking precedence). Commercial woodland harvest would be prohibited, 

and it would become a ROW avoidance area. The ACEC would be closed to salable minerals, withdrawn 

from locatable minerals, and closed to leasable minerals development. Collectively, these management 

actions would result in beneficial impacts to relevant and important values for cultural and historic 

resources by limiting surface disturbance and prioritizing preservation of the historic landscape. 

Effects under Alternative C 

No ACECs would be designated under Alternative C, but there would be management applied to the same 

area that would become the Anvik Traditional Trapping Area ACEC under Alternative B. 100 percent of 

the area (21,366 acres) would be managed per VRM Class II. This would be less protective of the historic 

visual landscape than Alternative B, but more than Alternative A. Surface disturbance or development in 

VRM II areas would still require change in the characteristic landscape to be low resulting in beneficial 

impacts to relevant and important values for cultural and historic resources from limited surface 

disturbance and prioritizing preservation of the historic landscape. The area would be NSO leasable, open 

to locatable minerals, and open to salable mineral development on a case-by-case basis. As this location is 

an area of low mineral potential, mineral development is not likely. The area would be open to 

commercial woodland harvest on a case-by-case basis. 

Effects under Alternative D 

No ACECs would be established under Alternative D. However, this area would be part of the INHT 

NTMC and would be managed as VRM Class III. This would provide more protection to relevant and 

important values identified for cultural resources than Alternative A, although less than Alternative B or 

C. The area would be open to commercial woodland harvest, ROW, and minerals development under 

conditions specified in management plans. As the proposed ACEC is located in an area of low mineral 

potential, mineral entry or leasing is not likely. 

Anvik River ACEC 

Effects under Alternative A 

The existing 114,386-acre (1 percent of planning area) Anvik River ACEC is managed to protect fisheries 

(chum salmon) resources. The lands are managed under the 1981 SWMFP and are open on a case-by-case 

basis to leases, permits, ROWs, and easements. 

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Effects Common to All Action Alternatives 

There are no effects common to all action alternatives for this ACEC. 

Effects under Alternative B 

Alternative B does not include the existing Anvik River ACEC. Instead, 100,948 acres (88 percent of 

potential ACEC; <1 percent of planning area) would be part of the Anvik River Watershed ACEC, 

discussed below. The remaining 13,438 acres would no longer be managed as an ACEC and would be 

managed by applicable BLM, State, and other federal regulations and management plans. 

Effects under Alternative C 

No ACECs would be established under Alternative C, but some management actions would apply to the 

potential Anvik River Watershed ACEC, as described below. 

Effects under Alternative D 

No ACECs would be established under Alternative D; 114,386 acres would no longer be managed as an 

ACEC and would be managed by applicable BLM, State, and other federal regulations and management 

plans. HVW would be designated in 108,991 acres (93 percent) of this potential ACEC under Alternative 

D, which includes protections against surface disturbance in floodplains that would have a beneficial 

impact to fishery values. 

Anvik River Watershed ACEC 

Effects under Alternative A 

Part of this area (100,948 acres, 41 percent of potential ACEC; <1 percent of planning area) is currently, 

and under Alternative A would continue to be, managed as part of the existing Anvik River ACEC to 

protect fisheries (chum salmon) resources as described above. The remainder of the proposed ACEC 

(147,924 acres, 1 percent of planning area) has no special designation and would be managed under the 

1981 SWMFP. 

Effects Common to All Action Alternatives 

There are no effects common to all action alternatives for this ACEC. 

Effects under Alternative B 

Under Alternative B, 248,872 acres (100 percent of potential ACEC; 2 percent of planning area) would be 

managed with additional fisheries habitat protections; any proposed floodplain development would be 

required to not diminish fish habitat or the ecological function of riparian systems. The ACEC would be 

closed to salable minerals, withdrawn from locatable minerals, and closed to leasable minerals 

development. In the event the withdrawals were not approved, suction dredging would be limited to 

navigable waters and reclamation of habitat would be required. VRM Class I would apply to 58,077 acres 

(23 percent of potential ACEC; <1 percent of planning area) and Class II would apply to 190,790 acres 

(77 percent of potential ACEC; 1 percent of planning area). This can provide an indirect fisheries value 

by limiting activities that have a large ground-disturbance footprint. Commercial woodland harvest would 

be prohibited, and transportation and travel management decisions would be protective of surface 

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disturbance that could have adverse impacts on water quality and fisheries habitat. Managing more of the 

Anvik River Watershed as an ACEC compared to existing conditions (Alternative A) would provide 

beneficial fisheries impacts by providing added management to avoid or minimize impairments to water 

quality or habitat. 

Effects under Alternative C 

No ACECs would be established under Alternative C, but some management actions would apply to this 

area. No acreage would be managed as VRM Class I, and VRM Class II would apply to 4,198 acres. 

Class III VRM would apply to 244,669 acres (98 percent of potential ACEC; 2 percent of planning area). 

The area would be NSO leasable, open to locatable minerals, and open to salable mineral development on 

a case-by-case basis. As this location is an area of low mineral potential, mineral development is not 

likely. The area would be open to commercial woodland harvest on a case-by-case basis. These 

management actions would provide a lower level of indirect benefit to its fisheries value than Alternative 

B but more than Alternative A. 

Effects under Alternative D 

No ACECs would be established under Alternative D. The area would be open to commercial woodland 

harvest and ROW development under conditions specified in management plans. Portions of the proposed 

ACEC are outside of areas withdrawn from minerals development by PLO 5180 and would be open to 

this use. As the proposed ACEC is located in an area of low mineral potential, mineral development is not 

likely. HVW would be designated in 241,480 acres (97 percent), and VRM Class III would apply to 

242,507 acres (97 percent) of this potential ACEC under Alternative D, which include protections against 

surface disturbance in floodplains that would have a beneficial impact to fishery values. 

Gisasa River ACEC 

Effects under Alternative A 

The existing 278,055-acre (99 percent of potential ACEC; 2 percent of planning area) Gisasa River 

ACEC is managed to protect fisheries (Chinook and chum salmon) resources. The upper portion of the 

river is closed to mineral leasing and non-metalliferous mineral entry by PLO 5180; the lower portion by 

PLO 5173/5184. The lands are managed under the CYMP and are open on a case-by-case basis to 

permits, leases, ROWs, and easements, although FLPMA sales and leases are not allowed in a 300-foot 

setback zone on the Gisasa River. 

Effects Common to All Action Alternatives 

There are no effects common to all action alternatives for this ACEC. 

Effects under Alternative B 

Under Alternative B, 278,247 acres (100 percent of potential ACEC; 2 percent of planning area) would be 

managed with additional fisheries habitat protections; the difference in size from Alternative A is due to 

improved watershed mapping. Any proposed floodplain development would be required to not diminish 

fish habitat or the ecological function of riparian systems. The ACEC would be closed to salable minerals, 

withdrawn from locatable minerals, and closed to leasable minerals development. In the event the 

withdrawals were not approved, suction dredging would be limited to navigable waters and reclamation 

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Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

of habitat would be required. Commercial woodland harvest would be prohibited, and the ACEC would 

be a ROW avoidance area. VRM Class II would apply to 62,189 acres (22 percent of potential ACEC; <1 

percent of planning area) and Class III would apply to 216,052 acres (78 percent of potential ACEC; 1 

percent of planning area) of the ACEC. This can provide an indirect fisheries value by limiting activities 

that have a large ground-disturbance footprint. Alternative B would provide a beneficial fisheries impact 

by providing added protections against activities that could impair water quality. 

Effects under Alternative C 

No ACECs would be established under Alternative C, but some management actions would apply to this 

area. VRM Class III would apply to the entire ACEC, the area would be NSO leasable, open to locatable 

minerals, and open to salable mineral development on a case-by-case basis. As this location is an area of 

low mineral potential, mineral development is not likely. The area would be open to commercial 

woodland harvest on a case-by-case basis, which would provide a lower level of protection from surface 

disturbance than Alternative B. 

Effects under Alternative D 

No ACECs would be established under Alternative D. The area would be open to commercial woodland 

harvest, ROW, and mineral entry and leasing under conditions specified in management plans. As the 

proposed ACEC is located in an area of low mineral potential, mineral development is not likely. VRM 

Class III would apply to 18,857 acres (7 percent of potential ACEC), the rest would be managed as VRM 

Class IV. This alternative would be least protective of fisheries resources. HVW would be designated in 

223,162 acres (80 percent) of this potential ACEC under Alternative D, which includes protections 

against surface disturbance in floodplains that would have some beneficial impact to fishery values 

compared to Alternative A. 

Inglutalik River ACEC 

Effects under Alternative A 

The existing 71,713-acre (100 percent of potential ACEC; <1 percent of planning area) Inglutalik River 

ACEC is managed to protect fisheries (four salmon species) resources. The ACEC is closed to nonmetalliferous mineral entry by PLO 5180. The lands are managed under the CYRMP and are open on a 

case-by case basis to permits, leases, ROWs, and easements. 

Effects Common to All Action Alternatives 

There are no effects common to all action alternatives for this ACEC. 

Effects under Alternative B 

Under Alternative B, 70,891 acres (99 percent of potential ACEC; <1 percent of planning area) would be 

managed with additional fisheries protection; the difference in size from Alternative A is due to improved 

watershed mapping. Any proposed floodplain development or travel route designations would be required 

to not diminish fish habitat or the ecological function of riparian systems. The ACEC would be closed to 

salable minerals, withdrawn from locatable minerals, and closed to leasable minerals development. In the 

event the withdrawals were not approved, suction dredging would be limited to navigable waters and 

reclamation of habitat would be required. Commercial woodland harvest would be prohibited, VRM 

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Class III management would apply, and the ACEC would be a ROW avoidance area. Alternative B would 

provide a beneficial fisheries impact by providing added protections against activities that could impair 

water quality. 

Effects under Alternative C 

No ACECs would be established under Alternative C, but some management actions would apply to this 

area. The area would be NSO leasable, open to locatable minerals, and open to salable mineral 

development on a case-by-case basis. As this location is an area of low mineral potential, mineral 

development is not likely. The area would be open to commercial woodland harvest on a case-by-case 

basis. 

Effects under Alternative D 

No ACECs would be established under Alternative D. The area would be open to commercial woodland 

harvest, ROW and floodplain development, and mineral leasing under conditions specified in 

management plans. As the proposed ACEC is located in an area of low mineral potential, mineral 

development is not likely. This alternative would be least protective of fisheries resources. HVW would 

be designated in 18,253 acres (25 percent) of this potential ACEC under Alternative D, which includes 

protections against surface disturbance in floodplains that would have some beneficial impact to fishery 

values in the area affected. 

Kateel River ACEC 

Effects under Alternative A 

The existing 568,083-acre (82 percent of potential ACEC; 4 percent of planning area) Kateel River ACEC 

is managed to protect fisheries (Chinook and chum salmon) resources. The upper portion of the river is 

closed to mineral leasing and non-metalliferous mineral entry by PLO 5180; the lower portion by PLO 

5173/5184. The lands are managed under the CYRMP and are open on a case-by case basis to permits, 

leases, ROWs, and easements. FLPMA sales and leases are not allowed within a 300-foot setback of the 

Kateel River. 

Effects Common to All Action Alternatives 

There are no effects common to all action alternatives for this ACEC. 

Effects under Alternative B 

Under Alternative B, 692,659 acres (100 percent of potential ACEC; 5 percent of planning area) would be 

managed with additional fisheries habitat protections; the difference in size compared to existing 

conditions is due mainly to the addition of lands located between the existing Kateel River ACEC 

(Alternative A) and the Koyukuk National Wildlife Refuge as a result of watershed mapping 

improvements for the Kateel River watershed. Any proposed floodplain development or travel route 

designations would be required to not diminish fish habitat or the ecological function of riparian systems. 

The ACEC would be closed to salable minerals, withdrawn from locatable minerals, and closed to 

leasable minerals development. In the event the withdrawal was not approved, suction dredging would be 

limited to navigable waters and reclamation of habitat would be required. Commercial woodland harvest 

would be prohibited, and the ACEC would be a ROW avoidance area. VRM Class II would apply to 

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55,820 acres of the ACEC (8 percent of potential ACEC; <1 percent of planning area). The remaining 

636,839 acres (92 percent of potential ACEC; 5 percent of planning area) would be managed as VRM 

Class III. Alternative B would provide the largest beneficial fisheries impact by providing added 

protections against activities that could impair water quality and by including a larger portion of the 

Kateel River watershed in these protections. 

Effects under Alternative C 

No ACECs would be established under Alternative C, but some management actions would apply to part 

of this area. The area covered by management actions to minimize impacts on fisheries would be 48 

percent smaller than that covered under Alternative B, and all would be managed as VRM Class III. The 

remaining 52 percent would be managed as VRM Class IV. The area would be NSO leasable, open to 

locatable minerals, and open to salable mineral development on a case-by-case basis. As this location is 

an area of low mineral potential, mineral development is not likely. The area would be open to 

commercial woodland harvest on a case-by-case basis. Alternative C includes additional anadromous 

river miles compared to Alternative A (141 compared to 106), as it would extend special management 

provisions to the boundary of the Koyukuk NWR; however, portions of the upper watersheds of the 

existing ACEC would be excluded from special management under Alternative C. Because the fisheries 

habitat resources protections would be stronger and would include more acreage near the river, 

Alternative C would provide beneficial impacts to fisheries resources compared to Alternative A, 

although less than Alternative B. 

Effects under Alternative D 

No ACECs would be established under Alternative D. The area would be open to commercial woodland 

harvest, ROW, and floodplain development, under conditions specified in management plans. As the area 

has low mineral potential, mineral development is not likely. The entire undesignated potential ACEC 

would be managed as VRM Class IV. This would be least protective action Alternative of fisheries 

resources. HVW would be designated in 300,069 acres (43 percent) of this potential ACEC under 

Alternative D, which includes protections against surface disturbance in floodplains that would have some 

beneficial impact to fishery values in the area affected compared to Alternative A. 

Nulato River ACEC 

Effects under Alternative A 

This area is not currently managed as an ACEC. It is located in an area closed to mineral leasing and nonmetalliferous mineral entry by PLO 5180, 5173, and 5184. The lands are currently managed under the 

1986 CYRMP and are open on a case-by-case basis to permits, leases, ROWs, and easements. FLPMA 

sales and leases are not allowed within a 300-foot setback of the Nulato River. 

Effects Common to All Action Alternatives 

There are no effects common to all action alternatives for this ACEC. 

Effects under Alternative B 

Under Alternative B, 344,183 acres (100 percent of potential ACEC; 3 percent of planning area) would be 

managed with additional fisheries habitat protections; any proposed floodplain development would be 

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required to not diminish fish habitat or the ecological function of riparian systems. The ACEC would be 

closed to salable minerals, withdrawn from locatable minerals, and closed to leasable minerals 

development. In the event the withdrawal was not approved, suction dredging would be limited to 

navigable waters and reclamation of habitat would be required. VRM Class I would apply to 259 acres, 

and Class II would apply to 245,758 acres (71 percent of potential ACEC; 2 percent of planning area) of 

the ACEC. The remainder would be managed as VRM Class III. This can provide an indirect fisheries 

value by limiting activities that have large ground-disturbance footprints. Commercial woodland harvest 

would be prohibited, and transportation and travel management decisions would be protective of surface 

disturbance that could have adverse impacts on water quality and fisheries. The ACEC would become a 

ROW avoidance area. Drinking water quality monitoring would begin for the Village of Nulato, and 

hazardous materials cleanups would be prioritized when they have the potential to affect water quality. 

Alternative B would provide beneficial fisheries impacts by providing added protections against activities 

that could impair water quality. 

Effects under Alternative C 

No ACECs would be established under Alternative C, but some management actions would apply to this 

area. VRM Class I would apply to 1 acre, and Class II would apply to 98,452 acres of the ACEC (29 

percent of potential ACEC; <1 percent of planning area). Drinking water monitoring and prioritization of 

hazardous materials cleanup would be implemented as in Alternative B. The area would be NSO leasable, 

open to locatable minerals, and open to salable mineral development on a case-by-case basis. As this 

location is an area of low mineral potential, mineral development is not likely. The area would be open to 

commercial woodland harvest on a case-by-case basis. These actions would provide some but fewer 

indirect beneficial impacts to fisheries values compared to Alternative B. 

Effects under Alternative D 

No ACECs would be established under Alternative D. The area would be open to commercial woodland 

harvest, ROW, and floodplain development under conditions specified in management plans. This 

alternative would be least protective of fisheries resources. VRM Class I or II would apply to 192 acres 

and Class III would apply to 196,484 acres (57 percent of potential ACEC; 1 percent of planning area). 

HVW would be designated in 297,923 acres (87 percent) of this potential ACEC under Alternative D, 

which includes protections against surface disturbance in floodplains that would have some beneficial 

impact to fishery values in the area affected compared to Alternative A, although less than Alternatives B 

and C. 

Shaktoolik River ACEC 

Effects under Alternative A 

The existing 192,591-acre (100 percent of potential ACEC; 1 percent of planning area) Shaktoolik River 

ACEC is managed to protect fisheries resources (four salmon species). The ACEC is closed to nonmetalliferous mineral entry by PLO 5180. The lands are managed under the CYRMP (and extend into the 

Kobuk Seward Peninsula Planning Area) and are open on a case-by case basis to permits, leases, ROWs, 

and easements. 

Effects Common to All Action Alternatives 

There are no effects common to all action alternatives for this ACEC. 

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Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

Effects under Alternative B 

Under Alternative B, 191,725 acres (>99 percent of potential ACEC; 2 percent of planning area) would 

be managed with additional fisheries habitat protections; the difference in size is due to improved 

watershed mapping. Any proposed floodplain development or travel route designations would be required 

to not diminish fish habitat or the ecological function of riparian systems. The ACEC would be closed to 

salable minerals, withdrawn from locatable minerals, and closed to leasable minerals development. In the 

event the withdrawal was not approved, suction dredging would be limited to navigable waters and 

reclamation of habitat would be required. VRM Class II would apply to 69,724 acres (36 percent of 

potential ACEC), and Class III would apply to 121,343 acres (64 percent of potential ACEC). This can 

provide an indirect beneficial impact to fisheries value by limiting activities that have large grounddisturbance footprints. Commercial woodland harvest would be prohibited, and the ACEC would be a 

ROW avoidance area. Alternative B would provide beneficial fisheries impacts by providing added 

protections against activities that could impair water quality. 

Effects under Alternative C 

No ACECs would be established under Alternative C, but some management actions would apply to this 

area. No portion would be managed as VRM Class II; instead, 191,067 acres would be managed as VRM 

Class III. This would provide fewer indirect benefits to fisheries than VRM management under 

Alternative B. The area would be NSO leasable, open to locatable minerals, and open to salable mineral 

development on a case-by-case basis. As this location is an area of low mineral potential, mineral 

development is not likely. The area would be open to commercial woodland harvest on a case-by-case 

basis. 

Effects under Alternative D 

No ACECs would be established under Alternative D. The area would be open to commercial woodland 

harvest, ROW, and floodplain development, under conditions specified in management plans. As the 

proposed ACEC is located in an area of low mineral potential, mineral development is not likely. VRM 

Class III would apply to 55,506 acres (29 percent) and the remaining undesignated area would be 

managed as VRM Class IV. This alternative would be least protective of fisheries resources. HVW would 

be designated in 124,472 acres (68 percent) of this potential ACEC under Alternative D, which includes 

protections against surface disturbance in floodplains that would have some beneficial impact to fishery 

values in the area affected. 

Sheefish ACEC 

Effects under Alternative A 

This area is not currently managed as an ACEC. It is located in an area closed to mineral leasing and nonmetalliferous mineral entry under PLO 5180. The lands are currently managed under the 1981 SWMFP 

and are open on a case-by-case basis to permits, leases, ROWs, and easements. 

Effects Common to All Action Alternatives 

There are no effects common to all action alternatives for this ACEC. 

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Effects under Alternative B 

Under Alternative B, 696,902 acres (100 percent of potential ACEC; 5 percent of planning area) would be 

designated an ACEC and managed with additional fisheries and cultural protections. 

• Management affecting fisheries habitat: Any proposed floodplain development or travel route 

designations would be required to not diminish fish habitat or the ecological function of riparian 

systems. The ACEC would be closed to salable minerals, withdrawn from locatable minerals, and 

closed to leasable minerals development. In the event the withdrawal was not approved, suction 

dredging would be limited to navigable waters and reclamation of habitat would be required. 

Commercial woodland harvest would be prohibited, and the ACEC would be a ROW avoidance 

area. Alternative B would provide the largest beneficial fisheries impact by providing added 

protections against activities that could impair water quality and by including a larger portion of 

the area in these protections. 

• Management affecting cultural resources: Under Alternative B, the Farewell Burn INHT 

NTMC would overlap 46,590 acres of the proposed sheefish ACEC (<1 percent of planning 

area). This section would be managed as VRM Class I due to its intersection with the INHT 

NTMC. An additional 195,594 acres (total of both is 35 percent of potential ACEC) would be 

managed as VRM Class I due to overlap with suitable WSR waterways. The remaining 454,717 

acres (65 percent of the potential ACEC) would be managed as VRM Class II due to cultural 

resource R&Is. Commercial woodland harvest would be prohibited, and it would become a ROW 

avoidance area. The ACEC would be closed to salable minerals, withdrawn from locatable 

minerals, and closed to leasable minerals development. These management actions would 

beneficially impact cultural and historic resources in the ACEC by limiting surface disturbance 

and prioritizing preservation of the historic visual landscape. 

Effects under Alternative C 

No ACECs would be established under Alternative C, but some management actions would apply to this 

area. Under Alternative C, special management provisions would cover 194,848 acres (28 percent of 

potential ACEC; 1 percent of planning area). Lands included would comprise non-contiguous areas and 

would include lands close to the INHT, the Big River and Blackwater Creek, and the Middle Fork 

Kuskokwim River. 

• Management affecting fisheries habitat: The area covered by management actions to minimize 

impacts to fisheries habitat would be 70 percent smaller than Alternative B. The area would be 

NSO leasable, open to locatable minerals, and open to salable mineral development on a case-bycase basis. As this location is an area of low mineral potential (with the exception of 528 acres 

mapped with medium mineral potential), mineral development is not likely. The area would be 

open to commercial woodland harvest on a case-by-case basis. 

• Management affecting cultural resources: Under Alternative C, 421,036 acres (60 percent) of 

the undesignated area would be managed as VRM Class II, 157,025 acres (23 percent) managed 

as VRM Class III, and 118,840 acres (17 percent) managed as VRM Class IV. The remaining 

actions pertaining to cultural resource protection would be the same, but the area covered by these 

protections would be smaller than Alternative B. 

Effects under Alternative D 

No ACECs would be established under Alternative D. The area within the INHT buffer would be 

managed as a VRM Class II (177,428 acres, 25 percent) and VRM Class III (315,845 acres, 45 percent). 

The area would be open to commercial woodland harvest, ROW and floodplain development, and 

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metalliferous mineral entry under conditions specified in management plans. As the proposed ACEC is 

not located in an area of known medium or high mineral potential (with the exception of 528 acres), 

mineral development is not likely. This alternative would be least protective of fisheries and cultural 

resources. HVW would be designated in 372,385 acres (53 percent) of this potential ACEC under 

Alternative D, which includes protections against surface disturbance in floodplains that would have some 

beneficial impact to fishery values in the area affected compared to Alternative A. 

Swift River Whitefish Spawning ACEC 

Effects under Alternative A 

This area is not currently managed as an ACEC. It is located in an area closed to mineral leasing and nonmetalliferous mineral entry by PLO 5180 and 5184. The lands are currently managed under the 1981 

SWMFP and are open on a case-by-case basis to permits, leases, ROWs, and easements. 

Effects Common to All Action Alternatives 

There are no effects common to all action alternatives for this ACEC. 

Effects under Alternative B 

Under Alternative B, 220,032 acres (100 percent of potential ACEC) would be managed with additional 

fisheries habitat protections; any proposed floodplain development would be required to not diminish fish 

habitat or the ecological function of riparian systems. The ACEC would be closed to salable minerals, 

withdrawn from locatable minerals, and closed to leasable minerals development. In the event the 

withdrawal was not approved, suction dredging would be limited to navigable waters and reclamation of 

habitat would be required. VRM Class II would apply to 13,504 acres (6 percent of potential ACEC), and 

Class III would apply to 206,528 acres (94 percent of potential ACEC). This can provide an indirect 

beneficial impact to fisheries by limiting activities that have large ground-disturbance footprints. 

Commercial woodland harvest would be prohibited, and transportation and travel management decisions 

would be protective of surface disturbance that could have adverse impacts on water quality and fisheries. 

The ACEC would become a ROW avoidance area. Alternative B would provide beneficial fisheries 

impacts by providing added protections against activities that could impair water quality. 

Effects under Alternative C 

No ACECs would be established under Alternative C, but some special management provisions would 

apply to this area. No portion would be managed as VRM Class II; instead, all 220,032 acres would be 

managed as VRM Class III. This would provide fewer indirect benefits to fisheries than VRM 

management under Alternative B. The area would be NSO leasable, open to locatable minerals, and open 

to salable mineral development on a case-by-case basis. As this location is an area of low mineral 

potential, mineral development is not likely. The area would be open to commercial woodland harvest on 

a case-by-case basis. 

Effects under Alternative D 

No ACECs would be established under Alternative D. The area would be open to commercial woodland 

harvest, ROW, and floodplain development under conditions specified in management plans. About 

78,427 acres (36 percent of potential ACEC) would be managed as VRM Class III and 141,604 acres (64 

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Appendix N: Supplemental Impact Analysis Information Section 3: Supplemental Impact Analysis 

percent of undesignated area) managed as VRM Class IV. This would be least protective of fisheries 

resources out of the action alternatives. HVW would be designated in 102,478 acres (47 percent) of this 

potential ACEC under Alternative D, which includes protections against surface disturbance in 

floodplains that would have some beneficial impact to fishery values in the area affected compared to 

Alternative A. 

Tagagawik River ACEC 

Effects under Alternative A 

This area is not currently managed as an ACEC. It is located in an area closed to mineral leasing and nonmetalliferous mineral entry by PLO 5180. The lands are currently managed under the 1986 CYRMP and 

are open on a case-by-case basis to permits, leases, ROWs, and easements. A 300-foot setback zone on 

the Tagagawik River is closed to FLMPA sales and leases. 

Effects Common to All Action Alternatives 

There are no effects common to all action alternatives for this ACEC. 

Effects under Alternative B 

Under Alternative B, 301,044 acres (100 percent of potential ACEC; 2 percent of planning area) would be 

managed with additional fisheries and cultural protections: 

• Management affecting fisheries habitat: any proposed floodplain development would be 

required to not diminish fish habitat or the ecological function of riparian systems. The ACEC 

would be closed to salable minerals, withdrawn from locatable minerals, and closed to leasable 

minerals development. In the event the withdrawal was not approved, suction dredging would be 

limited to navigable waters and reclamation of habitat would be required. Commercial woodland 

harvest would be prohibited, and transportation and travel management decisions would be 

protective of surface disturbance that could have adverse impacts on water quality and fisheries. 

The ACEC would become a ROW avoidance area. Alternative B would provide beneficial 

fisheries impacts by providing added protections against activities that could impair water quality. 

• Management affecting cultural resources: This ACEC would be managed as VRM Class II due 

to identified cultural R&Is. Commercial woodland harvest would be prohibited, and it would 

become a ROW avoidance area. The ACEC would be closed to salable minerals, withdrawn from 

locatable minerals, and have NSO leasable minerals development. These management actions 

would beneficially impact cultural resources in the ACEC by limiting surface disturbance and 

prioritizing preservation of the visual landscape. 

Effects under Alternative C 

No ACECs would be established under Alternative C, but some management actions would apply to this 

area. The area would be NSO leasable, open to locatable minerals, and open to salable mineral 

development on a case-by-case basis. As this location is an area of low mineral potential, mineral 

development is not likely. The area would be open to commercial woodland harvest on a case-by-case 

basis. 

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Effects under Alternative D 

No ACECs would be established under Alternative D. The area would be open to commercial woodland 

harvest, ROW, and floodplain development under conditions specified in management plans. This 

alternative would be least protective of fisheries resources. 

Alternative D would include the creation of Cultural Landscape Reports for the entire planning area. This 

would beneficially impact the understanding and documentation of cultural landscape in the Tagagawik 

ACEC and would therefore be more beneficial to cultural resources than Alternative A and would provide 

more understanding and documentation, although less protection against surface disturbance, than 

Alternatives B and C. 

Ungalik River ACEC 

Effects under Alternative A 

The existing 112,719-acre (99 percent of potential ACEC; 1 percent of planning area) Ungalik River 

ACEC is managed to protect fisheries (salmon) resources. The ACEC is closed to mineral leasing and 

non-metalliferous mineral entry by PLO 5180. The lands are managed under the CYMP and are open on a 

case-by case basis to permits, leases, ROWs, and easements. The river extends into the Kobuk-Seward 

planning area and that downstream portion is an ACEC under the 2008 Kobuk-Seward RMP. 

Effects Common to All Action Alternatives 

There are no effects common to all action alternatives for this ACEC. 

Effects under Alternative B 

Under Alternative B, 113,455 acres (100 percent of potential ACEC) would be managed with additional 

fisheries habitat protections; the difference in size from Alternative A is due to improved watershed 

mapping. Any proposed floodplain development would be required to not diminish fish habitat or the 

ecological function of riparian systems. The ACEC would be closed to salable minerals, withdrawn from 

locatable minerals, and closed to leasable minerals development. In the event the withdrawal was not 

approved, suction dredging would be limited to navigable waters and reclamation of habitat would be 

required. The ACEC would be managed as VRM Class III. Commercial woodland harvest would be 

prohibited, and the ACEC would be a ROW avoidance area. Alternative B would provide a beneficial 

fisheries impact by providing added protections against activities that could impair water quality. 

Effects under Alternative C 

No ACECs would be established under Alternative C, but some management actions would apply to this 

area. The area would be NSO leasable, open to locatable minerals, and open to salable mineral 

development on a case-by-case basis. As this location is an area of low mineral potential, mineral 

development is not likely. The area would be open to commercial woodland harvest on a case-by-case 

basis. 

Effects under Alternative D 

No ACECs would be established under Alternative D. The area would be open to commercial woodland 

harvest, ROW, and floodplain development, and mineral entry and leasing under conditions specified in 

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management plans. As the proposed ACEC is located in an area of low mineral potential, mineral 

development is not likely. This alternative would be least protective of fisheries resources. HVW would 

be designated in 64,809 acres (57 percent) of this potential ACEC under Alternative D, which includes 

protections against surface disturbance in floodplains that would have some beneficial impact to fishery 

values in the area affected. 

North River ACEC 

Effects under Alternative A 

The existing 137,349-acre (100 percent of potential ACEC; 1 percent of planning area) North River 

ACEC is managed to protect fisheries resources. It is located in an area closed to mineral leasing and nonmetalliferous mineral entry by PLO 5180. The lands are managed under the 1981 SWMFP and are open 

on a case-by-case basis to leases, permits, ROWs, and easements. FLPMA sales and leases are not 

allowed within a 300-foot setback of the North River. 

Effects Common to All Action Alternatives 

There are no effects common to all action alternatives for this ACEC. 

Effects under Alternative B 

Alternative B does not include the North River ACEC. Instead, the North River would be part of the 

Unalakleet River Watershed ACEC, discussed below. 

Effects under Alternative C 

No ACECs would be established under Alternative C, but some management actions would apply to this 

area, as discussed in the Unalakleet River Watershed ACEC section, below. 

Effects under Alternative D 

No ACECs would be established under Alternative D. The 137,349 acres would no longer be managed as 

an ACEC and would be managed under applicable BLM, State, and other federal regulations and 

management plans. HVW would be designated in 93,938 acres (68 percent) of this potential ACEC under 

Alternative D, which includes protections against surface disturbance in floodplains that would have some 

beneficial impact to fishery values in the area affected. 

Drainages of the Unalakleet ACEC 

Effects under Alternative A 

The existing 415,184-acre (100 percent of potential ACEC; 3 percent of planning area) Drainages of the 

Unalakleet River ACEC is managed to protect fisheries resources. It comprises four non-contiguous 

areas. The designated Unalakleet Wild River Corridor (46,953 acres, <1 percent of planning area) is 

located within the ACEC. Most of the ACEC is located in areas closed to mineral leasing and nonmetalliferous mineral entry by PLO 5180, 5179, and 5173. Some parts of the ACEC, primarily in the 

segment along the Chiroskey River, are open to mineral leasing and entry. The lands are managed under 

the 1981 SWMFP, 1986 CYMFP, and the Unalakleet Wild and Scenic River Plan (BLM 1983). 

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Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

Effects Common to All Action Alternatives 

The designated Unalakleet Wild River Corridor (46,953 acres) would remain in place under all action 

alternatives. 

Effects under Alternative B 

Alternative B does not include the Drainages of the Unalakleet River ACEC. Instead, most of the area 

would be part of the Unalakleet River Watershed ACEC, discussed below. 

Effects under Alternative C 

No ACECs would be established under Alternative C, but some management actions would apply to this 

area, as discussed in the Unalakleet River Watershed ACEC section, below. 

Effects under Alternative D 

No ACECs would be established under Alternative D. The 415,184 acres would no longer be managed as 

an ACEC and would be managed by applicable BLM, State, and other federal regulations and 

management plans. HVW would be designated in 244,367 acres (59 percent) of this potential ACEC 

under Alternative D, which includes protections against surface disturbance in floodplains that would 

have some beneficial impact to fishery values in the area affected. 

Unalakleet River Watershed ACEC 

Effects under Alternative A 

More than 60 percent of the proposed Unalakleet River Watershed ACEC area (depending on Alternative) 

is currently managed for fisheries protection as part of the existing Drainages of the Unalakleet River or 

North River ACECs, as described above. The designated Unalakleet Wild River Corridor (46,953 acres) 

is located within the Drainages of the Unalakleet ACEC. Most of the area is located in areas closed to 

mineral leasing and non-metalliferous mineral entry by PLO 5180, 5179, and 5173. Some parts of the 

existing ACECs, primarily in the segment along the Chiroskey River, are open to leasing and entry. The 

lands are managed under the 1981 SWMFP, 1986 CYMFP, and the Unalakleet Wild and Scenic River 

Plan (BLM 1983). 

Effects Common to All Action Alternatives 

The designated Unalakleet Wild River Corridor (46,953 acres) would remain in place under all action 

alternatives. 

Effects under Alternative B 

Under Alternative B, 733,995 acres (100 percent of potential ACEC; 5 percent of planning area) would be 

managed with additional fisheries and cultural protections. 

• Management affecting fisheries habitat: Any proposed floodplain development or travel route 

designations would be required to not diminish fish habitat or the ecological function of riparian 

systems. The ACEC would be closed to salable minerals, withdrawn from locatable minerals, and 

closed to leasable minerals development. In the event the withdrawal was not approved, suction 

dredging would be limited to navigable waters and reclamation of habitat would be required. 

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Commercial woodland harvest would be prohibited, and the ACEC would be a ROW avoidance 

area. Alternative B would provide beneficial fisheries impacts by providing added protections 

against activities that could impair water quality. 

• Management affecting cultural resources: The INHT and buffer, and the designated and 

eligible WSR waterways in the ACEC would be managed as VRM Class I. These areas overlap, 

and create a combined total of 352,094 acres (48 percent) in the ACEC managed as class I. The 

remainder of the ACEC (381,901 acres; 52 percent) would be managed as VRM Class II due to 

designation as a cultural resource ACEC. Commercial woodland harvest would be prohibited, and 

it would become a ROW avoidance area. The ACEC would be closed to salable minerals, 

withdrawn from locatable minerals, and closed to leasable minerals development. These 

management actions would beneficially impact historic resources in the ACEC by limiting 

surface disturbance and prioritizing preservation of the visual landscape. 

Effects under Alternative C 

No ACECs would be established under Alternative C, but some management actions would apply to this 

area. Under Alternative C, these management actions to minimize impacts on fisheries habitat and 

cultural resources would comprise 701,952 acres (96 percent of potential ACEC; 5 percent of planning 

area). The smaller size results primarily from less of the North River Watershed being included in the 

proposed ACEC. Alternative C would be less protective of fisheries and cultural resources than 

Alternative B, but more than Alternatives A and D. 

• Management affecting fisheries habitat: The area covered by management actions protective of 

fish habitat would be about 5 percent smaller. The area would be NSO leasable, open to locatable 

minerals, and open to salable mineral development on a case-by-case basis. As this location is an area 

of low mineral potential, mineral development is not likely. The area would be open to commercial 

woodland harvest on a case-by-case basis. 

• Management affecting cultural resources: Under Alternative C, 45,632 acres (6 percent) would be 

managed as VRM Class I due to overlap with the designated Unalakleet Wild River Corridor, and 

688,363 acres (94 percent) would be managed as VRM Class II. The remaining actions pertaining to 

cultural resource protection would be the same, but the area covered by these protections would be 

about 5 percent smaller. 

Effects under Alternative D 

No ACECs would be established under Alternative D. Except for the 46,953-acre designated Unalakleet 

Wild River Corridor and the INHT, the area would be open to commercial woodland harvest, ROW, and 

floodplain development, under conditions specified in management plans. As the proposed ACEC is 

located in an area of low mineral potential, mineral development is not likely. 

The Unalakleet Wild River Corridor and the INHT portions would retain VRM management actions 

under this alternative, which would result in 45,632 acres (6 percent) of Class I, 229,297 acres (31 

percent) of Class II, 354,179 acres (48 percent) of Class III, and the remainder as VRM Class IV. Cultural 

resources protections would increase compared to Alternative A but would be less than those under 

Alternative B or C. Alternative D would be least protective for fisheries resources of the action 

alternatives. HVW would be designated in 544,205 acres (74 percent) of this potential ACEC under 

Alternative D, which includes protections against surface disturbance in floodplains that would have some 

beneficial impact to fishery values in the areas affected compared to Alternative A. 

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Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

Box River Treeline Research Natural Area ACEC 

Effects under Alternative A 

The existing 13,592-acre (100 percent of potential ACEC; <1 percent of planning area) Box River 

Treeline RNA ACEC is managed to protect fisheries, wildlife, ecological and geological resources. It is 

located in an area closed to mineral leasing and non-metalliferous mineral entry by PLO 5180. The lands 

are managed under the CYRMP and are open on a case-by case basis to permits, leases, ROWs, and 

easements. 

Effects Common to All Action Alternatives 

There are no effects common to all action alternatives for this ACEC. 

Effects under Alternative B 

Alternative B does not include the Box River Treeline RNA ACEC. Instead, the entire area would be part 

of the Kateel River ACEC, discussed above. 

Effects under Alternative C 

No ACECs would be established under Alternative C, but some management actions would apply to this 

area, as discussed in the Kateel River ACEC section, above. 

Effects under Alternative D 

No ACECs would be established under Alternative D. The 13,592 acres would no longer be managed as 

an ACEC and would be managed by applicable BLM, State, and other federal regulations and 

management plans. 

Peregrine Falcon Nesting Habitat ACEC 

Effects under Alternative A 

The existing 8,096-acre (100 percent of potential ACEC; <1 percent of planning area) Peregrine Falcon 

Nesting Habitat ACEC is managed to protect wildlife resources. It comprises four non-contiguous 

locations near the Yukon River. The lands are currently managed under the 1981 SWMFP and are open 

on a case-by-case basis to leases, permits, ROWs, and easements. 

Effects Common to All Action Alternatives 

The Peregrine Falcon Nesting Habitat ACEC would no longer be managed as an ACEC under all action 

alternatives. As nesting sites had not been confirmed since 1981 and the peregrine falcon is no longer a 

listed threatened species, the ACEC no longer supports wildlife as an important value. These lands would 

be managed by applicable BLM, State and other federal regulations and management plans under all 

alternatives. 

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Kuskokwim River Raptor Nesting Habitat ACEC 

Effects under Alternative A 

The existing 6,072-acre (100 percent of potential ACEC; <1 percent of planning area) Kuskokwim River 

Raptor Nesting Habitat ACEC is managed to protect wildlife resources. It comprises three non-contiguous 

locations near the Kuskokwim River. It is located in an area closed to mineral leasing and nonmetalliferous mineral entry by PLO 5184. The lands are currently managed under the 1981 SWMFP and 

are open on a case-by-case basis to leases, permits, ROWs, and easements. 

Effects Common to All Action Alternatives 

The Kuskokwim River Raptor Nesting Habitat ACEC would no longer be managed as an ACEC under all 

action alternatives. As the peregrine falcon is no longer a listed threatened species the ACEC no longer 

supports wildlife as an important value. These lands would be managed by applicable BLM, State and 

other federal regulations and management plans under all alternatives. 

ACECs: Cumulative Effects 

Cultural Relevant and Important Values 

Reasonably foreseeable future actions that may affect cultural resources are primarily related to the 

ongoing development of the Donlin Gold Project and the potential for exploration and development of 

locatable minerals in the planning area. Infrastructure developments to communities also present potential 

for impacts on cultural resources. Any development of roads and other transportation routes through the 

potential ACECs would result in additional surface disturbance. 

Fish Relevant and Important Values 

Based on past commercial, subsistence, and personal use fisheries harvest data, resident fish production is 

forecast to remain stable in the planning area. The forecasted extent of disturbance to habitat is expected 

to remain minimal throughout the majority of the watersheds in the planning area. Activities that occur 

within the planning area that have the highest potential to affect fish production include placer mining, 

hard rock mining, gravel mining, timber harvests, and stream crossings of roads, trails, and utility 

corridors in important fish habitats. All of the potential ACECs are located in areas of low mineral 

potential where mineral entry or leasing is unlikely. 

Outside of the planning area, ocean-based commercial fishing has the largest cumulative impacts on the 

relevant and important fisheries value. The potential ACECs contain anadromous fish spawning habitat 

for spawning and rearing young. The fish populations are impacted where they are harvested 

commercially in the ocean, an indirect effect on the fisheries value. Subsistence fishing and sport fishing 

directly affect the fisheries value but are not high enough uses to affect the relevant and important 

fisheries value in any potential ACECs. 

Table 3.7.3-2 summarizes the results of the cumulative effects analysis for the potential ACECs within 

the planning area for all alternatives. 

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Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

Table 3.7.3-2: Cumulative Effects Analysis for ACECs 

Trends and Forecasts of the Trends and Forecasts of the Trends and Forecasts of the Trends and Forecasts of the 

Potential ACECs in Potential ACECs in Potential ACECs in Potential ACECs in 

Trends and Forecasts of 

the Potential ACECs in 

Consideration of Past and 

Consideration of Past, Present, 

and Reasonably Foreseeable 

Future Actions 

Consideration of Past, Present, 

and Reasonably Foreseeable 

Future Actions 

Consideration of Past, Present, 

and Reasonably Foreseeable 

Future Actions 

Consideration of Past, Present, 

and Reasonably Foreseeable 

Future Actions 

Present Actions (Alternative A) (Alternative B) (Alternative C) (Alternative D) 

There are 11 ACECs totaling 

1,884,376 acres (14 percent Alternative A continues managing 

11 ACECs totaling 1,884,376 

Current trends for cultural 

resources and fish are as 

Current trends for cultural 

resources and fish are as 

Alternative D does not designate 

ACECs. In undesignated potential 

of planning area) of BLM- acres. It does not designate new described in Alternative A. described in Alternative A. ACECs, Alternative D includes 

managed lands in the 

planning area. As three of 

these ACEC (supporting 

wildlife and ecological 

resources) were determined 

ACECs. In undesignated 

potential ACECs, Alternative A 

includes some protection from 

surface-disturbing activities. 

Alternative B designates 12 

ACECs totaling 3,912,698 acres. 

Alternative B includes the greatest 

protection from surface-disturbing 

Alternative C does not designate 

ACECs but would include some 

management actions in areas that 

would be designated as ACECs 

some protection from surfacedisturbing activities through 

designation of HVW and NTMC; 

however, the geographic extent of 

to no longer support their Trend: Fisheries resource activities. under Alternative C to minimize areas receiving these protections 

relevant or important 

nominated values, the trend 

is that these values are 

being adversely impacted. 

values in ACECs would 

continue to stabilize. 

Trend: Cultural resource 

values in ACECs would 

continue to degrade. 

Trend: Fisheries resource 

values in potential ACECs 

would continue to stabilize. 

Trend: Cultural resource values 

in potential ACECs would 

relevant and important fisheries 

and cultural values. Alternative C 

includes more protection than 

Alternative A, but less protection 

than Alternative B, from surfacedisturbing activities. 

would be less than Alternative C. 

Trend: Fish and cultural would 

continue to degrade. 

stabilize. Trend: Fisheries and cultural 

resource values would continue 

to stabilize, but in a smaller 

geographic area than

Alternative B. 

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3.8 National Trails 

3.8.1 Summary 

The Iditarod National Historic Trail (INHT) is the only national trail within the planning area and is the 

only National Historic Trail in Alaska. The BLM manages approximately 77 miles of the INHT within 

the planning area, including 20 miles known as the Farewell Burn, 35 miles between Unalakleet and 

Kaltag, and 7 miles in the Bonanza Creek area. The National Trails System is the network of scenic, 

historic, and recreation trails created by the National Trails System Act of 1968. These trails provide for 

outdoor recreation needs, promote the enjoyment, appreciation, and preservation of outdoor areas and 

historic resources, and encourage public access and citizen involvement. National historic trails (NHTs) 

are fragile nonrenewable evidence of recent human history and heritage on the landscape. They are public 

resources entrusted to the BLM for protection and interpretation, providing a context for present-day land 

use decisions. 

The INHT was designated an NHT due to its history as a trade route connector for Alaska Native villages, 

a portage during the Alaskan gold rush, and now as a travel and recreation route in contemporary Alaska. 

Its purpose is to provide an opportunity for contemporary users to experience the natural primitive 

settings and challenges experienced by gold stampeders a century ago and to test the mettle of users. 

Management under Alternatives B, C, and D is designed to support the nature and purpose of the INHT. 

Under all action alternatives, a National Trail Management Corridor (NTMC) would be established, 

consistent with BLM’s direction provided in Manual 6280 “Management of National Scenic and Historic 

Trails and Trails under Study or Recommended as Suitable for Congressional Designation” and the DOI’s 

conservation stewardship priority. ANILCA does not apply to the NTMC, as the NTMC's are a land 

management classification under this RMP, rather than an ANILCA CSU, which applies to the Primary 

Route of the INHT only. 

3.8.2 Methods of Analysis 

The analysis area is the NTMC, which includes consideration of physiographic breaks and viewsheds in 

the planning area. Existing information on national trails, including resource condition and trend, was 

reviewed and summarized in the national trail baseline analysis provided in the BSWI Draft RMP/EIS, 

Appendix M. To determine impacts from land management decisions, spatial data representing proposed 

management actions and land uses provided in each alternative were overlaid on the baseline. Where 

applicable, laws pertinent to determining effects on national trails (e.g., National Trails System Act, 

NHPA) were also considered. 

Impacts were quantified where possible; in the absence of quantitative data, a qualitative analysis was 

performed. Conclusions were based on assessment of how proposed management actions and land uses 

may affect known and potentially discoverable INHT resources. A lack of action can, in certain cases, 

result in deterioration of the trail resource. 

Direct impacts on the INHT typically result from actions that disturb the soil or alter characteristics of the 

surrounding environment. For example, surface-disturbing activities, such as OHV use, that create ruts 

are considered a direct impact because the trail has never had noticeable vehicle impacts and because ruts 

created by OHVs increase the snow depth necessary for safe passage by dog sled teams and over snow 

vehicles on the packed snow trail treadway. 

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Impacts on characteristics of the surrounding environment include visual elements that are out of 

character with, or alter, the trail’s physical, social, or administrative setting. Impacts may also include 

wildland fire damage, such as erosion or downed trees. Indirect impacts are actions that result in data 

collection and proactive preservation of NHTs (e.g., partnerships that encourage research or a greater 

understanding of the trail’s historic character). Indirect effects on the INHT could include side trail 

blockage or degradation outside the NTMC. 

The primary natural phenomena directly affecting trail resources are erosion, wildland fire, and changes 

to the length and intensity of winter weather. A number of historic roadhouses and shelter cabins 

originally located near waterways are either vulnerable to, or have been washed away by, shifting river 

and creek beds. 

Activities such as ROW authorizations that cross NHT segments or project development, such as wind 

energy or telecommunication sites, in the trail’s viewshed can contribute to a decrease in overall trail 

integrity and create a fragmented user experience. These actions may cause a change to the visual or 

historic character of the trail and possibly destroy important scientific information related to the trail. 

Federal actions defined as federal undertakings under Section 106 of the NHPA require the identification, 

evaluation, and consideration of adverse effects and the appropriate mitigation of those effects. Nearly all 

implementation actions would be subject to further cultural resource review before site-specific projects 

are authorized or implemented. If adverse effects are identified, mitigation measures, including 

avoidance, would have to be considered to minimize or eliminate the effects. 

Overall, objectives and actions associated with other resources that result in closure to surface disturbance 

activities near the INHT would be beneficial due to reduced chance of disturbance of INHT features. 

Potential Effects and Indicators 

Table 3.8.2-1 summarizes the types of effects to national trails that could result from implementation of 

the RMP along with the indicators that were used to evaluate possible impacts from the management 

actions. 

Table 3.8.2-1: Effects and Indicators for National Trails 

Types of Effects Management Actions Indicators 

ROW development and project 

development crossing the INHT 

could contribute to an overall 

decrease in trail quality by 

changing the visual and/or historic 

character of the INHT, through 

rutting and trail braiding, or by 

possibly adversely impacting 

scientific information related to the 

trail. 

• Designation of a NTMC for the INHT within the 

planning area 

• Management actions to prevent or reduce 

surface disturbance 

o Forestry and woodland harvest decisions 

o Grazing limitations 

o Minerals decisions 

o Travel and transportation management 

decisions 

• ROW development 

• Acres of the NTMC with direct or 

indirect impacts resulting in the loss 

of integrity or destruction of physical 

remnants of a trail 

• Acres of the NTMC with direct or 

indirect impacts resulting in 

“substantial interference” with the 

nature and purpose of the INHT 

Surface-disturbing activities, 

including OHV travel, activities 

within ROWs, and project 

development, could directly impact 

the INHT surface through 

waterway interception, erosion, 

and rut creation or trail braiding. 

• Designation of a NTMC for the INHT within the 

planning area 

• Management actions to prevent or reduce 

surface disturbance 

o Forestry and woodland harvest decisions 

o Grazing limitations 

o Minerals decisions 

o Travel and transportation management 

• Acres of the NTMC with direct or 

indirect impacts resulting in the loss 

of integrity or destruction of physical 

remnants of a trail 

• Acres of the NTMC with direct or 

indirect impacts resulting in 

“substantial interference” with the 

nature and purpose of the INHT 

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Types of Effects Management Actions Indicators 

decisions 

• ROW development 

Damage from wildland fire, • Authorize projects with short-term, minimal • Acres of the INHT directly or 

erosion, introduction of invasive adverse impacts on air quality indirectly affected by change in the 

plants, or downed trees could 

impact the characteristics of the 

surrounding environment by 

• Actions that prohibit the spread of nonnative 

invasive plant species 

cultural landscape that diminish the 

integrity of the trail’s historic 

character 

blocking side trail use and access 

or altering the visual character or 

vegetation composition on lands 

• Management actions to prevent or reduce 

surface disturbance 

o Forestry and woodland harvest decisions 

• Change in vegetation community 

composition (as defined by the REA) 

adjacent to and surrounding the 

trail. o Travel and transportation management 

decisions 

• Implement emergency stabilization and burned 

area rehabilitation projects after a fire 

Activities that produce noise and • Designation of a NTMC for the INHT within the • Acres of the INHT directly or 

pollution and introduce visual planning area indirectly affected by change in the 

changes could diminish the 

integrity of the INHT’s historic 

character by changing the setting 

• Authorize projects with short-term, minimal 

adverse impacts on air quality 

cultural landscape that diminish the 

integrity of the trail’s historic 

character 

and feeling of the trail. • Actions that prohibit the spread of nonnative 

invasive plant species 

• Management actions to prevent or reduce 

surface disturbance 

o Forestry and woodland harvest decisions 

o Grazing limitations 

o Minerals decisions 

o Travel and transportation management 

decisions 

• Implement emergency stabilization and burned 

area rehabilitation projects after a fire. 

• VRM decisions 

• Air safety and night lighting requirements 

• Restrictions on SRPs 

• Change in vegetation community 

composition (as defined by the REA) 

• Adverse effects on the INHT per the 

NHPA 

Assumptions 

The following assumptions were used to assess effects associated with national trails. 

• National trails and related sites are protected in accordance with federal laws (ANILCA, National 

Trails System Act, NHPA), State law, BLM regulations and policy, and interagency or 

partnership agreements. Specifically, BLM Manual 6280 states that the BLM may not permit 

proposed uses along national trails that would substantially interfere with the nature and purposes 

of the trail. 

• The BLM will follow 36 CFR 800 and Section 106 of the NHPA when addressing federal 

undertakings; therefore, adverse impacts on the INHT would be appropriately mitigated. 

• Degradation of the national trail from natural processes (e.g., erosion) will continue regardless of 

avoidance of human-caused impacts. 

• Potential impacts on an NHT and its setting from subsequent undertakings (implementation of the 

planning decisions or site-specific project proposals) require separate compliance with the NEPA 

and Section 106 of the NHPA. 

• No motorized and/or mechanical summer use historically occurred on the INHT on BLMmanaged lands in the planning area. 

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Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

• The INHT is vulnerable to effects to the integrity of the trail’s historic character. 

The effects analysis for national trails is not limited due to incomplete or unavailable information. All 

information necessary for analysis was available. 

Standard Operating Procedures and Best Management Practices 

The impact analysis below considers the SOPs and BMPs that could be implemented by the BLM. A 

comprehensive list of SOPs/BMPs pertaining to national trails is provided in the BSWI RMP/EIS. 

3.8.3 Effects Analysis 

Management actions proposed for the following resources and social and economic features would not 

result in effects on the INHT: 

• Soils 

• Water Resources and Fisheries 

• Vegetation 

• Wildlife 

• Paleontological Resources 

• Support for BSWI Communities 

• Hazardous Materials and Health and Human Safety 

Table 3.8.3-1 summarizes the potential effects of the alternatives’ management actions on the INHT 

NTMC based on the indicators. 

National Trails: Effects from Air Quality and Air Quality-related Values Management 

Actions 

There are no alternative-specific management actions for this resource; therefore, impacts from 

Alternatives B, C, and D are discussed in combination below. 

Effects under Alternative A 

Air quality along the INHT is generally good and is not influenced by large industrial facilities or 

residential emissions, as the BLM-managed portions of the trail are not located near small towns or 

villages. The exception is smoke from wildland fires during the summer months, which can temporarily 

adversely impact the nature and purpose of the INHT. Air emissions along the INHT are primarily from 

snowmobiles in the winter months from subsistence, casual use, and the Iron Dog race. Air quality and 

AQRVs were not addressed in the CYRMP or SWMFP RMP (BLM 1986a, 1981a). The BLM would 

continue to authorize projects that could result in short-term, minimal adverse impacts on air quality 

within the NTMC, impacting the physical setting of the trail. 

Effects Common to All Action Alternatives 

For all action alternatives, only projects that resulted in short-term, minimal adverse impacts on air 

quality within the NTMC would be authorized. 

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Table 3.8.3-1: Potential Effects on the INHT 

Indicators and Their 

Quantitative Measure Alternative A (acres) 

Alternative B (acres) Alternative C (acres) Alternative D (acres) 

Farewell 

Burn 

Kaltag

Portage Rohn 

Farewell 

Burn Kaltag Portage Rohn 

Farewell 

Burn 

Kaltag

Portage Rohn 

Acres of the NTMC with direct and/or indirect impacts resulting in the loss of integrity or destruction of physical remnants of a trail. 

Acres of the INHT directly or indirectly affected by change in the cultural landscape that diminish the integrity of the trail’s historic character. 

Acres of the NTMC with direct and/or indirect impacts resulting in “substantial interference” with the nature and purpose of the INHT. 

Cultural Resource Management 

Prioritize Cultural Resource 

Surveys 

No current management 46,591 241,512 0 31,367 241,512 0 31,367 241,512 0 

Designate High-priority 

Cultural Resource Areas 

No current management 46,591 241,512 0 31,367 241,512 0 31,367 241,512 0 

Visual Resource Management 

VRM I 46,9532 46,591 241,511 363 0 46,953 0 46,953 

VRM II 0 0 0.5 0 31,367 194,558 363 31,367 194,558 363 

VRM III 0 0 0 0 0 0 0 0.5 

Lands with Wilderness Characteristics 

Managed to protect 

wilderness characteristics as 

a priority over other 

resources values and 

multiple uses 

No current management 0 0 0 0 0 0 0 0 0 

Managed to emphasize other 

resource values and multiple 

uses while applying 

management restrictions to 

reduce impacts on 

wilderness characteristics 

46,591 241,512 363 31,367 241,512 363 0 0 0 

Managed to emphasize other 

resource values and multiple 

uses as a priority over 

protecting wilderness 

characteristics 

0 0 0 0 0 0 31,367 241,512 363 

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Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

Indicators and Their 

Quantitative Measure Alternative A (acres) 

Alternative B (acres) Alternative C (acres) Alternative D (acres) 

Farewell 

Burn 

Kaltag

Portage Rohn 

Farewell 

Burn Kaltag Portage Rohn 

Farewell 

Burn 

Kaltag

Portage Rohn 

Forestry and Woodland Products 

Casual Use Woodland 

Harvest by Permit Only 

All forest lands are open 

to casual, subsistence, 

and commercial timber 

harvest, except for 

92,355 acres of the 

Unalakleet Wild River 

Corridor that is closed to 

commercial woodland 

harvest 

46,591 241,512 363 31,367 241,512 363 31,367 241,512 363 

Casual Use Woodland 

Harvest without Permit 

0 0 0 0 0 0 0 0 0 

Subsistence Woodland 

Harvest by Permit Only 

46,591 241,512 363 0 0 0 0 0 0 

Subsistence Woodland 

Harvest without Permit 

0 0 0 31,367 241,512 363 31,367 241,512 363 

Non-subsistence House Log 

Harvest Prohibited 

46,591 228,116 0 31,367 188,822 0 0 0 0 

Non-Subsistence House Log 

Harvest on Case-By-Case 

Basis 

0 13,396 363 0 52,690 363 31,367 241,512 363 

Closed to Commercial 

Woodland Harvest 

46,591 241,512 363 0 46,953 0 0 0 0 

Open to Commercial 

Woodland Harvest by Permit 

Only 

0 0 0 0 51,369 363 0 0 0 

Open to Commercial 

Woodland Harvest without 

Permit 

0 0 0 0 0 0 31,367 241,512 363 

Grazing 

Potentially Open to Grazing 

on a Case-by-Case Basis 

241,512 0 0 0 0 0 0 31,367 241,512 363 

Closed to Grazing 46,9531 46,591 241,512 363 31,367 241,512 363 0 0 0 

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Indicators and Their 

Quantitative Measure Alternative A (acres) 

Alternative B (acres) Alternative C (acres) Alternative D (acres) 

Farewell 

Burn 

Kaltag

Portage Rohn 

Farewell 

Burn Kaltag Portage Rohn 

Farewell 

Burn 

Kaltag

Portage Rohn 

Minerals (Locatable and Salable) 

Withdrawn from Locatable The Unalakleet Wild 

River corridor is closed 

to locatable and salable 

minerals, including 

115,623 acres of the 

Kaltag Portage NTMC. 

The Farewell Burn area 

is closed to mining, 

except for metalliferous 

minerals. 

46,591 241,512 363 0 46,953 0 0 46,953 0 

Closed to Salable 46,591 241,512 363 0 46,953 0 0 46,953 0 

Minerals (Leasable) 

Closed to Leasing 172,156 46,591 241,512 363 0 46,953 0 0 46,953 0 

NSO Leasable 47 0 0 0 31,367 190,780 363 0 0 0 

Open to Leasing Subject to 

Standard Stipulations 

69,308 0 0 0 0 0 0 31,367 194,559 363 

Lands and Realty 

ROW Exclusion Areas No current management 46,591 241,512 363 0 0 0 0 0 0 

ROW Avoidance Areas 0 0 0 31,367 241,512 363 27,392 145,206 0 

ROW Permitted on a Caseby-Case Basis 

0 0 0 0 0 0 3,976 96,305 363 

FLPMA Withdrawals3,4 No current management 2,732 1,8975 363 2,732 1,8973 363 0 0 0 

Recreation and Visitor Services 

INHT SRMA Area No current management 46,591 241,512 363 31,367 241,512 363 31,367 241,512 363 

Travel and Transportation Management 

Summer Casual OHV Access 

Prohibited 

All lands are 

undesignated 

46,591 241,512 363 31,367 194,558 0 31,367 194,558 0 

Summer Subsistence OHV 

Access Prohibited 

46,591 194,558 363 31,367 194,558 363 0 0 0 

Summer Casual OHV Access 

Limited to Existing Trails6 

0 0 0 0 46,953 363 0 46,953 0 

Summer Casual CrossCountry Summer OHV 

0 0 0 0 0 0 0 0 363 

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Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

Indicators and Their 

Quantitative Measure Alternative A (acres) 

Alternative B (acres) Alternative C (acres) Alternative D (acres) 

Farewell 

Burn 

Kaltag

Portage Rohn 

Farewell 

Burn Kaltag Portage Rohn 

Farewell 

Burn 

Kaltag

Portage Rohn 

Access 

Summer Subsistence OHV 

Access Limited to Existing 

Trails6 

0 46,953 0 0 0 363 31,367 194,558 0 

Summer Subsistence Cross 

Country OHV Access 

0 0 0 0 46,953 0 0 46,953 363 

Winter Casual Use – 

Snowmobiles Only 

46,591 241,512 363 31,367 241,512 363 31,367 241,512 363 

Winter Subsistence Use – 

Snowmobiles Only 

46,591 241,512 363 31,367 241,512 363 31,367 241,512 363 

Areas of Critical Environmental Concern 

NTMC overlap with ACECs 141,178 46,590 188,822 0 0 0 0 0 0 0 

National Trails 

Establish the INHT NTMC 

within the Planning Area 

No NTMC designated 46,591 241,512 363 31,367 241,512 363 31,367 241,512 363 

Lighting in the INHT NTMC 

Viewshed 

No current management Do not allow structures that require air 

safety lighting in the NTMC 

Require hooded surface lighting 

Same as Alternative B Structure lighting restrictions determined on a 

case-by-case basis 

Wild and Scenic Rivers 

WSR Eligible 30,1022 0 0 0 0 0 0 0 0 0 

WSR Recommended 

Suitable 

0 25,090 5,012 0 0 0 0 0 0 0 

WSR Designated 46,9531 0 46,953 0 0 46,953 0 0 46,953 0 

Total Acres of the INHT Directly or Indirectly Affected by Climate Change 

Change in Vegetation 

Community Composition (as 

defined by the REA) 

No available data 24,425 126,332 191 16,336 126,332 191 16,336 126,332 191 

1

The proposed Kaltag Portage NTMC overlaps 46,953 acres of the Unalakleet Wild River Corridor. 2

The proposed Kaltag Portage and Farewell Burn segments of the INHT NTMC overlap with 30,102 acres of eligible WSR corridors. 3

1,000-foot-wide buffer centered on the existing INHT treadway. 4 Establish new FLMPA withdrawals (subject to ANILCA section 1326[a]) for salable, locatable, and leasable minerals for a 1,000-foot-wide buffer centered on the existing INHT treadway. 5

Outside the Unalakleet Wild River Corridor withdrawal. 6

Does not include the INHT which is a winter only trail. 

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Effects under Alternative B 

Under Alternative B, authorizing projects that would not cause more than short-term, minimal adverse 

impacts on air quality would provide air quality protections on 288,466 acres (corresponding to the 

NTMC) more than under Alternative A. Preserving air quality along the INHT would maintain the nature 

and purpose of the INHT. 

Effects under Alternative C 

Under Alternative C, authorizing projects that would not cause more than short-term, minimal adverse 

impacts on air quality would provide air quality protections on 272,242 acres (corresponding to the 

NTMC) more than Alternative A. However, Alternative B would provide 16,224 additional acres of 

protection above Alternative C. Preserving air quality along the INHT would maintain the nature and 

purpose of the INHT. 

Effects under Alternative D 

Effects to air quality would be the same as discussed under Alternative C. 

National Trails: Effects from Nonnative Invasive Species Management Actions 

The BLM would continue to require the use of certified weed-free straw as part of permit requirements 

for use of BLM facilities and immediate removal or destruction (by fire) after its use. There are no 

alternative-specific management actions for this resource; therefore, impacts from Alternatives B, C, 

and D are discussed in combination below. 

Effects under Alternative A 

Nonnative invasive plant species have been observed at Rohn and a few other public shelter cabins. The 

nonnative invasive plant species were likely transported in hay used as bedding for sled dogs during the 

Iditarod Trail Sled Dog Race. The BLM has inventoried the extent of invasive colonization along the 

BLM segments of the INHT, undertaken control efforts, and is monitoring the effectiveness of such 

efforts (Flagstad and Cortes-Burns 2010; Greenstein 2013). Continued colonization by nonnative species 

could diminish the landscape character surrounding the INHT and diminish the integrity and the nature 

and purpose of the INHT. The integrity of the trail would be affected because invasive plants change the 

plant communities around the NTMC and other areas along the trail, which leads to a degradation of the 

historic viewshed. 

Effects Common to All Action Alternatives 

Under all action alternatives, the BLM would cooperate with other agencies and landowners in the 

prioritization of treatment areas with known infestations of nonnative invasive plant species, including the 

INHT NTMC. This action would increase nonnative invasive plant species protection for 288,466 acres 

under Alternative B and 272,242 acres for Alternatives C and D, compared with no such direct 

protections under Alternative A. The proposed NNIS management protocol for the NTMC would limit 

the spread of NNIS along the NTMC and maintain habitat condition and landscape character surrounding 

the INHT, thereby preserving the integrity, nature, and purpose of the INHT. Therefore, Alternatives B, 

C, and D would have a beneficial, long-term effect on the INHT. 

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National Trails: Effects from Wildland Fire Management Actions 

There are no alternative-specific management actions for this resource; therefore, impacts from 

Alternatives B, C, and D are discussed in combination below. 

Effects under Alternative A 

The BLM manages wildland fire in the planning area according to the goals and objectives of the 2005 

wildland fire land use plan amendment environmental assessment (BLM 2005). Management includes 

preserving cultural sites such as the historic cabins associated with the INHT but does not specify fuels 

reduction and management around cultural sites. Allowing natural wildland fire maintains the natural 

landscape, which maintains the landscape character surrounding the INHT and maintains the integrity, 

nature, and purpose of the INHT. 

Effects Common to All Action Alternatives 

Under all action alternatives, the BLM would prioritize protection of the historic, eligible roadhouses of 

the INHT NTMC, public shelter cabins, and the Rohn Site. Fuels reduction efforts would provide 

additional protection for the historically important structures and the public facilities associated with the 

INHT. Protection would include fuels reduction through prescribed burns and chemical or manual 

disposal. Fire suppression and fuels reduction would decrease the risk to the historic structures and public 

shelter cabins along the INHT. Fuels reduction projects and prescribed fire are subject to project-level 

analysis and NHPA Section 106 process. Any effects could be mitigated to minimize adverse effects on 

the INHT or associated sites. 

Fire management could involve surface-disturbing activities that could also directly affect the INHT’s 

footprint and associated sites by erasing ruts created by sleds and altering the surrounding landscape. All 

fire management within the INHT NTMC would be implemented without OHVs, heavy equipment, or 

other surface-disturbing vehicles. Prohibiting the use of surface-disturbing vehicles in the NTMC would 

limit damage to the INHT and preserve the visual integrity of the trail corridor. However, these limits to 

suppression could put the INHT and the surrounding landscape at a greater risk of impact from wildland 

fire. 

After a fire, the BLM would implement emergency stabilization and burned area rehabilitation projects. 

These projects would stabilize soils, reestablish hydrologic function, maintain and enhance biological 

integrity, promote plant resiliency, limit expansion or dominance of invasive species, and reestablish 

native species. Rehabilitation and restoration of burned areas would support the restoration of the scenic 

and historic conditions within the INHT NTMC after fires. However, short-term impacts would visually 

impact the visual integrity of the trail corridor. 

National Trails: Effects from Cultural Resources Management Actions 

There are no alternative-specific management actions for this resource; therefore, impacts from 

Alternatives B, C, and D are discussed in combination below. 

Effects under Alternative A 

Portions of the INHT, including the Kaltag Portage, have historically been used by Alaska Native people 

and during the gold rush to transport goods and people. The Kaltag Portage provided a vital link from the 

rivers of interior Alaska to the Bering Sea coast used for thousands of years by Native peoples, as well as 

early Euroamerican explorers. 

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Currently, the BLM requires NHPA Section 106 consultation for any project that would impact the 

cultural and historical sites associated with the INHT. If adverse effects are identified, mitigation 

measures, including avoidance, would have to be considered to minimize or eliminate the effects. Actions 

for cultural resource protection would support maintaining the character, integrity, nature, and purpose of 

the INHT. 

Effects Common to All Action Alternatives 

Under the action alternatives, the BLM would continue to require NHPA Section 106 consultation for all 

individual projects and require mitigation measures for any adverse effects. In addition, all action 

alternatives would prioritize cultural resource surveys currently at risk from climate change (BSWI Draft 

RMP/EIS, Appendix H and M), including the Farewell Burn and Kaltag Portage NTMCs. These surveys 

would provide additional information regarding the cultural resources in the NTMCs and provide 

additional information for NHPA Section 106 consultation for proposed projects in the NTMCs. In 

addition, the BLM would categorize the Kaltag Portage and Farewell Burn NTMCs and their associated 

resources as high-priority cultural resource protection areas. These actions would increase cultural 

resource protection for 288,103 acres under Alternative B and an additional 272,879 acres for 

Alternatives C and D, compared with Alternative A (Table 3.8.3-1), and would maintain the integrity, 

nature, and purpose of the trail. Collectively, these actions would be considered beneficial impacts to the 

INHT. 

National Trails: Effects from Visual Resources Management Actions 

In addition to management actions common to all action alternatives, potential impacts from the 

following management topic were considered: 

• VRM Classification 

Effects under Alternative A 

The CYRMP or SWMFP RMP (BLM 1986a, 1981a) does not prescribe VRM classes to the majority of 

the INHT NTMC; therefore, no indirect protection from VRM management would occur. The BLM 

manages the Unalakleet Wild River Corridor as VRM Class I, which includes 46,953 acres of the 

proposed Kaltag Portage NTMC area. This designation preserves the existing character of the landscape 

for that portion of the NTMC. Visual impacts on the setting of the INHT would be considered in the 

NHPA Section 106 process, regardless of VRM designation. 

Effects under Alternative B 

Alternative B would designate the NTMCs as VRM Class I, except for 0.5 acre of the Kaltag Portage 

NTMC, which would be managed as VRM Class II. This action would improve visual protection 

compared with Alternative A by designating 241,513 more acres as VRM Class I. Alternative B would 

provide the strictest visual protection of the INHT NTMC; this alternative would preserve the existing 

character of the landscape and maintain the isolated and primitive nature of the trail. Visual impacts on 

the setting of the INHT would be considered in the NHPA Section 106 process, regardless of VRM 

designation. 

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Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

Effects under Alternative C 

Alternative C would designate 226,289 acres of the NTMCs as VRM Class II, which would provide 

visual protection of 226,289 acres that are currently undesignated. Alternative C would maintain 

protection of 46,953 acres of the Unalakleet Wild River corridor as VRM Class I, the same as currently 

managed as VRM Class I under Alternative A. The VRM Class II management objective is to retain the 

existing landscape character; management activities may be seen but should not attract the attention of the 

INHT user. This action would preserve the user experience and maintain the integrity, nature, and purpose 

of the INHT. Visual impacts on the setting of the INHT would be considered in the NHPA Section 106 

process, regardless of VRM designation. 

Effects under Alternative D 

Alternative D is the same as Alternative C, except that 0.5 acre of the Kaltag Portage NTMC would be 

managed as VRM Class III. Impacts would be the same as those described under Alternative C. 

National Trails: Effects from Lands with Wilderness Characteristics Management Actions 

In addition to management actions common to all action alternatives, potential impacts from the 

following management topic were considered: 

• Lands managed to protect wilderness characteristics as a priority over other resources values and 

multiple uses 

Effects under Alternative A 

No lands are managed to protect wilderness characteristics, which would not provide additional protection 

for the NTMC and maintain the risk for disturbance from OHV use or surface-disturbing activities. 

Effects under Alternative B 

Under Alternative B, the proposed NTMC would be managed as lands with wilderness characteristics 

managed to emphasize other resource values and multiple uses while applying management restrictions to 

reduce impacts on wilderness characteristics (Table 3.8.3-1). This designation would provide some 

management at the implementation level that would avoid or minimize impacts to the integrity, nature, 

and purpose of the INHT. However, those management actions would be identified as part of 

implementation. 

Effects under Alternative C 

Under Alternative C, impacts would be similar to those under Alternative B, except the NTMCs classified 

as lands with wilderness characteristics would total 273,242 acres (Table 3.8.3-1), which is 15,224 acres 

fewer than under Alternative B. However, this alternative would provide some management to 273,242 

acres that would have no protections associated with lands with wilderness characteristics under 

Alternative A. 

Effects under Alternative D 

Alternative D would not recommend any management specifically to prevent or minimize impacts to 

wilderness characteristic within the planning area, which would not provide additional protection for the 

NTMC and would maintain the risk for disturbance from OHV use or surface-disturbing activities. 

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National Trails: Effects from Forestry and Woodland Products Management Actions 

In addition to management actions common to all action alternatives, potential impacts from the 

following management topics were considered: 

• Casual Use Woodland Harvest by Permit Only 

• Casual Use Woodland Harvest without Permit 

• Subsistence Woodland Harvest by Permit Only 

• Subsistence Woodland Harvest without Permit 

• Non-Subsistence House Log Harvest Prohibited 

• Non-Subsistence House Log Harvest on Case-By-Case Basis 

• Closed to Commercial Woodland Harvest 

• Open to Commercial Woodland Harvest by Permit Only 

• Open to Commercial Woodland Harvest without Permit 

Effects under Alternative A 

All lands along the INHT are open to casual, subsistence, and commercial woodland harvest, except for 

92,355 acres of the proposed Kaltag Portage NTMC that overlaps the current Unalakleet Wild River 

Corridor, where commercial woodland harvest is prohibited. The INHT and adjacent lands are unaffected 

by current casual, subsistence, and commercial harvesting because the BLM-managed portions of the 

INHT are not proximate to the villages and populated areas where these activities generally occur. 

Effects under Alternative B 

Alternative B would require individuals to obtain permits for casual and non-commercial woodland 

harvesting within the proposed NTMCs. This action would impose controls on harvesting in the INHT 

NTMC (288,466 acres), compared with Alternative A. In addition, Alternative B would prohibit nonsubsistence house log harvesting on 46,591 acres of the Farewell Burn NTMC and 228,116 acres of the 

Kaltag Portage NTMC, which would restrict house log harvesting on 274,707 acres, compared with 

Alternative A. Alternative B would also prohibit commercial harvesting in the INHT NTMC, thereby 

removing an additional 196,111 acres from potential commercial harvest compared with Alternative A 

(Table 3.8.3-1). 

Controls on casual, subsistence, and commercial harvesting would reduce the potential direct and indirect 

impacts on the three proposed NTMCs, compared with Alternative A. Management actions under 

Alternative B are intended to prevent woodland harvest activities near the trail that could adversely affect 

the viewshed, thereby preserving the physical characteristics and historical integrity of the trail. The 

Kaltag Portage NTMC contains several forested sections of low timber value. Alternative B would 

require permits prior to any casual or subsistence harvesting from the NTMC, which is intended to 

prevent clear cutting or overharvesting near the trail, which would adversely impact the viewshed and 

historical integrity of the trail. The Farewell Burn NTMC is distant from villages and populated areas and 

is not used for subsistence harvesting as much as the Kaltag Portage. The Rohn Site is used primarily for 

purposes other than harvesting with the air strip and public shelter cabin providing heavier use than the 

other NTMCs. Management under Alternative B would preserve the integrity, nature and purpose of the 

INHT. 

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Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

Effects under Alternative C 

Alternative C would require individuals to obtain permits for casual woodland harvesting within the three 

proposed NTMCs but would allow subsistence harvesting without a permit in the NTMCs. This action 

would impose controls on casual woodland harvesting on 273,242 acres, compared with Alternative A. In 

addition, Alternative C would prohibit non-subsistence house log harvesting on 31,367 acres of the 

Farewell Burn NTMC and 188,822 acres of the Kaltag Portage NTMC, which would restrict house log 

harvesting on 220,189 acres, compared with Alternative A. Alternative C would prohibit commercial 

harvesting on 46,953 acres of the Kaltag Portage NTMC and require permits for commercial harvesting 

on the remainder of the NTMC. 

Restrictions on casual and commercial harvesting would maintain low levels of direct and indirect 

impacts on the three proposed NTMCs, compared with Alternative A. However, current impacts from 

casual and commercial harvesting are low within the three NTMCs. Subsistence harvesting would 

continue with the Kaltag Portage NTMC. Management under Alternative C would preserve the integrity, 

nature, and purpose of the INHT. 

Effects under Alternative D 

Alternative D would require individuals to obtain permits for casual woodland harvesting within the three 

proposed NTMCs but would allow subsistence harvesting without a permit in the NTMCs. This would 

restrict casual woodland harvesting on 273,242 acres, compared with Alternative A. Issuing permits for 

wood cutting in the NTMC is intended to reduce clear cutting or overharvesting near the trail, which 

would adversely impact the viewshed and historical integrity of the trail, thereby providing some 

protection of the physical characteristics and historical integrity of the trail. Alternative D would not 

restrict non-subsistence house log harvest or commercial woodland harvest, which would decrease 

protection on 92,355 acres, compared within Alternative A (Table 3.8.3-1). 

Alternative D would restrict casual woodland harvesting within the NTMCs compared with Alternative A 

but allow non-subsistence house log harvest and commercial woodland harvest throughout the NTMCs. 

This would increase the potential for direct and indirect impacts on the NTMCs from heavy equipment 

and loss of forested lands adjacent to the INHT. However, the probability for commercial woodland 

harvest adjacent to the INHT is low due to the isolated nature of the three NTMCs. Due to the remoteness 

of the NTMCs, the likelihood for Alternative D to substantially interfere with the integrity, nature, and 

purpose of the INHT is low. 

National Trails: Effects from Grazing Management Actions 

In addition to management actions common to all action alternatives, potential impacts from the 

following management topics were considered: 

• Areas Closed to Grazing 

• Areas Open to Grazing on a Case-by-case Basis 

Effects under Alternative A 

BLM policy has been to provide grazing leases for domestic livestock including reindeer and musk oxen 

where feasible. Currently, the only permitted grazing range within the planning area is in a northern 

portion of the planning area in the Sagoonick Area (see BSWI Draft RMP/EIS Map 3.3.2-1). The 

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Appendix N: Supplemental Impact Analysis Information Section 3: Supplemental Impact Analysis 

proposed NTMCs are currently open to grazing, except for 46,953 acres of the proposed Kaltag Portage 

NTMC that overlaps the current Unalakleet Wild River Corridor. 

Map 3.3.2-2 of the BSWI Draft RMP/EIS indicates high lichen cover near the mouth of the Unalakleet 

River, and vegetation mapping identifies 42,753 acres of lichen and/or dwarf shrub habitat in the 

proposed Kaltag Portage NTMC, which is considered general caribou habitat. Grazing has not occurred in 

this area of caribou habitat within the NTMC since before World War II, and no grazing permits have 

been requested for this area recently. Allowing grazing adjacent to the INHT could impact the integrity of 

the INHT by concentrating grazing use in localized areas, which can result in eroded soil, vegetation 

cover reduction, rutting, increased erosion, and other landscape changes that would affect the INHT. 

Grazing would occur in the summer months; because grazing is not considered a historic use of the INHT, 

there would be impacts on the visual and historic quality of the landscape. 

Effects under Alternative B 

Under Alternative B, the BLM would manage 288,466 acres of the proposed NTMC as unavailable to 

grazing, an increase of 241,513 acres closed to grazing from Alternative A (Table 3.8.3-1). Potential 

grazing impacts would be prevented under Alternative B, as there would be no acres of the NTMC open 

to grazing; current trail conditions would be maintained. Benefits of reduced grazing on the INHT would 

include less potential for long-term aesthetic changes from overgrazing and the effects of the use of 

summer OHV’s on NTMC lands. 

Effects under Alternative C 

Under Alternative C, the BLM would manage 273,242 acres of the NTMC as unavailable to grazing, a 

decrease of 15,224 acres closed to grazing from Alternative B (Table 3.8.3-1). There would be no acres of 

the NTMC open to grazing under Alternative C. Effects from livestock grazing management on the INHT 

would be the same as those described under Alternative B but would occur over a slightly smaller area. 

Effects under Alternative D 

Under Alternative D, all lands within the planning area would be open to grazing on a case-by-case basis. 

This includes the 46,953 acres currently closed to grazing as part of the Unalakleet Wild River Corridor 

under Alternative A. However, grazing would be permitted in the INHT NTMC only if it is determined 

that the proposed permitted grazing is consistent with maintenance of the historical and cultural setting of 

the INHT NTMC. The probability of grazing within the INHT NTMC is low due to the remote nature of 

the trail, including the Kaltag Portage NTMC. Due to the remoteness of the NTMCs, the likelihood for 

livestock grazing under Alternative D to substantially interfere with the integrity, nature, and purpose of 

the INHT is low. 

National Trails: Effects from Locatable and Salable Minerals Management Actions 

In addition to management actions common to all action alternatives, potential impacts from the 

following management topics were considered: 

• Locatable Mineral Exploration 

• Salable Mineral Development 

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Effects under Alternative A 

Lands within the Unalakleet Wild River Corridor are closed to all mineral entry, which includes a portion 

of the Kaltag Portage NTMC (BSWI Draft RMP/EIS Map 3.3.5-1). Potential for locatable or salable 

minerals adjacent to the INHT is low due to low potential for minerals (Map 3.3.3-3) and distance from 

markets. Currently, the NTMC is not impacted by any mineral exploration or extraction but is open to 

mineral extraction for those areas outside of the Unalakleet Wild River Corridor. Mineral exploration or 

extraction could impact the integrity, nature, and purpose of the trail through surface disturbance, 

viewshed, and noise-related impacts. However, the potential for these impacts is low due to low mineral 

potential in areas crossed by the NTMC. 

Effects under Alternative B 

All three INHT NTMC units would be withdrawn from locatable mineral exploration and development 

and closed to salable mineral development through retaining existing withdrawals and new proposed 

withdrawals. This action would withdraw an additional 172,843 acres from mineral exploration and 

extraction, compared with Alternative A (Table 3.8.3-1). Excluding these areas from mineral exploration 

and development would prevent new surface disturbance along the INHT within the NTMC, prevent 

indirect impacts within the NTMC, such as noise pollution and visual impacts, and preserve the integrity, 

nature, and purpose of the trail. However, due to the remoteness of the NTMC and because there are no 

areas of medium or high mineral potential within or adjacent to the INHT NTMC, there is low potential 

for impact from mineral development under to substantially interfere with the integrity, nature, and 

purpose of the INHT. 

Effects under Alternative C 

As discussed in Alterative B, due to the remoteness of the NTMC and because there are no areas of 

medium or high mineral potential within or adjacent to the INHT NTMC, there is low potential for impact 

from mineral development under to substantially interfere with the integrity, nature, and purpose of the 

INHT. 

Effects under Alternative D 

As discussed in Alterative B, due to the remoteness of the NTMC and because there are no areas of 

medium or high mineral potential within or adjacent to the INHT NTMC, there is low potential for impact 

from mineral development under to substantially interfere with the integrity, nature, and purpose of the 

INHT. 

National Trails: Effects from Leasable Minerals Management Actions 

In addition to management actions common to all action alternatives, potential impacts from the 

following management topics were considered: 

• Closed to Leasing 

• NSO Leasable 

• Open to Leasing Subject to Standard Stipulations 

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Effects under Alternative A 

There is low potential for coal, coalbed natural gas, and oil and gas development within the planning area 

due to the low grade of materials, lack of infrastructure, and high cost to develop. The Unalakleet Wild 

River Corridor is closed to leasing and includes a large portion of the proposed Kaltag Portage NTMC 

(172,156 acres). To date, the INHT has not been impacted by leasable mineral exploration or extraction; 

however, the proposed Farewell Burn and Rohn NTMCs and portions of the Kaltag Portage NTMC are 

open to leasing with standard stipulations. 

Effects Common to All Action Alternatives 

The INHT NTMC is excluded from coal extraction because coal leases shall not be issued on federal 

lands within the National System of Trails (see BLM M5280 42. E.6.i). This restriction would protect the 

INHT from any impacts associated with coal extraction. 

Leasable mineral actions would be managed with noise and atmospheric guidelines that would maintain 

the current remote and isolated trail experience and maintain the integrity, nature, and purpose of the 

INHT. 

Effects under Alternative B 

Alternative B would close the proposed NTMCs to leasing (Table 3.8.3-1), which would close 116,310 

more acres to leasing than Alternative A. Alternative B would prevent impacts on the INHT NTMC from 

leasable mineral development, thereby preserving the integrity, nature, and purpose of the INHT. 

Effects under Alternative C 

Alternative C would apply NSO restrictions to leasable mineral development within the Farewell Burn 

NTMC (31,367 acres), the Rohn NTMC (363 acres), and 190,780 acres of the Kaltag Portage NTMC. 

The remainder of the Kaltag Portage NTMC is within the proposed Unalakleet Wild River Corridor 

(46,953 acres) and would be closed to leasing (Table 3.8.3-1). 

Alternative C would apply NSO restrictions to leasable mineral development on 222,510 acres, including 

20,693 acres of the Kaltag Portage NTMC that was not protected under current leasing restrictions for the 

Unalakleet Wild River Corridor. This action would increase protection of those portions of the INHT 

NTMC and prevent surface disturbance to the NTMC from leasable mineral development as compared to 

Alternatives A and B. Alternative C would prohibit surface disturbance within the NTMC from leasable 

mineral development but would allow disturbance adjacent to the NTMC. Adjacent disturbance could 

result in noise or viewshed (setting) impacts to the trail, but would not substantially interfere with the 

integrity, nature, and purpose of the INHT. 

Effects under Alternative D 

Alternative D would close the portion of the Kaltag Portage NTMC within the Unalakleet Wild River 

Corridor to leasable mineral development (46,953 acres) and allow development with standard 

stipulations on 226,289 acres. This action would open an additional 226,289 acres to leasable 

development compared with all other alternatives. Leasable mineral development within the INHT 

NTMCs would change the landscape around the INHT, potentially adversely impact the trail, and alter the 

user experience as a result of noise or viewshed-related impacts. The NTMCs are in remote areas with a 

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lack of existing infrastructure, but the potential to substantially interfere with the integrity, nature, and 

purpose of the INHT exists. 

National Trails: Effects from Lands and Realty Management Actions 

In addition to management actions common to all action alternatives, potential impacts from the 

following management topics were considered: 

• ROW Exclusion Areas 

• ROW Avoidance Areas 

• ROW Permitted on a Case-by-Case Basis 

• FLPMA Withdrawals 

• Rohn Conveyance 

Effects under Alternative A 

Alternative A would allow ROW development within the proposed INHT NTMCs and allow surface 

disturbance and development adjacent to the INHT. New ROWs could directly and indirectly alter the 

unique visual and historic characteristics of the NTMC and could substantially interfere with the integrity, 

nature, and purpose of the INHT. 

Effects Common to All Action Alternatives 

INHT inholdings where no NHT easement reservation exists would be acquired from willing sellers 

(easement only or entire parcel if the surrounding lands are in federal ownership). Acquiring INHT 

inholdings from willing sellers would increase the continuity of BLM management; preserve the integrity, 

nature, and purpose of the INHT; and maintain the user experience resulting in long-term, beneficial 

impacts to the INHT. 

Effects under Alternative B 

Compared with Alternative A, management under Alternative B would decrease the potential impacts 

from new ROW development along the INHT. The three geographic units (Farewell Burn, Kaltag 

Portage, and Rohn; 288,466 acres) would be managed as ROW exclusion areas (Table 3.8.3-1), compared 

with no ROW exclusion areas in Alternative A. Excluding new ROW development would minimize 

changes to the unique visual and historic qualities of the INHT and potential for project-level noise 

impacts resulting in long-term, beneficial impacts to the INHT. 

Alternative B would also retain the Rohn parcel as an NTMC under BLM management. This would retain 

one of the most heavily used sites on the INHT currently under BLM management and ensure the 

integrity of the site under its protection as a NTMC. The BLM would pursue opportunities to acquire 

lands or public use easements within the INHT NTMC to support the goals and objectives of the NTMC, 

which would enhance the user experience by providing consistent management to large portions of the 

INHT where possible. 

Effects under Alternative C 

The INHT NTMC would be managed as a ROW avoidance area, which would provide additional 

protection of 273,242 acres, compared with Alternative A. Avoiding new ROW development would 

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minimize changes to the unique visual and historic qualities of the INHT and potential for project-level 

noise impacts. The BLM would pursue opportunities to acquire lands or public easements within the 

INHT NTMC as described under Alternative B and with similar impacts. 

Effects under Alternative D 

Under Alternative D, the BLM would grant ROWs within the proposed NTMCs on a case-by-case basis, 

similar to current management under Alternative A. 

National Trails: Effects from Recreation and Visitor Services Management Actions 

In addition to management actions common to all action alternatives, potential impacts from the 

following management topics were considered: 

• INHT SRMA 

• SRPs 

• BLM INHT Public Shelter Cabin Use 

Effects under Alternative A 

While the INHT Comprehensive Management Plan (BLM 1986b) guides BLM’s management of the trail, 

the plan does not establish a management corridor. Without a defined management corridor, it is difficult 

to evaluate the potential effects of management actions surrounding the trail. The BLM issues SRPs for 

races and other uses along the INHT, and those requests have been increasing over the past 10 years. The 

increase in permit requests requires management controls to reduce recreation conflicts. The increase in 

SRP requests for the INHT potentially impacts the user experience on the trail with overcrowded 

conditions, vague management controls that do not afford specific protections, and degradation to the trail 

surface. Given the current trend, Alternative A could adversely impact the user experience, trails setting, 

and could substantially interfere with the integrity, nature, and purpose of the INHT. 

Effects Common to All Action Alternatives 

All action alternatives establish the INHT SRMA for the three proposed NTMCs. For all action 

alternatives, INHT SRMA management controls would include, but not be limited to: limits to group size, 

limits to duration of stay, waste management (human and litter), and permitted activities and commercial 

filming. Dispersed recreation uses would be lightly managed, with little to no cost to the public. 

Effects under Alternative B 

Alternative B allows for casual use of the Rohn Public Shelter Cabin even when occupied by an SRP 

permittee. It would also restrict wood gathering to dead and down wood. Alternative B prohibits 

commercial trapping or guide outfitters from using the public cabin. Restrictions under Alternative B 

would preserve the remote and isolated user experience on the trail resulting in long-term, beneficial 

impacts to the INHT. 

Effects under Alternative C 

Effects of Rohn Public Shelter Cabin guidelines would be the same as those described under 

Alternative B. 

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Effects under Alternative D 

Alternative D allows for the exclusive use of the Rohn Public Shelter Cabin by SRP permittees, which 

would prevent the casual user from using the public shelter cabin during use of the trail at certain times of 

the year. This could impact the remote and isolated casual user by creating a potentially dangerous 

experience due to the possibility of exposure to extreme weather. As a result, some casual users may 

choose not to use the trail for recreation during the time when cabins are off-limits, which could impact 

the nature and purpose of the INHT. 

National Trails: Effects from Travel and Transportation Management Actions 

In addition to management actions common to all action alternatives, potential impacts from the 

following management topics were considered: 

• Summer Casual OHV Access Prohibited 

• Summer Subsistence OHV Access Prohibited 

• Summer Casual OHV Access Limited to Existing Trails 

• Summer Subsistence OHV Access Limited to Existing Trails 

• Winter Casual Use – Snowmobiles Only 

• Winter Subsistence Use – Snowmobiles Only 

Effects under Alternative A 

All lands within the planning area are managed as undesignated, which allows unrestricted OHV use 

within the proposed NTMCs in summer and winter months. One exception is the portion of Kaltag 

Portage that intersects with the Unalakleet Wild River Corridor which would be closed to casual OHV 

travel. Due to the predominance of wetlands in the area, the INHT is highly susceptible to damage from 

OHV traffic in the summer months due to rutting and erosion. Most, but not all, INHT sections managed 

by the BLM are far from villages and other population bases and show no signs of summer damage but 

remain vulnerable to future impacts. 

In addition, current regulations do not limit the size and weight of OHVs allowed on the trail. New 

technology is developing larger, wider vehicles that can traverse the trail in summer and winter months. 

These larger, heavier vehicles have the potential to create deeper and wider ruts in the trail that increase 

erosion and interfere with users who require a single-lane, snow-packed treadway in the winter. 

With diminishing annual snow, local planning area residents are increasingly using OHVs year-round to 

drive on frozen tundra or waterways, as well as community roads. Such OHVs also have the potential to 

create a substantial hazard (via the creation of parallel ruts) to other trail users who rely on a single-lane 

packed treadway. In addition, noise generated by OHVs interferes with the remote and isolated nature of 

the trail. Increased OHV use during the winter and summer months could interfere with the user 

experience due to increased noise levels. 

Effects Common to All Action Alternatives 

All action alternatives would designate the proposed NTMCs as “Limited” to motorized travel and 

designate the INHT NTMC as a TMA. Identification of specific limitations within the “Limited” 

designation (e.g., vehicle weight, vehicle width) are implementation-level planning decisions and would 

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be developed as part of a travel and transportation plan that would be completed by the BLM subsequent 

to this RMP. Implementation-level planning decisions could prohibit the use of larger, heavier vehicles on 

the INHT. 

All action alternatives would limit casual and subsistence use to the use of snowmobiles only on the 

NTMC during winter months. New technologies are developing larger and heavier summer OHVs 

capable of travel in winter conditions. There is no historic precedent for the use of these vehicles on the 

INHT, and their use may result in substantial changes to the nature of the trail, primarily from trail tread 

widening and corridor vegetation clearing. Prohibiting these vehicles would prevent rutting along the 

trails for trail users who rely on a single-lane, snow-packed treadway. 

The BLM would monitor winter casual and subsistence OHV use in the INHT NTMC. If the use results 

in degradation of the resources or prevents trail management that meets requirements of the National 

Trails System Act, then casual and subsistence winter OHV travel would be prohibited in affected areas. 

Effects under Alternative B 

Alternative B would prohibit summer casual OHV use within the three proposed NTMCs and prohibit 

summer subsistence OHV use within the Farewell Burn and Rohn NTMCs and 194,558 acres of the 

Kaltag Portage NTMC. The remaining 46,953 acres within the proposed Unalakleet Wild River Corridor 

would be restricted to existing trails and to ATVs only. This action would restrict OHV use in 241,512 

acres compared with Alternative A and maintain the integrity of winter trail surfaces from summer 

damage to the INHT during the vulnerable summer months. The Kaltag Portage NTMC is located 

adjacent to the Unalakleet River. This section would be most vulnerable to summer subsistence OHV use 

and difficult to traverse in the summer months due to extensive wetlands and waterways. 

Effects under Alternative C 

Alternative C would prohibit summer casual OHV access within the Farewell Burn NTMC and 194,558 

acres of the Kaltag Portage NTMC; 46,953 acres of the Kaltag NTMC and the Rohn NTMC would be 

restricted to existing trails for summer casual OHV access and with only ATVs. This action would restrict 

summer casual OHV access on 273,242 acres compared with Alternative A and protect the INHT during 

the vulnerable summer months. Casual OHV use on existing trails would potentially impact the Kaltag 

Portage portion of the INHT; however, summer use is limited due to extensive wetlands and waterways. 

Alternative C would prohibit summer subsistence OHV access on the Farewell Burn segment of the 

INHT NTMC and 194,558 acres of the Kaltag Portage segment; the Rohn NTMC would be open to 

summer subsistence OHV travel on existing trails only. A total of 46,953 acres of the Kaltag NTMC 

would be open to unrestricted summer subsistence OHV access with only ATVs. This would restrict 

subsistence OHV access on 273,242 acres compared with Alternative A and protect the INHT during the 

vulnerable summer months. Unlimited subsistence OHV use on the Kaltag Portage would pose a risk to 

the INHT, but current travel is almost non-existent in the summer months due to extensive wetlands and 

waterways. 

Effects under Alternative D 

Alternative D would prohibit summer casual OHV access within the Farewell Burn NTMC and 194,558 

acres of the Kaltag Portage NTMC; 46,953 acres of the Kaltag Portage NTMC would be restricted to 

existing trails for summer casual OHV access. Casual OHV use on existing trails would potentially 

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impact the Kaltag Portage portion of the INHT; however, summer use is limited due to extensive 

wetlands and waterways. 

Alternative D would limit summer subsistence OHV access to existing trails on the Farewell Burn NTMC 

and 194,558 acres of the Kaltag Portage NTMC with only ATVs. A total of 46,953 acres of the Kaltag 

Portage NTMC would be open to unrestricted summer subsistence OHV access with ATVs and UTVs. 

This would restrict subsistence OHV access on 225,925 acres compared with Alternative A and protect 

portions of the INHT during the vulnerable summer months. Unlimited subsistence OHV use on the 

Kaltag Portage NTMC would pose a risk to the INHT, but current travel is almost non-existent in the 

summer months due to extensive wetlands and waterways. In addition, the UTVs have wider wheel bases 

and are heavier than ATVs and would increase damage to the INHT through multiple deep ruts that could 

damage the surface of the winter trail treadway and create hazards for trail users. 

National Trails: Effects from Areas of Critical Environmental Concern Management 

Actions 

Potential impacts from the following management topics were considered: 

• Overlap of the INHT NTMC with Proposed ACECs 

Effects under Alternative A 

The proposed Kaltag Portage segment of the INHT NTMC overlaps with 141,178 acres of the Drainages 

of the Unalakleet River ACEC. Effects from resource management decisions are included under the other 

resource-specific headings (e.g., Lands and Realty) and analysis in this section. 

Effects under Alternative B 

Under Alternative B, the Farewell Burn NTMC overlaps 46,590 acres of the proposed Sheefish Spawning 

ACEC, and the Kaltag Portage NTMC overlaps 1 acre of the Nulato River ACEC and 188,821 acres of 

the Unalakleet Watershed ACEC. The alternatives include the prescriptions for both the NTMCs and 

ACECs and use the stricter prescriptions where they overlap, providing beneficial impacts to the nature 

and character of the NTMCs in these areas. Impacts are discussed under the other resource-specific 

headings in this section. 

Effects under Alternative C 

No ACECs would be designated in Alternative C; there would be no related beneficial effects on the 

INHT. 

Effects under Alternative D 

No ACECs would be designated in Alternative D; there would be no related beneficial effects on the 

INHT. 

National Trails: Effects from National Trails Management Actions 

In addition to management actions common to all action alternatives, potential impacts from the 

following management topics were considered: 

• Establishing the INHT NTMC within the Planning Area 

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• Lighting in the INHT NTMC Viewshed 

• Surface-Disturbing Activities 

Effects under Alternative A 

The BLM has not designated a NTMC for the INHT within the planning area. The only protection of the 

INHT is where the proposed Kaltag Portage NTMC overlaps the Unalakleet Wild River Corridor. The 

lack of an NTMC opens the NHT area to development that would interfere with the trail’s integrity and 

purpose. Effects from resource management decisions are included under the other resource-specific 

headings (e.g., Lands and Realty) and analysis in this section. 

Effects Common to All Action Alternatives 

All action alternatives would designate lands for the INHT NTMC. The alternatives vary in the number 

and size of NTMCs, as described below. 

Effects under Alternative B 

Alternative B designates 288,466 acres of the following NTMCs: Farewell Burn (46,591 acres), Kaltag 

Portage (241,512 acres), and Rohn (363 acres) (see BSWI Draft RMP/EIS, Map 2-49). This action 

provides designated protection of 288,466 more acres of the INHT than Alternative A. 

Alternative B would not allow structures that require air safety lighting as required by FAA and would 

require hooded lighting for any night lighting in the NTMCs. These restrictions would maintain the user 

experience during the dark winter months and preserve the integrity, nature, and purpose of the INHT. 

However, precluding lighting would mean that BLM would not be able to respond to ROW actions 

requests with the NTMC. The preclusion of lighting or requirement for hooded lighting may also add to 

the costs for the public if existing structures need to be relocated or modified. 

Alternative B would prohibit surface-disturbing activities within the NTMCs (unless allowed under 

ANILCA Title XI). Realty actions may be authorized within the INHT NTMC is if is determined by the 

AO that the activities are not visible from the INHT and impacts associated with the action would be 

consistent with the integrity, nature, and purpose of the INHT. These restrictions would prevent visible 

surface disturbance from within the NTMC and would prevent direct impacts on 288,466 acres, compared 

with Alternative A. Preventing visible surface disturbance in the NTMC would preserve the user 

experience and maintain the purpose and integrity of the INHT. 

Effects under Alternative C 

Alternative C designates 273,242 acres of NTMC: Farewell Burn (31,367 acres), Kaltag Portage (241,512 

acres), and Rohn (363 acres) (see BSWI Draft RMP/EIS, Map 2-50). This action provides designated 

protection of 273,242 more acres than Alternative A. 

Alternative C includes the same lighting restrictions and associated impacts as Alternative B. 

Alternative C authorizes surface-disturbing activities and other realty decisions within the INHT NTMC 

if it is determined by the AO that they meet the VRM Class allocations for the disturbance area (Table 

3.8.3-1) and impacts associated with the action would be consistent with the integrity, nature, and purpose 

of the INHT. This would prevent visible surface disturbance from within the NTMC, as Alternative C 

manages the NTMCs as VRM Class II, which retains the existing landscape character. Preventing visible 

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Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

surface disturbance in the NTMC would preserve the user experience and maintain the integrity, nature, 

and purpose of the INHT. 

Effects under Alternative D 

Alternative D designates the same NTMC areas as under Alternative C. Under Alternative D, structure 

lighting restrictions would be determined on a case-by-case basis with site-specific analysis that considers 

the darkness and winter-time use of the trail and the effect of lighting colors on trail experiences. Potential 

impacts on the user experience during darkness or winter-time would depend on the results of the sitespecific analysis and identified mitigation measures. 

Alternative D authorizes surface-disturbing activities and other realty decisions if the AO determines that 

they would not substantively conflict or interfere with the integrity, nature, and purpose of the INHT. 

Alternative D preserves the integrity, nature, and purpose of the INHT but would allow surface 

disturbance within the NTMC that would interfere with the user experience and possibly impact the 

INHT. 

National Trails: Effects from Wild and Scenic Rivers Management Actions 

In addition to management actions common to all action alternatives, potential impacts from the 

following management topic were considered: 

• Designation of the WSR Corridors 

Effects under Alternative A 

The BLM manages the Unalakleet Wild River Corridor, which overlaps the 46,953 acres of the proposed 

Kaltag Portage segment of the INHT NTMC. Management of the resources where the proposed NTMC 

overlaps with the WSR corridor is included under the other resource-specific heading in this section. The 

proposed Farewell Burn NTMC intersects five eligible WSR corridors, totaling 25,090 acres. The 

proposed Kaltag Portage NTMC intersects two eligible WSR corridors totaling 51,966 acres, including 

the existing Unalakleet Wild River Corridor (Table 3.8.3-1). According to BLM Manual 6400, projects on 

BLM-managed lands within the river corridor or on lands that are adjacent to or border eligible rivers 

must consider guidelines to protect ORVs, which could also provide protections to the INHT NTMC. 

Effects under Alternative B 

Alternative B recommends 18 waterbodies as suitable WSRs (BSWI Draft RMP/EIS, Map 2-51). The 

proposed Farewell Burn segment of the INHT NTMC intersects five WSR corridors recommended as 

suitable, totaling 25,090 acres. The proposed Kaltag Portage NTMC intersects one recommended suitable 

WSR corridor totaling 5,012 acres, and the designated Unalakleet Wild River Corridor (46,953 acres) 

(Table 3.8.3-1). The alternatives include the prescriptions for both the NTMCs and WSR corridors and 

utilize the stricter prescriptions where they overlap. Management of resources in the intersecting areas is 

included under the other resource-specific headings in this section. 

Effects under Alternative C 

Alternative C maintains the Unalakleet Wild River Corridor but does not recommend any additional 

waterbodies for inclusion in the National System. The Unalakleet Wild River Corridor intersects 46,953 

acres of the proposed Kaltag Portage NTMC. Management of resources in the intersecting areas is 

included under the resource-specific headings in this section. 

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Effects under Alternative D 

Effects would be the same as those described under Alternative C. 

National Trails: Effects from Climate Change 

There are no alternative-specific management actions for this resource; therefore, impacts from 

Alternatives B, C, and D are discussed in combination below. 

In addition to management actions common to all action alternatives, potential impacts from the 

following management topics were considered: 

• Increased Wildfire Intensity, Size, and Frequency 

• Decreased Snow Cover 

• Increase in NNIS Presence/Spread 

• Change in Vegetation Community Composition (as defined by the REA) 

Effects under Alternative A 

Wildland fire is expected to increase in frequency, size, and intensity as a result of climate change. 

Current management identifies historic structures on the INHT for protection but does not designate them 

for fuels treatment or reduction. 

A substantial shortening of the winter travel season on the trail appears to have occurred in the last 

15 years. Current management allows for undesignated OHV travel along the INHT during the summer 

and winter months. The use of ATVs on the INHT during the winter prior to sufficient snow cover for 

snowmobiles has the potential to create a major hazard to other trail users who rely on a single-lane 

packed treadway due to the creation of parallel ruts. Because most segments of the BLM-managed trail 

are located far from local communities, this use has not presented a problem to date, but is being 

monitored. 

No data to measure changes in vegetation community composition are available for Alternative A. 

Effects Common to All Action Alternatives 

All action alternatives would prioritize historic structures along the INHT for preservation during 

wildland fires and include fuels reduction and treatment to further protect the structures. 

All action alternatives would restrict both casual and subsistence winter OHV use to snowmobiles only. 

This would eliminate the risk of rutting from the use of ATVs or UTVs on the trail prior to sufficient 

snow cover and preserve the historic use of the INHT by those who rely on the single-lane packed 

treadway. In addition, the BLM would monitor winter casual and subsistence OHV use in the NTMC. If 

the use results in degradation of the resources or prevents trail management that meets requirements of the 

National Trails System Act, then casual and subsistence winter OHV travel would be prohibited in 

affected areas. 

Based on potential changes in climate, the BLM would promulgate supplementary rules, consistent with 

the INHT’s comprehensive management plan, to implement time-of-use rules related to winter use 

beginning and ending dates that reflects the actual yearly beginning and ending dates of sufficient snow 

cover. 

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Under all action alternatives, the BLM would cooperate with other agencies and landowners in the 

prioritization of treatment areas with known infestations of nonnative invasive plant species, including the 

INHT NTMC. The integrity of the trail would be affected because invasive plants change the plant 

communities around the NTMC and other areas along the trail, which leads to a degradation of the 

historic viewshed and the integrity of the trail. 

Effects under Alternative B 

Based on the REA, 150,948 acres of vegetation community composition would change under 

Alternative B, including 24,425 acres in the Farewell Burn NTMC, 126,332 acres in the Kaltag Portage 

NTMC, and 191 acres in the Rohn NTMC (Table 3.8.3-1). Comparison to Alternative A cannot be made 

due to lack of corresponding Alternative A data. 

Effects under Alternative C 

Based on the REA, 142,859 acres of vegetation community composition would change under Alternative 

B, including 16,336 acres in the Farewell Burn NTMC, 126,332 acres in the Kaltag Portage NTMC (the 

same as Alternative B), and 191 acres in the Rohn NTMC (the same as Alternative B) (Table 3.8.3-1). 

Comparison to Alternative A cannot be made due to lack of corresponding Alternative A data. 

Effects under Alternative D 

Effects would be the same as those described under Alternative C. 

National Trails: Cumulative Effects 

Table 3.8.3-2 summarizes the results of the cumulative effects analysis for the INHT in the planning area 

for all alternatives. 

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Table 3.8.3-2: Cumulative Effects Analysis for the INHT 

Trends and Forecasts of the 

INHT in Consideration of Past 

and Present Actions 

Trends and Forecasts of the 

INHT in Consideration of Past, 

Present, and Reasonably

Foreseeable Future Actions 

(Alternative A) 

Trends and Forecasts of the 

INHT in Consideration of Past, 

Present, and Reasonably

Foreseeable Future Actions 

(Alternative B) 

Trends and Forecasts of the 

INHT in Consideration of Past, 

Present, and Reasonably

Foreseeable Future Actions 

(Alternative C) 

Trends and Forecasts of the 

INHT in Consideration of Past, 

Present, and Reasonably

Foreseeable Future Actions 

(Alternative D) 

The primary natural phenomena Alternative A continues the current Alternative B designates two Alternative C designates three Alternative D designates three 

directly affecting trail resources management for the INHT. It does NTMCs associated with the INHT NTMCs associated with the INHT NTMCs. Alternative D would 

are erosion, wildland fire, and not designate NTMCs for the and includes the greatest and includes additional protection provide less protection to the 

changes to the length and INHT and does not include protection from OHV travel, both compared with Alternative A but to INHT and adjacent NTMCs 

intensity of winter weather. A additional protection from during the summer and winter a lesser extent; closes the NTMCs compared with Alternative A. It 

number of historic roadhouses unrestricted OHV travel in months; withdraws the NTMCs to grazing and a small portion to would restrict OHV travel 

and shelter cabins originally summer and winter; grazing; from locatable and salable mineral commercial woodland harvest; compared with Alternative A but 

located near waterways are commercial woodland harvest; development; closes the NTMCs closes the NTMCs to locatable would leave the INHT NTMCs 

either vulnerable to or have locatable, salable, or leasable to leasable mineral development; mineral development and a open to grazing; commercial 

been eroded or flooded by mineral development; or surface- closes the NTMCs to grazing and portion to salable mineral woodland harvest; locatable, 

shifting river and creek beds. disturbing activities. Increased use commercial woodland harvest; development; restricts leasable salable, and leasable minerals; 

Historic structures, historic trail could occur as a result of designates the NTMCs as VRM mineral development to NSO; and surface-disturbing activities. 

landforms, and contemporary 

public facilities are also 

vulnerable to loss from wildland 

fire. 

Trend: Degrading; not 

increased number of permit 

requests, and the INHT could 

experience additional impacts 

from use of larger and heavier 

OHVs from new technologies. 

Class I areas; and prohibits 

surface disturbance that would be 

visible or audible by INHT users. 

Trend: Counter the existing

degradation trend and moving 

designates the NTMCs as VRM 

Class II areas; and prohibits 

surface disturbance that would be 

visible or audible by INHT users. 

Trend: counter the existing

Trend: Continue to degrade the

INHT and associated NTMCs at 

a similar or greater rate than 

current conditions, and not 

achieve congressionally

achieving the congressionally Trend: Continue to degrade the forward maintaining and degradation trend and maintain identified nature and purpose 

identified nature and purpose resource at a similar rate to conserving the condition of the and conserve the condition of of the INHT. 

of the INHT. current conditions as it extends 

the current management

practice. Not achieving the 

congressionally identified 

nature and purpose of the INHT. 

INHT and associated NTMCs 

and moves toward achieving 

the congressionally identified 

nature and purpose of the INHT. 

the INHT and associated 

NTMCs in some cases. In other 

instances, degradation could be

accelerated, but to a lesser 

extent that Alternative B. Moves 

toward achieving the 

congressionally identified 

nature and purpose of the INHT. 

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Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

3.9 Wild and Scenic Rivers 

3.9.1 Summary 

This section describes the potential impacts from management actions on WSRs within the planning area. 

The planning area contains one designated WSR and 18 rivers determined eligible for inclusion in the 

National System (BLM 2018b). These rivers, which are tributaries to the Unalakleet, Anvik, and 

Kuskokwim Rivers, were assigned tentative classifications of “wild” by BLM. Collectively, these eligible 

river corridors measure 332,176 acres. Of the 18 rivers, 12 include ORVs for fish, four include ORVs for 

fish and historic resources, one includes ORVs for fish and cultural resources, and one includes ORVs for 

cultural resources (see Appendix M of the BSWI Draft RMP/EIS). The eligible rivers are proposed as 

suitable under Alternative B. Under all action alternatives, BLM management decisions would recognize 

that Alaska Natives rely upon the resources of the Unalakleet Wild River Corridor and study rivers to 

support their subsistence lifestyle. Under all action alternatives, the Unalakleet would continue to be 

accessible for subsistence use. Measures to protect and enhance fisheries and resources within the 

Unalakleet Wild River Corridor would result in indirect impacts to BSWI communities by ensuring a 

sustainable resource base. 

Under all alternatives, the 46,953 acres of the Unalakleet Wild River Corridor would continue to be 

managed as part of the National System per the Unalakleet National Wild River Management Plan (BLM 

1983). As such, the river would continue to be managed to protect and enhance free-flowing condition, 

water quality, wild river classification, and ORVs. Resource-specific management actions associated with 

soils, water resources and fisheries, cultural resources, VRM, forestry and woodland products, and 

grazing would contribute to the protection of ORVs, water quality, and wild river classification by 

maintaining resource integrity and landscape character. Management decisions for minerals (locatable and 

salable) and lands and realty would result in beneficial direct impacts by prohibiting or limiting surfacedisturbing activities that could affect river values. 

Under Alternative A, eligible rivers would continue to be managed per the SWMFP and CYRMP, as 

applicable. Free-flowing condition, water quality, wild river classification, and ORVs would be managed 

per guidelines provided in BLM Manual 6400 (BLM 2012) until a decision on their suitability is made. 

Accordingly, no direct impacts to these river values would result from Alternative A. Protections from 

BLM (2012a) would be applied consistently across all eligible rivers. 

Under Alternative B, eligible rivers would be recommended as suitable for inclusion in the National 

System. If designated, these rivers would receive the same protections as described for the Unalakleet 

Wild River Corridor. These rivers would be managed per the same VRM designation as the Unalakleet 

Wild River Corridor. Management of these corridors as VRM Class I would serve as a tool to limit direct 

impacts to water quality, wild river classification, and ORVs that could result from surface-disturbing 

activities. Additional protections would be applied through HVW, cultural resources, and NHT actions 

that could further protect these river values. All suitable rivers are located in areas of low mineral 

potential, further reducing the potential for direct impacts from these actions. Free-flowing condition, 

water quality, wild river classification, and ORVs would be managed per guidelines provided in BLM 

Manual 6400 (BLM 2012) until a decision on designation is made by Congress. Alternative B could result 

in beneficial direct impacts to BSWI communities should rivers recommended as suitable for inclusion in 

the National System be designated from increased protections of water quality and fish and cultural 

ORVs. 

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Appendix N: Supplemental Impact Analysis Information Section 3: Supplemental Impact Analysis 

Under Alternatives C and D, eligible rivers would be determined to be not suitable for inclusion in the 

National System. No protections of free-flowing quality would be extended under these options. 

Under Alternative C, the former study rivers would continue to receive protection where vacated 

corridors overlap HVWs (31,578 acres) and VRM Class I or II (148,998 acres). Overlap with these 

management actions would contribute to protection of water quality and ORVs for up to 45 percent of the 

vacated study corridors. 

Under Alternative D, the former study rivers would continue to receive protection where vacated 

corridors overlap HVW (31,578 acres) and VRM Class I or II (73,952 acres). Overlap with these 

management actions would contribute to protection of water quality and ORVs for up to 22 percent of the 

vacated study corridors. 

3.9.2 Methods of Analysis 

This section describes methods used to identify potential impacts from proposed management under each 

alternative to identified river values for eligible and designated rivers and other resources and resource 

uses. Where impacts were quantifiable, they were based on an assumed half-mile buffer on each side of 

the eligible river. The baseline conditions for the designated Unalakleet Wild River Corridor and rivers 

determined to be eligible for inclusion in the National System are described in Appendix M of the BSWI 

Draft RMP/EIS and the 2018 WSR Study (BLM 2018b). Approximate length, acreage, ORVs, and 

tentative classification for eligible rivers are summarized below in Table 3.9.2-1. 

Table 3.9.2-1: Rivers Identified as Eligible (Alternative A) and Recommended as Suitable 

(Alternative B) within the Planning Area 

Watercourse 

Approximate 

Length on BLM

Lands (miles) 

Acreage within

Eligible WSR

corridor (acres) 

Outstandingly

Remarkable 

Value(s) 

Tentative 

Classification 

Anvik River 119 61,100 Fish, Cultural Wild 

Bear Creek (Nikolai) 41 17,224 Fish, Historic Wild 

Big River 35 21,859 Fish Wild 

Blackwater Creek 12 7,617 Fish Wild 

Canyon Creek 16 8,233 Fish Wild 

Middle Fork Kuskokwim River 52 23,212 Fish Wild 

North Fork Unalakleet River 48 28,987 Fish Wild 

Otter Creek (Anvik) 35 20,130 Fish Wild 

Otter Creek (Tuluksak) 5 3,247 Fish Wild 

Pitka Fork Middle Fork 

Kuskokwim River 

62 24,921 Fish, Historic Wild 

Salmon River (Nikolai) 21 10,536 Fish, Historic Wild 

Sheep Creek 36 15,861 Fish Wild 

Sullivan Creek 22 9,192 Fish, Historic Wild 

Swift River (Anvik) 31 16,381 Fish, Historic Wild 

Tatlawiksuk River 17 8,975 Fish Wild 

Theodore Creek 15 7,384 Fish Wild 

Yellow River 70 28,409 Fish Wild 

Yukon River 13 18,908 Cultural Wild 

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Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

The total area within all eligible WSR corridors is approximately 332,173 acres. This represents less than 

3 percent of the planning area. 

Potential Effects and Indicators 

One designated Wild River Corridor, the Unalakleet, exists in the planning area, and would continue to be 

managed as part of the National Wild and Scenic River System under all alternatives. Resource pressures 

on the Unalakleet Wild River Corridor are low and are not forecasted to substantially increase. While the 

alternatives have some differences in WSR management among them (generally most protective of WSR 

values under Alternative B, and least protective under Alternative D), the beneficial or adverse impacts of 

these actions on the designated Unalakleet Wild River are likely to be small given the remoteness of the 

area, low mineral potential, and low demand for travel or resource use. 

In 2016, the BLM determined that 18 additional waterways meet WSR eligible criteria. Under 

Alternatives C and D, future development that lessens WSR values could occur near those waterways. 

However, because most of the waterways are very remote and are located within low mineral potential 

areas, and because travel and resource pressure are very low, such development is not currently foreseen. 

The specific types of effects to free-flowing condition, ORVs, water quality, and wild river classification 

that could result from management actions and other resources and resource uses are summarized in 

Table 3.9.2-2 and discussed below. 

Table 3.9.2-2: Summary of Effects to Wild and Scenic Rivers by Management Action 

Types of Effects Management Actions Indicators 

Development and/or surface disturbance • Soils management actions Impacts to wild river classification, freein riparian zones or floodplains could 

cause impacts wild river classification, • Water resources decisions (HVW) flowing condition water quality and 

ORVs, as measured by: 

water quality, and ORVs. • ROW decisions 

• Commercial woodland harvest 

decisions 

• Acres of HVW intersecting designated, 

eligible, or suitable rivers 

• Acres open to ROW development 

intersecting designated, eligible, or 

suitable rivers 

• Acres open to commercial woodland 

harvest intersecting designated, 

eligible, or suitable rivers 

Road development or other access 

improvements and/or surface-disturbing 

activities could adversely affect wild river 

classification. 

• Travel and transportation management 

actions 

• Land and realty ROW 

exclusion/avoidance zone actions 

• Change in preliminary or designated 

classification (wild, scenic, or 

recreational) 

Road development or other access 

improvements and/or surface-disturbing 

activities could adversely affect wild river 

classification. 

• Travel and transportation management 

actions 

• Land and realty ROW 

exclusion/avoidance zone actions 

• Change in preliminary or designated 

classification (wild, scenic, or 

recreational) 

Lands disposed within a WSR study 

corridor would no longer be managed by 

the BLM, thereby limiting the BLM’s 

ability to protect ORVs or other attributes 

per the BLM (2012). 

• Land and realty actions • Acres open for disposal 

Assumptions 

The following assumptions were used to assess effects associated with WSRs: 

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Appendix N: Supplemental Impact Analysis Information Section 3: Supplemental Impact Analysis 

• In implementing the mandate of the WSR Act, it is BLM’s responsibility to manage all eligible, 

suitable, or designated WSRs “so as to protect, enhance, and not degrade the free-flowing 

character, water quality, and identified ORVs” (BLM 2012). 

• Rivers identified as eligible (Alternative A) or suitable (Alternative B) would continue to be 

managed per guidelines provided in BLM Manual 6400 “Wild and Scenic Rivers: Policy and 

Program Direction for Identification, Evaluation, Planning, and Management” (BLM 2012). 

These guidelines are applicable to minerals, transportation, authorized ROW, recreation 

development, motorized travel, vegetation management, livestock grazing, invasive species 

management, and water resources and hydroelectric projects. Guidelines would protect freeflowing condition, water quality, wild river classification and ORVs until a decision is made 

regarding their suitability, or in the case of suitable rivers, until Congress designates the river or 

releases it for other uses. The BLM would exercise discretionary authority on a case-by case 

basis, through project-level decision making and the NEPA processes, not to impact river values 

or make decisions that might lead to a determination of ineligibility or non-suitability. 

• If WSR designation is not provided (i.e., if rivers are not found suitable and are released from 

further study under the WSR Act), provisions could still remain to protect these rivers and 

relevant ORVs through existing plans, policies, and other management actions considered in this 

RMP. 

• Although the geographic extent of management actions for most resources and resource uses is 

planning area-wide, WSR management prescriptions apply only to the designated WSR corridor 

or study corridor (1/2 mile on each side). 

• Permitted activities will not be allowed to impair the outstandingly remarkable values for which 

the WSRs are designated. 

• WSR designation provides protection and focused management for ORVs beyond that provided 

through general management of the parent resource as a result of the “protect and enhance” 

mandate. 

• Management of designated, eligible, and suitable WSR is included in other resource and resource 

use management decisions (e.g., travel restrictions in WSRs are brought forward in travel 

management) and will be recognized during future travel management planning. 

Standard Operating Procedures and Best Management Practices 

The impact analysis below takes into account the SOPs and BMPs that would be implemented by the 

BLM. A comprehensive list of SOPs/BMPs pertaining to WSRs is provided in Appendix K of the BSWI 

Draft RMP/EIS. 

3.9.3 Effects Analysis 

Management actions proposed for the following resources, resource uses, and special designations would 

not result in effects to eligible or designated WSRs: 

• Air Quality and AQRVs 

• Vegetation 

• Wildlife 

• Non-native invasive species 

• Wildland Fire 

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Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

• Paleontological Resources 

• Land with Wilderness Characteristics 

• Hazardous Materials and Health and Human Safety 

Wild and Scenic Rivers: Effects from Soils Management Actions 

Effects under Alternative A 

Under Alternative A, the BLM would continue to protect floodplains wherever they may be impacted by 

a BLM action. Such protections would result in beneficial impacts to designated and eligible rivers by 

managing surface-disturbing activities within these areas and contributing to the protection of water 

quality and ORVs. 

Under Alternative A, free-flowing condition, water quality, wild river classification, and river values (no 

ORVs identified) of the Unalakleet Wild River Corridor would continue to be protected under the 

SWMFP, the CYRMP, the Unalakleet National Wild River Management Plan (BLM 1983), and mandates 

of the WSR Act. The WSR attributes of rivers identified as eligible would continue to be managed per 

guidelines provided in BLM Manual 6400 (BLM 2012), as described in the subsection “Assumptions” 

above. Consequently, beneficial impacts from soils management would be greatest in areas where these 

protections were applied outside the corridor boundary, where existing management provisions for 

eligible and designated WSR do not apply. 

Soils management described in Alternative A would contribute to existing provisions that protect water 

quality and ORVs. There would be no effect on free-flowing condition or wild river classification. 

Effects Common to All Action Alternatives 

There are no management actions common to all action alternatives that would result in direct or indirect 

impacts to eligible, designated, or suitable WSRs. 

Effects under Alternative B 

Under Alternative B, any BLM-permitted surface-disturbing activity within the 100-year floodplain 

would require detailed reclamation plans and use of overburden materials. No surface-disturbing activities 

would be allowed within 100 feet of a natural spring. These actions would contribute to protection of 

water quality and ORVs in designated rivers and those rivers recommended as suitable for inclusion in the 

National System by ensuring integrity of floodplains was restored following surface disturbance. 

As in Alternative A, free-flowing condition, water quality, wild river classification, and river values of the 

Unalakleet Wild River Corridor would continue to be protected under the Unalakleet National Wild River 

Management Plan (BLM 1983) and mandates of the WSR Act. Eighteen rivers recommended as suitable 

would continue to be managed per guidelines provided in BLM Manual 6400 (BLM 2012). 

Consequently, beneficial impacts to ORVs from Alternative B would be greatest in areas along the 18 

suitable rivers, where existing management provisions do not apply. 

Effects under Alternative C 

Under Alternative C, rivers identified as eligible would be determined not to be suitable for inclusion in 

the National System. Water quality and ORVs of these vacated study rivers would continue to receive 

protections provided though BLM review of surface-disturbing activities in floodplains. The general 

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Appendix N: Supplemental Impact Analysis Information Section 3: Supplemental Impact Analysis 

protections provided through existing federal, state, and local laws would be applied to rivers eliminated 

from further consideration for inclusion in the National System. 

Determination of BLM-permitted surface-disturbing activities in the vicinity of floodplains and natural 

springs would be authorized on a case-by-case basis. These actions would contribute to protection of 

water quality and ORVs in designated rivers by ensuring potential impacts from land uses proposed 

outside the WSR corridor that could affect water quality impacts were reviewed. This management action 

would complement provisions of the Unalakleet National Wild River Management Plan (BLM 1983) and 

mandates of the WSR Act and could contribute to the protection of water quality and river values. 

Alternative C would contribute to existing provisions that protect water quality and river values. There 

would be no protection on free-flowing condition or wild river classification. 

Effects under Alternative D 

Impacts to WSRs from Alternative D would be identical to Alternative C for soils management actions. 

Wild and Scenic Rivers: Effects from Water Resources and Fisheries Management Actions 

This analysis considered HVW designations, which are independent of WSR actions. As a result, even 

under Alternatives C and D, where the currently eligible waterways would have no special WSR 

designation, the fisheries ORVs of parts of the currently eligible river corridors would receive some 

additional protections. Table 3.9.3-1 summarizes the approximate acreages affected; the effects are 

discussed in the alternatives sections below. 

Table 3.9.3-1: WSR Intersections with Proposed HVWs (all alternatives) 

Watercourse Alternative A acres Alternative B acres Alternative C acres Alternative D acres 

Anvik River 0 61,100 59,589 59,589 

Bear Creek (Nikolai) 0 16,947 15,922 15,922 

Big River 0 21,837 21,315 21,315 

Blackwater Creek 0 227 198 198 

Canyon Creek 0 8,233 8,233 8,186 

Middle Fork Kuskokwim 0 20,751 19,858 19,858 

North Fork Unalakleet 0 28,704 28,396 28,396 

Otter Creek (Anvik) 0 19,968 19,968 19,968 

Otter Creek (Tuluksak) 0 3,247 3,218 3,218 

Pitka Fork Middle Fork 

Kuskokwim River 

0 22,921 22,069 22,069 

Salmon River (Nikolai) 0 10,269 10,269 10,269 

Sheep Creek 0 9,241 121 121 

Sullivan Creek 0 9,192 9,123 9,123 

Swift River (Anvik) 0 16,381 16,381 16,381 

Tatlawiksuk River 0 8,975 8,792 8,792 

Theodore Creek 0 7,384 514 514 

Unalakleet Designated WSR 0 34,808 31,578 31,578 

Yellow River 0 28,168 27,680 27,478 

Yukon River 0 5,030 5,022 0 

Total 0 333,483 305,279 302,975 

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Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

Effects under Alternative A 

Under Alternative A, HVWs would not be designated. Consequently, no additional protection of water 

quality and/or ORVs would be applied to the designated Unalakleet River or eligible WSRs through this 

mechanism. 

Under Alternative A, free-flowing condition, water quality, wild river classification, and river values of 

the Unalakleet Wild River Corridor would continue to be protected under the SWMFP, the CYRMP, the 

Unalakleet National Wild River Management Plan (BLM 1983), and mandates of the WSR Act. These 

WSR attributes of rivers identified as eligible would continue to be managed per guidelines provided in 

BLM Manual 6400 (BLM 2012). 

Alternative A would not contribute to these existing provisions that protect or enhance free-flowing 

condition, water quality, wild river classification, and protection of ORVs; however, it would not degrade 

the condition of these attributes. 

Effects Common to All Action Alternatives 

Management actions common to all action alternatives include measures to protect water quality and 

quantity within the planning area. Additional management standards would restrict land development to 

those actions that would not adversely impact aquatic and riparian systems and would manage habitat to 

support self-sustaining populations of priority species. These measures would serve to protect and 

enhance free-flowing nature, water quality, and ORVs within the designated and suitable WSRs. 

Effects under Alternative B 

Under Alternative B, HVWs would be designated in the planning area. HVWs are established to protect 

water quality and quantity, and fisheries resources in areas classified as High, Medium-High, or Medium 

resource value. In areas designated as HVWs, any proposal to use or develop the lands, waters, or 

resources within the 100-year floodplain would be required to demonstrate that the condition and 

ecological functions of aquatic and riparian systems (water quality, stream flow, groundwater hydrology, 

channel connectivity, channel form, material recruitment, substrate composition, energy (food) flow, and 

riparian function) would not be adversely affected. Land use proposals would also be required to 

demonstrate that the quality and diversity of habitats needed to sustain the production of fish and wildlife 

populations at their natural potential would not be diminished. Commercial woodland harvest would be 

prohibited within the 100-year floodplains of HVWs. Under Alternative B, HVW overlaps all of the 

suitable river corridors; exact acreage is not available as floodplain areas have not been determined for 

these rivers. 

Direct beneficial impacts to WSR water quality and fish ORVs would result from these use restrictions 

where the suitable rivers intersect with HVWs. These land use restrictions could also indirectly 

beneficially impact cultural and historic ORVs (Anvik River, Bear Creek [Nikolai], Pitka Fork Middle 

Fork Kuskokwim River, Salmon River [Nikolai], Sullivan Creek, and Yukon River) by limiting surface 

disturbance. Table 3.9.3-2 summarizes the intersections of designated and suitable WSRs with the HVWs 

as proposed under Alternative B. 

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Appendix N: Supplemental Impact Analysis Information Section 3: Supplemental Impact Analysis 

Table 3.9.3-2: Suitable WSR Intersections with Proposed HVWs (Alternative B) 

Watercourse 

River Miles in 

Proposed HVW 

High Classification

(RM & %) 

High-Medium

Classification 

(RM & %) 

Medium 

Classification 

(RM & %) 

Anvik River 118 117 (99%) 0 <1 

Bear Creek (Nikolai) 41 41 (100%) 0 0 

Big River 35 35 (100%) 0 0 

Blackwater Creek 0 0 0 0 

Canyon Creek 16 16 (100%) 0 0 

Middle Fork Kuskokwim 52 52 (100%) 0 0 

North Fork Unalakleet 48 48 (100%) 0 0 

Otter Creek (Anvik) 35 35 (100%) 0 0 

Otter Creek (Tuluksak) 5 5 (100%) 0 0 

Pitka Fork Middle Fork 

Kuskokwim River 

61 61 (100%) 0 <1 

Salmon River (Nikolai) 21 21 (100%) 0 0 

Sheep Creek 22 0 0 22 (100%) 

Sullivan Creek 22 21 (95%) 0 0 

Swift River (Anvik) 31 32 (100+%) 0 0 

Tatlawiksuk River 17 17 (100%) 0 0 

Theodore Creek 15 <1 0 15 (100%) 

Unalakleet Designated 

WSR 

65 65 (100%) 0 <1 

Yellow River 69 69 (100%) 0 0 

Yukon River 7 0 7 (100%) 0 

Under Alternative B, free-flowing condition, water quality, wild river classification, and river values of 

the Unalakleet Wild River Corridor would continue to be protected under the Unalakleet National Wild 

River Management Plan (BLM 1983) and mandates of the WSR Act. The WSR attributes of rivers 

recommended as suitable would continue to be managed per guidelines provided in BLM Manual 6400 

(BLM 2012). 

Alternative B would include the most measures protect and enhance free-flowing condition, water quality, 

wild river classification, and protection of ORVs in the designated and suitable rivers. 

Effects under Alternative C 

Under Alternative C, the designated Unalakleet Wild River would intersect HVW classified as High 

(31,578 acres). It does not intersect any High-Medium value HVW, and less than 1 acre would intersect 

Medium-value HVW. Where the designated Unalakleet Wild River Corridor intersects HVW, land use 

rules would have direct beneficial impacts to protect and enhance water quality and ORVs for fish. The 

HVW land use restrictions could indirectly impact cultural and historic ORVs by limiting surface 

disturbance. 

None of the rivers that are eligible under Alternative A or recommended as suitable under Alternative B 

would retain WSR status under Alternative C. Protecting their free-flowing and wild characteristics would 

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Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

not be prioritized. However, 92 percent of the WSR acreage designated HVW under Alternative B would 

still be designated HVW under Alternative C, which would minimize impacts to water quality, fish, and 

cultural ORVs because of additional regulations of surface disturbance, commercial woodland harvest 

and ROW actions in HVW. 

Effects under Alternative D 

The types of impacts to WSR from Alternative D would be the same as Alternative C, except that a 

slightly smaller area would be designated as HVW, amounting to 91 percent of WSR acreage under 

Alternative B. 

Wild and Scenic Rivers: Effects from Cultural Resources Actions 

Effects under Alternative A 

Management actions for historic resources pertain to management of the INHT NTMC. Impacts for the 

INHT NTMC are discussed below in the section “Wild and Scenic Rivers: Effects from National Trails.” 

Effects Common to All Action Alternatives 

Under all action alternatives, cultural resources would continue to be protected under existing federal, 

State, and local laws. Cultural resources would continue to be surveyed and monitored. The BLM would 

work collaboratively with other federal agencies, State of Alaska, tribes, Native corporations, and private 

landowners for documentation, stewardship, and protection of cultural resources. The BLM would also 

prioritize nomination of contributing properties of the INHT on the NRHP and consult with tribes to 

identify TCPs of use areas. 

Collectively, these actions would result in direct beneficial impacts by supporting preservation of cultural 

ORVs of the Unalakleet Wild River Corridor or of identified eligible rivers, regardless of their inclusion 

in the National System. These measures would result in direct beneficial impacts to cultural resource 

values associated with the Unalakleet Wild River Corridor through increased awareness and preservation. 

Effects under Alternative B 

Under Alternative B, six rivers with cultural and/or historic ORVs would be recommended for inclusion 

in the National System: Anvik River, Bear Creek (Nikolai), Pitka Fork Middle Fork Kuskokwim River, 

Salmon River (Nikolai), Sullivan Creek, and the Yukon River. Direct beneficial impacts to these rivers’ 

ORVs would result from management actions for cultural resources through increased awareness and 

preservation. 

Cultural resource surveys for the Anvik and Yukon Rivers would be prioritized, further ensuring focus on 

these rivers and associated cultural ORVs. Under Alternative B, these rivers are recommended as suitable 

for inclusion in the National System. Prioritizing cultural resource surveys would contribute to protection 

of cultural ORVs identified for these rivers. 

Under Alternative B, the free-flowing character, water quality, wild river classification, and ORVs of 

rivers recommended as suitable would continue to be managed per guidelines provided in BLM Manual 

6400 (BLM 2012). 

Management actions for historic resources pertain to management of the INHT NTMC. Impacts for the 

INHT NTMC are discussed below in the section “Wild and Scenic Rivers: Effects from National Trails.” 

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Appendix N: Supplemental Impact Analysis Information Section 3: Supplemental Impact Analysis 

Effects under Alternative C 

Under Alternative C, eligible rivers would be determined to be not suitable for inclusion in the National 

System. Consequently, these rivers would not receive protection from management guidance provided in 

BLM Manual 6400 (BLM 2012). Cultural and historic ORVs of these vacated study corridors would 

continue to receive protection described in management actions common to all, and as described for the 

Anvik and Yukon Rivers under Alternative B. 

Management actions for historic resources pertain to management of the INHT NTMC. Impacts for the 

INHT NTMC are discussed below under the heading “Wild and Scenic Rivers: Effects from National 

Trails.” 

Effects under Alternative D 

Under Alternative D, eligible rivers would be determined to be not suitable for inclusion in the National 

System. Impacts to cultural and historic ORVs of these vacated study corridors would be the same as 

described under Alternative C. 

Management actions for cultural resources pertain to management of the INHT NTMC. Impacts for the 

INHT NTMC are discussed below in the section “Wild and Scenic Rivers: Effects from National Trails.” 

Wild and Scenic Rivers: Effects from Visual Resources Management Actions 

This analysis considered VRM designations that would be triggered either by WSR actions or by other 

management actions, such as those stemming from the INHT NTMC or ACEC designations. As a result, 

even under Alternatives C and D, where the currently eligible waterways have no special WSR 

designation, the wild character and/or cultural ORVs of parts of the rivers would receive some additional 

protections. Table 3.9.3-3 summarizes the approximate acreages affected; the effects are discussed in the 

sections below. 

Table 3.9.3-3: WSR Intersections with VRM actions 

Watercourse VRM Class Acres under A Acres under B Acres under C Acres under D 

Anvik River I 0 61,100 0 0 

II 0 0 177 0 

III 0 0 60,922 61,100 

Bear Creek (Nikolai) I 0 17,224 0 0 

II 0 0 17,224 17,224 

III 0 0 0 0 

Big River I 0 21,859 0 0 

II 0 0 21,044 0 

III 0 0 710 8,223 

Blackwater Creek I 0 7,617 0 0 

II 0 0 198 0 

III 0 0 7,419 7,617 

Canyon Creek I 0 8,233 0 0 

II 0 0 0 0 

III 0 0 3,502 3,502 

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Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

Watercourse VRM Class Acres under A Acres under B Acres under C Acres under D 

Middle Fork Kuskokwim I 0 23,212 0 0 

II 0 0 19,988 0 

III 0 0 874 12,174 

North Fork Unalakleet I 1,057 28,987 1,057 1,057 

II 0 0 27,930 8,032 

III 0 0 0 19,899 

Otter Creek (Anvik) I 0 20,130 0 0 

II 0 0 0 0 

III 0 0 6,420 3,622 

Otter Creek (Tuluksak) I 0 3,247 0 0 

II 0 0 0 0 

III 0 0 1,733 1 

Pitka Fork Middle Fork 

Kuskokwim River 

I 0 24,921 0 0 

II 0 0 23,885 13,307 

III 0 0 1,036 11,614 

Salmon River (Nikolai) I 0 10,536 0 0 

II 0 0 10,536 10,536 

III 0 0 0 0 

Sheep Creek I 0 15,861 0 0 

II 0 0 15,861 14,605 

III 0 0 0 1,256 

Sullivan Creek I 0 9,192 0 0 

II 0 0 9,192 9,192 

III 0 0 0 0 

Swift River (Anvik) I 0 16,381 0 0 

II 0 0 0 0 

III 0 0 9,668 7,238 

Tatlawiksuk River I 0 8,975 0 0 

II 0 0 0 0 

III 0 0 858 858 

Theodore Creek I 0 7,384 0 0 

II 0 0 0 0 

III 0 0 3,860 3,860 

Unalakleet Designated 

WSR 

I 46,953 46,953 46,953 46,953 

II 0 0 0 0 

III 0 0 0 0 

Yellow River I 0 28,409 0 0 

II 0 0 0 0 

III 0 0 4,933 4,933 

Yukon River I 0 18,908 0 0 

II 0 0 1,906 0 

III 0 0 17,002 18,908 

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Appendix N: Supplemental Impact Analysis Information Section 3: Supplemental Impact Analysis 

Effects under Alternative A 

Under Alternative A, the upper 65 river miles of the Unalakleet River would continue to be managed as a 

WSR per the SWMFP, the CYRMP, the Unalakleet National Wild River Management Plan (BLM 1983), 

and mandates of the WSR Act. The designated classification of “wild” established for the river in the 

Unalakleet National Wild River Management Plan (BLM 1983) would continue. While no ORV for 

scenery is identified for the Unalakleet Wild River Corridor in the management plan, the WSR corridor is 

managed to preserve the environment and the ecosystems of the river and to protect its free-flowing 

character and unpolluted waters. 

The CYRMP currently manages the 46,953 acres of the Unalakleet Wild River Corridor as VRM Class I. 

The objective of VRM Class I is to preserve the existing character of the landscape; any permitted change 

to the landscape should be very low and must not attract attention. Consequently, Alternative A would 

result in direct beneficial impacts to the Unalakleet Wild River Corridor by limiting developments that 

could dominate the landscape, thereby protecting the wild river classification. Because VRM can also be 

used to manage surface disturbance, Alternative A could result in indirect impacts by limiting 

development that may result in diminished water quality or river values. 

Under Alternative A, no VRM designations exist outside the Unalakleet Wild River Corridor and Seen 

Area of the Unalakleet River; consequently, no VRM-related management actions would apply to eligible 

rivers, and this mechanism could not be used as a tool to manage surface disturbance, development, or 

other actions that may affect wild river character, water quality, or ORVs. 

The WSR attributes of eligible rivers would continue to be managed per guidelines provided in BLM 

Manual 6400 (BLM 2012). 

Alternative A would contribute to protection of water quality, wild river classification, and river values of 

the Unalakleet Wild River Corridor. Alternative A would not contribute to the protection of these 

attributes of eligible rivers; however, it would not diminish these attributes. 

Effects Common to All Action Alternatives 

Under all action alternatives, the 46,953-acre designated Unalakleet Wild River Corridor would be 

managed as VRM Class I, which would provide the same direct and indirect beneficial impacts as 

described for Alternative A. 

Effects under Alternative B 

Under Alternative B, the combined 332,176-acre study corridors for eligible rivers would be proposed as 

suitable for inclusion in the National System and managed per VRM Class I. Consistent with Alternative 

A, management of designated and suitable rivers as VRM Class I would result in direct beneficial impacts 

that protect visual values of those areas by limiting developments that could dominate the setting and 

impact the wild character of the landscape. Indirect beneficial impacts to water quality, river values (of 

the Unalakleet River), and ORVs may result from this protective land use standard. 

Under Alternative B, free-flowing condition, water quality, wild river classification, and river values of 

the Unalakleet Wild River Corridor would continue to be protected under the Unalakleet National Wild 

River Management Plan (BLM 1983) and mandates of the WSR Act. These WSR attributes of suitable 

rivers would continue to be managed per guidelines provided in BLM Manual 6400 (BLM 2012). 

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Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

Alternative B would be most protective of water quality, wild river classification, and river values of the 

Unalakleet Wild River Corridor, as well as free-flowing and wild character, water quality, and ORVs of 

rivers recommended as suitable. 

Effects under Alternative C 

The 18 rivers in the planning area identified as eligible would be determined not suitable for inclusion in 

the National System and would be eliminated from further consideration. No VRM designation would be 

applied specifically to these study corridors; however, 147,941 acres (45 percent) of the vacated study 

corridors would be managed per VRM Class I or II due to protection for other resources. VRM classes 

provide protections to the wild character of the landscape and to cultural ORVs; however, free-flowing 

characteristics would not be protected and any benefit to fish ORVs would be indirectly derived from 

limitations of surface disturbance that would have visual impacts. 

Effects under Alternative D 

As in Alternative C, the 18 rivers in the planning area identified as eligible would be determined as not 

suitable for inclusion in the National System and would be eliminated from further consideration as 

eligible. No VRM designation would be applied specifically to these study corridors; however, 72,896 

acres (22 percent) of the vacated study corridors would be managed per VRM Class I or II to protect other 

resources. Direct impacts in these areas would be similar to those described above for Alternative C. 

Wild and Scenic Rivers: Effects from Forestry and Woodland Products Management 

Actions 

Effects under Alternative A 

Under Alternative A, commercial woodland harvesting would be permitted within the Unalakleet Wild 

River Corridor, and ongoing subsistence activities, including house log and fuel wood harvesting, would 

be allowed to continue per management standards provided in the Unalakleet National Wild River 

Management Plan (BLM 1983). Because subsistence-related house log and fuel wood harvesting 

activities within the Unalakleet Wild River Corridor are currently compatible with allowable uses and, if 

necessary, would be regulated through permits issued by the BLM, the potential for impacts from forestry 

and woodland product management actions within the WSR corridor would be small. This standard 

would protect water quality, wild river classification, and river values (no ORVs identified) of the 

Unalakleet River. 

Eligible rivers would continue to be managed for free-flowing condition, water quality, tentative 

classification, and ORVs per BLM (2012a) until a decision on suitability is made by Congress. This 

guidance and legal protections would contribute to the preservation of water quality and ORVs. Most 

eligible rivers are also located in remote portions of the planning area and are not near populated 

communities; therefore, pressure for this resource use is assumed to be low. 

Effects Common to All Action Alternatives 

Under all action alternatives, harvest activities that include surface disturbance would require surveys for 

sensitive resources that could be affected by the surface disturbance. Implementation-level surveys such 

as this could protect ORVs by ensuring that minimization or avoidance measures were taken, as needed. 

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Appendix N: Supplemental Impact Analysis Information Section 3: Supplemental Impact Analysis 

Effects under Alternative B 

Under Alternative B, commercial woodland harvest would be prohibited within the 46,953-acre 

Unalakleet Wild River Corridor. Because ongoing subsistence-related activities in the Unalakleet Wild 

River Corridor are currently compatible with allowable uses (including house log and fuel wood 

harvesting) and because the BLM could regulate these activities using a permit system if necessary, the 

potential for impacts to the Unalakleet Wild River Corridor from forestry and woodland product 

management actions would likely be small. These standards would contribute to the protection of freeflowing conditions, water quality, wild river classification, and river values of the Unalakleet River. 

Areas within 15 miles of the 18 rivers recommended as suitable for WSR designation would be open for 

commercial woodland harvest unless they overlap with ACECs, lands managed for wilderness 

characteristics as a priority, 100-year floodplains of HVW, or the INHT NTMC. Areas with these 

designations include about 301,922 acres (80 percent of suitable corridors under Alternative B) and 

overlap all of the corridors except for the Yukon. Because the majority of these rivers are located in 

remote portions of the planning area and not near populated communities, there is little demand for this 

resource and impacts are expected to be small. This standard would not protect or enhance free-flowing 

conditions, water quality, wild river classification, and ORVs of these rivers. 

Effects under Alternative C 

As with Alternative B, commercial woodland harvest would be prohibited within the 46,953 acres of the 

Unalakleet Wild River Corridor under Alternative C. The potential for impacts within the Unalakleet 

Wild River Corridor would be small for the same reasons described for Alternative B. 

Rivers considered eligible for inclusion in the National System would be eliminated from further 

consideration and would have no special WSR designation. However, commercial woodland harvest 

would be prohibited within the designated Unalakleet Wild River. 

Effects under Alternative D 

Under Alternative D, commercial woodland harvest (including timber, mushrooms, berries, bark, and 

other forest products) would be permitted within the Unalakleet Wild River Corridor. If management 

actions under Alternative D were to permit commercial woodland harvest activities at levels substantially 

higher than current levels, those management actions would be inconsistent with the current protections 

for the Unalakleet River included in the Unalakleet National Wild River Management Plan (BLM 1983). 

Adverse effects to the wild character of the corridor could result from increased demand for roads or trails 

associated with commercial harvest. However, no demand for substantially higher commercial woodland 

products harvest in the Unalakleet Wild River Corridor is foreseen. 

Rivers considered eligible for inclusion in the National System would be eliminated from further 

consideration. 

Wild and Scenic Rivers: Effects from Grazing Management Actions 

In addition to management actions common to all action alternatives, potential impacts from the 

following management topics were considered: 

• Areas Open to Grazing 

• Areas Closed to Grazing 

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Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

Effects under Alternative A 

Under Alternative A, the entire Unalakleet River, including the WSR corridor and major tributaries, 

would be excluded from grazing permit areas. This measure would contribute to the protection of water 

quality, wild river classification, and ORVs of these rivers by preventing sedimentation or erosion 

associated with an increase in grazing animals. 

Grazing would be permitted within the study corridors of the eligible rivers per the SWMFP. Eligible 

rivers would continue to be managed for free-flowing condition, water quality, tentative classification, 

and ORVs per BLM (2012a) until a decision on suitability is made. These values would also continue to 

receive protection through existing federal, State, and local laws. 

Collectively, the effects from grazing management actions on the Unalakleet Wild River Corridor and 

rivers eligible for WSR designation under Alternative A would be small because the WSRs are located in 

remote areas where demand for permitted grazing areas is low or absent. 

Effects under Alternative B 

Under Alternative B, all BLM-managed lands within the planning area would be closed to grazing, 

including BLM-managed lands near the rivers identified as eligible for WSR designation. No adverse 

impacts from grazing management actions would occur under Alternative B within the Unalakleet Wild 

River Corridor or rivers recommended as suitable for inclusion in the National System. This measure 

would contribute to the protection of water quality, wild river classification, and ORVs of these rivers by 

preventing sedimentation or erosion associated with an increase in grazing animals. These values would 

also continue to receive protection through existing federal, State, and local laws. 

Effects under Alternative C 

Under Alternative C, the Unalakleet Wild River Corridor would be closed to grazing. No impacts to freeflowing character, water quality, wild river classification or ORVs from grazing are expected to result 

from Alternative C. Similar to Alternative B; this measure would contribute to the protection of water 

quality, wild river classification, and ORVs of the Unalakleet River by preventing sedimentation or 

erosion associated with an increase in grazing animals. 

Under Alternative C, eligible rivers would be eliminated from further consideration for inclusion in the 

National System. The ORVs for which these rivers were recognized could be protected through other 

management actions (e.g. HVW, which would be closed to grazing until grazing standards and guidelines 

for riparian health were identified) and through existing federal, State, and local laws. Most of the eligible 

river segments are located in remote parts of the planning area without demand for grazing permit areas, 

so any adverse WSR impacts from this allowed use are likely to be small. 

Effects under Alternative D 

Under Alternative D, grazing would be permitted in the Unalakleet Wild River Corridor only if it is 

determined that the proposed grazing is consistent with provisions of the WSR Act. Consistent with the 

Act, grazing would be required to protect or enhance free-flowing conditions, water quality, wild river 

classification, and ORVs of the Unalakleet River. 

Under Alternative D, eligible rivers would be eliminated from further consideration for inclusion in the 

National System. As in Alternative C, the ORVs for which these rivers were recognized could be 

protected through existing federal, State, and local laws. Most of the eligible river segments are located in 

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Appendix N: Supplemental Impact Analysis Information Section 3: Supplemental Impact Analysis 

remote parts of the planning area without demand for grazing permit areas, so any adverse WSR impacts 

from this allowed use are likely to be small. 

Wild and Scenic Rivers: Effects from Locatable Minerals Management Actions 

Effects under Alternative A 

Under Alternative A, the Unalakleet Wild River Corridor would be closed to mineral entry. An additional 

36,725 acres in eligible river corridors is withdrawn from locatable mineral entry. This measure would 

contribute to the protection of free-flowing conditions, water quality, wild river classification, and ORVs 

of these rivers by limiting the potential for impacts (e.g., contamination, sedimentation, noise, visual) to 

these attributes from mineral development. 

Most areas of the eligible rivers would be open to mineral entry per the SWMFP (BLM 1981a), with 

exclusions coinciding with certain resource areas. Where eligible or designated rivers are open, 

Alternative A would not contribute to the protection of free-flowing conditions, water quality, wild river 

classification, or ORVs. Where eligible rivers overlap exclusion zones (e.g., Anvik River), Alternative A 

would contribute to protection of these attributes. Impacts to eligible rivers from locatable mineral 

development are expected to be small due to the remote locations of eligible river corridors and 

association with low mineral potential areas. Eligible rivers would continue to be managed for freeflowing condition, water quality, tentative classification, and ORVs per BLM (2012a) until a decision on 

suitability is made. These values would also continue to receive protection through existing federal, State, 

and local laws. 

Effects Common to All Action Alternatives 

Under all action Alternatives, WSR corridors would be withdrawn from locatable mineral entry, subject 

to valid existing rights. Impacts to the Unalakleet Wild River would be the same as described under 

Alternative A. 

Effects under Alternative B 

Under Alternative B, the Unalakleet Wild River Corridor and 98 percent of river corridors identified as 

suitable for inclusion in the National System would be withdrawn from locatable mineral entry and closed 

to salable mineral development. This action would contribute to the protection of free-flowing conditions, 

water quality, wild river classification, and ORVs by limiting the potential for impacts (e.g., 

contamination, sedimentation, noise, visual) to these attributes from mineral development. 

Suitable rivers would continue to be managed for free-flowing condition, water quality, tentative 

classification, and ORVs per BLM (2012a). Direct impacts to suitable WSRs from locatable minerals are 

expected to be small due to the remote locations of these rivers and their classification as areas of low 

mineral potential. These values would also continue to receive protection through existing federal, State, 

and local laws. 

Effects under Alternative C 

Under Alternative C, eligible rivers would be determined to be not suitable and eliminated from further 

consideration for inclusion in the National System. The ORVs for which these rivers were recognized 

could be protected through other management actions (e.g., HVWs), and in locations where the vacated 

study corridors intersect the INHT NTMC (see “Wild and Scenic Rivers: Effects from National Trails”). 

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Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

Direct impacts to these rivers from locatable mineral development are expected to be small due to the 

remote locations of these rivers and their association with areas of low mineral potential. The WSR values 

would also continue to receive protection through existing federal, State, and local laws. 

Effects under Alternative D 

Impacts from locatable minerals management actions would be the same as Alternative C. 

Wild and Scenic Rivers: Effects from Salable Minerals Management Actions 

Effects under Alternative A 

Under Alternative A, the Unalakleet Wild River Corridor (46,953 acres) would be closed to salable 

mineral entry. This measure would contribute to the protection of free-flowing conditions, water quality, 

wild river classification, and ORVs of this river by limiting the potential for adverse impacts (e.g., 

contamination, sedimentation, noise, visual) to these attributes from mineral development. 

Eleven percent (26,725 acres) of the area in eligible river corridors would also remain closed to salable 

entry under current withdrawals. The remainder of eligible river corridors would be open to salable 

mineral entry per the SWMFP (BLM 1981a). 

Where eligible rivers are open for leasing, Alternative A would not contribute to the protection of freeflowing conditions, water quality, wild river classification, and ORVs. Where eligible rivers overlap an 

exclusion zone (e.g., Anvik River), Alternative A would contribute to the protection of these attributes. 

Direct adverse impacts to eligible rivers from salable mineral development are expected to be small due to 

their remote location and association with low mineral potential areas. 

Eligible rivers would continue to be managed for free-flowing condition, water quality, tentative 

classification, and ORVs per BLM (2012a) until a decision on suitability is made. These values would 

also continue to receive protection through existing federal, State, and local laws. 

Effects under Alternative B 

Under Alternative B, the designated Unalakleet River would be closed to salable minerals. For suitable 

corridors, 324,220 acres (98 percent) would also be closed to salable minerals. This management action 

would result in beneficial direct impacts to the corridors by limiting potential for development that could 

affect water quality, ORVs, and wild river classification (e.g., contamination, sedimentation, noise, 

visual). 

Direct impacts to suitable WSRs from mineral development actions are expected to be small due to the 

remote locations of these rivers and their association with areas of low mineral potential. Where these 

rivers intersected the INHT, management actions to protect the INHT would benefit suitable WSRs by 

limiting the potential for the same impacts to water quality, ORVs and wild river classification described 

above (e.g., contamination, sedimentation, noise, visual) from leasable mineral development (see “Wild 

and Scenic Rivers: Effects from National Trails”). Additionally, suitable rivers would continue to be 

managed for free-flowing condition, water quality, tentative classification, and ORVs per BLM (2012a). 

These values would also continue to receive protection through existing federal, State, and local laws. 

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Appendix N: Supplemental Impact Analysis Information Section 3: Supplemental Impact Analysis 

Effects under Alternative C 

Under Alternative C, eligible rivers would be determined to be not suitable and eliminated from further 

consideration for inclusion in the National System. Other management actions would result in 7,801 acres 

(2 percent) of the corridors closed to salable, 286,614 acres (86 percent) open on a case-by-case basis, and 

36,704 acres (11 percent) open under standard conditions. Adverse impacts to these rivers from mineral 

development (lessening of wild character, increased surface disturbance leading to reductions in water 

quality and fish ORVs) are expected to be small given their locations in areas of low mineral potential. 

The ORVs for which these rivers were recognized could be protected through other management actions 

(e.g. HVWs), and also in locations where the vacated study corridors intersect the INHT NTMC (see 

“Wild and Scenic Rivers: Effects from National Trails”). These values would also continue to receive 

protection through existing federal, State, and local laws. 

Effects under Alternative D 

Under Alternative D, eligible rivers would be determined to be not suitable and eliminated from further 

consideration for inclusion in the National System. Salable entry would be closed in 9,824 acres of these 

areas, while standard entry would be permitted in the remaining 321,296 acres. This alternative would be 

least protective of ORVs in currently eligible corridors. 

Wild and Scenic Rivers: Effects from Leasable Minerals Management Actions 

Effects under Alternative A 

Under Alternative A, the Unalakleet Wild River Corridor (46,953 acres) would be closed to leasable 

mineral entry. This measure would contribute to the protection of free-flowing conditions, water quality, 

wild river classification, and ORVs of this river by limiting the potential for adverse impacts (e.g., 

contamination, sedimentation, noise, visual) to these attributes from mineral development. 

Thirty-eight percent (127,277 acres) of the eligible river corridors would also remain closed to leasable 

entry under current withdrawals. The remainder of eligible river corridors would be open to mineral entry 

per the SWMFP (BLM 1981a). 

Where eligible rivers are open for leasing, Alternative A would not contribute to the protection of freeflowing conditions, water quality, wild river classification, and ORVs. Where eligible rivers overlap an 

exclusion zone (e.g., Anvik River), Alternative A would contribute to the protection of these attributes. 

Direct adverse impacts to eligible rivers from leasable mineral development are expected to be small due 

to their remote location and association with low mineral potential areas. 

Eligible rivers would continue to be managed for free-flowing condition, water quality, tentative 

classification, and ORVs per BLM (2012a) until a decision on suitability is made. These values would 

also continue to receive protection through existing federal, State, and local laws. 

Effects under Alternative B 

Under Alternative B, the designated Unalakleet River would be closed to leasing. For suitable corridors, 

315,906 acres (95 percent) would be closed to leasing with most of the remainder open to NSO leasing. 

This management action would result in beneficial direct impacts to the corridors by limiting potential for 

development that could affect water quality, ORVs, and wild river classification (e.g., contamination, 

sedimentation, noise, visual). 

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Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

Direct impacts to suitable WSRs from leasable mineral development actions are expected to be small due 

to the remote locations of these rivers and their association with areas of low mineral potential. Where 

these rivers intersected the INHT, management actions to protect the INHT would benefit suitable WSRs 

by limiting the potential for the same impacts to water quality, ORVs and wild river classification 

described above (e.g., contamination, sedimentation, noise, visual) from leasable mineral development 

(see “Wild and Scenic Rivers: Effects from National Trails”). Additionally, suitable rivers would continue 

to be managed for free-flowing condition, water quality, tentative classification, and ORVs per BLM 

(2012a). 

These values would also continue to receive protection through existing federal, State, and local laws. 

Effects under Alternative C 

Impacts from leasable minerals management actions affecting the Unalakleet Wild River Corridor would 

be the same as described for Alternative B. 

Under Alternative C, eligible rivers would be determined to be not suitable and eliminated from further 

consideration for inclusion in the National System. NSO leasing would be permitted in 294,587 acres of 

these areas, while standard leasing would be permitted in the remaining 36,532 acres. Adverse impacts to 

these rivers from leasable mineral development (lessening of wild character, increased surface 

disturbance leading to reductions in water quality and fisheries ORVs) are expected to be small given 

their locations in areas of low mineral potential. 

The ORVs for which these rivers were recognized could be protected through other management actions 

(e.g. HVWs), and also in locations where the vacated study corridors intersect the INHT NTMC (see 

“Wild and Scenic Rivers: Effects from National Trails”). These values would also continue to receive 

protection through existing federal, State, and local laws. 

Effects under Alternative D 

Under Alternative D, eligible rivers would be determined to be not suitable and eliminated from further 

consideration for inclusion in the National System. NSO leasing would be permitted in 9,824 acres of 

these areas, while leasing subject to standard stipulations would be permitted in the remaining 321,296 

acres. This alternative would be least protective of ORVs in currently eligible corridors. 

Wild and Scenic Rivers: Effects from Lands and Realty Management Actions 

This analysis considered ROW decisions that would be triggered either by WSR actions or by other 

management actions, such as those stemming from the INHT NTMC or ACEC designations. This means 

that even under Alternatives C and D, where the currently eligible waterways would have no special WSR 

designation, the wild character and/or fishery and cultural ORVs of parts of the rivers would receive some 

additional protections. Table 3.9.3-4 summarizes the approximate acreages affected; the effects are 

discussed in the sections below. 

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Appendix N: Supplemental Impact Analysis Information Section 3: Supplemental Impact Analysis 

Table 3.9.3-4: WSR Intersections with ROW Actions 

Watercourse ROW Zone Acres under A Acres under B Acres under C Acres under D 

Anvik River Exclusion 0 61,100 0 0 

Avoidance 0 0 60,057 59,589 

Bear Creek (Nikolai) Exclusion 0 17,224 0 0 

Avoidance 0 0 16,453 15,922 

Big River Exclusion 0 21,859 0 0 

Avoidance 0 0 21,315 21,315 

Blackwater Creek Exclusion 0 7,617 0 0 

Avoidance 0 0 198 198 

Canyon Creek Exclusion 0 8,233 0 0 

Avoidance 0 0 8,233 8,186 

Middle Fork 

Kuskokwim 

Exclusion 0 23,212 0 0 

Avoidance 0 0 19,858 19,858 

North Fork Unalakleet Exclusion 0 28,987 0 0 

Avoidance 0 0 28,568 28,396 

Otter Creek (Anvik) Exclusion 0 21,130 0 0 

Avoidance 0 0 19,968 19,968 

Otter Creek (Tuluksak) Exclusion 0 3,247 0 0 

Avoidance 0 0 3,218 3,218 

Pitka Fork Middle Fork 

Kuskokwim River 

Exclusion 0 24,921 0 0 

Avoidance 0 0 22,833 22,069 

Salmon River (Nikolai) Exclusion 0 10,536 0 0 

Avoidance 0 0 10,536 10,269 

Sheep Creek Exclusion 0 15,861 0 0 

Avoidance 0 0 1,708 121 

Sullivan Creek Exclusion 0 9,192 0 0 

Avoidance 0 0 9,192 9,123 

Swift River (Anvik) Exclusion 0 16,381 0 0 

Avoidance 0 0 16,381 16,381 

Tatlawiksuk River Exclusion 0 8,975 0 0 

Avoidance 0 0 8,792 8,792 

Theodore Creek Exclusion 0 7,384 0 0 

Avoidance 0 0 7,308 514 

Unalakleet Designated 

WSR 

Exclusion 0 46,953 0 0 

Avoidance 0 0 46,953 46,953 

Yellow River Exclusion 0 28,409 0 0 

Avoidance 0 0 27,680 27,478 

Yukon River Exclusion 0 18,903 0 0 

Avoidance 0 0 13,336 7,801 

Total Exclusion 0 378,0731 0 0 

Avoidance 0 0 341,5401,2 325,0951 

Notes: 

1 1,057 acres of the eligible North Fork Unalakleet overlaps with the designated Unalakleet River. This acreage is only counted once. 

2 313,144 acres are designated ROW Avoidance, and 28396 acres are designated Avoidance for Linear Realty Actions 

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Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

Effects under Alternative A 

No current management direction for eligible or designated WSRs exists for ROW exclusion and 

avoidance areas under Alternative A. Lands within the Unalakleet Wild River Corridor would continue to 

be retained by the BLM. 

Under Alternative A, free-flowing condition, water quality, wild river classification, and river values of 

the Unalakleet Wild River Corridor would continue to be protected under the Unalakleet National Wild 

River Management Plan (BLM 1983) and mandates of the WSR Act. These WSR attributes of eligible 

rivers would continue to be managed per guidelines provided in BLM Manual 6400 (BLM 2012). These 

values would also continue to receive protection through existing federal, State, and local laws. 

Effects Common to All Action Alternatives 

Lands within the Unalakleet Wild River Corridor would be retained under all action alternatives. 

Effects under Alternative B 

Under Alternative B, 46,953 acres within the Unalakleet Wild River Corridor and the 18 rivers within the 

planning area (332,176 acres) proposed as suitable for inclusion in the National System would be 

designated as ROW exclusion areas subject to ANILCA and valid existing rights. Designation as ROW 

exclusion zones would beneficially impact the protection of the free-flowing condition, water quality, 

wild river classification, river values (of the Unalakleet Wild River Corridor), and ORVs by restricting 

the construction and operation of ROW and potential surface disturbance that could be associated with 

such action. 

Suitable rivers would continue to be managed for free-flowing condition, water quality, tentative 

classification, and ORVs per BLM (2012a). 

Effects under Alternative C 

Under Alternative C, 46,953 acres within the Unalakleet Wild River Corridor would be designated as a 

ROW avoidance area. Impacts from lands and realty management actions under Alternative C would not 

be expected to adversely impact the Unalakleet Wild River Corridor, as actions would be required to 

protect and enhance the free-flowing condition, water quality, wild river classification, and river values of 

this designated river. The Unalakleet Wild River Corridor would continue to be managed under the 

Unalakleet National Wild River Management Plan (BLM 1983) and the WSR Act. 

Although, under Alternative C, the 18 currently eligible river corridors would no longer have any special 

WSR designation, 294,587 acres of that area (89 percent of ROW exclusion for B) would be designated 

ROW avoidance areas on the basis of other management actions, such as those pertaining to ACECs or 

the INHT NTMC. This would limit surface disturbance that has adverse effects on water quality, fish 

ORVs, and cultural ORVs. The free-flowing and wild attributes of the currently eligible corridors would 

not be prioritized. 

Effects under Alternative D 

Under Alternative D, impacts from lands and realty management actions within the Unalakleet Wild 

River Corridor would be the same as described for Alternative C, but the ROW avoidance area from other 

management directives would be smaller. Under Alternative D, 278,142 acres of currently eligible river 

corridors (84 percent of ROW exclusion for B) would be designated ROW avoidance areas on the basis of 

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other management actions, such as those pertaining to the INHT NTMC. This would limit surface 

disturbance that has adverse effects on water quality, fish ORVs, and cultural ORVs. The free-flowing 

and wild attributes of the currently eligible corridors would not be prioritized. 

Wild and Scenic Rivers: Effects from Travel and Transportation Management Actions 

In addition to management actions common to all action alternatives, potential impacts from the 

Unalakleet Wild River Corridor Travel Management Decisions were considered. 

Effects under Alternative A 

Under Alternative A, the Unalakleet Wild River Corridor would be continued to be managed per 43 CFR 

36.11, which prohibits casual OHV use. There would be no restrictions for rivers within the planning area 

identified as eligible for WSR designation. Impacts to eligible WSRs could result if OHV use continued 

to increase in the planning area and/or impacts were exacerbated from OHV use during permafrost thaw. 

Alternative A would not contribute to protection of free-flowing character, water quality, wild river 

classification, or protection of ORVs. 

Effects under Alternative B 

Under Alternative B, casual summer OHV access to the Unalakleet Wild River Corridor would be 

prohibited. Subsistence summer OHV access would be limited to existing trails, primitive roads, and 

roads and would include ATVs only. Winter cross-country OHV access would be allowed for 

snowmobiles only. These actions would contribute to the protection of water quality, wild river 

classification, and river values associated with the Unalakleet Wild River Corridor by minimizing impacts 

from sedimentation, damage to riparian resources, or creation of OHV ruts within the corridor. 

Under Alternative B, no protections would be applied to study corridors for those rivers identified as 

suitable for inclusion in the National System. These areas would be managed per guidelines provided in 

BLM Manual 6400 (BLM 2012). The Unalakleet Wild River Corridor and suitable rivers would continue 

to receive protection from existing federal, State, and local laws. 

Effects under Alternative C 

Under Alternative C, casual summer OHV access to the Unalakleet Wild River Corridor would be limited 

to existing trails, primitive roads, and roads (as shown in the BLM’s current route inventory) and would 

include ATVs only. Subsistence cross-country summer OHV access would be allowed and would include 

ATVs only. Winter cross-county OHV access would be allowed for snowmobiles only. As with 

Alternative B, BLM-managed lands near rivers identified as eligible for WSR designation would be 

subject to the travel and transportation management decisions in the SWMFP. While the seasonal access 

and vehicle use restrictions under Alternative C would be less restrictive than those described for 

Alternative B, impacts to the Unalakleet Wild River Corridor from travel and transportation management 

actions under Alternative C would still be relatively small because of the remoteness of these areas and 

the low demand for increased OHV use. 

The Unalakleet Wild River Corridor and vacated study rivers would continue to receive protection from 

existing federal, State, and local laws. 

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Effects under Alternative D 

Under Alternative D, casual summer OHV access to the Unalakleet Wild River Corridor would be limited 

to existing trails, primitive roads, and roads (as shown in the BLM’s current route inventory) and would 

include both UTVs and ATVs. Subsistence cross-county summer OHV access would be allowed and 

would include both UTVs and ATVs. Winter cross-county OHV access would be allowed and would 

include snowmobiles. While the seasonal access and vehicle use restrictions under Alternative D would 

be less restrictive than those described for Alternatives B and C, impacts to the Unalakleet Wild River 

Corridor from travel and transportation management actions under Alternative D would still be relatively 

small because of the remoteness of these areas and the low demand for increased OHV use. 

The Unalakleet Wild River Corridor and vacated study rivers would continue to receive protection from 

existing federal, State, and local laws. 

Wild and Scenic Rivers: Effects from Areas of Critical Environmental Concern 

Management Actions 

In addition to management actions common to all action alternatives, potential impacts from ACECspecific designations and their overlap with WSR study corridors were considered. 

Table 3.9.3-5 summarizes the WSR intersections with ACECs. 

Table 3.9.3-5: WSR Intersections with ACECs 

Watercourse Alternative A Acres Alternative B acres Alternative C acres Alternative D Acres 

Anvik River 61,100 56,500 0 0 

Bear Creek (Nikolai) 0 17,224 0 0 

Big River 0 21,859 0 0 

Blackwater Creek 0 7,617 0 0 

Canyon Creek 0 0 0 0 

Middle Fork Kuskokwim 0 23,212 0 0 

North Fork Unalakleet 0 28,209 0 0 

Otter Creek (Anvik) 400 375 0 0 

Otter Creek (Tuluksak) 0 0 0 0 

Pitka Fork Middle Fork 

Kuskokwim River 

0 24,625 0 0 

Salmon River (Nikolai) 0 10,213 0 0 

Sheep Creek 0 15,861 0 0 

Sullivan Creek 0 9,192 0 0 

Swift River (Anvik) 200 600 0 0 

Tatlawiksuk River 0 0 0 0 

Theodore Creek 1,000 600 0 0 

Unalakleet Designated 

WSR 

0 45,633 0 0 

Yellow River 80 0 0 0 

Yukon River 0 0 0 0 

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Effects under Alternative A 

The Unalakleet Wild River Corridor is fully located within the boundaries of the existing Drainages of the 

Unalakleet River ACEC. Although management actions associated with the WSR would take precedence 

over those assigned to the ACEC, direct beneficial impacts to the Unalakleet Wild River Corridor could 

result from added protection of ORVs for fisheries, as the ACEC occupies a larger geographic area than 

the designated corridor, with more of a watershed approach to management. 

Under Alternative A, direct beneficial impacts to eligible WSRs would result from overlap with existing 

ACECs, where ORVs correspond to the relevant and important values for which the ACEC was 

designated. Beneficial impacts would be greatest where overlapping acreage is the largest. Acreage values 

listed in Table 3.9.3-6 are based on GIS layers and should be considered approximate. Table 3.9.3-6 

summarizes the intersections of eligible WSRs with existing ACECs. 

Table 3.9.3-6: Intersections of Eligible WSRs with Existing ACECs (Alternative A) 

Watercourse Existing ACEC 

Eligible River Miles

in ACEC 

Percent of Eligible

Waterway in ACEC 

Size of ACEC 

(acres) 

Anvik River Anvik 118 99% 114,386 

North Fork Unalakleet Drainages of the Unalakleet 48 100% 403,378 

Otter Creek (Anvik) Anvik Less than 2 4% 114,386 

Swift River (Anvik) Anvik Less than 2 4% 114,386 

Theodore Creek Anvik Less than 4 24% 114,386 

Yellow River Anvik 3 4% 114,386 

Effects under Alternative B 

Impacts to the Unalakleet Wild River would be the same as described under Alternative A, although it 

would intersect with the potential Unalakleet Watershed ACEC rather than the existing Drainages of the 

Unalakleet ACEC. 

Under Alternative B, eligible rivers would be considered as suitable for inclusion in the National System. 

Direct beneficial impacts of overlap of suitable rivers with potential ACECs would result from added 

protection of relevant and important values for fish and/or cultural resources, as applicable, if the ACECs 

are designated. Table 3.9.3-7 summarizes the suitable WSR intersections with potential ACECs. 

Table 3.9.3-7: Suitable WSR Intersections with Potential ACECs (Alternative B) 

Watercourse Potential ACEC 

Eligible River Miles

in Potential ACEC 

Percent of Eligible

Waterway in ACEC 

Size of Potential 

ACEC (acres) 

Anvik River Anvik River Watershed 117 98% 248,872 

Bear Creek (Nikolai) Sheefish 41 100% 696,902 

Big River Sheefish 35 100% 696,902 

Blackwater Creek Sheefish 12 100% 696,902 

Canyon Creek Anvik River Watershed Less than 1 Less than 1% 248,872 

Middle Fork Kuskokwim Sheefish 52 100% 696,902 

North Fork Unalakleet Unalakleet Watershed 39 81% 733,995 

Otter Creek (Anvik) Anvik River Watershed Less than 1 Less than 1% 248,872 

Pitka Fork Middle Fork 

Kuskokwim River 

Sheefish 61 98% 696,902 

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Watercourse Potential ACEC 

Eligible River Miles

in Potential ACEC 

Percent of Eligible

Waterway in ACEC 

Size of Potential 

ACEC (acres) 

Salmon River (Nikolai) Sheefish 20 95% 696,902 

Sheep Creek Sheefish 36 100% 696,902 

Sullivan Creek Sheefish 22 100% 696,902 

Swift River (Anvik) Anvik River Watershed Less than 1 Less than 1% 248,872 

Theodore Creek Anvik River Watershed Less than 1 Less than 1% 248,872 

Effects under Alternative C 

Under Alternative C, no ACECs would be designated and eligible rivers would not be carried forward for 

inclusion in the National System. Therefore; there would be no impacts from ACEC management to 

designated or eligible rivers under Alternative C, and the wild or free-flowing character of the currently 

eligible waterways would not receive protections under Alternative C. 

Effects under Alternative D 

Under Alternative D, the eligible rivers would retain no special management designation. The Unalakleet 

Wild River Corridor would continue to be managed under the Unalakleet National Wild River 

Management Plan (BLM 1983) and the WSR Act. The Unalakleet Wild River Corridor and vacated study 

rivers would continue to receive protection from existing federal, State, and local laws. 

Wild and Scenic Rivers: Effects from National Trails Actions 

Effects under Alternative A 

Under Alternative A, no INHT NTMC would be established and, consequently, there would be no 

beneficial direct impacts to WSRs from management actions associated with this designation. 

Effects Common to All Action Alternatives 

Under all action alternatives, a NTMC would be established in three geographically distinct areas: Kaltag 

Portage, Farewell Burn, and Rohn. The Unalakleet Wild River Corridor would intersect the Kaltag 

Portage in all action alternatives, with the only difference being the number of acres allocated across each 

of the alternatives. Under all action alternatives, lands within the WSR corridor are managed per equal or 

more restrictive management actions. Consequently, there would be no impact from management of 

NHTs. 

Effects under Alternative B 

Under Alternative B, the entire Unalakleet Wild River Corridor (46,953 acres) would intersect the INHT 

NTMC in the Kaltag Portage segment. Because the WSR entails more restrictive management actions 

than the NTMC, there would be no impact to the Unalakleet Wild River Corridor from management 

actions associated with NHTs, as described in the section “Effects Common to All Action Alternatives” 

above. 

Under Alternative B, study corridors for rivers identified as suitable for inclusion in the National System 

also intersect the NTMC, for approximately 5,012 acres in the Kaltag Portage Segment (North Fork of the 

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Unalakleet) and 25,090 acres in the Farewell Burn Segment (Pitka Fork Middle Fork Kuskokwim River), 

Salmon River (Nikolai), Bear Creek (Nikolai), and Sheep Creek. 

In the portions of these study rivers that overlap the INHT corridor, study rivers would receive protections 

from mineral decisions, and surface disturbance that could result in direct impacts to study rivers by 

protecting water quality, ORVs, and wild river classification (see Section 3.8, “National Trails”). Rivers 

recommended as suitable for inclusion in the National System would also continue to be managed per 

guidelines provided in BLM Manual 6400 (BLM 2012) and existing federal, State, and local laws. 

Effects under Alternative C 

Under Alternative C, the entire Unalakleet Wild River Corridor (46,953 acres) would intersect the INHT 

NTMC. There would be no impact to the Unalakleet from management actions associated with NHTs, as 

described in the section “Effects Common to All Action Alternatives” above. 

Under Alternative C, eligible rivers would be determined to be not suitable and eliminated from 

consideration for the National System. Water quality and ORVs in portions of the vacated study rivers 

that overlap the NTMC would be protected by land management decisions associated with the INHT 

NTMC where they intersect the management corridor. Free-flowing condition would not be prioritized. 

These added protections could result in direct beneficial impacts by protecting water quality, ORVs, and 

wild river characteristics (see Section 3.8, “National Trails”). Rivers would also continue to be managed 

per existing federal, State, and local laws. 

Effects under Alternative D 

Impacts would be the same as those described for Alternative C. 

Wild and Scenic Rivers: Effects from Wild and Scenic Rivers Management Actions 

In addition to management actions common to all action alternatives, potential impacts from 

improvements within the Unalakleet Wild River Corridor (recreation and visitor services actions) were 

considered. 

Effects under Alternative A 

Under Alternative A, the Unalakleet Wild River Corridor would continue to be managed under the 

SWMFP, the CYRMP, and the Unalakleet National Wild River Management Plan (BLM 1983). The 

SWMFP excludes the WSR corridor from oil and gas leasing and other types of entries (BLM 1981a). 

The SWMFP also includes the goal to “identify and recommend for designation any rivers in the planning 

area that are suitable for designation as components of the National WSR System.” This goal was 

accomplished as part of the BSWI RMP planning process through the WSR Study (BLM 2018b). 

Management direction in the Unalakleet National Wild River Management Plan (BLM 1983) includes 

management actions for subsistence, facilities, visitor management, surface transportation, publicity, 

private lands (Native allotments), fisheries habitat management, local involvement, navigability, fire 

management, and cultural resources. Alternative A would protect and enhance the free-flowing condition, 

water quality, wild river classification and ORVs of the Unalakleet Wild River Corridor based on 

management objectives and actions provided in the Unalakleet National Wild River Plan (BLM 1983). 

Under Alternative A, rivers identified as eligible would continue to be managed per guidelines provided 

in BLM Manual 6400 (BLM 2012). These guidelines would protect free-flowing condition, water quality, 

wild river classification, and ORVs. 

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Effects Common to All Action Alternatives 

Under all action alternatives, the Unalakleet Wild River Corridor would continue to be managed under the 

Unalakleet National Wild River Management Plan (BLM 1983). The management objectives would 

protect and enhance the free-flowing condition, water quality, wild river classification, and ORVs of the 

Unalakleet Wild River Corridor by improving manageability (through land acquisition); limiting potential 

for development that could result in visual, noise, or water quality impacts (withdrawals, commercial 

development, restrictions on air travel); managing resources (prohibiting harvest of house logs except for 

subsistence use); and maintaining wild character (travel-related decision that maintain semi-primitive 

motorized travel). 

Effects under Alternative B 

Under Alternative B, the Unalakleet Wild River Corridor would continue to be managed under the 

Unalakleet National Wild River Management Plan (BLM 1983) and as described for Alternative A. 

Additional restrictions on improvements (landing areas, campsites, interpretive sites, or toilets) and UASs 

would be applied under Alternative B. Clearing of vegetation near shelter cabins would be limited to the 

minimum needed for fire protection. These restrictions would ensure that development that could affect 

the wild river classification would not occur, and that potential noise-related impacts from UASs would 

not occur. Collectively, these management actions would protect and enhance free-flowing condition, 

water quality, wild river classification and ORVs. 

Rivers identified as eligible for inclusion in the National System would be recommended as suitable 

under Alternative B. These rivers would continue to be managed per guidelines provided in BLM Manual 

6400 (BLM 2012) to protect free-flowing condition, water quality, wild river classification, and ORVs, 

until a decision is made regarding their inclusion in the National System. In addition, all of the suitable 

corridors would be managed as VRM Class I. Management of these corridors as VRM Class I would 

serve as a tool to limit direct impacts to water quality, wild river classification, and ORVs that could 

result from surface-disturbing activities. 

If designated as WSRs, these rivers would be managed as described above for the Unalakleet, which 

includes restrictions on improvements (landing areas, campsites) and UASs. If designated, these 

management actions would protect and enhance free-flowing condition, water quality, wild river 

classification, and ORVs. 

Impacts to WSRs from travel management and visual resource management decisions are described in the 

subsections “Wild and Scenic Rivers: Effects from Travel and Transportation Management,” and “Wild 

and Scenic Rivers: Effects from Travel and Visual Resource Management.” 

Effects under Alternative C 

Under Alternative C, the Unalakleet Wild River Corridor would continue to be managed under the 

Unalakleet National Wild River Management Plan (BLM 1983) as described for Alternative A. 

Construction or formal improvement of landing areas, campsites, interpretive sites or toilets would occur 

only as needed to maintain those facilities for use. These improvements would be compatible with the 

primitive setting and ORVs for which the WSR was designated and consistent with VRM Class I. As in 

Alternative B, takeoff and landing of casual use UASs would be prohibited, and administrative use would 

be permitted on a case-by-case basis. Management actions specific to Alternative C would protect wild 

river classification and ORVs by limiting development that would change access or character and 

ensuring protection of ORVs. Collectively, these management actions would protect and enhance free3-254 
 

 

 

 

 

 

 

 

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flowing condition, water quality, wild river classification, and ORVs of the Unalakleet Wild River 

Corridor. 

Under Alternative C, eligible rivers would be determined to be not suitable and eliminated from further 

consideration for inclusion in the National System. Water quality and ORVs would continue to receive 

protections through existing federal, State, and local laws. While not afforded the additional protections 

provided by a recommendation as suitable or subsequent WSR designation, impacts to these rivers are 

likely to be limited due to these existing protections and the remoteness of these rivers, which has 

precluded demand for development of facilities. 

Protections for ORVs of fish (all eligible rivers, except the Yukon River), cultural resources (Anvik and 

Yukon Rivers), and historic resources (Bear Creek [Nikolai], Pitka Fork Middle Fork Kuskokwim River, 

Salmon River [Nikolai], Swift River [Anvik], and Sullivan Creek) for vacated study rivers would still be 

applied through existing federal, State, and local laws. 

Effects under Alternative D 

Under Alternative D, the Unalakleet Wild River Corridor would continue to be managed under the 

Unalakleet National Wild River Management Plan (BLM 1983) as described for Alternative A. 

Construction or formal improvement of landing areas, campsites, interpretive sites, or toilets would be 

allowed within the Unalakleet Wild River Corridor if they do not substantively conflict with the ORVs 

for which the WSR was designated and are compatible with VRM Class I. Management actions specific 

to Alternative D would protect wild river classification and ORVs by limiting development that would 

change access or character and evaluating impacts to ORVs on a case-by-case basis. 

Under Alternative D, eligible rivers would be eliminated from further consideration for inclusion in the 

National System. Impacts to these rivers would be identical to Alternative C. 

Wild and Scenic Rivers: Effects from Support for BSWI Communities Management 

Actions 

Impacts to WSRs from Support for BSWI Communities are analyzed below and in the following relevant 

sections: 

• “Wild and Scenic Rivers: Effects from Grazing Management Actions” 

• “Wild and Scenic Rivers: Effects from Water Resources and Fisheries Management Actions” 

• “Wild and Scenic Rivers: Effects from Travel and Transportation Management Actions” 

• “Wild and Scenic Rivers: Effects from Forestry and Woodland Products Management Actions” 

In addition to management actions common to all action alternatives, potential impacts from Cultural 

Landscape Reports were considered. 

Effects under Alternative A 

Under Alternative A, land under the SWMFP (1981) is managed per objectives to protect and preserve 

cultural sites from damage or destruction. No specific management actions are identified; however, the 

planning area would be managed per existing federal and State laws and regulations developed to protect 

cultural resources. Existing laws and regulations would contribute to the protection of cultural and 

historic ORVs. Alternative A would not impact free-flowing condition, water quality, wild river 

classification, or ORVs of eligible or designated WSRs; however, it would not degrade these values. 

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Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

Effects under Alternative B 

Under Alternative B, the BLM would support BSWI villages by working collaboratively with rural 

communities in the planning area and other partners to develop Cultural Landscape Reports. These 

documents would utilize traditional and other knowledge to give a contemporary picture of resources uses 

(cultural, fisheries, and wildlife) and their social and historical context and would help villages in their 

own planning efforts, as well as allow the BLM and other agencies to assess impacts of proposed projects 

and plans. Under Alternative B, Cultural Landscape Reports would be developed for 2 to 3 high-priority 

villages but may not be relevant to the Unalakleet Wild River Corridor or those rivers recommended as 

suitable for inclusion in the National System if they are not proximate to the high-priority village selected 

for study. 

Effects under Alternative C 

Under Alternative C, the BLM would also develop Cultural Landscape Reports; this effort would be 

applied to 4 to 6 high-priority villages in the planning area. Therefore, beneficial impacts to cultural and 

fisheries ORVs could be greater than Alternative B but may not be relevant to the Unalakleet Wild River 

Corridor or those rivers recommended as suitable for inclusion in the National System if they are not 

proximate to the high-priority village selected for study. 

Effects under Alternative D 

Under Alternative D, the BLM would also develop Cultural Landscape Reports; however, this effort 

would be applied the entire planning area. Cultural Resource Reports would result in beneficial impacts to 

designated WSRs and those rivers recommended as suitable for inclusion in the National System through 

increased knowledge and documentation of cultural and fisheries ORVs. Beneficial impacts from 

development of Cultural Landscape Reports would be higher under Alternative D than Alternatives B or 

C. 

Wild and Scenic Rivers: Effects from Climate Change Actions 

WSRs could be subject to direct and indirect effects of climate change through changes to the occurrence, 

quantity, distribution, movement, and quality of water. These changes could affect ORVs for fish by 

reducing production and survival. Warming trends, permafrost thaw and increases in wildland fire can 

directly damage or destroy cultural resources, including historic structures, by deepening the active soil 

layer. Deeping of the active layer (absent erosional forces) promotes decomposition and could adversely 

affect organic paleontological and cultural materials. Where soils could experience higher rates of 

erosion, cultural resources could be indirectly impacted as adjacent lands are degraded and subject to 

more erosional forces. The rate of future erosion is expected to be faster and potentially more damaging. 

Increased frequency of strong storms also increases shoreline erosion that could directly and adversely 

affect cultural and paleontological resources. 

Climate change is not expected to affect free-flowing condition or river classification of WSRs. 

Effects Common to all Action Alternatives 

WSR management under all alternatives would not counteract potential climate change impacts to water 

quality, free-flowing conditions, and ORVs of WSRs. 

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Wild and Scenic Rivers: Cumulative Effects 

Currently, the Unalakleet Wild River Corridor is the only designated WSR within the planning area. 

Management direction for the Unalakleet Wild River Corridor is provided in the Unalakleet National 

Wild River Management Plan (BLM 1983), which includes specific management actions for subsistence, 

facilities, visitor management, surface transportation, publicity, private lands (Native allotments), 

fisheries habitat management, local involvement, navigability, wildland fire management, and cultural 

resources. These values remain stable for the Unalakleet Wild River Corridor. The levels of activity and 

demand for access within the Unalakleet Wild River Corridor are expected to remain stable. No existing 

plans or pressure for increased access to the WSR that could affect its classification as a wild river have 

been identified. The corridor continues to be used for primitive recreation opportunities, including 

recreational boating and the Iditarod Race. Historic and archeological values, wildlife/wildlands use, and 

water quality remains stable largely due to the remoteness of the WSR corridor. 

The recently completed BSWI WSR Study (BLM 2018b) identified an additional 18 watercourses within 

the planning area (primarily tributaries to the Unalakleet, Anvik, and Kuskokwim Rivers) that were 

determined by BLM to be eligible for inclusion in the National System. Eligible rivers in the planning 

area were identified for fish, cultural, and historic ORVs. These resources are protected to varying 

degrees by existing federal, State, and local laws and existing ACEC designations. The rivers are 

generally remote and currently experience low use and resource pressure. 

As part of the WSR Study (BLM 2018b), reasonable foreseeable future uses of these rivers were assessed 

to determine if these uses would be enhanced, curtailed, or foreclosed. Only one use was identified that 

could be curtailed or foreclosed if these rivers were designated: the currently permitted Donlin Gold 

Project pipeline ROW intersects the Big River. If this river were designated as a WSR, it would be 

managed as a ROW exclusion (Alternative B) or ROW avoidance (Alternative C) zone. WSR values of 

all rivers would be enhanced by inclusion in the National System; however, this designation would 

complement existing protections provided by existing federal, State, and local laws. 

Table 3.9.3-8 summarizes the effects of the cumulative effects analysis for WSR for all alternatives. 

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Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

Table 3.9.3-8: Cumulative Effects Analysis for Wild and Scenic Rivers 

Trends and Forecasts of WSRs 

in Consideration of Past and 

Present Actions 

Trends and Forecasts of WSRs 

in Consideration of Past, 

Present, and Reasonably

Foreseeable Future Actions 

(Alternative A) 

Trends and Forecasts of WSRs 

in Consideration of Past, 

Present, and Reasonably

Foreseeable Future Actions 

(Alternative B) 

Trends and Forecasts of WSRs 

in Consideration of Past, 

Present, and Reasonably

Foreseeable Future Actions 

(Alternative C) 

Trends and Forecasts of WSRs 

in Consideration of Past, 

Present, and Reasonably 

Foreseeable Future Actions 

(Alternative D) 

Designated and eligible rivers The Unalakleet Wild River would Inclusion of additional rivers in The Unalakleet Wild River would Protections from other 

experience generally low use, be the only river within the the National System would be the only river within the management actions for 

with little pressure on water planning area managed as a ensure that free-flowing planning area managed as a watershed-level protections 

quality, free-flowing condition, WSR. In the Unalakleet Wild condition, wild river classification, WSR. In the Unalakleet Wild would be less than B or C but 

wild river character, and ORVs. River, free-flowing condition, wild ORVs, and water quality were River, free flowing condition, wild greater than A. Protections of 

These qualities are expected to river classification, ORVs, and managed to protect and enhance river classification, ORVs, and free-flowing condition and wild 

remain stable due to the water quality would be managed these attributes in a similar water quality would be managed character would be less than A, 

remoteness of the rivers. to protect and enhance these 

attributes. 

Eligible rivers would continue to 

receive added protection of these 

river attributes per BLM (2012a) 

until a decision on their suitability 

was made. 

Trend: Continues to improve 

manner to the designated 

Unalakleet Wild River. 

Trend: Continues to improve 

to protect and enhance these 

attributes. 

Rivers eliminated from 

consideration in the National 

System could benefit from other 

protections applied to HVWs 

and/or lands managed as 

wilderness characteristics as a 

priority, in addition to 

management actions for VRM. 

B or C. 

Trend: Stabilizes 

Trend: Stabilizes 

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Appendix N: Supplemental Impact Analysis Information Section 3: Supplemental Impact Analysis 

3.10 Support for BSWI Communities 

This section describes the potential impacts on socioeconomics, environmental justice, and support for 

BSWI communities. A discussion of the existing conditions, which is the basis of this analysis, is found 

in the BSWI Draft RMP/EIS Appendix M. 

3.10.1 Economic Conditions 

Summary 

This section addresses the extent to which the alternatives would affect economic conditions in the 

planning area, including how management of other resources and resource uses may impact household 

livelihoods and overall economic viability. Management actions under the alternatives are consistent with 

BLM’s priorities for ensuring energy and economic security for the United States. 

Methods of Analysis 

This section provides qualitative analysis of impacts of the alternatives on socioeconomic conditions in 

the planning area. In particular, the analysis estimates how each alternative would contribute to the ruralmixed economy, including market and non-market values. Given the planning area’s strong rural mixed 

economic composition, it would not be practical or useful to estimate economic effects using IMPLAN or 

another input-output model. The ratings and qualitative descriptions will be based on considerations of 

how management actions may influence risk to household livelihoods reliant upon cash and subsistence 

incomes relative to Alternative A. Public comments and effects to other resources inform the analytical 

approach, narrowing the scope of indicators to those that may reflect a meaningful measure of change in 

risk to household livelihoods and community vitality. 

Potential Effects and Indicators 

The types of effects to the rural-mixed economy that could result from management actions in the RMP 

include effects to market and non-market values (Table 3.10.1-1). Market values include economic 

conditions defined by such measures as jobs and labor income. Due to the planning area’s remote location 

and the existing low level of infrastructure development, there are few economic development 

opportunities where communities in the planning area have a competitive advantage. Such opportunities 

to leverage a competitive advantage are related to unique resource values and recreation opportunities 

afforded in the planning area. The direct and indirect effects of this project contribute to the economic 

structure of households and communities in the planning area. 

Three general types of management actions that may affect market values or economic development 

opportunities in the planning area include grazing, minerals management, and the management of special 

recreation permits. Areas open to grazing would provide opportunities for BSWI communities to take 

advantage of emerging technologies in the processing, packaging, and distribution of reindeer meat, 

which would provide new economic development opportunities that create jobs and increase labor income 

in rural communities. Withdrawals or closures of areas from locatable, leasable, and saleable mineral 

development would restrict the utilization of marketable resources in these areas and therefore limit future 

economic development opportunities. Restrictions placed on SRPs related to where guide outfitters are 

allowed to operate in relation to communities and may affect the amount of expenditures in rural 

communities and hiring of local residents for support services. This may in turn affect the number of job 

opportunities and the amount of labor income in local communities. 

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Non-market values considered in the socioeconomic analysis relate to subsistence resource values that 

contribute to household incomes and to some extent reduce monetary household income requirements 

needed to provide for food, clothing, shelter, and heat. Management actions that reduce risks to natural 

resource conditions important to support the maintenance and reproduction of subsistence resources may 

reduce risks to subsistence incomes. Management actions, such as the designation of wildlife protection 

areas, HVWs, WSRs, ACECs, and caribou avoidance areas, protect terrestrial and aquatic habitats that 

contribute to sustaining subsistence resources. 

It is not only the effects on the maintenance and reproduction of subsistence resources that is considered 

in this analysis but also how management actions may affect access to subsistence resources. Barriers to 

access that may be affected by management actions would be those that would affect the distance required 

to access subsistence resources, as this would affect the income requirements of households related to fuel 

costs to procure subsistence resources. This may be a considerable barrier for some households given the 

high cost of fuel in the planning area and the large percentage of household classified as low-income. 

Management actions that may affect access to subsistence resources in this respect include designations 

affecting where OHV and OSV travel is allowed, where subsistence woodland gathering is allowed, and 

where outfitter-guides are allowed to operate in relation to communities. In respect to SRP administration, 

management actions that reduce the potential for competition between resident and visitor populations for 

subsistence resources near villages may reduce the potential travel requirements and associated costs for 

securing subsistence resources. In summary, management actions that reduce risk to terrestrial and 

aquatic habitats, do not hinder travel and transportation, and reduce competition for subsistence resources 

would have a positive effect on subsistence incomes within the planning area. 

Table 3.10.1-1: Summary of Effects to Economic Conditions by Management Action*** 

Type of Effects Management Action Indicators 

Non-Market Values 

Protection of sensitive areas that support 

the reproduction and maintenance of 

subsistence resources would reduce risks 

to subsistence incomes. 

Designation of wildlife 

protection areas 

• Acres of Innoko Bottoms Priority Wildlife Habitat 

Area 

• Acres of caribou connectivity corridors 

Designation of HVWs • River miles of HVW 

Proposed WSRs • Acres of WSR designations 

Designation of ACECs • Acres of ACECs 

Lands with Wilderness 

characteristics 

• Acres of lands managed to protect wilderness 

characteristics as a priority 

Unrestricted domestic grazing in sensitive 

areas that support the reproduction and 

maintenance of subsistence resources 

would pose risks to subsistence resources. 

Areas closed to grazing • Acres open for commercial grazing 

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Type of Effects Management Action Indicators 

Management of SRP Permittees may affect 

competition for subsistence resources near 

villages, which in turn may affect access to 

subsistence resources and/or increase the 

economic burden on households in terms of 

increased fuel costs due to greater 

distances travelled to secure subsistence 

resources. 

SRP management and 

administration 

• Authorization of Special Recreation Permits 

within Community Focus Zones. 

Affects availability and ease of access to 

subsistence resources, such as firewood, 

which reduces household costs for heating 

oil. 

Personal use and 

subsistence woodland 

harvest areas 

• Acres of woodland harvest land open for 

subsistence use 

• Percent of land where commercial woodland 

harvest is permitted 

• Permit requirements for subsistence collection 

of woodland harvest 

Affects access to subsistence resources Travel and transportation • Acres where summer subsistence OHV is 

and economic burden on households management prohibited. 

related to fuel costs. • Acres where summer subsistence OHV access 

is limited to existing trails. 

• Acres where winter subsistence use 

(snowmobiles only) is allowed 

Market Values 

Factors influencing economic development FLPMA Withdrawals • Acres of land withdrawn to locatable minerals 

opportunities and related jobs and labor 

income that may be generated. Lands open/closed to 

leasable mineral 

development 

Lands open/closed to 

salable mineral 

development 

• Acres of land closed to leasable minerals 

• Acres of land closed to salable minerals 

Lands where domestic grazing is allowed Areas open to grazing • Acres open for commercial grazing 

will create economic development 

opportunities providing jobs and labor 

incomes for rural communities. 

SRP permit administration that would allow SRP management and • Authorization of SRPs within 10-mile radius of 

outfitter guides who have demonstrated administration communities 

consideration of community relations and 

are allowed to operate within 10 miles of 

villages may increase the likelihood of 

expenditures in rural communities and 

hiring of local residents for support services 

and may thereby increase opportunities for 

jobs and labor income in local communities. 

Assumptions 

The following assumptions were used to assess impacts associated with economic conditions in the 

planning area: 

• The BLM has the potential to contribute to economic activity in the planning area through 

management actions that allow or restrict access to the rural mixed economy. 

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Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

• Subsistence incomes are not included in measures that assess poverty or low-income status. 

Subsistence incomes include but are not limited to food, safe drinking water, shelter, and heating 

fuel. 

• In households that are highly reliant upon subsistence incomes some level of cash income is 

required to purchase capital and consumable goods, such as snowmobiles and fuel, which support 

subsistence incomes. 

• The alternatives may differ in terms of their risk reduction to non-market resources, such as 

reduction in risk to wildlife and fisheries habitats. These resources are valued, but not bought or 

sold through markets. 

• Direct and indirect effects from management actions on subsistence and cash incomes are 

speculative, and as such, are described in terms of changes in likelihood or risk. 

• Management actions that would reduce the likelihood of direct competition for subsistence 

resources on BLM-managed lands among visitors and residents of the planning area near villages 

would reduce risks to subsistence incomes. 

• People classified as living in poverty are disproportionately affected by increases in the amount of 

fuel required to access subsistence resources. 

• It is assumed that the closer to rural communities that commercial game hunting is allowed, the 

higher the likelihood of job creation and increased labor income in rural communities. 

• It is assumed that the closer to rural communities that commercial game hunting is allowed, the 

higher the likelihood for increased competition for subsistence game species and therefore 

increased risk to subsistence incomes in rural communities. 

Standard Operating Procedures and Best Management Practices 

The effects analysis below takes into account SOPs and BMPs that could be implemented by the BLM 

(see the BSWI RMP/EIS). Several examples are presented below. The SOPs or BMPs most important for 

reducing risk of adverse impacts to economic conditions include the following: 

• The permit of a Special Recreation Permittee convicted of trespass or subject to a civil judgment 

in trespass where the trespass occurred while under a BLM SRP may be suspended. 

• Pipelines and roads will be designed to allow the free movement of wildlife and the safe, 

unimpeded passage of the public while participating in traditional subsistence activities. Listed 

below are the currently accepted design practices: 

o Aboveground pipelines will be elevated a minimum of 7 feet as measured from the ground to 

the bottom of the pipeline at vertical support members. 

o In areas where facilities or terrain may funnel caribou movement, ramps over pipelines, 

buried pipelines, or pipelines buried under roads may be required by the AO after conferring 

with federal, State, and local government regulatory and resource agencies as appropriate, 

based on agency legal authority and jurisdictional responsibility. 

o Where feasible, road and pipelines should be co-located. 

Effects Analysis 

Management actions proposed for Air Quality, Wildland Fire, Paleontological Resources, and Visual 

Resources would not result in a measurable impact to economic conditions that differ by alternative; 

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Appendix N: Supplemental Impact Analysis Information Section 3: Supplemental Impact Analysis 

however, each would contribute to the sustained flow of benefits and services associated with market and 

non-market resources. 

Economic Conditions: Effects to Non-Market Values from Cultural Resources 

Effects Common to All Alternatives 

All alternatives would include management measures to support partnerships with Native corporations, 

State of Alaska, tribes, and private landowners for the documentation, stewardship and protection of 

cultural resources. The preservation of cultural resources may indirectly affect sustaining subsistence 

incomes by protecting historic and contemporary cultural uses of the landscape that help inform the 

foundation of traditional livelihood strategies and the cultural values associated with them. 

Economic Conditions: Effects to Non-Market Values from Soils 

Effects Common to All Alternatives 

All alternatives would adopt management activities to protect permafrost and mitigate surface-disturbing 

activities. Damage to permafrost is expected to increase costs associated with infrastructure maintenance 

and repair. Permafrost carbon feedback – that is, carbon released from permafrost that contributes to 

accelerated climate change – is expected to contribute to global economic costs, including infrastructure 

damage, changes in agricultural productivity, and adverse human health effects. 

Economic Conditions: Effects to Non-Market Values from Non-native Invasive Species 

Effects Common to All Alternatives 

Under all alternatives, permittees would be responsible for eradication costs of NNIS introduced by their 

permitted activity. Permittees must also use certified weed-free materials. These management actions 

would increase operating costs for permittees but would decrease risks to non-market values from 

nonnative invasive species management. There is no variation in NNIS management actions across 

alternatives. 

Economic Conditions: Effects to Market Activity from National Trails 

Effects Common to All Alternatives 

All alternatives establish the INHT NTMC in the planning area. The INHT NTMC provides recreational, 

cultural, and transportation opportunities in the planning area. The non-market values of the INHT 

NTMC—identified in the trail’s “nature and purpose” document as including cultural, historic, and 

ecological values—would be protected under all alternatives. Market activity due to INHT NTMC would 

continue and be the same under all the alternatives. 

Economic Conditions: Effects to Market and Non-Market Values from Grazing 

While recent history has shown that domestic grazing has not directly or indirectly affected market or 

non-market values in the planning area, new efforts to address limiting factors related to infrastructure 

needs that would support commercial grazing are being developed that address these barriers and may 

afford market opportunities for domestic reindeer grazing. 

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Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

Effects under Alternative A 

Alternative A would provide the greatest amount of opportunity for grazing and would provide the 

greatest likelihood of contributing to the creation of jobs and increased labor income from grazing for 

communities in the planning area. Conversely, Alternative A, while providing the greatest opportunity for 

grazing, would also pose the greatest amount of risk of resource degradation, such as impacts to water 

quality and therefore would have the highest risk to subsistence values reliant upon high water quality. 

Effects under Alternative B 

Alternative B closes all BLM-managed public lands within the planning area to grazing and would 

therefore not afford communities the opportunity to use these lands for domestic reindeer grazing. 

Alternative B would not contribute to the creation of jobs or increase labor income for communities in the 

planning area from grazing. Conversely, Alternative B would provide the greatest level of assurance of 

risk reduction to subsistence values from potential resource impacts related to grazing. 

Effects under Alternative C 

Alternative C would provide for grazing opportunities and could contribute to the creation of jobs and 

increased labor income but less so than Alternatives A and D. Alternative C, however, would limit where 

grazing is permitted to locations where ecological conditions could support grazing and ensure separation 

between domestic and wild animals, thereby avoiding adverse effects to resource conditions and risks to 

subsistence resources. This is the only alternative in which a substantial amount of acreage (HVWs) is 

closed until standards are developed for appropriate use. 

Effects under Alternative D 

Alternative D provides the greatest amount of land where grazing is permitted and thereby provides the 

greatest opportunity for the creation of jobs and increasing labor income due to grazing activities. 

Alternative D would allow for grazing in specially designated areas, such as the Unalakleet WSR corridor 

and the INHT NTMC, however, the proposed grazing must be consistent with maintaining the resource 

values for which they were designated. Alternative D would pose the highest risk of all the alternatives to 

resource conditions that may impact subsistence resources given that protecting resource conditions will 

be dependent upon careful consideration in permit administration, monitoring of grazing impacts to 

outstanding resource values and effective enforcement or adaptive management response should 

violations occur. Without a grazing management plan or range management plan, evaluating proposed 

permits and effectively administering grazing permits that would not put sensitive subsistence resources 

at risk within the Unalakleet WSR corridor would be challenging. In addition, Alternative D has the 

highest utilization rate of the action alternatives. At 75 to 100 percent of primary forage species utilized, 

Alternative D may have adverse impacts to soils causing erosion and sedimentation of water resources 

resulting to impacts to fisheries habitat, which could adversely affect the maintenance of subsistence 

resources. 

Economic Conditions: Effects to Non-Market Values from Water Resources and Fisheries Habitat 

Table 3.10.1-2 summarizes acres of HVW by alternative. Associated impacts to non-market values from 

water resources are described in the subsections below. 

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Appendix N: Supplemental Impact Analysis Information Section 3: Supplemental Impact Analysis 

Table 3.10.1-2: River Miles of HVW by Alternative 

Management Decision Alternative A Alternative B Alternative C Alternative D 

HVW – Medium Value 0 6,494 0 0 

HVW – Medium - High Value 0 1,906 1,906 0 

HVW – High Value 0 12,982 12,982 12,982 

Effects Common to All Alternatives 

All alternatives would follow total maximum daily load recommendations on 303(d) listed streams, 

incorporate best management practices and floodplain buffers, and manage fisheries for self-sustaining 

populations of priority species. All alternatives are expected to support non-market values associated with 

clean water and fish for subsistence and recreational use. 

Effects under Alternative A 

Alternative A would not define any criteria to identify or propose HVW. No HVWs are identified in 

Alternative A to protect water or fish resource values. Alternative A does, however, include roughly 

10 percent of the planning area designated as ACECs, which provides some protection for water and fish 

resources. Alternative A would pose the greatest risk to non-market values associated with water 

resources and fisheries from surface-disturbing activities. 

Effects under Alternative B 

Alternative B includes the broadest criteria for identifying three levels of HVW, which results in the 

largest number of acres of HVW at approximately 21,000 river miles. This alternative would enhance 

reclamation requirements for mining and buffers for surface-disturbing activities within the 100-year 

floodplain across the entire planning area. Alternative B would close salable mineral development and 

recommend withdrawal from locatable mineral entry within HVW. Alternative B would not permit 

commercial woodland harvest on public lands managed by the BLM within the Unalakleet Wild River 

Corridor, 100-year floodplains within HVW, lands managed for wilderness character as a priority, INHT 

NTMC, or ACECs. Alternative B provides the greatest reduction of risk to water quality and the fishery 

resource that are vital to non-market values in the planning area. 

Effects under Alternative C 

Alternative C includes criteria for identifying HVW, which results in the second largest number of acres 

of HVWs and approximately 15,000 river miles. This alternative would enhance reclamation 

requirements for mining and buffers for surface-disturbing activities within the 100-year floodplain within 

HVWs, which is less than Alternative B. HVWs would be open to salable and locatable mineral 

development under Alternative C. Alternative C would allow commercial woodland harvest on a case-bycase basis, which would provide for a site-specific analysis prior to allowing development, which would 

help minimize impacts in HVWs from commercial woodland harvest, but to a lesser extent than 

Alternative B. Overall, Alternative C provides less resource protection to protect water quality and the 

fishery resource than that of Alternative B, however, it provides more than Alternatives D in respect to 

reducing risk to non-market values in the planning area. 

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Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

Effects under Alternative D 

Alternative D includes criteria for identifying HVW, which results in approximately 13,000 river miles of 

HVWs, the least among the action alternatives but more than Alternative A. Related to mineral 

development, Alternative D does not require that a plan for water recycling be submitted, nor is 

concurrent reclamation required prior to developing a new area. Therefore, Alternative D would not 

reduce risk to water quality or fishery habitat to the same degree as Alternatives B and C. Surface 

disturbance would be allowed within the 100-year floodplain subject to case-by-case interpretation on 

requirement to “minimize sediment delivery.” Alternative D provides for the most flexibility for mining 

operations; it is the only action alternative that allows for suction dredging within HVW on a case-by-case 

basis. Alternative D does not include any restrictions on commercial woodland harvest within the 

100-year floodplain of HVW, or the Unalakleet Wild River Corridor. Alternative D allows for the greatest 

amount of disturbance and would pose the greatest risk to water quality and fish resources of all of the 

action alternatives and provides only slightly more protection to non-market values than does 

Alternative A. 

Economic Conditions: Effects to Non-Market Values from Wildlife 

Table 3.10.1-3 summarizes acres of wildlife habitat for important subsistence game species by alternative. 

Associated impacts to non-market values from wildlife are described in the subsections below. 

Table 3.10.1-3: Wildlife Habitat for Important Subsistence Game Species 

Wildlife Habitat Alternative A Alternative B Alternative C Alternative D 

Connectivity Corridors -- 845,670 576,038 --

Innoko Bottoms Priority 

Wildlife Habitat Area 

-- 236,556 236,556 236,556 

Effects under Alternative A 

Alternative A would continue current management related to wildlife habitat, of which there is little 

explicit management direction on habitat for important subsistence species such as caribou and moose. 

Alternative A would be less least likely to protect priority wildlife habitat areas, as such, disturbance to 

wildlife habitat is more likely under Alternative A compared to the action alternatives. Disturbance to 

wildlife habitat may affect non-market values associated with wildlife, including existence values and 

opportunities for subsistence, recreational hunting, and wildlife viewing. 

Effects under Alternative B 

Alternative B would provide the greatest level of resource protection for priority wildlife habitat areas 

through the designation of connectivity corridors and the Innoko Bottom Priority Wildlife Habitat Area. 

Conservation of habitat would be prioritized by pursuing withdrawal from locatable mineral entry, closing 

the area for salable mineral development, and having NSO requirements for surface-disturbing BLMpermitted activities. Alternative B also outlines explicit management direction for travel management and 

ROW exclusions within wildlife habitat areas. The management direction within Alternative B provides 

the greatest restrictions on activities that could disturb wildlife habitat as compared to the other action 

alternatives. This alternative would be the most likely of the alternatives to protect wildlife habitat for 

species important for subsistence, recreation, and wildlife viewing. 

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Effects under Alternative C 

The effects under Alternative C would be the same as those described under Alternative B for the Innoko 

Bottoms Priority Wildlife Habitat Area. However, Alternative C would only manage one connectivity 

corridor and would allow locatable mineral development and salable mineral development on a case-bycase basis. Additionally, it would not restrict construction in moose and caribou essential winter habitat 

areas, nor does it exclude any ROWs but rather identifies these as ROW avoidance areas. Alternative C 

reduces risks to priority wildlife habitat for subsistence game species through limiting activities in these 

areas more than Alternative A and D, but less so than Alternative B. 

Effects under Alternative D 

Alternative D would adopt fewer restrictions on surface-disturbing activities near wildlife habitat than 

Alternatives B and C. Alternative D does not provide management direction explicit for connectivity 

corridors, nor does it provide seasonal limitations on construction in moose and caribou calving and 

essential winter habitats. Management direction for the Innoko Bottoms Priority Wildlife Habitat Area, 

however, is consistent with the direction in Alternative C. This alternative would pose a higher risk to 

non-market values for opportunities for subsistence hunting than the other action alternatives given that 

disturbance in crucial reproductive periods is not restricted and that the connectivity corridors are not 

identified as ROW exclusion or avoidance areas. 

Economic Conditions: Effects to Non-Market Values from Lands with Wilderness Characteristics 

Effects under Alternative A 

Alternative A would not address lands with wilderness characteristics. This alternative would not actively 

conserve non-market values associated with wilderness characteristics. 

Effects under Alternative B 

Alternative B would manage 277,489 acres to protect wilderness characteristics as a priority and 

12.0 million acres would be managed to emphasize other resource values while applying management 

restrictions to reduce impacts to wilderness characteristics. This alternative would manage the largest 

share of the planning area for wilderness characteristics. Wilderness characteristics support non-market 

values related to maintaining the naturalness of an area and opportunities for solitude. Due to the 

remoteness and very low population density across the planning area, opportunities for solitude are 

abundant. 

Effects under Alternative C 

Alternative C would not manage any lands to protect wilderness characteristics as a priority. 

Approximately 8.1 million acres would be managed to emphasize other resource values while applying 

management restrictions to reduce impacts to wilderness characteristics. This alternative would manage 

the second-largest share of the planning area to reduce impacts to wilderness characteristics. Wilderness 

characteristics support non-market values the naturalness of an area and opportunities for solitude. 

However, due to the remoteness and very low population density across the planning area, opportunities 

for solitude are abundant. 

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Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

Effects under Alternative D 

Alternative D would not manage any lands for wilderness characteristics. The effects of this alternative 

would be consistent with Alternative A. 

Economic Conditions: Effects to Market Activity from Locatable, Salable, and Leasable Minerals 

Table 3.10.1-4 below summarizes acres of land open to mineral entry by alternative. Associated impacts 

to non-market values from locatable, salable, and leasable minerals are described in the subsections 

below. 

Table 3.10.1-4: Acres identified by Alternative as Open to Mineral Entry 

Management Decision Alternative A Alternative B Alternative C Alternative D 

Open to Locatable Mineral 

Development 

8,661,406 3,623,397 13,418,941 13,418,941 

Open to Salable Mineral 

Development 

8,661,406 3,623,397 6,645,750 13,182,385 

Open to Salable Mineral 

Development on a Case-byCase Basis 

0 0 6,536,635 0 

Open to Leasable Mineral 

Development with Standard 

Stipulations 

8,246,152 2,517,414 6,594,906 13,182,385 

Effects under Alternative A 

Alternative A would maintain existing management direction, including existing withdrawals and lands 

closed to salable mineral development. As a result of those withdrawals, Alternative A would have more 

areas open to locatable and salable mineral development than Alternative B but less than Alternative C or 

D. However; Alternative A would have more acres open to leasable mineral development with standard 

stipulations than Alternative C and D. Areas open to mineral development would provide future economic 

opportunities that would generally be more than Alternative B and less than Alternative C and D, 

particularly due to the low potential for leasable minerals in the planning area. 

Effects under Alternative B 

Under Alternative B, locatable mining activities would be withdrawn in the INHT NTMC and on Wild 

and Scenic River corridors through retaining existing withdrawals and proposing new withdrawals, which 

could increase the number of acres withdrawn should the proposed suitable river segments be designated 

as WSRs. This alternative would reduce economic opportunities associated with locatable and salable 

minerals relative to current conditions because fewer areas would be open for development. Relative to 

Alternative A, Alternative B reduces the profitability of mining activities in the planning area for private 

industries. 

Alternative B would designate the most ROW exclusion and avoidance areas among the range of 

alternatives. The increase in exclusion and avoidance areas may increase the cost of infrastructure 

development in the planning area. Alternative B creates the least favorable conditions for minerals 

development among the range of alternatives. 

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Effects under Alternative C 

Alternative C considerably increases the amount of land open to locatable and salable mining as 

compared to Alternative A when considering areas open case-by-case. Alternative C would designate 

ROW avoidance areas, but no exclusion areas. Alternative C is less likely to increase the operating costs 

of mining for private industry in the planning area. 

Alternative C provides more favorable conditions than Alternatives A and B for mineral development. 

Effects under Alternative D 

The effects of Alternative D are similar to the effects of Alternative C. Alternative D would revoke all 

ANCSA 17(d)(1) withdrawals on locatable minerals and provide the greatest level of support for locatable 

minerals development than all other alternatives. Alternative D would designate fewer ROW avoidance 

areas than Alternative C. Due to the relatively small acreage designated as ROW avoidance areas under 

Alternative D, this alternative is not expected to increase the cost of infrastructure development in the 

planning area. Alternative D would provide the most favorable management platform for locatable and 

saleable mineral development. 

Economic Conditions: Effects to Market Activity & Non-Market Values from Recreation and 

Visitor Services 

Table 3.10.1-5 below summarizes SRP management decisions by alternative. Associated impacts to 

market activity and non-market values from recreation and visitor services are described in the subsections below. 

Table 3.10.1-5: Special Recreation Permit Measures Affecting Non-Market Values 

Management Decision Alternative A Alternative B Alternative C Alternative D 

Community Focus Zone 

applied around communities, 

where SRPs for hunting 

guide-outfitters are not 

authorized. 

0 10-mile zone (818,395 

acres) 

5-mile zone (95,307 

acres) 

No Community Focus 

Zones; SRPs 

determined on caseby-case basis 

Effects Common to All Alternatives 

A 5-year study on the economic impacts from guided hunting found that guide expenditures on goods and 

services are mainly determined by where the guide lives and where the hunt occurs (McDowell 2014). 

None of the alternatives are expected to drive sizeable changes in where hunting guide-outfitter choose to 

live, therefore the economic contributions to rural communities from hunting guide-outfitters is largely 

limited to opportunities for local jobs and income to support hunting guide-outfitting services, subsistence 

meat donated to communities, and incidental expenditures by visitors in local communities. 

Effects under Alternative A 

Alternative A would continue to support recreational visitation consistent with current management. 

Alternative A is the least restrictive alternative providing little management direction on activities 

occurring near communities. A variety of motorized and non-motorized recreation opportunities would be 

available to residents and visitors. Commercial occupancy of cabins and shelters would be allowed, 

providing economic opportunities for commercial guides. Hunting guide-outfitters would continue to 

operate in the area and earn income associated with recreational use in the planning area. Exclusive 

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commercial use of the shelters may inhibit use for subsistence purposes and pose risks to subsistence 

users. The low level of management restrictions on hunting outfitter-guides is likely to provide relatively 

favorable conditions for commercial hunting activities and related economic contributions in rural 

communities, more so than Alternatives B and C. 

Effects under Alternative B 

Alternative B would implement a 14 day stay limit for dispersed camping and at BLM Public Use 

Shelters within the ERMA within a 28-day period and impose 3-day limits at BLM INHT Public Shelter 

Cabins. Guided hunts would not occur within 10 miles of communities within the CFZ, which could 

increase costs for outfitter guides. This cost would likely be passed along to the client and would be 

nominal in respect the total cost or expenditures visitors are willing to pay for big game hunting 

experiences. This would decrease the likelihood of competition for big game between subsistence and 

commercial hunts within 10 miles of villages, decreasing the likelihood of competition for subsistence 

game and therefore decreasing risks to households in villages reliant upon the subsistence economy. 

Alternative B may limit the economic contributions to rural communities within the CFZ from hunting 

guide-outfitter activities more so than the other alternatives given that commercial hunting would not be 

allowed within 10 miles of communities. 

Effects under Alternative C 

Alternative C, like Alternative B, would implement a 14 day stay limit for dispersed camping and at BLM 

Public Use Shelters within the ERMA within a 28-day period, and impose 3-day limits at BLM INHT 

Public Shelter Cabins. Guided hunts would not occur within 5 miles of communities within the CFZ, 

which could increase costs for outfitter-guides, but less than Alternative B. Such cost would likely be 

passed along to the client and would be nominal in respect the total cost or expenditures visitors are 

willing to pay for big game hunting experiences. Limitations on guided hunts close to villages could also 

decrease the likelihood of direct competition for subsistence game species and therefore decrease risk to 

subsistence incomes, less so than Alternative B but more so than Alternatives A and D. Alternative C may 

limit the economic contributions to rural communities from hunting guide-outfitter activities more so than 

Alternatives A and D, but less so than Alternative B given that CFZ would be half the size. 

Effects under Alternative D 

Alternative D allows for the greatest length of stay for dispersed camping, general BLM Public Shelter 

Cabins, and BLM INHT Public Shelter Cabin. Alternative D would not apply CFZs and therefore would 

not limit hunting guide-outfitter SRPs in proximity to communities in the planning area. This alternative 

may enable more residents in rural communities to earn an income as hunting guide-outfitters in the 

planning area than Alternatives B and C given that hunting guide-outfitters would be allowed to operate 

in closer proximity to communities. Alternative D is likely to result in similar economic effects as 

Alternative A. Alternative D is also likely to result in a greater amount of competition for subsistence 

game species within proximity to villages, which may put subsistence incomes at a higher risk than 

Alternatives B and C. 

Economic Conditions: Effects to Non-Market Values from Forestry and Woodland Products 

Table 3.10.1-6 summarizes acres of land open for subsistence and casual use by alternative. Associated 

impact to non-market values from forestry and woodland products are discussed in the subsections below. 

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Table 3.10.1-6: Acres of Land Open for Subsistence and Personal Use 

Management Decision Alternative A Alternative B Alternative C Alternative D 

Open for personal use and 

subsistence harvest on a case-bycase basis 

13,465,894 42,445 42,445 --

Open for personal woodland 

harvest by permit and open for 

subsistence woodland harvest 

without permit 

-- -- 8,291,190 13,465,894 

Open for subsistence and 

personal woodland harvest by 

permit 

-- 13,423,449 -- --

Non-subsistence house log 

harvest prohibited 

-- 9,427,588 3,044,745 --

Non-subsistence house log 

harvest on a case-by-case basis 

-- -- -- 13,465,894 

Acres of land where commercial 

harvesting of forestry and 

woodland products is permitted 

1,644,588 5,017,161 9,811,727 13,423,449 

Acres of land where commercial 

harvesting of forestry and 

woodland products is permitted on 

a case-by-case basis 

10,237,555 29,829 3,607,214 42,445 

Effects Common to All Alternatives 

All alternatives would allow commercial harvest of forest products with a permit, which would contribute 

to economic opportunities to sell wood products. However, given the lack of development of a 

commercial wood products industry in rural Alaska to date, it is unlikely that changes in the portion of the 

landscape where commercial harvesting is allowed would lead to a measurable change in labor and 

employment due to commercial forestry. All alternatives would also enable continued subsistence and 

personal use collection of firewood and non-timber forest products. Subsistence and personal use of 

woodland products supplements household income through the provision of fuel and food sources. The 

high cost of heating fuel in the region makes the availability of firewood particularly important to area 

residents (Association of Village Council Presidents 2014). 

Effects under Alternative A 

Alternative A would continue current management, whereby nearly all of the BLM acres are open to 

commercial woodland harvest by permit either outright or on a case-by-case basis. Economic 

opportunities associated with forestry would be available in the planning area. Subsistence and personal 

use collection of firewood and non-timber forest products would be available to contribute to household 

consumption and support cultural traditions. 

Effects under Alternative B 

Alternative B would not allow commercial harvest in the Unalakleet Wild River Corridor, ACECs, INHT 

NTMC, or 100-year floodplains within HVWs. It also has the fewest number of acres open to commercial 

woodland harvest when considering areas open on a case-by-case basis. This alternative could reduce 

opportunities for economic activity and increase the operating costs associated with forestry in the 

planning area. Alternative B would require a permit for subsistence and personal use collection of 

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firewood and non-timber forest products (e.g., berries). This alternative could increase the difficulty of 

engaging in subsistence and non-subsistence activities in the planning area; however, it would also 

contribute to jobs and income in rural communities. This alternative would also increase costs to the BLM 

for the subsistence and personal use permit program; however, there would be more accurate information 

available about the demand for special forest products collections and the popular collection locations to 

provide for a sustained supply. 

Effects under Alternative C 

Alternative C would not allow commercial harvest in the Unalakleet Wild River Corridor. Alternative C 

would require a permit for personal use collection of over 10 cords of firewood per household and nontimber forest products (e.g., berries), but would not require a permit for subsistence users. This alternative 

would be less likely than Alternative B to reduce opportunities for economic activity or to increase the 

operating costs associated with forestry in the planning area. This alternative would not affect the cost or 

difficulty of subsistence activities. The requirement that non-local users obtain a permit could reduce 

conflict and competition for resources among subsistence and non-local users, providing the most benefit 

to subsistence users as compared to the other alternatives. This alternative has a large proportion of acres 

open to commercial woodland harvest by permit (second only to Alternative D), but also relies on caseby-case issuance of permits in more sensitive areas. 

Effects under Alternative D 

Alternative D would allow commercial harvest by permit or on a case-by-case basis throughout the entire 

planning area. This alternative would be more likely than Alternatives A, B, and C to contribute to 

economic activity associated with forestry in the planning area due to less restrictions placed on where 

and what type of collection is allowed. Alternative D would have the similar effects as Alternative C in 

regard to the subsistence and personal use; however, a permit would not be required for personal use 

collection of firewood or non-timber forest products. 

Economic Conditions: Effects to Non-Market Values from Travel and Transportation Management 

Table 3.10.1-7 summarizes summer and winter subsistence travel decisions by alternative. Associated 

impacts to non-market values from travel and transportation management are discussed in the subsections 

below. 

Table 3.10.1-7: Summer and Winter Subsistence Travel Designations 

Management Decision Alternative A Alternative B Alternative C Alternative D 

Summer Subsistence OHV 

access Prohibited 

46,953 241,512 225,925 0 

Summer subsistence OHV 

limited to existing trails 

All lands open to 

motorized travel. 

324,443 363 225,925 

Limited winter subsistence use 

(snowmobiles only) 

All lands open to 

motorized travel. 

4,243,914 3,097,798 225,925 

Effects Common to All Alternatives 

All alternatives would continue to enable people to use lands in the planning area to transport goods and 

people. Travel and transportation management is important to facilitating economic well-being of area 

residents and visitors, enabling subsistence use and market activity 

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Effects under Alternative A 

Alternative A would not affect the ability of people and goods to move across the planning area relative to 

current conditions. Under Alternative A, there are no restrictions on travel across the planning area, unless 

restricted by a special designation, such as identified in the Unalakleet WSR management plan. Travel 

and transportation management under this alternative allow for the most flexibility in allowable 

transportation patterns and vehicle types, which would support market activity and well-being associated 

with transportation to support subsistence use. Sensitive areas may be impacted by unregulated motorized 

travel, which may increase risks to subsistence resources. 

Effects under Alternative B 

All action alternatives contain different areas identified as “limited” to motorized travel. Specific 

limitations are identified at the implementation-level travel planning and would be evaluated against the 

same criteria in making decision. 

Alternative B may slightly increase the cost, in terms of fuel and time, of travel within the planning area 

due to restrictions on OHV use. Some of the rural communities within the planning area have exceedingly 

high rates of poverty. Given the high cost of fuel in rural communities and the high incidence of poverty, 

even relatively small increases in the amount of fuel and time required for transportation may have a 

much larger proportional effect on economic activity related to casual use and recreation and 

transportation for subsistence purposes. While Alternative B would reduce direct risks to the reproduction 

of important subsistence species, it may also slightly increase risks to communities and households with 

extremely limited income by increasing fuel costs and thereby could limit subsistence user access to 

subsistence resources. 

Effects under Alternative C 

Alternative C would have similar effects to Alternative B. 

Effects under Alternative D 

Alternative D would have fewer restrictions on summer and winter subsistence travel than Alternatives B 

and C but is expected to have largely similar effects as Alternative B and C. 

Economic Conditions: Effects to Non-Market Values from ACECs 

Table 3.10.1-8 summarizes acres of ACECs by alternative. Associated impacts to non-market values from 

ACECs are discussed in the subsections below. 

Table 3.10.1-8: Acres of ACECs by Alternative 

Management Decision Alternative A Alternative B Alternative C Alternative D 

ACEC 1,884,376 3,912,698 0 0 

Effects under Alternative A 

Under Alternative A, 1,884,376 acres (approximately 14 percent of the planning area) are designated as 

ACECs to protect non-market values such as fisheries, which provide an important source of food and 

well-being in planning area communities. 

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Effects under Alternative B 

Under Alternative B, 3,912,698 acres (approximately 29 percent of the planning area) are proposed as 

ACECs for protection of fisheries and cultural resources. Alternative B provides the greatest level of 

protection or risk reduction for fisheries and their related subsistence non-market values. 

Effects under Alternative C 

Under Alternative C, no ACECs would be designated. Alternative C, however, includes more protections 

than the no action alternative against adverse effects from surface disturbance through the designation of 

ROW avoidance areas. 

Effects under Alternative D 

Alternative D would not propose any ACECs. This alternative would be least likely to restrict surfacedisturbing activities that contribute to economic activity, such as mining. This alternative is less likely to 

protect fisheries that contribute to subsistence non-market values. 

Economic Conditions: Effects to Non-Market Values from Wild and Scenic Rivers 

Table 3.10.1-9 summarizes acres of WSR corridors by alternative. Associated impacts to non-market 

values from WSRs are discussed in the subsections below. 

Table 3.10.1-9: Acres of New Wild and Scenic River Corridors by Alternative 

Management Decision Alternative A Alternative B Alternative C Alternative D 

Designated - Wild 46,953 46,953 46,953 46,953 

Eligible - Wild 332,176 0 0 0 

Recommended - Suitable Wild 0 332,176 0 0 

Effects under Alternative A 

Alternative A would not propose any new WSRs as eligible for designation. This alternative would not 

affect OHV access for subsistence activities relative to current conditions. However, 18 river segments 

(332,176 acres) have been identified as eligible wild river corridors. According to BLM Manual 6400, 

projects on BLM-managed lands within the river corridor or on lands that are adjacent to or border 

eligible rivers must consider guidelines to protect ORVs for activities such as locatable, salable, and 

leasable mineral development; transportation and motorized travel; ROW authorization; recreation; and 

livestock grazing, which could protect cultural and paleontological resources from associated impacts 

(BLM 2012). Impacts to eligible WSRs could result if OHV use continued to increase in the planning area 

and/or impacts were exacerbated from OHV use during permafrost thaw, which could contribute to 

impacts to water quality. Alternative A would be less likely than Alternative B to protect non-market 

values associated with WSRs related to fish and wildlife habitat. 

Effects under Alternative B 

Alternative B would propose 332,176 acres as suitable for WSR designation, which is the most acres 

proposed under any alternative. Alternative B is the most likely to affect transportation via OHVs in the 

planning area WSRs. However, given that the corridors are narrow and associated with rivers (which are 

impassable by OHVs, this limitation would not change transportation access dramatically. Travel 

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management actions under Alternative B could protect water quality by minimizing sedimentation and 

damage to riparian resources. This alternative is also the most likely to protect non-market values 

associated with WSRs by providing the most restrictions on development within these sensitive areas. 

Effects under Alternative C 

Alternative C would have similar economic effects to Alternative A, as this alternative would not propose 

new WSRs as suitable for designation. 

Effects under Alternative D 

Alternative D would have similar economic effects to Alternative A, as this alternative would not propose 

new WSRs as suitable for designation. 

Economic Conditions: Climate Change 

This section presents analysis of how management actions would counteract cumulative climate change 

impacts to economic conditions in the planning area. Climate change may impact market and non-market 

value of resources in the planning area due to any of the following effects, or complex interactions 

thereof: 

• Increased temperatures 

• Permafrost thaw 

• Decreased snow cover (albedo effect), subnivean species impacts 

• Increased wildland fire intensity, size, and frequency 

• Increase in NNIS introduction or spread 

• Later freeze-up dates (river ice) 

• Sea level rise (salt intrusion, transportation changes) 

Actions that increase protections of market and non-market values from climate change effects could 

counteract the impacts of climate change on planning area communities. As such, Alternative B would be 

the most likely to counteract the effects of climate change on market and non-market values, with lesser 

degrees of counteraction occurring under Alternatives C and D. Alternative A is likely to provide the 

lowest degree of counteraction of climate change impacts on market and non-market values under the 

alternatives. 

Economic Conditions: Cumulative Effects 

Past and Present Actions 

The planning area is characterized as a rural-mixed economy where households and communities are 

reliant upon both the market and non-market values cultivated in the subsistence economy. Planning area 

communities must rely upon both cash and subsistence sectors of the economy as neither can support 

communities alone (Fried 2018; Association of Village Council Presidents 2014). 

The market or cash economy in the planning area is weak, providing few opportunities for jobs and 

income generation. Local government accounts for the largest portion of jobs across the analysis area 

typically between 23 percent in Takotna and 73 percent in Pitkas Point. People employed in the natural 

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resources and mining sector account for an extremely small portion of jobs in the planning area, with the 

highest reported amount at 14 percent in Nikolai, followed by McGrath, Holy Cross, and Anvik at 6 

percent. Due to the remote location of the planning area to global markets, costs of transportation and 

infrastructure development are high, and timber and grazing are not competitive commodities. Outside of 

the Donlin Gold Mine, mineral development potential is also weak in the planning area due to the low 

grade of minerals in the planning area. Recreation and visitation provide limited opportunities for rural 

communities to benefit from jobs and income; however, many of the direct economic benefits related to 

guided big-game hunts, and fly-in fishing lodges and excursions, as well as competitive events benefit the 

urban communities outside the planning area, such as Anchorage. BLM-managed lands play a limited role 

in supporting jobs and income in the planning area given the geographic context of the planning area and 

the unfavorable economic conditions to support commodities markets. 

On the other hand, the non-market values provided by the BLM-managed lands, NWR lands, national 

park lands, State lands, and Native lands play a substantial role in the subsistence economy of planning 

area communities. The subsistence economy reduces the cash burden for households in the planning area 

where the cost of food is roughly twice as the cost in Anchorage, Alaska, and fuel costs for transportation 

and heating also well exceed the State and national averages. 

Reasonably Foreseeable Future Actions 

Changes in the price of diesel, gasoline, and heating oil are largely driven by changes in the cost of crude 

oil determined through global market conditions that are beyond the influence of the planning area 

communities. Given the volatility of market prices for crude oil over the past 18 years, as illustrated in 

Figure 3.10.1-1, it is reasonable to assume that prices for petroleum-based fuel will continue to fluctuate 

unpredictably and demonstrate an overall upward trend in price. 

Figure 3.10.1-1: U.S. Average Monthly Prices for Crude Oil and Heating Oil, 2000-2017 

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It is anticipated that the Donlin Gold Project will be in construction for 4 years, at the end of which, 

mining operation will commence and continue over the life of the plan. See BSWI Draft RMP/EIS 

Chapter 2 for more information. 

Climate change is expected to shift cliomes in the region at varying rates. Climate change effects on 

precipitation and snowfall are expected to be relatively minor, affecting the shoulder winter months of 

April and October. Communities that are located further west are expected to see a large change in snow 

days for all winter months. The frequency of fires in the planning area is not expected to change 

substantially in the planning area. Across the planning area, vegetation types vary; however, are generally 

expected to change, with declining representation of black and white spruce forest, while an increasing 

portion of the land base is expected to be deciduous forest. 

Jobs and income in the planning area are heavily influenced by federal and State funding for education, 

social, and medical assistance programs. Congressional budget allocations are beyond the influence of the 

planning area communities, and there is uncertainty of continued funding and what level these programs 

will be funded. 

Incremental Cumulative Impacts – All Alternatives 

Limited opportunities to increase jobs and income in the planning area in the face of volatile global 

market conditions related to the cost of crude oil that belays the importance of maintaining a strong 

subsistence economy to support household livelihoods and community vitality. In times of rising oil 

prices, households will rely increasingly on subsistence resources that can be gathered and produced with 

a low over-head cost for petroleum-based fuel products. Management under Alternative B is the most 

restrictive (and Alternative D is the least restrictive) to activities that would adversely affect subsistence 

resources. 

While Alternatives A provides the least amount of restriction regarding where travel is allowed and 

thereby affords the greatest opportunity for people to minimize travel distances, it also includes few 

measures to guard against potential risks to subsistence resources caused by the development of the 

Donlin Mine and related infrastructure. Alternative B would provide the greatest measure of protection 

for the maintenance and perpetuation of subsistence resources indirectly affected by the development of 

the Donlin gold mine and the associated natural gas pipeline. 

The development of ancillary facilities, temporary access roads, and airstrips developed in association 

with the pipeline may result in unintended development along this corridor, which coincides with the 

subsistence gathering regions. Designations that provide measures of protections for aquatic and 

terrestrial habitats, such as HVW, ACEC, WSR, and areas managed to preserve wilderness 

characteristics, will reduce risk to sensitive areas important for subsistence values. Alternatives A and D 

would do little to afford protection against unintended development associated with the development of 

the pipeline corridor. 

Overall, the market activity related to jobs and income is not expected to differ measurably among 

alternatives. With an estimated 2,500 workers required to construct the mine and 650 estimated to 

construct the pipeline, the population in the immediate vicinity of the mine and along the pipeline corridor 

would increase substantially over the construction period. With many of these workers being fly-in/flyout commuters, the social characteristic of the communities immediately surrounding the mine and 

pipeline corridor would also be impacted. 

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Being that subsistence economies are reliant upon on social systems that exercise systems of reciprocity, 

this change in the social make-up of the communities may affect community social dynamics and systems 

of reciprocity. Increased population and longer-term commuters, those who stay for a week or more, may 

also increase pressure on large-game and fish subsistence resources, which would increase risk to 

subsistence incomes. Alternative B provides the greatest level of protection to minimize risks related to 

direct competition for subsistence resources by restricting hunting outfitter-guide operations within 10 

miles of communities within CFZs. 

Changes in snowfall patterns and frequency, forest type, and overall shifting cliomes would likely drive 

changes in subsistence resource distribution related to plants, fish, wildlife, and timber. Such changes 

would increase economic insecurity to communities in the planning area reliant upon subsistence incomes 

due to increased time and fuel costs to locate resources or to cultivate new methods to secure subsistence 

livelihoods closer to their villages. When the effects of Alternative B are considered in context with the 

cumulative effects of climate change, measures to reduce direct and indirect stressors on ecological 

systems that support important subsistence species may lend to a higher level of ecological resilience in 

responding to changing climate. Alternative B may increase ecological resilience to climate change, 

which could result in decreased risk to households and communities reliant upon subsistence resources. 

3.10.2 Social Conditions 

Summary 

This section addresses the extent to which the alternatives affect social conditions in planning area 

communities, including impacts to environmental justice communities. Management actions under the 

alternatives are consistent with BLM’s priorities for enabling expanded access and use of public lands 

while maintaining a balance between conservation and utilization of the lands, energy and mineral 

resources, waters, fish and wildlife, and other natural and cultural resources. 

Methods of Analysis 

This section analyzes the impacts of the alternatives on social conditions in planning area communities 

qualitatively and summarizes the effects using a simple rating system. The ratings and qualitative 

descriptions are based on information from the Subsistence analysis (Section 3.11), other resource 

analyses, and public comments on the preliminary alternatives. Some actions pertinent to Support for 

BSWI Communities management (see Chapter 2 of the BSWI Draft RMP/EIS) are unique to social 

conditions and not described as actions under the subsistence, economy, or other resource sections. For 

these actions, new analyses were conducted. Impacts also are identified in the economic conditions 

analysis in the preceding section, which also describes the effects of the alternatives to non-market values 

related to subsistence use. The environmental justice analysis considers social and economic impacts to 

determine if there will be disproportionate impacts to low-income or minority communities. 

Potential Effects and Indicators 

The RMP could have several types of effects on social conditions in planning area communities. 

Management actions and designation of special resource protection areas may increase protection of 

community subsistence resources from other potentially degrading resource uses (e.g., minerals 

development). However, some management actions and designation of special resource protection areas 

also could affect access to community subsistence resources. Additionally, the alternatives would 

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implement varying degrees of management intended to reduce conflicts with other uses, collect additional 

information about community use areas and values, and/or increase coordination and collaboration 

between BLM and planning area communities. 

The following indicators were used to analyze impacts to social conditions in the planning area: 

• Level of protection for subsistence species and habitats (i.e., greater, less, or the same). This 

overall rating was developed using the impact analyses from the sections on ACECs, watershed 

protection, and locatable minerals. 

• Level of access to subsistence resources (i.e., greater, less, or the same). This overall rating was 

developed using the impact analyses from the section on travel management and forest and 

woodlands management. 

• Level of potential conflict with sport hunters and other users (i.e., greater, less, or the same). This 

overall rating was developed using the impact analyses from the sections on recreation, travel 

management, and special permit management. 

• Level of coordination and collaboration with communities (i.e., greater, less, or the same). This 

overall rating was developed using the descriptions in Chapter 2 of the BSWI Draft RMP/EIS on 

BLM support for planning area communities, including level of coordination with BSWI 

communities, level of monitoring of coordination efforts, and level of information to be collected 

about community subsistence uses and landscape meanings. 

• The global rating for economic effects, both market and non-market, based on the economic 

condition analysis. Effects on market opportunities, which provide potential for jobs, income, or 

reduced expenses, are a crucial component of life in bush villages. Effects on non-market 

resource values are also essential to subsistence and village lifestyles. 

• The rating for effects on environmental justice populations (i.e., greater, less, or the same) was 

developed using information from the other socioeconomics indicators and effects analyses. 

Table 3.10.2-1 summarizes the type of effects that could occur to social conditions by management 

action, the management actions that could result in those effects, and the indicators used to measure those 

effects. 

Table 3.10.2-1: Summary of Effects to Social Conditions by Management Action 

Type of Effects Management Action Indicators 

Resources and habitats support 

subsistence lifestyles and the rural mixed 

economy. They can be adversely affected 

by development, climate change, and other 

actions or conditions. 

Actions designed to address impacts 

and risks to subsistence resources, 

including wildlife protection areas, 

HVWs, ACECs, management for 

wilderness characteristics, or areas 

withdrawn from locatable mineral entry. 

Level of protection of subsistence 

resources and habitats; acres 

designated or otherwise receiving 

special protection 

Access to subsistence resources and 

species can be adversely affected by 

competition with other resource users, 

conditions, or BLM management actions 

that make access more costly or 

cumbersome. 

Management of SRP permittees, 

management of overland and trail 

motorized uses within the planning 

area, management of woodland 

harvest. 

Level of access to and competition for 

subsistence resources. 

Communities have expressed a desire to 

work more closely with the BLM and have 

more of a say in management of BLM lands 

of value to community residents. 

Actions in the Support for BSWI 

Communities alternative theme that are 

designed to address coordination and 

collaboration between the BLM and 

communities. 

Level of coordination and collaboration 

with communities. 

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Type of Effects Management Action Indicators 

Opportunities for jobs and income are 

scarce in bush communities so there is 

community desire for BLM management to 

facilitate or at least not impede economic 

development opportunities. 

Actions that have the potential to 

preclude economic development (such 

as mining withdrawals) or that are 

designed to facilitate economic 

development as described in the 

Support for BSWI Communities 

alternative theme. 

Level of effect on opportunities for jobs 

and income. 

All of the communities in the planning area 

are considered environmental justice 

communities due to their low-income or 

Alaska Native status, or both. Communities 

should not be disproportionately, adversely 

affected by BLM management actions. 

The net effects of all of the above 

actions on communities in the planning 

area. 

Level of effects on environmental justice 

populations. 

Assumptions 

The following assumptions were used to assess impacts associated with social conditions and 

environmental justice. 

• The analysis of impacts to economic conditions concluded that “BLM managed lands play a 

limited role in supporting jobs and income in the planning area...the market activity related to 

jobs and income is not expected to differ measurably between alternatives.” 

• The indicator “Level of protection for subsistence species and habitats” in the social conditions 

analysis is most closely linked to how the alternatives affect non-market values. 

• For the purpose of environmental justice, all of the identified communities are low-income and/or 

minority environmental justice populations qualifying for a consideration of environmental 

justice issues. 

• The differences among alternatives described in this and other resource sections are described 

relative to one another. However, in many cases, it is difficult to tell if these differences would be 

meaningful in regard to actual social conditions. For example, one alternative may more acres 

protected than another—but it is not known to what degree this additional protection is actually 

needed given current and potential future threats to the protected resources. The assumption is 

that greater resource protection would provide greater benefits to social conditions, but it is 

difficult to factor in any trade-offs that exist. Specifically, Alternatives C and D reflect an 

adaptive approach in which many decisions are made on a case-by-case basis; Alternative C 

provides more structure than Alternative D for making these decisions. Although the case-by-case 

approach provides greater uncertainty regarding the outcome of each individual decision, the 

flexibility allows managers to consult with affected communities, increasing the chances that a 

given decision will be able to balance desired resource protection with desired economic 

development opportunities as they arise. 

The impact analysis for social conditions is limited due to incomplete or unavailable information, 

including the following: 

• The scale of the analysis of impacts to subsistence and other resources is the planning area, with 

no analysis of impacts to the community groups; therefore, the results presented here are at the 

same broad scale. Some communities will be affected more, and some less, depending on their 

orientation to the resource, location relative to BLM-managed lands, population size, and other 

variables. 

• Changes to noise levels, noise-producing activities, and associated impacts throughout the 

planning area would depend on actual activities and projects implemented in the planning area. 

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Therefore, a detailed noise analysis is not included in this document and instead would be 

performed at the project level. 

Standard Operating Procedures and Best Management Practices 

The impact analysis below takes into account SOPs and BMPs that could be implemented by the BLM 

(the BSWI RMP/EIS). Because impacts to subsistence and related social values depends on the condition 

of nearly every other resource described in this document, nearly all of the directions and guidance in the 

list of SOPs and BMPs are relevant. 

Effects Analysis 

This section presents analysis of the net effects of actions on social conditions in planning area 

communities under the alternatives. This analysis is summarized using a rating system that describes the 

expected change from existing conditions resulting from implementation of an alternative. A rating of “–” 

indicates that the resource or social condition would be expected to become worse under that alternative; 

a rating of “=” indicates that the resource or condition would remain about the same (although some 

aspects or components of that condition could increase/improve and some decrease/become worse); and a 

rating of “+” indicates that the resource or social condition would be expected to improve under that 

alternative. In some cases, an extra “+” is added to indicate a larger difference relative to other 

alternatives. 

Table 3.10.2-2 summarizes the expected changes from existing conditions under all alternatives. 

Table 3.10.2-2: Expected Change from Existing Conditions under All Alternatives 

Indicator Alternative A Alternative B Alternative C Alternative D 

Level of protection for 

subsistence species 

and habitats 

- ++ + = 

Level of access to 

subsistence resources = = + + 

Level of potential 

conflict with sport 

hunters and other 

users 

- ++ + = 

Level of coordination 

and collaboration with 

communities 

- + ++ ++ 

Economic effects = + + + 

Effects on 

environmental justice 

populations 

- + + = 

The following sections provide the basis for the ratings in Table 3.10.2-2. 

Social Conditions: Effects of All Other Actions under Alternative A 

This alternative represents existing management mandated by current land use plans for the planning area. 

The following management actions would affect social conditions in the planning area. 

• Alternative A does not propose to designate any HVWs. The BLM has designated 11 ACECs 

covering 1,884,376 acres within the planning area. Alternative A would not provide any 

additional protection of lands with wilderness characteristics or work to create connectivity 

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corridors. The other alternatives all presume that some additional level of protection is necessary 

to address possible threats to resources over the next 20 years, so this alternative is not responsive 

to community demands for ensured, sustainable protection of subsistence resources. This 

alternative also has the second-most acres of proposed or retained locatable mineral withdrawals 

that overlap with medium or high potential areas for locatable minerals (about 271,000 acres). 

While this provides additional protection for resources and habitats, it also poses the greatest 

restrictions to possible future mining activities that could bring jobs and additional income to 

some community residents. That is why locatable mineral withdrawals can be controversial in 

communities. People want to see jobs, as evident by support for the Donlin Gold Mine, but also 

do not want to see subsistence resources and access damaged by the mine and associated 

development, including the natural gas pipeline corridor that will bring energy to the Donlin 

operation. Alternative A has the fewest open acres where commercial woodland harvest allowed 

by permit, instead relying primarily on issuance of permits on a case-by-case basis. 

• Alternative A manages all lands in the planning area as undesignated, with no limitations on 

winter cross-country travel for subsistence (or casual use) and restrictions on subsistence and 

casual winter cross-country travel within the Unalakleet Wild River Corridor only. Alternative A 

does not require a permit for subsistence collection of firewood and non-timber forest products 

(e.g., berries). Subsistence and casual use would continue under the management to which people 

are accustomed but would not address any issues where they exist now or would be likely to 

develop under this alternative. 

• There would be no new attempts to restrict guides in areas near communities or to require any 

additional training on sport-subsistence conflicts. Currently, many residents point out that sport 

hunting can conflict with subsistence use and that communities do not necessarily reap possible 

benefits of sport hunting occurring near communities. Thus, the alternative would not be 

responsive to this concern. 

• None of the new efforts proposed for coordinating and collaborating with communities would be 

instituted. Existing levels and types of coordination would continue. No more ACECs would be 

designated, including those proposed by communities and tribes, which could discourage future 

collaboration. The BLM would not seek out opportunities to provide assistance with cultural 

tourism activities to communities or to work collaboratively to develop Cultural Landscape 

Reports or similar analyses that describe how communities use BLM-managed and other lands. 

Community leaders and residents have expressed the desire for the BLM to be a good neighbor, 

part of which is how effectively the BLM coordinates and collaborates with communities and 

whether communities feel that their input and views are being considered and applied by the 

BLM. Alternative A would not meet these community needs. 

• Alternative A would lead to adverse effects on low-income and minority populations because no 

new actions would be taken to provide additional protection for subsistence resources, reduce 

conflicts with other uses, collect additional information about community use areas and values, or 

increase coordination and collaboration with communities. The other three alternatives address 

these issues in to varying degrees. No other populations of users or stakeholders would be 

similarly affected, so this level of impact is considered a disproportionate, adverse effect on 

environmental justice populations. 

Social Conditions: Effects Common to All Action Alternatives 

The three action alternatives contain a variety of measures to protect subsistence uses of BLM-managed 

lands and address community demands for protection of and increased participation in management of 

resources and opportunities. These and other actions will reduce the risk to subsistence resources. 

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The action alternatives generally pose fewer restrictions on OHV use and routes for subsistence use than 

for casual use, maintaining access while reducing potential conflict. The travel management goal for all 

alternatives is to “Maintain the BSWI planning area in such a manner that local communities retain 

unfettered access to the land.” When the BLM develops travel management plans, it will consider travel 

routes and corridors among the communities and how to meet connectivity and destination goals for the 

communities. These travel management actions will help to meet community needs for travel, including 

access to subsistence resources. 

The action alternatives also contain many measures designed to reduce conflicts with hunting guides and 

outfitters, and other users. In addition to allocation decisions, these include supporting community efforts 

to train local residents as guides, considering community concerns when making decisions about 

allocation, and encouraging permitted hunting guide-outfitters to coordinate activities with local 

communities. Such actions should decrease conflicts and improve community-guide relations. 

All of the alternatives allow for ROW permitting for essential community infrastructure including 

communication sites. Actions common to all action alternatives include making lands available for lease 

or sale to benefit local communities per the criteria for R&PP Act and considering land exchange and 

other mechanisms on a case-by-case basis to benefit public interests including community expansion or 

relocation. This will ensure communities that BLM-managed lands will not hinder development of needed 

infrastructure and allow the BLM to address impacts from climate change. 

As funding permits, the BLM would continue to hire employees stationed in planning area communities. 

This could include implementing a program similar to the USFWS Refuge Information Technician 

system, whereby community residents are hired as BLM employees (or through a similar mechanism) 

coordinate management activities and conduct outreach between the BLM and the rural communities. 

This would establish a closer link between the BLM and communities, paving the way for better 

relationships, trust, and collaboration on management activities. 

Social Conditions: Effects of All Other Actions under Alternative B 

This alternative emphasizes reducing the potential for competition between recreational and subsistence 

resources by designating key areas for additional protections of long-term resource values within the 

planning area. The following Alternative B management actions would affect social conditions in the 

planning area. 

• Alternative B designates more miles as HVWs and generally provides more conservation in 

HVWs than do the other two action alternatives. Seven new ACECs would be established, 

resulting in just under 4 million acres protected with this designation. Alternative B would also 

provide the greatest protection of lands with wilderness characteristics and would provide two 

connectivity corridors. As a result, this alternative is the one most likely to protect species and 

habitats valuable for subsistence, and to successfully address current and future threats. This 

alternative also has the most acres of proposed or retained locatable mineral withdrawals that 

overlap with medium or high potential areas for locatable minerals (about 363,000 acres). While 

this provides additional protection for resources and habitats, it also poses the greatest restrictions 

to possible future mining activities that could bring jobs and additional income to some 

community residents. This alternative also has a substantially greater number of acres closed to 

commercial woodland harvest, which does not pose an immediate barrier given the history of 

little harvest but could limit future opportunities. 

• Alternative B has only a small amount of acreage (about the same as Alternative C) where 

summer subsistence OHV access would be prohibited, and there would be no limitations on 

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winter cross-country travel for subsistence. This alternative generally is the most restrictive of 

casual OHV use, thereby reducing potential conflict with subsistence use. As a result, Alternative 

B would be expected to benefit travel to subsistence resources more than any other. However, 

Alternative B is the only alternative under which the BLM would require a permit for subsistence 

collection of firewood and non-timber forest products (e.g., berries), which would be a concern 

for many residents who are used to collecting without a permit. Many commenters talked about 

how difficult it was to accept having to obtain a permit from an agency to do something they have 

always done. The associated conflict could be reduced somewhat because the system would be 

administered by hiring a local in a targeted area to issue permits and collect use information, but 

enforcement could be difficult. Access to affected subsistence resources could be more difficult 

due to this permit and to the many protective resource measures, which could make access more 

costly or difficult in some situations. 

• Alternative B would add several measures designed to reduce conflicts with guided sport hunting, 

including the strictest limits on numbers and location near communities of any alternative. 

Therefore, Alternative B would be the most likely alternative to address conflicts to the 

satisfaction of community residents. 

• For nominated ACECs not found to be relevant and important for cultural resources, the BLM 

would work with tribes to gather more information on the particular areas and resources. The 

BLM would provide assistance with cultural tourism activities to communities requesting 

assistance. The BLM would support rural BSWI communities by working collaboratively with 

rural communities in the planning area and other partners to develop Cultural Landscape Reports 

for a small number of communities. These actions represent a concerted effort to increase 

coordination and collaboration with communities, a goal heard many times during community 

meetings. The BLM would have a greater presence in the communities, allowing for better 

relationships and trust to develop. This would improve the BLM’s ability to manage its resources 

and make it more likely that management would be consistent with community needs. 

• Alternative B would lead to positive effects on low-income and minority populations—essentially 

all of the residents of planning area communities. This is because many new actions would be 

taken to provide additional protection for subsistence resources, reduce conflicts with other uses, 

collect additional information about community use areas and values, and increase coordination 

and collaboration with communities. 

Social Conditions: Effects of All Other Actions under Alternative C 

This alternative emphasizes adaptive management at the planning level to protect the long-term 

sustainability of resources while providing for multiple resource uses. The following Alternative C 

management actions would impact social conditions in the planning area. 

• Alternative C designates more miles as HVWs than Alternative D but fewer than Alternative B 

and generally provides a level of protection of HVWs that is less stringent than Alternative B. 

Alternative C would protect lands with wilderness characteristics, though not as priority or to the 

extent of Alternative B and would establish one connectivity corridor. As a result, this alternative 

would provide additional protection for subsistence resources. This would not retain any locatable 

mineral withdrawals that overlap with medium or high potential areas for locatable minerals, 

thereby opening all areas where mineral development is most likely to occur on BLM-managed 

land in the planning area. It poses fewer restrictions to possible future mining activities that could 

bring jobs and additional income to some community residents than Alternative A and B. 

• Alternative C has only a small amount of acreage (similar but slightly less than Alternative B) 

where summer subsistence OHV access would be prohibited, and there would be no limitations 

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on winter cross-country travel for subsistence. This alternative is generally intermediate (between 

Alternatives B and D) regarding restrictions of casual OHV use. Alternative C would require a 

permit for personal use collection of firewood and non-timber forest products (e.g., berries), but 

would not require a permit for subsistence users. The requirement that non-local users obtain a 

permit could reduce conflict and competition for resources among subsistence and non-local users 

in some areas, providing the most benefit to subsistence users as compared to the other 

alternatives. As a result, Alternative C would improve community access to subsistence plant 

resources. This alternative has a large proportion of acres open to commercial woodland harvest 

by permit (second only to Alternative D) but also relies on case-by-case issuance of permits in 

more sensitive areas. 

• Alternative C would add several measures designed to reduce conflicts with guided sport hunting 

where they occur, including the second strictest limits on numbers and location near communities 

of the alternatives. Therefore, Alternative C would be likely to address conflicts to the satisfaction 

of community residents, although not perhaps as well as Alternative B. 

• No ACECs would be designated, including those proposed by communities and tribes, which 

could discourage future collaboration. However, this would provide more opportunity to work 

with the specific affected communities when the BLM is faced with making a decision, and to 

tailor resource protections to specific conditions on the ground. The BLM would provide 

assistance with cultural tourism activities to communities requesting assistance. The BLM would 

support rural BSWI communities by working collaboratively with them and other partners to 

develop Cultural Landscape Reports for a number of communities, which is desirable when 

decisions are being made on a case-by-case basis. Alternative C would therefore increase 

community opportunities to collaborate in BLM management processes. Community leaders and 

residents have called for increased ability to participate in decisions that affect their well-being. 

Alternative C would lead to positive effects on low-income and minority populations—essentially 

all of the residents of planning area communities. This is because some new actions would be 

taken to provide additional protection for subsistence resources (with the exception for the 

elimination of all ACECs and increased locatable and salable mineral development 

opportunities), reduce conflicts with other uses, collect additional information about community 

use areas and values, and increase coordination and collaboration with communities. 

Social Conditions: Effects of All Other Actions under Alternative D 

This alternative provides additional flexibility at the project-specific implementation level and fewer 

overarching management restrictions at the planning level. The following Alternative D management 

actions would affect social conditions in the planning area. 

• Alternative D generally provides the least stringent level of protection for HVWs compared with 

Alternatives B and C. No ACECs would be designated. Alternative D would not provide any 

additional protection of lands with wilderness characteristics or establish any connectivity 

corridors. Many decisions about resources and uses would be made on a case-by-case basis. 

Although this could be viewed as providing lower levels of protection, it provides an opportunity 

for the BLM to more closely tailor management to individual community needs and situations, 

rather than relying on broad restrictions and allocations that may or may not be needed in a given 

situation. It also provides more opportunity to work with the specific affected communities when 

the BLM is faced with making a decision. However, there is greater uncertainty regarding the 

outcomes of these case-by-case decisions compared to predetermined allocations or designations, 

which may be uncomfortable to some. This alternative has no acres of proposed or retained 

locatable mineral withdrawals that overlap with medium or high potential areas for locatable 

minerals. While not providing additional protection for resources and habitats, it provides more 

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opportunities for possible future mining activities that could bring jobs and additional income to 

some community residents. Nearly all of the acreage is open to commercial woodland harvest by 

permit. 

• Alternative D has no acreage where summer subsistence OHV access would be prohibited, and 

no limitations on winter cross-country travel for subsistence. This alternative generally is the least 

restrictive of casual OHV use among the action alternatives. Like Alternative C, Alternative D 

would require a permit for personal use collection of firewood and non-timber forest products 

(e.g., berries), but would not require a permit for subsistence users; the effects would be similar to 

those described under Alternative C and would be acceptable to subsistence users. 

• Measures to limit guided sport hunting to address conflict and/or resource impacts would be 

determined on a case-by-case basis, rather than by predetermining limits. This could end up being 

just as effective at reducing conflicts and would avoid establishing limits in places or instances 

where they might not be needed. However, the methods and effectiveness of measures eventually 

taken to reduce conflict would be more uncertain. 

• No ACECs would be designated, including those proposed by communities and tribes, which 

could discourage future collaboration. However, this would provide more opportunity to work 

with the specific affected communities when the BLM is faced with making a decision, and to 

tailor resource protections to specific conditions on the ground. The BLM would provide 

assistance with cultural tourism activities to communities requesting assistance. The BLM would 

support rural BSWI communities by working collaboratively with them and other partners to 

develop Cultural Landscape Reports for all communities, which is desirable when decisions are 

being made on a case-by-case basis. Alternative D would therefore greatly increase community 

opportunities to collaborate in BLM management processes. Community leaders and residents 

have called for increased ability to participate in decisions that affect their well-being. 

• Not designating the Sheefish and Whitefish ACECs could negatively impact the sheefish 

population, as these are the spawning areas for the sheefish population of the larger entire 

Kuskokwim River. Non-salmon fish species are important subsistence resources due to declines 

in the salmon returns, and lack of protection of this spawning area could impact communities that 

use this species for subsistence. Not designating the Sheefish and Whitefish ACECs could 

negatively affect abundance and availability of this important subsistence resource. 

• Alternative D would likely maintain or slightly improve existing effects on low-income and 

minority populations—essentially all of the residents of planning area communities. This 

alternative would provide some additional protection for subsistence resources, although not to 

the extent of the other action alternatives. Reducing conflicts between subsistence and other 

resource uses would still be a goal, but with many actions taken on a case-by-case basis rather 

than with predetermined allocations or regulations. Alternative D’s flexible approach would 

necessitate additional coordination and collaboration with communities, and the actions “common 

to all” include many community goals. For example, this is the only alternative that calls for a 

collaborative effort to develop Cultural Landscape Reports or similar analyses for all 

environmental justice communities. 

Social Conditions: Climate Change 

This section describes how management actions would counteract cumulative climate change impacts to 

populations in the planning area, including environmental justice populations. Climate change may 

impact availability and distribution of subsistence resources due to any of the following effects, or their 

interactions: 

• Increased temperatures 

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• Permafrost thaw 

• Decreased snow cover (albedo effect), subnivean species impacts 

• Increased wildland fire intensity, size, and frequency 

• Increase in NNIS introduction or spread 

• Later freeze-up dates (river ice) 

• Sea level rise (salt intrusion, transportation changes) 

Low-lying areas within the planning area are at risk from the effects of flooding due to hydrologic 

changes of thawing permafrost. This includes almost all of the villages within the planning area, which 

are located along the Yukon or Kuskokwim Rivers or the ocean coastline. 

Winter travel is expected to be adversely affected by continued wintertime warming, reducing the time 

period for functional travel that requires frozen rivers, frozen wetlands, or ice roads. 

Mining infrastructure containing hazardous materials is currently not designed to withstand the future 

environmental conditions that are expected to change dramatically from current conditions within the 

upcoming century. This could impede the facilities’ ability to function properly. 

In general, actions that increase protection of subsistence resources and allow for flexibility of access to 

these resources could help to counteract the impacts of climate change on planning area communities. As 

such, Alternative B would be the most likely to provide a buffer against climate change effects on 

planning area communities, Alternative A is likely to provide the lowest degree of buffer against climate 

change impacts on planning area communities among the alternatives, with Alternatives C and D 

somewhere in between. However, all of the action alternatives contain measures designed to benefit 

communities and make them more resilient. 

Social Conditions: Cumulative Effects 

Because the BLM’s mission is to manage resources and opportunities on lands it manages, it cannot 

directly address or attempt to resolve many social issues and trends facing bush communities in the BSWI 

area. These issues include fuel costs, opportunities for jobs and income, crime and mental health issues, 

education, or changes in population. However, BLM management can address some of these issues either 

incrementally or indirectly, including ways described in the economic conditions analysis above. 

Opportunities such as the Donlin Gold Project could have a greater effect on jobs than any of the actions 

contained in the alternatives. The BLM can provide the greatest assistance to communities by protecting 

subsistence resources and access to them, supporting job and income opportunities where possible, and by 

taking actions consistent with being a good neighbor. These actions serve as a buffer against the effects of 

planned and future actions taken by other entities. 

Table 3.10.2-3 identifies how management actions under the alternatives would affect both social and 

economic trends in the planning area. 

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Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

Table 3.10.2-3: Incremental Cumulative Impact to Economic and Social Conditions 

Trends and Forecasts of Trends and Forecasts of Trends and Forecasts of Trends and Forecasts of Trends and Forecasts of 

Economic and Social Economic and Social Economic and Social Economic and Social Economic and Social 

Conditions in consideration of Conditions in consideration of Conditions in consideration of Conditions in consideration of Conditions in consideration of 

past and present actions past and present actions 

(Alternative A) 

past and present actions 

(Alternative B) 

past and present actions 

(Alternative C) 

past and present actions 

(Alternative D) 

Cost of living in the planning Alternative A lacks management Alternative B provides the Alternative C provides a high Alternative D provides more 

area is higher and income is direction to conserve greatest level of protection for level of protection for protection for provisioning of 

lower than averages for other subsistence values near subsistence resources, which subsistence resources, which subsistence resources than does 

places in Alaska and much communities and provides a may mitigate risks associated may mitigate risks associated Alternative A, but less than 

higher than for the United States lower level of resource with changes in cash economy, with changes in cash economy, Alternative C. Alternative D 

as a whole. The mixed cash- conservation than the other such as increasing fuel prices or such as changing fuel prices and poses a higher risk to 

subsistence economy depends alternatives. Alternative A does decreasing federal and state changes in federal and state subsistence provisioning in 

on protection of subsistence not act to reduce conflicts budgets affecting employment budgets affecting employment proximity to villages given the 

resources and access while between subsistence and other and income in the planning area. and income in the planning area. lack of commercial guide 

facilitating and not foreclosing resource uses and does not This alternative may make Alternative C, is likely to provide limitations on quality, number 

opportunities for jobs and increase coordination with access to some subsistence a greater level of access to allowed, business practices, and 

economic development. communities to address current resources more difficult through subsistence resources through a continues to allow for 

Trend: The BLM has a 

relatively small amount of 

influence on social and 

economic conditions in 

planning area communities. 

or upcoming issues. It also does 

not provide the BLM with new 

avenues to work with 

communities on economic 

development. 

Trend: Where they exist,

current problems with 

subsistence resources and 

access on BLM-managed 

lands would continue. 

Opportunities for jobs and 

economic development would 

not be hampered but they

would not be facilitated by the 

BLM. 

required permitting and travel 

management restrictions, which 

could increase costs to 

households in the form of time 

and fuel but could decrease 

competition for these resources. 

Alternative B is slightly less likely 

than Alternative C to mitigate 

risk from global market volatility 

and changes in federal budgets 

as it has less flexibility in 

management measures, which 

may create undue economic 

burdens on households than 

Alternatives C or D. 

Trend: Where they exist,

current problems with 

reduced burden on permitting 

and fewer travel management 

restrictions, which would reduce 

costs to households in the form 

of time and fuel resources in 

comparison to Alternative B. 

Alternative C is likely to provide 

the highest level of mitigation 

from global market and 

unknowns in government 

budgets, by protecting 

subsistence resource values 

close to communities and 

providing flexibility in 

management measures that will 

not create undue economic 

burdens on households. 

commercial hunting near 

villages. However, there would 

be greater potential for economic 

and other benefits of sport 

hunting operations to 

communities. Alternative D 

mitigates risk from global market 

volatility and changes in federal 

budgets slightly more than 

Alternative A. Making decisions 

on a case-by-case basis allows 

for a greater ability to adapt to 

changing conditions and 

community needs, but with 

greater uncertainty over the 

outcome. 

Trend: Where they exist,

subsistence resources and 

access on BLM-managed 

lands would be likely to 

decrease. Opportunities for

jobs and economic

development could be 

hampered due to BLM

resource protection but some 

types of economic 

opportunities would be

facilitated. 

Trend: Where they exist,

current problems with 

subsistence resources and 

access would be likely to

decrease on BLM-managed 

lands. The BLM would try to 

facilitate opportunities for 

jobs and economic 

development. 

current problems with 

subsistence resources and 

access on BLM-managed 

lands would be likely to 

decrease. The BLM would try 

to facilitate opportunities for

jobs and economic

development. 

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3.11 Subsistence 

3.11.1 Summary 

This section presents the potential effects from proposed management actions on subsistence activities in 

the planning area. As described in Appendix M of the BSWI Draft RMP/EIS, the planning area contains 

rural communities whose residents live a subsistence-based lifestyle that mixes the customary, traditional 

harvest of natural resources with an economic system that includes share, barter, and cash exchanges. A 

wide variety of wild fish, wildlife, and vegetation are harvested by subsistence users for myriad purposes, 

including food, fuel, arts and crafts, tools, and clothing. Management actions with the greatest likelihood 

to have substantial effects to availability of and access to subsistence resources include locatable mineral 

decisions, ROW development, and OHV access. 

Of the three action alternatives described in Chapter 2 of the BSWI Draft RMP/EIS, Alternative B is the 

most restrictive and Alternative D is the least restrictive of the activities that would adversely affect 

subsistence resources. This would generally result in a management approach that would minimize 

competition and conflict between subsistence and other user groups more than the other alternatives. All 

alternatives would impact access, abundance, and availability of subsistence resources in some 

communities; although impacts under Alternative B would be of lesser magnitude and to a smaller 

geographic extent than the other alternatives. Alternative A, B, and C would also affect access to hunting, 

fishing, and harvesting subsistence use areas from OHV restrictions; there would be no affects to access 

from OHV restrictions for Alternative D. 

Therefore, Alternative B would result in impacts of lesser magnitude and geographic extent than the other 

action alternatives. However, Alternative B is more restrictive than Alternatives C and D of overland 

subsistence travel. 

Management actions that would benefit subsistence would further the purposes of Title VIII of ANILCA 

and align with the U.S. Department of the Interior’s strategy of providing stewardship of land, surface 

water, streams, and shorelines and its goal of supporting tribal self-determination, self-governance, and 

sovereignty. 

3.11.2 Methods of Analysis 

Impact analyses and conclusions are based on the existing conditions that are described in Appendix M of 

the BSWI Draft RMP/EIS. The analysis area for subsistence includes the planning area—wholly or in 

part, Game Management Units 18, 19A, 19B, 27 19C, 19D, 20C, 21A, 21D, 21E, and 22A (BSWI Draft 

RMP/EIS, Map 3.5.2-1)—and an evaluation of the management decisions that could affect subsistence 

resources and thereby subsistence harvest practices (e.g., vegetation, fish, large mammals, small 

furbearers). This analysis uses quantitative and qualitative information to describe impacts on subsistence 

from other resources. Best professional judgment is used in evaluating effects on subsistence resources. 

Additionally, analysis focused on the management actions that were seen as having the most potential for 

impacts to subsistence. GIS calculations were performed by overlaying available data for subsistence use 

areas with the following management decisions: 

• Areas open to locatable mineral development (in areas of high and medium potential) 

• OHV- travel management 

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Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

• ROW exclusion or avoidance areas (for the alternatives where this was a factor) 

Impacts thresholds were established for a quantitative and qualitative review to determine significant 

impacts (i.e., a positive finding for the ANILCA Section 810 Analysis [Appendix O]) for each 

community in each alternative. Determinations were then made according to the aggregated subsistence 

use category and by management decision. For the communities that lacked data or digitized data for a 

subsistence use category, available subsistence use data from neighboring communities that have similar 

subsistence use patterns was applied to the analysis. (Kling, 2018; Newell, 2018). 

In determining the impacts threshold for quantitative analysis, for management actions (listed above) 

found to cover 10 percent or greater of the total subsistence use area for the community (regardless of 

ownership of land); a rebuttable presumption of significance was made. Areas with less than a 10 percent 

overlap could specifically affect individuals that use those areas but were presumed to have no significant 

impact. This was confirmed after a qualitative review. Management actions that do not overlap 

subsistence use areas were assumed to have no significant adverse effect (i.e., no positive finding). For 

the qualitative analysis a potentially significant impact was determined if the analyzed management 

action intersects a known travel route; closure would occur during the season in which the resource is 

harvested; and/or closure would impact a resource that is heavily relied upon by a community. 

Nature and Types of Effects 

The types of effects to subsistence that could result from implementation of the RMP would be from 

actions that change rates of subsistence resource harvest, affect the access to subsistence resources, and 

whether there is resulting increased competition for subsistence resources. Actions could change the 

number of acres directly owned or managed by the BLM in the planning area. Lands that are disposed of 

would no longer be subject to BLM management, limiting the BLM’s ability to protect resources and 

accommodate future activities. The creation of new withdrawals could have implications on subsistence 

resource protections in areas that are withdrawn. The addition of new BMPs and other stipulations and 

requirements (such as travel management) are also management actions that affect subsistence. The types 

of effects to subsistence that could result from management actions and the indicators used to evaluate 

them are shown below in Table 3.11.2-1 

Layered protections for subsistence exist in Title VIII of ANILCA and federal and state regulations and 

are described further in Chapter 1 and Appendix E of the BSWI Draft RMP/EIS. 

The nature and types of potential effects on subsistence is closely tied to potential effects on fisheries, 

vegetation, and wildlife resources used for subsistence purposes. For additional information, please see 

the discussion of effects in those sections. 

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Table 3.11.2-1: Summary of Effects to Subsistence by Management Action 

Types of Effects Management Actions Indicators 

Impacts to subsistence resources would 

alter the traditional lifestyles of rural 

residents. 

• Minerals Decisions in HVWs 

• Locatable Mineral Withdrawals 

• Areas Closed to Salable Minerals 

• Seeding and Planting for 

Reclamation/Restoration 

• Protection of vegetation from 

degradation 

• Effects from Wildlife Management 

Decisions: 

• Caribou and Moose habitat areas 

• Innoko Bottoms Priority Wildlife 

Habitat Area 

• Connectivity Corridors 

• Migratory Birds 

• Travel Management Decisions 

• UAS Uses 

• Providing Assistance with Cultural 

Tourism 

• Zones between Hunting GuideOutfitter Operating Areas and 

Rural Communities 

• SSS Flora and Lichen Areas 

(Caribou Habitat) 

• Travel Management Decisions 

• BLM-permitted Surface Disturbance 

• Distribution and abundance of 

subsistence resources within the 

planning area 

• Current and past use of resources 

within the planning area 

• Availability and access 

• Subsistence closures 

OHV use could result in resource • Effects from Travel and • Distribution and abundance of 

degradation and limit (restrict use) Transportation Management subsistence resources within the 

subsistence access. Decisions 

• Innoko Bottoms Priority Wildlife 

Habitat Area 

• All BSWI Lands Not Managed as 

TMUs, Conservation System Units, 

or Sensitive Resource Areas 

• Unalakleet Wild River Corridor 

• Travel Management Decisions 

• INHT NTMC TMA 

• Rohn Site Travel Decisions 

• Lands Managed for Wilderness 

Characteristics 

planning area 

• Current and past use of resources 

within the planning area 

• Availability and access 

• Subsistence closures 

Lack of regulation of motorized use • Distribution and abundance of 

within lands with wilderness subsistence resources within the 

characteristics use could result in planning area 

resource degradation. • Current and past use of resources 

within the planning area 

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Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

Types of Effects Management Actions Indicators 

Subsistence use of forest products • Permitted Commercial Woodland • Distribution and abundance of 

would be allowed in certain places Harvesting Areas subsistence resources within the 

within the planning area. planning area 

• Current and past use of resources 

within the planning area 

• Availability and access 

• Subsistence closures 

Mineral entry could result in impacts to • Locatable Mineral Withdrawals • Distribution and abundance of 

distribution and abundance of 

subsistence resources, and access to • Areas Closed to Salable Minerals subsistence resources within the 

planning area 

subsistence resources and use areas. • Areas Closed to Leasing 

• NSO Leasable Designation 

• Transportation Management 

Decisions 

• Minerals Decisions 

• Mineral Decisions in the INHT NTMC 

• Current and past use of resources 

within the planning area 

• Availability and access 

Increased use of trapping cabins could • INHT SRMA • Distribution and abundance of 

result in increased competition to local 

subsistence users. • BSWI ERMA – OHV 

• Unalakleet Wild River Corridor – 

Travel Decisions 

• User Conflicts 

• Recreation Management Area 

Designations 

subsistence resources within the 

planning area 

• Current and past use of resources 

within the planning area 

• Availability and access 

• Subsistence closures 

Casual and subsistence OHV use could • Effects from Recreation and Visitor • Distribution and abundance of 

result in resource impacts within Services Management Actions subsistence resources within the 

Conservation System Units. • INHT SRMA planning area 

Summer cross-country OHV use could 

result in resource degradation and • BSWI ERMA – OHV • Current and past use of resources 

within the planning area 

impact ORVs. • Unalakleet Wild River Corridor – 

Travel Decisions 

• User Conflicts 

• Recreation Management Area 

Designations 

Restrictions could inhibit subsistence • ROW Exclusion and Avoidance • Distribution and abundance of 

access. Areas 

• Permits and Leases 

• Land Acquisitions 

• Disposals 

subsistence resources within the 

planning area 

• Current and past use of resources 

within the planning area 

• Availability and access 

• Subsistence closures 

Assumptions 

The following assumptions were used to assess impacts associated with subsistence. 

• The BLM will continue to have a major role in the management of public lands important to 

subsistence resources over the life of the RMP. The demand for subsistence resources could 

increase. Competition for resources could increase, especially those that receive high use from all 

resource users, because more lands would be private and recreational use of BLM-managed lands 

could increase. 

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• Subsistence harvest patterns and practices occur year-round following the seasonal cycles of the 

target resources. Subsistence practices will adapt and change based on the natural variations in 

population trends, migration patterns, and species shifts. Analysis is based on the current rates of 

harvest data, seasonal round and areas of use, and traditional use areas. As indicated (BSWI Draft 

RMP/EIS, Map 3.5.2-1), the primary subsistence harvest areas are along river corridors in the 

planning area. 

Incomplete or Unavailable Information 

There are limited data available for places or areas significant to, and for subsistence use in, the planning 

area. Studies of patterns of use such as seasonal cycles, use areas, and resources harvested have been 

conducted by ADF&G Division of Subsistence and other agencies and organizations. Available data are 

primarily in technical reports by the ADF&G Division of Subsistence but are limited in the data sets and 

may be reflective only of use areas when the data were collected or may represent historical use areas. 

The lack of data for a community does not indicate that subsistence harvests lack importance in an area. 

Not all species are included in the ADF&G surveys, and only a few communities in the state are surveyed 

each year. 

The discussion of harvest information in the following sections is supplemented by information that is 

available from recent ADF&G technical papers and from publicly available information. Because 

resource distribution and subsistence use areas change over time, information on subsistence use areas 

that was gathered during the scoping period, alternatives outreach, and ACEC nominations are important 

supplements. 

Standard Operating Procedures and Best Management Practices 

The impact analysis takes into account the SOPs and BMPs that could be implemented by the BLM, 

which are included in Appendix K. 

3.11.3 Effects Analysis 

Management actions proposed for the following resources would not result in effects to subsistence: 

• Air Quality and AQRVs 

• Soils 

• Cultural Resources 

• Paleontological Resources 

• Visual Resources 

• Hazardous Materials and Health and Human Safety 

Management actions for resources that result in effects to subsistence are discussed in the following 

sections. 

Subsistence: Effects from Water Resources and Fisheries Management Decisions 

In addition to the management actions common to all of the action alternatives, potential impacts from the 

following management topic were considered: 

• Minerals Decisions in HVWs 

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Effects under Alternative A 

Alternative A does not identify HVWs. Direct and indirect effects under this alternative would be highly 

variable and depend on the type of activities/authorizations permitted. Surface-disturbing activities have 

the potential to alter stream processes and degrade fish habitat, which could adversely affect water and 

fish resources. The duration of these impacts would be highly variable depending on the activity and the 

BMPs that are implemented. The BLM would continue to consider protection of floodplains and crucial 

salmon spawning habitat when implementing actions, reducing the potential for habitat loss or 

degradation due to surface-disturbing activities, human disturbance, and reduction in salmon. BMPs 

include the protection of streams and associated fish habitats, including avoidance of known spawning 

habitat and migration/spawning time periods. 

Under Alternative A, mineral leasing is closed in essential riverine habitat to protect anadromous 

spawning areas. The closed areas equal 12,857 miles of streams (39 percent of total streams on BLMmanaged land) and 20,430 acres of waterbodies (24 percent of total waterbodies on BLM-managed land). 

The geographic extent of management actions under Alternative A would be less than under the action 

alternatives because HVWs would not be defined or designated. Therefore, the amount of fisheries 

resources protected as HVWs would also be less than under Alternatives B or C. 

There are no minerals decisions in HVWs under Alternative A. 

Effects Common to All Action Alternatives 

Under all of the action alternatives, subsistence users would benefit from efforts to protect water 

resources and fisheries. Maintenance of healthy watersheds, riparian areas, and associated fish habitats 

would support continued harvests of subsistence resources including fish, waterfowl, and furbearers. 

Implementation of BMPs and mitigation measures would also protect aquatic resources important to 

subsistence users. 

Under all of the action alternatives, the BLM would complete a watershed-level cumulative impact 

analysis of all disturbances as part of permitting for most surface-disturbing activities. The analysis would 

allow the BLM to better manage habitats that are important subsistence use areas at the watershed scale 

because the BLM would coordinate and share information with USFWS and manage for connectivity of 

neighboring NWRs. 

Under all of the action alternatives, the BLM would manage fish habitat to maintain self-sustaining 

populations of species used for subsistence. The BLM would also cooperate with tribal organizations and 

rural communities for efficient and effective program implementation for subsistence species 

conservation. 

Effects under Alternative B 

Alternative B would protect more river miles in HVWs than Alternatives C and D, which would result in 

fewer adverse impacts on water quality and fisheries than the other alternatives. Any proposals to develop 

land, water, or resources in the 100-year floodplain associated with high resource values 12,982 river 

miles (39 percent of stream miles on BLM-managed lands), medium-high resource values (1,906 stream 

miles [6 percent of stream miles on BLM-managed lands]) and medium resource values of 6,494 stream 

miles (20 percent of stream miles on BLM-managed lands) would be required to demonstrate that the 

development would not diminish the quality or diversity of habitats needed for fish and wildlife 

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populations, including those used for subsistence. There is the potential for direct effects to unknown 

spawning habitat in regions due to the lack of information regarding spawning areas in some regions. Any 

management action within HVWs apply to these values including appropriate buffers (BSWI Draft 

RMP/EIS, Map 2-2), extensively limiting surface-disturbing activities from minerals, travel management, 

and realty management actions, which would result in fewer impacts on water quality and ultimately 

fisheries compared to other alternatives 

Compared to the other action alternatives, Alternative B would have the greatest amount of land receiving 

additional protection as HVWs and management actions providing the greatest amount of incidental 

benefit to fish species that are subsistence resources. Alternative B would also have more restrictions on 

mineral development in HVWs by maintaining the quality and diversity of areas of high fish and wildlife 

habitat value and river-based subsistence use from potential mineral development, which if not 

implemented could displace or impede access to subsistence uses, than Alternative C or D. Alternative B 

would result in long-term improvement to distribution and abundance of subsistence resources in HVWs 

in the planning area Alternative B would result in long-term improvement to distribution and abundance 

of subsistence resources in HVWs in the planning area and provides the most protection for streams/acres 

of waterbodies available for development associated with water resources actions among the other 

alternatives. 

Effects under Alternative C 

Alternative C proposes HVWs for watersheds with a high resource value of 12,982 river miles 

(39 percent) and medium-high resource value of 1,906 river miles (6 percent). Under Alternative C, any 

proposals to develop land, water, or resources in the 100-year floodplain associated in HVWs would be 

required to demonstrate that the development would not diminish quality and diversity of habitats needed 

for fish and wildlife populations, including those used for subsistence. 

Certain protections that would apply to the entire planning area under Alternative B would only apply to 

HVWs under Alternative C, including avoidance of permanent structures in the 100-year floodplain and 

restrictions on surface-disturbing activities or permanent structures in the 100-year floodplain of fishbearing streams. Therefore, the incidental benefits to subsistence fish resources would be less than under 

Alternative B. Compared to Alternative B, this Alternative has a greater potential to impact fish and 

aquatic resources due to fewer exclusions to surface-disturbing activities in or around streams or 

waterbodies. Within HVWs (with the exception of locatable and salable mineral development and 

permitted activities by other agencies [ADF&G]) and subsistence users for permitted camps, there would 

be long-term improvement to distribution and abundance of subsistence resources by maintaining the 

quality and diversity of areas of high fish and wildlife habitat value and river-based subsistence use from 

potential mineral development although to a lesser magnitude and geographic extent than Alternative B. 

Effects under Alternative D 

Alternative D proposes protection of a high resource value of 12,982 river miles (39 percent of stream 

miles on BLM-managed lands). As with the other action alternatives, any proposals to develop land, 

water, or resources within the 100-year floodplain of HVWs would be required to demonstrate that the 

development would not diminish quality and diversity of habitats needed for fish and wildlife 

populations, including those used for subsistence. Alternative D would have fewer restrictions on mineral 

development in HVWs than Alternatives B or C. 

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Alternative D would provide the least amount of protection for fish and aquatic resources and would rely 

on the operator to characterize the potential of streams for reclamation. Additionally, because watersheds 

with medium-high and medium resource values would not be protected as HVWs as proposed in 

Alternatives B and C, resources in these areas could degrade due to development activities. They would 

still be subject to the same SOPs and BMPs as Alternative B and C that could be implemented by the 

BLM as shown in Appendix K of the BSWI Draft RMP/EIS. 

Subsistence: Effects from Grazing Management Decisions 

In addition to the management actions common to all of the action alternatives, potential impacts from the 

following management topic were considered: 

• SSS Flora and Lichen Areas (Caribou Habitat) 

• Travel Management Decisions 

• BLM-permitted Surface Disturbance 

• Seeding and Planting for Reclamation/Restoration 

Effects under Alternative A 

Current management plans do not specify requirements for Grazing Management Plans. Alternative A 

would result in no change to the current extent, duration, or intensity of livestock grazing and the 

relationship to subsistence resources in the planning area compared to current practices. Crucial caribou 

habitat would continue to be protected. While authorized, the current level of grazing is extremely low. 

Of the areas open to grazing, approximately 19 percent is considered ecologically suitable, meaning it has 

at least 20 percent lichen cover by definition based on the classification classes from the REAs. Within 

the open areas, of the areas currently permitted for reindeer grazing, approximately 40 percent is 

considered ecologically suitable. 

Effects Common to All Action Alternatives 

There would be no effects common to all action alternatives. 

Effects under Alternative B 

All BLM-managed public lands within the planning area would be closed to grazing. Grazing would not 

be permitted under Alternative B, so there would be no impacts to subsistence resources from grazing 

management actions. 

Effects under Alternative C 

In Alternative C, 1,565,761 acres would be open and considered suitable for grazing, or approximately 

12 percent of the planning area. Permits would be authorized on a case-by-case basis. Under this 

alternative 617,422 acres are closed to grazing. Proposed grazing operations must submit a grazing permit 

application that includes a comprehensive Grazing Management Plan or a Range Conservation Plan. The 

areas closed to grazing (areas with important fisheries and watersheds values in the Nulato River 

watershed, Unalakleet Wild River Corridor, and INHT NTMC) would not sustain vegetation community 

changes due to grazing because no grazing permits would be considered or issued. HVWs would be 

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treated similarly in that they would be closed to grazing until grazing standards and guidelines for riparian 

vegetation health are developed; grazing in these areas would then be determined on a case-by-case basis. 

To prevent adverse interactions between caribou and grazing permit-based reindeer herds, grazing permits 

would be issued on a case-by-case basis in known caribou habitat. For this alternative, ecological 

condition would take into account ecological suitability for grazing and reduce the potential for adverse 

changes in vegetation composition, structure, or function. New applications submitted under the 1937 

Reindeer Industry Act and the Alaska Livestock Grazing Act of 1927 would be considered on a case-bycase basis if the applicant can: (1) provide a management plan which includes management objectives and 

how the applicant would ensure separation between domestic and wild animals and (2) conduct all land 

health monitoring activities as determined appropriate by the BLM AO. 

Effects under Alternative D 

There would be no requirement for a Grazing Management Plan or a Range Conservation Plan when 

applying for a grazing permit. New applications submitted under the 1937 Reindeer Industry Act and the 

Alaska Livestock Grazing Act of 1927 would be considered in the planning area on a case-by-case basis. 

Under Alternative D, the area open to grazing and considered ecologically feasible would be 

2,635,231 acres or approximately 20 percent of the planning area. Effects under Alternative D would be 

the same as those described under Alternative C with two differences. The first difference is that grazing 

would be permitted in areas of the Nulato River watershed that are closed under Alternative C, Unalakleet 

Wild River Corridor, and INHT NTMC only if it is determined that the proposed permitted grazing is 

consistent with maintenance of the values for which these areas were deemed important or designated and 

with the historical and cultural setting of the INHT NTMC. The second difference is that no caribou 

avoidance would be required under Alternative D. 

Subsistence: Effects from Vegetation Management Decisions 

In addition to the management actions common to all of the action alternatives, potential impacts from the 

following management topic were considered: 

• Protection from Degradation 

• Seeding and Planting for Reclamation/Restoration 

Effects under Alternative A 

Existing land use plans provide some protections for floodplains, wetlands, riparian areas, threatened and 

endangered plant habitat, and caribou habitat (lichen-rich areas) and provide guidance for sustainable 

yield of forest resources that would benefit vegetation communities. Alternative A does not have 

management direction specific to seeding and planting for reclamation and/or restoration activities. There 

would be no additional management specific to vegetation or special status plants in the planning area that 

would benefit subsistence resources. Under Alternative A, no acres of land would be protected by 

vegetation regulations, and there would be no formal program for controlling invasive weeds. 

Effects Common to All Action Alternatives 

Vegetation management decisions would benefit subsistence resources by ensuring that habitats support 

healthy, productive, and diverse populations of native plants and animals. Actions to minimize the 

footprint of BLM-permitted surface-disturbing activities, limit the magnitude or duration of impacts, and 

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preserve vegetation would benefit subsistence users and use areas in the development areas by potentially 

reducing associated habitat loss and fragmentation. 

Effects under Alternative B 

OHV use limitations, trail relocation, trail hardening, or trail closure implemented to reduce or eliminate 

degradation to SSS flora habitats (including dwarf shrub and lichen habitats [approximately 2,711,156 

acres or 20 percent of BLM-managed land in the planning area] or sparse vegetation types [approximately 

139 acres; less than 1 percent of BLM-managed land in the planning area]) would protect vegetation in 

these areas from further degradation. Under Alternative B, only native seeds and propagules would be 

used for reclamation and restoration and could include species that are used for subsistence, which would 

help maintain the distribution and abundance of subsistence resources in the planning area. 

Effects under Alternative C 

Protections for SSS flora habitats (including dwarf shrub and lichen habitats and sparse vegetation types) 

from OHV use would be the same as under Alternative B. Alternative C recommends the use of native 

species for revegetation of disturbed areas but would allow nonnative seed and propagules to be 

considered if applicable for the climatic condition and ecosystem function and if native plant species were 

not available or feasible. The use of nonnative plant species for restoration could lead to an adverse effect 

to subsistence users if reduction of the availability of plants traditionally used for subsistence purposes 

occurred and therefore affected harvest rates of traditionally used resources. 

For example, subsistence users could respond to a decrease in the availability of an edible plant by 

harvesting more of another edible resource. However, this would be limited to a small portion of the 

planning area and would not necessarily coincide with vegetation subsistence harvest areas. 

Effects under Alternative D 

No protections for SSS flora habitats and lichen areas would be implemented if these areas become 

degraded by OHV use, and these areas could therefore be subject to further degradation. Under 

Alternative D, revegetation of disturbed areas would focus on using plant species that are appropriate for 

the climatic condition and ecological function, including nonnative plant species. There could be an 

adverse effect to subsistence users if native plants important for subsistence uses were not considered in 

revegetating areas, limiting the availability of these plants for subsistence harvest and use compared to 

Alternatives B and C. However, subsistence users could respond to a decrease in the availability of an 

edible plant by harvesting more of another edible resource. This would be limited to a small portion of the 

planning area and would not necessarily coincide with vegetation subsistence harvest areas. 

Subsistence: Effects from Wildlife Management Decisions 

In addition to the management actions common to all of the action alternatives, potential impacts from the 

following management topics were considered: 

• Caribou and Moose habitat areas 

• Innoko Bottoms Priority Wildlife Habitat Area 

• Connectivity Corridors 

• Migratory Birds 

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Effects under Alternative A 

Under Alternative A, the BLM would continue to follow all laws, regulations, and policies, which pertain 

predominantly to wildlife that are used as subsistence resources. The BLM would consider impacts to 

wildlife used as subsistence resources when evaluating actions in the planning area that could affect 

subsistence resources and would implement mitigation as needed on a case-by-case basis. 

Under Alternative A, the BLM would also consider caribou and moose in its management of resource 

uses in the planning area although no specific management actions are identified. Existing conditions 

would continue under Alternative A. The BLM would consider impacts to wildlife used as subsistence 

resources when evaluating actions in the planning area that could affect subsistence resources and would 

implement mitigation as needed on a case-by-case. Alternative A could have a long-term impact on 

migration and species movement if future development occurs in areas where it would fragment species 

ranges and reduce habitat connectivity. However, the proposed connectivity corridors under Alternatives 

B and C occur in areas that do not have medium or high LMP, so future development may have a low 

impact on migration for species important to subsistence under this alternative even without the corridors. 

Effects Common to All Action Alternatives 

Under all of the action alternatives, management of wildlife resources and mitigation of impacts to 

wildlife would benefit subsistence users through maintenance of ecosystem functions and the quantity and 

quality of habitat to support healthy populations of wildlife. All of the action alternatives would include 

management considerations that focus on wildlife species that are important subsistence resources. 

Wildlife that is subsistence resources would be managed to sustain wild resource population levels to 

provide for continued rural economic opportunity and support subsistence lifestyles. 

Under all of the action alternatives, the BLM would coordinate with the ADF&G to use predator control 

as a tool for managing the long-term sustainability of predator and prey populations. Additionally, the 

BLM would use adaptive management that considers climate change and shifts in habitat or timing of 

essential portions of subsistence species’ life cycles. 

The BLM would implement numerous SOPs and BMPs designed to protect sensitive species and habitats, 

which would benefit subsistence resources and users. The SOPs and BMPs include buffer requirements, 

design features, seasonal restrictions, aircraft height restrictions, and location restrictions for activities 

with the potential to impact species and habitats of management concern from habitat loss, degradation, 

and fragmentation; noise and human disturbance; spread of diseases; and direct harm of individual 

species. Decisions that would benefit wildlife subsistence species include minimizing the potential for 

disease transmission; domestic sheep, goats, alpacas, llamas, and other similar species in Dall sheep 

habitat would be reviewed on a case-by-case basis. 

The alternatives would vary in terms of the timing, extent, and magnitude of restrictions on mineral 

activities, construction, vegetation clearing, and surface-disturbing activities in caribou and moose habitat 

and riparian areas and the extent of land receiving additional protections through designation as the 

Innoko Bottoms Priority Wildlife Habitat Area, and in the number of connectivity corridors that the BLM 

would manage to maintain wildlife movement between two NWRs. 

Effects under Alternative B 

Management actions under Alternative B would provide the most protections to wildlife and thereby 

subsistence resources. Management actions would target important species and habitats in the planning 

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area. The geographic extent of these actions is summarized in Table 3.11.3-1, although in many cases 

these areas overlap. Note that Table 3.11.3-1 does not take into account management for other resources 

or resources uses that may also provide protections to wildlife. Alternative B offers more restrictions than 

Alternative C or D on construction and mineral development, which could interfere with or displace 

subsistence activities in migratory bird habitat, the Innoko Bottoms Priority Wildlife Habitat Area, and in 

moose and caribou calving and wintering habitat. Fall hunting in the area for moose and waterfowl is 

largely by Yukon and Innoko River village residents using river boats. A winter subsistence moose hunt 

occurs in February and March using snowmobiles. Moose are an important subsistence resource for 

village residents of the area. Moose populations in the Innoko Bottoms area are recognized as having 

some of the highest population densities in the State of Alaska by both Alaska resident and non-resident 

sport and subsistence hunters. 

Table 3.11.3-1: Extent of Wildlife Management Actions Influencing Subsistence under

Alternative B 

Species/Habitat 

Geographic Extent on BLM-Managed

Lands in Planning Area Associated Management Actions 

Caribou and Moose calving and 

wintering habitats 

10,251,780 acres (76 percent) Mineral development, seasonal use 

restrictions 

Innoko Bottoms Priority Wildlife 

Habitat Area 

236,556 acres (2 percent) Mineral development, Surface-disturbing 

activities, ROW exclusion, airboats/ 

hovercraft 

Connectivity Corridors 2 corridors totaling 845,670 acres 

(6 percent) 

Mineral development, Surface-disturbing 

activities, ROW exclusion areas, 

airboats/hovercraft 

Riparian habitat 2,290,454 acres (17 percent) ROW avoidance, Mineral development 

Other Migratory Bird Habitat Not quantified Surface-disturbing activity – Seasonal 

restrictions 

The geographic extent of protective wildlife management actions under Alternative B would be greater 

than under Alternatives C and D. Wildlife and SSS in the Innoko Bottoms Priority Wildlife Habitat Area 

and two proposed connectivity corridors (North Connectivity Corridor and South Connectivity Corridor; 

see BSWI Draft RMP/EIS, Map 3.2.7-3) would receive protections from proposed locatable mineral 

withdrawal of these areas, would be designated as NSO for leasable development, closed to salable 

development, and designated as NSO for surface-disturbing BLM-permitted activities. The corridors 

would also be ROW exclusion areas, and there would be restrictions on casual use airboats and 

hovercraft. 

These management actions would reduce disturbance to wildlife and provide protection to these key 

habitats by reducing the potential for habitat loss, degradation, and fragmentation. Connectivity corridors 

are designed to sustain and maximize abundance and landscape-scale biodiversity by maintaining general 

habitat connectivity, minimizing habitat fragmentation and loss, and avoiding or mitigating barriers to 

wildlife movement within the corridors (Magness et al. 2018). The corridors are expected to benefit a 

wide range of species that are important to subsistence. The South Connectivity Corridor includes a 

portion of the Innoko Bottoms Priority Wildlife Habitat Area and would therefore provide management 

protections to the variety of species in this area, including waterfowl, moose, and wood bison. The North 

Connectivity Corridor includes a portion of the winter range of the Western Arctic Caribou Herd; this 

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corridor would provide protected habitat and allow for movement of caribou in this herd near the southern 

end of their range. Creating two connectivity corridors between the Innoko and Yukon Delta NWRs 

would allow for landscape connectivity at multiple locations, provide more options for movement, and 

benefit a greater number of wildlife than a single connectivity corridor. Therefore, the management 

actions would benefit a wide range of species important to subsistence activities. The total area managed 

as connectivity corridors under Alternative B would be 845,670 acres (6 percent of the planning area). 

These management actions would maintain the existing distribution and abundance of bird and terrestrial 

wildlife subsistence resources in the planning area. 

Effects under Alternative C 

Alternative C would restrict development on BLM-managed land in one connectivity corridor totaling 

576,038 acres (4 percent of the planning area). Management actions for the connectivity corridor under 

Alternative C would be less restrictive for locatable and salable mineral development (which would be 

allowed) than those under Alternative B. Alternative C would maintain the long-term benefits to wildlife 

movement in the Innoko Bottoms area that were discussed for the South Connectivity Corridor under 

Alternative B but would not provide the same management protections in the area identified as the North 

Connectivity Corridor, which intersects the range of the Western Arctic Caribou Herd. One connectivity 

corridor would still allow for landscape connectivity between the Innoko and Yukon Delta NWRs but 

would offer fewer options for movement across the landscape and would potentially benefit fewer 

wildlife subsistence resources than Alternative B. Because neither proposed connectivity corridor under 

Alternative B occurs in an area of medium or high LMP, the probability of future development in key 

movement areas may be low, and having only one corridor under Alternative C may not have a sizable 

difference on wildlife movement and habitat connectivity. Without information regarding the existing 

migration routes in the vicinity of the two corridors, it is difficult to assess the impacts of one location 

versus another. It is also difficult to evaluate the effectiveness of the proposed management actions 

without knowing how existing migration are currently affected by the types of activities that would be 

restricted. However, in general, having one corridor rather than two may increase the distance subsistence 

hunters would have to travel to reach the corridor. This in turn may reduce rates of subsistence harvest of 

wildlife species in this area as hunters would have to travel farther to be successful. 

Alternative C offers more restrictions than Alternative D and fewer restrictions than Alternative B on 

construction and mineral development activities, which could interfere with or displace subsistence 

activities in migratory bird habitat, the Innoko Bottoms Priority Wildlife Habitat Area, and in moose and 

caribou calving and wintering habitat. Restrictions on casual use airboats and hovercraft would be the 

same as those under Alternative B, so there would be no difference in the potential reductions in auditory 

disturbance to wildlife and subsistence resources from these types of vehicles/boats. Alternative C would 

be slightly less protective than Alternative B and have a greater risk for disturbance to subsistence 

resources during the breeding season during certain activities, unless they were addressed through specific 

SOPs and BMPs. Under Alternative C, protections for wildlife that are important subsistence resources 

from management actions would be of slightly lower magnitude and smaller geographic extent than those 

under Alternative B (Table 3.11.3-2). 

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Table 3.11.3-2: Extent of Wildlife Management Actions Influencing Subsistence under

Alternative C 

Species/Habitat 

Geographic Extent on BLMManaged Lands in Planning Area Associated Management Actions 

Caribou and Moose calving 

habitat 

540,896 acres (4 percent) Mineral development, seasonal use restrictions 

Innoko Bottoms Priority 

Wildlife Habitat Area 

236,556 acres (2 percent) ROW avoidance, airboats/hovercraft 

Connectivity Corridors 1 corridor, 576,038 acres (4 percent) Surface-disturbing activities, ROW avoidance, 

airboats/hovercraft, case-by-case salable mineral 

development 

Riparian habitat 2,290,454 acres (17 percent) ROW avoidance, mineral development 

Other Migratory Bird Habitat Not quantified Surface-disturbing activity – seasonal restrictions 

For caribou and moose, which are important subsistence resources, the management actions pertaining to 

leasable minerals and construction would apply only to calving habitat. Therefore, while caribou and 

moose would be protected during the breeding period, they could be disturbed in their crucial winter 

habitat areas, with disturbances potentially causing increased energy expenditures and stresses on 

wintering populations, which could result in decreased survivorship. This in turn can affect levels of 

subsistence hunting success and rates of harvest and sharing. This management would reduce potential 

impacts to wildlife over a much smaller geographic extent than under Alternative B, at only 4 percent of 

the planning area, which is 72 percent less. However, due to low potential for leasable development in the 

planning area, the potential for these impacts is low. In addition, although the Innoko Bottoms Priority 

Wildlife Management Area and South Connectivity Corridor would be open to locatable mineral 

development under Alternative C, there is no medium or high LMP in that area, so potential impacts 

would be low based on low likelihood for mineral development. 

Effects under Alternative D 

Alternative D offers fewer restrictions than either Alternative B or C (Table 3.11.3-3) on construction and 

mineral development, which could interfere with or displace subsistence activities in migratory bird 

habitat, the Innoko Bottoms Priority Wildlife Habitat Area, and moose and caribou calving and wintering 

habitat. Similar to Alternative A, the BLM would not manage connectivity corridors under Alternative D, 

but the proposed connectivity corridors under Alternatives B and C occur in areas that do not have 

medium or high LMP, so future development may have a low impact on migration under this alternative 

even without the connectivity corridors. Fewer protections would exist for caribou and moose, 

particularly during the winter use period, during which there would be no additional protections beyond 

those described for all action alternatives and the BMPs/SOPs listed in Appendix K. For the Innoko 

Bottoms Priority Wildlife Habitat Area, management actions pertaining to mineral decisions and ROWs 

would be the same as those under Alternative C, and the reduced potential for impacts to fish, wildlife, 

and SSS from disturbance and habitat loss and fragmentation from mineral development and ROWs 

would also be the same. However, unlike Alternatives B and C, there would be no restrictions on casual 

use airboats and hovercraft and therefore no reduction in the potential for impacts to waterbirds and other 

species from associated disturbance. Because restrictions and mitigations for migratory birds would be 

determined on a case-by-case basis, it is difficult to assess the difference in impacts to migratory birds 

relative to other alternatives. Alternative D would be less protective than Alternatives B and C. 

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Table 3.11.3-3: Extent of Wildlife Management Actions Influencing Subsistence under

Alternative D 

Species/Habitat 

Geographic Extent on BLM-Managed

Lands in Planning Area Associated Management Actions 

Innoko Bottoms Priority Wildlife 

Habitat Area 

236,556 acres (2 percent) Mineral development, seasonal use restrictions, 

ROW avoidance 

Riparian Habitat 2,290,454 acres (17 percent) Case by case 

Other Migratory Bird Habitat No information Surface-disturbing activity – case by case 

Subsistence: Effects from Nonnative Invasive Species Management Decisions 

There are no alternative-specific management actions for NNIS; therefore, impacts from Alternatives B, 

C, and D are discussed in combination. 

Effects under Alternative A 

Control of NNIS would continue to be required under applicable federal, State, county, and municipal 

regulations. Known invasive species control work has been performed at the Rohn cabin and the Nixon 

Fork Mine. There are no other known organized control or eradication efforts underway on known NNIS 

on BLM-managed land in the planning area. Under Alternative A, there would be no formal program for 

controlling invasive weeds throughout the planning area. Under Alternative A, NNIS would continue to 

alter the habitats of plants and animals harvested for subsistence. 

Effects Common to All Action Alternatives 

Invasive species can alter vegetative communities and fish and wildlife habitat, which can impact 

subsistence resource populations. Invasive species such as Elodea can take over waterways and impede 

subsistence-related travel via floatplane or boat. Under all of the action alternatives, NNIS management 

would reduce the potential for spread of NNIS throughout the planning area, which would help maintain 

the distribution and abundance of subsistence resources in the planning area. However, vegetation 

treatments to eliminate some species could adversely affect subsistence resources temporarily while 

plants become established. 

Subsistence: Effects from Lands with Wilderness Characteristics Management Decisions 

In addition to the management actions common to all of the action alternatives, potential impacts from the 

following management topics were considered: 

• Acres Managed to Protect Wilderness Characteristics as a Priority over Other Resource Values 

and Multiple Uses 

• Acres Managed to Emphasize Other Resource Values and Multiple Uses while Applying 

Management Restrictions to Reduce Impacts on Wilderness Characteristics 

Effects under Alternative A 

Wilderness characteristics are not addressed under Alternative A. Therefore, there would be no effects to 

subsistence resources or users associated with management pertaining to lands with wilderness 

characteristics. Existing conditions would continue. 

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Effects Common to All Action Alternatives 

There are no effects common to all of the action alternatives because areas that are managed for 

wilderness characteristics as a priority. The alternatives would vary in terms of area of lands managed for 

wilderness characteristics as a priority, area of lands managed to emphasize resource values and multiple 

uses, and the extent and magnitude of management restrictions in these areas that could reduce the 

potential for impacts to subsistence resources from various land uses. 

Effects under Alternative B 

Under Alternative B, 277,489 acres (2 percent) would be managed for wilderness characteristics as a 

priority. Management restrictions to reduce impacts on wilderness characteristics in these areas would 

also limit disturbance to fish, wildlife and SSS that are important to subsistence and degradation of 

habitats from land uses such as OHV use, facility construction, wood cutting and other forms of 

vegetation manipulation, and some types of mineral development. Additionally, actions to monitor and 

assess climate change impacts on current wildlife corridors and allocations for lands managed for 

wilderness characteristics based on predicted shifts in wildlife corridors would benefit subsistence 

resources by preserving corridors over the long term. Lands managed for wilderness characteristics as a 

priority under this alternative would overlap caribou wintering habitat (180,158 acres), and moose calving 

(18,757 acres) and wintering (26,100 acres) habitat. Therefore, it is expected that there would be a 

reduction in potential impacts to these wildlife habitats from various land uses as a result of wilderness 

management under this alternative. 

Additionally, the BLM would manage 12,040,490 acres (89 percent of the planning area) to emphasize 

other resource values and multiple uses while applying management restrictions to reduce impacts on 

wilderness characteristics. This management would also reduce the potential for impacts to wildlife 

subsistence resources and that are associated with lands with wilderness characteristics from various land 

uses, but to a lesser degree than lands managed for wilderness characteristics as a priority, because land 

uses with the potential to impact wildlife would be allowed in these areas. Lands managed to emphasize 

other resource values and multiple uses while applying management restrictions to reduce impacts on 

wilderness characteristics under this alternative would overlap a wider range of important wildlife habitat 

areas, although the magnitude of effects as far as reduced potential for impacts would be lower. This 

management category would affect caribou calving habitat (160,096 acres) and wintering habitat 

(8,956,098 acres), moose calving habitat (362,042 acres) and wintering habitat (868,707 acres), Audubon 

Important Bird Areas (314,297 acres), the Innoko Bottoms area (236,556 acres), muskox range 

(3,289,736), and wood bison range (3,362,942 acres). 

Effects under Alternative C 

Under Alternative C, no land would be identified as lands managed for wilderness characteristics as a 

priority, and 8,105,979 acres (60 percent of BLM-managed lands in the planning area) would be managed 

to emphasize other resource values and multiple uses while applying management restrictions to reduce 

impacts on wilderness characteristics. This management would also reduce the potential for wildlife and 

subsistence in these areas from various land uses, but to a lesser degree than under Alternative B. 

Important wildlife habitats to subsistence that overlap this land management designation would be the 

same as those under Alternative B, with either the same or lower geographic extent of overlap. This 

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management category would affect caribou calving habitat (160,096 acres) and wintering habitat 

(5,881,286 acres), moose calving habitat (304,906 acres) and wintering habitat (717,457), Audubon 

Important Bird Areas (217,545 acres), the Innoko Bottoms area (236,555 acres), muskox range 

(2,053,738) and wood bison range (2,418,190 acres). Management under this alternative would have the 

potential to reduce impact to wildlife and subsistence resources in these important habitat areas from 

various land uses. However, reduced impacts associated with use restrictions and wildlife corridor 

planning would not occur under this alternative. 

Effects under Alternative D 

Under Alternative D, no acres would be identified as lands managed for wilderness characteristics as a 

priority or managed to emphasize other resource values and multiple uses while applying management 

restrictions to reduce impacts on wilderness characteristics. Similar to Alternative A, there would be no 

effects to fish, wildlife and SSS that are subsistence resources associated with management pertaining to 

lands with wilderness characteristics. 

Subsistence: Effects from Wildfire Management Decisions 

There are no alternative-specific management actions for this resource; therefore, impacts from 

Alternatives B, C, and D are described in combination below. 

Effects under Alternative A 

Under Alternative A, prescribed and natural fires are recognized as a tool to maintain moose habitat 

which is an important subsistence resource. The use of wildland fire may become more frequent in moose 

habitat under Alternative A, resulting in fuels treatments being used as a tool to maintain natural 

vegetation composition that is in turn important to species that are important subsistence resources. 

Under Alternative A, the BLM would continue to follow all laws, regulations, and guidance pertaining to 

wildland fire management and would follow the applicable BLM wildland fire management direction for 

the planning area. While there are no specific management actions stipulated under this alternative, 

managing wildland fire in the planning area according to the goals and objectives identified in the 2005 

Land Use Plan Amendment Environmental Assessment for Wildland Fire and Fuels Management for 

Alaska (BLM 2005) would reduce the risk of human-caused fires in the planning area and associated 

short- and long-term impacts to fish, wildlife and SSS habitat through direct mortality and loss or 

alteration of habitat. ES&R plans would help rehabilitate fish, wildlife and SSS habitat following burns, 

which could reduce the intensity and duration of impacts from fire. Use of wildland fire to meet wildlife 

management objectives would also benefit fish, wildlife and SSS habitat. These actions would not change 

the amount of wildlife habitat in the planning area but could minimize short- and long-term reductions in 

late-successional habitat types in certain areas. However, fire suppression actions may result in a 

deviation from the natural fire regime which may affect fish, wildlife, and SSS habitat. This alternative 

does not specify the amount of BLM-managed land in the planning area is protected from fire or allowed 

to burn. The amount of wildlife habitat allowed to burn may increase or decrease, depending on where 

natural wildland fires occur and what fish, wildlife and SSS habitats are present in those areas. 

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Effects Common to All Action Alternatives 

Wildfire management could impact wildlife or wildlife habitat that could in turn impact subsistence 

resources and use areas if there was a reduction in subsistence resource population and the distribution of 

subsistence species changes patterns of traditional harvest use area(s). If wildland fire changes the routes 

into an area, it may become easier for non-local users to access subsistence use areas and increase the 

potential for competition of the resource. 

Wildland fire management under all action alternatives would be similar to that under Alternative A, 

although there would be BMPs/SOPs and additional management actions implemented that may benefit 

fish, wildlife and SSS. These actions include measures to prevent impacts to fish, wildlife and SSS from 

wildland fire suppression efforts, fuel breaks, and ES&R activities. Additionally, the BLM would monitor 

and measure the interactions between climate change, wildland fire, and resource objectives (including 

wildlife), and would adapt fire management strategies as necessary to protect resources. Strategies that 

pertain to lichen forage to changes in fire regime could allow the BLM to better manage caribou winter 

habitat in the long term. 

Subsistence: Effects from Forestry and Woodland Products Management Decisions 

In addition to the management actions common to all of the action alternatives, potential impacts from the 

following management topic were considered: 

• Permitted Commercial Woodland Harvesting Areas 

Forests and woodlands comprise approximately 35 percent of the planning area. Removing both living 

and dead forest products from these areas can reduce the components of wildlife physical habitat for 

subsistence resources and remove food sources such as berries, seeds, and lichens. The magnitude and 

extent of the impact to subsistence would depend on the amount of habitat that was removed and the 

availability of these habitat components in nearby areas. 

Effects under Alternative A 

Commercial harvest of forest and woodland products in the planning area is limited but could increase 

with increasing demand. Under Alternative A, 1,644,588 (12 percent of the planning area) acres would 

continue to be open to commercial harvest, with permits granted on a case-by-case basis for 

10,237,555 acres (76 percent of the planning area). A total of 1,583,751 acres (12 percent of the planning 

area) would be closed to commercial harvest. Alternative A does not provide management guidelines for 

woodland harvest in HVWs, the INHT NTMC, or ACECs. Under current management, impacts to 

subsistence would be limited in extent to areas where forest and woodland products removal occurs and 

where wildlife habitat that is important to subsistence use would be protected. Wildlife species and 

habitats most likely to be affected by permitted vegetation removal are those that occur in areas open to 

commercial harvest are described in Section 3.3. Subsistence harvest would continue to be common in 

areas around communities. Forests and woodlands over the entire planning area would continue to be 

open to personal use and subsistence woodland harvest, with permits for certain products issued on a 

case-by-case basis. 

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Effects Common to All Action Alternatives 

Under all of the action alternatives, management actions and BMPs/SOPs would include considerations 

for wildlife when planning forest products harvest, surveys for sensitive resources prior to surfacedisturbing activities, and labeling wildlife trees, among others. Actions to reduce impacts to other 

resources, such as lands managed for wilderness characteristics, would provide incidental benefits to fish, 

wildlife and SSS that are important subsistence resources that occur in these areas. These actions would 

provide a greater degree of protection to subsistence use areas than are currently afforded under 

Alternative A. 

Effects under Alternative B 

Under Alternative B, the total acres of fish, wildlife and SSS habitat that could be impacted by removal of 

forest and woodland products would be less than under Alternative A, because personal use and 

subsistence woodland harvest areas would be designated over 42,445 acres (3 percent of the planning 

area) in the vicinity of streams, communities, and burned areas, and permits would be required for harvest 

in these areas. Under Alternative B, 5,017,161 acres (37 percent of the planning area) would be permitted 

for commercial harvest. Timber sale operations and commercial woodland harvest would not be allowed 

within the 100-year floodplain of perennial rivers and streams. All types of commercial woodland harvest 

would be permitted by the BLM on all BLM-managed public lands unless they are within the Unalakleet 

Wild River Corridor, ACECs, lands managed for wilderness characteristics as a priority, 100-year 

floodplains in HVWs, or the INHT NTMC. House log harvesting would not be allowed within the 

riparian zone of perennial streams. While removal of forest and woodland products would be allowed 

outside of these areas on a case-by-case basis, it is expected that impacts to fish, wildlife and SSS would 

be concentrated in the personal use and subsistence woodland harvest areas. 

This alternative would include additional restrictions that would reduce impacts to fish, wildlife and SSS 

habitat in 100-year floodplains in HVWs, the INHT NTMC, ACECs, and riparian areas, with 8,418,904 

(63 percent of BLM-managed land in the planning area) closed to commercial woodland harvest, and 

permits required for commercial harvest on a case-by-case basis on 29,829 acres (less than 1 percent of 

BLM-managed land in the planning area; see Table 2-1b in Chapter 2 of the BSWI Draft RMP/EIS). This 

alternative would provide protections to fish, wildlife and SSS and habitat from the effects of vegetation 

removal by commercial harvest over a larger area than under Alternative A (about 6.8 million more acres 

of the planning area closed to commercial harvest). Wildlife species and habitats important to subsistence 

and those most likely to be affected by permitted vegetation removal are those that occur in areas that 

would be open to commercial harvest under this alternative are described in Section 3.3. 

Effects under Alternative C 

Management actions under Alternative C would have fewer restrictions on personal use and subsistence 

harvest that would reduce impacts to fish, wildlife and SSS, as the amount of harvest requiring a permit 

would increase. Subsistence use gathering of products would not require a permit in most of the planning 

area (13,423,449, nearly all BLM-managed land in the planning area), thus increasing ease of access for 

subsistence use. However, this alternative would otherwise be similar to Alternative B, with the 

same acres and locations of personal use and subsistence woodland harvest areas. Timber sale operations 

would not be allowed within the 100-year floodplain of perennial rivers and streams. All types of 

commercial woodland harvest would be permitted by the BLM on all BLM-managed public lands unless 

they are within the Unalakleet Wild River Corridor. House log harvesting would not be allowed within 

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Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

the riparian zone of perennial streams. These additional restrictions would reduce the potential for 

impacts to fish, wildlife, and SSS habitat in and the Unalakleet and riparian areas but would not provide 

the same level of protection as under Alternative B. Commercial woodland harvest is permitted in the 

INHT NTMC on a case-by-case basis. These actions would result in less than 1 percent of BLM-managed 

land in the planning area closed to commercial woodland harvest, 9,811,727acres (about 73 percent) open 

to commercial harvest, and permits for commercial harvest on a case-by-case basis on 3,607,214 acres 

(about 27 percent of the planning area). This alternative would provide substantially fewer protections to 

fish, wildlife and SSS and habitat from removal of vegetation by commercial harvest than under 

Alternative B (about 1.4 million acres less of the planning area closed to commercial harvest). It would 

open more acres to commercial woodland harvest than Alternative A, although Alternative A would have 

more areas available on a case-by-case basis. However; since permits issued on a case-by-case basis 

would include site-specific review, impacts to subsistence resources would likely be less under 

Alternative A than Alternative C. Wildlife species and habitats important to subsistence and most likely to 

be affected by permitted vegetation removal are those that occur in areas that would be open to 

commercial harvest under this alternative are described in this appendix. 

Effects under Alternative D 

Management actions under Alternative D would result in a similar level of potential impact to fish, 

wildlife and SSS habitat as Alternative C, as permits would not be required for subsistence use harvest or 

personal use gathering of firewood, and all of the planning area would potentially be available for 

personal use and subsistence woodland harvest. However; one notable difference is that Alternative C has 

more areas open on a case-by-case basis than Alternative B such that impacts would likely be less under 

Alternative C. 

There would be fewer restrictions on commercial woodland harvest that would reduce the potential for 

impacts to wildlife than under Alternatives B, as almost the entire planning area (13,423,449 acres [99 

percent] of the planning area) would potentially be open. Wildlife species and habitats most likely to be 

affected by permitted vegetation removal are those that occur in areas open to commercial harvest are 

described in Section 3.3. 

Subsistence: Effects from Locatable and Salable Minerals Management Decisions 

In addition to management actions common to all action alternatives, potential impacts from the 

following management topics were considered: 

• Locatable Mineral Withdrawals 

• Areas Closed to Salable Minerals 

Locatable and salable minerals management could affect fish, wildlife and SSS that are important to 

subsistence because development of mineral sites results in a loss of wildlife habitat, there is the potential 

for loss of subsistence access, and there is generally long-term surface disturbance, noise, and human 

activity at these sites for as long as they remain open and active. Associated access roads may result in 

loss and fragmentation of fish, wildlife and SSS habitat. Mining activities may cause localized 

degradation of important components of wildlife habitat, through contamination of air quality, water, and 

soil. Locatable mineral development is considered one of the management actions with the greatest 

likelihood to have high magnitude impacts to availability and abundance of subsistence resources due to 

the long-term impacts it would have on wildlife habitat and because there are areas of known medium and 

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high locatable mineral potential in the planning area where locatable mineral development is likely. Fish, 

including salmon and non-salmon (sheefish, whitefish, and trout) and large land mammals (including 

moose and caribou) are some of the most heavily harvested resources by rural communities within the 

planning area. If areas open to locatable mineral development in medium and high LMP areas are located 

upstream or alongside known fishing locations or within the calving areas or travel routes of the 

Mulchatna caribou herd, the abundance and availability of these species could be negatively impacted. 

Communities within the planning area rely heavily on fish (and salmon in particular), moose, and caribou 

to support their subsistence needs. With the heavy reliance on fish, moose, and caribou harvesting to 

supply the subsistence needs for the planning area communities, impacts from locatable mineral 

development could occur to the availability of subsistence resources as wildlife species would likely 

move out of the area during exploration, operation, and reclamation activities. Impacts could occur to the 

abundance of these resources as well from potential increased competition for fishing and 

hunting/trapping resources due to the influx of workers needed for mining activities. Subsistence users 

would likely make some adjustments to where they might traditionally harvest resources and then target 

resources that would be less affected by mineral development activities. It could be expected that adaptive 

approaches would likely sustain harvest levels for affected communities though the expenses and time 

needed to harvest subsistence resources could increase. 

Effects under Alternative A 

Under Alternative A, 4,804,488 acres (36 percent) of the planning area would continue to be withdrawn 

from locatable minerals and closed to salable minerals, including withdrawals to protect wildlife habitat 

and other resource values that are important to subsistence. There would be no impacts to wildlife or SSS 

and no associated impacts to subsistence access from mineral development in these areas and therefore no 

impacts to subsistence. However, 294,325 acres of medium to high LMP areas would continue to be open 

(52 percent of that available in the planning area under BLM management). High magnitude impacts to 

important wildlife habitat (see Section 3.3) within these areas of medium to high LMP would result if 

locatable mineral development were to occur, which is likely in these areas. The communities most likely 

to experience impacts to availability of subsistence resources from locatable mineral development under 

Alternative A include: Chuathbaluk, Lower Kalskag, and Upper Kalskag. 

Effects Common to All Action Alternatives 

Under each action alternative, locatable mineral exploration and development would be allowed in some 

portions of the planning area. The potential impacts to subsistence resources could occur if there is 

temporary displacement in localized areas; temporary and long-term loss of habitat; degradation of 

habitat; and direct mortality of small mammals or nestlings and brooding birds. Reduced or constrained 

access to use areas and to users and an increase in competition for the resources by non-residents may 

occur. Mechanisms to reduce these potential impacts would be through implementation of BMPs and 

SOPs (Appendix K of the BSWI Draft RMP/EIS) would minimize the potential impacts to subsistence 

users and specific mitigation measures to the impact causing actions. 

Salable minerals and material disposal could have direct and indirect impacts to subsistence resources and 

harvest areas. Mineral activity could also impact access and lead to an increase in competition for use of 

resources that are important to subsistence. Impacts to subsistence from salable minerals may be low 

impacts under the action alternatives as there are sufficient material sources that have already been 

identified that can meet the needs of the communities and there are few mineral material disposal actions 

anticipated. BMPs and SOPs would minimize the potential impacts to subsistence users. 

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Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

Under all action alternatives, WSR corridors would continue to be withdrawn from mineral entry. This 

management would provide protection from habitat loss and other impacts to fish, wildlife and SSS 

important to subsistence associated with mineral development. Additionally, BMPs and SOPs to protect 

wildlife and other natural resources would help reduce long-term impacts to fish, wildlife and SSS habitat 

in the planning area. Specifically, these actions would minimize mineral development and extraction in 

stream and river channels, deltas, wetlands, riparian zones, active floodplains, lakes, and habitat essential 

to local fish and wildlife populations, which would help prevent impacts to associated fish, wildlife and 

SSS that are subsistence resources. BMPs/SOPs would also include measures to minimize degradation of 

these habitats and expedite reclamation of disturbed areas. These measures would help reduce the level of 

impact to wildlife habitats in areas that remain open to locatable and salable mineral development. 

The alternatives would vary in terms of land withdrawn from locatable minerals and closed to salable 

minerals. 

Effects under Alternative B 

Under Alternative B, 3,623,397 acres of the planning area would be open to locatable and salable mineral 

development which is less than half of that open under Alternative A. Of this area, 202,610 acres would 

be within areas of medium or high LMP (or 36 percent of that available on BLM-managed land in the 

planning area), where development and associated impacts to availability of subsistence resources is 

likely. Areas that would be open to locatable and salable mineral development, in areas of medium to 

high LMP, include the important wildlife habitat areas described in Section 3.3 that are also important to 

subsistence. Alternative B would have the most acres of medium or high locatable mineral withdrawn to 

locatable mineral development than any other alternative and therefore would have the least potential for 

impacts to subsistence resources from mining. Since Alternative B would open a smaller area to locatable 

mineral development, particularly in areas with medium or high LMP, than all other alternatives, it would 

reduce the potential for impacts to wildlife and SSS habitat over a larger geographic extent than current 

management. 

New mines and associated infrastructure would only occur in areas open to locatable and salable mineral 

development. Because less of the planning area would be available for this resource use, there may be 

fewer new mines and infrastructure as compared to Alternative A, although demand for minerals would 

still likely be the biggest factor in determining the amount of new mineral development. BMPs/SOPs 

would also include measures to minimize degradation of these habitats and expedite reclamation of 

disturbed areas. These measures would help reduce the level of impact to wildlife habitats in areas that 

remain open to locatable and salable mineral development. The communities most likely to experience 

impacts to availability of subsistence resources from locatable mineral development under Alternative B 

include: Aniak, Crooked Creek, Chuathbaluk, Lower Kalskag, McGrath, Sleetmute, and Upper Kalskag. 

Effects under Alternative C 

Under Alternative C, 13,418,941 acres (over 99 percent) of BLM-managed land in the planning area 

would be open to locatable minerals and 6,645,750 acres acres (about 49 percent) would be open to 

salable mineral development with another 6,536,635 acres (about 49 percent) open on a case-by-case 

basis. However, all areas of medium or high LMP on BLM-managed land would be open to locatable 

mineral development. Alternative C would open more areas to locatable and salable mineral development 

than Alternative B, including in areas of medium or high LMP where likelihood for development and 

associated impacts is highest. While Alternative C would open fewer areas to salable mineral 

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development than Alternative A, when considering areas open on a case-by-case basis, it would have the 

potential to open more areas than Alternative A. Since potential for salable mineral development is low in 

the planning area, and Alternative C would open more areas of medium or high LMP to locatable mineral 

development than Alternative A, there would be high magnitude impacts to subsistence resources over a 

greater geographic extent than Alternative A. 

Similar to Alternatives A and B, the potential for a number of new mines and associated infrastructure 

would likely increase, dependent on future demand for minerals, but would not occur in portions of the 

planning area closed to development. BMPs/SOPs listed in Appendix K of the BSWI Draft RMP/EIS 

would also include measures to minimize degradation of these habitats and expedite reclamation of 

disturbed areas. These measures would help reduce the level of impact to wildlife habitats in areas that 

remain open to locatable and salable mineral development. The communities most likely to experience 

impacts to availability of subsistence resources from locatable mineral development under Alternative C 

include: Aniak, Crooked Creek, Chuathbaluk, Lower Kalskag, McGrath, Sleetmute, and Upper Kalskag. 

Effects under Alternative D 

Alternative D would open the same acreage to locatable mineral development as Alternative C. 

Alternative D would close the same acreage to salable mineral development as Alternative C, and would 

open the remaining BLM-managed lands in the planning area to salable development rather than opening 

some areas on a case-by-case basis, as with Alternative C. Impacts to subsistence resources from 

locatable mineral development would be the same as Alternative C and nearly the same for impacts 

associated with salable mineral development due to low salable mineral potential and demand in the 

planning area. Areas that would be open to locatable and salable mineral development, in areas of 

medium to high mineral potential, include important wildlife habitat areas as described in Section 3.3. 

Similar to Alternatives A and B, the potential for a number of new mines and associated infrastructure 

would likely increase, dependent on future demand for minerals, but would not occur in portions of the 

planning area closed to development. New mines and associated infrastructure would have the potential to 

occur over more of the planning area than under the other alternatives based on areas open to 

development. BMPs/SOPs would also include measures to minimize degradation of these habitats and 

expedite reclamation of disturbed areas. These measures would help reduce the level of impact to wildlife 

habitats in areas that remain open to locatable and salable mineral development. The communities most 

likely to experience impacts to availability of subsistence resources from locatable mineral development 

under Alternative D include: Aniak, Crooked Creek, Chuathbaluk, Lower Kalskag, McGrath, Sleetmute, 

and Upper Kalskag. 

Subsistence: Effects from Leasable Minerals Management Decisions 

In addition to the management actions common to all of the action alternatives, potential impacts from the 

following management topics were considered: 

• Areas Closed to Leasing 

• NSO Leasable Designation 

Activities associated with leasable minerals have the potential to affect fish, wildlife, and SSS habitat that 

is important to subsistence resources and users through habitat loss and degradation and disturbance of 

resources. Seismic surveys may have long-term effects on habitat by removing vegetation and potentially 

creating new summer and winter OHV routes which can disturb wildlife and fragment habitat. 

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Exploration can harm small mammals and nesting birds and can harm small mammals and temporarily 

displace larger mammals such as caribou that are an important subsistence resource. Because there is a 

low development potential for leasable mineral resources in the planning area, impacts to subsistence 

resources and users is likely to be low, although demand could change. 

Effects under Alternative A 

Alternative A would continue to include closures and protective stipulations that would provide 

protections to fish, wildlife and SSS in the planning area. A total of 5,053,308 acres (38 percent) of the 

planning area would be closed to leasing, and 17,521 acres (less than 1 percent) of the planning area 

would be designated as NSO leasable. Additionally, there would be special stipulations for grizzly/brown 

bear denning areas and raptor nesting areas over a small portion of the INHT (unquantified), which would 

help reduce impacts to these species from leasable mineral actions. Overall, the area of wildlife habitat 

covered by management, reducing impacts to wildlife from impacts associated with leasable minerals, 

would be less than under the action alternatives, although the area of land completely closed to leasing 

would be greater than Alternative C and D. 

Effects Common to All Action Alternatives 

All action alternatives would include stipulations that provide protections to fish, wildlife and SSS that 

are important subsistence resources. While numerous stipulations would reduce impacts to wildlife and 

SSS, thereby protecting subsistence resources, there would also be stipulations specific to SSS, Dall sheep 

habitat, caribou calving/postcalving habitat, raptor nests, trumpeter swans, high value moose habitat, and 

active bald eagle nests. These stipulations would help minimize loss of caribou and moose calving and 

wintering areas, moose and caribou winter habitat, Dall sheep habitat, raptor nesting habitat, and 

migratory bird habitat in the event of mineral leasing in these areas and would therefore be beneficial to 

subsistence resources and users. Additional SOPs/BMPs designed to protect wetlands and streams/water 

quality and reduce the establishment and spread of NNIS would provide additional protections to 

subsistence resources from actions. 

The alternatives would vary in terms of areas of land further protected by being closed to leasing, 

designated as NSO leasable, or open, subject to special stipulations leasing. 

Effects under Alternative B 

Alternative B would increase the proportion of the planning area designated as NSO leasable to 

1,597,599 acres (12 percent of BLM-managed land in the planning area) and the land area closed to 

leasing to 9,350,881 acres (69 percent of BLM-managed land in the planning area). Therefore; fewer 

acres of fish, wildlife and SSS habitats (important as subsistence resources) over more of the planning 

area would be open to mineral leasing and more areas subject NSO lease stipulations necessary to protect 

resources important to subsistence. 

Under Alternative B for the entire planning area (exception would be locatable mineral development and 

permitted activities by other agencies [e.g., ADF&G]), for fish-bearing streams the disturbance buffer 

would be the 100-year floodplain, no surface-disturbing activities or permanent structures would be 

allowed within these buffers. Buffers and therefore the total miles of streams would vary depending on 

stream order. Therefore, metrics for this alternative would be calculated on a case-by-case basis. If 

adverse effects resulted from these actions in displacement and disturbance to the resource then 

subsistence activities in these areas and harvest could be affected. The potential for and level of impact on 

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fish and aquatic resources is influenced by numerous factors, including management decisions allowing 

for surface-disturbing activities, combined with the success and adequacy of protective measures, such as 

maintaining riparian vegetation in proper functioning condition and the application of mineral 

withdrawals, BMPs, and reclamation procedures. Direct/indirect affects under this alternative would be 

highly variable and depend on the type of activities/authorizations permitted. All activities have the 

potential to alter stream processes and degrade fish habitat. The duration of these impacts would also be 

highly variable and dependent upon the activity and the BMPs that are implemented. Any BMP that 

protects the streams and associated habitats would be valuable and would include avoidance of known 

spawning habitat and migration/spawning time periods. 

Alternative B would include the most restrictions associated with leasable mineral development compared 

with the other alternatives. Although potential for impacts would be low due to low potential in the 

planning area. BMPs/SOPs would include measures to minimize habitat degradation, expedite 

reclamation of disturbed areas, and minimizing conflicts with subsistence activities and access. These 

measures would help reduce the level of impact to wildlife habitats important to subsistence and on 

subsistence activities in areas that remain open to locatable, salable, and leasable mineral development. 

Effects under Alternative C 

Under Alternative C, the area designated as NSO leasable (6,824,035 acres; 51 percent) and closed to 

leasing (46,953 acres; less than 1 percent) would be substantially less than under Alternative B, and the 

remaining 6,594,906 acres of BLM-managed land in the planning area (49 percent) would be open to 

leasing with standard stipulations. Therefore, this alternative would be more likely to impact wildlife and 

subsistence resources from mineral leasing than Alternative B. 

Under Alternative C within HVWs (exception would be locatable mineral development and permitted 

activities by other agencies [e.g., ADF&G]), for fish-bearing streams, the disturbance buffer would be the 

100-year floodplain of fish-bearing streams; no surface-disturbing activities or permanent structures 

would be allowed within these buffers. Buffers and therefore the total miles of streams would vary 

depending on stream order. Therefore, metrics for this alternative would be calculated on a case-by-case 

basis. Areas open/closed to mining activities are provided in Table 3.1.3-7. If adverse effects resulted 

from these actions in displacement and disturbance to the resources then subsistence activities in these 

areas and harvest could be affected. The potential for and level of impact on fish and aquatic resources is 

influenced by numerous factors, including management decisions allowing for surface-disturbing 

activities, combined with the success and adequacy of protective measures, such as maintaining riparian 

vegetation in proper functioning condition and the application of mineral withdrawals. BMPs and 

reclamation procedures under this alternative would be similar to Alternative B. 

Effects under Alternative D 

Alternative D would result in the lowest proportion of the planning area closed to leasing (46,953 acres; 

less than 1 percent) or designated as NSO leasable (236,556 acres; 2 percent) and the greatest proportion 

designated as open to leasing subject to standard stipulations (13,182,385 acres; 98 percent), relative to 

the other action alternatives. Based on geographic extent of areas open to leasable minerals, this 

alternative would be more likely to impact fish, wildlife and SSS from leasable mineral development than 

Alternatives A, B, and C. 

Under Alternative D surface-disturbing activities or permanent structures would be allowed within the 

100-year floodplain of perennial and fish-bearing streams. This would occur if permittees can 

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demonstrate these activities would not substantively impact floodplain function and would be decided on 

a case-by-case basis. If adverse effects resulted from these actions in displacement and disturbance to the 

resource then subsistence activities in these areas and harvest could be affected. The potential for and 

level of impact on fish and aquatic resources is influenced by numerous factors, including management 

decisions allowing for surface-disturbing activities, combined with the success and adequacy of protective 

measures, such as maintaining riparian vegetation in proper functioning condition and the application of 

mineral withdrawals, BMPs, and reclamation procedures. BMPs under this alternative would be similar to 

Alternatives B and C. Therefore, Alternative D could impact fish, wildlife, and SSS important for 

subsistence over a greater geographic extent and higher magnitude than Alternative B and C. It could 

have subsistence impacts over a greater geographic extent than Alternative A although the magnitude of 

impacts would be less due to BMPs, SOPs, and reclamation procedures that would be implemented under 

Alternative D. 

Subsistence: Effects from Lands and Realty Management Decisions 

In addition to the management actions common to all of the action alternatives, potential impacts from the 

following management topics were considered: 

• ROW Exclusion and Avoidance Areas 

• Permits and Leases 

• Disposals 

Potential impacts on subsistence resources from lands and realty management would include habitat loss, 

fragmentation, and degradation; disturbance of or direct mortality to resources; loss of species diversity 

from ROW development and other permitted facilities; and changes in ownership that might result in 

different standards for managing subsistence resources. Permits and leases are often associated with 

human uses that increase human presence, which may increase stress on wildlife resources during 

breeding, migration, and wintering periods, and potentially interfere with subsistence harvest activities. 

Land acquisitions could benefit fish, wildlife, and SSS that are subsistence resources by increasing 

the acres of wildlife habitat in the planning area, including sensitive or key habitats, and by creating more 

contiguous blocks of habitat for management purposes. Conversely, land disposals would reduce the 

amount of habitat for subsistence resources under BLM management. Land withdrawals would have the 

potential to benefit fish, wildlife and SSS used for subsistence if the BLM closed BLM-managed lands to 

activities with the potential to impact species and their habitat. 

Areas open for ROW development are considered one of the management actions with the greatest 

likelihood to have high magnitude impacts to availability of subsistence resources due to the long-term 

impact ROWs could have on availability of subsistence resources by changing species movement 

patterns. Areas open to ROW location could cause habitat degradation and fragmentation and increase 

competition for resources if those ROWs were used to build structures, utilities, or transportation 

corridors. This may impact moose, caribou, and fish resources (particularly salmon, but also non-salmon 

fish including sheefish, whitefish, and trout) as these resources are typically the most heavily harvested 

resources in the planning area communities. New ROW would likely be associated with locatable mineral 

development for roads and pipelines needed for transportation of personnel, equipment, and resources. 

Access to subsistence resources and traditional harvest areas could be of low to high magnitude 

depending on the portions of the nearby communities’ harvest areas that are affected and could be adverse 

or beneficial. 

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Effects under Alternative A 

Under Alternative A, all existing ANCSA 17(d)(1) withdrawals would remain in place, affecting 

12,559,533 acres (93 percent) of the planning area. Alternative A does not provide additional 

management guidance for lands and realty that would affect fish, wildlife and SSS used as subsistence 

resources or their indicators. Existing conditions would continue. Under Alternative A, new ROW would 

be permitted on the entire planning area on a case-by-case basis, which would affect availability of 

subsistence resources. The communities most likely to experience impacts to access and availability of 

subsistence resources from new ROW development under Alternative A include: Aniak, Anvik, Bethel, 

Crooked Creek, Chuathbaluk, Grayling, Holy Cross, Kaltag, Lime Village, Lower Kalskag, Marshall, 

McGrath, Nikolai, Nulato, Russian Mission, Shageluk, Sleetmute, Stony River, Unalakleet, and Upper 

Kalskag. 

Effects Common to All Action Alternatives 

Under all of the action alternatives, the BLM would implement actions to consolidate land management 

that could affect the amount of fish, wildlife, and SSS habitat that is important for subsistence use and 

resources in the planning area. The BLM would consider objectives to protect subsistence resource 

habitat and reduce habitat fragmentation when making decisions about land disposal, exchange, and 

acquisition. Additionally, the BLM would attempt to co-locate linear projects within existing ROWs and 

would require ROWs to provide for unimpeded caribou passage in all caribou connectivity corridors or 

where essential winter habitat exists. 

Additional SOPs/BMPs listed in Appendix K of the BSWI Draft RMP/EIS designed to protect wetlands 

and streams/water quality and reduce the establishment and spread of NNIS would provide additional 

protections to subsistence resources from actions associated with lands and realty. 

Effects under Alternative B 

Identification of ROW exclusion and avoidance areas under Alternative B would help minimize habitat 

fragmentation and degradation in these areas, which could affect availability of subsistence resources. It 

would also minimize unintentionally opening new access routes to uses competing with subsistence 

activities. ROW exclusion areas would occur on 1,464,069 acres (11 percent) of the planning area and 

include high value wildlife habitat, such as the Innoko Bottoms Priority Wildlife Habitat Area, the 

managed North Connectivity Corridor and South Connectivity Corridor, and the Unalakleet Wild River 

Corridor. ROW avoidance areas would occur on an additional 8,824,848 acres (66 percent) of the 

planning area, and would provide some protections to additional areas, including fish and wildlife 

habitats. Restrictions on where trapping/subsistence cabins could occur would reduce impacts in fish, 

wildlife and subsistence locations and would provide a minimal benefit to those resources but could also 

restrict the traditional subsistence use of cabins. Areas with the greatest potential for habitat loss, 

degradation, and fragmentation from development of ROWs that could reduce availability of subsistence 

resources would be in the 3,176,977 acres (about 24 percent of BLM-managed land in the planning area) 

areas outside of ROW exclusion and avoidance areas. The communities most likely to experience impacts 

to access and availability of subsistence resources from new ROW development under Alternative B 

include: Aniak, Crooked Creek, Holy Cross, Kaltag, McGrath, Marshall, Nikolai, Sleetmute, Unalakleet, 

Upper Kalskag, and Lime Village 

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Under Alternative B, the BLM would pursue opportunities to acquire lands within the INHT NTMC, 

which could result in an increase in wildlife habitat in the planning area and associated benefits to 

subsistence. 

Under Alternative B, there would be approximately 9,795,543 acres of new FLPMA withdrawals 

proposed, approximately 8,530,066 acres of existing ANCSA 17(d)(1) withdrawals that would be 

retained, and approximately 4,931,465 acres of existing ANCSA 17(d)(1) withdrawals that would be 

revoked. Other existing withdrawals in the planning area would remain. Under this alternative, 

342,360 acres (3 percent) of the planning area are available for exchange, which could reduce the total 

amount of wildlife habitat in the planning area under BLM management depending on the areas that were 

added to BLM-management under the exchange. Available exchanges and acquisitions under 

Alternative B that would affect important wildlife habitat and subsistence in the planning area include 

reductions in riparian area, moose calving and wintering areas, caribou crucial winter habitat, and the 

Innoko Bottoms Priority Wildlife Habitat Area. These reductions could be offset to some degree by 

available acquisitions, which would include a smaller geographic extent of riparian areas and moose 

calving and wintering areas and no caribou crucial winter habitat, but a greater extent of the Innoko 

Bottoms Priority Wildlife Habitat Area. Adverse effects to subsistence resources could result if there were 

reductions in harvest success and limits in access to resources in areas where BLM is no longer managing 

the land. 

Effects under Alternative C 

Alternative C would have a greater risk for habitat fragmentation and degradation affecting availability of 

subsistence resources than Alternative B, because there would be no designated ROW exclusion areas. 

Additionally, a smaller portion of the planning area (7,645,532 acres; 57 percent of the planning area) 

would be identified as ROW avoidance area (including areas of ROW avoidance for linear realty actions 

only). Areas outside of ROW avoidance areas, with the greatest potential for habitat loss, degradation, 

and fragmentation from development of ROWs would include habitats important to subsistence harvest of 

resources. The communities most likely to experience impacts to access and availability of subsistence 

resources from new ROW development under Alternative C include: Aniak, Crooked Creek, Grayling, 

Holy Cross, Kaltag, Lower Kalskag, McGrath, Marshall, Nikolai, Russian Mission, Shageluk, Sleetmute, 

Stony River, Unalakleet, Upper Kalskag, Lime Village. 

The potential increase in wildlife habitat managed by BLM that could affect subsistence in the planning 

area would be the same as Alternative B. Based on the land available for exchange (356,942 acres; 

3 percent of the planning area), the amount of fish and wildlife habitat under BLM management could be 

slightly reduced compared to Alternative B, with greater reductions in riparian areas and moose calving 

and wintering areas but the same amount of caribou crucial winter habitat and Innoko Bottoms Priority 

Wildlife Habitat Area. Available acquisitions that could somewhat offset disposals would be the same as 

under Alternative B. 

Effects under Alternative D 

Alternative D would have a greater risk for wildlife and subsistence habitat fragmentation and 

degradation affecting availability of subsistence resources than Alternatives B and C, because there would 

be no designated ROW exclusion areas, and the acreage of ROW avoidance areas would be the lowest of 

all the action alternatives (5,130,927 acres; 37 percent of the planning areas). Areas outside of ROW 

exclusion and avoidance areas, with the greatest potential for habitat loss, degradation, and fragmentation 

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from development of ROWs would include habitats that are important for subsistence resources. The 

communities most likely to experience impacts to access and availability of subsistence resources from 

new ROW development under Alternative D include: Aniak, Anvik, Crooked Creek, Chuathbaluk, 

Grayling, Holy Cross, Kaltag, Lower Kalskag, McGrath, Marshall, Nikolai, Russian Mission, Shageluk, 

Sleetmute, Stony River, Unalakleet, Upper Kalskag, and Lime Village. 

Because the BLM would not pursue opportunities to acquire public land under Alternative D, there would 

be no potential increase in wildlife habitat in the planning area. Based on the amount of land available for 

disposal (451,173 acres; 3 percent of the planning area), this alternative would result in the greatest 

reduction in the amount of wildlife habitat under BLM management, compared to Alternatives B and C, 

and there would be no acquisitions of these habitats to help offset the losses. The amount of caribou 

crucial winter habitat available for exchange or disposal would be the same as Alternatives B and C, but 

with no acquisition of this habitat to help offset the loss. If all available exchanges/disposals and 

acquisitions are carried out, the amount of high-value wildlife in the planning area would be less than 

under Alternatives A, B, and C. The amount of caribou crucial winter habitat would be the same as 

Alternatives B and C, but less than under Alternative A. Overall, Alternative D would have a greater 

adverse impact on fish and wildlife habitat and related subsistence resources than Alternatives A, B, and 

C in terms of the geographic extent of key wildlife habitats important for subsistence available for 

exchange or disposal. 

Subsistence: Effects from Recreation and Visitor Services Management Actions 

In addition to the management actions common to all of the action alternatives, potential impacts from the 

following management topics were considered: 

• INHT SRMA 

• BSWI ERMA – OHV 

• Unalakleet Wild River Corridor – Travel Decisions 

• User Conflicts 

• Recreation Management Area Designations 

Recreation can affect subsistence resources and local users in the planning area by introducing humans 

into remote areas and potentially interfere with subsistence activities and compete for subsistence 

resources. The presence of motorized vehicles, vessels and humans can disturb fish and wildlife 

resources, potentially resulting in increased energy expenditure due to movement away from the activity 

and avoidance of the activity for the short and long term. The movement of wildlife in turn can impact 

subsistence harvest activities and result in hunters having to travel farther and expend more resources 

(fuel/time) to hunt and harvest resources. Recreation activities during breeding periods can reduce 

reproductive success of subsistence resources. Wildlife can also habituate to human presence, which can 

increase the risk of injury or mortality from human-wildlife interactions. Recreation can also result in 

degradation or loss of habitat although there are no existing or proposed recreation facilities in the 

planning area where concentrated recreation use is likely to occur with the exception of the INHT. Use of 

OHVs can degrade wildlife habitats and subsistence use areas through surface disturbance, particularly 

when soils are not frozen; can crush nests and small terrestrial species; and can lead to the creation of new 

trails, which can increase the amount of disturbed area and provide access to competing harvest of fish 

and wildlife. Most recreation in the planning area occurs along the INHT corridor, and fish, wildlife and 

SSS that are important to subsistence users in this area are the most likely to be affected by increased use 

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Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

of recreationists and visitors. Recreational hunting and fishing have a direct impact on wildlife and 

subsistence resources through mortality and reduction in prey species, although because game populations 

are managed by ADF&G, these impacts are not the focus of this analysis. If it were to occur on a large 

scale recreational berry picking can affect grizzly bears, migratory birds, and other species by resulting in 

a localized reduction in availability of this food source to subsistence users. 

Impacts on subsistence from recreation are generally the result of conflicts between recreational uses 

(e.g., motorized versus non-motorized use), sport hunting and fishing, the designation of SRMAs and 

ERMAs, and limits or stipulations placed on SRPs. The frequency and intensity of user conflicts are 

seasonal, localized, and only occur when users perceive the uses to be incompatible. Conflicts increase 

over time as an increasing number of visitors seek recreation opportunities on BLM-managed land. The 

potential for impacts is greatest where visitors’ expectations are for a remote experience with little 

interaction with other users. 

Managing SRMAs and ERMAs would improve diverse recreation experiences in accordance with 

management objectives. Based on specific SRMA and ERMA management, potential increases in 

recreation would occur. Developing new recreation facilities in SRMAs would expand recreation 

opportunities but would also attract more visitors to the decision area. Increased visitation could result in 

more conflicts between recreation users and subsistence users, particularly in high-use areas, such as 

along the INHT. 

Effects under Alternative A 

Under Alternative A, under a continuation of current management, there would be a potential for user 

conflicts, especially in popular recreation areas, such as along the INHT and Unalakleet Wild River 

Corridor. Due to an increase in vehicle technology, there would be more frequent and intense impacts 

between motorized and non-motorized users. 

The BLM would not designate Recreation Management Areas, and in general, would support dispersed 

and unstructured recreation opportunities throughout the entire decision area. 

Continuing to issue SRPs on a case-by-case basis would allow outfitters to accommodate demand for 

guided hunting and fishing (which can conflict with subsistence activities and compete for resources), 

special events on the INHT, and other specially permitted activities. Over time, an expanding number and 

size of SRP activities would increase the potential for conflicts with subsistence users and damage natural 

resources that contribute to the recreation setting for all users. These impacts to subsistence would be 

greatest in areas of high recreation use, such as along the INHT. 

Effects Common to All Action Alternatives 

Under all of the action alternatives, in the BSWI ERMA, hunting and dispersed camping would be the 

primary recreation activities for which the BLM would manage. The management actions would reduce 

the potential for conflicts in secondary activities, such as snowmobiling and commercial fishing guides. 

The issuance of SRPs with stipulations to protect resources that contribute to positive recreation 

experiences and the recreation setting would provide for the long-term protection of those resources from 

permitted activities in the ERMA. 

Recreation and travel management would have the potential to affect subsistence by influencing the 

amount of associated human presence and habitat disturbance. Proposed management would allow the 

BLM to reduce the impacts on important subsistence resource areas and limit the potential for conflicts 

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between user groups. The BLM would seek to reduce conflicts between recreation and subsistence users 

by taking community interests and impact into account in hunting guide permitting decisions and by 

encouraging hunting guide-outfitters to coordinate with local communities. The BLM would also 

implement SOPs/BMPs that would help protect streams, water quality, wetlands, and floodplains, as well 

as associated wildlife and SSS that are important to subsistence resources. 

Effects under Alternative B 

Under Alternative B, the planning area would be managed as 355,799 acres as SRMA and 

13,110,096 acres as ERMA and have an OHV designation of “Limited.” Compared with Alternative A, 

there would be a reduction in the potential for user conflicts. 

The 355,799-acre INHT SRMA would provide specific outcome-focused management objectives and 

setting characteristics intended to reduce conflicts while supporting trail-based recreation activities and 

positive user experiences. Alternative B applies a CFZ within a 10-mile buffer surrounding BSWI 

communities. SRPs for hunting guide-outfitter businesses would not be authorized within a 10-mile 

radius of any established community in the planning area (10-mile radius of all communities includes 

818,395 acres of BLM-managed public lands), although shuttle service operations would be allowed with 

a required SRP throughout the entire ERMA (including CFZs). This would reduce conflicts with 

subsistence users in comparison to Alternatives A, C and D. 

Unalakleet Wild River Corridor 

Under Alternative B, OHV designation in the Unalakleet Wild River Corridor would be limited. Casual 

summer access would be prohibited; however, subsistence summer access would be permitted, limited to 

existing trails, primitive roads, and roads. This would remove potential for use conflicts between 

recreationists and subsistence users. Winter casual use would be permitted by snowmobile only, 

providing for recreation opportunities that do not cause resource damage. Because winter recreation use is 

low, it is not expected to conflict with subsistence or other casual uses of the area. 

Effects under Alternative C 

Under Alternative C, 13,125,320 acres would be managed as and ERMA and 340,574 acres as SRMA. 

Impacts under Alternative C would be similar to Alternative B with the exceptions that a slightly smaller 

SRMA. Under Alternative C, casual and subsistence OHV use would be permitted on existing routes at 

the Rohn Site. Winter casual and subsistence access would be allowed for snowmobiles only, similar to 

Alternative B, and impacts from winter travel would be the same as Alternative B. Management actions 

would provide for increased recreation opportunity during summer months, and could also result in 

increased conflicts between recreational, casual and subsistence users. Increased use could result in 

damage to the trail resource, thereby altering recreation setting, opportunity, and experience over time. 

Summer OHV casual use would be limited to existing routes. Subsistence cross-country summer OHV 

access on all lands in the planning area managed as undesignated would be allowed by ATV and UTV. 

This action could also result in potential conflict between recreationists and casual or subsistence users. 

Alternative C applies a CFZ within a 5-mile buffer surrounding BSWI communities. SRPs for hunting 

guide-outfitter businesses would not be authorized within a 5-mile radius of any established community 

in the planning area (5-mile radius of all communities includes 95,307 acres of BLM-managed public 

lands). As with Alternative B, SRPs would not be authorized in CFZs for hunting guide/outfitters. These 

restrictions would not apply to shuttle service operations, which would be allowed without an SRP 

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throughout the ERMA unless increases in use conflict with the BSWI ERMA objectives, at which point 

the BLM would engage in additional planning to maintain the objectives. This would reduce conflicts 

with subsistence users compared to Alternatives A and D, though to a lesser extent than under Alternative 

B. 

Unalakleet Wild River Corridor 

OHV use in the Unalakleet Wild River Corridor for casual summer access would be limited to existing 

trails, primitive roads, and roads and would include ATVs only. Subsistence cross-country summer OHV 

access on lands in the Unalakleet Wild River Corridor would be allowed by ATV. Recreation access in 

the summer would provide for increased opportunity for conflict. However, due to the wet and boggy 

condition of the area, summer travel is expected to be minimal such that while damage to the lands 

(rutting, braiding) could occur and there could be an increased potential for use conflicts between 

recreationists and subsistence users, it would be low in terms of magnitude. 

Effects under Alternative D 

Under Alternative D, the planning area would be managed as 13,125,320 acres as ERMA and 340,574 as 

SRMA, same as Alternative C. Under Alternative D, the BLM would designate the INHT SRMA; 

however, there would be limited additional management beyond that specified in Alternative A to limit 

SRPs or mitigate user conflicts. Under Alternative D, the BLM’s recreation program would accommodate 

demand for future permitted recreation activities, and these activities could conflict with each other and 

with other subsistence and individual users. There would be no CFZs applied under this alternative. 

Alternative D does not propose SRPs for hunting guide-outfitter/outfitter business authorizations 

operating within a radius of any established community in the planning area and allows shuttle service 

operations throughout the ERMA without an SRP. However, if the ERMA objectives are not being met, 

BLM would increase monitoring, outreach, education, and/or enforcement, case-by-case. Therefore, 

Alternative D would be less protective than Alternatives A, B and C. 

Unalakleet Wild River Corridor 

OHV designation in the Unalakleet Wild River Corridor would be limited. Casual and subsistence 

summer access would be the same as Alternative C; however, travel could be by ATV or UTV. Winter 

access would be the same as under Alternative B. The expanded mode of summer travel would provide 

increased recreation opportunities. However, due to the wet and boggy condition of the area, summer 

travel is expected to be minimal such that while damage to the lands (rutting, braiding) could occur and 

there may be an increase potential for use conflicts between recreationists and subsistence users it would 

be low in terms of magnitude, similar to Alternative C. Impacts from winter travel would be identical to 

Alternative C. 

Subsistence: Effects from Travel and Transportation Management Decisions 

In addition to the management actions common to all of the action alternatives, potential impacts from the 

following management topics were considered: 

• Innoko Bottoms Priority Wildlife Habitat Area 

• All BSWI Lands Not Managed as TMUs, Conservation System Units, or Sensitive Resource 

Areas 

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• Unalakleet Wild River Corridor Travel Management Decisions 

• INHT NTMC TMA 

• Rohn Site Travel Decisions 

• Lands Managed for Wilderness Characteristics TMA 

Summer subsistence OHV travel restrictions are considered one of the management actions with the 

greatest likelihood to have high magnitude impacts to access to subsistence resources since they could 

obstruct existing routes to subsistence resources used by rural communities, particularly areas for moose, 

caribou, and fish harvesting. Additionally, casual OHV use in the planning area can lead to degradation of 

habitats and resources, and may increase competition for resources, which may affect the availability and 

abundance of subsistence resources. 

Effects under Alternative A 

All lands in the planning area are managed as undesignated for travel and transportation management, 

which allows full access to the planning area for subsistence uses. Traditional means of access such as 

outboard motorboats, airplanes, dogsleds, and snowmobiles are allowed for all river users. Other means of 

access, such as inboard jet boats, airboats, hovercraft, and all-terrain vehicles are not allowed in the 

Unalakleet Wild River Corridor. However, because there is a lack of travel and transportation 

management for all uses in the planning area, impacts to subsistence could occur from OHV vehicle use 

that could result in loss or degradation of subsistence resource habitat from physical disturbance and also 

to loss of habitat in use areas through avoidance of the area by resources, and could fragment habitat in 

use areas if new trails were created. It could also create additional access for activities that compete for 

subsistence resources, such as sport hunting and fishing. The existing conditions would continue under 

Alternative A. Due to the lack of management direction on OHV use, the route network would continue 

to expand which would affect subsistence resources. Additionally, restricting OHV summer subsistence 

OHV use in the Unalakleet Wild River Corridor could obstruct access to fishing subsistence use areas. 

The communities most likely to experience impacts to access to subsistence resources from summer OHV 

restrictions under Alternative A include: Aniak, Anvik, Bethel, Crooked Creek, Chuathbaluk, Grayling, 

Holy Cross, Kaltag, Lime Village, Lower Kalskag, Marshall, McGrath, Nikolai, Nulato, Russian Mission, 

Shageluk, Sleetmute, Stony River, Unalakleet, and Upper Kalskag. 

Effects Common to All Action Alternatives 

Under all of the action alternatives, the BLM would work with local communities to mark winter travel 

routes between communities and take actions to limit motorized use that degrades habitats and leads to 

displacement of wildlife due to noise and activity. Designating all of BLM-managed lands in the planning 

area as “Limited” would reduce the potential for loss, degradation, and fragmentation of wildlife habitats 

that are important to subsistence, as OHV use would be limited to certain areas or specific trails. 

Additionally, implementing travel management planning would allow the BLM to develop a travel 

network that meets the needs of subsistence and other users while considering potential impacts to 

wildlife and subsistence in the planning area. Additional resource competition from recreational users 

would be mitigated through more lenient restrictions on motorized watercraft, snowmobiles, and OHVs 

used for subsistence purposes. The BLM would support overland travel needed for accessing subsistence 

resources and traveling between communities to share subsistence resources by working with 

communities to maintain existing trail systems and by managing winter and summer travel routes. The 

BLM would also support the development of communications infrastructure, such as cell phone towers 

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and emergency shelter cabins. The communications infrastructure would improve safety for subsistence 

harvesters. Summer subsistence OHV restrictions could impact access to fishing and harvesting 

subsistence use areas, depending on where the restrictions would occur. 

Effects under Alternative B 

To minimize impacts to subsistence resources and reduce subsistence conflict, casual use airboats and 

hovercraft would not be allowed on non-navigable waterways on BLM-managed land within the 

designated connectivity corridors (845,670 acres) or the Innoko Bottoms Priority Wildlife Habitat Area. 

These actions would help reduce impacts to habitat used by caribou and other wildlife important to 

subsistence. In the Innoko Bottoms Wildlife Habitat Area, restrictions on airboats and hovercraft would 

reduce disturbance impacts to subsistence resources. 

Alternative B would be more restrictive on summer and winter overland travel for casual use 

(565,955 acres, 4 percent of the planning area) than for subsistence uses (see Table 3.11.3-4Error! Not a 

valid bookmark self-reference.). Alternative B is also generally more restrictive on overland travel for 

casual and subsistence uses than Alternatives C and D (see Table 3.11.3-5 and Table 3.11.3-6). OHV 

restrictions could minimize impacts to subsistence resources and reduce competition between casual and 

subsistence users by providing more access to more of the planning area for subsistence uses. However; 

the 288,466 acres (about 2 percent of BLM-managed land in the planning area) that would be closed to 

summer subsistence OHV use would impact access to hunting, fishing, and harvesting subsistence use 

areas. 

Impacts from OHV restrictions for winter or summer use could occur for the following communities: 

Anvik, Grayling, Holy Cross, Kaltag, McGrath, Nikolai, Shageluk, Sleetmute, Stony River, Unalakleet, 

and Lime Village. 

Designation of the two connectivity corridors and Innoko Bottoms Priority Wildlife Habitat Area and 

associated management actions under Alternative B would provide protections for wildlife and 

subsistence resources, minimize impacts to subsistence resources, and reduce subsistence conflict with 

recreation use in those areas. 

Table 3.11.3-4: Overland Travel Restrictions for Subsistence and Casual Use 

Proposed under Alternative B 

Travel Restriction 

Affected Area for 

Subsistence Use (acres) 

Affected Area 

for Casual Use (acres) 

Summer OHV Access Prohibited 241,512 565,955 

Summer OHV Access Limited to Existing Trails 324,443 12,899,939 

Winter Use – Snowmobiles Only 4,243,914 13,465,894 

Effects under Alternative C 

To minimize impacts to subsistence resources and reduce subsistence conflict, casual use airboats and 

hovercraft would not be allowed on non-navigable waterways on BLM-managed land in the designated 

wildlife connectivity corridor (576,038 acres, 4 percent of the planning area) or the Innoko Bottoms 

Priority Wildlife Habitat Area. Management actions in caribou habitat and the Innoko Bottoms Wildlife 

Habitat Area and associated effects on wildlife that affect subsistence resources would be identical to 

those under Alternative B. Alternative C would have the same restrictive on summer overland travel for 

casual use and subsistence use (see Table 4.6.2-6). Alternative C would also be slightly less restrictive on 

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Appendix N: Supplemental Impact Analysis Information Section 3: Supplemental Impact Analysis 

overland subsistence travel than Alternative B and more restrictive than Alternative D. The 225,925 acres 

(about 2 percent of BLM-managed land in the planning area) that would be closed to summer subsistence 

OHV use would impact access to hunting, fishing, and harvesting subsistence use areas. 

The following communities would have impacts related to OHV use: Anvik, Grayling, Holy Cross, 

Kaltag, Nikolai, Shageluk, Sleetmute, Stony River, Unalakleet, and Lime Village. 

Designation of the one connectivity corridor and Innoko Bottoms Priority Wildlife Habitat Area and 

associated management actions under Alternative C would provide protections for wildlife and 

subsistence resources, minimize impacts to subsistence resources, and reduce subsistence conflict with 

recreation use in those areas. 

Table 3.11.3-5: Overland Travel Restrictions for Subsistence and Casual Use Proposed under 

Alternative C 

Travel Restriction 

Affected Area for Subsistence 

Use (acres) 

Affected Area for Casual Use 

(acres) 

Summer OHV Access Prohibited 225,925 225,925 

Summer OHV Access Limited to Existing Trails 0 13,239,969 

Winter Use – snowmobiles only 3,097,798 3,097,798 

Effects under Alternative D 

Alternative D would be somewhat more restrictive on summer overland travel for casual use than for 

subsistence use (see Table 3.11.3-6). Alternative D would also be less restrictive on overland subsistence 

travel than Alternative B and C. Since Alternative D would not prohibit summer OHV subsistence access, 

it would not impact access to subsistence resources for any communities. 

Alternative D would not prohibit casual use airboats or hovercraft on non-navigable waterways on BLMmanaged land. There would be no additional travel management for caribou habitat and the Innoko 

Bottoms Priority Wildlife Habitat Area, so disturbance impacts to wildlife and subsistence in these areas 

would not be reduced as they would be under Alternatives B and C. 

Table 3.11.3-6: Overland Travel Restrictions for Subsistence and Casual Use 

Proposed under Alternative D 

Travel Restriction 

Affected Area for Subsistence 

(acres) 

Affected Area for Casual Use 

(acres) 

Summer OHV Access Prohibited 0 225,925 

Summer OHV Access Limited to Existing Trails 225,925 46,953 

Winter Use – snowmobiles only 225,925 225,925 

Subsistence: Effects from Areas of Critical Environmental Concern Management Decisions 

Potential impacts from the following management topics were considered: 

• Transportation Management Decisions 

• Minerals Decisions 

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Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

Effects under Alternative A 

Under Alternative A, 1,884,376 existing acres would continue to be managed as ACECs where special 

attention is required to protect and prevent irreparable damage to important resources. 

Effects Common to All Action Alternatives 

There would be no effects common to all action alternatives. 

Effects under Alternative B 

Under Alternative B, 3,913,372 acres would be designated and managed as ACECs, where special 

attention is required to protect and prevent irreparable damage to important resources. Management 

decisions on ACECs would include more restrictions on overland travel for casual use than for 

subsistence and additional restrictions on mineral development. These restrictions would help reduce 

competition between recreational and subsistence uses and reduce displacement of subsistence resources 

and activities by mineral development. 

Effects under Alternative C 

Under Alternative C, no land would be managed as ACECs, and there would be potential for less 

protection for subsistence resources and harvest practices in areas that are in existing ACECs under 

Alternative A and proposed under Alternative B. However, some management actions would apply to this 

area under VRM and HVW classifications. 

Effects under Alternative D 

Under Alternative D, no land would be managed as ACECs. Under Alternative D, the Sheefish ACEC 

and the Swift River Whitefish Spawning ACEC would not be designated, which could impact subsistence 

resources because these spawning areas support the sheefish and whitefish populations of the Kuskokwim 

River. The area would be open to commercial woodland harvest, ROW, and floodplain development 

under conditions specified in the RMP. This would be least protective of fisheries resources, though some 

management actions would apply to these areas to provide protections. Fishing resources, including 

salmon and non-salmon species (e.g., sheefish and whitefish) are one of the most heavily harvested 

resources for subsistence communities. The importance of non-salmon fish species has increased as a 

subsistence resource due to declines in the salmon returns which had made sheefish and whitefish even 

more important over time. 

Subsistence: Effects from National Trails Management Decisions 

In addition to the management actions common to all of the action alternatives, potential impacts from the 

following management topic were considered: 

• Mineral Decisions in the INHT NTMC 

• Management Decisions regulating casual access and OHV 

The INHT supports habitats used by fish, wildlife, and SSS. This trail is a focal area for recreation and is 

associated with increased human presence and motorized uses that have the potential to impact wildlife 

and SSS. While national trails management generally does not pertain to wildlife, it may help reduce the 

potential for impacts wildlife and SSS or their habitats from various land uses. 

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Effects under Alternative A 

Existing management of the INHT is focused on the historic sites associated with the trail. Under 

Alternative A, the INHT would not be designated as an NTMC and would not be subject to associated 

management. However, the BLM would continue to implement management actions for the INHT that 

are designed to reduce surface disturbance from other resources uses, including minerals, forestry and 

woodland products, and livestock grazing. These actions could reduce the potential for impacts to fish, 

wildlife and SSS in the INHT area from these resource uses and in turn provide protections for 

subsistence. Existing conditions would continue under Alternative A. 

Effects Common to All Action Alternatives 

Under all action alternatives, effects to wildlife and SSS from disturbance and habitat degradation 

associated with use of the INHT would be similar to those under Alternative A. However, the BLM 

would establish the INHT NTMC in the planning area. This designation would include additional 

management with prescriptions such as exclusion from coal leasing, noise restrictions, and a “Limited” 

travel management designation. Additionally, the BLM would implement BMPs/SOPs to limit the spread 

of NNIS, which could result in minor, typically localized benefits to fish, wildlife and SSS and 

subsistence. The alternatives would vary in terms of acreage designated as the INHT NTMC, where 

additional protections to wildlife and SSS could occur. 

Under all of the action alternatives, coal leasing would not occur in the INHT NTMC, which would 

reduce the potential for displacement of subsistence resources and activities. The BLM would prohibit 

winter OHV use in areas where it has degraded resources or interferes with National Trails System Act of 

1968 trails management, which could impede subsistence-related travel but would also limit wildlife 

disturbance and degradation of wildlife habitat. 

Effects under Alternative B 

Under Alternative B, designation of the INHT NTMC on 288,466 acres (2 percent of the planning area) 

could provide incidental, localized protections that would reduce impacts to fish, wildlife and SSS and 

their habitats that are important for subsistence over Alternative A. Alternative B would be more 

restrictive on mineral development in the 288,466-acre INHT NTMC than Alternatives C and D. This 

would offer the most protection of all of the alternatives for the abundance of subsistence resources and 

activities within the INHT NTMC. 

Effects under Alternative C 

Under Alternative C, the INHT NTMC would consist of 273,242 acres (2 percent of the planning area). 

Therefore, incidental, localized protections that would reduce impacts to fish, wildlife and SSS and their 

habitats that are important for subsistence would occur over a slightly smaller area than under 

Alternative B. Alternative C would be more restrictive on mineral development in the INHT NTMC than 

Alternative D and less restrictive than Alternative B. At 273,242 acres, the INHT NTMC would also be 

smaller under Alternative C than under Alternative B and therefore offer fewer protections to the 

abundance of subsistence resources. 

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Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

Effects under Alternative D 

The INHT NTMC would be the same size under Alternative D as it would under Alternative C, but 

Alternative D would impose the fewer restrictions on mineral development and exploration than 

Alternatives B and C, which could result in lesser protections to subsistence resources and activities. 

Alternative D would be somewhat more restrictive on summer overland travel for casual use than for 

subsistence use in comparison to Alternative A which has no restrictions. As compared to Alternative B 

and C, Alternative D would be less restrictive on overland subsistence travel. Alternative D would not 

prohibit casual use airboats or hovercraft on non-navigable waterways on BLM-managed land. 

Alternatives B and C include additional travel management for caribou habitat and the Innoko Bottoms 

Priority Wildlife Habitat Area, reducing disturbance impacts to wildlife and subsistence. Alternative D 

does not include this travel management, so disturbance impacts could lead to increase potential for use 

conflicts between recreationists and subsistence users. Alternative D would prohibit casual OHV use on 

about 2 percent of the planning area and restrict less than one percent to existing trails. Subsistence OHV 

use would be prohibited nowhere within the planning area would be restricted to existing trails for about 

2 percent of the planning area. Therefore, Alternative D would have the least impact on existing access 

for both casual and subsistence use and would only limit OHV use to existing routes in one area (INHT 

NTMC TMA) thus providing opportunities for network expansion. 

Subsistence: Effects from Wild and Scenic Rivers Management Decisions 

In addition to the management actions common to all of the action alternatives, potential impacts from the 

following management topics were considered: 

• Travel Management Decisions 

• UAS Uses 

WSR corridors provide habitat for subsistence resources and users that use stream and riparian habitats. 

Management to preserve the outstanding natural, cultural, and recreational values in a free-flowing 

condition promotes wildlife habitat health in these areas. However, human disturbance associated with 

recreational use of these areas may disturb fish, wildlife and SSS and therefore disturb subsistence 

resources and users. 

Effects under Alternative A 

Alternative A includes the designated Unalakleet Wild River Corridor (46,953 acres, less than 1 percent 

of the planning area) and 18 river segments (332,176 acres) identified as eligible. Management direction 

to preserve the environment of the river and river corridor in a natural, primitive condition would limit 

impacts to subsistence resources within the Unalakleet Wild River Corridor. Alternative A does not 

include management direction regarding use of UASs or travel management decisions that would pertain 

to fish, wildlife and SSS or their habitat in WSRs. In accordance with BLM Manual 6400, projects on 

BLM-managed lands within the eligible river corridor or on lands that are adjacent to or border eligible 

rivers must consider guidelines to protect ORVs from activities such as locatable, salable, and leasable 

mineral development; transportation and motorized travel; ROW authorization; recreation; wildlife and 

fish projects; and livestock grazing which could reduce impacts to wildlife and their habitats (and in turn 

affect subsistence) within those eligible river corridors from these resource uses, if implemented. 

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Appendix N: Supplemental Impact Analysis Information Section 3: Supplemental Impact Analysis 

Effects Common to All Action Alternatives 

All action alternatives would include additional management actions in WSR corridors that may reduce 

impacts to wildlife and SSS from various resource uses, such as acquiring additional lands within 

designated WSR corridors, which would potentially increase the amount of protected wildlife and SSS 

habitat, prohibiting or restricting development and some types of uses in these areas with the potential to 

degrade or fragment habitats, and minimizing noise intrusions that could disturb nesting birds and other 

fish, wildlife and SSS that are important to subsistence. 

The alternatives would vary in terms of area of land within WSR corridors and in the magnitude of 

management restrictions pertaining to OHVs and UASs in these areas. 

Effects under Alternative B 

Under Alternative B, the Unalakleet Wild River Corridor would remain in place. In addition, 

332,176 acres (3 percent of the planning area) would be recommended as suitable for WSR designation. 

Under Alternative B, the Unalakleet Wild River Corridor and all corridors recommended as suitable 

would be subject to management actions that could reduce impacts to fish and wildlife from various land 

uses, as described in the section Effects Common to All Action Alternatives. Because Alternative B 

provides additional protections for the 332,176 acres of rivers recommended as suitable, compared with 

the guidelines that would be considered for those same 332,176 acres determined eligible, Alternative B 

would have a greater potential to reduce impacts to wildlife from resource uses in these areas compared 

with Alternative A. Additionally, this alternative includes travel management decisions that would limit 

OHV use in designated and eligible WSR corridors, which would reduce associated disturbance and 

habitat degradation. Restrictions on some uses of UASs could also reduce disturbance to fish, wildlife and 

SSS (predominantly birds) that are used as subsistence resources. 

Effects under Alternative C 

Under Alternative C, 46,953 acres (less than 1 percent of the planning area) would be within WSR 

corridors (Unalakleet Wild River Corridor), which is identical to Alternative A and less than 

Alternative B. Travel management decisions and restrictions and management pertaining to UASs, which 

would be similar to those under Alternative B, would provide a similar reduction of potential impacts to 

wildlife and SSS and subsistence from resource uses in these areas, but the geographic extent of these 

effects would be less than under Alternative B. 

Effects under Alternative D 

Under Alternative D, the land area within WSR corridors (Unalakleet Wild River Corridor) would be 

identical to the area under Alternatives A and C. Compared to Alternatives B and C, management 

pertaining to travel management and UASs would be less restrictive (e.g., takeoff and landing of casual 

use UASs would be allowed in the WSR corridor) and would have slightly less ability to reduce impacts 

to wildlife and SSS and subsistence from resource uses in these areas. 

Subsistence: Effects from Support for BSWI Communities 

In addition to the management actions common to all of the action alternatives, potential impacts from the 

following management topics were considered: 

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Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

• Providing Assistance with Cultural Tourism 

• Zones between Hunting Guide-Outfitter Operating Areas and Rural Communities 

Effects under Alternative A 

There are no existing management actions specific to support for BSWI communities. The existing 

conditions would continue under Alternative A. 

Effects Common to All Action Alternatives 

Under all of the action alternatives, subsistence resources would be managed to sustain wild resource 

population levels to provide for continued rural economic opportunity and support subsistence lifestyles. 

The BLM would support efforts to train local residents as commercial recreation guides, encourage BLMpermitted operators to use local hire and accommodate subsistence schedules, and hire and train local 

workers for BLM operations, which would increase the cash income to local communities that is needed 

to sustain and supplement a subsistence lifestyle. 

The BLM would seek to reduce conflicts between recreation and subsistence users by taking community 

interests and potential impacts into account in hunting guide permitting decisions and by encouraging 

hunting guide-outfitters to coordinate with local communities and donate meat to communities. 

Additional resource competition from recreational users would be mitigated through more lenient 

restrictions on motorized watercraft, snowmobiles, and OHVs used for subsistence purposes. 

The BLM would support overland travel needed for accessing subsistence resources and traveling 

between communities to share subsistence resources by working with communities to maintain existing 

trail systems and by managing winter and summer travel routes. The BLM would also support the 

development of communications infrastructure, such as cell phone towers and emergency shelter cabins. 

The communications infrastructure would improve safety for subsistence harvesters. 

Effects under Alternative B 

Under Alternative B, the BLM would cooperate with the AIANTA to carry out activities to enhance 

cultural tourism in the planning area, which could expand economic opportunities in BSWI communities 

and lead to an increase in the cash incomes that are needed to sustain and supplement a subsistence 

lifestyle. Alternative B also applies a CFZ within a 10-mile buffer surrounding BSWI communities where 

SRPs for hunting guide-outfitters, guide, or outfitter businesses would not be authorized. This would 

reduce conflicts with subsistence users in comparison to Alternatives A, C and D. 

Effects under Alternative C 

Alternative C would be the same as Alternative B except it would include a 5-mile buffer between rural 

communities and hunting guide-outfitter operating areas on BLM lands. The buffer would help reduce 

competition and conflicts between recreation and subsistence users; however, the area would be 723,088 

acres smaller than Alternative B. 

Effects under Alternative D 

Alternative D would be the same as Alternative C except the BLM would seek funding to provide grants, 

loans, and technical assistance to BSWI communities to increase cultural tourism capacity, spur 

associated infrastructure development, and elevate living standards in BSWI communities. These 

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Appendix N: Supplemental Impact Analysis Information Section 3: Supplemental Impact Analysis 

opportunities for grants, loans, and assistance would increase the likelihood over Alternatives B and C 

that cash incomes would increase in local communities as a result of cultural tourism. Also, Alternative D 

would not propose any buffers between rural communities and hunting guide-outfitter operating areas on 

BLM lands. 

Subsistence: Climate Change Impacts 

Management actions that relate to subsistence would not counteract climate change impacts to subsistence 

resources. Changes in snowfall patterns and frequency, forest type, and overall shifting “cliomes” would 

likely drive changes in subsistence resource distribution related to plants, fish, wildlife, and timber. Such 

changes would increase economic insecurity of communities in the planning area reliant upon subsistence 

incomes due to increased time and fuel costs to locate resources or to cultivate new methods to secure 

subsistence livelihoods closer to their villages. When the effects of Alternative B are considered in 

context with the cumulative effects of climate change, measures to reduce direct and indirect stressors on 

ecological systems that support important subsistence species may lead to a higher level of ecological 

resilience in responding to changing climate. Alternative B may increase ecological resilience to climate 

change, which could result in decreased risk to households and communities reliant upon subsistence 

resources. On the other hand, Alternative D could be viewed as allowing BLM management to be more 

adaptable to changing conditions on a site-specific basis. 

Subsistence: Cumulative Effects 

Past and present land uses in the planning area, such as resource exploration and extraction, management 

of the INHT, community infrastructure, military activities, research and monitoring, recreation, and 

subsistence activities can all affect subsistence. Land use for all lands, including lands not managed by 

BLM, within the planning area can influence the current condition of subsistence resources in the 

planning area. Impacts from such actions include ROW establishment, lease sales, and surface occupancy. 

Past recreation, sport hunting and fishing activities, and traditional subsistence practices are expected to 

continue. Past uses of the INHT are also expected to continue. Recent funding has supported trail 

improvements such as shelter cabins. Land use for recreation, subsistence, and tourism may increase as 

local, state, and national populations grow. Climate change will benefit some subsistence resources and 

adversely affect others. Frequency and severity of natural wildland fire in western Alaska are predicted to 

increase and result in shifts to deciduous and shrub-dominated landscapes, which may benefit moose and 

some furbearers but not caribou. Predicted increases in water temperatures would alter chemical and 

biotic conditions to the detriment of subsistence fish diversity and abundance. Increases in soil 

temperatures would result in drying of lakes and ponds. 

The potential development of transportation corridors and trails, solid mineral exploration and 

development on State and Native lands, and the potential for increased recreational activities occurring in 

or adjacent to the planning area, would have cumulative impacts on subsistence resources. Depending on 

the location, extent, intensity, and duration of development these impacts could include: habitat integrity 

(relative to fragmentation, degradation, conversion could be compromised); increased access into wildlife 

habitats; unauthorized or uncontrolled OHV use; increased disturbance impacts; increased potential for 

mortality (road kills); and possible alteration of behavior or movement patterns and seasonal habitat use 

of wildlife. 

The continued use of small roads that connect communities within the planning area may aid subsistence 

users in accessing their traditional harvest areas. However, these small roads may also concentrate 

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Section 3. Supplemental Impact Analysis Appendix N: Supplemental Impact Analysis Information 

hunting efforts along the road/trail corridors, depleting resources from the area, and potentially altering 

harvest from current traditional harvest areas. Increased competition for subsistence resources would 

likely result if smaller communities were linked to new transportation corridors, as non-resident and nonlocal hunters would be able to access the area with little effort. This may also result in an increase in 

tourist traffic and recreational use of the area, resulting in additional impacts to wildlife. However, the 

construction of major road projects within the life of the plan would be dependent upon social and 

economic conditions and it is not clear which, if any, of these projects would be completed during the life 

of the plan. Because road construction in the planning area is so uncertain and the level of development 

projected through this plan so minimal, no cumulative impacts to subsistence species are anticipated. 

When considering the cumulative case, impacts to subsistence may result in any reasonably foreseeable or 

significant restriction of subsistence use for rural communities within the planning area if significant 

activities occur with transportation corridor development, mineral exploration and development, increased 

recreational activities occurring in or adjacent to the planning area, or unforeseen events in climate 

change that impact resource abundance, change harvest patterns, limit access to resources or increase 

competition. Under all alternatives Donlin Gold’s proposed mine may result in a restriction to subsistence 

uses for communities along the Kuskokwim River and communities along the gas pipeline right-of way. 

The development of ancillary facilities, temporary access roads, and airstrips association with the pipeline 

may result in unintended development along this corridor, which affects subsistence gathering regions. 

Designations that provide measures of protections for aquatic and terrestrial habitats, such as HVW, 

ACEC, WSR, and areas managed to preserve wilderness characteristics, will reduce risk to sensitive areas 

important for the reproduction of subsistence values. 

In comparison to the other alternatives, Alternative B would provide the greatest measure of protection 

for the maintenance and perpetuation of subsistence resources indirectly affected by the development of 

the Donlin Gold Mine and the associated natural gas pipeline. 

The results of the cumulative effects analysis for subsistence are presented in Table 3.11.3-7. 

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Appendix N: Supplemental Impact Analysis Information Section 3: Supplemental Impact Analysis 

Table 3.11.3-7: Cumulative Effects Analysis for Subsistence 

Trends and Forecasts of 

Subsistence in Consideration 

of Past and Present Actions 

Trends and Forecasts of 

Subsistence in Consideration 

of Past, Present, and 

Reasonably Foreseeable 

Future Actions (Alternative A) 

Trends and Forecasts of 

Subsistence in Consideration 

of Past, Present, and 

Reasonably Foreseeable 

Future Actions (Alternative B) 

Trends and Forecasts of 

Subsistence in Consideration 

of Past, Present, and 

Reasonably Foreseeable 

Future Actions (Alternative C) 

Trends and Forecasts of 

Subsistence in Consideration 

of Past, Present, and 

Reasonably Foreseeable 

Future Actions (Alternative D) 

Local residents harvest a wide With the trends of continued With the trends of continued With the trends of continued With the trends of continued 

variety of wild fish, wildlife, and natural resource development natural resource development natural resource development natural resource development 

vegetation for myriad purposes and increased casual and and increased casual and and increased casual and and increased casual and 

including for food, fuel, arts and recreational use in the planning recreational use in the planning recreational use in the planning recreational use in the planning 

crafts, tools, and clothing. Past area, subsistence resources area, subsistence resources area, subsistence resources area, subsistence resources 

and present activities have could continue to degrade, and could continue to degrade, could could continue to degrade, could could continue to degrade, could 

disturbed and displaced some subsistence users could become less available, and become less available, and become less available, and 

subsistence resources and face increased competition for some subsistence users could some subsistence users could some subsistence users could 

activities, but harvest levels and resources. face increased competition for face increased competition for face increased competition for 

practices would likely continue. Trend: Existing trends would resources. resources. resources. 

Trend: No change overall for continue, with no trend Trend: Improving. It is Trend: Varies between species Trend: Varies between 

wildlife habitat important for overall, but degrading for expected that implementing important to subsistence. It is species, stable or declining. 

subsistence resources but some species important to Alternative B would result in expected that implementing For forest and woodland 

degrading for some species subsistence and improving for an improved trend for most Alternative C would result in a species and species in areas 

and improving for others. others. With increased 

development in the planning 

area, species with affected 

habitat may experience a trend 

of increased degradation or 

lessened improvement at a 

similar rate. 

fish and wildlife that are 

subsistence resources. For 

species with habitat or 

populations that are 

degrading, this alternative 

would lessen the rate of 

degradation or stabilize or 

counter the existing trend. For 

species with habitat or 

populations that are 

improving, improvement 

would continue at a similar or 

greater rate. 

degrading trend for most fish 

and wildlife that are 

subsistence resources, 

though this trend would be 

less than Alternative A. With 

the trends of continued 

natural resource development 

and increased casual and 

recreational use in the 

planning area, subsistence 

resources would continue to 

be degraded and subsistence 

users would face increased 

competition for available 

resources by non-local users. 

For species with habitat or 

populations that are 

degrading, the degradation 

may continue but at a lesser 

rate and could be stabilized. 

of medium to high mineral 

development that are 

important as subsistence 

resources, potential trends 

could degrade as a result of 

the cumulative effects of 

future development, climate 

change, and fragmentation of 

habitats. These species would 

experience a trend of 

increased degradation or 

lessened improvement. 

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Appendix N: Supplemental Impact Analysis Information Section 4. References 

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Greenstein, C. 2013. Monitoring and Controlling Invasive Plants at Rohn Cabin: 2013 Update. Alaska 

Natural Heritage Program, University of Alaska, Anchorage. Available at: 

http://accs.uaa.alaska.edu/files/invasivespecies/Publications/2013/Controlling_Invasive_Plants_Rohn_Cabin_2013.pdf (accessed August 

2018). 

Harris, J.A., R.J. Hobbs, E. Higgs, and J. Aronson. 2006. Ecological Restoration and Global Climate 

Change. Restoration Ecology, 14(2):170-176. Available at: 

https://training.fws.gov/courses/csp/csp3132/resources/Climate%20Change/Ecological%20restor 

ation%20and%20CC.pdf (accessed August 2018). 

Johnson, J., and V. Litchfield. 2016a. Catalog of waters important for spawning, rearing, or migration of 

anadromous fishes – Interior Region, Effective March 1, 2016. Alaska Department of Fish and 

Game, Special Publication No. 16-02, Anchorage. 

Johnson, J., and V. Litchfield. 2016b. Catalog of waters important for spawning, rearing, or migration of 

anadromous fishes – Southwestern Region, Effective June 1, 2016. Alaska Department of Fish 

and Game, Special Publication No. 16-05, Anchorage. 

Johnson, J., and V. Litchfield. 2016c. Catalog of waters important for spawning, rearing, or migration of 

anadromous fishes – Western Region, Effective June 1, 2016. Alaska Department of Fish and 

Game, Special Publication No. 16-06, Anchorage. 

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Section 4. References Appendix N: Supplemental Impact Analysis Information 

Kling, L 2018. Personal communication -Louise Kling, AECOM to Jena Barringer, Bonnie Million and 

Bruce Seppi, BLM. Status Update and Next Steps. 

Kurtak, J., J. Hoppe and R. Ellefson. 2017. Mineral Occurrence and Development Potential Report, 

Locatable and Salable Minerals. BLM Alaska Technical Report 63, July 2017. Available at: 

https://eplanning.blm.gov/epl-frontoffice/projects/lup/36665/145032/178739/2017_Minerals_Occurrence_and_Development_Potenti 

al_Report_Rev1.pdf (accessed September 2018). 

Magness, D.R., A.L. Sesser, and T. Hammond. 2018. Using Geodiversity to Connect Conservation Lands 

in the Central Yukon, Alaska. Landscape Ecology. 33(4) pp 547–556. Available at: 

https://doi.org/10.1007/s10980-018-0617-0. 

McDowell Group. 2014. The Economic Impacts of Guided Hunting in Alaska. Alaska Professional 

Hunters Association: Juneau, AK. 23 p. 

Newell, E. 2018. Personal communication Emily Newell, AECOM and Bruce Seppi, BLM on November 

26, 2018 regarding ANILCA 810 Status Update.NovaGold. 2018. Donlin Gold Permitting. 

Available at: http://www.novagold.com/properties/donlin_gold/permitting/ (accessed October 

2018). 

NovaGold. 2018. Donlin Gold Permitting. Available at: 

http://www.novagold.com/properties/donlin_gold/permitting/ (accessed October 2018). 

NPS (National Park Service). 2009. Lake Clark National Park and Preserve Foundation Statement. Alaska 

Regional Office. Available at: 

https://parkplanning.nps.gov/showFile.cfm?projectID=24966&filename=LACL%20Foundation% 

20Statement%20Final%20101009.pdf&sfid=74704 (accessed August 2018). 

NPS. 2013. Draft Land Protection Plan. Lake Clark National Park and Preserve, Alaska. Available at: 

https://parkplanning.nps.gov/document.cfm?parkID=17&projectID=47089&documentID=53457 

(accessed August 2018). 

NPS. 2014. Lake Clark General Management Plan Amendment/Environmental Assessment. Lake Clark 

National Park and Preserve, Alaska. Available at: 

https://parkplanning.nps.gov/document.cfm?parkID=17&projectID=36331&documentID=57141 

(accessed August 2018). 

Pajunen, A., R. Virtanen, and H. Roininen. 2008. “The effects of reindeer grazing on the composition and 

species richness of vegetation in forest-tundra ecotone.” Polar Biology, 31:1233.1244. 

Swanson, J.D., and M.H.W. Barker. 1992. Assessment of Alaska reindeer populations and range 

conditions. Rangifer, 12:33-43. Available at: 

https://septentrio.uit.no/index.php/rangifer/article/view/1023/977 (accessed August 2018). 

4-4 
 

Appendix N: Supplemental Impact Analysis Information Section 4. References 

U.S. Census Bureau. 2010a. 2010 Census Fact Finder. Available at: 

https://factfinder.census.gov/faces/nav/jsf/pages/index.xhtml (accessed October 2018). 

U.S. Census Bureau. 2010b. 2010 Census Interactive Population Search Bethel City. 

USFWS (U.S. Fish and Wildlife Service). 1988. Yukon Delta National Wildlife Refuge comprehensive 

conservation plan, environmental impact statement, wilderness review, and wild river plan: Final. 

Anchorage, AK: U.S. Department of the Interior, Fish and Wildlife Service, Alaska Region 

USFWS. 2008. Revised Comprehensive Conservation Plan for the Innoko National Wildlife Refuge. 

Alaska Region U.S. Fish and Wildlife Service. Available at: 

https://www.fws.gov/alaska/nwr/planning/pdf/innoko/Inn_CoverandFrontPages.pdf (accessed 

August 2018). 

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Appendix O: Alaska National Interest Lands Conservation 

Act (ANILCA) Preliminary Section 810 Evaluation 

 

 

 

 

Appendix O: ANILCA Preliminary Section 810 Evaluation BSWI Draft RMP/EIS 

Table of Contents 

Acronyms....................................................................................................................................................iv 

Section 1 Introduction ................................................................................................................................1 

Section 2 Subsistence Evaluation Factors under ANILCA Section 810(a) ............................................3 

2.1 Determinations............................................................................................................................3 

2.2 Findings.......................................................................................................................................4 

Section 3 Evaluations and Findings for All Alternatives and the Cumulative Case.............................7 

3.1 Evaluation and Findings for Alternative A (No Action Alternative)..........................................7 

3.1.1 Evaluation of the Effect of Use, Occupancy, or Disposition on Subsistence Uses 

and Needs....................................................................................................................... 9 

3.1.2 Evaluation of the Availability of Other Lands for Land Use Decisions Allowed 

under Alternative A...................................................................................................... 10 

3.1.3 Evaluation of Other Alternatives that would Reduce or Eliminate the Use, 

Occupancy, or Disposition of Public Lands Needed for Subsistence Purposes........... 10 

3.1.4 Findings ....................................................................................................................... 10 

3.2 Evaluation and Findings for Alternative B ............................................................................... 11 

3.2.1 Evaluation of the Effects of Use, Occupancy, or Disposition on Subsistence Uses 

and Needs..................................................................................................................... 13 

3.2.2 Evaluation of the Availability of Other Lands for Land Use Decisions Allowed 

Under Alternative B..................................................................................................... 13 

3.2.3 Evaluation of Other Alternatives that Would Reduce or Eliminate the Use, 

Occupancy, or Disposition of Public Lands Needed for Subsistence Purposes........... 14 

3.2.4 Findings ....................................................................................................................... 14 

3.3 Evaluation and Findings for Alternative C ............................................................................... 15 

3.3.1 Evaluation of the Effects of Use, Occupancy, or Disposition on Subsistence Uses 

and Needs..................................................................................................................... 18 

3.3.2 Evaluation of the Availability of Other Lands for Land Use Decisions Allowed 

Under Alternative C..................................................................................................... 18 

3.3.3 Evaluation of Other Alternatives that Would Reduce or Eliminate the Use, 

Occupancy, or Disposition of Public Lands Needed for Subsistence Purposes........... 19 

3.3.4 Findings ....................................................................................................................... 19 

3.4 Evaluation and Findings for Alternative D ............................................................................... 21 

3.4.1 Evaluation of the Effects of Use, Occupancy, or Disposition on Subsistence Uses 

and Needs..................................................................................................................... 24 

3.4.2 Evaluation of the Availability of Other Lands for Land Use Decisions Allowed 

Under Alternative D..................................................................................................... 24 

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3.4.3 Evaluation of Other Alternatives that Would Reduce or Eliminate the Use, 

Occupancy, or Disposition of Public Lands Needed for Subsistence Purposes........... 25 

3.4.4 Findings ....................................................................................................................... 25 

3.5 Evaluation and Findings for the Cumulative Case.................................................................... 26 

3.5.1 Past, Present and Reasonably Foreseeable Land Use and Activities ........................... 27 

3.6 Evaluation and Findings for the Cumulative Case – Alternative A.......................................... 39 

3.6.1 Evaluation of the Effects of Use, Occupancy, or Disposition on Subsistence Uses 

and Needs..................................................................................................................... 39 

3.6.2 Evaluation of the Availability of Other Lands for Land Use Plan Decisions 

Allowed in the Planning area....................................................................................... 40 

3.6.3 Evaluation of Other Alternatives that would Reduce or Eliminate the Use, 

Occupancy, or Disposition of Public Lands Needed for Subsistence Purposes........... 40 

3.6.4 Findings ....................................................................................................................... 40 

3.7 Evaluation and Findings for the Cumulative Case – Alternative B .......................................... 41 

3.7.1 Evaluation of the Effects of Use, Occupancy, or Disposition on Subsistence Uses 

and Needs..................................................................................................................... 41 

3.7.2 Evaluation of the Availability of Other Lands for Land Use Plan Decisions 

Allowed in the Planning area....................................................................................... 41 

3.7.3 Evaluation of Other Alternatives that would Reduce or Eliminate the Use, 

Occupancy, or Disposition of Public Lands Needed for Subsistence Purposes........... 41 

3.7.4 Findings ....................................................................................................................... 42 

3.8 Evaluation and Findings for the Cumulative Case – Alternative C .......................................... 42 

3.8.1 Evaluation of the Effects of Use, Occupancy, or Disposition on Subsistence Uses 

and Needs..................................................................................................................... 42 

3.8.2 Evaluation of the Availability of Other Lands for Land Use Plan Decisions 

Allowed in the Planning area....................................................................................... 43 

3.8.3 Evaluation of Other Alternatives that would Reduce or Eliminate the Use, 

Occupancy, or Disposition of Public Lands Needed for Subsistence Purposes........... 43 

3.8.4 Findings ....................................................................................................................... 43 

3.9 Evaluation and Findings for the Cumulative Case – Alternative D.......................................... 44 

3.9.1 Evaluation of the Effects of Use, Occupancy, or Disposition on Subsistence Uses 

and Needs..................................................................................................................... 44 

3.9.2 Evaluation of the Availability of Other Lands for Land Use Plan Decisions 

Allowed in the Planning area....................................................................................... 44 

3.9.3 Evaluation of Other Alternatives that would Reduce or Eliminate the Use, 

Occupancy, or Disposition of Public Lands Needed for Subsistence Purposes........... 44 

3.9.4 Findings ....................................................................................................................... 45 

Section 4 Notice and Hearings ................................................................................................................. 46 

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Appendix O: ANILCA Preliminary Section 810 Evaluation BSWI Draft RMP/EIS 

Section 5 Subsistence Determinations Under ANILCA Sections 810(a)(3)(A), (B), and (C).............. 47 

5.1 Significant Restriction of Subsistence Use is Necessary, Consistent with Sound Management 

Principles for the Utilization of Public Lands........................................................................... 47 

5.2 The Proposed Activity Will Involve the Minimal Amount of Public Lands Necessary to 

Accomplish the Purposes of such Use, Occupancy or Other Disposition ................................ 47 

5.3 Reasonable Steps will be Taken to Minimize Adverse Impacts upon Subsistence Uses and 

Resources Resulting from such Actions. .................................................................................. 47 

Section 6 References.................................................................................................................................. 48 

Tables 

Table 1: High Locatable Mineral Potential in the Planning Area ............................................................... 35 

Appendices 

Appendix O-1: Impact Methodology and Results 

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BSWI Draft RMP/EIS Appendix O: ANILCA Preliminary Section 810 Evaluation 

Acronyms 

ACEC Area of Critical Environmental Concern 

ADF&G Alaska Department of Fish and Game 

ADNR Alaska Department of Natural Resources 

ANCSA Alaska Native Claims Settlement Act 

ANILCA Alaska National Interest Lands Conservation Act 

APDES Alaska Pollutant Discharge Elimination System 

ATV all-terrain vehicle 

BLM Bureau of Land Management 

BMP best management practice 

BSWI Bering Sea–Western Interior 

CFR Code of Federal Regulations 

CFZ Community Focus Zone 

CYRMP Central Yukon Resource Management Plan 

EIS Environmental Impact Statement 

EO Executive Order 

ERMA Extensive Recreation Management Area 

FLPMA Federal Land Policy and Management Act of 1976 

GMU Game Management Unit 

HVW high-value watershed 

IM Instruction Manual 

INHT Iditarod National Historic Trail 

LMP locatable mineral potential 

LUP land use plan 

NEPA National Environmental Protection Act 

NPS National Park Service 

NSO no surface occupancy 

NTMC National Trail Management Corridor 

NWR National Wildlife Refuge 

OHV off-highway vehicle 

RMP Resource Management Plan 

ROW right-of-way 

SOP standard operating procedures 

SRMA Special Recreation Management Area 

SRP special recreation permit 

SSS special status species 

SWMFP Southwest Management Framework Plan 

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Appendix O: ANILCA Preliminary Section 810 Evaluation BSWI Draft RMP/EIS 

TKC The Kuskokwim Corporation 

U.S.C. United States Code 

USFWS United States Fish and Wildlife Service 

UTV utility terrain vehicle 

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Appendix O: ANILCA Preliminary Section 810 Evaluation BSWI Draft RMP/EIS 

Section 1 Introduction 

In 2013, the U.S. Department of the Interior, Bureau of Land Management (BLM), issued a Notice of 

Intent to prepare a Resource Management Plan (RMP) and associated Environmental Impact Statement 

(EIS) for public lands in the Bering Sea–Western Interior (BSWI) Planning Area (planning area). In 

accordance with Alaska National Interest Lands Conservation Act (ANILCA) § 810, the BLM is required 

to conduct an analysis of the effects of this proposed action on subsistence resources associated with the 

planning area. 

In 2018, the BLM Anchorage Field Office prepared the Bering Sea–Western Interior Resource 

Management Plan: Affected Environment Report (Appendix M) and Supplemental Impact Analysis 

Information (Appendix N) to support the Draft RMP/EIS. These appendices provide: 

• Consolidated direction to address land and resource use and development on BLM-managed 

lands in the planning area, and 

• Analysis of the environmental effects that could result from the implementation of the 

alternatives proposed in the Draft BSWI RMP/EIS. 

When final, the BSWI RMP, will replace the current 1981 Southwest Alaska Management Framework 

Plan (SWMFP [BLM 1981]) and a small portion of the 1986 Resource Management Plan and Record of 

Decision for the Central Yukon Planning Area (Central Yukon RMP [CYRMP]) (BLM 1986), including 

amendments. 

In accordance with the Federal Land Policy and Management Act of 1976 (FLPMA) (43 United States 

Code [U.S.C.] 1701 et seq.), resource management planning regulations (43 Code of Federal Regulations 

[CFR] 1610 et seq.), and BLM’s Land Use Planning Handbook, H-1601-1 (BLM 2005), the Draft BSWI 

RMP/EIS provides planning-level guidance for the management of resources and designation of uses on 

all BLM-managed public lands in the planning area and any BLM-managed subsurface estate, including 

the subsurface beneath private surface estate if the subsurface estate was reserved to the BLM. The Draft 

BSWI RMP/EIS was developed in coordination with federal, State, and local governments; tribal 

governments; Alaska Native corporations; and interested members of the public. New management 

direction in the RMP addresses land use issues and conflicts that have emerged since the 1981 SWMFP 

was adopted. 

The FLPMA requires the BLM to “develop, maintain, and, when appropriate, revise land use plans” (43 

U.S.C. 1712 (a)).1 Because the existing SWMFP does not follow the current land use process for the 

development of RMPs, the BLM has decided to replace the 1981 plan with the BSWI RMP/EIS (the first 

RMP for the planning area) rather than revise the 1981 plan. The BLM is also revising the 1986 CYRMP 

for the portions of that planning area that changed under a district boundary realignment and are now in 

the current planning area (Appendix E of the Draft BSWI RMP/EIS). 

The purpose of the Draft BSWI RMP/EIS is to document decisions that will guide future land 

management actions and subsequent site-specific implementation decisions. The decisions will establish 

goals and objectives for resource management (desired outcomes) and the identified uses (allocations) 

that are allowable, restricted, or prohibited in order to achieve the goals and objectives. Management 

1 For purposes of BLM planning, “land use plan” is synonymous with RMP. 

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BSWI Draft RMP/EIS Appendix O: ANILCA Preliminary Section 810 Evaluation 

actions are also identified where they can help achieve desired outcomes and include measures or criteria 

that may guide day-to-day as well as long-term management. Such management actions could include 

protection and restoration opportunities; administrative designations such as Areas of Critical 

Environmental Concern (ACECs); proposed withdrawals, disposals, exchanges, acquisitions; and 

suitability for congressional designations. All decisions are pursuant to the multiple-use and sustained 

yield mandate of FLPMA. 

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Appendix O: ANILCA Preliminary Section 810 Evaluation BSWI Draft RMP/EIS 

Section 2 Subsistence Evaluation Factors under ANILCA Section 

810(a) 

ANILCA § 810(a) requires an evaluation of the effects on subsistence uses of any federal determination 

to “withdraw, reserve, lease, or otherwise permit the use, occupancy or disposition of public lands.” As 

such, an evaluation of the potential impacts to subsistence under ANILCA § 810(a), must be evaluated for 

the BSWI RMP. ANILCA § 810(a) (16 U.S.C. 3120) requires that the evaluation include findings on the 

following three issues: 

• Effect of use, occupancy, or disposition on subsistence uses and needs. 

• Availability of other lands for the purpose sought to be achieved. 

• Other alternatives that would reduce or eliminate the use, occupancy, or disposition of public 

lands needed for subsistence purposes. 

The evaluation and findings required by ANILCA § 810(a) are set out for each of the four alternatives 

considered in the Draft BSWI RMP/EIS. The four alternatives are as follows: 

• Alternative A (No Action): This alternative represents existing management mandated by current 

land use plans for the planning area and provides the baseline against which to compare the other 

alternatives. 

• Alternative B: This alternative emphasizes reducing the potential for competition between 

recreational or developmental uses and subsistence resources by compartmentalizing key areas 

for additional protections of long-term resource values within the planning area. 

• Alternative C: This alternative emphasizes adaptive management at the planning level to protect 

the long-term sustainability of resources while providing for multiple resource uses. 

• Alternative D: This alternative provides additional flexibility at the project-specific 

implementation level and fewer overarching management restrictions at the planning level. 

2.1 Determinations 

Pursuant to ANILCA § 810, a finding that the proposed action may significantly restrict subsistence uses 

imposes additional requirements, including provisions for notices to the State of Alaska and appropriate 

regional and local subsistence committees, a hearing in the vicinity of the area involved, and the making 

of the following determinations, as required by ANILCA § 810(a)(3) prior to approving the proposed land 

use: 

Such a significant restriction of subsistence uses is necessary, consistent with sound 

management principles for the utilization of the public lands; 

The proposed activity will involve the minimal amount of public lands necessary to 

accomplish the purpose of the use, occupancy, or other disposition; and, 

Reasonable steps will be taken to minimize adverse effects upon subsistence uses and 

resources resulting from such actions. 

If there is no positive finding (i.e., no significant restrictions to subsistence uses are expected to occur), 

then the ANILCA § 810(a)(3) determinations are not required. 

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BSWI Draft RMP/EIS Appendix O: ANILCA Preliminary Section 810 Evaluation 

To determine if a significant restriction of subsistence uses and needs may result from any one of the 

alternatives discussed in the Draft BSWI RMP/EIS, including their cumulative effects, the following 

factors in particular are considered in accordance with BLM Instruction Manual (IM) 2011-008 (BLM 

2010): 

Abundance: The reduction in the availability of subsistence resources caused by a 

decline in the population or abundance of harvestable resources. This may include fish, 

wildlife, edible plants, house logs, firewood or drinking water, for example. Forces that 

might cause a reduction in abundance include adverse impacts on habitat, direct impacts 

on the resource, increased harvest, and increased competition from non-subsistence 

users. 

Availability: Reductions in the availability of resources used for subsistence purposes 

caused by alteration of their distribution, migration patterns, or location, and 

Access: Limitations on access to subsistence resources, including from increased 

competition for the resources, including physical and legal barriers. 

2.2 Findings 

The IM 2011-008 policy states that the ANILCA § 810 evaluation shall conclude with a distinct finding 

that the proposed action and alternatives either may or will not significantly restrict subsistence uses for 

identified subsistence communities or groups (BLM 2010). 

A finding of “may significantly restrict” requires either (1) that the process be stopped for the action and 

the action prohibited; or (2) that the agency proceed to the notice and hearings step described below. A 

finding of “no significant restriction” concludes the ANILCA § 810 process. 

A proposed action and/or alternatives would be considered to significantly restrict subsistence uses if, 

after consideration of any stipulations or protection measures included as a part of each alternative, that 

action or alternative can be expected to result in a substantial reduction in the opportunity to continue 

subsistence uses of renewable resources. Substantial reductions in the opportunity to continue subsistence 

uses generally are caused by large reductions in the abundance, or a major redistribution of resources; 

extensive interference with access; or, major increases in the use of those resources by non-local users 

(BLM 2010). A proposed action and/or alternatives may be found to “not create a significant restriction,” 

but it may be appropriate for the analyst to identify and attempt to mitigate localized, individual 

restrictions created by an action. 

According to IM 2011-008, the Findings shall be stated as either: 

• This evaluation concludes that the action will not result in a significant reduction in subsistence 

uses; or 

• This evaluation concludes that the action may result in a significant restriction to subsistence uses 

for the communities of ______________________ due to (specify causes). 

The first Finding, above, is frequently referred to as a “Negative Finding,” in that no significant 

restrictions are expected to occur. Likewise, the second Finding is commonly referred to as a “Positive 

Finding,” in that significant restriction may be expected to occur. 

In some cases, individual alternatives will fall below the “may significantly restrict” threshold, and only 

the cumulative case exceeds the threshold. Note that the cumulative effects analysis is not, in and of itself, 

4 
 

 

Appendix O: ANILCA Preliminary Section 810 Evaluation BSWI Draft RMP/EIS 

a proposed action. Instead, the purpose of the cumulative effects analysis is to determine the effects of the 

proposed action and alternatives together with other past, present, and reasonably foreseeable future 

actions. In this way, a finding of “may significantly restrict” subsistence uses in the cumulative case is, in 

effect, a Positive Finding, even though the finding is only noted under the cumulative case. A Positive 

Finding in the cumulative case triggers the Notice, Hearing, and Determination requirements of ANILCA 

§ 810(a). 

Chapter 3, Affected Environment and Environmental Consequences, of the Draft BSWI RMP/EIS, and 

Appendix M provide information on areas and resources important for subsistence use and the degree of 

dependence of affected villages or communities on different subsistence populations. Chapter 3 and 

Appendix N provide much of the data on potential impacts and levels of reduction and limitations under 

each alternative, which were used to determine whether the action would cause a significant restriction to 

subsistence uses. Appendix N also lists the methodology and assumptions used in the analysis. The 

information in the Draft BSWI RMP/EIS and Appendices N and O are the primary data used in the 

analysis that is presented in this report. 

A subsistence evaluation and findings under ANILCA § 810 must also include a cumulative impacts 

analysis. The following section begins with evaluations and findings for each of the four alternatives 

discussed in the BSWI RMP/EIS. The cumulative case, as discussed in Chapter 3, Affected Environment 

and Environmental Consequences, of the Draft BSWI RMP/EIS, is evaluated. This approach will help the 

reader separate the subsistence restrictions that could result from activities proposed under the four 

alternatives from those that could be caused by past, present, and future activities that could occur, or 

have already occurred, in the surrounding area. 

Environmental Justice 

In addition to ANILCA, Executive Order (EO) 12898, Environmental Justice for Low Income & Minority 

Populations, calls for an analysis of the effects of federal actions on minority populations with regard to 

subsistence. Environmental Justice is defined as: 

The fair treatment and meaningful involvement of all people regardless of race, color, 

national origin, or income with respect to the development, implementation, and 

enforcement of environmental laws, regulations, and policies (U.S. Environmental 

Protection Agency). 

Fair treatment is defined as: 

The principle that no group of people, including racial, ethnic, or socioeconomic groups 

should bear a disproportionate share of the negative environmental consequences 

resulting from industrial, municipal, and commercial operations or the execution of 

federal, state, local, and Tribal programs and policies (U.S. Environmental Protection 

Agency). 

Section 4-4 of EO 12898, Subsistence Consumption of Fish and Wildlife, requires federal agencies to 

collect, maintain, and analyze information on the consumption patterns of populations that principally 

rely on fish and/or wildlife for subsistence. The EO also requires federal agencies to communicate to the 

public any risks associated with the consumption patterns from activities they are proposing. The 

following were reviewed and found to comply with EO 12898: 

• Description of subsistence use in Chapter 3, Affected Environment and Environmental 

Consequences, of the Draft BSWI RMP/EIS and Appendix M. 

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BSWI Draft RMP/EIS Appendix O: ANILCA Preliminary Section 810 Evaluation 

• Subsistence analyses of the alternatives in Chapter 3, Affected Environment and Environmental 

Consequences, of the Draft BSWI RMP/EIS and Appendix N. 

6 
Appendix O: ANILCA Preliminary Section 810 Evaluation BSWI Draft RMP/EIS 

Section 3 Evaluations and Findings for All Alternatives and the 

Cumulative Case 

The ANILCA § 810 evaluations in this section are based on information related to the environmental 

and subsistence consequences of Alternatives A through D and the cumulative impacts analysis as 

presented in Chapter 3, Affected Environment and Environmental Consequences, of the Draft BSWI 

RMP/EIS. The standard operating procedures (SOPs) and best management practices (BMPs) are 

discussed in Appendix K of the Draft BSWI RMP/EIS and were also considered for the alternatives to 

which they apply. The evaluations and findings focus on potential impacts to the subsistence resources 

themselves as well as access to resources and economic and cultural issues that relate to subsistence. 

The action alternatives (Alternatives B, C, and D), and the leasing stipulations and SOPs that accompany 

them, take into consideration comments and concerns generated during the scoping and alternative 

scoping process for the Draft BSWI RMP/EIS, including consultation with federally recognized tribal 

governments. 

3.1 Evaluation and Findings for Alternative A (No Action Alternative) 

This section provides an overview of impacts for the planning area. A detailed community by community 

analysis is provided in Appendix A. 

Alternative A represents the existing management mandated by current land use plans for the planning 

area. Alternative A meets the National Environmental Policy Act (NEPA) (42 U.S.C. 4321 et seq.) 

requirement in 40 CFR 1502.14 that the BLM consider a No Action alternative and provides the baseline 

against which to compare the other alternatives. This alternative would continue the present management 

direction and practices based on existing land use plans (LUPs) and LUP amendments, SOPs, and BMPs. 

Direction in existing laws, regulations, policies, and standards would also continue to be implemented, 

sometimes superseding provisions of the 1981 SWMFP (BLM 1981) and the 1986 CYRMP (BLM 1986) 

and subsequent amendments. The current levels, methods, and mix of multiple use management of BLMmanaged lands in the planning area would continue, and resource values would continue to receive 

attention at present levels. 

Alternative A would not designate any high-value watersheds (HVWs); therefore, the amount of fisheries 

resources protected as HVWs would be less than under Alternative B or C. 

Under Alternative A, no acres of land would be protected by vegetation regulations, and there would be 

no formal program for controlling invasive weeds. Existing conditions would continue under 

Alternative A in terms of the availability, abundance and access to these resources for subsistence users. 

BLM would consider impacts to wildlife used as subsistence resources when evaluating actions in the 

planning area that could affect the abundance and availability of subsistence resources and would 

implement mitigation as needed on a case-by-case basis. Under Alternative A, the BLM would consider 

caribou and moose in its management of resource uses although no specific management actions are 

identified. Alternative A could have a long-term impact on migration and species movement if future 

development occurs in areas where it would fragment species ranges and reduce habitat connectivity. 

Existing conditions would continue under Alternative A in terms of the availability, abundance and access 

to these resources for subsistence users. 

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BSWI Draft RMP/EIS Appendix O: ANILCA Preliminary Section 810 Evaluation 

Alternative A would continue to include closures and protective stipulations that would provide 

protections to fish, wildlife, and special status species (SSS) in the planning area. A total of 5,202,221 

acres (39 percent) of the planning area would be closed to leasing, and 17,521 acres (less than 1 percent) 

of the planning area would be designated as no surface occupancy (NSO) leasable. Overall, the area of 

wildlife habitat covered by management, reducing impacts to wildlife from impacts associated with 

leasable minerals, would be less than under the action alternatives, although the area of land completely 

closed to leasing would be greater than under the action alternatives. Existing conditions would continue 

under Alternative A in terms of the availability, abundance, and access to these resources for subsistence 

users. 

Under Alternative A, 4,804,488 acres (36 percent) of the planning area would continue to be withdrawn 

from locatable minerals and closed to salable minerals, including withdrawals to protect wildlife habitat 

and other resource values that are important to subsistence. Under Alternative A, 8,661,406 acres (64 

percent of BLM-managed land in the planning area) would continue to be open to locatable and salable 

mineral development with 294,325 acres open in areas of medium or high locatable mineral potential 

(LMP). Of these mineral decisions, areas open to locatable mineral development are most likely to affect 

subsistence resources because there are areas of medium and high LMP in the planning area. Locatable 

mineral development could affect abundance and availability of subsistence resources by impacting 

habitat and causing wildlife populations to migrate out of the area, most notably to fishing resources 

within the planning area. Fish (including salmon, trout, and whitefish) are some of the most heavily 

harvested resources for the communities within the planning area. If areas open to locatable mineral 

development that have a medium and high LMP are located upstream or alongside known fishing 

locations, the abundance and availability of these fish species could be negatively impacted. These 

impacts may be caused by habitat degradation from mining exploration and operational activities (e.g., 

the release of chemicals from mining activities and increased particulates in the water due to soil 

disturbance) but also from the potential for increased competition for fishing resources due to the influx 

of workers for the mining activities. Communities within the planning area rely heavily on fish (and 

salmon in particular) to support their subsistence needs. Salmon populations have been declining sharply 

within the Kuskokwim and Yukon River watersheds (Ikuta 2014), increasing the importance of nonsalmon species for subsistence. With the heavy reliance on fish harvesting to supply the subsistence needs 

for the planning area communities, areas open to locatable mineral development and that have medium or 

high LMP may threaten the abundance or availability of fish in the planning area. Important wildlife 

habitat areas that could be affected are further described in Appendix N of the Draft BSWI RMP/EIS. 

Under Alternative A, all BLM-managed land within the planning area would be open to right-of-way 

(ROW) decisions on a case-by-case basis. Alternative A could result in wildlife and subsistence habitat 

fragmentation and degradation because there would be no designated ROW exclusion or avoidance areas. 

Areas open to ROWs on a case-by-case basis with the greatest potential for habitat loss, degradation, and 

fragmentation from development of ROWs would include habitats that are important for the availability 

of subsistence resources, including moose, caribou, and fish species important to communities within the 

planning area. 

All existing Alaska Native Claims Settlement Act (ANCSA) 17(d)(1) (43 U.S.C. 1616(d)(1)) withdrawals 

would remain in place, affecting 13,461,531 acres (> 99 percent) of the planning area. Alternative A does 

not provide additional management guidance for lands and realty that would affect fish, wildlife, or SSS 

used as subsistence resources or their indicators. Existing conditions would continue. Under the 

continuation of current management, there would be a potential for user conflicts, especially in popular 

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Appendix O: ANILCA Preliminary Section 810 Evaluation BSWI Draft RMP/EIS 

recreational areas, such as along the Iditarod National Historic Trail (INHT) and Unalakleet Wild River 

Corridor. Due to an increase in vehicle technology, there would be more frequent and intense impacts 

between subsistence and non-local users. The impacts would be greatest during the summer when 

subsistence activities may be concentrated. The BLM would not designate Recreation Management Areas 

or manage for specific desired outcomes or setting characteristics. In general, management would support 

dispersed and unstructured recreational opportunities throughout the entire planning area. Continuing to 

issue special recreation permits (SRPs) on a case-by-case basis would allow outfitters (commercial 

operators that provide hands-on hunting assistance and guide services) to accommodate demand for 

guided hunting and fishing (which can conflict with subsistence activities and compete for resources), 

special events on the INHT, and other specially permitted activities. No current management decisions 

pertain to the operation of shuttle services in the planning area under Alternative A. Over time, an 

expanding number and size of SRP activities could increase the potential for conflicts with subsistence 

users and damage natural resources that contribute to the recreational setting for all users. These impacts 

to subsistence that could impact the abundance and availability of harvestable resources would be greatest 

in areas of high recreational use, such as along the INHT. 

All lands in the planning area are managed as undesignated for travel and transportation management, 

which allows full access to the planning area for subsistence uses. Traditional means of access such as 

outboard motorboats, airplanes, dogsleds, and snowmobiles are allowed for all river users. Other means of 

access, such as inboard jet boats, airboats, hovercraft, and all-terrain vehicles (ATVs) are not allowed in 

the Unalakleet Wild River Corridor. Off-highway vehicle (OHV) use could result in loss or degradation 

of subsistence resource habitat from physical disturbance and could fragment habitat if new trails were 

created. OHV use could also create additional access for activities that compete for subsistence resources, 

such as sport hunting and fishing. Due to the lack of management direction on OHV use, the route 

network would continue to expand which would adversely affect subsistence resources if there is a 

reduction in the abundance and availability of harvestable resources because of increased access and/or 

competition from non-local hunters. The harvesting of large land mammals (including, most notably, 

moose and caribou) is one of the most important subsistence activities for most of the communities in the 

planning area (based on weight of harvested resources per year). The moose populations throughout the 

planning area have experienced some decreases within the past couple decades, especially in Game 

Management Units (GMUs) 18, 19, and 21 (Ikuta 2014). The BLM has used various management actions 

to try to boost the moose populations in the GMUs within the planning area. Similarly, threats to caribou 

populations have also resulted in the Mulchatna caribou herd (the predominant herd in the planning area) 

being heavily managed in an attempt to increase its population. Undesignated OHV use within the 

planning area may bring increased competition for moose and caribou harvest and may also degrade the 

habitat to a degree that the abundance and availability of these resources will be impacted. 

3.1.1 Evaluation of the Effect of Use, Occupancy, or Disposition on Subsistence Uses and 

Needs 

Under Alternative A, there would be no reduction in the availability of harvestable resource area that is 

used for subsistence, and existing conditions as described in the Draft BSWI RMP/EIS would continue. 

Alternative A would continue to include closures and protective stipulations in certain areas that would 

provide protections to fish, wildlife, and SSS in the planning area. A total of 5,202,221 acres (39 percent) 

of the planning area would be closed to leasing, and 17,521 acres (less than 1 percent) of the planning 

area would be designated as NSO leasable. There would be no limitations on the access of subsistence 

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users to resources. However, harvest, conflict, and competition from non-local users could all increase 

which could reduce the abundance and availability of the resources for subsistence users. Continuing to 

issue SRPs on a case-by-case basis would allow outfitters to accommodate demand for guided hunting 

and fishing, special events on the INHT, and other specially permitted activities. Over time, an expanding 

number and size of SRP activities, particularly during the summer, would increase the potential for these 

activities to conflict with subsistence users and damage natural resources that contribute to the 

recreational setting for all users. 

3.1.2 Evaluation of the Availability of Other Lands for Land Use Decisions Allowed 

under Alternative A 

Under Alternative A, the management of the BLM-managed lands in the planning area would continue 

under the 1981 SWMFP (BLM 1981) and a small portion of the 1986 CYRMP (BLM 1986), including 

amendments. Subsurface estate within U. S. Fish and Wildlife Service (USFWS) lands is managed by the 

BLM under the Mineral Leasing Act of 1920. ANILCA § 304(c) is addressed in the Mineral Occurrence 

and Development Potential Report for Leasable Minerals within the Bering Sea – Western Interior 

Planning Area (BLM 2015) and would be addressed on a case-by-case basis and would not be subject to 

the Draft BSWI RMP/EIS. Similarly, any prior existing mining claims administered by the BLM existing 

within USFWS or National Park Service (NPS) lands would be addressed on a case-by-case basis and 

would not be covered by the Draft BSWI RMP/EIS. Other BLM-managed lands in the state already have 

land use planning documents in place or are being addressed by separate planning processes. State, Native 

corporation lands, Native allotments, and private lands cannot be considered in a BLM plan, and under 

BLM policy, other BLM lands outside Alaska are not considered under ANILCA. 

3.1.3 Evaluation of Other Alternatives that would Reduce or Eliminate the Use, 

Occupancy, or Disposition of Public Lands Needed for Subsistence Purposes 

The proposed action and/or alternatives are to occur on lands needed for subsistence purposes. For the 

BSWI RMP, the planning area is by definition the focus, not other areas. Areas outside of the planning 

area are not subject to the planning process and are outside the scope of the planning process and 

therefore would not be considered under this analysis. Alternatives that would reduce or eliminate the use 

of public lands needed for subsistence include Alternatives B, C, and D, which are analyzed in Chapters 2 

and 3 of the Draft BSWI RMP/EIS. These alternatives were created to represent a wide range of potential 

activities that could occur on BLM-managed lands, along with management actions that would serve to 

protect specific resource values following current national guidelines. Additional alternatives that were 

considered but not analyzed in detail are also discussed in Chapter 2 of the Draft BSWI RMP/EIS. 

3.1.4 Findings 

Management actions that are seen as having the most potential to significantly restrict abundance, 

availability, or access of subsistence resources are: 

• Areas open to locatable mineral development (in areas of high and medium LMP) in known 

subsistence use areas; 

• OHV closures to subsistence use areas; and 

• ROW exclusion or avoidance areas in subsistence use areas. 

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Appendix O: ANILCA Preliminary Section 810 Evaluation BSWI Draft RMP/EIS 

Appendix A provides detail on the methods and analysis used to determine the communities that may 

have a significant restriction to subsistence uses. Alternative A may result in a significant restriction to 

subsistence uses for the communities of Aniak, Anvik, Bethel, Crooked Creek, Chuathbaluk, Grayling, 

Holy Cross, Kaltag, Lime Village, Lower Kalskag, Upper Kalskag, Marshall, McGrath, Nikolai, Nulato, 

Russian Mission, Shageluk, Sleetmute, Stony River, and Unalakleet. 

Locatable mineral decisions would impact the abundance and availability of fishing resources for the 

communities of Lower Kalskag and Upper Kalskag. OHV use would impact the abundance and 

availability of moose and caribou in all of the communities in the planning area. ROW decisions would 

impact the availability of subsistence resources (moose and caribou) for all of the communities in the 

planning area. Appendix A provides a detailed analysis by community that supports these findings. 

Under Alternative A, the BLM would continue to follow all laws, regulations, and policies that pertain 

predominantly to subsistence resources. The BLM would consider impacts to subsistence resources when 

evaluating actions in the planning area that could affect subsistence resources and would implement 

BMPs and mitigation as needed on a case-by-case basis. Under Alternative A, the BLM would also work 

with the Alaska Department of Fish and Game (ADF&G) to monitor caribou and moose populations in 

the planning area and make management recommendations to the Federal Subsistence Board. The Federal 

Subsistence Board would determine whether to take management action based on results of caribou and 

moose populations. 

3.2 Evaluation and Findings for Alternative B 

This section provides an overview of impacts for the planning area. A detailed community by community 

analysis is provided in Appendix A. 

Alternative B emphasizes reducing the potential for competition between recreational and subsistence 

users by compartmentalizing key areas for additional protections of long-term resource values in the 

planning area. These areas include ACECs, lands managed for wilderness characteristics, the INHT 

segments on BLM-managed public lands and associated sites (e.g., Rohn Site, Kaltag Portage, Farewell 

Burn), and identified HVWs. This alternative seeks to support subsistence uses through sustainable 

management of the resources on which subsistence depends and by attempting to reduce competition for 

these resources in key areas surrounding rural communities by applying Community Focus Zones (CFZs) 

to a 10-mile buffer around BSWI communities (818,935 acres). SRPs would not be authorized in CFZs 

for hunting guide/outfitters, although shuttle service operations would be allowed with a required SRP 

throughout the entire Extensive Recreation Management Area (ERMA) (including CFZs). This alternative 

also provides clear guidance on the requirements for subsequent site-specific management and projects, 

which ensures consistency but limits flexibility at the site-specific implementation level. 

Alternative B would decrease the proportion of the planning area currently open to locatable, salable, and 

locatable mineral development. Of these mineral decisions, areas open to locatable mineral development 

are most likely to affect subsistence resources because there are areas of medium and high LMP in the 

planning area. Alternative B would decrease the amount of land open to locatable mineral development 

compared to Alternative A, with 3,623,397 acres open to locatable mineral development and 202,610 

acres open in areas of medium or high LMP. Locatable mineral development could affect abundance of 

subsistence resources by impacting habitat, removing resources (such as trees, plants, and berries), and 

causing wildlife populations to migrate out of the area. The total area of land open to mineral 

development would decrease compared to Alternative A. Fish, including salmon and non-salmon 

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BSWI Draft RMP/EIS Appendix O: ANILCA Preliminary Section 810 Evaluation 

(sheefish, whitefish, and trout) and large land mammals (including moose and caribou) are some of the 

most heavily harvested resources for the communities within the planning area. If areas open to locatable 

mineral development that have a medium and high LMP are located upstream or alongside known fishing 

locations or within the calving areas or travel routes of the Mulchatna caribou herd, the abundance and 

availability of these species could be negatively impacted. These impacts may be caused by habitat 

degradation or fragmentation from mining exploration and operational activities (e.g., the release of 

chemicals from mining activities and increased particulates in the water due to soil disturbance), but also 

from the increased competition for fishing and hunting/trapping resources due to the influx of workers for 

the mining activities. Communities within the planning area rely heavily on fish (and salmon in 

particular), moose, and caribou to support their subsistence needs. With the heavy reliance on fish, moose, 

and caribou harvesting to supply the subsistence needs for the planning area communities, areas open to 

locatable mineral development in areas of medium or high LMP may threaten the abundance or 

availability of fish, moose, and caribou in the planning area. 

Identification of ROW exclusion and avoidance areas under Alternative B would help minimize habitat 

fragmentation and degradation in these areas but could affect access for subsistence users to resources. 

While restrictions on where trapping/subsistence cabins could occur would reduce impacts on fish, 

wildlife, and subsistence locations, they would provide a minimal benefit to those resources but could 

also restrict access to traditional subsistence use of cabins. However, areas open to ROW location could 

cause habitat degradation and fragmentation and increase competition for resources if those ROWs were 

used to build structures, utilities, or transportation corridors. This may impact moose, caribou, and fish 

(particularly salmon, but also non-salmon fish including sheefish, whitefish, and trout) resources as these 

resources are typically the most heavily harvested resources in the planning area communities. 

Under Alternative B 8,530,066 acres of existing ANCSA 17(d)(1) withdrawals would be retained and 

342,360 acres (3 percent) of the planning area would be available for exchange, which could reduce the 

total amount of wildlife habitat under BLM management. Lands available for exchange and acquisitions 

under Alternative B would affect important wildlife habitat and subsistence in the planning area such as 

changes in riparian area, moose calving and wintering areas, caribou crucial winter habitat, and the 

Innoko Bottoms Priority Wildlife Habitat Area. These potential reductions could be offset by lands 

available for acquisitions, which would include a smaller geographic extent of riparian areas and moose 

calving and wintering areas and no caribou crucial winter habitat, but a greater extent of the Innoko 

Bottoms Priority Wildlife Habitat Area. If all exchanges and acquisitions are carried out on lands 

identified as available for those actions, the amount of high-value wildlife habitat associated with 

important wildlife habitat in the planning area would be less than under Alternative A, with associated 

effects on the reduction in the abundance of subsistence resources and access to the resources. BLM 

management actions to protect wildlife habitat would no longer be implemented on those lands. These 

actions would not affect fish, wildlife, and SSS habitat important to subsistence in lands with wilderness 

characteristics being managed as a priority, ACECs, or connectivity corridors. 

Under Alternative B, a total of 5,017,161 acres (37 percent of the planning area) would be permitted for 

commercial woodland harvest. Under this alternative, in personal use and subsistence woodland harvest 

areas, house log harvesting would not be allowed within the riparian zone of perennial streams. Gathering 

of forest firewood in excess of that required for personal or household use would require a permit. A pilot 

project would be instituted to hire a local in a targeted area to issues permits and collect use information 

and/or include maps or questions in local subsistence surveys. This would apply to all BLM-managed 

public lands within 15 miles of a river area that are open for subsistence and personal use woodland 

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Appendix O: ANILCA Preliminary Section 810 Evaluation BSWI Draft RMP/EIS 

harvest; all areas within 25 miles of a community that are open for subsistence and personal use woodland 

harvest; and all burned areas outside of the areas above that are open for subsistence and personal use 

woodland harvest. This alternative would also include additional restrictions that would reduce impacts to 

fish, wildlife, and SSS habitat in HVWs, the INHT National Trail Management Corridor (NTMC), 

ACECs, and riparian areas, with a total of 8,418,904 (63 percent of the planning area) closed to 

commercial woodland harvest, and permits required for commercial harvest on a case-by-case basis on 

29,829 acres (less than 1 percent of the planning area; see Chapter 2 of the Draft BWSI RMP/EIS). 

Permits would be granted outside these areas on a case-by-case basis dependent on resource concerns. 

These permits would include required stipulations to minimize harvesting impacts. Under Alternative B, 

cutting or otherwise disturbing trees used for trapping would be prohibited. 

Subsistence cross-country summer OHV access would be prohibited on 241,512 acres (2 percent of 

BLM-managed land in the planning area) and limited to existing roads and trails on 324,443 acres (2 

percent of BLM-managed land in the planning area). The remaining acres within the planning area would 

be open for OHV cross-country access for subsistence. While OHV prohibitions and restrictions on casual 

use would help to preserve the subsistence resources in the planning area by minimizing habitat 

fragmentation and degradation, some access restrictions for subsistence uses would impact the planning 

area communities. OHV restriction and prohibitions extending to subsistence OHV use would limit 

access to moose, caribou, and fishing subsistence areas for several of the communities. While these access 

restrictions are fairly limited in scope, they do impact some of the most heavily harvested resources for 

the planning area communities. 

3.2.1 Evaluation of the Effects of Use, Occupancy, or Disposition on Subsistence Uses and 

Needs 

Alternative B would reduce the potential impacts on subsistence use as a result of management actions or 

designations within the planning area. Several of the proposed actions under this alternative would 

positively impact subsistence because management decisions and actions would provide for fish and 

wildlife habitat and in turn provide subsistence resource protections. Management decisions and actions 

such as ACECs, lands managed for wilderness characteristics, the INHT segments located on BLMmanaged public lands and associated sites (e.g., Rohn Site, Kaltag Portage, Farewell Burn), and identified 

HVWs would not limit or impose any restriction on subsistence. Alternative B would decrease the 

proportion of the planning area open to locatable mineral development in areas of medium or high LMP 

to 202,610 acres (2 percent of BLM-managed land in the planning area and 36 percent of medium and 

high LMP areas). Lands available for exchange and acquisitions under Alternative B could adversely 

affect important wildlife habitat and subsistence in the planning area, with reductions in riparian area, 

moose calving and wintering areas, caribou crucial winter habitat, and the Innoko Bottoms Priority 

Wildlife Habitat Area because BLM management actions to protect wildlife habitat would no longer be 

implemented on these lands. 

3.2.2 Evaluation of the Availability of Other Lands for Land Use Decisions Allowed 

Under Alternative B 

The proposed action and/or alternatives are to occur on lands needed for subsistence purposes. For the 

BSWI RMP, the planning area is by definition the focus, not other areas. Areas outside of the planning 

area are not subject to the planning process and therefore would not be considered under this analysis. 

Under Alternative B, BLM-managed lands in the planning area would be managed to reduce the impacts 

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BSWI Draft RMP/EIS Appendix O: ANILCA Preliminary Section 810 Evaluation 

to species important to subsistence, reduce the potential for competition between recreational and 

subsistence resources, lessen impacts that impeded access to resources by identifying key areas for 

additional protections of long-term resource values within the planning area. Other BLM lands in the state 

already have land use planning documents in place that specify the amounts and types of activities that 

can or cannot occur or are currently being evaluated by separate planning processes. State and Native 

corporation lands cannot be considered in a BLM plan, and under BLM policy, other BLM lands outside 

Alaska are not considered under ANILCA, but activity and land use on adjacent State or Native lands 

would potentially impact BLM subsistence activity and resources in terms of resource abundance, 

distribution, movements, and subsistence user access to said resources. BLM lands may provide support 

infrastructure for access, mineral materials, water resource transportation systems, or other things needed 

for development on adjacent non-BLM lands, which may have impacts to fish and wildlife resources, 

habitats, and subsistence uses. Further evaluation of such developments may be necessary if and when 

they are proposed. Such development would also potentially increase competition for subsistence 

resources from other user groups by providing increased accessibility, which may increase harvest on 

BLM lands and adjacent lands that share subsistence resource populations. 

3.2.3 Evaluation of Other Alternatives that Would Reduce or Eliminate the Use, 

Occupancy, or Disposition of Public Lands Needed for Subsistence Purposes 

Alternatives that would reduce or eliminate the use of public lands needed for subsistence include 

Alternatives C and D, which are presented and analyzed in Chapters 2 and 3 of the Draft BSWI RMP/EIS. 

These alternatives were created to represent a wide range of potential activities that could occur on BLMmanaged lands, along with management actions that would serve to protect specific resource values 

following current national guidelines. Additional alternatives that were considered but not analyzed in 

detail are also discussed in Chapter 2 of the Draft BSWI RMP/EIS. 

3.2.4 Findings 

Management actions that are seen as having the most potential to significantly restrict abundance, 

availability, or access of subsistence resources are: 

• Areas open to locatable mineral development (in areas of high and medium LMP) in known 

subsistence use areas; 

• OHV closures to subsistence use areas; and 

• ROW exclusion or avoidance areas in subsistence use areas. 

Appendix A provides detail on the methods and analysis used to determine the communities that may 

have as significant restriction to subsistence uses. Alternative B may result in a significant restriction to 

subsistence uses for the communities of Aniak, Anvik, Crooked Creek, Chuathbaluk, Grayling, Holy 

Cross, Kaltag, Lime Village, Lower Kalskag, Upper Kalskag, Marshall, McGrath, Nikolai, Shageluk, 

Sleetmute, Stony River, and Unalakleet. Gathering practices of and access to available forestry and 

woodland resources could also be inhibited and substantially reduced if users became deterred from this 

harvest due to the requirements to obtain a permit. 

Locatable mineral decisions would impact the abundance and availability of fishing resources, and moose 

and caribou harvesting, for the communities of Aniak, Crooked Creek, Chuathbaluk, Lower Kalskag, 

McGrath, Sleetmute, and Upper Kalskag. OHV restrictions and prohibitions for subsistence users would 

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Appendix O: ANILCA Preliminary Section 810 Evaluation BSWI Draft RMP/EIS 

impact the access to moose, caribou, and fishing locations in the communities of Anvik, Grayling, Kaltag, 

Lime Village, McGrath, Nikolai, Shageluk, Sleetmute, Stony River, and Unalakleet. ROW decisions 

would impact the availability of subsistence resources (moose, caribou, and fish species) for the 

communities of Aniak, Crooked Creek, Holy Cross, Kaltag, Lime Village, Marshall, McGrath, Nikolai, 

Sleetmute, Unalakleet, and Upper Kalskag. Appendix A provides a detailed analysis by community that 

supports these findings. 

If all available exchanges and acquisitions are carried out, the amount of high-value wildlife habitat 

associated with important wildlife habitat in the planning area would be less than under Alternative A and 

could adversely affect the abundance of subsistence resources if there were reductions in harvest success 

and limitations in access to resources in areas where BLM is no longer managing the land. Available land 

exchanges under Alternative B would affect important wildlife habitat and subsistence in the planning 

area, with reductions in riparian area, moose calving and wintering areas, caribou crucial winter habitat, 

and the Innoko Bottoms Priority Wildlife Habitat Area. These reductions could be offset to some degree 

by lands available for acquisitions, which would include a smaller geographic extent of riparian areas and 

moose calving and wintering areas and no caribou crucial winter habitat but a greater extent of the Innoko 

Bottoms Priority Wildlife Habitat Area. 

Management decisions and actions such as ACECs, lands managed for wilderness characteristics, the 

INHT segments on BLM-managed public lands and associated sites (e.g., Rohn Site, Kaltag Portage, 

Farewell Burn), and identified HVWs that impact subsistence resources would be beneficial, and any 

impacts from the limited development allowed under this alternative would be minimized by BMPs, 

SOPs, and stipulations. 

3.3 Evaluation and Findings for Alternative C 

This section provides an overview of impacts for the planning area. A detailed community by community 

analysis is provided in Appendix A. 

Alternative C emphasizes adaptive management at the planning level to protect the long-term 

sustainability of resources while providing for multiple resource uses. It provides for planning-level 

protections of key areas, such as the portions of the INHT on BLM-managed lands while allowing for 

flexibility in resource use in those areas depending on the monitoring of resource impacts. It emphasizes 

collaboration with and education of permit applicants to address potential competition for use of existing 

resources. This alternative is meant to provide flexibility at the planning level while still providing 

enough direction to make processing of site-specific projects easier and more consistent. 

Alternative C recommends the use of native species for revegetation of disturbed areas but would allow 

nonnative seed and propagules to be considered if applicable for the climatic condition and ecosystem 

function and if native plant species were not available or feasible. The use of nonnative plant species for 

restoration could lead to an adverse effect to subsistence users if reduction of the availability of and 

access to plants traditionally used for subsistence purposes occurred and therefore affected harvest rates 

of traditionally used resources. 

Alternative C would restrict development on BLM-managed land in one connectivity corridor totaling 

576,038 acres (4 percent) of the planning area. Alternative C would only manage one connectivity 

corridor, the South Connectivity Corridor, rather than the two proposed under Alternative B and would 

open the connectivity corridor to locatable and salable minerals. Having one corridor rather than two may 

increase the distance subsistence hunters would have to travel to reach the corridor, making access to 

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BSWI Draft RMP/EIS Appendix O: ANILCA Preliminary Section 810 Evaluation 

available resources more challenging. This in turn may reduce rates of subsistence harvest of wildlife 

species in this area as hunters will have to travel further to be successful. 

Under Alternative C, 13,418,941 acres (99 percent) of the planning area would be open to locatable 

minerals and 6,645,750 acres (49 percent) would be open to salable mineral development, with another 

6,536,635 acres (about 49 percent) open on a case-by-case basis. All areas of medium or high LMP on 

BLM-managed land would be open to locatable mineral development. Areas that would be open to 

locatable and salable mineral development, in areas of medium to high LMP, include important wildlife 

habitat areas that are important in terms of abundance of subsistence resources (Section 3.2.7 of the Draft 

BSWI RMP/EIS). 

Alternative C would open more areas to locatable and salable mineral development than Alternative B, 

including areas of medium or high LMP where likelihood for development and associated impacts is 

highest. While Alternative C would open fewer areas to salable mineral development than Alternative A, 

when considering areas open on a case-by-case basis, it would have the potential to open more areas than 

Alternative A. Since potential for salable mineral development is low in the planning area, and 

Alternative C would open more areas of medium or high LMP to locatable mineral development than 

Alternative A, there would be high magnitude impacts to subsistence resources over a greater geographic 

extent than Alternative A. 

Similar to Alternatives A and B, the potential for a number of new mines and associated infrastructure 

would likely increase, dependent on future demand for minerals, but would not occur in portions of the 

planning area closed to development. This could affect access to resources in some areas for subsistence 

users. Fish, including salmon and non-salmon (sheefish, whitefish, and trout) and large land mammals 

(moose and caribou) are some of the most heavily harvested resources for the communities within the 

planning area. If areas open to locatable mineral development that have a medium and high LMP are 

located upstream or alongside known fishing locations or within the calving areas or travel routes of the 

Mulchatna caribou herd, the abundance and availability of these species could be negatively impacted. 

These impacts may be caused by habitat degradation or fragmentation from mining exploration and 

operational activities (e.g., the release of chemicals from mining activities and increased particulates in 

the water due to soil disturbance) but also from the potential for increased competition for fishing and 

hunting/trapping resources due to the influx of workers for the mining activities. Communities within the 

planning area rely heavily on fish (and salmon in particular), moose, and caribou to support their 

subsistence needs. With the heavy reliance on fish, moose, and caribou harvesting to supply the 

subsistence needs for the planning area communities, areas open to locatable mineral development and 

that have medium or high LMP may threaten the abundance or availability of fish, moose, and caribou in 

the planning area. 

Under Alternative C, the area designated as NSO leasable (6,824,035 acres; 51 percent of the lands 

managed by BLM) and closed to leasing (46,953acres; <1 percent of the lands managed by BLM) would 

be less than under Alternative B, and 6,594,906 acres (49 percent of the lands managed by BLM) would 

be open to leasing with standard stipulations. Therefore, this alternative would be more likely to impact 

wildlife and subsistence resources from mineral leasing than Alternative B. This could affect access to 

resources in some areas for subsistence users. Under Alternative C, within HVWs, BMPs and other 

protective measures would be similar to Alternative B but less restrictive. For example, HVWs would be 

NSO leasable under Alternative C but would be closed to mineral leasing under Alternative B. 

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Appendix O: ANILCA Preliminary Section 810 Evaluation BSWI Draft RMP/EIS 

Alternative C would have a greater risk for habitat fragmentation and degradation than Alternative B 

because there would be no designated ROW exclusion areas. Additionally, a smaller portion of the 

planning area (7,069,494 acres or 52 percent of the lands managed by BLM) would be identified as ROW 

avoidance area and 576,038 acres (about 4 percent of lands managed by BLM) would be ROW avoidance 

for linear realty actions. Areas outside ROW exclusion and avoidance areas with the greatest potential for 

habitat loss, degradation, and fragmentation from development of ROWs include habitats that are 

important to subsistence. The potential increase in wildlife habitat that could affect subsistence in the 

planning area would be identical to that under Alternative B. Based on the amount of land available for 

exchange (356,942 acres or 3 percent of the lands managed by BLM), the amount of fish and wildlife 

habitat under BLM management in the planning area would be slightly reduced compared to 

Alternative B, with greater reductions in riparian areas and moose calving and wintering areas but the 

same amount of caribou crucial winter habitat and Innoko Bottoms Priority Wildlife Habitat Area. Lands 

available for acquisitions that could somewhat offset lands available for disposals would be the same as 

under Alternative B. Therefore, if all available land exchanges and acquisitions are carried out, the 

amount of high-value wildlife habitat in the planning area would be less than under Alternative A or B. 

Overall, Alternative C would have a larger adverse impact on fish, wildlife habitat, and potentially SSS 

habitat that is important to the abundance and availability of subsistence resources than Alternative B. 

Under this alternative, in personal use and subsistence woodland harvest areas, house log harvesting 

would not be allowed within the riparian zone of perennial streams. Gathering of forest firewood and 

forestry products for subsistence would not require a permit. Gathering of more than 10 cords of forest 

firewood per household per year for personal use (defined as allowed use of renewable resources, which 

cannot be sold, bartered, traded or used for profit, by individuals other than federally qualified rural 

residents) and gathering of forestry products for personal use would require a permit for all areas within 

15 miles of a river that are open for subsistence and personal use woodland harvest; all areas within 25 

miles of a community that are open for subsistence and personal use woodland harvest; and all burned 

areas outside of the areas above that are open for subsistence and personal use woodland harvest. Permits 

would be granted outside these areas on a case-by-case basis dependent on resource concerns. Under 

Alternative C cutting or otherwise disturbing trees used for trapping would be prohibited. This may limit 

the success of subsistence individual trapping activities that require these materials. 

Under Alternative C, 13,125,320 acres (97 percent) of the planning area would be managed as an ERMA 

and 340,574 acres (2 percent) of the planning area would be managed as a Special Recreation 

Management Area (SRMA). Impacts under Alternative C would be similar to Alternative B with the 

exception of a slightly smaller SRMA and smaller CFZs. Under Alternative C, CFZs would be applied to 

a 5-mile buffer around BSWI communities (95,307 acres). As with Alternative B, SRPs would not be 

authorized in CFZs for hunting guide/outfitters. These restrictions would not apply to shuttle service 

operations, which would be allowed without an SRP throughout the ERMA unless increase in use 

conflicts with the BSWI ERMA objectives, at which point the BLM would engage in additional planning 

to maintain the objectives. Under Alternative C, casual and subsistence use would be permitted on 

existing routes at the Rohn Site. Winter casual and subsistence access would be allowed for snowmobiles 

only, similar to Alternative B, and impacts from winter travel would be the same as Alternative B. 

Management actions would provide for increased recreation opportunity during summer months, and 

could also result in increased conflicts between recreational, casual and subsistence users. Increased use 

could result in damage to the trail resource, thereby altering recreation setting, opportunity, and 

experience over time. Summer OHV casual use would be limited to existing routes. Subsistence cross17 
 

 

 

BSWI Draft RMP/EIS Appendix O: ANILCA Preliminary Section 810 Evaluation 

country summer OHV access would be prohibited on 225,925 acres (2 percent of BLM-managed land in 

the planning area) and limited to existing roads and trails on 363 acres. The remaining acres within the 

planning area would be open for OHV cross-country access for subsistence. 

Under Alternative C, OHV designation in the Unalakleet Wild River Corridor as casual summer access 

would be limited to existing trails, primitive roads, and roads and would include ATVs only. Subsistence 

cross-country summer OHV access on lands in the Unalakleet Wild River Corridor would be allowed by 

ATV. Recreation access in the summer would provide for increased opportunity for conflict and could 

reduce the availability of resources for harvest by subsistence users. However, due to the wet and boggy 

condition of the area, summer travel is expected to be minimal such that while damage to the lands 

(rutting, braiding) could occur and there could be an increased potential for use conflicts between 

recreationists and subsistence users it would be low in terms of magnitude. Alternative C would be more 

protective of subsistence resource habitat than Alternative A, which does not have any OHV restrictions 

except for within the Unalakleet Wild River Corridor. However, some access restrictions for subsistence 

uses would impact the planning area communities. OHV restriction and prohibitions extending to 

subsistence OHV use would limit access to moose, caribou, and fishing subsistence areas for several of 

the communities. While these access restrictions are fairly limited in scope, they do impact some of the 

most heavily harvested resources for the planning area communities. 

3.3.1 Evaluation of the Effects of Use, Occupancy, or Disposition on Subsistence Uses and 

Needs 

Alternative C would reduce the potential impacts on subsistence use as a result of management actions or 

designations within the planning area. Several of the proposed actions under this alternative would 

positively impact subsistence because management decisions and actions would provide for fish and 

wildlife habitat and in turn provide subsistence resource protections. Management decisions and actions 

such as the INHT segments located on BLM-managed public lands and associated sites (e.g., Rohn Site, 

Kaltag Portage, Farewell Burn) and identified HVWs would not limit or impose any restriction on 

subsistence. 

Alternative C would have a greater proportion of the planning open to locatable mineral development 

than Alternative A and B including areas with medium or high LMP. Lands available for exchange and 

acquisitions under Alternative C would adversely affect important wildlife habitat and abundance and 

access to subsistence resources in the planning area, with reductions in riparian area, moose calving and 

wintering areas, caribou crucial winter habitat, and the Innoko Bottoms Priority Wildlife Habitat Area 

because BLM management actions to protect wildlife habitat would no longer be implemented on these 

lands. 

3.3.2 Evaluation of the Availability of Other Lands for Land Use Decisions Allowed 

Under Alternative C 

The proposed action and/or alternatives are to occur on lands needed for subsistence purposes. For the 

BSWI RMP, the planning area is by definition the focus, not other areas. Areas outside of the planning 

area are not subject to the planning process and are outside the scope of the planning process and 

therefore would not be considered under this analysis. Under Alternative C, BLM-managed lands in the 

planning area would be managed to reduce the impacts to species important to subsistence, reduce the 

potential for competition between recreational and subsistence resources, and lessen impacts that impede 

subsistence access to resources by identifying key areas for additional protections of long-term resource 

18 
Appendix O: ANILCA Preliminary Section 810 Evaluation BSWI Draft RMP/EIS 

values within the planning area. Other BLM lands in the state already have land use planning documents 

in place that specify the amounts and types of activities that can or cannot occur or are currently being 

evaluated by separate planning processes. State and Native corporation lands cannot be considered in a 

BLM plan, and under BLM policy, other BLM lands outside Alaska are not considered under ANILCA. 

However, activity and land use on adjacent State or Native lands would potentially impact BLM 

subsistence activity and resources in terms of resource abundance, distribution, movements, and 

subsistence user access to said resources. BLM lands may provide support infrastructure for access, 

mineral materials, water resources transportation systems, or other things needed for development on 

adjacent non-BLM lands, which may have impacts to fish and wildlife resources, habitat, and subsistence 

uses. Further evaluation of such developments may be necessary if and when proposed. Such 

development would also potentially increase competition for subsistence resources from other user groups 

by providing increased accessibility, which may increase harvest on BLM lands and adjacent lands that 

share subsistence resource populations. 

3.3.3 Evaluation of Other Alternatives that Would Reduce or Eliminate the Use, 

Occupancy, or Disposition of Public Lands Needed for Subsistence Purposes 

Alternatives that would reduce or eliminate the use of public lands needed for subsistence include actions 

in Alternatives B and D that are presented and analyzed in Chapters 2 and 3 of the Draft BSWI RMP/EIS. 

These alternatives were created to represent a wide range of potential activities that could occur on BLMmanaged lands, along with management actions that would serve to protect specific resource values 

following current national guidelines. Additional alternatives that were considered but not analyzed in 

detail are also discussed in Chapter 2 of the Draft BSWI RMP/EIS. 

3.3.4 Findings 

Management actions that are seen as having the most potential to significantly restrict abundance, 

availability, or access of subsistence resources are: 

• Areas open to locatable mineral development (in areas of high and medium LMP) in known 

subsistence use areas; 

• OHV closures to subsistence use areas; and 

• ROW exclusion or avoidance areas in subsistence use areas. 

Appendix A provides detail on the methods and analysis used to determine the communities that may 

have as significant restriction to subsistence uses. 

This evaluation concludes that Alternative C may result in a significant restriction to subsistence uses for 

the communities of Aniak, Anvik, Crooked Creek, Chuathbaluk, Grayling, Holy Cross, Kaltag, Lime 

Village, Lower Kalskag, Upper Kalskag, Marshall, McGrath, Nikolai, Russian Mission, Shageluk, 

Sleetmute, Stony River, and Unalakleet. 

Locatable mineral decisions would impact the abundance and availability of fishing resources, and moose 

and caribou harvesting, for the communities of Aniak, Crooked Creek, Chuathbaluk, Lower Kalskag, 

McGrath, Sleetmute, and Upper Kalskag. OHV restrictions and prohibitions for subsistence users would 

impact the access to moose, caribou, and fishing locations in the communities of Anvik, Grayling, Kaltag, 

Lime Village, Nikolai, Shageluk, Sleetmute, Stony River, and Unalakleet. ROW decisions would impact 

the availability of subsistence resources (moose, caribou, and fish species) for the communities of Aniak, 

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BSWI Draft RMP/EIS Appendix O: ANILCA Preliminary Section 810 Evaluation 

Crooked Creek, Grayling, Holy Cross, Kaltag, Lime Village, Lower Kalskag, Marshall, McGrath, 

Nikolai, Russian Mission, Shageluk, Sleetmute, Stony River, Unalakleet, and Upper Kalskag. Appendix 

A provides a detailed analysis by community that supports these findings. 

In addition to the bullets listed above, the following proposed management under Alternative C would 

also adversely affect subsistence: 

• The use of nonnative plant species for restoration could lead to an adverse effect to subsistence 

users if reduction of the availability of plants traditionally used for subsistence purposes occurred 

and substantially affected harvest rates of traditionally used resources. 

• For caribou and moose, which are important subsistence resources, the management actions 

pertaining to leasable minerals and construction would apply only to calving habitat. Therefore, 

while caribou and moose would be protected during the breeding period, they could be disturbed 

in their crucial winter habitat areas, with disturbances potentially causing increased energy 

expenditures and stresses on wintering populations, which could result in decreased survivorship. 

Decreased survivorship could substantially affect levels of subsistence hunting success in terms 

of abundance of available resources and reduce rates of harvest and sharing. 

• If all available disposals and acquisitions are carried out, the amount of high-value wildlife 

habitat in the planning area would be less than under Alternative A or B. As with Alternative B, 

these actions would not affect fish, wildlife, or SSS habitat important to subsistence in lands with 

wilderness characteristics being managed as a priority or connectivity corridor. Overall, this 

alternative would have a larger adverse negative impact on fish, wildlife habitat, and potentially 

SSS habitat that is important maintaining abundant subsistence resources and provides access to 

resources than Alternative B. 

• Under Alternative C, in addition to subsistence use, casual use would be permitted on existing 

routes at the Rohn Site. Winter casual and subsistence access would be allowed for snowmobiles 

only, similar to Alternative B. This action could result in potential conflict between recreational 

users and casual users and subsistence users and increased competition for resources and 

interference with access to resources that reduces subsistence harvest success. 

• Subsistence cross-country summer OHV access would be allowed by ATV and utility terrain 

vehicle (UTV) (Chapter 2 of the Draft BSWI RMP/EIS). Summer OHV casual use would be 

limited to existing routes (as shown in the BLM’s current route inventory once implementation

planning occurs). Recreational access in the summer could result in impacts to setting through 

damage to the resource (e.g., rutting, braiding) and could increase the potential for use conflicts 

between recreationists and subsistence users including increased competition for resources and 

interference with access to resources that reduces subsistence harvest success. 

• While gathering of forest firewood and forestry products for subsistence would not require a 

permit, gathering of forest firewood of more than 10 cords of firewood per household per year for 

personal use (defined as allowed use of renewable resources, which cannot be sold, bartered, 

traded or used for profit, by individuals other than federally qualified rural residents) and 

gathering of forestry products for personal use would require a permit for all areas within 15 

miles of a river that are open for subsistence and personal use woodland harvest; all areas within 

25 miles of a community that are open for subsistence and personal use woodland harvest; and all 

burned areas outside of the areas above that are open for subsistence and personal use woodland 

20 
 

 

 

 

 

 

Appendix O: ANILCA Preliminary Section 810 Evaluation BSWI Draft RMP/EIS 

harvest. Permits would be granted outside these areas on a case-by-case basis dependent on 

resource concerns. This action could result in increased competition to the resources by non-local 

users (including other federally qualified users) and in a substantial reduction in the opportunity 

to continue subsistence uses of renewable resources. 

Management decisions and actions such as the INHT segments on BLM-managed public lands and 

associated sites (e.g., Rohn Site, Kaltag Portage, Farewell Burn), and identified HVWs that impact 

subsistence resources would be beneficial, and any impacts from the limited development allowed under 

this alternative would be minimized by BMPs, SOPs, and stipulations. 

3.4 Evaluation and Findings for Alternative D 

This section provides an overview of impacts for the planning area. A detailed community by community 

analysis is provided in Appendix A. 

Alternative D provides additional flexibility at the project-specific implementation level and fewer 

overarching management restrictions at the planning level. It also emphasizes lands available for 

exchange or disposal as necessary to consolidate and simplify management. It depends on existing federal 

laws and implementation-level NEPA to a greater degree than the other action alternatives to determine 

how to best manage multiple-use of sensitive resources while preserving long-term sustainability. This 

alternative provides more flexibility at the site-specific implementation level but requires additional work 

to ensure consistency and compliance with management requirements. Impacts from the development 

allowed under this alternative would be minimized to some degree by BMPs, SOPs, and stipulations. 

Alternative D proposes protection of a high resource value of 12,982 river miles (39 percent of river miles 

on BLM-managed lands). As with the other action alternatives, any proposals to develop land, water, or 

resources within the 100-year floodplain of HVWs would be required to demonstrate that the 

development would not diminish quality and diversity of habitats needed for fish and wildlife 

populations, including those used for subsistence. Alternative D would have fewer restrictions on mineral 

development in HVWs than Alternatives B or C because they would be open to mineral leasing subject to 

standard stipulations. Alternative D would provide the least amount of protection for fish and aquatic 

resources and would rely on the operator to characterize the potential of streams for reclamation. 

Additionally, because watershed medium-high and medium resource values would not be protected as 

HVWs as proposed in Alternatives B and C, resources and their availability to subsistence users in these 

areas could degrade due to development activities. They would still be subject the same SOPs and BMPs 

as Alternative B and C that could be implemented by the BLM. 

No protections for SSS flora habitats and lichen areas would be implemented if these areas become 

degraded by OHV use and therefore these areas could be subject to further degradation. Under 

Alternative D, revegetation of disturbed areas would focus on using plant species that are appropriate for 

the climatic condition and ecological function, including nonnative plant species. There could be an 

adverse effect to subsistence users if native plants important for subsistence uses were not considered in 

revegetating areas, limiting the availability and access to these plants for subsistence harvest and use 

compared to Alternatives B and C. However, subsistence users could respond to a decrease in the 

availability of an edible plant by harvesting more of another edible resource but would be limited to a 

small portion of the planning area and would not necessarily coincide with vegetation subsistence harvest 

areas. 

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BSWI Draft RMP/EIS Appendix O: ANILCA Preliminary Section 810 Evaluation 

Alternative D offers fewer restrictions than Alternative A, B or C on construction and mineral 

development, which could interfere with or displace subsistence activities in migratory bird habitat, the 

Innoko Bottoms Priority Wildlife Habitat Area, and in moose and caribou calving and wintering habitat. 

Unlike Alternatives B and C, there would be no restrictions on casual use airboats and hovercraft and 

therefore no reduction in the potential for impacts to waterbirds and other species from associated 

disturbance. Because restrictions and mitigations for migratory birds would be determined on a case-bycase basis, it is difficult to assess the difference as far as impacts to migratory birds relative to other 

alternatives. Alternative D would have a greater effect on the availability of resources to subsistence than 

Alternative A and Alternative D would be less protective than Alternatives B and C. 

Under Alternative D, all acres of medium or high LMP within the planning area would be open to 

locatable minerals development, which is to the same as Alternative C, and substantially less protective 

than Alternative B. Alternative D would close 283,509 acres (2 percent) to salable minerals mineral 

development; however, potential for impacts from salable mineral development is low to due to low 

potential and demand. Alternative D would also result in the lowest proportion of the planning area 

designated as NSO and the greatest proportion designated as open to leasing subject to standard 

stipulations. Based on geographic extent of areas open to locatable salable minerals and leasable minerals, 

this alternative would have a lower potential to reduce impacts to fish, wildlife, and SSS associated with 

mineral development than Alternatives B and C, but a higher potential than Alternative A. Areas that 

would be open to locatable and salable mineral development in areas of medium to high LMP include 

important wildlife habitat areas are described in Draft BSWI RMP/EIS, Section 3.3.3, and Appendix N. 

Fish, including salmon and non-salmon (sheefish, whitefish, and trout) and large land mammals (moose 

and caribou) are some of the most heavily harvested resources for the communities within the planning 

area. If areas open to locatable mineral development that have a medium and high LMP are located 

upstream or alongside known fishing locations or within the calving areas or travel routes of the 

Mulchatna caribou herd, the abundance and availability of these species could be negatively impacted. 

These impacts may be caused by habitat degradation or fragmentation from mining exploration and 

operational activities (e.g., the release of chemicals from mining activities and increased particulates in 

the water due to soil disturbance), but also from the potential for increased competition for fishing and 

hunting/trapping resources due to the influx of workers for the mining activities. Communities within the 

planning area rely heavily on fish (and salmon in particular), moose, and caribou to support their 

subsistence needs. With the heavy reliance on fish, moose, and caribou harvesting to supply the 

subsistence needs for the planning area communities, areas open to locatable mineral development and 

that have medium or high LMP may threaten the abundance or availability of fish, moose, and caribou in 

the planning area. 

Similar to Alternatives A and B, the potential for a number of new mines and associated infrastructure 

would likely increase, dependent on future demand for minerals, but would not occur in portions of the 

planning area closed to development. Under Alternative D surface-disturbing activities or permanent 

structures would be allowed on a case-by-case basis within the 100-year floodplain of perennial and fishbearing streams, if permittees can demonstrate these activities would not substantively impact floodplain 

function. If adverse effects resulted from these actions in displacement and disturbance to the resource, 

then access to resources for subsistence activities in these areas and availability of the harvests could be 

affected. BMPs and reclamation procedures under this alternative would be the same as Alternatives B 

and C. 

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Appendix O: ANILCA Preliminary Section 810 Evaluation BSWI Draft RMP/EIS 

Alternative D would have a greater risk for wildlife and subsistence habitat fragmentation and 

degradation than Alternatives B and C because there would be no designated ROW exclusion areas, and 

the acreage of ROW avoidance areas would be the lowest of all the action alternatives (5,130,927 acres; 

37 percent of the lands managed by BLM). Areas outside of ROW exclusion and avoidance areas with the 

greatest potential for habitat loss, degradation, and fragmentation from development of ROWs would 

include habitats that are important for available subsistence resources. Because the BLM would not 

pursue opportunities to acquire public land under Alternative D, there would be no potential increase in 

wildlife habitat in the planning area. Based on the amount of available land proposed for disposal 

(451,173 acres; 3 percent of the lands managed by BLM), this alternative would result in the greatest 

reduction in the amount of wildlife habitat under BLM management, compared to Alternatives B and C, 

and there would be no acquisitions of these habitats to help offset the losses. The amount of caribou 

crucial winter habitat proposed for exchange or disposal would be the same as Alternatives B and C, but 

with no acquisition of this habitat to help offset the loss. If all available exchanges/disposals and 

acquisitions are carried out, the amount of high-value wildlife in the planning area would be less than 

under Alternatives A, B, and C. The amount of caribou crucial winter habitat would be the same as 

Alternatives B and C, but less than under Alternative A. Overall, Alternative D would have a greater 

adverse impact on fish and wildlife habitat and related availability of subsistence resources than 

Alternatives A, B, and C in terms of the geographic extent of key wildlife habitats important for 

subsistence available for disposal. 

Under this alternative, subsistence use gathering of forest firewood and forestry products and personal use 

gathering of forest firewood would not require a permit. Personal use gathering of forestry products 

would require a permit. Unless otherwise restricted by other resource management actions in this RMP, 

all of the planning area would be available for personal use and subsistence woodland harvest. Under 

Alternative D, cutting or otherwise disturbing trees used for trapping would be prohibited. This may limit 

the success of subsistence individual trapping activities that require these materials to be available in 

order to be used during subsistence trapping activities. 

Under Alternative D, the 13,125,320 acres of the planning area would be managed as ERMA and 340,574 

acres as SRMA, same as Alternative C. Under Alternative D, the BLM would designate the INHT 

SRMA; however, there would be limited additional management beyond that specified in Alternative A to 

limit SRPs or mitigate user conflicts. OHV designation in the Unalakleet Wild River Corridor would be 

limited. Casual and subsistence summer access would be the same as Alternative C; however, travel could 

be by ATV or UTV. Winter access would be the same as under Alternative B. The expanded mode of 

summer travel would provide increased recreation opportunities. However, due to the wet and boggy 

condition of the area, summer travel is expected to be minimal such that while damage to the lands 

(rutting, braiding) could occur and there may be an increase potential for use conflicts between 

recreationists and subsistence users it would be low in terms of magnitude, similar to Alternative C. 

Impacts from winter travel would be identical to Alternative C. There would be no CFZ applied under this 

alternative. Alternative D does not propose SRP limitations for hunting guide-outfitters and 

guide/outfitter business authorizations operating within a radius of any applied CFZ in the planning area 

and allows shuttle service operations throughout the planning area without an SRP. However, if the 

ERMA objectives are not being met, BLM would increase monitoring, outreach, education, and/or 

enforcement, case-by-case. Therefore, this alternative would be less protective in terms of preventing 

increased competition for available resources between subsistence users and non-local users than existing 

conditions under Alternatives A, and the buffer zones provided under Alternatives B and C. 

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BSWI Draft RMP/EIS Appendix O: ANILCA Preliminary Section 810 Evaluation 

Alternative D would not prohibit casual use airboats or hovercraft on non-navigable waterways on BLMmanaged land. Alternatives B and C include additional travel management for caribou habitat and the 

Innoko Bottoms Priority Wildlife Habitat Area, reducing disturbance impacts to wildlife and subsistence. 

Alternative D does not include this travel management, so disturbance impacts could lead to increase 

potential for use conflicts between recreationists and subsistence users. Alternative D would prohibit 

casual OHV use on about 2 percent of the lands managed by BLM and restrict less than 1 percent to 

existing trails. Subsistence OHV use would be prohibited nowhere within the planning area and limited to 

existing roads and trails in 225,925 acres (2 percent of BLM-managed land in the planning area). 

Therefore, Alternative D would have the least impact on existing access for both casual and subsistence 

use and would only limit OHV use to existing routes in one area (INHT NTMC Travel Management 

Area) thus providing opportunities for network expansion. The harvesting of large land mammals 

(including, most notably, moose and caribou) is one of the most important subsistence activities for most 

of the communities in the planning area (based on weight of harvested resources per year). Unrestricted 

OHV use throughout most of the planning area under Alternative D may bring increased competition for 

moose and caribou harvest and may also degrade the habitat to a degree that the abundance and 

availability of these resources will be impacted. 

3.4.1 Evaluation of the Effects of Use, Occupancy, or Disposition on Subsistence Uses and 

Needs 

Under Alternative D, the impacts to subsistence would be associated with management decisions that 

could result in reduction in the availability of harvest of subsistence resources or limitations to access and 

cause increased competition for subsistence resources between local and nonlocal user groups by acting 

on lands available for disposal. Alternative D would have more land open to locatable mineral 

development in areas of medium or high LMP than Alternative A. There would be no designation of 

ACECs or HVW and fewer restrictions on construction and mineral development, which could interfere 

with or displace subsistence activities in migratory bird habitat, the Innoko Bottoms Priority Wildlife 

Habitat Area, and in moose and caribou calving and wintering habitat. Alternative D does not include the 

management of connectivity corridors. The BLM would not manage connectivity corridors under this 

alternative, which would result in fewer protections for caribou and moose, particularly during the winter 

use period. There would be no restrictions on casual use airboats and hovercraft, which could disturb 

waterbirds and the other subsistence species that are harvested. 

3.4.2 Evaluation of the Availability of Other Lands for Land Use Decisions Allowed 

Under Alternative D 

The proposed action and/or alternatives are to occur on lands needed for subsistence purposes. For the 

BSWI RMP, the planning area is by definition the focus, not other areas. Areas outside of the planning 

area are not subject to the planning process and are outside the scope of the planning process and 

therefore would not be considered under this analysis. Under Alternative D, BLM-managed lands in the 

planning area would be managed to reduce the impacts to species important to subsistence, reduce the 

potential for competition between recreationists and subsistence resources, and lessen impacts that 

impede access to resources by identifying key areas for additional protections of long-term resource 

values within the planning area. Alternative D would manage BLM lands in the planning area in order to 

provide additional flexibility at the project-specific implementation level and fewer overarching 

management restrictions at the planning level. Lands managed by other federal agencies in the planning 

area are managed under NPS or USFWS planning documents, and wide-scale development of these lands 

24 
Appendix O: ANILCA Preliminary Section 810 Evaluation BSWI Draft RMP/EIS 

is limited or disallowed by the mission and goals of these federal lands as conservation system units. 

Additional BLM lands in the state are managed by current planning documents that allow a mixture of 

development and conservation following the BLM multiple-use mission or are currently being evaluated 

through the planning process. State and Native corporation lands cannot be considered in a BLM plan, 

and under BLM policy, other BLM lands outside Alaska are not considered under ANILCA. However, 

activities on adjacent State and Native land may impact subsistence fish and wildlife resources and the 

access to and use of subsistence resources on BLM-managed lands. BLM has little control over such 

activities except by active participation in input and the management of proposed actions that would 

occur on BLM lands in support of development on non-BLM lands. 

3.4.3 Evaluation of Other Alternatives that Would Reduce or Eliminate the Use, 

Occupancy, or Disposition of Public Lands Needed for Subsistence Purposes 

Alternatives that would reduce or eliminate the use of public lands needed for subsistence include 

Alternatives B and C, which analyzed in Chapters 2 and 3 of the Draft BSWI RMP/EIS. These 

alternatives were created to represent a wide range of potential activities that could occur on BLMmanaged lands, along with management actions that would serve to protect specific resource values 

following current national guidelines. Additional alternatives that were considered but not analyzed in 

detail are also discussed in Chapter 2 of the Draft BSWI RMP/EIS. 

3.4.4 Findings 

Management actions that are seen as having the most potential to significantly restrict abundance, 

availability, or access of subsistence resources are: 

• Areas open to locatable mineral development (in areas of high and medium LMP) in known 

subsistence use areas; 

• OHV closures to subsistence use areas; and 

• ROW exclusion or avoidance areas in subsistence use areas. 

Appendix A provides detail on the methods and analysis used to determine the communities that may 

have as significant restriction to subsistence uses. 

This evaluation concludes that Alternative D may result in a significant restriction to subsistence uses for 

the communities of Aniak, Anvik, Bethel, Crooked Creek, Chuathbaluk, Grayling, Holy Cross, Kaltag, 

Lime Village, Lower Kalskag, and Upper Kalskag, Marshall, McGrath, Nikolai, Nulato, Russian Mission, 

Shageluk, Sleetmute, Stony River, and Unalakleet. 

Locatable mineral decisions would impact the abundance and availability of fishing resources, and moose 

and caribou harvesting, for the communities of Aniak, Crooked Creek, Chuathbaluk, Lower Kalskag, 

McGrath, Sleetmute, and Upper Kalskag. OHV use would impact the availability and abundance of 

moose, caribou, and fish species in all of the communities in the planning area. ROW decisions would 

impact the availability of subsistence resources (moose, caribou, and fish species) for all of the 

communities in the planning area, except Nulato. Appendix A provides a detailed analysis by community 

that supports these findings. 

In addition to the bullets listed above, the following proposed management under Alternative D would 

also adversely affect subsistence: 

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BSWI Draft RMP/EIS Appendix O: ANILCA Preliminary Section 810 Evaluation 

• This alternative would provide the least amount of protection for fish and aquatic resources and 

would rely on the operator to characterize the potential of streams for reclamation. Additionally, 

because watershed medium-high and medium resource values would not be protected as HVWs 

as proposed in Alternatives B and C, resources in these areas could degrade due to allowable 

development activities. This action could result in a substantial reduction in the opportunity to 

continue subsistence uses of renewable resources. 

• No protections for SSS flora habitats and lichen areas would be implemented if these areas 

became degraded by OHV use, and these areas could therefore be subject to further degradation. 

There could be an adverse effect to subsistence users if native plants important for subsistence 

uses were not considered in revegetating areas, reducing the abundance and availability of these 

plants for subsistence harvest and use compared to Alternatives B and C. 

• There would be no restrictions on casual use airboats and hovercraft and therefore no reduction in 

the potential for impacts to waterbirds and other species from associated disturbance. Because 

restrictions and mitigations for migratory birds would be determined on a case-by-case basis, it is 

difficult to assess the difference in impacts to migratory birds relative to other alternatives. This 

action could result in a substantial reduction in the opportunity to continue subsistence uses of 

renewable resources. 

• There would be no restriction on areas that would be available for exchange or disposal, and there 

would be no consideration of lands available for acquisitions to help offset potential losses. If all 

lands available for disposal and acquisitions are carried out, the amount of high-value wildlife 

important to preserve the abundance of subsistence resources in the planning area would be less 

than under Alternative A, B, or C. 

• Alternative D does not apply CFZ buffers around the communities in the planning area. The lack 

of this buffer could increase the potential for use conflicts and increase competition for available 

resources between subsistence users and non-local resource users. This action could result in a 

substantial reduction in the opportunity to continue subsistence uses of renewable resources and 

interference with access. 

• Alternative D would not prohibit casual use airboats or hovercraft on non-navigable waterways 

on BLM-managed land. There would be no additional travel management for caribou habitat and 

the Innoko Bottoms Priority Wildlife Habitat Area, so disturbance impacts to wildlife could 

increase and reduce the abundance and availability of wildlife resources for subsistence in these 

areas. This action could result in a substantial reduction in the opportunity to continue subsistence 

uses of renewable resources and interference with access. 

3.5 Evaluation and Findings for the Cumulative Case 

The goal of the cumulative analysis is to evaluate the incremental impact of the current action in 

conjunction with all past, present, and reasonably foreseeable future actions in or near the planning area. 

The cumulative analysis considers in greatest detail the activities that are more certain to happen and 

activities that were identified as being of great concern during scoping. Actions considered in the 

cumulative analysis include, but are not limited to, the actions that are presented in the following 

subsections. Past and present land use activities are described below. 

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Appendix O: ANILCA Preliminary Section 810 Evaluation BSWI Draft RMP/EIS 

3.5.1 Past, Present and Reasonably Foreseeable Land Use and Activities 

Relevant past and present actions are those that have influenced the current condition of the resources in 

the planning area. These actions, described below, were identified based on a review of the planning 

issues; agency records, including existing decisions and formal proposals; and non-federal actions on 

lands not managed by the BLM. 

Land Use 

The planning area and much of the surrounding lands are characterized by large tracts of undisturbed 

ecosystems that support a variety of native wildlife and fish species. Past and present land use and 

activities in the planning area are summarized below and provide the basis for analysis of cumulative 

effects. More detail regarding land uses in the planning area can be found in Chapter 1 of the Draft BSWI 

RMP/EIS and in Appendix M. 

Although the Draft BSWI RMP/EIS does not address lands that are not managed by the BLM, including 

State of Alaska lands, ANCSA Native corporation lands, NPS lands, USFWS lands, private lands, and 

Native allotments, past and present (as well as reasonable foreseeable future actions) land use for all lands 

within the planning area has influenced or has the potential to influence the current condition of the 

resources in the planning area and is therefore considered in the cumulative effects analysis. Impacts from 

such actions include ROW establishment, lease sales, and surface occupancy. As noted in Chapter 1 of 

the BSWI Draft RMP/EIS, subsurface estate within USFWS lands is managed by the BLM under the 

Mineral Leasing Act of 1920. ANILCA § 304(c) is addressed in the Mineral Occurrence and 

Development Potential Report for Leasable Minerals within the Bering Sea – Western Interior Planning 

Area Planning Area (BLM 2015). Conservation system units and other land tracts established by 

ANILCA will be addressed on a case-by-case basis and are not subject to this plan. Similarly, any prior 

existing mining claims administered by the BLM within USFWS or NPS lands will be addressed on a 

case-by-case basis. 

BLM Land 

Past and current land use on BLM-managed land in the planning area (see Draft BSWI RMP/EIS, Map 1-

2), including the INHT, are considered for the cumulative effects analysis. This information is described 

in detail in Chapter 3 of the Draft BSWI RMP/EIS. These are lands that will most likely be retained in 

long-term federal ownership. These lands, which constitute 10,727,251 acres, or approximately 

17 percent of the lands managed by BLM, are not selected by the State of Alaska or by Native 

corporations. An additional 2,594,941 (approximately 4 percent of the lands managed by BLM) and 

144,284 acres (less than 1 percent of the lands managed by BLM) are selected by the State of Alaska and 

Native corporations, respectively. Selected lands are in BLM management until interim conveyed or 

tentatively approved; however, selected lands do not qualify as Federal Public Lands under ANILCA 

§ 810. 

National Wildlife Refuges 

The Yukon Delta National Wildlife Refuge (NWR) and the Innoko Unit of the Innoko NWR are in the 

planning area. These refuges were established in 1980 by ANILCA with the following management 

goals: (1) to conserve fish and wildlife populations and their habitats in their natural diversity, (2) to 

fulfill the international treaty obligations of the United States with respect to fish and wildlife and their 

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BSWI Draft RMP/EIS Appendix O: ANILCA Preliminary Section 810 Evaluation 

habitats, (3) to provide the opportunity for continued subsistence uses by local residents, and (4) to ensure 

adequate water quantity and quality necessary to meet refuge purposes. Activities taking place on the 

refuges include hunting, fishing, recreational use, and subsistence harvest, as well as research and 

management activities. Residents of adjacent villages on the lower Innoko and Yukon Rivers harvest the 

land’s fish and wildlife resources. Fish and fall hunting camps are still in use up and down rivers of the 

Innoko region. Indigenous people known as the Yup’ik and Cup’ik Eskimos and Athabaskans inhabit the 

Yukon Delta NWR and rely heavily on local natural resources. 

Historically, 77 lode and placer mining claims were located in the Yukon NWR, mostly in the Kilbuck 

Mountains in the southeastern quarter of the refuge. Currently, no active mining claims or valid oil and 

gas leases are located on refuge lands. Eight pending oil and gas lease applications (totaling 20,392 acres) 

are on file with the BLM for the Yukon NWR. All were filed in 1968, but leases were never issued. The 

lease applications were “grandfathered in” under the authority of the Federal Onshore Oil and Gas

Leasing Reform Act of 1987 (101 Stat. 1330-256, 259). 

National Park Service Lands 

One NPS unit, Lake Clark National Park and Preserve, reaches into the southeastern portion of the 

planning area, constituting approximately 1.0 percent of the lands managed by BLM. The 4-million-acre 

Lake Clark National Park and Preserve was established in 1980 by ANILCA. Approximately 2,572,000 

acres of the park is designated wilderness. The stated purpose of Lake Clark National Park and Preserve is 

to “protect a region of dynamic geologic and ecological processes that create scenic mountain landscapes, 

unaltered watersheds supporting Bristol Bay red salmon, and habitats for wilderness dependent 

populations of fish and wildlife, vital to 10,000 years of human history” (NPS 2009). Subsistence 

activities by local rural residents and those who live on private land in the park and preserve boundaries 

include hunting, trapping, fishing, and timber harvest. Recreational and sport uses of the Lake Clark area 

are those commonly associated with Alaskan wilderness activities such as hunting, fishing, trapping, river 

running, hiking, photography, and wilderness camping. Sport fishing is allowed throughout the park and 

preserve, but sport hunting and trapping are confined to the national preserve. Visitor access is by 

commercial and privately operated airplanes and boats. The use of off-road vehicles for other than 

subsistence activities is prohibited on federal lands within the park and preserve. 

Management of the park and preserve is guided by a portfolio of management plans, including a 

foundation statement (NPS 2009), a general management plan amendment (NPS 2014), and draft land 

protection plan (NPS 2013). The guiding principle of land protection plans is to ensure the protection of 

each unit of the national park system consistent with the stated purposes for which the unit was created 

and administered. 

Nine patented mining claims total 51.2 acres within the Lake Clark Park and Preserve boundary. Park and 

preserve lands are no longer available for new mineral entry and location (NPS 2013). 

State Lands 

The planning area includes roughly 18.1 million acres of State lands and 2.6 million acres of BLM lands 

that have been selected by the State (approximately 21 and 4 percent of the lands managed by BLM, 

respectively). The BLM continues to manage lands selected by the State of Alaska that have not yet been 

conveyed. Lands that have already been conveyed to the State constitute approximately 29 percent of 

lands managed by BLM. State lands in the planning area are managed under guidelines outlined in Alaska 

28 
Appendix O: ANILCA Preliminary Section 810 Evaluation BSWI Draft RMP/EIS 

Department of Natural Resources (ADNR) area plans, such as the Kuskokwim Area Plan (ADNR 1988) 

and Tanana Basin Area Plan (ADNR 1991). The State lands are managed for multiple uses, with 

priorities varying according to the resource values for particular subunits. Primary land uses include 

forestry, agriculture, minerals management, recreation, fish and wildlife habitat, heritage resources, 

recreation and tourism, settlement, public access, transportation, and low-value resource management. 

Wood-Tikchik State Park reaches into the southern boundary of the planning area. The park is a 

1.6-million-acre area that was established to protect fish and wildlife populations and to support 

traditional subsistence and recreational activities. Traditional activities in the park include subsistence 

fishing, hunting, and trapping, as well as recreational fishing and hunting. The number of recreational 

wilderness-travel activities in the park has grown and includes kayaking, river floating, hiking, and some 

mountain climbing. The park management plan (ADNR 2002) designates the upper Tikchik Lakes and 

Kulik/Grant lakes as “Wilderness,” most of the remainder of the park “Natural Area,” and the Agulowak 

River and Lake Aleknagik State Recreation Site as “Recreational Development.”

Native Lands 

The planning area includes lands conveyed to village and regional Native corporations (approximately 

16 percent of the lands managed by BLM) and lands acquired by Alaska Natives under the Alaska Native 

Allotment Act of 1906 (34 Stat. 197) and the Native Townsite Act of 1926 (43 U.S.C. 733–736) 

(approximately 440,000 acres, or about 1 percent of the lands managed by BLM). 

Federally recognized tribes, ANCSA village corporations, and ANCSA regional corporations with a 

nexus to the planning area are listed in Chapter 1 of the Draft BSWI RMP/EIS. More than 50 village 

corporations and five regional corporations (Doyon, Limited, Calista Corporation, Cook Inlet Region 

Incorporated, Bering Straits Native Corporation, and NANA Regional Corporation) have a nexus to the 

planning area. Management objectives for regional corporation lands in the planning area are focused on 

the protection of traditional shareholder uses and responsible economic development of resources. 

Throughout much of the twentieth century, mining provided an economic basis for shareholders. Placer 

gold mining supported several settlements, including Iditarod, Marshall, and Nyac. Currently, placer gold 

production continues on a small scale and is an important source of revenue for shareholders. Illustrative 

of regional corporation objectives to support responsible development is NANA’s historical involvement 

with the Red Dog mine north of the planning area. 

Exploration and baseline studies for the Donlin Gold Project in the Calista Region near Crooked Creek 

have been ongoing since 1995. This mineral resource site is located on surface land owned by The 

Kuskokwim Corporation (TKC), and Calista Corporation owns the subsurface land. 

Military Lands 

Military lands constitute less than 0.1 percent of the lands managed by BLM. If military lands are 

released and returned to BLM management during the life of the BSWI RMP, the direction in the Draft 

BSWI RMP/EIS would apply. Generally, military use of lands in the planning area was during the Cold 

War era following World War II and was tied to the communication, navigation, and radar needs of the 

time. Most military installations have been decommissioned, and little present use exists. 

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BSWI Draft RMP/EIS Appendix O: ANILCA Preliminary Section 810 Evaluation 

Past and Present Activities 

Oil, Gas, Coal, and Geothermal Leasing and Exploration 

Fluid mineral occurrence and development potential in the planning area is associated primarily with coal 

and coal bed natural gas, oil and gas, peat, and geothermal resources (BLM 2015). The findings in this 

report on past and present activities are summarized in the following subsections. 

Oil and Gas 

Oil and gas basins in the planning area include Bethel, Galena, Holitna, Innoko, Minchumina, and Yukon 

Delta Basins. Historically, several geophysical surveys (e.g., airborne magnetic surveys, gravity surveys, 

reflection seismic surveys) have been conducted in the region, and one exploratory well was drilled in the 

Bethel Basin (Napatuk Creek No. 1) in the early 1960s but was abandoned as a dry hole. No additional 

exploratory wells have been drilled in the area, and no recent federal oil and gas leasing has taken place. 

Pending Oil and Gas Leases 

Fifty-nine pending oil and gas lease offers within the planning area were filed in the late 1960s, all within 

the boundary of the Yukon Delta NWR. These pending lease offers were subsequently suspended by 

Public Land Orders and remain unavailable for oil and gas leasing. 

Coal 

The areas in the planning area that contain coal have been divided into one field and five districts: 

Farewell (Little Tonzona) Coal Field and the Windy Fork, Middle Fork, Cheeneetnuk, Big River, and 

Nelson Island Districts (Draft BSWI RMP/EIS, Map 3.3.4-1). Most of the coal in the planning area is 

tertiary-aged and subbituminous. Known coal mineral resources are limited to a few thin coal beds on 

Nelson and Nunivak Islands, but these are considered noncommercial. Modest amounts of coal from 

Windy Fork have been used by trappers, prospectors, and big game hunters for local home heating 

applications. Coal was also noted to have been mined at Flat and used for home heating until the 1930s. 

Some limited coal exploration of the Little Tonzona River coal deposits occurred in the 1980s for Doyon, 

Ltd. However, this field has no substantial past production. 

Geothermal 

Two geothermal springs are documented in the planning area: Ophir Hot Springs and Chuilnuk Hot 

Springs. The only spring that is currently being used as a source of energy is the hot spring occurrence 

near Ophir Creek. 

Mineral Exploration and Mining 

The current report analyzing locatable and salable mineral resource potential in the planning area for the 

BSWI RMP is the Mineral Occurrence and Development Potential Report – Locatable and Salable 

Minerals Bering Sea-Western Interior Resource Management Plan (Kurtak et al. 2017). The findings 

from this report on past and present activities specific to this resource are summarized in the following 

subsections. Distribution of mineral occurrences in the planning area is illustrated in the Draft BSWI 

RMP/EIS, Map 3.3.3-1, and is generally concentrated in upland portions of the planning area and 

lowlands in the immediate vicinity of these uplands where placer deposits occur. 

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Appendix O: ANILCA Preliminary Section 810 Evaluation BSWI Draft RMP/EIS 

The planning area has a long and colorful mining history, dating back to the late 1830s when Russian 

traders discovered mercury-bearing minerals along the Kuskokwim River near Aniak. Gold was 

discovered in the Flat area in 1908, driving one of the last great gold rushes in Alaska. Documented 

mineral production in the planning area totals 3.2 million ounces of gold, 151,750 ounces of silver, 

2.1 million pounds of copper, and 41,767 flasks of mercury. The Iditarod Mining District, which includes 

the Flat area, ranks third in placer gold production in Alaska (Kurtak et al. 2017). 

The planning area contains 453 documented mineral occurrences (Draft BSWI RMP/EIS, Map 3.3.3-3) 

and 2,480 mining claims, with 207 of those under federal management. Mineral occurrences include 

placer gold, gold-bearing quartz veins, copper-gold skarns, and silica-carbonate mercury deposits. In 

2015, there were 19 active placer mines and one active lode mine. Currently, less than 1 percent of the 

total acreage taken up by mining claims and prospecting sites in the planning area are under federal 

management. The majority of the mining and mineral exploration is taking place on State of Alaska, 

Native corporation, or private lands (Kurtak et al. 2017). 

Twelve separate companies or individuals (11 open pit placers and one hard rock mine) were estimated to 

be producing metals (predominantly gold) in the planning area in 2014. Additionally, the Donlin Gold 

Project near Crooked Creek is an advanced stage exploration project (Kurtak et al. 2017). On August 13, 

2018, the U.S. Army Corps of Engineers and BLM issued a joint Federal Record of Decision, along with 

the Clean Water Act Section 404/Rivers and Harbors Act Section 10 permit and the Offer to Lease for the 

pipeline ROW at Donlin Gold. The project is currently seeking State permit approval for initial mine 

startup (NovaGold 2018). 

The primary mineral material commodities used in the planning area are crushed rock and sand and 

gravel. Thirteen material sites were reported to be active in 2008 in Southwest Alaska, which includes the 

planning area. Sand and gravel are used in construction and road maintenance. Currently, the BLM does 

not have any requests to develop sand and gravel on BLM-managed land in the planning area because 

local demands are being met by sand and gravel producers located on private or State-owned lands. This 

status is unlikely to change in the near future due to lack of appropriate BLM-managed land in the 

vicinity of population centers that require sand and gravel (Kurtak et al. 2017). 

Forest Resources Use 

Forest resources in the planning area have historically provided materials for sheltering and heating. 

House logs and local sawmills have been used to construct housing, lodges, and commercial buildings 

throughout the area. Firewood is a staple of the subsistence lifestyle for heating and, in some instances, 

cooking. BLM forests, although generally farther from communities than non-BLM lands, may still play a 

role in the long-term supply of wood—especially BLM lands near rivers that can assist in wood transport. 

Most villages have portable sawmills to produce building materials or repair materials locally, and one 

full sawmill in Chuathbaluk has produced building materials for use in the Kuskokwim Basin. There has 

been recent interest from villages in the use of biomass for heating buildings or communities; these 

projects could eventually expand to include power generation. 

Development of Infrastructure for Communities 

There are 65 rural communities in the planning area. Based on 2010 data from the U.S. Census Bureau for 

these communities, the population in the planning area is approximately 25,000 (U.S. Census Bureau 

2010a). The largest population center is Bethel in the southwest portion of the planning area, with a 

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BSWI Draft RMP/EIS Appendix O: ANILCA Preliminary Section 810 Evaluation 

population of 6,080 (U.S. Census Bureau 2010b). Very few roads pass through the planning area; the 

longest is a 43-mile gravel road that connects Sterling Landing on the Kuskokwim River with the 

historical mining community of Ophir on the Innoko River. A handful of short roads serving local 

communities, or remaining from past human activities, also exist. Almost all of these existing roads in the 

planning area are on lands managed by entities other than the BLM. 

Military Activities 

Little additional military use and activities are anticipated in the planning area. 

Research, Monitoring, and Land Management 

Research, monitoring, and land management are frequent activities on non-BLM lands in the planning 

area. Specifically, fixed-wing aircraft and helicopters are used to transport personnel and equipment and 

to conduct surveys. Remote areas are also accessed by boats during the summer and snow machines 

during the winter to conduct research, monitoring, and other land-management activities. 

Recreation and Subsistence 

Sport hunting and subsistence uses are the most prevalent land uses in the planning area. The 

undeveloped nature of the planning area, the existence of unique historical features such as the INHT, and 

the presence of surrounding NWRs provide opportunities for unique outdoor recreational opportunities, 

including guided hunting, fishing, eco-tourism, and organized events such as the Iditarod Sled Dog Race 

and the Iron Dog Snowmobile Race. Subsistence fishing and hunting are important for the economies and 

cultures of many families and communities in Alaska, especially for rural families who depend on 

subsistence hunting and fishing as sources of nutrition and cultural practices. Subsistence use occurs 

under both federal subsistence regulations and State general fishing, hunting, and subsistence regulations. 

ADF&G reports statewide harvest for 2014 as follows: 0.9 percent—subsistence food harvested by 

Alaska residents (about 33.8 million pounds); 0.2 percent—personal use fishing and hunting under 

general regulations by Alaskans; 0.4 percent—sport fishing and hunting; 98.5 percent—commercial 

fisheries (ADF&G 2014). 

Reasonably Foreseeable Future Land Use and Actions 

For this analysis, reasonably foreseeable future actions are actions that are external to the proposed action 

and likely (or reasonably certain) to occur, although they may be subject to a degree of uncertainty, within 

the next 15 to 25 years. Typically, they are based on documents such as existing plans, permit 

applications, and fiscal appropriations. 

Future Land Use 

BLM Lands 

Alternative land use scenarios for BLM-managed land in the planning area are described in Chapter 2 of 

the BSWI Draft RMP/EIS. Conveyance of lands to the State of Alaska and Native corporations is 

ongoing. On a statewide basis, about 98 percent of the Native conveyances and 95 percent of the State 

conveyances have been completed. 

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Appendix O: ANILCA Preliminary Section 810 Evaluation BSWI Draft RMP/EIS 

Donlin Gold LLC, a limited liability company jointly owned by Barrick Gold U.S. Inc. and NovaGold 

Resources Alaska, Inc., received key permits on August 13, 2018, for development of the Donlin Gold 

Project, an open pit hardrock mine near the village of Crooked Creek., including ROW permit approval 

from BLM. The ROW Grant has a term of 30 years. Construction has not yet begun, and Donlin Gold 

LLC has 8 years from August 13, 2018, to complete construction. 

The Donlin Gold Mine Project includes development and operation of an open pit mine, mine facilities, 

and a port site, as well as ancillary facilities such as airstrips, access roads, material sites, and a 

connecting 14-inch-diameter, 316-mile-long natural gas pipeline. The pipeline would cross 97 miles of 

largely remote and undisturbed BLM-managed land. The total footprint for the temporary 150-foot 

construction ROW and ancillary facilities on BLM land is 2,329 acres. The total footprint for the 51-foot 

operations and maintenance ROW on BLM land is 601 acres. The proposed mine and related facilities 

would have a total footprint of approximately 16,300 acres located throughout 80,600 acres of leased land 

(USACE 2018). The proposed project would require 3 to 4 years to construct, followed by an active mine 

life of approximately 27 years. After the end of the Operations Phase, the mine site facilities would be 

closed and reclaimed as required by permit conditions. The ROW Grant includes stipulations to reduce 

impacts to the environment. However, Donlin Gold’s proposed mine may result in a significant restriction

to subsistence uses for communities along the Kuskokwim River and communities along the gas pipeline 

right-of way (Appendix N in USACE 2018). The development of ancillary facilities, temporary access 

roads, and airstrips developed in association with the pipeline may result in unintended development 

along this corridor, which affects subsistence gathering regions. Designations that provide measures of 

protections for aquatic and terrestrial habitats, such as HVW, ACEC, wild and scenic rivers, and areas 

managed to preserve wilderness characteristics, will reduce risk to sensitive areas important for the 

protection of subsistence values. 

National Wildlife Refuges 

Conservation plans are in place for the refuges that guide management principles. The Yukon Delta plan 

was prepared in 2004 (USFWS 2004) and the revised Innoko plan was prepared in 2008 (USFWS 2008). 

This analysis assumes that management of the Yukon Delta and Innoko NWRs would continue as it has 

during recent decades and as outlined in the current conservation plans. Approximately 1.3 million acres 

(35 percent of the refuge) southeast of the Innoko River is designated wilderness. Two wilderness areas 

(Andreafsky Wilderness and Nunivak Wilderness) are designated inside the Yukon Delta NWR, totaling 

approximately 1.9 million acres. Limited activities are allowed in designated wilderness areas. Wilderness 

characteristics would be preserved on the majority of the refuge lands that are not designated as 

wilderness. Development and exploration activities could occur on Native and privately owned lands 

within the refuge boundaries. While oil and gas development is not reasonably foreseeable on the refuge 

lands due to low potential, some exploration from Native corporation lands and private land owners 

within the refuge boundaries could occur. Decisions to allow exploration on refuge lands would be made 

on a case-by-case basis. These activities would require a Special Use Permit with site-specific stipulations 

to ensure compatibility with refuge purposes and consistency with comprehensive conservation plan 

management objectives. 

National Park Service Lands 

This analysis assumes that the current management direction for the Lake Clark National Park and 

Preserve would continue. As outlined in the General Management Plan Amendment (NPS 2014) and 

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BSWI Draft RMP/EIS Appendix O: ANILCA Preliminary Section 810 Evaluation 

Lake Clark National Park and Preserve Draft Land Protection Plan (NPS 2013), the NPS intends to 

manage the park to maintain its natural and cultural resource values and maintain and enhance public 

understanding and enjoyment of these values. 

Park and preserve lands are no longer available for new mineral entry and location. Mining could occur 

on private lands, including Native corporation lands, within the park and preserve boundaries. 

Additionally, State mineral claims may currently be filed anywhere on State lands inside the unit (the 

submerged lands beneath the navigable lakes and rivers). As outlined in the Lake Clark National Park and 

Preserve Draft Land Protection Plan (NPS 2013), the NPS recommends that the State close the beds of 

navigable waters to new mineral entry, extraction of oil and gas, and sand and gravel resources and will 

apply to the State for these closures. The NPS will also pursue cooperative agreements with the State for 

the management of lands under navigable waterbodies (shorelands). 

Mineral development and operation of the existing mining claims within the park boundary could 

continue. Development of these claims would need to be in compliance with the Mining in the Parks Act 

(16 U.S.C. 1901 et seq.). NPS (2013) identifies the Johnson River as the area of the park most likely to 

see future mining. 

State Lands 

State lands would continue under multiple use management, with uses prioritized to conserve valuable 

resources in some areas while allowing resource use in other areas. As much as possible, State lands are 

managed so that uses are compatible with land use on adjoining federal lands. Land use for recreation, 

subsistence, and tourism may increase as local, state, and national populations grow. 

State of Alaska permitting in the planning area is for the proposed Donlin Gold Project’s ancillary

facilities that would be constructed on State lands, such as material sites and portions of the natural gas 

pipeline ROW. Project details are listed above in the section “BLM Lands.” Significant progress has been 

made to advance State permitting for the Donlin Gold Mine Project, including issuance of the State air 

quality and Alaska Pollutant Discharge Elimination System (APDES) wastewater discharge permits 

(NovaGold 2018). 

Native Lands 

Economic development of resources is a reasonably foreseeable use of Native-owned lands within the 

planning area. The Donlin Gold Project, described above in the section “BLM Lands,” also includes land 

leased from Calista Native Corporation, which holds the subsurface (mineral) estate for ANCSA lands in 

the project area. A surface use agreement with TKC, the village corporation that owns the surface land, 

grants surface use rights to lands that TKC holds at the mine site. The proposed mine would provide 

income from employment during both construction and operations of the mine. This would allow 

employed subsistence users to better afford fuel and equipment necessary for subsistence activities. 

Project employment and incomes would benefit 25 to 29 percent of area households during the estimated 

3- to 4-year construction period and 5 to 9 percent of households during the estimated 27-year operation 

period (USACE 2018, Section 3.21). Higher mean income levels are associated with lower subsistence 

productivity at the community level (Wolfe and Walker 1987), suggesting households with jobs and 

incomes participate less in subsistence activities, and subsistence productivity may increase with lower 

median income at the community level. Outmigration and adverse effects of rotation work shifts may also 

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Appendix O: ANILCA Preliminary Section 810 Evaluation BSWI Draft RMP/EIS 

affect up to half of households with project employment, with greater impacts in the smaller communities 

with more concentrated project employment (USACE 2018). 

Future Activities 

Oil and Gas, Coal, and Geothermal Leasing and Exploration 

The development potential for leasable mineral resources such as coal, coal bed natural gas, oil and gas, 

geothermal, peat, and coalbed natural gas in the planning area is low (BLM 2015). The expense of 

developing some of these resources and the lack of roads or railroads connecting the planning area to the 

rest of the state would also likely preclude small- and large-scale development in the foreseeable future. 

Prospective oil and gas basins in the region of the planning area include the Holitna, Bethel, and 

Minchumina Basins, along with the Yukon Delta. There are 59 pending oil and gas Pre-Reform Act lease 

offers in the planning area, all within the boundary of the Yukon Delta NWR and therefore have been 

suspended. No additional oil and gas lease offers may be filed until the land selection process that the 

State and various Alaska Native entities are undertaking is complete. The BLM will continue its 

adjudicative role on prior existing rights under the mining laws and process dispositions under the mineral 

leasing laws or material sales. Some areas of known coal (leasable) mineral potential exist, but there has 

been little interest in developing it to date. 

Mineral Exploration and Mining 

A total of 101 areas in the planning area are considered to have high LMP, including a number of areas 

that are in BLM-managed land and covered by federal mining claims. These include the Nixon Fork Mine 

area, Flat-Chicken Mountain area, Ophir Creek drainage (Kilbuck Mountains), and the Nyac (Shamrock 

Creek) area. Additional areas of interest include the high LMP areas on State-selected lands near the 

Little Creek (west of Donlin), Oskawalik, Julian Creek, and the Granite-Willow Creek areas. Future 

mineral exploration and mining activities have the potential to occur in these areas and could have 

impacts on BLM-managed land extending outside the mining claim boundaries (Kurtak et al. 2017). See 

the discussion of the Donlin Gold Project above in the section “BLM Lands.” Table 1 details the high 

LMP areas in the planning area as identified in Kurtak et al. (2017). 

Table 1: High Locatable Mineral Potential in the Planning Area 

District Name Production Status Deposit Type Land Status 

Canyon Creek Past producer Placer Au-PGE State 

Cripple Creek Producer Placer Au-PGE State 

Eureka Creek Past producer Past producer Past producer 

Gemuk Mtn No production Au-polymetallic State 

Akiak 

Kisa No production Felsic-dike-hosted qtz veinlets State 

Marvel Creek Producer Placer Au-PGE State 

Nyac Placer Producer Placer Au-PGE Calista Corp./BLM 

Nyac Lode No production Plutonic-hosted cu-au polymetallic Calista Corp. 

Ophir Creek No production Placer Au-PGE BLM 

Russian Mtns No production Polymetallic veins Calista Corp. 

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District Name Production Status Deposit Type Land Status 

Georgetown 

Donlin Creek (Ruby 

Gulch) 

Producer Placer Au-PGE Calista Corp. 

Donlin Creek (Lewis 

Gulch) 

Producer Placer Au-PGE Calista Corp. 

Donlin Creek Lode No production Felsic-dike-hosted qtz veinlets Calista Corp. 

Fortyseven Creek Past producer Placer Au-PGE State 

Granite-Willow Creeks Producer Placer Au-PGE State 

Julian Creek Producer Placer Au-PGE State 

Mountain Top Past producer Silica-carbonate Hg State 

Oskawalik River No production Polymetallic replacement deposits 

and veins 

State 

Red Devil Past producer Silica-carbonate Hg BLM 

Murry Gulch Past producer Placer Au-PGE State 

Taylor Creek Past producer Placer Au-PGE State 

Iditarod 

Chicken Mtn-Flat No production Plutonic-hosted Cu-Au polymetallic Doyon Ltd 

Decourcy Mtn Past producer Silica-carbonate Hg Calista Corp. 

Flat Creek Past producer Placer Au-PGE BLM 

Golden Horn Mine Past producer Plutonic-hosted Cu-Au polymetallic State 

Little Creek No production Placer Au-PGE State 

Otter Creek Past producer Placer Au-PGE BLM 

Prince Creek Past producer Placer Au-PGE BLM 

Willow Creek Past producer Placer-Au-PGE BLM 

Little Creek Producer Placer Au-PGE Patented 

Innoko 

Beaver Mtns (Cirque) No production Polymetallic vein State 

Boob Creek-Mt Hurst Past producer Placer Au-PGE State 

Colorado Creek Past producer Placer Au-PGE State 

Cripple Creek Past producer Placer Au-PGE State 

Ester Creek Past producer Placer Au-PGE State 

Esperanto Creek Past producer Placer Au-PGE State 

Ganes Creek (Lower) Past producer Placer Au-PGE Patented 

Ganes Creek (Upper) Producer Placer Au-PGE Patented/State 

Innoko River (Lower) Past producer Placer Au-PGE State 

Montana Creek Producer Placer Au-PGE State 

Moore Creek Producer Placer Au-PGE State 

Yankee Creek (Lower) Past producer Placer Au-PGE Doyon Ltd. 

Yankee Creek (Upper) Producer Placer Au-PGE Patented/ Doyon 

Ltd./ State 

Win No production Sn-polymetallic veins State 

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Appendix O: ANILCA Preliminary Section 810 Evaluation BSWI Draft RMP/EIS 

District Name Production Status Deposit Type Land Status 

Marshall 

Buster Creek Past producer Placer Au-PGE Patented 

Stuyahok – Flat Creek No production Felsic-dike-hosted qtz veinlets Calista Corp. 

Willow Creek Past producer Placer Au-PGE Calista 

McGrath 

Bowser No production Zn-Pb skarn deposits State 

Broken Shovel No production Plutonic-hosted Cu-Au polymetallic State 

Candle Creek Producer Placer Au-PGE State/ Doyon Ltd. 

Eagle Creek Past producer Placer Au-PGE State 

Nixon Fork Mine Producer Cu skarn deposits BLM/ 

Doyon Ltd. 

Roberts Pgm No production Noril'sk Cu-Ni-PGE State 

Sheep Creek No production Polymetallic replacement deposits 

and veins 

Doyon Ltd. 

Terra Producer Low-sulfide Au-quartz veins State 

Tin Creek No production Zn-Pb skarn deposits Doyon Ltd. 

Vinasale No production Plutonic-hosted Cu-Au polymetallic Doyon Ltd. 

Tonzona Reef Ridge No production Southeast Missouri Pb-Zn Doyon Ltd. 

Source: Kurtak et al. (2017) 

AU = gold Ni = nickel qtz = quartz 

BLM = Bureau of Land Management Pb = lead Sn = tin 

Cu = copper PGE = platinum group element Zn = zinc 

Hg = mercury 

Sand and Gravel 

Future demand for additional sand and gravel will be driven by development in the planning area, such as 

the proposed Donlin Gold Project pipeline that would cross 97 miles of BLM lands. 

Peat 

It is possible that villages and individuals in the planning area could develop peat as a resource for smallscale energy and heat generation. This type of development is unlikely on BLM-managed land because 

most villages in the planning area have enough land to harvest peat on their own or from adjacent State 

lands with fewer restrictions. Additional discussion of peat resources can be found in Section 3.3.8, 

Renewable Energy, of the Draft BSWI RMP/EIS. 

Infrastructure and Communities 

Potential transportation corridors are under review by the State of Alaska and include two road and ROW 

corridors—the Western Alaska Access Planning Study (“Road to Nome” Fairbanks–Nome route [DOWL 

2010]) and the Yukon-Kuskokwim Energy Corridor Plan (WHPacific Inc. and Information Insights 

2015)—both of which would cross BLM-managed land in the planning area. The Western Alaska Access 

Planning Study has evaluated three routes, including the preferred Yukon River Corridor, to connect the 

Nome-Council Road to the existing road system in the Fairbanks area. The proposed final stage of the 

Yukon River Corridor is between the villages of Koyuk and Nulato and would cross BLM-managed land 

in the Nulato Hills region of the planning area. The Yukon-Kuskokwim Energy Corridor Plan evaluated 

overland transport routes in the Portage Mountains area to connect the Yukon and Kuskokwim Rivers for 

37 
BSWI Draft RMP/EIS Appendix O: ANILCA Preliminary Section 810 Evaluation 

fuel and freight transport purposes. The assessed routes would cross BLM-managed land from Paimute 

Slough on the Yukon River to the northeast of the Upper and Lower Kalskag and Kuskokwim River 

communities. 

Projects that have been studied but not considered as a reasonably foreseeable future action for the time 

frame of the impact analysis include the following: 

• Yukon-Kuskokwim Transportation Corridor – This project was proposed by the Association of 

Village Council Presidents (funded through a State of Alaska general fund appropriation) and is 

currently in the planning phase. A report on this potential project was presented at the Association 

of Village Counsel President’s Annual Convention in 2013 and prepared for Alaska Department 

of Transportation and Public Facilities. However, the project has no appropriation for 

construction and is not currently on the Alaska Department of Transportation and Public 

Facilities’ Statewide Transportation Improvement Program for construction funding or identified 

in an Alaska Statewide Long Range Transportation Plan (ADOT 2002). 

• Road to Nome – A proposed highway from the Interior to Western Alaska was studied by the 

Alaska Department of Transportation but has not advanced beyond conceptual design. One route 

that was studied would connect the Elliott Highway near Manley Hot Springs to the end of the 

Nome-Council Highway. No definite sources of funding for the project have been identified, and 

it is not currently identified in an Alaska Statewide Long Range Transportation Plan. 

State Lands 

Activities on State lands and for State-managed resources will continue and increase in proportion to 

population growth, resource development to generate economic activity and revenue for corporation 

shareholders, and tourism. The mission of the ADF&G is to protect, maintain, and improve the fish, 

game, and aquatic resources of the state and manage their use and development in the best interest of the 

economy and the well-being of the people of the state, consistent with the sustained yield principle 

(ADF&G 2017). Education, nongame management and research, and wildlife viewing opportunities are 

expected to increase. Future actions will address human-wildlife conflicts, subsistence management, and 

predator management. 

Research, Monitoring, and Land Management 

Research, monitoring, and land management will continue on federal, State, and Native lands. Remote 

areas will continue to be accessed by fixed-wing aircraft, helicopters, boats, and snowmobiles, depending 

on the season. 

Subsistence and Recreation 

Past recreation, sport hunting, and fishing activities and traditional subsistence practices are expected to 

continue. Past uses of the INHT are also expected to continue. Recent funding has supported trail 

improvements such as shelter cabins. Land use for recreation, subsistence, and tourism may increase as 

local, state, and national populations grow. 

38 
Appendix O: ANILCA Preliminary Section 810 Evaluation BSWI Draft RMP/EIS 

Climate Change 

Climate change will benefit some subsistence resources and adversely affect others. Frequency and 

severity of natural wildland fire in western Alaska are predicted to increase and result in shifts to 

deciduous and shrub-dominated landscapes, which may benefit moose and some furbearers but not 

caribou. Predicted increases in water temperatures would alter chemical and biotic conditions to the 

detriment of subsistence fish diversity and abundance. Increases in soil temperatures would result in 

drying of lakes and ponds. 

The following climate warming scenarios are likely in the planning area, based on the Rapid Ecoregional 

Assessment and the National Climate Assessment and are considered in the cumulative effects analysis: 

• Increased temperatures 

• Permafrost thaw; the only areas in the planning area that are expected to retain permafrost to a 

depth of 1 meter, the most influential on vegetation and surface conditions, in the future, aside 

from isolated pockets, are in the Nulato Hills region. 

• Decreased snow cover (albedo effect), subnivean species impacts 

• Increased wildland fire intensity, size, and frequency 

• Increase in nonnative invasive species presence/spread 

• Later freeze-up dates (river ice) 

• Sea level rise (salt intrusion, transportation changes) 

• Shrub encroachment 

• Spruce trees replaced with aspen/birch hardwood trees 

3.6 Evaluation and Findings for the Cumulative Case – Alternative A 

3.6.1 Evaluation of the Effects of Use, Occupancy, or Disposition on Subsistence Uses and 

Needs 

Based on the analyses in Chapter 3 of the Draft BSWI RMP/EIS, and Appendix N, potential development 

of transportation corridors, mineral exploration and development on State and Native lands, and the 

potential for increased recreational activities occurring in or adjacent to the planning area would have 

cumulative impacts on subsistence resources. Depending on the location, extent, intensity, and duration of 

development, these impacts may include alteration of the traditional lifestyles of rural residents, 

subsistence resource degradation and limits to subsistence access, distribution to and limited abundance of 

subsistence resources, and increased competition to local subsistence users. 

The potential list of cumulative activities would, depending on timing, magnitude, duration, intensity, and 

type of activity, impact the full spectrum of local and regional subsistence species fish and wildlife 

relative to abundance, distribution, seasonal habitat use, movement patterns, habitat integrity (relative to 

fragmentation, degradation, conversion). 

The continued use of small roads that connect communities in the planning area may aid subsistence users 

in accessing their traditional harvest areas. However, these small roads may also concentrate hunting 

efforts along the road/trail corridors, depleting resources from the area, and potentially altering harvest 

39 
 

 

 

BSWI Draft RMP/EIS Appendix O: ANILCA Preliminary Section 810 Evaluation 

from current traditional harvest areas. Increased competition for subsistence resources would likely result 

if smaller communities were linked by construction of new transportation corridors because non-resident 

and non-local hunters would be able to access the area with little effort. This may also result in an 

increase in recreational use of the area, resulting in additional impacts to wildlife. 

3.6.2 Evaluation of the Availability of Other Lands for Land Use Plan Decisions Allowed 

in the Planning area 

As described, the cumulative case contains information on reasonably foreseeable activities that could 

have an effect on the management decisions being analyzed as part of the Draft BSWI RMP/EIS. The 

purpose of the cumulative case is to present known ongoing activity by all entities on all lands near or 

within the planning area, as well as activities that have been proposed for the future and are likely to 

occur. The cumulative case is not an implementable alternative that specifies land uses and management 

but is instead a discussion of impacts that could affect the management decisions in Alternatives A 

through D. 

3.6.3 Evaluation of Other Alternatives that would Reduce or Eliminate the Use, 

Occupancy, or Disposition of Public Lands Needed for Subsistence Purposes 

The proposed action and/or alternatives are to occur on lands needed for subsistence purposes. For the 

BSWI RMP, the planning area is by definition the focus, not other areas. Areas outside of the planning 

area are not subject to the planning process and are outside the scope of the planning process and 

therefore would not be considered under this analysis. Alternatives that would reduce or eliminate other 

uses of public lands otherwise needed for subsistence include the alternatives that are presented and 

analyzed in Chapters 2 and 3 of the Draft BSWI RMP/EIS. These alternatives were created to represent a 

wide range of potential activities that could occur on BLM-managed lands, along with management 

actions that would serve to protect specific resource values following current national guidelines. 

Additional alternatives that were considered but not analyzed in detail are also discussed in Chapter 2 of 

the Draft BSWI RMP/EIS. 

3.6.4 Findings 

The cumulative case, as presented in this analysis, may result in a significant restriction of subsistence 

uses for the communities of Aniak, Anvik, Bethel, Crooked Creek, Chuathbaluk, Grayling, Holy Cross, 

Kaltag, Lime Village, Lower Kalskag, Upper Kalskag, Marshall, McGrath, Nikolai, Nulato, Russian 

Mission, Shageluk, Sleetmute, Stony River, and Unalakleet due to a decrease in resource availability, 

alteration in the distribution of resources, obstruction to access of resources, and an increase in 

competition from access by non-qualified subsistence. Increased recreational activities occurring in or 

adjacent to the planning area, and climate influences (climate change) would impact resources important 

to subsistence users. With the trends of continued natural resource development and increased casual and 

recreational use in the planning area, subsistence resources would continue to be degraded and 

subsistence users would face increased competition for resources by non-local users. Donlin Gold’s 

proposed mine may result in a restriction to subsistence uses for communities along the Kuskokwim 

River and communities along the gas pipeline right-of way. The development of ancillary facilities, 

temporary access roads, and airstrips developed in association with the pipeline may result in unintended 

development along this corridor, which affects subsistence gathering regions. Designations that provide 

measures of protections for aquatic and terrestrial habitats, such as HVW, ACEC, wild and scenic rivers, 

40 
 

 

 

Appendix O: ANILCA Preliminary Section 810 Evaluation BSWI Draft RMP/EIS 

and areas managed to preserve wilderness characteristics, would reduce risk to sensitive areas important 

for the protection of subsistence values. 

3.7 Evaluation and Findings for the Cumulative Case – Alternative B 

3.7.1 Evaluation of the Effects of Use, Occupancy, or Disposition on Subsistence Uses and 

Needs 

Based on the analyses in Chapter 3 of the Draft BSWI RMP/EIS, and Appendix N, potential development 

of transportation corridors, mineral exploration and development on State and Native lands, and the 

potential for increased recreational activities occurring in or adjacent to the planning area would have 

cumulative impacts on subsistence resources. Depending on the location, extent, intensity, and duration of 

development, these impacts may include alteration of the traditional lifestyles of rural residents, 

subsistence resource degradation and limits to subsistence access, distribution to and limited abundance of 

subsistence resources, and increased competition to local subsistence users. 

The potential list of cumulative activities would, depending on timing, magnitude, duration, intensity, and 

type of activity, impact the full spectrum of local and regional subsistence species fish and wildlife 

relative to abundance, distribution, seasonal habitat use, movement patterns, habitat integrity (relative to 

fragmentation, degradation, conversion). 

The continued use of small roads that connect communities in the planning area may aid subsistence users 

in accessing their traditional harvest areas. However, these small roads may also concentrate hunting 

efforts along the road/trail corridors, depleting resources from the area, and potentially altering harvest 

from current traditional harvest areas. Increased competition for subsistence resources would likely result 

if smaller communities were linked by construction of new transportation corridors because non-resident 

and non-local hunters would be able to access the area with little effort. This may also result in an 

increase in recreational use of the area, resulting in additional impacts to wildlife. 

3.7.2 Evaluation of the Availability of Other Lands for Land Use Plan Decisions Allowed 

in the Planning area 

The proposed action and/or alternatives are to occur on lands needed for subsistence purposes. For the 

BSWI RMP, the planning area is by definition the focus, not other areas. Areas outside of the planning 

area are not subject to the planning process and are outside the scope of the planning process and 

therefore would not be considered under this analysis. As described, the cumulative case contains 

information on reasonably foreseeable activities that could have an effect on the management decisions 

being analyzed as part of the Draft BSWI RMP/EIS. The purpose of the cumulative case is to present 

known ongoing activity by all entities on all lands near or within the planning area, as well as activities 

that have been proposed for the future and are likely to occur. The cumulative case is not an 

implementable alternative that specifies land uses and management but is instead a discussion of impacts 

that could affect the management decisions in Alternatives A through D. 

3.7.3 Evaluation of Other Alternatives that would Reduce or Eliminate the Use, 

Occupancy, or Disposition of Public Lands Needed for Subsistence Purposes 

Alternatives that would reduce or eliminate other uses of public lands otherwise needed for subsistence 

include the alternatives that are presented and analyzed in Chapters 2 and 3 of the Draft BSWI RMP/EIS. 

41 
BSWI Draft RMP/EIS Appendix O: ANILCA Preliminary Section 810 Evaluation 

These alternatives were created to represent a wide range of potential activities that could occur on BLMmanaged lands, along with management actions that would serve to protect specific resource values 

following current national guidelines. Additional alternatives that were considered but not analyzed in 

detail are also discussed in Chapter 2 of the Draft BSWI RMP/EIS. 

3.7.4 Findings 

The cumulative case, as presented in this analysis, may result in a significant restriction of subsistence 

uses for the communities of Aniak, Anvik, Crooked Creek, Chuathbaluk, Grayling, Holy Cross, Kaltag, 

Lime Village, Lower Kalskag, Upper Kalskag, Marshall, McGrath, Nikolai, Shageluk, Sleetmute, Stony 

River, and Unalakleet due to a decrease in resource availability, alteration in the distribution of resources, 

obstructions to access of resources, and an increase in competition from access by non-qualified 

subsistence. Increased mineral exploration and development due to the lifting of withdrawals, increased 

recreational activities occurring in or adjacent to the planning area, and climate influences (climate 

change) would impact resources important to subsistence users. With the trends of continued natural 

resource development and increased casual and recreational use in the planning area, subsistence 

resources would continue to be degraded and subsistence users would face increased competition for 

available resources by non-local users. For species with habitat or populations that are degrading, this 

alternative would lessen the rate of degradation or stabilize or counter the existing trend. For species with 

habitat or populations that are improving, this alternative would allow the improvement to continue at a 

similar or greater rate. Alternative B would provide a greater measure of protection than the other 

alternatives for the maintenance and perpetuation of subsistence resources indirectly affected by the 

development of the Donlin Gold Mine and the associated natural gas pipeline. 

3.8 Evaluation and Findings for the Cumulative Case – Alternative C 

3.8.1 Evaluation of the Effects of Use, Occupancy, or Disposition on Subsistence Uses and 

Needs 

Based on the analyses in Chapter 3 of the Draft BSWI RMP/EIS, and Appendix N, potential development 

of transportation corridors, mineral exploration and development on State and Native lands, and the 

potential for increased recreational activities occurring in or adjacent to the planning area would have 

cumulative impacts on subsistence resources. Depending on the location, extent, intensity, and duration of 

development, these impacts could include alteration of the traditional lifestyles of rural residents, 

subsistence resource degradation and limits to subsistence access, distribution to and limited abundance of 

subsistence resources, and increased competition to local subsistence users. 

The potential list of cumulative activities would, depending on timing, magnitude, duration, intensity, and 

type of activity, impact the full spectrum of local and regional subsistence species fish and wildlife 

relative to abundance, distribution, seasonal habitat use, movement patterns, habitat integrity (relative to 

fragmentation, degradation, conversion). 

The continued use of small roads that connect communities in the planning area may aid subsistence users 

in accessing their traditional harvest areas. However, these small roads may also concentrate hunting 

efforts along the road/trail corridors, depleting resources from the area, and potentially altering harvest 

from current traditional harvest areas. Increased competition for subsistence resources would likely result 

if smaller communities were linked by construction of new transportation corridors because non-resident 

42 
 

 

 

Appendix O: ANILCA Preliminary Section 810 Evaluation BSWI Draft RMP/EIS 

and non-local hunters would be able to access the area with little effort. This may also result in an 

increase in recreational use of the area, resulting in additional impacts to wildlife. 

3.8.2 Evaluation of the Availability of Other Lands for Land Use Plan Decisions Allowed 

in the Planning area 

The proposed action and/or alternatives are to occur on lands needed for subsistence purposes. For the 

BSWI RMP, the planning area is by definition the focus, not other areas. Areas outside of the planning 

area are not subject to the planning process and are outside the scope of the planning process and 

therefore would not be considered under this analysis. As described, the cumulative case contains 

information on reasonably foreseeable activities that could have an effect on the management decisions 

being analyzed as part of the Draft BSWI RMP/EIS. The purpose of the cumulative case is to present 

known ongoing activity by all entities on all lands near or within the planning area, as well as activities 

that have been proposed for the future and are likely to occur. The cumulative case is not an 

implementable alternative that specifies land uses and management but is instead a discussion of impacts 

that could affect the management decisions in Alternatives A through D. 

3.8.3 Evaluation of Other Alternatives that would Reduce or Eliminate the Use, 

Occupancy, or Disposition of Public Lands Needed for Subsistence Purposes 

Alternatives that would reduce or eliminate other uses of public lands otherwise needed for subsistence 

include the alternatives that are presented and analyzed in Chapters 2 and 3 of the Draft BSWI RMP/EIS. 

These alternatives were created to represent a wide range of potential activities that could occur on BLMmanaged lands, along with management actions that would serve to protect specific resource values 

following current national guidelines. Additional alternatives that were considered but not analyzed in 

detail are also discussed in Chapter 2 of the Draft BSWI RMP/EIS. 

3.8.4 Findings 

The cumulative case, as presented in this analysis, may result in a significant restriction of subsistence use 

for the communities of Aniak, Anvik, Crooked Creek, Chuathbaluk, Grayling, Holy Cross, Kaltag, Lime 

Village, Lower Kalskag, , Upper Kalskag, Marshall, McGrath, Nikolai, Russian Mission, Shageluk, 

Sleetmute, Stony River, and Unalakleet due to a decrease in resource availability, alteration in the 

distribution of resources, obstruction to access of resources, and an increase in competition from access 

by non-qualified subsistence. Increased mineral exploration and development due to the lifting of 

withdrawals, increased recreational activities occurring in or adjacent to the planning area, and climate 

influences (climate change) would impact resources important to subsistence users. With the trends of 

continued natural resource development and increased casual and recreational use in the planning area, 

subsistence resources would continue to be degraded and subsistence users would face increased 

competition for available resources by non-local users. For species with habitat or populations that are 

degrading, the degradation may continue but at a lesser rate and could be stabilized. Alternative C would 

provide a greater measure of protection than Alternatives A and D but to a lesser extent than Alternative 

B for the maintenance and perpetuation of subsistence resources indirectly affected by the development of 

the Donlin Gold Mine and the associated natural gas pipeline. 

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BSWI Draft RMP/EIS Appendix O: ANILCA Preliminary Section 810 Evaluation 

3.9 Evaluation and Findings for the Cumulative Case – Alternative D 

3.9.1 Evaluation of the Effects of Use, Occupancy, or Disposition on Subsistence Uses and 

Needs 

Based on the analyses in Chapter 3 of the Draft BSWI RMP/EIS, and Appendix N, potential development 

of transportation corridors, mineral exploration and development on State and Native lands, and the 

potential for increased recreational activities occurring in or adjacent to the planning area would have 

cumulative impacts on subsistence resources. Depending on the location, extent, intensity, and duration of 

development, these impacts may include alteration of the traditional lifestyles of rural residents, 

subsistence resource degradation and limits to subsistence access, distribution to and limited abundance of 

subsistence resources, and increased competition to local subsistence users. 

The potential list of cumulative activities would, depending on timing, magnitude, duration, intensity, and 

type of activity, impact the full spectrum of local and regional subsistence species fish and wildlife 

relative to abundance, distribution, seasonal habitat use, movement patterns, habitat integrity (relative to 

fragmentation, degradation, conversion). 

The continued use of small roads that connect communities in the planning area may aid subsistence users 

in accessing their traditional harvest areas. However, these small roads may also concentrate hunting 

efforts along the road/trail corridors, depleting resources from the area, and potentially altering harvest 

from current traditional harvest areas. Increased competition for subsistence resources would likely result 

if smaller communities were linked by construction of new transportation corridors because non-resident 

and non-local hunters would be able to access the area with little effort. This may also result in an 

increase in recreational use of the area, resulting in additional impacts to wildlife. 

3.9.2 Evaluation of the Availability of Other Lands for Land Use Plan Decisions Allowed 

in the Planning area 

The proposed action and/or alternatives are to occur on lands needed for subsistence purposes. For the 

BSWI RMP, the planning area is by definition the focus, not other areas. Areas outside of the planning 

area are not subject to the planning process and are outside the scope of the planning process and 

therefore would not be considered under this analysis. As described, the cumulative case contains 

information on reasonably foreseeable activities that could have an effect on the management decisions 

being analyzed as part of the Draft BSWI RMP/EIS. The purpose of the cumulative case is to present 

known ongoing activity by all entities on all lands near or within the planning area, as well as activities 

that have been proposed for the future and are likely to occur. The cumulative case is not an 

implementable alternative that specifies land uses and management but is instead a discussion of impacts 

that could affect the management decisions in Alternatives A through D. 

3.9.3 Evaluation of Other Alternatives that would Reduce or Eliminate the Use, 

Occupancy, or Disposition of Public Lands Needed for Subsistence Purposes 

Alternatives that would reduce or eliminate other uses of public lands otherwise needed for subsistence 

include the alternatives that are presented and analyzed in Chapters 2 and 3 of the Draft BSWI RMP/EIS. 

These alternatives were created to represent a wide range of potential activities that could occur on BLMmanaged lands, along with management actions that would serve to protect specific resource values 

44 
Appendix O: ANILCA Preliminary Section 810 Evaluation BSWI Draft RMP/EIS 

following current national guidelines. Additional alternatives that were considered but not analyzed in 

detail are also discussed in Chapter 2 of the Draft BSWI RMP/EIS. 

3.9.4 Findings 

The cumulative case, as presented in this analysis, may result in a significant restriction of subsistence 

uses for the communities of Aniak, Anvik, Bethel, Crooked Creek, Chuathbaluk, Grayling, Holy Cross, 

Kaltag, Lime Village, Lower Kalskag, Upper Kalskag, Marshall, McGrath, Nikolai, Nulato, Russian 

Mission, Shageluk, Sleetmute, Stony River, and Unalakleet due to a decrease in resource availability, 

alteration in the distribution of resources, obstruction to access of resources, and an increase in 

competition from access by non-qualified subsistence. Increased mineral exploration and development 

due to the lifting of withdrawals, increased recreational activities occurring in or adjacent to the planning 

area, and climate influences (climate change) would impact resources important to subsistence users. 

With the trends of continued natural resource development and increased casual and recreational use in 

the planning area, subsistence resources would continue to be degraded and subsistence users would face 

increased competition for available resources by non-local users. For forest and woodland species and 

species in areas of medium to high mineral development that are important as subsistence resources, 

potential trends could degrade as a result of the cumulative effects of future development, climate change, 

and fragmentation of habitats. These species would experience a trend of increased degradation or 

lessened improvement. Donlin Gold’s proposed mine may result in a restriction to subsistence uses for 

communities along the Kuskokwim River and communities along the gas pipeline ROW. 

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BSWI Draft RMP/EIS Appendix O: ANILCA Preliminary Section 810 Evaluation 

Section 4 Notice and Hearings 

ANILCA § 810(a) provides that no “withdrawal, reservation, lease, permit, or other use, occupancy or

disposition of the public lands which would significantly restrict subsistence uses shall be effected” until 

the federal agency gives the required notice and holds a hearing in accordance with ANILCA § 810(a)(1) 

and (2). The BLM will provide notice in the Federal Register that it has made positive findings pursuant 

to ANILCA § 810 that the alternatives and the cumulative case presented in the Draft BSWI RMP/EIS 

meet the “may significantly restrict” threshold. As a result, public hearings will be held in the vicinity of 

the potentially affected communities in the planning area which are Aniak, Anvik, Bethel, Crooked 

Creek, Chuathbaluk, Grayling, Holy Cross, Kaltag, Lime Village, Lower Kalskag, Upper Kalskag, 

Marshall, McGrath, Nikolai, Nulato, Russian Mission, Shageluk, Sleetmute, Stony River, and Unalakleet. 

Notice of these hearings will also be provided by way of the local media, including the newspaper and the 

local radio station, with coverage to communities in the planning area. 

46 
 

 

Appendix O: ANILCA Preliminary Section 810 Evaluation BSWI Draft RMP/EIS 

Section 5 Subsistence Determinations Under ANILCA Sections 

810(a)(3)(A), (B), and (C) 

ANILCA § 810(a) provides that no “withdrawal, reservation, lease, permit, or other use, occupancy or

disposition of the public lands which would significantly restrict subsistence uses shall be effected” until 

the federal agency gives the required notice and holds a hearing in accordance with ANILCA § 810(a)(1) 

and (2) and makes the three determinations required by ANILCA § 810(a)(3)(A), (B), and (C). The three 

determinations are (1) that such a significant restriction of subsistence use is necessary, consistent with 

sound management principles for the utilization of the public lands, (2) that the proposed activity will 

involve the minimal amount of public lands necessary to accomplish the purposes of such use, occupancy, 

or other such disposition, and (3) that reasonable steps will be taken to minimize adverse impacts to 

subsistence uses and resources resulting from such actions (16 U.S.C. 3120(a)(3)(A), (B), and (C)). 

The BLM has found in this subsistence evaluation that each of the alternatives considered in the Draft 

BSWI RMP/EIS may significantly restrict subsistence uses. Therefore, the BLM will undertake the notice 

and hearing procedures required by ANILCA § 810(a)(1) and (2) in conjunction with release of the Draft 

BSWI RMP/EIS to solicit public comment from the potentially affected communities and subsistence 

users in Aniak, Anvik, Bethel, Crooked Creek, Chuathbaluk, Grayling, Holy Cross, Kaltag, Lime Village, 

Lower Kalskag, Upper Kalskag, Marshall, McGrath, Nikolai, Nulato, Russian Mission, Shageluk, 

Sleetmute, Stony River, and Unalakleet. 

The determination that the requirements of ANILCA § 810(a)(3)(A), (B), and (C) have been met will be 

analyzed in the Final ANILCA § 810 Evaluation, using input from the communities in which subsistence 

hearings will be held. 

Note: the following sections are placeholders for the Final Section 810 analysis. 

5.1 Significant Restriction of Subsistence Use is Necessary, Consistent with 

Sound Management Principles for the Utilization of Public Lands 

5.2 The Proposed Activity Will Involve the Minimal Amount of Public Lands 

Necessary to Accomplish the Purposes of such Use, Occupancy or Other 

Disposition 

5.3 Reasonable Steps will be Taken to Minimize Adverse Impacts upon 

Subsistence Uses and Resources Resulting from such Actions 

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BSWI Draft RMP/EIS Appendix O: ANILCA Preliminary Section 810 Evaluation 

Section 6 References 

ADF&G (Alaska Department of Fish and Game). 2014. Subsistence in Alaska: A Year 2014 Update. 

Division of Subsistence, Anchorage, Alaska. Accessed December 6, 2017. Available at: 

http://www.adfg.alaska.gov/static/home/subsistence/pdfs/subsistence_update_2014.pdf 

ADF&G. 2017. Alaska Department of Fish and Game “Agency Mission,” accessed December 6, 2017.

Available at: http://www.adfg.alaska.gov/index.cfm?adfg=about.mission 

ADNR (Alaska Department of Natural Resources). 1988. Kuskokwim Area Plan. Available at: 

http://dnr.alaska.gov/mlw/planning/areaplans/kuskokwim/ (accessed October 2018) 

ADNR. 1991. Tanana Basin Area Plan. Available at: 

http://dnr.alaska.gov/mlw/planning/areaplans/tanana/ (accessed October 2018). 

ADNR. 2002. Wood-Tikchik State Park Management Plan. Available at: 

http://dnr.alaska.gov/parks/plans/woodt/woodtpln.htm (accessed October 2018). 

ADOT (Alaska Department of Transportation and Public Facilities). 2002. Yukon Kuskokwim Delta 

Transportation Plan. Executive Summary. 

BLM (U.S. Bureau of Land Management). 1981. Management Framework Plan, Southwest Planning 

Area. Anchorage: BLM Anchorage District Office. Available at: https://eplanning.blm.gov/eplfrontoffice/eplanning/planAndProjectSite.do?methodName=dispatchToPatternPage¤tPageId=4 

8431 (accessed October 2016). 

BLM. 1986. Central Yukon Planning Area Resource Management Plan and Record of Decision, 

September 1986. Fairbanks District Office, Northwest Resource Area. Available at: 

https://eplanning.blm.gov/epl-frontoffice/eplanning/planAndProjectSite.do?methodName=dispatchToPatternPage¤tPageId=4 

8431 (accessed October 2016). 

BLM. 2005. Land Use Planning Handbook (H-1601-1). March 11, 2005. Washington, DC. Available at: 

https://www.ntc.blm.gov/krc/uploads/360/4_BLM%20Planning%20Handbook%20H-1601-1.pdf 

(accessed July 31, 2018). 

BLM. 2010. Instruction Manual, Bureau of Land Management (BLM) Instructions and Policy for 

Compliance with Section 810 the Alaska National Interest Lands Conservation Act (ANILCA). 

Available at: https://www.blm.gov/policy/im-ak-2011-008. 

BLM. 2015. Mineral Occurrence and Development Potential Report for Leasable Minerals within the 

Bering Sea – Western Interior Planning Area. Prepared by Zachary Lyons, Geologist, Energy and 

Minerals Branch, Division of Resources, BLM Alaska State Office. January 2015. Available at: 

https://eplanning.blm.gov/epl-front-office/projects/lup/36665/43890/58028/2015-01-

07_LeasableMineralsReport.pdf. 

DOWL. 2010. Western Alaska Access Planning Study Corridor Planning Report. Executive Summary. 

Prepared for State of Alaska, Department of Transportation and Public Facilities. Northern 

Region Planning. 14 p. 

Ikuta, H., C.L. Brown, and D.S. Koster. 2014. Subsistence Harvests in 8 Communities in the Kuskokwim 

River Drainage and Lower Yukon River, 2011. Alaska Department of Fish and Game, Division 

of Subsistence Technical Paper No. 396. Fairbanks, AK. 

48 
 

 

 

 

Appendix O: ANILCA Preliminary Section 810 Evaluation BSWI Draft RMP/EIS 

Kurtak, J., J. Hoppe, and R. Ellefson. 2017. Mineral Occurrence and Development Potential Report, 

Locatable and Salable Minerals. BLM Alaska Technical Report 63, July 2017. Available at: 

https://eplanning.blm.gov/epl-frontoffice/projects/lup/36665/145032/178739/2017_Minerals_Occurrence_and_Development_Potenti 

al_Report_Rev1.pdf. 

NovaGold. 2018. NovaGold. 2018. Donlin Gold Permitting. Available at: 

http://www.novagold.com/properties/donlin_gold/permitting/ (accessed September 7, 2018). 

NPS (National Park Service). 2009. Lake Clark National Park and Preserve Foundation Statement, 

October 2009. National Park Service, Alaska Regional Office. 

NPS. 2013. Lake Clark National Park and Preserve Draft Land Protection Plan. 

NPS. 2014. General Management Plan Amendment/Environmental Assessment. 

U.S. Census Bureau. 2010a. 2010 Census Fact Finder. Available at: 

https://factfinder.census.gov/faces/nav/jsf/pages/index.xhtml (accessed October 2016). 

U. S. Census Bureau. 2010b. 2010 Community Facts Search Bethel City. Available at: 

https://factfinder.census.gov/faces/nav/jsf/pages/community_facts.xhtml (accessed October 

2018). 

USACE (U.S. Army Corps of Engineers). 2018. Donlin Gold Project Final Environmental Impact 

Statement. Alaska District. 

USFWS (U.S. Fish and Wildlife Service). 2004. Land Conservation Plan for Yukon Delta National 

Wildlife Refuge, Bethel, Alaska. Available at: 

https://www.fws.gov/alaska/nwr/planning/pdf/YD_LCP.pdf (accessed October 2018) 

U. S. Fish and Wildlife Service (USFWS). 2008. Revised Comprehensive Conservation Plan: Innoko 

National Wildlife Refuge. 

WHPacific Inc., and Information Insights. 2015. Yukon-Kuskokwim Energy Corridor Plan. Executive 

Summary. Prepared for Nuvista Light and Electric Cooperative, Inc. Draft June 2015. 89 p. 

Wolfe, R. J., and R. J. Walker. 1987. Subsistence economies in Alaska: productivity, geography, and 

development impacts. Arctic Anthropology. 24(2): 56-81. 

49 
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50 
Appendix O: ANILCA Preliminary Section 810 Evaluation BSWI Draft RMP/EIS 

Appendix O-1: Impact Methodology and Results 

 

 

Appendix O: ANILCA Preliminary Section 810 Evaluation BSWI Draft RMP/EIS 

Impact Methodology 

The Alaska National Interest Lands Conservation Act (ANILCA) Preliminary Section 810 Evaluation 

performed for the Draft Bering–Sea Western Interior (BSWI) Resource Management Plan 

(RMP)/Environmental Impact Statement (EIS) included a quantitative and qualitative analysis to identify 

which communities may have a significant restriction to subsistence uses. 

The impact analysis focused on the following three management actions as they were identified to have 

the most potential to significantly restrict abundance of, availability to, or access to subsistence resources: 

• Areas open to locatable mineral development (in areas of high and medium locatable 

mineral potential) in known subsistence use areas. Impacts from locatable mineral 

development could occur to the availability of subsistence resources as wildlife species would 

likely move out of the area while exploration, operation, and reclamation activities occur. 

Subsistence users would likely make some adjustments to where they might traditionally harvest 

resources and then target resources that would be less affected by mineral development activities 

• Off-highway vehicle (OHV) closures to subsistence use areas. Summer subsistence OHV 

travel restrictions could obstruct existing routes to subsistence resources used by rural 

communities. 

• Right-of-way (ROW) exclusion or avoidance areas. Areas open for ROW development could 

impact availability of subsistence resources due to the long-term impact ROWs could have on 

availability of subsistence resources by changing species movement patterns. New ROWs would 

likely be associated with locatable mineral development for roads and pipelines needed for 

transportation of personnel, equipment, and resources. Access to subsistence resources and 

traditional harvest areas could be of low to high magnitude depending on the portions of the 

nearby communities’ harvest areas that are affected and could be adverse or beneficial.

Quantitative Analysis 

In determining the impacts threshold for quantitative analysis, for management actions (listed above) 

found to cover 10 percent or greater of the total subsistence use area for the community (regardless of 

ownership of land), a rebuttable presumption of significance was made. Areas with less than a 10 percent 

overlap could have specific impacts to individuals that use those areas; however, these impacts were 

presumed to be less than significant. If there is no overlap, there is an assumption of no significant 

adverse effect (i.e., no positive finding). 

Qualitative Analysis 

Potentially significant impacts identified per the quantitative analysis were next reviewed using a 

qualitative approach. For the qualitative analysis a potentially significant impact was determined if the 

analyzed management action intersects a known travel route; closure would occur during the season in 

which the resource is harvested; and/or closure would impact a resource that is heavily relied upon by a 

community. 

Assumptions 

Due to similarities between some communities we may be able to make assumptions to “reasonably

predict” subsistence use areas: 

O-1-1 
 

 

BSWI Draft RMP/EIS Appendix O: ANILCA Preliminary Section 810 Evaluation 

• Shageluk and Holy Cross are located within the Lower Middle Yukon River in an area that is 

referred to as the “GASH.” It was assumed that subsistence use information for these two 

communities is the same as other GASH communities for which we do have data (Grayling and 

Anvik). 

• For Marshall, subsistence uses would be similar to other communities that are upstream (such as 

Holy Cross). 

• Kaltag has similar subsistence uses as Unalakleet due to the proximity of the two communities. 

• Lime Village and Nulato are very small communities; however, they are dependent on specific 

caribou herds. 

O-1-2 
Appendix O: ANILCA Preliminary Section 810 Evaluation BSWI Draft RMP/EIS 

Impact Analysis Results 

A “(+)” symbol indicates a positive finding for one or more subsistence use areas within the community 

for the respective management action (LM = locatable minerals; OHV = subsistence OHV access; ROW 

= Right-of-Way) and a “(-)” symbol indicates a negative finding. Communities with a positive finding for 

a minimum of one subsistence use area for a minimum of one management action are considered to have 

a positive finding for the purposes of this analysis. 

Community Alternative A Alternative B Alternative C Alternative D 

Aniak 

LM (-) 

OHV (+) 

ROW (+) 

LM (+) 

OHV (-) 

ROW (+) 

LM (+) 

OHV (-) 

ROW (+) 

LM (+) 

OHV (+) 

ROW (+) 

Anvik 

LM (-) 

OHV (+) 

ROW (+) 

LM (-) 

OHV (+) 

ROW (-) 

LM (-) 

OHV (+) 

ROW (-) 

LM (-) 

OHV (+) 

ROW (+) 

Bethel 

LM (-) 

OHV (+) 

ROW (+) 

LM (-) 

OHV (-) 

ROW (-) 

LM (-) 

OHV (-) 

ROW (-) 

LM (-) 

OHV (+) 

ROW (-) 

Crooked Creek 

LM (-) 

OHV (+) 

ROW (+) 

LM (+) 

OHV (-) 

ROW (+) 

LM (+) 

OHV (-) 

ROW (+) 

LM (+) 

OHV (+) 

ROW (+) 

Chuathbaluk 

LM (+) 

OHV (+) 

ROW (+) 

LM (+) 

OHV (-) 

ROW (-) 

LM (+) 

OHV (-) 

ROW (-) 

LM (+) 

OHV (+) 

ROW (+) 

Grayling 

LM (-) 

OHV (+) 

ROW (+) 

LM (-) 

OHV (+) 

ROW 

LM (-) 

OHV (+) 

ROW (+) 

LM (-) 

OHV (+) 

ROW (+) 

Holy Cross 

LM (-) 

OHV (+) 

ROW (+) 

LM (-) 

OHV (-) 

ROW (+) 

LM (-) 

OHV (-) 

ROW (+) 

LM (-) 

OHV (+) 

ROW (+) 

Kaltag 

LM (-) 

OHV (+) 

ROW (+) 

LM (-) 

OHV (+) 

ROW (+) 

LM (-) 

OHV (+) 

ROW (+) 

LM (-) 

OHV (+) 

ROW (+) 

Lime Village 

LM (-) 

OHV (+) 

ROW (+) 

LM (-) 

OHV (+) 

ROW (+) 

LM (-) 

OHV (+) 

ROW (+) 

LM (-) 

OHV (+) 

ROW (+) 

Lower Kalskag 

LM (+) 

OHV (+) 

ROW (+) 

LM (+) 

OHV (-) 

ROW (-) 

LM (+) 

OHV (-) 

ROW (+) 

LM (+) 

OHV (+) 

ROW (+) 

Marshall 

LM (-) 

OHV (+) 

ROW (+) 

LM (-) 

OHV (-) 

ROW (+) 

LM (-) 

OHV (-) 

ROW (+) 

LM (-) 

OHV (+) 

ROW (+) 

McGrath 

LM (-) 

OHV (+) 

ROW (+) 

LM (+) 

OHV (+) 

ROW (+) 

LM (+) 

OHV 

ROW (+) 

LM (+) 

OHV (+) 

ROW (+) 

Nikolai 

LM (-) 

OHV (+) 

ROW (+) 

LM (-) 

OHV (+) 

ROW (+) 

LM (-) 

OHV (+) 

ROW (+) 

LM (-) 

OHV (+) 

ROW (+) 

Nulato 

LM (-) 

OHV (+) 

ROW (+) 

LM (-) 

OHV (-) 

ROW (-) 

LM (-) 

OHV (-) 

ROW (-) 

LM (-) 

OHV (+) 

ROW (-) 

Russian Mission 

LM (-) 

OHV (+) 

ROW (+) 

LM (-) 

OHV (-) 

ROW (-) 

LM (-) 

OHV (-) 

ROW (+) 

LM (-) 

OHV (+) 

ROW (+) 

Shageluk 

LM (-) 

OHV (+) 

ROW (+) 

LM (-) 

OHV (+) 

ROW (-) 

LM (-) 

OHV (+) 

ROW (+) 

LM (-) 

OHV (+) 

ROW (+) 

Sleetmute 

LM (-) 

OHV (+) 

ROW (+) 

LM (+) 

OHV (+) 

ROW (+) 

LM (+) 

OHV (+) 

ROW (+) 

LM (+) 

OHV (+) 

ROW (+) 

Stony River 

LM (-) 

OHV (+) 

ROW (+) 

LM (-) 

OHV (+) 

ROW (-) 

LM (-) 

OHV (+) 

ROW (+) 

LM (-) 

OHV (+) 

ROW (+) 

O-1-3 
 

 

 

BSWI Draft RMP/EIS Appendix O: ANILCA Preliminary Section 810 Evaluation 

Community Alternative A Alternative B Alternative C Alternative D 

Unalakleet 

LM (-) 

OHV (+) 

ROW (+) 

LM (-) 

OHV (+) 

ROW (+) 

LM (-) 

OHV (+) 

ROW (+) 

LM (-) 

OHV (+) 

ROW (+) 

Upper Kalskag 

LM (+) 

OHV (+) 

ROW (+) 

LM (+) 

OHV (-) 

ROW (+) 

LM (+) 

OHV (-) 

ROW (+) 

LM (+) 

OHV (+) 

ROW (+) 

O-1-4 
Appendix O: ANILCA Preliminary Section 810 Evaluation BSWI Draft RMP/EIS 

Impact Analysis Results—Aniak 

Aggregated 

Subsistence 

Use Category 

Species 

Included in 

Aggregated 

Category1 

Annual 

Pounds of 

Resource 

Harvested2 

Alternative A 

Significant Impact? [POSITIVE FINDING?] 

Alternative B 

Significant Impact? [POSITIVE FINDING?] 

Alternative C 

Significant Impact? [POSITIVE FINDING?] 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Alternative D 

Significant Impact? [POSITIVE FINDING?] 

Hunting and 

Trapping (LLM) 

Black Bear 

Caribou 

Moose 

41.2 

LM: 3% of use area. Closest open area is located ~25 

miles from the town. It covers a portion of the Kolmakof 

River, but a majority of the river corridor is withdrawn. 

Negative (-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

LM: 2% of use area. Closest open area is located ~15 

miles from the village, but most areas located 20 miles or 

more from town. Open areas are located towards the 

northern and eastern boundaries of the use polygon, and 

generally leave areas around waterways clear. There is a 

potential chokepoint that could occur along the 

Kuskokwim River near the confluence of Kolmakof River, 

though travel could still take place on the Kuskokwim 

River itself. Additionally, there is a route along a valley 

area that is withdrawn from locatable and may serve as a 

travel route. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter use. 40% 

of the use area limits summer casual use to existing trails. 

This same 40% is also limited to snowmobiles only for 

casual winter use. Therefore, there is no access 

restriction for subsistence uses and the greatest 

protection against habitat degradation and competing 

uses, as compared to Alternative A. Negative (-). 

ROW: 12% of use area would be open to ROW location, 

27% would be ROW avoidance areas, and .6% would be 

ROW exclusion areas. LLM are the second most heavily 

harvested resource (by weight) for Aniak. This alternative 

would minimize habitat fragmentation and degradation in 

these areas, as compared to Alternative A, but may still 

have a significant impact. Positive (+). 

LM: 7% of use area. Closest open area is located ~15 

miles from the village, but most areas located 20 miles or 

more from town. Open areas are located towards the 

northern and eastern boundaries of the use polygon, and 

generally leave areas around waterways clear. There is a 

potential chokepoint that could occur along the 

Kuskokwim River near the confluence of Kolmakof River, 

though travel could still take place on the Kuskokwim 

River itself even if this section were fully developed. 

Larger amount of land impacted than Alternative A. LLM 

are the second most heavily harvested resource (by 

weight) for Aniak. Positive (+). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter use. 40% 

of the use area limits summer casual use to existing trails. 

There is no limit on casual winter use. Therefore, there is 

no access restriction for subsistence uses and some 

protection against habitat degradation and competing 

uses, as compared to Alternative A. Negative (-). 

ROW: 20% of the use area is open to ROW location, 20% 

would be ROW avoidance areas, and 0% would be ROW 

exclusion areas. LLM are the second most heavily 

harvested resource (by weight) for Aniak. This could have 

a potentially significant impact on subsistence uses and 

resources, but is less than Alternative A, which has no 

restrictions. Positive (+). 

LM: Same as Alternative C. Positive (+). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

ROW: 31% of the use area would be open to ROW 

location, and 9% of the use area would be a ROW 

avoidance area. LLM are the second most heavily 

harvested resource (by weight) for Aniak. This could have 

a potentially significant impact on subsistence uses and 

resources, but is less than Alternative A, which has no 

restrictions. Positive (+). 

Hunting and 

Trapping (SLM) SLM 3.2 

LM: 3% of use area. Closest open area is located ~25 

miles from the town. The open areas are concentrated in 

the Kolmakof River watershed and cross portions of 

Kolmakof River, Quinn Creek, and Getmuna Creek. 

Majority of SLM area is closer to the village and does not 

overlap with high and medium potential mineral decision 

areas. Negative (-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

LM: 2% of use area. Closest open area that overlaps with 

use polygon is over 20 miles from the village. The open 

areas are concentrated in the Kolmakof River watershed, 

but do not cross the Kolmakof River or Getmuna Creek. A 

small portion of Quinn Creek is open. Majority of SLM 

area is closer to the village and does not overlap with 

high and medium potential mineral decision areas. Less 

impacts as compared to Alternative A. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter use. 32% 

of the use area limits summer casual use to existing trails. 

This same 32% is also limited to snowmobiles only for 

casual winter use. Therefore, there is no access 

restriction for subsistence uses and the greatest 

protection against habitat degradation and competing 

uses, as compared to Alternative A. Negative (-). 

ROW: 9% of use area would be open to ROW location, 

23% would be ROW avoidance areas, and .4% would be 

ROW exclusion areas. This alternative would minimize 

habitat fragmentation and degradation in these areas, as 

compared to Alternative A. Negative (-). 

LM: 8% of use area. Closest open area that overlaps with 

use polygon is over 20 miles from the village. The open 

areas are concentrated in the Kolmakof River watershed 

and cross portions of Kolmakof River, Quinn Creek, and 

Getmuna Creek. Larger amount of land impacted than 

Alternative A. Positive (+). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter use. 32% 

of the use area limits summer casual use to existing trails. 

This same 32% is also limited to snowmobiles only for 

casual winter use. Therefore, there is no access 

restriction for subsistence uses and the greatest 

protection against habitat degradation and competing 

uses, as compared to Alternative A. Negative (-). 

ROW: 15% of use area would be open to ROW location, 

17% would be ROW avoidance areas, and 0% would be 

ROW exclusion areas. This alternative would minimize 

habitat fragmentation and degradation in these areas as 

compared to Alternative A but may still have significant 

impacts. Positive (+). 

LM: Same as Alternative C. Positive (+). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

ROW: 25% of use area would be open to ROW location, 

7% would be ROW avoidance areas, and 0% would be 

ROW exclusion areas. This alternative would minimize 

habitat fragmentation and degradation in these areas as 

compared to Alternative A but may still have significant 

impacts. Positive (+). 

O-1-5 
BSWI Draft RMP/EIS Appendix O: ANILCA Preliminary Section 810 Evaluation 

Aggregated 

Subsistence 

Use Category 

Species 

Included in 

Aggregated 

Category1 

Annual 

Pounds of 

Resource 

Harvested2 

Alternative A 

Significant Impact? [POSITIVE FINDING?] 

Alternative B 

Significant Impact? [POSITIVE FINDING?] 

Alternative C 

Significant Impact? [POSITIVE FINDING?] 

 

 

 

 

 

 

 

 

 

 

 

 

Alternative D 

Significant Impact? [POSITIVE FINDING?] 

Hunting (Birds) Ducks 

Geese 0.0 

LM: No overlap in open areas and use areas. Negative (-

). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

LM: .06% of use area. Open areas are along edges of 

use area along the Kuskokwim River and do not appear 

to block travel routes (i.e., there is area along the river 

shore and the river itself to travel further into the use 

area). Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter use. 19% 

of the use area limits summer casual use to existing trails. 

This same 19% is also limited to snowmobiles only for 

casual winter use. Therefore, there is no access 

restriction for subsistence uses and the greatest 

protection against habitat degradation and competing 

uses, as compared to Alternative A. Negative (-). 

ROW: 13% of use area would be open to ROW location, 

4% would be ROW avoidance areas, and 3% would be 

ROW exclusion areas. This alternative would minimize 

habitat fragmentation and degradation in these areas, as 

compared to Alternative A, but is for a resource that is not 

heavily harvested (0 lbs. in 2009). Negative (-). 

LM: .06% of use area. Open areas are along edges of 

use area along the Kuskokwim River and do not appear 

to block travel routes (i.e., though a portion of the use 

area land upstream of the confluence of Seuter Creek is 

open, the river itself can be used to travel further into the 

use area). Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter use. 19% 

of the use area limits summer casual use to existing trails. 

Therefore, there is no access restriction for subsistence 

uses and greater protection against habitat degradation 

and competing uses, as compared to Alternative A. 

Negative (-). 

ROW: 16% of use area would be open to ROW location, 

0% would be ROW avoidance areas, and 3% would be 

ROW exclusion areas. This alternative would minimize 

habitat fragmentation and degradation in these areas, as 

compared to Alternative A, but is for a resource that is not 

heavily harvested (0 lbs. in 2009). Negative (-). 

LM: Same as Alternative C. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

ROW: 17% of use area would be open to ROW location, 

2% would be ROW avoidance areas, and 0% would be 

ROW exclusion areas. This alternative would minimize 

habitat fragmentation and degradation in these areas as 

compared to Alternative A but is for a resource that is not 

heavily harvested (0 lbs. in 2009). Negative (-). 

Fishing 

Salmon 

Trout 

Whitefish 

Salmon: 

190.04 

NonSalmon 

Fish: 

49.58 

LM: Closest areas to high/med mineral potential areas 

are withdrawn from locatable mining. The closest open 

area to fishing locations is over 5 miles away. Negative 

(-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses because OHV use is 

unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

LM: Areas open to locatable minerals with high/med 

potential are near (right along the shoreline) to fishing 

locations along the Kuskokwim River (near the 

confluence of Kolmakof River). Fishing resources are the 

majority of the subsistence resources harvested by this 

community (in lbs.) and make up over 78% of the harvest 

in 2009. Positive (+). 

OHV: No limits to access for subsistence users. Casual 

summer use is limited to existing trails in several areas 

close to fishing locations, and winter casual use is limited 

to snowmobiles only in these same areas. Negative (-). 

ROW: Fish are the most heavily harvested resource (by 

weight) for Aniak. This alternative would minimize habitat 

fragmentation and degradation in these areas, as 

compared to Alternative A, but may still have a significant 

impact due to the prevalence of open and avoidance 

areas near fishing locations. Positive (+). 

LM: Areas open to locatable minerals with high/med 

potential are near (right along the shoreline) to fishing 

locations along the Kuskokwim River (near the 

confluence of Kolmakof River). Fishing resources are the 

majority of the subsistence resources harvested by this 

community (in lbs.) and make up over 78% of the harvest 

in 2009. Positive (+). 

OHV: No limits to access for subsistence users. Casual 

summer use is limited to existing trails in several areas 

close to fishing locations, but there are no limitations on 

winter casual use. Therefore, there is no access 

restriction for subsistence uses and greater protection 

against habitat degradation and competing uses, as 

compared to Alternative A. Negative (-). 

ROW: Fish are the most heavily harvested resource (by 

weight) for Aniak. This alternative would minimize habitat 

fragmentation and degradation in these areas, as 

compared to Alternative A, but may still have a significant 

impact due to the prevalence of open and avoidance 

areas near fishing locations. Positive (+). 

LM: Areas open to locatable minerals with high/med 

potential are near (right along the shoreline) to fishing 

locations along the Kuskokwim River (near the 

confluence of Kolmakof River). Fishing resources are the 

majority of the subsistence resources harvested by this 

community (in lbs.) and make up over 78% of the harvest 

in 2009. Positive (+). 

OHV: Summer casual use is not restricted to existing 

trails, which could lead to degradation of habitat and 

conflict from competing uses. Winter casual use is not 

restricted to snowmobiles only, so the entire use area is 

open to all winter OHV uses. This is the same impact as 

Alternative A. Fish is the most harvested resources (by 

weight) in this community. Positive (+). 

ROW: Numerous areas open to ROW near fishing 

locations that could impede access and decrease 

availability of resources. Positive (+). 

O-1-6 
Appendix O: ANILCA Preliminary Section 810 Evaluation BSWI Draft RMP/EIS 

Aggregated 

Subsistence 

Use Category 

Species 

Included in 

Aggregated 

Category1 

Annual 

Pounds of 

Resource 

Harvested2 

Alternative A 

Significant Impact? [POSITIVE FINDING?] 

Alternative B 

Significant Impact? [POSITIVE FINDING?] 

Alternative C 

Significant Impact? [POSITIVE FINDING?] 

 

 

 

 

 

Alternative D 

Significant Impact? [POSITIVE FINDING?] 

Gathering Berries 

Plants 5.8 

LM: No overlap in open areas and use areas. Negative 

(-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

LM: .06% of use area. Some open areas along the 

Kuskokwim River on both sides of the bank. However, 

does not appear to block travel routes as the river is still 

accessible, as are portions of the bank on either side. 

Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter use. 19% 

of the use area limits summer casual use to existing trails. 

This same 19% is also limited to snowmobiles only for 

casual winter use. Therefore, there is no access 

restriction for subsistence uses and the greatest 

protection against habitat degradation and competing 

uses, as compared to Alternative A. Negative (-). 

ROW: 8% of use area would be open to ROW location, 

12% would be ROW avoidance areas, and 0% would be 

ROW exclusion areas. This alternative would minimize 

habitat fragmentation and degradation in these areas, as 

compared to Alternative A. Negative (-). 

LM: .09% of use area. Some open areas along the 

Kuskokwim River on both sides of the bank. However, 

does not appear to block travel routes as the river is still 

accessible, as are portions of the bank on either side. 

Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter use. 19% 

of the use area limits summer casual use to existing trails. 

0% of the use area has limitations placed on winter 

casual use and therefore all winter OHVs are allowed. 

Gathering does not make up a substantial part of the 

harvesting in this community (in lbs.). Negative (-). 

ROW: 10% of use area would be open to ROW location, 

9% would be ROW avoidance areas, and 0% would be 

ROW exclusion areas. This alternative would minimize 

habitat fragmentation and degradation in these areas, as 

compared to Alternative A, but is to a threshold that could 

be significant even though gathering does not make up a 

substantial part of the harvesting for this community (in 

lbs.). Positive (+). 

LM: Same as Alternative C. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

ROW: 16% of use area would be open to ROW location, 

3% would be ROW avoidance areas, and 0% would be 

ROW exclusion areas. This alternative would minimize 

habitat fragmentation and degradation in these areas, as 

compared to Alternative A, but is to a threshold that could 

be significant even though gathering does not make up a 

substantial part of the harvesting for this community (in 

lbs.). Positive (+). 

Notes: 

LM: Locatable minerals with med/high potential 

OHV: travel decisions relating to OHV use 

ROW: Right-of-way decisions 

Impact analysis to determine whether there is a positive or negative finding is based on an assessment of magnitude, duration, extent, likelihood, and intensity. 

1) This column shows which species the BSWI EIS Team has GIS data for at the time of the DEIS release. Communities may have differing sets of data available or may be missing data completely for an aggregated category. In most instances where data sets for "Hunting and Trapping (SLM)" were 

available, the subsistence use area did not specify which species are included in the use area. 

2) Data is from the ADF&G Community Subsistence Information System (CSIS), available at http://www.adfg.alaska.gov/sb/CSIS/ 

O-1-7 
BSWI Draft RMP/EIS Appendix O: ANILCA Preliminary Section 810 Evaluation 

Impact Analysis Results—Anvik 

Aggregated 

Subsistence 

Use Category 

Species 

Included in 

Aggregated 

Category1 

Annual 

Pounds of 

Resource 

Harvested2 

Alternative A 

Significant Impact? [POSITIVE FINDING?] 

Alternative B 

Significant Impact? [POSITIVE FINDING?] 

Alternative C 

Significant Impact? [POSITIVE FINDING?] 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Alternative D 

Significant Impact? [POSITIVE FINDING?] 

LM: No overlap in open areas and use areas. Negative 

(-). 

LM: No overlap in open areas and use areas. Negative 

(-). 

Hunting and 

Trapping (LLM) Moose 90.0 

LM: No overlap in open areas and use areas. Negative 

(-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

OHV: 0% of use area is restricted for summer 

subsistence use and 8% is restricted for winter 

subsistence use. 36% of the use area limits summer 

casual use to existing trails. This same 36% is also 

limited to snowmobiles only for casual winter use. There 

would be some access restriction for subsistence uses in 

the 8% of the use area that limits winter subsistence use 

to snowmobiles only. This alternative provides the 

greatest protection against habitat degradation and 

competing uses, as compared to Alternative A. While the 

access restrictions do not meet the 10% threshold for 

impacts, this is one of the top harvested resources in the 

community (in lbs.). Positive (+). 

ROW: 3% of use area would be open to ROW location, 

15% would be ROW avoidance areas, and 18% would be 

ROW exclusion areas. This alternative would minimize 

habitat fragmentation and degradation in these areas, as 

compared to Alternative A. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 8% is restricted for winter 

subsistence use. 36% of the use area limits summer 

casual use to existing trails. 8% is also limited to 

snowmobiles only for casual winter use. There would be 

some access restriction for subsistence uses in the 8% of 

the use area that limits winter subsistence use to 

snowmobiles only. This alternative provides the better 

protection against habitat degradation and competing 

uses, as compared to Alternative A. While the access 

restrictions do not meet the 10% threshold for impacts, 

this is one of the top harvested resources in the 

community (in lbs.). Positive (+). 

ROW: 4% of use area would be open to ROW location, 

23% would be ROW avoidance areas, and 10% would be 

ROW avoidance areas for linear realty actions. This 

alternative would decrease habitat fragmentation and 

degradation in these areas, as compared to Alternative A. 

Negative (-). 

LM: No overlap in open areas and use areas. Negative 

(-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

ROW: 6% of use area would be open to ROW location, 

30% would be ROW avoidance areas. This alternative 

would decrease habitat fragmentation and degradation in 

these areas, as compared to Alternative A. Negative (-). 

Hunting and 

Trapping (SLM) 

Beaver 

SLM 19.3 

LM: No overlap in open areas and use areas. Negative 

(-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

LM: No overlap in open areas and use areas. Negative 

(-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 5% is restricted for winter 

subsistence use. 26% of the use area limits summer 

casual use to existing trails. This same 26% is also 

limited to snowmobiles only for casual winter use. There 

would be some access restriction for subsistence uses in 

the 5% of the use area that limits winter subsistence use 

to snowmobiles only. This alternative provides the 

greatest protection against habitat degradation and 

competing uses, as compared to Alternative A. The 

access restrictions do not hit 10% of the use area, and 

this is not one of the top harvested resources. Negative 

(-). 

ROW: 3% of use area would be open to ROW location, 

4% would be ROW avoidance areas, and 19% would be 

ROW exclusion areas. This alternative would minimize 

habitat fragmentation and degradation in these areas, as 

compared to Alternative A. Negative (-). 

LM: No overlap in open areas and use areas. Negative 

(-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 5% is restricted for winter 

subsistence use. 26% of the use area limits summer 

casual use to existing trails. There would be some access 

restriction for subsistence and casual uses in the 5% of 

the use area that limits winter OHV use to snowmobiles 

only. This alternative provides higher protection against 

habitat degradation and competing uses, as compared to 

Alternative A, though it provides some access restrictions 

to portions of the use area. Negative (-). 

ROW: 6% of use area would be open to ROW location, 

1% would be ROW avoidance areas, and 19% would be 

ROW avoidance areas for linear realty actions. This 

alternative would decrease habitat fragmentation and 

degradation in these areas, as compared to Alternative A. 

Negative (-). 

LM: No overlap in open areas and use areas. Negative 

(-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

ROW: 25% of use area would be open to ROW location, 

1% would be ROW avoidance areas. This alternative 

would decrease habitat fragmentation and degradation in 

these areas, as compared to Alternative A, but would rise 

to a level of significance because of the amount of land 

impacted. Positive (+). 

O-1-8 
Appendix O: ANILCA Preliminary Section 810 Evaluation BSWI Draft RMP/EIS 

Aggregated 

Subsistence 

Use Category 

Species 

Included in 

Aggregated 

Category1 

Annual 

Pounds of 

Resource 

Harvested2 

Alternative A 

Significant Impact? [POSITIVE FINDING?] 

Alternative B 

Significant Impact? [POSITIVE FINDING?] 

Alternative C 

Significant Impact? [POSITIVE FINDING?] 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Alternative D 

Significant Impact? [POSITIVE FINDING?] 

Hunting (Birds) 

Ducks 

Geese 

Ptarmigan 

Grouse 

12.8 

LM: No overlap in open areas and use areas. Negative 

(-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

LM: No overlap in open areas and use areas. Negative 

(-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 2% is restricted for winter 

subsistence use. 21% of the use area limits summer 

casual use to existing trails. This same 21% is also 

limited to snowmobiles only for casual winter use. There 

would be some access restriction for subsistence uses in 

the 2% of the use area that limits winter subsistence use 

to snowmobiles only. This alternative provides the 

greatest protection against habitat degradation and 

competing uses, as compared to Alternative A. While the 

access restrictions do not hit 10% of the use area, and 

this is not one of the top harvested resources. Negative 

(-). 

ROW: 3% of use area would be open to ROW location, 

4% would be ROW avoidance areas, and 14% would be 

ROW exclusion areas. This alternative would minimize 

habitat fragmentation and degradation in these areas, as 

compared to Alternative A. Negative (-). 

LM: No overlap in open areas and use areas. Negative 

(-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 2% is restricted for winter 

subsistence use. 21% of the use area limits summer 

casual use to existing trails. There would be some access 

restriction for subsistence and casual uses in the 2% of 

the use area that limits winter OHV use to snowmobiles 

only. This alternative provides higher protection against 

habitat degradation and competing uses, as compared to 

Alternative A, though it provides some access restrictions 

to portions of the use area. Negative (-). 

ROW: 4% of use area would be open to ROW location, 

9% would be ROW avoidance areas, and 8% would be 

ROW avoidance areas for linear realty actions. This 

alternative would decrease habitat fragmentation and 

degradation in these areas, as compared to Alternative A. 

Negative (-). 

LM: No overlap in open areas and use areas. Negative 

(-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

ROW: 25% of use area would be open to ROW location, 

1% would be ROW avoidance areas. This alternative 

would decrease habitat fragmentation and degradation in 

these areas, as compared to Alternative A, but would rise 

to a level of significance because of the amount of land 

impacted. Positive (+). 

LM: No overlap in open areas and use areas. Negative 

(-). 

LM: No overlap in open areas and use areas. Negative 

(-). LM: No overlap in open areas and use areas. Negative 

(-). 

Fishing 

Burbot 

Chinook 

Chum 

Northern 

Pike 

Pike 

Salmon: 

231.8 

Nonsalmon 

LM: No overlap in open areas and use areas. Negative 

(-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

OHV: Some areas limit winter subsistence use to 

snowmobiles only, but if these areas are accessed for 

any winter fishing, the access would not be impeded by 

these areas closed to larger winter OHVs as the river 

areas up to the fishing locations are open to all 

subsistence OHV use. Negative (-). 

OHV: Some areas limit winter subsistence use to 

snowmobiles only, but if these areas are accessed for 

any winter fishing, the access would not be impeded by 

these areas closed to larger winter OHVs as the river 

areas up to the fishing locations are open to all 

subsistence OHV use. Negative (-). 

OHV: Access to fishing areas will not be impacted by 

OHV use as the locations are mostly within a 10-mile 

radius from the community and directly accessible 

through the Yukon River and a tributary creek that is near 

the Anvik community. Negative (-). 

Salmon 

Sheefish 

Whitefish 

Fish: 

34.8 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

ROW: None of the fishing locations would be covered by 

an area that is open to ROWs, though some spots are 

located close to areas that are ROW avoidance areas. 

Access would not be impeded by ROWs as the Yukon 

River is able to be used to access these fishing spots 

unimpeded. Negative (-). 

ROW: None of the fishing locations would be covered by 

an area that is open to ROWs, though some spots are 

located close to areas that are ROW avoidance areas. 

Access would not be impeded by ROWs as the Yukon 

River is able to be used to access these fishing spots 

unimpeded. Negative (-). 

ROW: None of the fishing locations would be covered by 

an area that is open to ROWs, though some spots are 

located close to areas that are ROW avoidance areas. 

Access would not be impeded by ROWs as the Yukon 

River is able to be used to access these fishing spots 

unimpeded. Negative (-). 

Gathering Berries 

Greens 2.2 

LM: No overlap in open areas and use areas. Negative 

(-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

LM: No overlap in open areas and use areas. Negative 

(-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. 31% of the use area limits summer 

casual use to existing trails. This same 31% is also 

limited to snowmobiles only for casual winter use. There 

would be no access restriction for subsistence uses. This 

alternative provides the greatest protection against 

habitat degradation and competing uses, as compared to 

Alternative A. Negative (-) 

ROW: 3% of use area would be open to ROW location, 

16% would be ROW avoidance areas, and 13% would be 

ROW exclusion areas. This alternative would minimize 

habitat fragmentation and degradation in these areas, as 

compared to Alternative A. Negative (-). 

LM: No overlap in open areas and use areas. Negative 

(-). 

OHV: OHV: 0% of use area is restricted for summer 

subsistence use and 5% is restricted for winter 

subsistence use. 26% of the use area limits summer 

casual use to existing trails. There would be some access 

restriction for subsistence and casual uses in the 5% of 

the use area that limits winter OHV use to snowmobiles 

only. This alternative provides higher protection against 

habitat degradation and competing uses, as compared to 

Alternative A, though it provides some access restrictions 

to portions of the use area. Negative (-). 

ROW: 3% of use area would be open to ROW location, 

23% would be ROW avoidance areas, and 6% would be 

ROW avoidance areas for linear realty actions. This 

alternative would decrease habitat fragmentation and 

degradation in these areas, as compared to Alternative A. 

Negative (-). 

LM: No overlap in open areas and use areas. Negative 

(-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

ROW: 8% of use area would be open to ROW location, 

23% would be ROW avoidance areas. This alternative 

would decrease habitat fragmentation and degradation in 

these areas, as compared to Alternative A. Negative (-). 

Notes: 

LM: Locatable minerals with med/high potential 

OHV: travel decisions relating to OHV use 

ROW: Right-of-way decisions 

O-1-9 
 

 

BSWI Draft RMP/EIS Appendix O: ANILCA Preliminary Section 810 Evaluation 

Impact analysis to determine whether there is a positive or negative finding is based on an assessment of magnitude, duration, extent, likelihood, and intensity. 

1) This column shows which species the BSWI EIS Team has GIS data for at the time of the DEIS release. Communities may have differing sets of data available or may be missing data completely for an aggregated category. In most instances where data sets for "Hunting and Trapping (SLM)" were 

available, the subsistence use area did not specify which species are included in the use area. 

2) Data is from the ADF&G Community Subsistence Information System (CSIS), available at http://www.adfg.alaska.gov/sb/CSIS/ 

O-1-10 
Appendix O: ANILCA Preliminary Section 810 Evaluation BSWI Draft RMP/EIS 

Impact Analysis Results—Bethel 

Aggregated 

Subsistence 

Use Category 

Species 

Included in 

Aggregated 

Category1 

Annual 

Pounds of 

Resource 

Harvested2 

Alternative A 

Significant Impact? [POSITIVE FINDING?] 

Alternative B 

Significant Impact? [POSITIVE FINDING?] 

Alternative C 

Significant Impact? [POSITIVE FINDING?] 

 

 

 

 

 

 

 

 

 

 

Alternative D 

Significant Impact? [POSITIVE FINDING?] 

LM: Close to 0% of use area overlaps with LM with 

med/high potential. Negative (-). 

LM: 1% of use area overlaps with LM with med/high 

potential. Negative (-). LM: Same as Alt C. Negative (-). 

Hunting and 

Trapping (LLM) 

Black Bear 

Brown Bear 

Caribou 

43.3 

LM: Close to 0% of use area overlaps with LM with 

med/high potential. Negative (-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive. 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. 4% of the use area limits summer 

casual use to existing trails. This same 4% is also limited 

to snowmobiles only for casual winter use. Therefore, 

there is no access restriction for subsistence uses and 

the greatest protection against habitat degradation and 

competing uses, as compared to Alternative A. Negative 

(-). 

ROW: 1% of use area would be open to ROW location, 

3% would be ROW avoidance areas, and close to 0% 

would be ROW exclusion areas. This alternative would 

minimize habitat fragmentation and degradation in these 

areas, as compared to Alternative A. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. 4% of the use area limits summer 

casual use to existing trails. 0% of the use area has 

limitations placed on winter casual use and therefore all 

winter OHVs are allowed. LLM does make up a 

substantial part of the harvesting in this community (in 

lbs.). Negative (-). 

ROW: 2% of use area would be open to ROW location, 

2% would be ROW avoidance areas, and close to 0% 

would be ROW avoidance areas for linear realty actions. 

This alternative would reduce habitat fragmentation and 

degradation in these areas, as compared to Alternative A. 

Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

ROW: 3% of use area would be open to ROW location, 

1% would be ROW avoidance areas. This alternative 

would minimize habitat fragmentation and degradation in 

these areas, as compared to Alternative A. Negative (-). 

Hunting (marine 

mammals) 

Beluga 

Seal 

Walrus 

3.2 No overlap No overlap No overlap No overlap 

Fishing 

Salmon 

Sheefish 

Whitefish 

Salmon: 

68.8 

Nonsalmon 

Fish: 

33.3 

LM: There is no overlap between this use area and the 

areas with med/high LM potential. Additionally, only one 

fishing location is near land that is open to LM with 

med/high potential. Majority of locations are over 100 

river miles downstream. Negative (-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

LM: There is no overlap between this use area and the 

areas with med/high LM potential. Additionally, only one 

fishing location is near land that is open to LM with 

med/high potential. Majority of locations are over 100 

river miles downstream. Negative (-). 

OHV: Majority of the fishing locations are not near BLM 

land. There is no restriction on access for subsistence 

users, and the limitations on casual summer and winter 

OHV use provide the highest degree of protection, as 

compared to Alternative A. Negative (-). 

ROW: Two fishing locations on the Kuskokwim River are 

near areas open to ROW development. The majority of 

the fishing locations, however, lie near the village and 

would be unimpacted by ROW development. Negative 

(-). 

LM: There is no overlap between this use area and the 

areas with med/high LM potential. Additionally, only one 

fishing location is near land that is open to LM with 

med/high potential. Majority of locations are over 100 

river miles downstream. Negative (-). 

OHV: Majority of the fishing locations are not near BLM 

land. There is no restriction on access for subsistence 

users, and the limitations on casual summer and winter 

OHV use provide a higher degree of protection, as 

compared to Alternative A. Negative (-). 

ROW: Two fishing locations on the Kuskokwim River are 

near areas open to ROW development. The majority of 

the fishing locations, however, lie near the village and 

would be unimpacted by ROW development. Negative (-) 

LM: Same as Alt C. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

ROW: Two fishing locations on the Kuskokwim River are 

near areas open to ROW development. The majority of 

the fishing locations, however, lie near the village and 

would be unimpacted by ROW development. Negative (-) 

Notes: 

LM: Locatable minerals with med/high potential 

OHV: travel decisions relating to OHV use 

ROW: Right-of-way decisions 

Impact analysis to determine whether there is a positive or negative finding is based on an assessment of magnitude, duration, extent, likelihood, and intensity. 

Available data for the Community of Bethel did not include hunting and trapping (small land mammals), hunting (birds), and gathering subsistence use areas. 

1) This column shows which species the BSWI EIS Team has GIS data for at the time of the DEIS release. Communities may have differing sets of data available or may be missing data completely for an aggregated category. In most instances where data sets for "Hunting and Trapping (SLM)" were 

available, the subsistence use area did not specify which species are included in the use area. 

2) Data is from the ADF&G Community Subsistence Information System (CSIS), available at http://www.adfg.alaska.gov/sb/CSIS/ 

O-1-11 
BSWI Draft RMP/EIS Appendix O: ANILCA Preliminary Section 810 Evaluation 

Impact Analysis Results—Crooked Creek 

Aggregated 

Subsistence 

Use Category 

Species 

Included in 

Aggregated 

Category1 

Annual 

Pounds of 

Resource 

Harvested2 

Alternative A 

Significant Impact? [POSITIVE FINDING?] 

Alternative B 

Significant Impact? [POSITIVE FINDING?] 

Alternative C 

Significant Impact? [POSITIVE FINDING?] 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Alternative D 

Significant Impact? [POSITIVE FINDING?] 

LM: 4% of use area. Closest open area is located ~25 

LM: Less than 1% of the use area would be open to 

locatable with high/med potential, and 6% would be 

withdrawn. Negative (-). 

LM: 6% of the use area would be open to locatable, with 

high/med potential. LLM are one of the most highly 

harvested resources for this community, and the impacts 

LM: Same as Alternative C. Positive (+). 

OHV: 0% of use area is restricted for summer 

Hunting and 

Trapping (LLM) 

Black Bear 

Moose 25.5 

miles from the village. Open areas are located towards 

the northern and eastern boundaries of the use polygon 

and leave most areas around waterways clear. Negative 

(-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. 57% of the use area limits summer 

casual use to existing trails. This same 57% is also 

limited to snowmobiles only for casual winter use. 

Therefore, there is no access restriction for subsistence 

uses and the greatest protection against habitat 

degradation and competing uses, as compared to 

Alternative A. Negative (-). 

would be greater than Alternative A. Positive (+). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. 57% of the use area limits summer 

casual use to existing trails. 0% of the use area has 

limitations placed on winter casual use and therefore all 

winter OHVs are allowed. Negative (-). 

ROW: 20% of use area would be open to ROW location, 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

ROW: 31% of use area would be open to ROW location, 

26% would be ROW avoidance areas. This alternative 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

ROW: 3% of use area would be open to ROW location, 

54% would be ROW avoidance areas, and 0% would be 

ROW exclusion areas. This alternative would minimize 

habitat fragmentation and degradation in these areas, as 

compared to Alternative A. Negative (-). 

37% would be ROW avoidance areas. This alternative 

would decrease habitat fragmentation and degradation in 

avoidance areas, as compared to Alternative A, but is 

over the threshold for impacts for the areas open to 

ROWs. Positive (+). 

would decrease habitat fragmentation and degradation in 

these areas, as compared to Alternative A, but is over the 

threshold for impacts for the areas open to ROWs. This 

could result in impacts to the availability of resources. 

Positive (+). 

LM: Less than 1% of the use area would be open to 

locatable with high/med potential. Negative (-). LM: Same as Alternative B. Negative (-). LM: Same as Alternative B. Negative (-). 

Hunting and 

Trapping (SLM) SLM 6.8 

LM: No land within the use area would be open. Negative 

(-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. 37% of the use area limits summer 

casual use to existing trails. This same 37% is also 

limited to snowmobiles only for casual winter use. 

Therefore, there is no access restriction for subsistence 

uses and the greatest protection against habitat 

degradation and competing uses, as compared to 

Alternative A. Negative (-). 

ROW: Close to 0% of use area would be open to ROW 

location, 37% would be ROW avoidance areas, and 0% 

would be ROW exclusion areas. This alternative would 

minimize habitat fragmentation and degradation in these 

areas, as compared to Alternative A. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. 37% of the use area limits summer 

casual use to existing trails. 0% of the use area has 

limitations placed on winter casual use and therefore all 

winter OHVs are allowed. SLM does not make up a 

substantial part of the harvesting in this community (in 

lbs.). Negative (-). 

ROW: 3% of use area would be open to ROW location, 

35% would be ROW avoidance areas, and 0% would be 

ROW exclusion areas. This alternative would minimize 

habitat fragmentation and degradation in these areas, as 

compared to Alternative A. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

ROW: 7% of use area would be open to ROW location, 

31% would be ROW avoidance areas, and 0% would be 

ROW exclusion areas. This alternative would minimize 

habitat fragmentation and degradation in these areas, as 

compared to Alternative A. Negative (-). 

LM: Less than 1% of the use area would be open to 

locatable with high/med potential. 0lbs of birds were 

harvested in 2009. Negative (-). LM: Same as Alternative A. Negative (-). LM: Same as Alternative A. Negative (-). 

Hunting (Birds) Ducks 

Geese 0.0 

LM: Less than 1% of the use area would be open to 

locatable with high/med potential. 0lbs of birds were 

harvested in 2009. Negative (-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. 3% of the use area limits summer 

casual use to existing trails. This same 3% is also limited 

to snowmobiles only for casual winter use. Therefore, 

there is no access restriction for subsistence uses and 

the greatest protection against habitat degradation and 

competing uses, as compared to Alternative A. 0lbs of 

birds were hunted according to 2009 data. Negative (-). 

ROW: 2% of use area would be open to ROW location, 

1% would be ROW avoidance areas, and 0% would be 

ROW exclusion areas. This alternative would minimize 

habitat fragmentation and degradation in these areas, as 

compared to Alternative A. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. 3% of the use area limits summer 

casual use to existing trails. 0% of the use area has 

limitations placed on winter casual use and therefore all 

winter OHVs are allowed. SLM does not make up a 

substantial part of the harvesting in this community (in 

lbs.). Negative (-). 

ROW: 2% of use area would be open to ROW location, 

1% would be ROW avoidance areas, and 0% would be 

ROW exclusion areas. This alternative would minimize 

habitat fragmentation and degradation in these areas, as 

compared to Alternative A. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

ROW: 3% of use area would be open to ROW location, 

0% would be ROW avoidance areas, and 0% would be 

ROW exclusion areas. This alternative would minimize 

habitat fragmentation and degradation in these areas, as 

compared to Alternative A. Negative (-). 

O-1-12 
Appendix O: ANILCA Preliminary Section 810 Evaluation BSWI Draft RMP/EIS 

Aggregated 

Subsistence 

Use Category 

Species 

Included in 

Aggregated 

Category1 

Annual 

Pounds of 

Resource 

Harvested2 

Alternative A 

Significant Impact? [POSITIVE FINDING?] 

Alternative B 

Significant Impact? [POSITIVE FINDING?] 

Alternative C 

Significant Impact? [POSITIVE FINDING?] 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Alternative D 

Significant Impact? [POSITIVE FINDING?] 

Fishing 

Salmon 

Trout 

Whitefish 

Salmon: 

171.1 

Nonsalmon 

Fish: 

29.2 

LM: No fishing locations would be near areas with 

med/high potential for locatable mineral development and 

the majority of the uses would be easily accessible from 

the village. The closest area is approximately 11 river 

miles from the furthest upstream fishing site. Negative (-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive. 

LM: There are a few portions of locatable mineral sites 

with high and medium potential directly upstream of 

fishing sports along Crooked Creek.82% of the harvested 

resources in 2009 (by lbs.) was fish. While most of the 

areas on the shorelines are withdrawn from mineral 

actions, areas within the water basin are open and are 

situated approximately 3.5 river miles from the closest 

fishing location. This is a greater impact than Alternative 

A. Positive (+). 

OHV: There are no restrictions to OHV use for 

subsistence users. Some restrictions for casual winter 

and summer use would provide protections to the habitat 

and resource, as compared to Alternative A. Negative (-). 

ROW: Numerous areas around known fishing locations 

for the community are open to ROW development. This 

could cause habitat degradation and introduce new 

competing users to the area. Fishing is the most heavily 

harvested resource (by weight) for the community. 

Positive (+). 

LM: There are a few portions of locatable mineral sites 

with high and medium potential directly upstream of 

fishing sports along Crooked Creek.82% of the harvested 

resources in 2009 (by lbs.) was fish. This is also greater 

impacts than Alternative A. Positive (+). 

OHV: There are no restrictions to OHV use for 

subsistence users. Some restrictions for casual winter 

and summer use would provide protections to the habitat 

and resource, as compared to Alternative A. Negative (-). 

ROW: Numerous areas around known fishing locations 

for the community are open to ROW development. This 

could cause habitat degradation and introduce new 

competing users to the area. Fishing is the most heavily 

harvested resource (by weight) for the community. 

Positive (+). 

LM: Same as Alternative C. Positive (+). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

ROW: Numerous areas around known fishing locations 

for the community are open to ROW development. This 

could cause habitat degradation and introduce new 

competing users to the area. Fishing is the most heavily 

harvested resource (by weight) for the community. 

Positive (+). 

Gathering Berries 

Plants 10.9 

LM: 0% of the use area would be open to locatable with 

high/med potential. Negative (-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

LM: Less than 1% of the use area would be open to 

locatable with high/med potential. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. 20% of the use area limits summer 

casual use to existing trails. This same 20% is also 

limited to snowmobiles only for casual winter use. 

Therefore, there is no access restriction for subsistence 

uses and the greatest protection against habitat 

degradation and competing uses, as compared to 

Alternative A. Negative (-). 

ROW: 7% of use area would be open to ROW location, 

13% would be ROW avoidance areas, and 0% would be 

ROW exclusion areas. This alternative would minimize 

habitat fragmentation and degradation in these areas, as 

compared to Alternative A. Gathering is not one of the top 

harvesting activities by volume for the community. 

Negative (-). 

LM: Less than 1% of the use area would be open to 

locatable with high/med potential. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. 20% of the use area limits summer 

casual use to existing trails. 0% of the use area has 

limitations placed on winter casual use and therefore all 

winter OHVs are allowed. Negative (-). 

ROW: 9% of use area would be open to ROW location, 

12% would be ROW avoidance areas, and 0% would be 

ROW exclusion areas. This alternative would decrease 

habitat fragmentation and degradation in these areas, as 

compared to Alternative A. Gathering is not one of the top 

harvesting activities by volume for the community. 

Negative (-). 

LM: Same as Alternative C. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

ROW: 18% of use area would be open to ROW location, 

3% would be ROW avoidance areas, and 0% would be 

ROW exclusion areas. This alternative would minimize 

habitat fragmentation and degradation in these areas, as 

compared to Alternative A. This is above the impacts 

threshold. Positive (+). 

Notes: 

LM: Locatable minerals with med/high potential 

OHV: travel decisions relating to OHV use 

ROW: Right-of-way decisions 

Impact analysis to determine whether there is a positive or negative finding is based on an assessment of magnitude, duration, extent, likelihood, and intensity. 

1) This column shows which species the BSWI EIS Team has GIS data for at the time of the DEIS release. Communities may have differing sets of data available or may be missing data completely for an aggregated category. In most instances where data sets for "Hunting and Trapping (SLM)" were 

available, the subsistence use area did not specify which species are included in the use area. 

2) Data is from the ADF&G Community Subsistence Information System (CSIS), available at http://www.adfg.alaska.gov/sb/CSIS/ 

O-1-13 
BSWI Draft RMP/EIS Appendix O: ANILCA Preliminary Section 810 Evaluation 

Impact Analysis Results—Chuathbaluk 

Aggregated 

Subsistence 

Use Category 

Species 

Included in 

Aggregated 

Category1 

Annual 

Pounds of 

Resource 

Harvested2 

Alternative A 

Significant Impact? [POSITIVE FINDING?] 

Alternative B 

Significant Impact? [POSITIVE FINDING?] 

Alternative C 

Significant Impact? [POSITIVE FINDING?] 

 

 

 

 

 

 

 

 

 

 

 

Alternative D 

Significant Impact? [POSITIVE FINDING?] 

Hunting and 

Trapping (LLM) 

Black Bear 

Caribou 

Moose 

40.9 

LM: 0% of the use area would be open to locatable with 

high/med potential. Negative (-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

LM: 1% of the use area would be open to locatable with 

high/med potential. This is below the significance 

threshold but is for a resource that is the second-most 

harvested resource (in lbs.) for the community (17% of 

harvested lbs. in 2009). This is also a larger impact than 

Alternative A. Positive (+). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. 16% of the use area limits summer 

casual use to existing trails. This same 16% is also 

limited to snowmobiles only for casual winter use. 

Therefore, there is no access restriction for subsistence 

uses and the greatest protection against habitat 

degradation and competing uses, as compared to 

Alternative A. Negative (-). 

ROW: 2% of use area would be open to ROW location, 

14% would be ROW avoidance areas, and 0% would be 

ROW exclusion areas. This alternative would minimize 

habitat fragmentation and degradation in these areas, as 

compared to Alternative A. Negative (-). 

LM: 4% of the use area would be open to locatable with 

high/med potential. This is below the significance 

threshold but is for a resource that is the second-most 

harvested resource (in lbs.) for the community (17% of 

harvested lbs. in 2009). This is also a larger impact than 

Alternative A. Positive (+). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. 16% of the use area limits summer 

casual use to existing trails. 0% of the use area has 

limitations placed on winter casual use and therefore all 

winter OHVs are allowed. LLM does make up a 

substantial part of the harvesting in this community (in 

lbs.) and is the second most harvest resource. Negative 

(-). 

ROW: 6% of use area would be open to ROW location, 

10% would be ROW avoidance areas, and 0% would be 

ROW exclusion areas. This alternative would minimize 

habitat fragmentation and degradation in these areas, as 

compared to Alternative A. Negative (-). 

LM: Same as Alternative C. Positive (+). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

ROW: 10% of use area would be open to ROW location, 

6% would be ROW avoidance areas, and 0% would be 

ROW exclusion areas. This alternative would minimize 

habitat fragmentation and degradation in these areas, as 

compared to Alternative A. This is over the threshold for 

impacts and could result in impacts to access and 

availability of resources. Positive (+). 

Hunting and 

Trapping (SLM) SLM 8.0 

LM: There is no overlap between SLM and LM areas with 

med/high potential. Negative (-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

LM: There is no overlap between SLM and LM areas with 

med/high potential. Negative (-). 

OHV: There is no overlap between SLM and OHV 

decisions. Negative (-). 

ROW: There is no overlap between SLM and ROW 

decisions. Negative (-). 

LM: There is no overlap between SLM and LM areas with 

med/high potential. Negative (-). 

OHV: There is no overlap between SLM and OHV 

decisions. Negative (-). 

ROW: There is no overlap between SLM and ROW 

decisions. Negative (-). 

LM: There is no overlap between SLM and LM areas with 

med/high potential. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

ROW: There is no overlap between SLM and ROW 

decisions. Negative (-). 

Hunting (Birds) Ducks 

Geese 2.5 

LM: Less than 1% of the use area overlaps with LM areas 

with med/high potential. Negative (-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

LM: Less than 1% of the use area overlaps with LM areas 

with med/high potential. Negative (-). 

OHV: There is almost no (close to 0%) overlap between 

bird hunting areas and OHV decisions. Negative (-). 

ROW: There is almost no (close to 0%) overlap between 

bird hunting areas and ROW decisions. Negative (-). 

LM: Same as Alternative A. Negative (-). 

OHV: There is almost no (close to 0%) overlap between 

bird hunting areas and OHV decisions. Negative (-). 

ROW: There is almost no (close to 0%) overlap between 

bird hunting areas and ROW decisions. Negative (-). 

LM: Same as Alternative A. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

ROW: There is almost no (close to 0%) overlap between 

bird hunting areas and ROW decisions. Negative (-). 

O-1-14 
Appendix O: ANILCA Preliminary Section 810 Evaluation BSWI Draft RMP/EIS 

Aggregated 

Subsistence 

Use Category 

Species 

Included in 

Aggregated 

Category1 

Annual 

Pounds of 

Resource 

Harvested2 

Alternative A 

Significant Impact? [POSITIVE FINDING?] 

Alternative B 

Significant Impact? [POSITIVE FINDING?] 

Alternative C 

Significant Impact? [POSITIVE FINDING?] 

 

 

 

 

 

 

 

 

 

 

Alternative D 

Significant Impact? [POSITIVE FINDING?] 

Fishing 

Salmon 

Trout 

Whitefish 

Salmon: 

159.0 

Nonsalmon 

Fish: 20.0 

LM: Some med/high potential LM areas are located in a 

basin ~15 miles from numerous fishing locations. This 

has the potential to degrade habitat. Fishing is the most 

harvested resource (by weight). Positive (+). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

LM: Some med/high potential LM areas are located in a 

basin ~15 miles from numerous fishing locations. This 

has the potential to degrade habitat. Fishing is the most 

harvested resource (by weight). Positive (+). 

OHV: There are no restrictions to OHV use for 

subsistence users. Some restrictions for casual winter 

and summer use would provide protections to the habitat 

and resource, as compared to Alternative A. Negative (-). 

ROW: Areas close to known fishing locations are mostly 

ROW avoidance areas. There are some areas open to 

ROW development, though these do not appear to block 

access to the fishing locations. Negative (-). 

LM: Some med/high potential LM areas are located in a 

basin ~15 miles from numerous fishing locations. This 

has the potential to degrade habitat. Fishing is the most 

harvested resource (by weight). Positive (+). 

OHV: There are no restrictions to OHV use for 

subsistence users. Some restrictions for casual winter 

and summer use would provide protections to the habitat 

and resource, as compared to Alternative A. Negative (-). 

ROW: Areas close to known fishing locations are mostly 

ROW avoidance areas. There are some areas open to 

ROW development, though these do not appear to block 

access to the fishing locations. Negative (-). 

LM: Some med/high potential LM areas are located in a 

basin ~15 miles from numerous fishing locations. This 

has the potential to degrade habitat. Fishing is the most 

harvested resource (by weight). Positive (+). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

ROW: Numerous areas around known fishing locations 

for the community are open to ROW development. This 

could cause habitat degradation and introduce new 

competing users to the area. Fishing is the most heavily 

harvested resource (by weight) for the community. 

Positive (+). 

Gathering Berries 

Plants 13.7 

LM: 2% of the use area would be open to locatable with 

high/med potential. This resource is not one of the most 

highly harvested resources (in lbs.) and the open area 

does not seem to block access routes. Negative (-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

LM: Less than 1% of the use area would be open to 

locatable with high/med potential. This resource is not 

one of the most highly harvested resources (in lbs.) and 

the open area does not seem to block access routes. 

Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. 17% of the use area limits summer 

casual use to existing trails. This same 17% is also 

limited to snowmobiles only for casual winter use. 

Therefore, there is no access restriction for subsistence 

uses and the greatest protection against habitat 

degradation and competing uses, as compared to 

Alternative A. Negative (-). 

ROW: 1% of use area would be open to ROW location, 

16% would be ROW avoidance areas, and 0% would be 

ROW exclusion areas. This alternative would minimize 

habitat fragmentation and degradation in these areas, as 

compared to Alternative A. Negative (-). 

LM: Same as Alternative A. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. 17% of the use area limits summer 

casual use to existing trails. 0% of the use area has 

limitations placed on winter casual use and therefore all 

winter OHVs are allowed. Negative (-). 

ROW: 9% of use area would be open to ROW location, 

9% would be ROW avoidance areas, and 0% would be 

ROW exclusion areas. This alternative would minimize 

habitat fragmentation and degradation in these areas, as 

compared to Alternative A. Negative (-). 

LM: Same as Alternative A. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

ROW: 10% of use area would be open to ROW location, 

7% would be ROW avoidance areas, and 0% would be 

ROW exclusion areas. This alternative would minimize 

habitat fragmentation and degradation in these areas, as 

compared to Alternative A. This is over the threshold for 

impacts and could result in impacts to access and 

availability of resources. Positive (+). 

Notes: 

LM: Locatable minerals with med/high potential 

OHV: travel decisions relating to OHV use 

ROW: Right-of-way decisions 

Impact analysis to determine whether there is a positive or negative finding is based on an assessment of magnitude, duration, extent, likelihood, and intensity. 

1) This column shows which species the BSWI EIS Team has GIS data for at the time of the DEIS release. Communities may have differing sets of data available or may be missing data completely for an aggregated category. In most instances where data sets for "Hunting and Trapping (SLM)" were 

available, the subsistence use area did not specify which species are included in the use area. 

2) Data is from the ADF&G Community Subsistence Information System (CSIS), available at http://www.adfg.alaska.gov/sb/CSIS/ 

O-1-15 
BSWI Draft RMP/EIS Appendix O: ANILCA Preliminary Section 810 Evaluation 

Impact Analysis Results—Grayling 

Aggregated 

Subsistence 

Use Category 

Species 

Included in 

Aggregated 

Category1 

Annual 

Pounds of 

Resource 

Harvested2 

Alternative A 

Significant Impact? [POSITIVE FINDING?] 

Alternative B 

Significant Impact? [POSITIVE FINDING?] 

Alternative C 

Significant Impact? [POSITIVE FINDING?] 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Alternative D 

Significant Impact? [POSITIVE FINDING?] 

LM: No overlap in open areas and use areas. Negative 

(-). 

LM: No overlap in open areas and use areas. Negative 

(-). 

Hunting and 

Trapping (LLM) Moose 58.7 

LM: No overlap in open areas and use areas. Negative (-

). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

LM: No overlap in open areas and use areas. Negative 

(-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter use. 10% 

of the use area limits summer casual use to existing trails. 

This same 10% is also limited to snowmobiles only for 

casual winter use. Therefore, there is no access 

restriction for subsistence uses and the greatest 

protection against habitat degradation and competing 

uses, as compared to Alternative A. Negative (-). 

ROW: 1% of use area would be open to ROW location, 

1% would be ROW avoidance areas, and 9% would be 

ROW exclusion areas. This alternative would minimize 

habitat fragmentation and degradation in these areas, as 

compared to Alternative A. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter use. 10% 

of the use area limits summer casual use to existing trails. 

There is no limit for OHV use for casual winter use. 

Therefore, there is no access restriction for subsistence 

uses and the greatest protection against habitat 

degradation and competing uses, as compared to 

Alternative A. Negative (-). 

ROW: 1% of use area would be open to ROW location, 

4% would be ROW avoidance areas, and 6% would be 

ROW avoidance areas for linear realty. This alternative 

would decrease habitat fragmentation and degradation in 

these areas, as compared to Alternative A. The realty 

avoidance area would cross a portion of the LLM use 

area that could impede access to the remaining portions 

of the use area, and also cause impacts to availability. 

LLM is one of the most highly harvested resources in the 

community. Positive (+). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

ROW: 3% of use area would be open to ROW location, 

7% would be ROW avoidance areas. This alternative 

would decrease habitat fragmentation and degradation in 

these areas, as compared to Alternative A. The 

remainder of the BLM land would allow ROWs on a caseby-case basis, which could potentially cross a portion of 

the LLM use area that could impede access to the 

remaining portions of the use area, and also cause 

impacts to availability. LLM is one of the most highly 

harvested resources in the community. Positive (+). 

LM: No overlap in open areas and use areas. Negative 

(-). LM: No overlap in open areas and use areas. Negative 

LM: No overlap in open areas and use areas. Negative 

(-). 

Hunting and 

Trapping (SLM) 

SLM 

Beaver 15.4 

LM: No overlap in open areas and use areas. Negative 

(-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter use. 1% of 

the use area limits summer casual use to existing trails. 

This same 1% is also limited to snowmobiles only for 

casual winter use. Therefore, there is no access 

restriction for subsistence uses and the greatest 

protection against habitat degradation and competing 

uses, as compared to Alternative A. Negative (-). 

(-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

fragment habitats and degrade subsistence resources. 

Positive (+). ROW: Close to 0% of use area would be ROW 

avoidance areas. This alternative would minimize habitat 

fragmentation and degradation in these areas, as 

compared to Alternative A. Negative (-). 

This is the same impact as Alternative A. Positive (+). 

ROW: Same as Alternative B. Negative (-). 

ROW: Close to 0% of use area would be open to ROW 

location, 1% would be ROW avoidance areas. This 

alternative would minimize habitat fragmentation and 

degradation in these areas, as compared to Alternative A. 

Negative (-). 

Hunting (Birds) 

Ducks 

Geese 

Ptarmigan 

Grouse 

7.9 

LM: No overlap in open areas and use areas. Negative 

(-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

LM: No overlap in open areas and use areas. Negative 

(-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, nearly 0% of summer casual 

use is restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only 

except for 26 acres, so nearly the entire use area is open 

to all winter OHV uses. This is the same impact as 

Alternative A. Positive (+). 

ROW: Close to 0% of use area would be open to ROW 

location, close to 0% would be ROW exclusion areas. 

This alternative would minimize habitat fragmentation and 

degradation in these areas, as compared to Alternative A. 

Negative (-). 

LM: No overlap in open areas and use areas. Negative 

(-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, nearly 0% of summer casual 

use is restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only 

except for 26 acres, so nearly the entire use area is open 

to all winter OHV uses. This is the same impact as 

Alternative A. Positive (+). 

ROW: Close to 0% of use area would be open to ROW 

location, close to 0% would be ROW avoidance for linear 

realty areas. This alternative would minimize habitat 

fragmentation and degradation in these areas, as 

compared to Alternative A. Negative (-). 

LM: No overlap in open areas and use areas. Negative 

(-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

ROW: 26 acres would be open to ROWs at the edge of 

the use area. Bird harvesting is not a significant portion of 

the resources harvested for this community. Negative (-). 

O-1-16 
Appendix O: ANILCA Preliminary Section 810 Evaluation BSWI Draft RMP/EIS 

Aggregated 

Subsistence 

Use Category 

Species 

Included in 

Aggregated 

Category1 

Annual 

Pounds of 

Resource 

Harvested2 

Alternative A 

Significant Impact? [POSITIVE FINDING?] 

Alternative B 

Significant Impact? [POSITIVE FINDING?] 

Alternative C 

Significant Impact? [POSITIVE FINDING?] 

 

 

 

 

 

 

 

 

 

 

 

Alternative D 

Significant Impact? [POSITIVE FINDING?] 

Fishing 

Burbot 

Chinook 

Chum 

Norther 

Pike 

Salmon 

Sheefish 

Whitefish 

Salmon: 

121.9 

Nonsalmon 

Fish: 

37.4 

LM: LM areas with med/high potential are not near any 

fishing spots for Grayling. Negative (-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

LM: LM areas with med/high potential are not near any 

fishing spots for Grayling. Negative (-). 

OHV: Several portions of the areas near fishing spots 

have summer OHV restrictions for casual use that would 

limit OHV use to existing trails and winter casual use to 

snowmobiles only. This would be more protective to 

habitats and subsistence resources than Alternative A. 

Additionally, there is no access restrictions for 

subsistence uses. There are areas where subsistence 

winter use is limited to snowmobiles only to the west and 

north of the community, but none of these portions would 

impede access to the fishing locations. Negative (-). 

ROW: Areas close to fishing spots are ROW exclusion 

areas and will not impact access or availability. Negative 

(-). 

LM: LM areas with med/high potential are not near any 

fishing spots for Grayling. Negative (-). 

OHV: Several portions of the areas near fishing spots 

have summer OHV restrictions for casual use that would 

limit OHV use to existing trails. This would be more 

protective to habitats and subsistence resources than 

Alternative A. Additionally, there is no access restrictions 

for subsistence uses. There are areas where both casual 

and subsistence winter use is limited to snowmobiles only 

to the west and north of the community, but none of these 

portions would impede access to the fishing locations. 

Negative (-). 

ROW: Fishing spots north of the village would be located 

close to ROW avoidance areas for linear realty. While this 

area is small, it is close to several fishing locations for the 

community, and fish are the most heavily harvested 

subsistence resource for this community (65% of lbs. 

harvested in 2011). Positive (+). 

LM: LM areas with med/high potential are not near any 

fishing spots for Grayling. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

ROW: Fishing spots north of the village would be located 

close to ROW open areas. While this area is small, it is 

close to several fishing locations for the community, and 

fish are the most heavily harvested subsistence resource 

for this community. Positive (+). 

Gathering Berries 

Greens 4.6 

LM: 0% of the use area would be open to locatable with 

high/med potential. Negative (-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

LM: Less than 1% of the use area would be open to 

locatable with high/med potential. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. 20% of the use area limits summer 

casual use to existing trails. This same 20% is also 

limited to snowmobiles only for casual winter use. 

Therefore, there is no access restriction for subsistence 

uses and the greatest protection against habitat 

degradation and competing uses, as compared to 

Alternative A. Negative (-). 

ROW: 4% of use area would be open to ROW location, 

1% would be ROW avoidance areas, and 12% would be 

ROW exclusion areas. This alternative would minimize 

habitat fragmentation and degradation in these areas, as 

compared to Alternative A. Negative (-). 

LM: Less than 1% of the use area would be open to 

locatable with high/med potential. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. 20% of the use area limits summer 

casual use to existing trails. 0% of the use area has 

limitations placed on winter casual use and therefore all 

winter OHVs are allowed. Negative (-). 

ROW: 4% of use area would be open to ROW location, 

1% would be ROW avoidance areas, and 12% would be 

ROW avoidance areas for linear realty. This alternative 

would minimize habitat fragmentation and degradation in 

these areas, as compared to Alternative A. Negative. 

Negative (-). 

LM: Same as Alternative C. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

ROW: 11% of use area would be open to ROW location, 

7% would be ROW avoidance areas. This alternative 

would minimize habitat fragmentation and degradation in 

these areas, as compared to Alternative A, but is over the 

threshold for impacts. Positive (+). 

Notes: 

LM: Locatable minerals with med/high potential 

OHV: travel decisions relating to OHV use 

ROW: Right-of-way decisions 

Impact analysis to determine whether there is a positive or negative finding is based on an assessment of magnitude, duration, extent, likelihood, and intensity. 

1) This column shows which species the BSWI EIS Team has GIS data for at the time of the DEIS release. Communities may have differing sets of data available or may be missing data completely for an aggregated category. In most instances where data sets for "Hunting and Trapping (SLM)" were 

available, the subsistence use area did not specify which species are included in the use area. 

2) Data is from the ADF&G Community Subsistence Information System (CSIS), available at http://www.adfg.alaska.gov/sb/CSIS/ 

O-1-17 
BSWI Draft RMP/EIS Appendix O: ANILCA Preliminary Section 810 Evaluation 

Impact Analysis Results—Holy Cross 

Aggregated 

Subsistence 

Use Category 

Species 

Included in 

Aggregated 

Category1 

Annual 

Pounds of 

Resource 

Harvested2 

Alternative A 

Significant Impact? [POSITIVE FINDING?] 

Alternative B 

Significant Impact? [POSITIVE FINDING?] 

Alternative C 

Significant Impact? [POSITIVE FINDING?] 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Alternative D 

Significant Impact? [POSITIVE FINDING?] 

LM: Close to 0% of the use area is designated as 

high/med potential for LM decisions. Negative (-). 

OHV: 0% of use area is restricted for summer 

LM: Close to 0% of the use area is designated as 

high/med potential for LM decisions. Negative (-). LM: Close to 0% of the use area is designated as 

high/med potential for LM decisions. Negativ (-)e. 

Hunting and 

Trapping (LLM) Moose 0.0 

LM: Close to 0% of the use area is designated as 

high/med potential for LM decisions. Negative (-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

subsistence use and 1% is restricted for winter 

subsistence use. 44% of the use area limits summer 

casual use to existing trails. This same 44% is also 

limited to snowmobiles only for casual winter use. There 

would be some access restriction for subsistence uses in 

the 1% of the use area that limits winter subsistence use 

to snowmobiles only. This alternative provides the 

greatest protection against habitat degradation and 

competing uses, as compared to Alternative A. Data for 

harvests is limited, but 1990 totals list 0lbs of LLM 

harvested. Negative (-). 

ROW: 14% of use area would be open to ROW location, 

15% would be ROW avoidance areas, and 15% would be 

ROW exclusion areas. This alternative would minimize 

habitat fragmentation and degradation in these areas, as 

compared to Alternative A, but is over the threshold for 

OHV: 0% of use area is restricted for summer 

subsistence use and 1% is restricted for winter 

subsistence use. 44% of the use area limits summer 

casual use to existing trails. 1% is limited to snowmobiles 

only for casual and subsistence winter use. This 

alternative provides the greatest protection against 

habitat degradation and competing uses, as compared to 

Alternative A. Data for harvests is limited, but 1990 totals 

list 0lbs of LLM harvested. Negative (-). 

ROW: 19% of use area would be open to ROW location, 

12% would be ROW avoidance areas, and 12% would be 

ROW avoidance areas for linear realty actions. This 

alternative would minimize habitat fragmentation and 

degradation in these areas, as compared to Alternative A, 

but is over the threshold for impacts. Positive (+). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

ROW: 30% of use area would be open to ROW location, 

14% would be ROW avoidance areas, and 0% would be 

ROW exclusion areas. This alternative would minimize 

habitat fragmentation and degradation in these areas, as 

compared to Alternative A, but is over the threshold for 

impacts. Positive (+). 

impacts. Positive (+). 

Hunting and 

Trapping (SLM) 

(ANVIK DATA) 

68.6 

LM: Same as Anvik. Negative (-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

LM: Same as Anvik. Negative (-). 

OHV: Same as Anvik. Negative (-). 

ROW: Same as Anvik. Negative (-). 

LM: Same as Anvik. Negative (-). 

OHV: Same as Anvik. Negative (-). 

ROW: Same as Anvik. Negative (-). 

LM: Same as Anvik. Negative (-). 

OHV: Same as Anvik. Positive (+). 

ROW: Same as Anvik. Positive (+). 

Hunting (Birds) 

(ANVIK DATA) 28.5 

LM: Same as Anvik. Negative (-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

LM: Same as Anvik. Negative (-). 

OHV: Same as Anvik. Negative (-). 

ROW: Same as Anvik. Negative (-). 

LM: Same as Anvik. Negative (-). 

OHV: Same as Anvik. Negative (-). 

ROW: Same as Anvik. Negative (-). 

LM: Same as Anvik. Negative (-). 

OHV: Same as Anvik. Positive. 

ROW: Same as Anvik. Positive. 

Fishing (ANVIK 

DATA) 

Salmon 

Burbot 

Whitefish 

Lamprey 

Dolly 

Varden 

Arctic 

Grayling 

Arctic Char 

Salmon: 

121.2 

Nonsalmon 

Fish: 80.9 

LM: Same as Anvik. Negative (-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

LM: Same as Anvik. Negative (-). 

OHV: Same as Anvik. Negative (-). 

ROW: Same as Anvik. Negative (-). 

LM: Same as Anvik. Negative (-). 

OHV: Same as Anvik. Negative (-). 

ROW: Same as Anvik. Negative (-). 

LM: Same as Anvik. Negative (-). 

OHV: Same as Anvik. Negative (-). 

ROW: Same as Anvik. Negative (-). 

O-1-18 
Appendix O: ANILCA Preliminary Section 810 Evaluation BSWI Draft RMP/EIS 

Aggregated 

Subsistence 

Use Category 

Species 

Included in 

Aggregated 

Category1 

Annual 

Pounds of 

Resource 

Harvested2 

Alternative A 

Significant Impact? [POSITIVE FINDING?] 

Alternative B 

Significant Impact? [POSITIVE FINDING?] 

Alternative C 

Significant Impact? [POSITIVE FINDING?] 

 

 

 

 

Alternative D 

Significant Impact? [POSITIVE FINDING?] 

Gathering 

(ANVIK DATA) 12.7 

LM: Same as Anvik. Negative (-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

LM: Same as Anvik. Negative (-). 

OHV: Same as Anvik. Negative (-). 

ROW: Same as Anvik. Negative (-). 

LM: Same as Anvik. Negative (-). 

OHV: Same as Anvik. Negative (-). 

ROW: Same as Anvik. Negative (-). 

LM: Same as Anvik. Negative (-). 

OHV: Same as Anvik. Positive (+). 

ROW: Same as Anvik. Negative (-). 

Notes: 

LM: Locatable minerals with med/high potential 

OHV: travel decisions relating to OHV use 

ROW: Right-of-way decisions 

Impact analysis to determine whether there is a positive or negative finding is based on an assessment of magnitude, duration, extent, likelihood, and intensity. 

1) This column shows which species the BSWI EIS Team has GIS data for at the time of the DEIS release. Communities may have differing sets of data available or may be missing data completely for an aggregated category. In most instances where data sets for "Hunting and Trapping (SLM)" were 

available, the subsistence use area did not specify which species are included in the use area. 

2) Data is from the ADF&G Community Subsistence Information System (CSIS), available at http://www.adfg.alaska.gov/sb/CSIS/ 

O-1-19 
BSWI Draft RMP/EIS Appendix O: ANILCA Preliminary Section 810 Evaluation 

Impact Analysis Results—Kaltag 

Aggregated 

Subsistence 

Use Category 

Species 

Included in 

Aggregated 

Category1 

Annual 

Pounds of 

Resource 

Harvested2 

Alternative A 

Significant Impact? [POSITIVE FINDING?] 

Alternative B 

Significant Impact? [POSITIVE FINDING?] 

Alternative C 

Significant Impact? [POSITIVE FINDING?] 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Alternative D 

Significant Impact? [POSITIVE FINDING?] 

LM: Same as Unalakleet. Negative (-). 

Hunting and 

Trapping (LLM) 

(UNALAKLEET 

DATA) 

No data. 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

LM: Same as Unalakleet. Negative (-). 

OHV: Same as Unalakleet. Positive (+). 

ROW: Same as Unalakleet. Negative (-). 

LM: Same as Unalakleet. Negative (-). 

OHV: Same as Unalakleet. Positive (+). 

ROW: Same as Unalakleet. Negative (-). 

LM: Same as Unalakleet. Negative (-). 

OHV: Same as Unalakleet. Positive (+). 

ROW: Same as Unalakleet. Positive (+). 

LM: Same as Unalakleet. Negative (-). 

Hunting and 

Trapping (SLM) 

(UNALAKLEET 

DATA) 

No data. 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

LM: Same as Unalakleet. Negative (-). 

OHV: Same as Unalakleet. Positive (+). 

ROW: Same as Unalakleet. Negative (-). 

LM: Same as Unalakleet. Negative (-). 

OHV: Same as Unalakleet. Positive (+). 

ROW: Same as Unalakleet. Positive (+). 

LM: Same as Unalakleet. Negative (-). 

OHV: Same as Unalakleet. Positive (+). 

ROW: Same as Unalakleet. Positive (+). 

Hunting (Birds) 

(UNALAKLEET 

DATA) 

No data. 

LM: No overlap in use area and areas with med/high LM 

potential. Negative (-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

LM: Same as Unalakleet. Negative (-). 

OHV: Same as Unalakleet. Positive (+). 

ROW: Same as Unalakleet. Positive (+). 

LM: Same as Unalakleet. Negative (-). 

OHV: Same as Unalakleet. Positive (+). 

ROW: Same as Unalakleet. Positive (+). 

LM: Same as Unalakleet. Negative (-). 

OHV: Same as Unalakleet. Positive (+). 

ROW: Same as Unalakleet. Positive (+). 

Fishing 

(UNALAKLEET 

DATA) 

Salmon: 

665.4 

LM: Same as Unalakleet. Negative (-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

LM: Same as Unalakleet. Negative (-). 

OHV: Same as Unalakleet. Negative (-). 

ROW: Same as Unalakleet. Negative (-). 

LM: Same as Unalakleet. Negative (-). 

OHV: Same as Unalakleet. Negative (-). 

ROW: Same as Unalakleet. Negative (-). 

LM: No overlap in use area and areas with med/high LM 

potential. Negative (-). 

OHV: OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

ROW: No overlap in the use area and areas with ROW 

decisions. Negative (-). 

Notes: 

LM: Locatable minerals with med/high potential 

OHV: travel decisions relating to OHV use 

ROW: Right-of-way decisions 

Impact analysis to determine whether there is a positive or negative finding is based on an assessment of magnitude, duration, extent, likelihood, and intensity. 

Available data for the Community of Kaltag did not include gathering subsistence use areas. 

1) This column shows which species the BSWI EIS Team has GIS data for at the time of the DEIS release. Communities may have differing sets of data available or may be missing data completely for an aggregated category. In most instances where data sets for "Hunting and Trapping (SLM)" were 

available, the subsistence use area did not specify which species are included in the use area. 

2) Data is from the ADF&G Community Subsistence Information System (CSIS), available at http://www.adfg.alaska.gov/sb/CSIS/ 

O-1-20 
Appendix O: ANILCA Preliminary Section 810 Evaluation BSWI Draft RMP/EIS 

Impact Analysis Results—Lime Village 

Aggregated 

Subsistence 

Use Category 

Species 

Included in 

Aggregated 

Category1 

Annual 

Pounds of 

Resource 

Harvested2 

Alternative A 

Significant Impact? [POSITIVE FINDING?] 

Alternative B 

Significant Impact? [POSITIVE FINDING?] 

Alternative C 

Significant Impact? [POSITIVE FINDING?] 

 

 

 

 

 

 

 

 

 

 

 

Alternative D 

Significant Impact? [POSITIVE FINDING?] 

LM: There is no overlap between use area and LM areas 

with med/high potential. Negative (-). 

LM: There is no overlap between use area and LM areas 

with med/high potential. Negative (-). LM: There is no overlap between use area and LM areas 

Hunting and 

Trapping (LLM) 

Black Bear 

Caribou 

Moose 

260.0 

LM: There is no overlap between use area and LM areas 

with med/high potential. Negative (-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

OHV: 0% of use area is restricted for summer 

subsistence use and 3% is restricted for winter use. 38% 

of the use area limits summer casual use to existing trails. 

This same 38% is also limited to snowmobiles only for 

casual winter use. There is some access restriction for 

subsistence uses and the greatest protection against 

habitat degradation and competing uses, as compared to 

Alternative A. LLM are one of the most heavily harvested 

resources for the community. Positive (+). 

OHV: 0% of use area is restricted for summer 

subsistence use and 3% is restricted for winter use. 38% 

of the use area limits summer casual use to existing trails. 

3% of both casual and subsistence use is limited to 

snowmobiles only for winter use. There is some access 

restriction for subsistence uses and greater protection 

against habitat degradation and competing uses, as 

compared to Alternative A. LLM are one of the most 

heavily harvested resources for the community. Positive 

(+). 

with med/high potential. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

ROW: 14% of use area would be open to ROW location, 

23% would be ROW avoidance areas, and 0% would be 

ROW exclusion areas. This alternative would minimize 

habitat fragmentation and degradation in these areas, as 

compared to Alternative A. LLM are one of the top 

resources harvested in the community. Access may be 

impacted by the open ROW areas as they are located 

throughout the LLM use area. Habitat may be degraded, 

and the ROWs may allow for competing uses for the 

subsistence resources. Positive (+). 

ROW: 29% of use area would be open to ROW 

location,9% would be ROW avoidance areas. This 

alternative would decrease habitat fragmentation and 

degradation in these areas, as compared to Alternative A. 

LLM are one of the top resources harvested in the 

community. Access may be impacted by the open ROW 

areas as they are located throughout the LLM use area. 

Habitat may be degraded, and the ROWs may allow for 

competing uses for the subsistence resources. Positive 

(+). 

ROW: 33% of use area would be open to ROW location, 

4% would be ROW avoidance areas. This alternative 

would decrease habitat fragmentation and degradation in 

the avoidance areas, as compared to Alternative A. LLM 

are one of the top resources harvested in the community. 

Access may be impacted by the open ROW areas as they 

are located throughout the LLM use area. Habitat may be 

degraded, and the ROWs may allow for competing uses 

for the subsistence resources. Positive (+). 

LM: There is no overlap between use area and LM areas 

with med/high potential. Negative (-). 

LM: There is no overlap between use area and LM areas 

with med/high potential. Negative (-). 

Hunting and 

Trapping (SLM) SLM 17.2 

LM: There is no overlap between use area and LM areas 

with med/high potential. Negative (-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

OHV: 0% of use area is restricted for summer 

subsistence use and 3% is restricted for winter use. 15% 

of the use area limits summer casual use to existing trails. 

This same 15% is also limited to snowmobiles only for 

casual winter use. There is some access restriction for 

subsistence uses along the upper northern boundary of 

the use area along the Swift River, and the greatest 

protection against habitat degradation and competing 

uses, as compared to Alternative A. SLM is not one of the 

top harvested resources for the community, and access 

restrictions would not be significant. Negative (-). 

ROW: 9% of use area would be open to ROW location, 

6% would be ROW avoidance areas, and 0% would be 

ROW exclusion areas. This alternative would minimize 

habitat fragmentation and degradation in these areas, as 

compared to Alternative A. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 3% is restricted for winter use. 15% 

of the use area limits summer casual use to existing trails. 

3% is also limited to snowmobiles only for casual winter 

use. There is some access restriction for subsistence 

uses along the upper northern boundary of the use area 

along the Swift River, and the greatest protection against 

habitat degradation and competing uses, as compared to 

Alternative A. SLM is not one of the top harvested 

resources for the community, and access restrictions 

would not be significant. Negative (-). 

ROW: 12% of use area would be open to ROW location, 

3% would be ROW avoidance areas. This alternative 

would limit habitat fragmentation and degradation in these 

areas, as compared to Alternative A, but is above the 

threshold for impacts. Positive (+). 

LM: There is no overlap between use area and LM areas 

with med/high potential. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

ROW: Same as Alternative C. Positive (+). 

O-1-21 
BSWI Draft RMP/EIS Appendix O: ANILCA Preliminary Section 810 Evaluation 

Aggregated 

Subsistence 

Use Category 

Species 

Included in 

Aggregated 

Category1 

Annual 

Pounds of 

Resource 

Harvested2 

Alternative A 

Significant Impact? [POSITIVE FINDING?] 

Alternative B 

Significant Impact? [POSITIVE FINDING?] 

Alternative C 

Significant Impact? [POSITIVE FINDING?] 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Alternative D 

Significant Impact? [POSITIVE FINDING?] 

Hunting (Birds) Waterfowl 0.0 

LM: There is no overlap between use area and LM areas 

with med/high potential. Negative (-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

LM: There is no overlap between use area and LM areas 

with med/high potential. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter use. 29% 

of the use area limits summer casual use to existing trails. 

This same 29% is also limited to snowmobiles only for 

casual winter use. Therefore, there is no access 

restriction for subsistence uses and the greatest 

protection against habitat degradation and competing 

uses, as compared to Alternative A. Negative (-). 

ROW: 24% of use area would be open to ROW location, 

5% would be ROW avoidance areas. This alternative 

would limit habitat fragmentation and degradation in these 

areas, as compared to Alternative A, but is above the 

threshold for impacts. Positive (+). 

LM: There is no overlap between use area and LM areas 

with med/high potential. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter use. 29% 

of the use area limits summer casual use to existing trails. 

There is no limit for OHV use for casual winter use. 

Therefore, there is no access restriction for subsistence 

uses and the greatest protection against habitat 

degradation and competing uses, as compared to 

Alternative A. Negative (-). 

ROW: 27% of use area would be open to ROW location, 

2% would be ROW avoidance areas. This alternative 

would limit habitat fragmentation and degradation in these 

areas, as compared to Alternative A, but is above the 

threshold for impacts. Positive (+). 

LM: There is no overlap between use area and LM areas 

with med/high potential. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

ROW: 28% of use area would be open to ROW location, 

1% would be ROW avoidance areas. This alternative 

would limit habitat fragmentation and degradation in these 

areas, as compared to Alternative A, but is above the 

threshold for impacts. Positive (+). 

LM: There is no overlap between use area and LM areas 

LM: There is no overlap between use area and LM areas 

with med/high potential. No LM areas with med/high 

LM: There is no overlap between use area and LM areas 

with med/high potential. No LM areas with med/high 

potential are nearby or within the basin for the fishing 

locations. Negative (-). 

LM: There is no overlap between use area and LM areas 

with med/high potential. No LM areas with med/high 

potential are nearby or within the basin for the fishing 

locations. Negative (-). 

with med/high potential. No LM areas with med/high 

potential are nearby or within the basin for the fishing 

locations. Negative (-). 

OHV: 0% of use area is restricted for summer 

Fishing 

Salmon 

Whitefish 

Lease cisco 

Humpback 

whitefish 

Grayling 

Northern 

Pike 

Salmon: 

555.8 

Nonsalmon 

Fish: 

49.9 

potential are nearby or within the basin for the fishing 

locations. Negative (-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

OHV: There is no overlap between areas that limit winter 

subsistence uses and the fishing locations for the 

community. Surrounding BLM land has limits on casual 

summer and winter use, which provides protection 

against habitat degradation and competing uses. 

Negative (-). 

ROW: Access does not appear to be impeded by areas 

open to ROWs. However, a large portion of the upstream 

basins for the fishing locations are open to ROW 

development. These open areas could degrade habitat 

and bring new users to the area that would compete for 

resources. Fish are the top harvested resource for the 

community. Positive (+). 

OHV: There is no overlap between areas that limit winter 

subsistence uses and the fishing locations for the 

community. Surrounding BLM land has limits on casual 

summer use, which provides protection against habitat 

degradation and competing uses. Negative (-). 

ROW: Access does not appear to be impeded by areas 

open to ROWs. However, a large portion of the upstream 

basins for the fishing locations are open to ROW 

development. These open areas could degrade habitat 

and bring new users to the area that would compete for 

resources. Fish are the top harvested resource for the 

community. Positive (+). 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

ROW: Access does not appear to be impeded by areas 

open to ROWs. However, a large portion of the upstream 

basins for the fishing locations are open to ROW 

development. These open areas could degrade habitat 

and bring new users to the area that would compete for 

resources. Fish are the top harvested resource for the 

community. Positive (+). 

Gathering 

Plants 

Wood 

Berries 

48.2 

LM: There is no overlap between use area and LM areas 

with med/high potential. Negative (-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

LM: There is no overlap between use area and LM areas 

with med/high potential. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter use. 4% of 

the use area limits summer casual use to existing trails. 

This same 4% is also limited to snowmobiles only for 

casual winter use. Therefore, there is no access 

restriction for subsistence uses and the greatest 

protection against habitat degradation and competing 

uses, as compared to Alternative A. Negative (-). 

ROW: 3% of use area would be open to ROW location, 

1% would be ROW avoidance areas, and 0% would be 

ROW exclusion areas. This alternative would minimize 

habitat fragmentation and degradation in these areas, as 

compared to Alternative A. Negative (-). 

LM: There is no overlap between use area and LM areas 

with med/high potential. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter use. 4% of 

the use area limits summer casual use to existing trails. 

There is no limit for OHV use for casual winter use. 

Therefore, there is no access restriction for subsistence 

uses and the greatest protection against habitat 

degradation and competing uses, as compared to 

Alternative A. Negative (-). 

ROW: 4% of use area would be open to ROW location. 

This is less than the threshold for impacts and does not 

appear to interfere with travel routes. Negative (-). 

LM: There is no overlap between use area and LM areas 

with med/high potential. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

ROW: Same as Alternative C. Negative (-). 

Notes: 

LM: Locatable minerals with med/high potential 

OHV: travel decisions relating to OHV use 

ROW: Right-of-way decisions 

Impact analysis to determine whether there is a positive or negative finding is based on an assessment of magnitude, duration, extent, likelihood, and intensity. 

O-1-22 
Appendix O: ANILCA Preliminary Section 810 Evaluation BSWI Draft RMP/EIS 

1) This column shows which species the BSWI EIS Team has GIS data for at the time of the DEIS release. Communities may have differing sets of data available or may be missing data completely for an aggregated category. In most instances where data sets for "Hunting and Trapping (SLM)" were 

available, the subsistence use area did not specify which species are included in the use area. 

2) Data is from the ADF&G Community Subsistence Information System (CSIS), available at http://www.adfg.alaska.gov/sb/CSIS/ 

O-1-23 
BSWI Draft RMP/EIS Appendix O: ANILCA Preliminary Section 810 Evaluation 

Impact Analysis Results—Lower Kalskag 

Aggregated 

Subsistence 

Use Category 

Species 

Included in 

Aggregated 

Category1 

Annual 

Pounds of 

Resource 

Harvested2 

Alternative A 

Significant Impact? [POSITIVE FINDING?] 

Alternative B 

Significant Impact? [POSITIVE FINDING?] 

Alternative C 

Significant Impact? [POSITIVE FINDING?] 

 

 

 

 

 

 

 

 

 

Alternative D 

Significant Impact? [POSITIVE FINDING?] 

Hunting and 

Trapping (LLM) 

Black Bear 

Caribou 

Moose 

35.4 

LM: There is no overlap between LLM and LM areas with 

med/high potential. Negative (-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

LM: There is no overlap between LLM and LM areas with 

med/high potential. Negative (-). 

OHV: Close to 0% of the use area has OHV decisions. 

Negative (-). 

ROW: Close to 0% of the use area has ROW decisions. 

Negative (-). 

LM: There is no overlap between LLM and LM areas with 

med/high potential. Negative (-). 

OHV: Close to 0% of the use area has OHV decisions. 

Negative (-). 

ROW: Close to 0% of the use area has ROW decisions. 

Negative (-). 

LM: There is no overlap between LLM and LM areas with 

med/high potential. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

ROW: Close to 0% of the use area has ROW decisions. 

Negative (-). 

Hunting and 

Trapping (SLM) SLM 3.3 

LM: There is no overlap between SLM and LM areas with 

med/high potential. Negative (-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

LM: There is no overlap between SLM and LM areas with 

med/high potential. Negative (-). 

OHV: There is no overlap between SLM and OHV 

decisions. Negative (-). 

ROW: There is no overlap between SLM and ROW 

decisions. Negative (-). 

LM: There is no overlap between SLM and LM areas with 

med/high potential. Negative (-). 

OHV: There is no overlap between SLM and OHV 

decisions. Negative (-). 

ROW: There is no overlap between SLM and ROW 

decisions. Negative (-). 

LM: There is no overlap between SLM and LM areas with 

med/high potential. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

ROW: There is no overlap between SLM and ROW 

decisions. Negative (-). 

Hunting (Birds) Ducks 

Geese 0.0 

LM: There is no overlap between bird hunting and LM 

areas with med/high potential. Negative (-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

LM: There is no overlap between bird hunting and LM 

areas with med/high potential. Negative (-). 

OHV: Close to 0% of the use area has OHV decisions. 

Negative (-). 

ROW: Close to 0% of the use area has ROW decisions. 

Negative (-). 

LM: There is no overlap between bird hunting and LM 

areas with med/high potential. Negative (-). 

OHV: Close to 0% of the use area has OHV decisions. 

Negative (-). 

ROW: Close to 0% of the use area has ROW decisions. 

Negative (-). 

LM: There is no overlap between bird hunting and LM 

areas with med/high potential. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

ROW: Close to 0% of the use area has ROW decisions. 

Negative (-). 

O-1-24 
Appendix O: ANILCA Preliminary Section 810 Evaluation BSWI Draft RMP/EIS 

Aggregated 

Subsistence 

Use Category 

Species 

Included in 

Aggregated 

Category1 

Annual 

Pounds of 

Resource 

Harvested2 

Alternative A 

Significant Impact? [POSITIVE FINDING?] 

Alternative B 

Significant Impact? [POSITIVE FINDING?] 

Alternative C 

Significant Impact? [POSITIVE FINDING?] 

 

 

 

 

Alternative D 

Significant Impact? [POSITIVE FINDING?] 

Fishing Salmon 

Whitefish 

Salmon: 

98.6 

Nonsalmon 

Fish: 

0 

LM: Med/high areas open to LM mining are located 

approximately 6 river miles upstream on Ophir Creek of 

numerous fishing locations in Whitefish Lake. Fish make 

up approximately half of the harvested subsistence 

resources for the community (in lbs.) based on 2009 data. 

Access is not likely to be impacted, but mining could 

result in degradation of resources and increased 

competition. Positive (+). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

LM: Med/high areas open to LM mining are located 

approximately 6 river miles upstream on Ophir Creek of 

numerous fishing locations in Whitefish Lake. 

Additionally, more open areas are located approximately 

17 river miles upstream on the Kuskokwim River. Fish 

make up approximately half of the harvested subsistence 

resources for the community (in lbs.) based on 2009 data. 

Access is not likely to be impacted, but mining could 

result in degradation of resources and increased 

competition. The impacts would be greater than 

Alternative A as more areas are open. Positive (+). 

OHV: None of the surrounding area would have 

limitations to winter or summer subsistence OHV use, so 

no impacts to access. This alternative also has the 

greatest limitations to casual summer and winter OHV 

use (limited to existing trails for summer use, and limited 

to only snowmobiles in winter), so it is more protective of 

resources than Alternative A. Negative (-). 

ROW: Some areas open to ROW placement around the 

Crooked Creek area, which has a few fishing locations for 

the community. However, the majority of fishing locations 

are not near areas open to ROW placement and do not 

appear to block access. Negative (-). 

LM: Med/high areas open to LM mining are located 

approximately 6 river miles upstream on Ophir Creek of 

numerous fishing locations in Whitefish Lake. 

Additionally, more open areas are located approximately 

17 river miles upstream on the Kuskokwim River. Fish 

make up approximately half of the harvested subsistence 

resources for the community (in lbs.) based on 2009 data. 

Access is not likely to be impacted, but mining could 

result in degradation of resources and increased 

competition. The impacts would be greater than 

Alternative A as more areas are open. Positive (+). 

OHV: None of the surrounding area would have 

limitations to winter or summer subsistence OHV use, so 

no impacts to access. This alternative also has limitations 

to casual summer OHV use (limited to existing trails for 

summer use) but no limitations on casual winter OHV 

use. It is more protective of resources than Alternative A. 

Negative (-). 

ROW: Some areas open to ROW placement around the 

Crooked Creek area, which has a few fishing locations for 

the community. There are more open areas upstream of 

Ophir Creek, which flows into Whitefish Lake, which is a 

heavily used area for fishing. These areas could lead to 

resource and habitat degradation, as well as increased 

competition for resources. Fish is the most heavily 

harvested subsistence resource for the community. 

Positive (+). 

LM: Same as Alternative C. Positive (+). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

ROW: Same as Alternative C. Positive (+). 

Gathering Berries 

Plants 12.6 

LM: There is no overlap between Gathering and LM areas 

with med/high potential. Negative (-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

LM: There is no overlap between Gathering and LM areas 

with med/high potential. Negative (-). 

OHV: There is no overlap between Gathering and OHV 

decisions. Negative (-). 

ROW: There is no overlap between Gathering and ROW 

decisions. Negative (-). 

LM: There is no overlap between Gathering and LM areas 

with med/high potential. Negative (-). 

OHV: There is no overlap between Gathering and OHV 

decisions. Negative (-). 

ROW: There is no overlap between Gathering and ROW 

decisions. Negative (-). 

LM: There is no overlap between Gathering and LM areas 

with med/high potential. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

ROW: There is no overlap between Gathering and ROW 

decisions. Negative (-). 

Notes: 

LM: Locatable minerals with med/high potential 

OHV: travel decisions relating to OHV use 

ROW: Right-of-way decisions 

Impact analysis to determine whether there is a positive or negative finding is based on an assessment of magnitude, duration, extent, likelihood, and intensity. 

1) This column shows which species the BSWI EIS Team has GIS data for at the time of the DEIS release. Communities may have differing sets of data available or may be missing data completely for an aggregated category. In most instances where data sets for "Hunting and Trapping (SLM)" were 

available, the subsistence use area did not specify which species are included in the use area. 

2) Data is from the ADF&G Community Subsistence Information System (CSIS), available at http://www.adfg.alaska.gov/sb/CSIS/ 

O-1-25 
BSWI Draft RMP/EIS Appendix O: ANILCA Preliminary Section 810 Evaluation 

Impact Analysis Results—Marshall 

Aggregated 

Subsistence 

Use Category 

Species 

Included in 

Aggregated 

Category1 

Annual 

Pounds of 

Resource 

Harvested2 

Alternative A 

Significant Impact? [POSITIVE FINDING?] 

Alternative B 

Significant Impact? [POSITIVE FINDING?] 

Alternative C 

Significant Impact? [POSITIVE FINDING?] 

 

 

 

 

 

 

 

 

 

 

Alternative D 

Significant Impact? [POSITIVE FINDING?] 

LM: Close to 0% of the use area would overlap with LM 

decisions with med/high potential. Negative (-). LM: Close to 0% of the use area would overlap with LM 

decisions with med/high potential. Negative (-). LM: Close to 0% of the use area would overlap with LM 

Hunting and 

Trapping (LLM) LLM 72.0 

LM: Close to 0% of the use area would overlap with LM 

decisions with med/high potential. Negative (-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter use. 25% 

of the use area limits summer casual use to existing trails. 

This same 25% is also limited to snowmobiles only for 

casual winter use. Therefore, there is no access 

restriction for subsistence uses and the greatest 

protection against habitat degradation and competing 

uses, as compared to Alternative A. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter use. 25% 

of the use area limits summer casual use to existing trails. 

There is no limit for OHV use for casual winter use. 

Therefore, there is no access restriction for subsistence 

uses and the greatest protection against habitat 

degradation and competing uses, as compared to 

Alternative A. Negative (-). 

decisions with med/high potential. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

ROW: 8% of use area would be open to ROW location, 

15% would be ROW avoidance areas, and 2% would be 

ROW exclusion areas. This alternative would minimize 

habitat fragmentation and degradation in these areas, as 

compared to Alternative A. LLM are one of the top 

resources harvested in the community. Access does not 

appear to be impacted by the open ROW areas, though 

habitat may be degraded ROWs in open and avoidance 

areas. Positive (+). 

ROW: 14% of use area would be open to ROW location, 

10% would be ROW avoidance areas, and 1% would be 

ROW avoidance areas for linear realty. This alternative 

would decrease habitat fragmentation and degradation in 

these areas, as compared to Alternative A, though the 

areas impacted are above the threshold. LLM is one of 

the most highly harvested resources in the community. 

Positive (+). 

This is the same impact as Alternative A. Positive (+). 

ROW: 21% of use area would be open to ROW location, 

4% would be ROW avoidance areas. This alternative 

would decrease habitat fragmentation and degradation in 

these areas, as compared to Alternative A. LLM is one of 

the most highly harvested resources in the community. 

Positive (+). 

LM: Close to 0% of the use area would overlap with LM 

decisions with med/high potential. Negative (-). 

LM: Close to 0% of the use area would overlap with LM 

decisions with med/high potential. Negative (-). 

LM: Close to 0% of the use area would overlap with LM 

decisions with med/high potential. Negative (-). 

Hunting and 

Trapping (SLM) SLM 5.8 

LM: Close to 0% of the use area would overlap with LM 

decisions with med/high potential. Negative (-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter use. 48% 

of the use area limits summer casual use to existing trails. 

This same 48% is also limited to snowmobiles only for 

casual winter use. Therefore, there is no access 

restriction for subsistence uses and the greatest 

protection against habitat degradation and competing 

uses, as compared to Alternative A. Negative (-). 

ROW: 8% of use area would be open to ROW location, 

15% would be ROW avoidance areas, and 2% would be 

ROW exclusion areas. This alternative would minimize 

habitat fragmentation and degradation in these areas, as 

compared to Alternative A. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter use. 48% 

of the use area limits summer casual use to existing trails. 

There is no limit for OHV use for casual winter use. 

Therefore, there is no access restriction for subsistence 

uses and the greatest protection against habitat 

degradation and competing uses, as compared to 

Alternative A. Negative (-). 

ROW: 9% of use area would be open to ROW location, 

15% would be ROW avoidance areas, and 39% would be 

ROW exclusion areas. This alternative would minimize 

habitat fragmentation and degradation in these areas, as 

compared to Alternative A. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

ROW: 28% of use area would be open to ROW location, 

15% would be ROW avoidance areas, and 20% would be 

ROW exclusion areas. This alternative would minimize 

habitat fragmentation and degradation in these areas, as 

compared to Alternative A, but is over the threshold. 

Positive (+). 

LM: No overlap in open areas and use areas. Negative 

(-). 

LM: No overlap in open areas and use areas. Negative 

(-). LM: No overlap in open areas and use areas. Negative 

(-). 

Hunting (Birds) Birds 13.7 

LM: No overlap in open areas and use areas. Negative 

(-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter use. 1% of 

the use area limits summer casual use to existing trails. 

This same 1% is also limited to snowmobiles only for 

casual winter use. Therefore, there is no access 

restriction for subsistence uses and the greatest 

protection against habitat degradation and competing 

uses, as compared to Alternative A. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter use. 1% of 

the use area limits summer casual use to existing trails. 

There is no limit for OHV use for casual winter use. 

Therefore, there is no access restriction for subsistence 

uses and the greatest protection against habitat 

degradation and competing uses, as compared to 

Alternative A. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

fragment habitats and degrade subsistence resources. 

Positive (+). ROW: 0% of use area would be open to ROW location, 

1% would be ROW avoidance areas. This alternative 

would minimize habitat fragmentation and degradation in 

these areas, as compared to Alternative A. Negative (-). 

ROW: Close to 0% of use area would be open to ROW 

location, close to 1% would be ROW avoidance. This 

alternative would minimize habitat fragmentation and 

degradation in these areas, as compared to Alternative A. 

Negative (-). 

ROW: 1% would be open to ROWs at the edge of the use 

area. Bird harvesting is not a significant portion of the 

resources harvested for this community. Negative (-). 

O-1-26 
Appendix O: ANILCA Preliminary Section 810 Evaluation BSWI Draft RMP/EIS 

Aggregated 

Subsistence 

Use Category 

Species 

Included in 

Aggregated 

Category1 

Annual 

Pounds of 

Resource 

Harvested2 

Alternative A 

Significant Impact? [POSITIVE FINDING?] 

Alternative B 

Significant Impact? [POSITIVE FINDING?] 

Alternative C 

Significant Impact? [POSITIVE FINDING?] 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Alternative D 

Significant Impact? [POSITIVE FINDING?] 

Fishing Salmon 

Salmon: 

393.2 

Nonsalmon 

Fish: 

194.3 

LM: No overlap in open areas and use areas. Negative 

(-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

LM: No overlap in open areas and use areas. Negative 

(-). 

OHV: Only a small portion of BLM land lies near the 

fishing locations for the community. These areas limit 

casual summer use to existing trails and casual winter 

use to snowmobiles only. There would be no access 

restrictions for subsistence uses. Negative (-). 

ROW: Close to 0% of the use area would be open and 

close to 0% would be avoidance areas. These portions of 

land are towards the edges of the fishing locations and 

would not impede access. Negative (-). 

LM: No overlap in open areas and use areas. Negative 

(-). 

OHV: Only a small portion of BLM land lies near the 

fishing locations for the community. These areas limit 

casual summer use to existing trails. There would be no 

access restrictions for subsistence uses. Negative (-). 

ROW: Close to 0% of the use area would be open to 

ROWs. These portions of land are towards the edges of 

the fishing locations and would not impede access. 

Negative (-). 

LM: No overlap in open areas and use areas. Negative 

(-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

ROW: Same as Alternative C. Negative (-). 

LM: Close to 0% of the use area would overlap with LM 

decisions with med/high potential. Negative (-). LM: Close to 0% of the use area would overlap with LM 

decisions with med/high potential. Negative (-). 

LM: Close to 0% of the use area would overlap with LM 

decisions with med/high potential. Negative (-). 

Gathering Vegetation 8.2 

LM: Close to 0% of the use area would overlap with LM 

decisions with med/high potential. Negative (-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter use. 24% 

of the use area limits summer casual use to existing trails. 

This same 24% is also limited to snowmobiles only for 

casual winter use. Therefore, there is no access 

restriction for subsistence uses and the greatest 

protection against habitat degradation and competing 

uses, as compared to Alternative A. Negative (-). 

ROW: 5% of use area would be open to ROW location, 

17% would be ROW avoidance areas, and 2% would be 

ROW exclusion areas. This alternative would minimize 

habitat fragmentation and degradation in these areas, as 

compared to Alternative A. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. 24% of the use area limits summer 

casual use to existing trails. 0% of the use area has 

limitations placed on winter casual use and therefore all 

winter OHVs are allowed. Negative (-). 

ROW: 10% of use area would be open to ROW location, 

13% would be ROW avoidance areas, and 1% would be 

ROW avoidance areas for linear realty. This alternative 

would minimize habitat fragmentation and degradation in 

these areas, as compared to Alternative A, but is above 

the threshold. Positive (+). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

ROW: 18% of use area would be open to ROW location, 

6% would be ROW avoidance areas. This alternative 

would decrease habitat fragmentation and degradation in 

these areas, as compared to Alternative A. Positive (+). 

Notes: 

LM: Locatable minerals with med/high potential 

OHV: travel decisions relating to OHV use 

ROW: Right-of-way decisions 

Impact analysis to determine whether there is a positive or negative finding is based on an assessment of magnitude, duration, extent, likelihood, and intensity. 

1) This column shows which species the BSWI EIS Team has GIS data for at the time of the DEIS release. Communities may have differing sets of data available or may be missing data completely for an aggregated category. In most instances where data sets for "Hunting and Trapping (SLM)" were 

available, the subsistence use area did not specify which species are included in the use area. 

2) Data is from the ADF&G Community Subsistence Information System (CSIS), available at http://www.adfg.alaska.gov/sb/CSIS/ 

O-1-27 
BSWI Draft RMP/EIS Appendix O: ANILCA Preliminary Section 810 Evaluation 

Impact Analysis Results—McGrath 

Aggregated 

Subsistence 

Use Category 

Species 

Included in 

Aggregated 

Category1 

Annual 

Pounds of 

Resource 

Harvested2 

Alternative A 

Significant Impact? [POSITIVE FINDING?] 

Alternative B 

Significant Impact? [POSITIVE FINDING?] 

Alternative C 

Significant Impact? [POSITIVE FINDING?] 

 

 

 

 

 

 

 

Alternative D 

Significant Impact? [POSITIVE FINDING?] 

Hunting and 

Trapping (LLM) 

Black Bear 

Brown Bear 

Caribou 

Moose 

115.0 

LM: Nearly 0% of the use area is open to LM and have 

med/high potential. Negative (-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

LM: 1% of the use area has med/high potential for LM. 

LLM is the most harvested resource (by weight). This 

area of open LM is located on a tributary of the 

Kuskokwim. It covers a portion of the use area that leads 

to further upstream areas for LLM harvest, but it appears 

that access could still be achieved in portions of the 

surrounding land. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter use. 7% of 

the use area limits summer casual use to existing trails. 

This same 7% is also limited to snowmobiles only for 

casual winter use. Therefore, there is no access 

restriction for subsistence uses and the greatest 

protection against habitat degradation and competing 

uses, as compared to Alternative A. Negative (-). 

ROW: 1% of use area would be open to ROW location, 

5% would be ROW avoidance areas, and 0% would be 

ROW exclusion areas. This alternative would minimize 

habitat fragmentation and degradation in these areas, as 

compared to Alternative A. Negative (-). 

LM: Same as Alternative B. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter use. 7% of 

the use area limits summer casual use to existing trails. 

There is no OHV limitation for casual winter use. 

Therefore, there is no access restriction for subsistence 

uses and the greater protection against habitat 

degradation and competing uses, as compared to 

Alternative A. Negative (-). 

ROW: 5% of use area would be open to ROW location, 

2% would be ROW avoidance areas, and 0% would be 

ROW exclusion areas. This alternative would limit habitat 

fragmentation and degradation in these areas, as 

compared to Alternative A. Negative (-). 

LM: Same as Alternative B. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

ROW: 6% of use area would be open to ROW location, 

2% would be ROW avoidance areas, and 0% would be 

ROW exclusion areas. This alternative would limit habitat 

fragmentation and degradation in these areas, as 

compared to Alternative A. Negative (-). 

LM: Nearly 0% of the use area is open to LM and have 

med/high potential. Negative (-). 

OHV: 1% of use area is prohibited for summer 

LM: Nearly 0% of the use area is open to LM and have 

med/high potential. Negative (-). LM: Nearly 0% of the use area is open to LM and have 

med/high potential. Negative (-). 

Hunting and 

Trapping (SLM) 

SLM 

Beaver 

Wolf 

11.3 

LM: Nearly 0% of the use area is open to LM and have 

med/high potential. Negative (-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

subsistence use (in the INHT) and 15% is restricted for 

winter subsistence use to snowmobiles only. 23% of the 

use area limits summer casual use to existing trails and 

1% is prohibited to casual OHV use. 24% is limited to 

snowmobiles only for casual winter use. There would be 

access restriction for subsistence uses in the 1% of the 

use area that prohibits OHV use in the summer, and the 

15% that limits winter subsistence OHV use to 

snowmobiles only. This alternative provides the greatest 

protection against habitat degradation and competing 

uses, as compared to Alternative A, but the access 

impacts would be significant. Positive (+). 

ROW: 8% of use area would be open to ROW location, 

12% would be ROW avoidance areas, and 4% would be 

ROW exclusion areas. This alternative would minimize 

habitat fragmentation and degradation in these areas, as 

OHV: 1% of use area is prohibited for summer 

subsistence use (in the INHT) and 4% is restricted for 

winter subsistence use to snowmobiles only. 23% of the 

use area limits summer casual use to existing trails and 

1% is prohibited to casual OHV use. 4% of casual winter 

OHV use is limited to snowmobiles only. The access 

impacts to subsistence users does not meet the 

threshold, and this alternative provides greater protection 

to resources than Alternative A. Negative (-). 

ROW: 14% of use area would be open to ROW location, 

9% would be ROW avoidance areas, and 0% would be 

ROW exclusion areas. This alternative would limit habitat 

fragmentation and degradation in these areas, as 

compared to Alternative A, but is above the threshold for 

impacts. Positive (+). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

ROW: 15% of use area would be open to ROW location, 

9% would be ROW avoidance areas, and 0% would be 

ROW exclusion areas. This alternative would limit habitat 

fragmentation and degradation in these areas, as 

compared to Alternative A, but is above the threshold for 

impacts. Positive (+). 

compared to Alternative A. Negative (-). 

O-1-28 
Appendix O: ANILCA Preliminary Section 810 Evaluation BSWI Draft RMP/EIS 

Aggregated 

Subsistence 

Use Category 

Species 

Included in 

Aggregated 

Category1 

Annual 

Pounds of 

Resource 

Harvested2 

Alternative A 

Significant Impact? [POSITIVE FINDING?] 

Alternative B 

Significant Impact? [POSITIVE FINDING?] 

Alternative C 

Significant Impact? [POSITIVE FINDING?] 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Alternative D 

Significant Impact? [POSITIVE FINDING?] 

Hunting (Birds) 

Ducks 

Geese 

Ptarmigan 

Grouse 

9.1 

LM: Nearly 0% of the use area is open to LM and have 

med/high potential. Negative (-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

LM: 1% of the use area is open to LM with med/high 

potential. This does not meet the threshold and birds are 

not one of the top harvested resources. It covers a portion 

of the use area that leads to further upstream areas for 

bird harvest, but it appears that access could still be 

achieved in portions of the surrounding land. Negative (-) 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. 8% of the use area limits summer 

casual use to existing trails. 8% is limited to snowmobiles 

only for casual winter use. This alternative provides the 

greatest protection against habitat degradation and 

competing uses, as compared to Alternative A. Negative 

(-). 

ROW: 2% of use area would be open to ROW location, 

6% would be ROW avoidance areas, and 0% would be 

ROW exclusion areas. This alternative would minimize 

habitat fragmentation and degradation in these areas, as 

compared to Alternative A. Negative (-). 

LM: Same as Alternative B. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. 8% of the use area limits summer 

casual use to existing trails. There are no restrictions for 

casual winter use. This alternative provides the greatest 

protection against habitat degradation and competing 

uses, as compared to Alternative A. Negative (-). 

ROW: 6% of use area would be open to ROW location, 

2% would be ROW avoidance areas, and 0% would be 

ROW exclusion areas. This alternative would limit habitat 

fragmentation and degradation in these areas, as 

compared to Alternative A. Negative (-). 

LM: Same as Alternative B. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

ROW: 7% of use area would be open to ROW location, 

1% would be ROW avoidance areas, and 0% would be 

ROW exclusion areas. This alternative would limit habitat 

fragmentation and degradation in these areas, as 

compared to Alternative A. Negative (-). 

Fishing 

Burbot 

Chinook 

Chum 

Pike 

Salmon 

Sheefish 

Whitefish 

Salmon: 

66.0 

Nonsalmon 

Fish: 

25.6 

LM: Fishing locations for the community are upstream of 

LM decisions with med/high potential. Fish is one of the 

largest portions of harvested resources for the 

community, but access will not be impeded by LM areas, 

nor will habitat or resources be degraded based on the 

location of the LM areas. Negative (-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

LM: Some open areas are positioned upstream of 

numerous fish harvesting areas. This has the potential to 

degrade habitat and increase competition for the 

resource. Fish are one of the most harvested resources in 

the community (by weight). Positive (+). 

OHV: Access to fishing locations is not impacted by the 

areas closed to subsistence OHV summer use or 

limitations to winter OHV use for subsistence users. 

Negative (-). 

ROW: Some areas that are open to ROW placement are 

upstream of or close to known fishing locations for the 

community. Because fish is one of the most harvested 

resources (by weight), this could cause habitat 

degradation and increase competition for resources. 

Positive (+). 

LM: Some open areas are positioned upstream of 

numerous fish harvesting areas. This has the potential to 

degrade habitat and increase competition for the 

resource. Fish are one of the most harvested resources in 

the community (by weight). Positive (+). 

OHV: Access to fishing locations is not impacted by the 

areas closed to subsistence OHV summer use or 

limitations to winter OHV use for subsistence users. 

Negative (-). 

ROW: Some areas that are open to ROW placement are 

upstream of or close to known fishing locations for the 

community. Because fish is one of the most harvested 

resources (by weight), this could cause habitat 

degradation and increase competition for resources. 

Positive (+). 

LM: Some open areas are positioned upstream of 

numerous fish harvesting areas. This has the potential to 

degrade habitat and increase competition for the 

resource. Fish are one of the most harvested resources in 

the community (by weight). Positive (+). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

ROW: Some areas that are open to ROW placement are 

upstream of or close to known fishing locations for the 

community. Because fish is one of the most harvested 

resources (by weight), this could cause habitat 

degradation and increase competition for resources. 

Positive (+). 

Gathering Berries 

Greens 14.2 

LM: There is no overlap between Gathering and LM areas 

with med/high potential. Negative (-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

LM: There is no overlap between Gathering and LM areas 

with med/high potential. Negative (-). 

OHV: There is no overlap between Gathering and OHV 

decisions. Negative (-). 

LM: There is no overlap between Gathering and LM areas 

with med/high potential. Negative (-). 

OHV: There is no overlap between Gathering and OHV 

decisions. Negative (-). 

LM: There is no overlap between Gathering and LM areas 

with med/high potential. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

ROW: There is no overlap between Gathering and ROW 

decisions. Negative (-). 

ROW: There is no overlap between Gathering and ROW 

decisions. Negative (-). 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

ROW: There is no overlap between Gathering and ROW 

decisions. Negative (-). 

Notes: 

LM: Locatable minerals with med/high potential 

OHV: travel decisions relating to OHV use 

ROW: Right-of-way decisions 

Impact analysis to determine whether there is a positive or negative finding is based on an assessment of magnitude, duration, extent, likelihood, and intensity. 

O-1-29 
BSWI Draft RMP/EIS Appendix O: ANILCA Preliminary Section 810 Evaluation 

1) This column shows which species the BSWI EIS Team has GIS data for at the time of the DEIS release. Communities may have differing sets of data available or may be missing data completely for an aggregated category. In most instances where data sets for "Hunting and Trapping (SLM)" were 

available, the subsistence use area did not specify which species are included in the use area. 

2) Data is from the ADF&G Community Subsistence Information System (CSIS), available at http://www.adfg.alaska.gov/sb/CSIS/ 

O-1-30 
Appendix O: ANILCA Preliminary Section 810 Evaluation BSWI Draft RMP/EIS 

Impact Analysis Results—Nikolai 

Aggregated 

Subsistence 

Use Category 

Species 

Included in 

Aggregated 

Category1 

Annual 

Pounds of 

Resource 

Harvested2 

Alternative A 

Significant Impact? [POSITIVE FINDING?] 

Alternative B 

Significant Impact? [POSITIVE FINDING?] 

Alternative C 

Significant Impact? [POSITIVE FINDING?] 

 

 

 

 

 

 

 

 

Alternative D 

Significant Impact? [POSITIVE FINDING?] 

Hunting and 

Trapping (LLM) 

Black Bear 

Brown Bear 

Caribou 

Moose 

247.2 

LM: There is no overlap between LLM and LM areas with 

med/high potential. Negative (-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

LM: There is no overlap between LLM and LM areas with 

med/high potential. Negative (-). 

OHV: Less than 1% of use area is prohibited for summer 

subsistence use (in the INHT) and 17% is restricted for 

winter subsistence use to snowmobiles only. 18% of the 

use area limits summer casual use to existing trails and 

less than 1% is prohibited to casual OHV use. 18% is 

limited to snowmobiles only for casual winter use. There 

would be access restriction for subsistence uses in the 

1% of the use area that prohibits OHV use in the summer, 

and the 17% that limits winter subsistence OHV use to 

snowmobiles only. This alternative provides the greatest 

protection against habitat degradation and competing 

uses, as compared to Alternative A, but the access 

impacts would be significant. LLM is the most highly 

harvest resource in the community. Positive (+). 

ROW: Close to 0% of use area would be open to ROW 

location, 17% would be ROW avoidance areas, and 1% 

would be ROW exclusion areas. This alternative would 

minimize habitat fragmentation and degradation in these 

areas, as compared to Alternative A. Negative (-). 

LM: There is no overlap between LLM and LM areas with 

med/high potential. Negative (-). 

OHV: Less than 1% of use area is prohibited for summer 

subsistence use (in the INHT) and 6% is restricted for 

winter subsistence use to snowmobiles only. 6% of the 

use area limits summer casual use to existing trails and 

less than 1% is prohibited to casual OHV use. There are 

no restrictions to casual winter use outside of the INHT 

area. There would be access restriction for subsistence 

uses in the 1% of the use area that prohibits OHV use in 

the summer, and the 6% that limits winter subsistence 

OHV use to snowmobiles only. This alternative provides 

more protection against habitat degradation and 

competing uses, as compared to Alternative A, but the 

access impacts would be significant for LLM, which is the 

most highly harvest resource in the community. Positive 

(+). 

ROW: 8% of use area would be open to ROW location, 

10% would be ROW avoidance areas. This alternative 

would minimize habitat fragmentation and degradation in 

these areas, as compared to Alternative A. Negative (-). 

LM: There is no overlap between LLM and LM areas with 

med/high potential. Negative (-). 

OHV: Less than 1% of use area is restricted for summer 

subsistence use and less than 1% is restricted for winter 

subsistence use. However, summer casual use is 

restricted to existing trails for that same portion of land, 

which could lead to degradation of habitat and conflict 

from competing uses. Winter casual and subsistence use 

is restricted to snowmobiles only for this 1%, and the rest 

of the BLM land in the use area is open to all winter OHV 

uses. This is similar impact as Alternative A. Positive (+). 

ROW: 8% of use area would be open to ROW location, 

10% would be ROW avoidance areas. This alternative 

would minimize habitat fragmentation and degradation in 

these areas, as compared to Alternative A. Negative (-). 

Hunting and 

Trapping (SLM) SLM 14.6 

LM: There is no overlap between SLM and LM areas with 

med/high potential. Negative (-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

LM: There is no overlap between SLM and LM areas with 

med/high potential. Negative (-). 

OHV: 1% of use area is prohibited for summer 

subsistence use (in the INHT) and 7% is restricted for 

winter subsistence use to snowmobiles only. 10% of the 

use area limits summer casual use to existing trails and 

less than 1% is prohibited to casual OHV use. 10% is 

limited to snowmobiles only for casual winter use. There 

would be access restriction for subsistence uses in the 

1% of the use area that prohibits OHV use in the summer, 

and the 7% that limits winter subsistence OHV use to 

snowmobiles only. This alternative provides the greatest 

protection against habitat degradation and competing 

uses, as compared to Alternative A. The area where 

casual and subsistence OHV use is prohibited would cut 

off a portion of the use area, which could be a significant 

impact. Positive (+). 

ROW: Close to 0% of use area would be open to ROW 

location, 9% would be ROW avoidance areas, and 1% 

would be ROW exclusion areas. This alternative would 

minimize habitat fragmentation and degradation in these 

areas, as compared to Alternative A. Negative (-). 

LM: There is no overlap between SLM and LM areas with 

med/high potential. Negative (-). 

OHV: Less than 1% of use area is prohibited for summer 

subsistence use (in the INHT) and 9% is restricted for 

winter subsistence use to snowmobiles only. 30% of the 

use area limits summer casual use to existing trails and 

less than 1% is prohibited to casual OHV use. There are 

no restrictions to casual winter use outside of the INHT 

area. There would be access restriction for subsistence 

uses in the 1% of the use area that prohibits OHV use in 

the summer, and the 9% that limits winter subsistence 

OHV use to snowmobiles only. This alternative provides 

more protection against habitat degradation and 

competing uses, as compared to Alternative A. The area 

where casual and subsistence OHV use is prohibited 

would cut off a portion of the use area, which could be a 

significant impact. Positive (+). 

ROW: 3% of use area would be open to ROW location, 

7% would be ROW avoidance areas. This alternative 

would minimize habitat fragmentation and degradation in 

these areas, as compared to Alternative A. Some SLM 

routes are crossed by open areas, but this resource was 

not one of the top harvested resources based on 2011 

data. Negative (-). 

LM: There is no overlap between SLM and LM areas with 

med/high potential. Negative (-). 

OHV: 1% of use area is restricted for summer 

subsistence use and 1% is restricted for winter 

subsistence use. However, summer casual use is 

restricted to existing trails for that same portion of land, 

which could lead to degradation of habitat and conflict 

from competing uses. Winter casual and subsistence use 

is restricted to snowmobiles only for this 1%, and the rest 

of the BLM land in the use area is open to all winter OHV 

uses. This is similar impact as Alternative A. Positive (+). 

ROW: Same as Alternative C. Negative (-). 

O-1-31 
BSWI Draft RMP/EIS Appendix O: ANILCA Preliminary Section 810 Evaluation 

Aggregated 

Subsistence 

Use Category 

Species 

Included in 

Aggregated 

Category1 

Annual 

Pounds of 

Resource 

Harvested2 

Alternative A 

Significant Impact? [POSITIVE FINDING?] 

Alternative B 

Significant Impact? [POSITIVE FINDING?] 

Alternative C 

Significant Impact? [POSITIVE FINDING?] 

 

Alternative D 

Significant Impact? [POSITIVE FINDING?] 

LM: There is no overlap between birds and LM areas with 

med/high potential. Negative (-). 

LM: There is no overlap between birds and LM areas with 

med/high potential. Negative (-). 

Hunting (Birds) 

Ducks 

Geese 

Ptarmigan 

Grouse 

24.4 

LM: There is no overlap between birds and LM areas with 

med/high potential. Negative (-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

OHV: Less than 1% of use area is prohibited for summer 

subsistence use (in the INHT) and 27% is restricted for 

winter subsistence use to snowmobiles only. 30% of the 

use area limits summer casual use to existing trails and 

less than 1% is prohibited to casual OHV use. 10% is 

limited to snowmobiles only for casual winter use. There 

would be access restriction for subsistence uses in the 

1% of the use area that prohibits OHV use in the summer, 

and the 27% that limits winter subsistence OHV use to 

snowmobiles only. This alternative provides the greatest 

protection against habitat degradation and competing 

uses, as compared to Alternative A. The area where 

casual and subsistence OHV use is prohibited would cut 

off a portion of the use area, which could be a significant 

impact. Positive (+). 

ROW: 1% of use area would be open to ROW location, 

28% would be ROW avoidance areas, and 2% would be 

ROW exclusion areas. This alternative would minimize 

habitat fragmentation and degradation in these areas, as 

compared to Alternative A. Negative (-). 

OHV: Less than 1% of use area is prohibited for summer 

subsistence use (in the INHT) and 9% is restricted for 

winter subsistence use to snowmobiles only. 30% of the 

use area limits summer casual use to existing trails and 

less than 1% is prohibited to casual OHV use. 9% is 

limited to snowmobiles only for casual winter use. There 

would be access restriction for subsistence uses in the 

1% of the use area that prohibits OHV use in the summer, 

and the 30% that limits winter subsistence OHV use to 

snowmobiles only. This alternative provides the greatest 

protection against habitat degradation and competing 

uses, as compared to Alternative A. The area where 

casual and subsistence OHV use is prohibited would cut 

off a portion of the use area, which could be a significant 

impact. Positive (+). 

ROW: 12% of use area would be open to ROW location, 

18% would be ROW avoidance areas. This alternative 

would minimize habitat fragmentation and degradation in 

these areas, as compared to Alternative A, but the open 

areas are over the threshold. Positive (+). 

LM: There is no overlap between birds and LM areas with 

med/high potential. Negative (-). 

OHV: Less than 1% of use area is restricted for summer 

subsistence use and less than 1% is restricted for winter 

subsistence use. However, summer casual use is 

restricted to existing trails for that same portion of land, 

which could lead to degradation of habitat and conflict 

from competing uses. Winter casual and subsistence use 

is restricted to snowmobiles only for this 1%, and the rest 

of the BLM land in the use area is open to all winter OHV 

uses. This is similar impact as Alternative A. Positive (+). 

ROW: 13% of use area would be open to ROW location, 

17% would be ROW avoidance areas. This alternative 

would minimize habitat fragmentation and degradation in 

these areas, as compared to Alternative A, but the open 

areas are over the threshold. Positive (+). 

LM: There is no overlap between fish and LM areas with 

med/high potential. Negative (-). 

LM: There is no overlap between fish and LM areas with 

med/high potential. Negative (-). 

LM: There is no overlap between fish and LM areas with 

med/high potential. Negative (-). 

Fishing 

Pike 

Salmon 

Sheefish 

Whitefish 

Salmon: 

131.0 

Nonsalmon 

Fish: 

75.9 

LM: There is no overlap between fish and LM areas with 

med/high potential. Negative (-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

OHV: A portion of the INHT that prohibits subsistence 

OHV use in the summer and limits OHV use in the winter 

would cover known fishing locations for the community. 

This would be an impact to access. Positive (+). 

ROW: Areas open to ROWs exist close to fishing 

locations and make up a large portion of the upstream 

basins of the Salmon River and other tributaries to the 

Kuskokwim, which could contribute to degradation of 

habitat and increased competition for resources. Fish are 

one of the top harvested resource for the community. 

Positive (+). 

OHV: A portion of the INHT that prohibits subsistence 

OHV use in the summer and limits OHV use in the winter 

would cover known fishing locations for the community. 

This would be an impact to access. Positive (+). 

ROW: Areas open to ROWs exist close to fishing 

locations and make up a large portion of the upstream 

basins of the Salmon River and other tributaries to the 

Kuskokwim, which could contribute to degradation of 

habitat and increased competition for resources. Fish are 

one of the top harvested resource for the community. 

Positive (+). 

OHV: A portion of the INHT that prohibits subsistence 

OHV use in the summer and limits OHV use in the winter 

would cover known fishing locations for the community. 

This would be an impact to access. Positive. This is the 

same impact as Alternative A. Positive (+). 

ROW: Areas open to ROWs exist close to fishing 

locations and make up a large portion of the upstream 

basins of the Salmon River and other tributaries to the 

Kuskokwim, which could contribute to degradation of 

habitat and increased competition for resources. Fish are 

one of the top harvested resource for the community. 

Positive (+). 

LM: There is no overlap between gathering and LM areas 

with med/high potential. Negative (-). 

LM: There is no overlap between gathering and LM areas 

with med/high potential. Negative (-). 

LM: There is no overlap between gathering and LM areas 

Gathering Berries 

Greens 9.8 

LM: There is no overlap between gathering and LM areas 

with med/high potential. Negative (-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

OHV: 0% of use area is prohibited for summer 

subsistence use and 56% is restricted for winter 

subsistence use to snowmobiles only. 58% of the use 

area limits summer casual use to existing trails and 58% 

is limited to snowmobiles only for casual winter use. 

There would be access restriction for subsistence uses in 

the 56% that limits winter subsistence OHV use to 

snowmobiles only. This alternative provides the greatest 

protection against habitat degradation and competing 

uses, as compared to Alternative A, but the access 

impacts would be significant for any winter gathering. 

Positive (+). 

ROW: Close to 0% of use area would be open to ROW 

location, 55% would be ROW avoidance areas, and 3% 

would be ROW exclusion areas. This alternative would 

minimize habitat fragmentation and degradation in these 

areas, as compared to Alternative A. Negative (-). 

OHV: 0% of use area is prohibited for summer 

subsistence use and 17% is restricted for winter 

subsistence use to snowmobiles only. 58% of the use 

area limits summer casual use to existing trails and 17% 

is limited to snowmobiles only for casual winter use. 

There would be access restriction for subsistence uses in 

the 17% that limits winter subsistence OHV use to 

snowmobiles only. This alternative provides greater 

protection against habitat degradation and competing 

uses, as compared to Alternative A, but the access 

impacts would be significant for any winter gathering. 

Positive (+). 

ROW: 26% of use area would be open to ROW location, 

32% would be ROW avoidance areas. This alternative 

would minimize habitat fragmentation and degradation in 

these areas, as compared to Alternative A, but the open 

areas are over the threshold of the assumptions of the 

analysis. Positive (+). 

with med/high potential. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

ROW: 27% of use area would be open to ROW location, 

31% would be ROW avoidance areas. This alternative 

would minimize habitat fragmentation and degradation in 

these areas, as compared to Alternative A, but the open 

areas are over the threshold of the assumptions of the 

analysis Positive (+). 

O-1-32 
Appendix O: ANILCA Preliminary Section 810 Evaluation BSWI Draft RMP/EIS 

Notes: 

LM: Locatable minerals with med/high potential 

OHV: travel decisions relating to OHV use 

ROW: Right-of-way decisions 

Impact analysis to determine whether there is a positive or negative finding is based on an assessment of magnitude, duration, extent, likelihood, and intensity. 

1) This column shows which species the BSWI EIS Team has GIS data for at the time of the DEIS release. Communities may have differing sets of data available or may be missing data completely for an aggregated category. In most instances where data sets for "Hunting and Trapping (SLM)" were 

available, the subsistence use area did not specify which species are included in the use area. 

2) Data is from the ADF&G Community Subsistence Information System (CSIS), available at http://www.adfg.alaska.gov/sb/CSIS/ 

O-1-33 
BSWI Draft RMP/EIS Appendix O: ANILCA Preliminary Section 810 Evaluation 

Impact Analysis Results—Nulato 

Aggregated 

Subsistence 

Use Category 

Species 

Included in 

Aggregated 

Category1 

Annual 

Pounds of 

Resource 

Harvested2 

Alternative A 

Significant Impact? [POSITIVE FINDING?] 

Alternative B 

Significant Impact? [POSITIVE FINDING?] 

Alternative C 

Significant Impact? [POSITIVE FINDING?] 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Alternative D 

Significant Impact? [POSITIVE FINDING?] 

LM: There is no overlap between LLM and LM areas with 

med/high potential. Negative (-). LM: There is no overlap between LLM and LM areas with 

med/high potential. Negative (-). 

LM: There is no overlap between LLM and LM areas with 

med/high potential. Negative (-). 

Hunting and 

Trapping (LLM) 85.5 

LM: There is no overlap between LLM and LM areas with 

med/high potential. Negative (-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for subsistence 

winter use to snowmobiles. 3% of the use area limits 

summer casual use to existing trails. This same 3% is 

also limited to snowmobiles only for casual winter use. 

Therefore, there are no access restriction for subsistence 

uses and the greatest protection against habitat 

degradation and competing uses, as compared to 

Alternative A. Negative (-). 

ROW: 2% of use area would be open to ROW location, 

1% would be ROW avoidance areas, and close to 0% 

would be ROW exclusion areas. This alternative would 

minimize habitat fragmentation and degradation in these 

areas, as compared to Alternative A. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter use. 3% of 

the use area limits summer casual use to existing trails. 

There is no OHV limitation for casual winter use. 

Therefore, there is no access restriction for subsistence 

uses and greater protection against habitat degradation 

and competing uses, as compared to Alternative A. 

Negative (-). 

ROW: 3% of use area would be open to ROW location, 

close to 0% would be ROW avoidance areas. This 

alternative would minimize habitat fragmentation and 

degradation in these areas, as compared to Alternative A. 

Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

ROW: 3% of use area would be open to ROW location, 

close to 0% would be ROW avoidance areas. This 

alternative would minimize habitat fragmentation and 

degradation in these areas, as compared to Alternative A. 

Negative (-). 

Hunting and 

Trapping (SLM) 9.3 

LM: There is no overlap between SLM and LM areas with 

med/high potential. Negative (-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

LM: There is no overlap between SLM and LM areas with 

med/high potential. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and close to 0% is restricted for 

subsistence winter use to snowmobiles. 1% of the use 

area limits summer casual use to existing trails. This 

same 1% is also limited to snowmobiles only for casual 

winter use. Therefore, there is limited access restriction 

for subsistence uses and the greatest protection against 

habitat degradation and competing uses, as compared to 

Alternative A. Negative (-). 

ROW: 1% of use area would be ROW avoidance areas. 

This alternative would minimize habitat fragmentation and 

degradation in these areas, as compared to Alternative A. 

Negative (-). 

LM: There is no overlap between SLM and LM areas with 

med/high potential. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and close to 0% is restricted for winter 

use. 1% of the use area limits summer casual use to 

existing trails. Close to 0% of the use area restricts casual 

winter OHV use to snowmobiles only. Therefore, there is 

limited access restriction for subsistence uses and 

greater protection against habitat degradation and 

competing uses, as compared to Alternative A. Negative 

(-). 

ROW: Same as Alternative B. Negative (-). 

LM: There is no overlap between SLM and LM areas with 

med/high potential. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

ROW: Same as Alternative B. Negative (-). 

Hunting (Birds) 2.4 

LM: There is no overlap between bird hunting and LM 

areas with med/high potential. Negative (-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

LM: There is no overlap between bird hunting and LM 

areas with med/high potential. Negative (-). 

OHV: There is no overlap between bird hunting and OHV 

decisions. Negative (-). 

ROW: There is no overlap between bird hunting and 

ROW decisions. Negative (-). 

LM: There is no overlap between bird hunting and LM 

areas with med/high potential. Negative (-). 

OHV: There is no overlap between bird hunting and OHV 

decisions. Negative (-). 

ROW: There is no overlap between bird hunting and 

ROW decisions. Negative (-). 

LM: There is no overlap between bird hunting and LM 

areas with med/high potential. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

ROW: There is no overlap between bird hunting and 

ROW decisions. Negative (-). 

O-1-34 
Appendix O: ANILCA Preliminary Section 810 Evaluation BSWI Draft RMP/EIS 

Aggregated 

Subsistence 

Use Category 

Species 

Included in 

Aggregated 

Category1 

Annual 

Pounds of 

Resource 

Harvested2 

Alternative A 

Significant Impact? [POSITIVE FINDING?] 

Alternative B 

Significant Impact? [POSITIVE FINDING?] 

Alternative C 

Significant Impact? [POSITIVE FINDING?] 

 

 

 

 

 

 

Alternative D 

Significant Impact? [POSITIVE FINDING?] 

Fishing 

Salmon: 

108.4 

Nonsalmon 

Fish: 

25.7 

LM: There is no overlap between fishing and LM areas 

with med/high potential. No LM areas in upstream 

portions of the basin. Negative (-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

LM: There is no overlap between fishing and LM areas 

with med/high potential. No LM areas in upstream 

portions of the basin. Negative (-). 

OHV: There is no overlap between fishing and OHV 

decisions. Negative (-). 

ROW: There is no overlap between fishing and ROW 

decisions. Negative (-). 

LM: There is no overlap between fishing and LM areas 

with med/high potential. No LM areas in upstream 

portions of the basin. Negative (-). 

OHV: There is no overlap between fishing and OHV 

decisions. Negative (-). 

ROW: There is no overlap between fishing and ROW 

decisions. Negative (-). 

LM: There is no overlap between fishing and LM areas 

with med/high potential. No LM areas in upstream 

portions of the basin. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

ROW: Negative (-). 

Gathering 7.3 

LM: There is no overlap between Gathering and LM areas 

with med/high potential. Negative (-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

LM: There is no overlap between Gathering and LM areas 

with med/high potential. Negative (-). 

OHV: There is no overlap between Gathering and OHV 

decisions. Negative (-). 

ROW: There is no overlap between Gathering and ROW 

decisions. Negative (-). 

LM: There is no overlap between Gathering and LM areas 

with med/high potential. Negative (-). 

OHV: There is no overlap between Gathering and OHV 

decisions. Negative (-). 

ROW: There is no overlap between Gathering and ROW 

decisions. Negative (-). 

LM: There is no overlap between Gathering and LM areas 

with med/high potential. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

ROW: There is no overlap between Gathering and ROW 

decisions. Negative (-). 

Notes: 

LM: Locatable minerals with med/high potential 

OHV: travel decisions relating to OHV use 

ROW: Right-of-way decisions 

Impact analysis to determine whether there is a positive or negative finding is based on an assessment of magnitude, duration, extent, likelihood, and intensity. 

1) This column shows which species the BSWI EIS Team has GIS data for at the time of the DEIS release. Communities may have differing sets of data available or may be missing data completely for an aggregated category. In most instances where data sets for "Hunting and Trapping (SLM)" were 

available, the subsistence use area did not specify which species are included in the use area. 

2) Data is from the ADF&G Community Subsistence Information System (CSIS), available at http://www.adfg.alaska.gov/sb/CSIS/ 

O-1-35 
BSWI Draft RMP/EIS Appendix O: ANILCA Preliminary Section 810 Evaluation 

Impact Analysis Results—Russian Mission 

Aggregated 

Subsistence 

Use Category 

Species 

Included in 

Aggregated 

Category1 

Annual 

Pounds of 

Resource 

Harvested2 

Alternative A 

Significant Impact? [POSITIVE FINDING?] 

Alternative B 

Significant Impact? [POSITIVE FINDING?] 

Alternative C 

Significant Impact? [POSITIVE FINDING?] 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Alternative D 

Significant Impact? [POSITIVE FINDING?] 

LM: There is no overlap between LLM and LM areas with 

med/high potential. Negative (-). 

LM: There is no overlap between LLM and LM areas with 

med/high potential. Negative (-). 

LM: There is no overlap between LLM and LM areas with 

med/high potential. Negative (-). 

Hunting and 

Trapping (LLM) 

Black Bear 

Caribou 

Moose 

107.5 

LM: There is no overlap between LLM and LM areas with 

med/high potential. Negative (-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter use. 10% 

of the use area limits summer casual use to existing trails. 

This same 10% is also limited to snowmobiles only for 

casual winter use. Therefore, there is no access 

restriction for subsistence uses and the greatest 

protection against habitat degradation and competing 

uses, as compared to Alternative A. Negative (-). 

ROW: Close to 0% of use area would be open to ROW 

location, 7% would be ROW avoidance areas, and 3% 

would be ROW exclusion areas. This alternative would 

minimize habitat fragmentation and degradation in these 

areas, as compared to Alternative A. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter use. 10% 

of the use area limits summer casual use to existing trails. 

There is no OHV limitation for casual winter use. 

Therefore, there is no access restriction for subsistence 

uses and the greater protection against habitat 

degradation and competing uses, as compared to 

Alternative A. Negative (-). 

ROW: 3% of use area would be open to ROW location, 

4% would be ROW avoidance areas, and 2% would be 

ROW avoidance areas for linear realty. This alternative 

would minimize habitat fragmentation and degradation in 

these areas, as compared to Alternative A. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

ROW: 7% of use area would be open to ROW location, 

2% would be ROW avoidance areas. This alternative 

would minimize habitat fragmentation and degradation in 

these areas, as compared to Alternative A and does not 

surpass the threshold. Open areas do not appear to block 

travel routes. Negative (-). 

Hunting and 

Trapping (SLM) SLM 4.4 

LM: There is no overlap between SLM and LM areas with 

med/high potential. Negative (-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

LM: There is no overlap between SLM and LM areas with 

med/high potential. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter use. Close 

to 0% of the use area limits summer casual use to 

existing trails. This nearly 0% is also limited to 

snowmobiles only for casual winter use. Therefore, there 

is no access restriction for subsistence uses and the 

greatest protection against habitat degradation and 

competing uses, as compared to Alternative A. SLM was 

not one of the top harvested resources according to data 

from 2011 (by weight). Negative (-). 

ROW: 59 acres (close to 0%) would be ROW avoidance 

areas. Negative (-). 

LM: There is no overlap between SLM and LM areas with 

med/high potential. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter use. Close 

to 0% of the use area limits summer casual use to 

existing trails. There is no OHV limitation for casual winter 

use. Therefore, there is no access restriction for 

subsistence uses and more protection against habitat 

degradation and competing uses for the 3% within the 

use area, as compared to Alternative A. Negative (-). 

ROW: 59 acres (close to 0%) would be ROW avoidance 

areas. Negative (-). 

LM: There is no overlap between SLM and LM areas with 

med/high potential. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

ROW: 59 acres (close to 0%) would be ROW avoidance 

areas. Negative (-). 

LM: There is no overlap between birds and LM areas with 

med/high potential. Negative (-). LM: There is no overlap between birds and LM areas with 

med/high potential. Negative (-). 

LM: There is no overlap between birds and LM areas with 

med/high potential. Negative (-). 

Hunting (Birds) 

Ducks 

Geese 

Ptarmigan 

Grouse 

9.5 

LM: There is no overlap between birds and LM areas with 

med/high potential. Negative (-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter use. 3% of 

the use area limits summer casual use to existing trails. 

This 3% is also limited to snowmobiles only for casual 

winter use. Therefore, there is no access restriction for 

subsistence uses and the greatest protection against 

habitat degradation and competing uses, as compared to 

Alternative A. Birds were not one of the top harvested 

resources according to data from 2011 (by weight). 

Negative (-). 

ROW: 3% of use area would be a ROW avoidance area. 

This alternative would minimize habitat fragmentation and 

degradation in these areas, as compared to Alternative A. 

Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter use. 3% of 

the use area limits summer casual use to existing trails. 

There is no OHV limitation for casual winter use. 

Therefore, there is no access restriction for subsistence 

uses and more protection against habitat degradation and 

competing uses for the 59 acres within the use area, as 

compared to Alternative A. Negative (-). 

ROW: 2% of use area would be open to ROW location, 

1% would be ROW avoidance areas. This alternative 

would limit habitat fragmentation and degradation in these 

areas, as compared to Alternative A. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

ROW: 3% of use area would be open to ROW location, 

close to 0% would be ROW avoidance areas. This 

alternative would limit habitat fragmentation and 

degradation in these areas, as compared to Alternative A. 

Negative (-). 

O-1-36 
Appendix O: ANILCA Preliminary Section 810 Evaluation BSWI Draft RMP/EIS 

Aggregated 

Subsistence 

Use Category 

Species 

Included in 

Aggregated 

Category1 

Annual 

Pounds of 

Resource 

Harvested2 

Alternative A 

Significant Impact? [POSITIVE FINDING?] 

Alternative B 

Significant Impact? [POSITIVE FINDING?] 

Alternative C 

Significant Impact? [POSITIVE FINDING?] 

 

 

 

 

 

 

 

 

 

 

Alternative D 

Significant Impact? [POSITIVE FINDING?] 

LM: One small area of open land with med/high potential LM: Two small area of open land with med/high potential 

Fishing 

Burbot 

Pike 

Salmon 

Sheefish 

Whitefish 

Salmon: 

110.4 

Nonsalmon 

Fish: 

89.4 

LM: There are no open areas with med/high potential in 

the vicinity of the fishing locations for the community. 

Negative (-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

in the vicinity of the fishing locations but does not appear 

to be upstream of the locations or in spot that would 

impede access. Negative (-). 

OHV: No limit to subsistence access for areas 

surrounding fishing locations. Summer casual OHV use is 

limited to existing trails, and winter casual use is limited to 

snowmobiles only. Negative (-). 

ROW: There are a few spots of land open to ROW 

placement that are close to the village, but they do not 

appear to be in a basin that is upstream of the fishing 

locations. These areas also do not appear to block 

in the vicinity of the fishing locations but does not appear 

to be upstream of the locations or in spot that would 

impede access. Negative (-). 

OHV: No limit to subsistence access for areas 

surrounding fishing locations. Summer casual OHV use is 

limited to existing trails. Negative (-). 

ROW: More land that is open to ROWs is closer to fishing 

locations for the community. These areas could bring in 

competing uses for fish resources and also degrade the 

surrounding habitat. Fish is the most highly harvest 

resource (by weight) for the community, based on 2011 

LM: Same as Alternative C. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

ROW: Same as Alternative C. Positive (+). 

access to these locations. Negative (-). data. Positive (+). 

LM: There is no overlap between gathering and LM areas 

with med/high potential. Negative (-). LM: There is no overlap between gathering and LM areas 

with med/high potential. Negative (-). LM: There is no overlap between gathering and LM areas 

with med/high potential. Negative (-). 

Gathering Berries 

Greens 4.7 

LM: There is no overlap between gathering and LM areas 

with med/high potential. Negative (-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter use. 24% 

of the use area limits summer casual use to existing trails. 

This 24% is also limited to snowmobiles only for casual 

winter use. Therefore, there is no access restriction for 

subsistence uses and the greatest protection against 

habitat degradation and competing uses, as compared to 

Alternative A. Gathering was not one of the top harvested 

resources according to data from 2011 (by weight). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter use. 24% 

of the use area limits summer casual use to existing trails. 

There is no OHV limitation for casual winter use. 

Therefore, there is no access restriction for subsistence 

uses and the greater protection against habitat 

degradation and competing uses, as compared to 

Alternative A. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

Negative (-). 

ROW: 0% of use area would be open to ROW location, 

22% would be ROW avoidance areas, and 10% would be 

ROW exclusion areas. This alternative would minimize 

habitat fragmentation and degradation in these areas, as 

compared to Alternative A. Negative (-). 

ROW: 11% of use area would be open to ROW location, 

12% would be ROW avoidance areas, and 1% would be 

ROW avoidance areas for linear realty. This alternative 

would limit habitat fragmentation and degradation in these 

areas, as compared to Alternative A, but is above the 

threshold for impacts. Positive (+). 

ROW: 22% of use area would be open to ROW location, 

2% would be ROW avoidance areas. This alternative 

would limit habitat fragmentation and degradation in these 

areas, as compared to Alternative A, but is above the 

threshold for impacts. Positive (+). 

Notes: 

LM: Locatable minerals with med/high potential 

OHV: travel decisions relating to OHV use 

ROW: Right-of-way decisions 

Impact analysis to determine whether there is a positive or negative finding is based on an assessment of magnitude, duration, extent, likelihood, and intensity. 

1) This column shows which species the BSWI EIS Team has GIS data for at the time of the DEIS release. Communities may have differing sets of data available or may be missing data completely for an aggregated category. In most instances where data sets for "Hunting and Trapping (SLM)" were 

available, the subsistence use area did not specify which species are included in the use area. 

2) Data is from the ADF&G Community Subsistence Information System (CSIS), available at http://www.adfg.alaska.gov/sb/CSIS/ 

O-1-37 
BSWI Draft RMP/EIS Appendix O: ANILCA Preliminary Section 810 Evaluation 

Impact Analysis Results—Shageluk 

Aggregated 

Subsistence 

Use Category 

Species 

Included in 

Aggregated 

Category1 

Annual 

Pounds of 

Resource 

Harvested2 

Alternative A 

Significant Impact? [POSITIVE FINDING?] 

Alternative B 

Significant Impact? [POSITIVE FINDING?] 

Alternative C 

Significant Impact? [POSITIVE FINDING?] 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Alternative D 

Significant Impact? [POSITIVE FINDING?] 

Hunting and 

Trapping (LLM) Moose 126.1 

LM: No overlap in use areas. Negative (-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

LM: No overlap in use areas. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and close to 0% is restricted for 

subsistence winter use to snowmobiles. 31% of the use 

area limits summer casual use to existing trails. This 

same 31% is also limited to snowmobiles only for casual 

winter use. Therefore, there is limited access restriction 

for subsistence uses and the greatest protection against 

habitat degradation and competing uses, as compared to 

Alternative A. Negative (-). 

ROW: 4% of use area would be open to ROW location, 

7% would be ROW avoidance areas, and 20% would be 

ROW exclusion areas. This alternative would minimize 

habitat fragmentation and degradation in these areas, as 

compared to Alternative A. Negative (-). 

LM: No overlap in use areas. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and close to 0% is restricted for 

subsistence winter use. 31% of the use area limits 

summer casual use to existing trails. Close to 0% is also 

limited to snowmobiles only for casual winter use. 

Therefore, there is limited access restriction for 

subsistence uses and greater protection against habitat 

degradation and competing uses, as compared to 

Alternative A. Negative (-). 

ROW: 4% of use area would be open to ROW location, 

7% would be ROW avoidance areas, and 20% would be 

ROW avoidance areas for linear realty. This alternative 

would decrease habitat fragmentation and degradation in 

these areas, as compared to Alternative A, but may have 

significant impacts due to the amount of LLM that is 

harvested in the community. The avoidance and open 

areas could affect access and availability. LLM is the 

second highest subsistence resource harvested (by 

weight). Positive (+). 

LM: No overlap in use areas. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

ROW: 12% of use area would be open to ROW location, 

18% would be ROW avoidance areas. This alternative 

would decrease habitat fragmentation and degradation in 

these areas, as compared to Alternative A, but may have 

significant impacts due to the amount of LLM that is 

harvested in the community. The avoidance and open 

areas could affect access and availability. LLM is the 

second highest subsistence resource harvested (by 

weight). Positive (+). 

LM: Same as Grayling. Negative (-). 

Hunting and 

Trapping (SLM) 

(GRAYLING 

DATA) 

8.2 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

LM: No overlap in open areas and use areas. Negative 

(-). 

OHV: Same as Grayling. Negative (-). 

ROW: Same as Grayling. Negative (-). 

LM: No overlap in open areas and use areas. Negative 

(-). 

OHV: Same as Grayling. Positive (+). 

ROW: Same as Grayling. Negative (-). 

LM: Same as Grayling. Negative (-). 

OHV: Same as Grayling. Positive (+). 

ROW: Same as Grayling. Negative (-). 

LM: Same as Grayling. Negative (-). 

Hunting (Birds) 

(GRAYLING 

DATA) 

9.1 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

LM: No overlap in open areas and use areas. Negative 

(-). 

OHV: Same as Grayling. Positive (+). 

ROW: Same as Grayling. Negative (-). 

LM: No overlap in open areas and use areas. Negative 

(-). 

OHV: Same as Grayling. Positive (+). 

ROW: Same as Grayling. Negative (-). 

LM: Same as Grayling. Negative (-). 

OHV: Same as Grayling. Positive (+). 

ROW: Same as Grayling. Negative (-). 

O-1-38 
Appendix O: ANILCA Preliminary Section 810 Evaluation BSWI Draft RMP/EIS 

Aggregated 

Subsistence 

Use Category 

Species 

Included in 

Aggregated 

Category1 

Annual 

Pounds of 

Resource 

Harvested2 

Alternative A 

Significant Impact? [POSITIVE FINDING?] 

Alternative B 

Significant Impact? [POSITIVE FINDING?] 

Alternative C 

Significant Impact? [POSITIVE FINDING?] 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Alternative D 

Significant Impact? [POSITIVE FINDING?] 

Fishing Fish 

Salmon: 

157.9 

Nonsalmon 

Fish: 

141.4 

LM: No overlap in open areas and use areas. Negative 

(-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

LM: No overlap in open areas and use areas. Negative 

(-). 

OHV: There are no areas close to fishing use areas that 

limit subsistence access in the summer or winter. Also, 

several portions of the surrounding land have summer 

and winter limitations for casual use. Negative (-). 

ROW: 3% of use area would be open to ROW location, 

8% would be ROW avoidance areas, and 10% would be 

ROW exclusion areas. This alternative would minimize 

habitat fragmentation and degradation in these areas, as 

compared to Alternative A. Negative (-). 

LM: No overlap in open areas and use areas. Negative 

(-). 

OHV: There are no areas close to fishing use areas that 

limit subsistence access in the summer or winter. Also, 

several portions of the surrounding land have summer 

(but no winter) limitations for casual use. Negative (-). 

ROW: 8% of use area would be open to ROW location, 

7% would be ROW avoidance areas, and 7% would be 

ROW avoidance areas for linear realty. This alternative 

would decrease habitat fragmentation and degradation in 

these areas, as compared to Alternative A, but may have 

significant impacts due to the amount of fish that is 

harvested in the community. The avoidance and open 

areas could affect access and availability. Fish is the 

number one subsistence resource harvested (by weight). 

Positive (+). 

LM: No overlap in open areas and use areas. Negative 

(-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

ROW: 12% of use area would be open to ROW location, 

9% would be ROW avoidance areas. This alternative 

would decrease habitat fragmentation and degradation in 

these areas, as compared to Alternative A, but may have 

significant impacts due to the amount of fish that is 

harvested in the community. The avoidance and open 

areas could affect access and availability. Fish is the 

number one subsistence resource harvested (by weight). 

Positive (+). 

Gathering 

(GRAYLING 

DATA) 

2.6 

LM: Same as Grayling. Negative (-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

LM: No overlap in open areas and use areas. Negative 

(-). 

OHV: Same as Grayling. Negative (-). 

ROW: Same as Grayling. Negative (-). 

LM: No overlap in open areas and use areas. Negative 

(-). 

OHV: Same as Grayling. Negative (-). 

ROW: Same as Grayling. Negative (-). 

LM: Same as Grayling. Negative (-). 

OHV: Same as Grayling. Positive (+). 

ROW: Same as Grayling. Negative (-). 

Notes: 

LM: Locatable minerals with med/high potential 

OHV: travel decisions relating to OHV use 

ROW: Right-of-way decisions 

Impact analysis to determine whether there is a positive or negative finding is based on an assessment of magnitude, duration, extent, likelihood, and intensity. 

1) This column shows which species the BSWI EIS Team has GIS data for at the time of the DEIS release. Communities may have differing sets of data available or may be missing data completely for an aggregated category. In most instances where data sets for "Hunting and Trapping (SLM)" were 

available, the subsistence use area did not specify which species are included in the use area. 

2) Data is from the ADF&G Community Subsistence Information System (CSIS), available at http://www.adfg.alaska.gov/sb/CSIS/ 

O-1-39 
BSWI Draft RMP/EIS Appendix O: ANILCA Preliminary Section 810 Evaluation 

Impact Analysis Results—Sleetmute 

Aggregated 

Subsistence 

Use Category 

Species 

Included in 

Aggregated 

Category1 

Annual 

Pounds of 

Resource 

Harvested2 

Alternative A 

Significant Impact? [POSITIVE FINDING?] 

Alternative B 

Significant Impact? [POSITIVE FINDING?] 

Alternative C 

Significant Impact? [POSITIVE FINDING?] 

 

 

 

 

 

 

 

 

 

 

Alternative D 

Significant Impact? [POSITIVE FINDING?] 

Hunting and 

Trapping (LLM) 

Black Bear 

Caribou 

Moose 

43.9 

LM: Close to 0% of the use area is withdrawn from LM 

with med/high potential. Negative (-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

LM: Nearly 0% of the use area is open to LM and have 

med/high potential. There is a potential chokepoint that 

could occur along the Kuskokwim River near the 

confluence of Kolmakof River, though travel could still 

take place on the Kuskokwim River itself. Additionally, 

there is a route along a valley area that may serve as a 

travel route. Negative. Negative (-). 

OHV: 0% of use area is prohibited for summer 

subsistence use and 6% is restricted for winter 

subsistence use to snowmobiles only. 8% of the use area 

limits summer casual use to existing trails. 8% is limited 

to snowmobiles only for casual winter use. There would 

be access restriction for subsistence uses in the 6% that 

limits winter subsistence OHV use to snowmobiles only. 

This alternative provides the greatest protection against 

habitat degradation and competing uses, as compared to 

Alternative A, but the access impacts would be 

significant. LLM is the most highly harvested resource in 

the community. Positive (+). 

ROW: 0% of use area would be open to ROW location, 

8% would be ROW avoidance areas, and 0% would be 

ROW exclusion areas. This alternative would minimize 

habitat fragmentation and degradation in these areas, as 

compared to Alternative A. Negative (-). 

LM: Same as Alternative B. Negative (-). 

OHV: 0% of use area is prohibited for summer 

subsistence use and 6% is restricted for winter 

subsistence use to snowmobiles only. 8% of the use area 

limits summer casual use to existing trails. 6% is limited 

to snowmobiles only for casual winter use. There would 

be access restriction for subsistence uses in the 6% that 

limits winter subsistence OHV use to snowmobiles only. 

This alternative provides the greatest protection against 

habitat degradation and competing uses, as compared to 

Alternative A, but the access impacts would be 

significant. LLM is the most highly harvested resource in 

the community. Positive (+). 

ROW: 1% of use area would be open to ROW location, 

7% would be ROW avoidance areas. This alternative 

would minimize habitat fragmentation and degradation in 

these areas, as compared to Alternative A. Negative (-). 

LM: Same as Alternative B. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

ROW: 5% of use area would be open to ROW location, 

4% would be ROW avoidance areas. This alternative 

would minimize habitat fragmentation and degradation in 

these areas, as compared to Alternative A. Negative (-). 

Hunting and 

Trapping (SLM) SLM 15.1 

LM: 1% of the use area is withdrawn from LM with 

med/high potential. Negative (-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

LM: 1% of the use area is open to LM and have med/high 

potential. There is a potential chokepoint that could occur 

along the Kuskokwim River near the confluence of 

Kolmakof River, though travel could still take place on the 

Kuskokwim River itself. Additionally, there is a route along 

a valley area that may serve as a travel route. Negative 

(-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for subsistence 

winter use to snowmobiles. 2% of the use area limits 

summer casual use to existing trails. This same 2% is 

also limited to snowmobiles only for casual winter use. 

Therefore, there are no access restrictions for 

subsistence uses and the greatest protection against 

habitat degradation and competing uses, as compared to 

Alternative A. Negative (-). 

ROW: 1% of use area would be open to ROW location, 

1% would be ROW avoidance areas, and 0% would be 

ROW exclusion areas. This alternative would minimize 

habitat fragmentation and degradation in these areas, as 

compared to Alternative A. Negative (-). 

LM: Same as Alternative B. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and close to 0% is restricted for 

subsistence winter use. 2% of the use area limits summer 

casual use to existing trails. There is no OHV limitation for 

casual winter use. Therefore, there is no access 

restriction for subsistence uses and greater protection 

against habitat degradation and competing uses, as 

compared to Alternative A. Negative (-). 

ROW: 1% of use area would be open to ROW location, 

1% would be ROW avoidance areas, and 0% would be 

ROW exclusion areas. This alternative would minimize 

habitat fragmentation and degradation in these areas, as 

compared to Alternative A. Negative (-). 

LM: Same as Alternative B. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

ROW: 2% of use area would be open to ROW location, 

0% would be ROW avoidance areas, and 0% would be 

ROW exclusion areas. This alternative would minimize 

habitat fragmentation and degradation in these areas, as 

compared to Alternative A. Negative (-). 

O-1-40 
Appendix O: ANILCA Preliminary Section 810 Evaluation BSWI Draft RMP/EIS 

Aggregated 

Subsistence 

Use Category 

Species 

Included in 

Aggregated 

Category1 

Annual 

Pounds of 

Resource 

Harvested2 

Alternative A 

Significant Impact? [POSITIVE FINDING?] 

Alternative B 

Significant Impact? [POSITIVE FINDING?] 

Alternative C 

Significant Impact? [POSITIVE FINDING?] 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Alternative D 

Significant Impact? [POSITIVE FINDING?] 

Hunting (Birds) Ducks 

Geese 5.4 

LM: 2% of the use area is withdrawn from LM with 

med/high potential. Negative (-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

LM: 2% of the use area is open to LM and have med/high 

potential. There is a potential chokepoint that could occur 

along the Kuskokwim River near the confluence of 

Kolmakof River, though travel could still take place on the 

Kuskokwim River itself. Additionally, there is a route along 

a valley area that may serve as a travel route. Negative 

(-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for subsistence 

winter use to snowmobiles. 3% of the use area limits 

summer casual use to existing trails. This same 3% is 

also limited to snowmobiles only for casual winter use. 

Therefore, there are no access restrictions for 

subsistence uses and the greatest protection against 

habitat degradation and competing uses, as compared to 

Alternative A. Negative (-). 

ROW: 2% of use area would be open to ROW location, 

1% would be ROW avoidance areas, and 0% would be 

ROW exclusion areas. This alternative would minimize 

habitat fragmentation and degradation in these areas, as 

compared to Alternative A. Negative (-). 

LM: Same as Alternative B. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and close to 0% is restricted for 

subsistence winter use. 3% of the use area limits summer 

casual use to existing trails. There is no OHV limitation for 

casual winter use. Therefore, there is no access 

restriction for subsistence uses and greater protection 

against habitat degradation and competing uses, as 

compared to Alternative A. Negative (-). 

ROW: 2% of use area would be open to ROW location, 

1% would be ROW avoidance areas, and 0% would be 

ROW exclusion areas. This alternative would minimize 

habitat fragmentation and degradation in these areas, as 

compared to Alternative A. Negative (-). 

LM: Same as Alternative B. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

ROW: 2% of use area would be open to ROW location, 

0% would be ROW avoidance areas, and 0% would be 

ROW exclusion areas. This alternative would minimize 

habitat fragmentation and degradation in these areas, as 

compared to Alternative A. Negative (-). 

Fishing 

Salmon 

Trout 

Whitefish 

Salmon: 

277.1 

Nonsalmon 

Fish: 

53.9 

LM: Some BLM land near known fishing locations for the 

community is withdrawn from LM with med/high potential. 

Negative (-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

LM: Some BLM land close to known fishing locations for 

the community are open for LM and have high/med 

potential. This could cause access impacts and 

degradation of habitat, in addition to potentially bringing in 

new users to the area that could increase competition for 

resources. Fish make up the largest portion of harvested 

resources for the community. Positive (+). 

OHV: Some fishing locations on the Stony River are near 

areas where subsistence OHV use is limited to 

snowmobiles in the winter, but the access to these spots 

would not be impacted. Additionally, limitations places on 

casual summer and winter OHV use provide some 

protection to the habitat and decrease conflict between 

competing users. This impact is less than Alternative A. 

Negative (-). 

ROW: Land that is open to ROWs is close to fishing 

locations for the community. These areas could bring in 

competing uses for fish resources and also degrade the 

surrounding habitat. Fish is the most highly harvest 

resource (by weight) for the community, based on 2009 

data. Positive (+). 

LM: Same as Alternative B. Positive (+). 

OHV: Some fishing locations on the Stony River are near 

areas where subsistence OHV use is limited to 

snowmobiles in the winter, but the access to these spots 

would not be impacted. Additionally, limitations places on 

casual summer and winter OHV use provide some 

protection to the habitat and decrease conflict between 

competing users. This impact is less than Alternative A. 

Negative (-). 

ROW: Land that is open to ROWs is close to fishing 

locations for the community. These areas could bring in 

competing uses for fish resources and also degrade the 

surrounding habitat. Fish is the most highly harvest 

resource (by weight) for the community, based on 2009 

data. Positive (+). 

LM: Same as Alternative B. Positive (+). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

ROW: Land that is open to ROWs is close to fishing 

locations for the community. These areas could bring in 

competing uses for fish resources and also degrade the 

surrounding habitat. Fish is the most highly harvest 

resource (by weight) for the community, based on 2009 

data. Positive (+). 

O-1-41 
BSWI Draft RMP/EIS Appendix O: ANILCA Preliminary Section 810 Evaluation 

Aggregated 

Subsistence 

Use Category 

Species 

Included in 

Aggregated 

Category1 

Annual 

Pounds of 

Resource 

Harvested2 

Alternative A 

Significant Impact? [POSITIVE FINDING?] 

Alternative B 

Significant Impact? [POSITIVE FINDING?] 

Alternative C 

Significant Impact? [POSITIVE FINDING?] 

 

 

 

 

 

 

 

Alternative D 

Significant Impact? [POSITIVE FINDING?] 

Gathering Berries 

Plants 10.5 

LM: 2% of the use area is withdrawn from LM with 

med/high potential. Negative (-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

LM: 2% of the use area is open to LM and have med/high 

potential. There is a potential chokepoint that could occur 

along the Kuskokwim River near the confluence of 

Kolmakof River, though travel could still take place on the 

Kuskokwim River itself. Additionally, there is a route along 

a valley area that may serve as a travel route. Negative 

(-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for subsistence 

winter use to snowmobiles. 4% of the use area limits 

summer casual use to existing trails. This same 4% is 

also limited to snowmobiles only for casual winter use. 

Therefore, there are no access restrictions for 

subsistence uses and the greatest protection against 

habitat degradation and competing uses, as compared to 

Alternative A. Negative (-). 

ROW: 3% of use area would be open to ROW location, 

1% would be ROW avoidance areas, and 0% would be 

ROW exclusion areas. This alternative would minimize 

habitat fragmentation and degradation in these areas, as 

compared to Alternative A. Negative (-). 

LM: Same as Alternative B. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and close to 0% is restricted for 

subsistence winter use. 4% of the use area limits summer 

casual use to existing trails. There is no OHV limitation for 

casual winter use. Therefore, there is no access 

restriction for subsistence uses and greater protection 

against habitat degradation and competing uses, as 

compared to Alternative A. Negative (-). 

ROW: Same as Alternative B. Negative (-). 

LM: Same as Alternative B. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

ROW: 4% of use area would be open to ROW location. 

This alternative would have the same impacts as 

compared to Alternative A. Positive (+). 

Notes: 

LM: Locatable minerals with med/high potential 

OHV: travel decisions relating to OHV use 

ROW: Right-of-way decisions 

Impact analysis to determine whether there is a positive or negative finding is based on an assessment of magnitude, duration, extent, likelihood, and intensity. 

1) This column shows which species the BSWI EIS Team has GIS data for at the time of the DEIS release. Communities may have differing sets of data available or may be missing data completely for an aggregated category. In most instances where data sets for "Hunting and Trapping (SLM)" were 

available, the subsistence use area did not specify which species are included in the use area. 

2) Data is from the ADF&G Community Subsistence Information System (CSIS), available at http://www.adfg.alaska.gov/sb/CSIS/ 

O-1-42 
Appendix O: ANILCA Preliminary Section 810 Evaluation BSWI Draft RMP/EIS 

Impact Analysis Results—Stony River 

Aggregated 

Subsistence 

Use Category 

Species 

Included in 

Aggregated 

Category1 

Annual 

Pounds of 

Resource 

Harvested2 

Alternative A 

Significant Impact? [POSITIVE FINDING?] 

Alternative B 

Significant Impact? [POSITIVE FINDING?] 

Alternative C 

Significant Impact? [POSITIVE FINDING?] 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Alternative D 

Significant Impact? [POSITIVE FINDING?] 

Hunting and 

Trapping (LLM) 

Black Bear 

Caribou 

Moose 

20.3 

LM: No overlap in use area and areas with med/high LM 

potential. Negative (-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

LM: No overlap in use area and areas with med/high LM 

potential. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 7% is restricted for subsistence 

winter use to snowmobiles. 37% of the use area limits 

summer casual use to existing trails. This same 37% is 

also limited to snowmobiles only for casual winter use. 

This alternative offers the greatest protection against 

habitat degradation and competing uses, as compared to 

Alternative A, but may result in access impacts for 

subsistence users. LLM is one of the most heavily 

harvested resources for this community. Positive (+). 

ROW: 5% of use area would be open to ROW location, 

32% would be ROW avoidance areas, and 0% would be 

ROW exclusion areas. This alternative would minimize 

habitat fragmentation and degradation in these areas, as 

compared to Alternative A. Negative (-). 

LM: No overlap in use area and areas with med/high LM 

potential. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 7% is restricted for subsistence 

winter use to snowmobiles. 37% of the use area limits 

summer casual use to existing trails. 7% is also limited to 

snowmobiles only for casual winter use. This alternative 

offers greater protection against habitat degradation and 

competing uses, as compared to Alternative A, but may 

result in access impacts for subsistence users. LLM is 

one of the most heavily harvested resources for this 

community. Positive (+). 

ROW: 12% of use area would be open to ROW location, 

25% would be ROW avoidance areas. This alternative 

would minimize habitat fragmentation and degradation in 

these areas, as compared to Alternative A. The area of 

land open to new ROWs is above the threshold for 

impacts. Additionally, LLM is one of the most heavily 

harvested resources for the community. Positive (+). 

LM: No overlap in use area and areas with med/high LM 

potential. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

ROW: 27% of use area would be open to ROW location, 

11% would be ROW avoidance areas. This alternative 

would minimize habitat fragmentation and degradation in 

these areas, as compared to Alternative A. The area of 

land open to new ROWs is above the threshold for 

impacts. Additionally, LLM is one of the most heavily 

harvested resources for the community. Positive (+). 

LM: No overlap in use area and areas with med/high LM 

potential. Negative (-). 

LM: No overlap in use area and areas with med/high LM 

potential. Negative (-). 

LM: No overlap in use area and areas with med/high LM 

potential. Negative (-). 

Hunting and 

Trapping (SLM) SLM 38.7 

LM: No overlap in use area and areas with med/high LM 

potential. Negative (-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

OHV: 0% of use area is restricted for summer 

subsistence use and close to 0% is restricted for 

subsistence winter use to snowmobiles. 74% of the use 

area limits summer casual use to existing trails. This 

same 74% is also limited to snowmobiles only for casual 

winter use. Therefore, there are no access restrictions for 

subsistence uses and the greatest protection against 

habitat degradation and competing uses, as compared to 

Alternative A. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and close to 0% is restricted for 

subsistence winter use. 74% of the use area limits 

summer casual use to existing trails. There is no OHV 

limitation for casual winter use. Therefore, there is no 

access restriction for subsistence uses and greater 

protection against habitat degradation and competing 

uses, as compared to Alternative A. Negative (-). 

ROW: 48% of use area would be open to ROW location, 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

ROW: 60% of use area would be open to ROW location, 

fragment habitats and degrade subsistence resources. 

Positive (+). ROW: Close to 0% of use area would be open to ROW 

location, 74% would be ROW avoidance areas, and 0% 

would be ROW exclusion areas. This alternative would 

minimize habitat fragmentation and degradation in these 

areas, as compared to Alternative A. Negative (-). 

26% would be ROW avoidance areas. This alternative 

would minimize habitat fragmentation and degradation in 

these areas, as compared to Alternative A. The area of 

land open to new ROWs is above the threshold for 

impacts. Additionally, SLM is one of the most heavily 

harvested resources for the community. Positive (+). 

15% would be ROW avoidance areas. This alternative 

would minimize habitat fragmentation and degradation in 

these areas, as compared to Alternative A. The area of 

land open to new ROWs is above the threshold for 

impacts. Additionally, SLM is one of the most heavily 

harvested resources for the community. Positive (+). 

Hunting (Birds) Ducks 

Geese 0.0 

LM: No overlap in use area and areas with med/high LM 

potential. Negative (-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

LM: No overlap in use area and areas with med/high LM 

potential. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and close to 0% is restricted for 

subsistence winter use to snowmobiles. 12% of the use 

area limits summer casual use to existing trails. This 

same 12% is also limited to snowmobiles only for casual 

winter use. Therefore, there are no access restrictions for 

subsistence uses and the greatest protection against 

habitat degradation and competing uses, as compared to 

Alternative A. Negative (-). 

ROW: 1% of use area would be open to ROW location, 

9% would be ROW avoidance areas, and 2% would be 

ROW exclusion areas. This alternative would minimize 

habitat fragmentation and degradation in these areas, as 

compared to Alternative A. Negative (-). 

LM: No overlap in use area and areas with med/high LM 

potential. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and close to 0% is restricted for 

subsistence winter use. 12% of the use area limits 

summer casual use to existing trails. There is no OHV 

limitation for casual winter use. Therefore, there is no 

access restriction for subsistence uses and greater 

protection against habitat degradation and competing 

uses, as compared to Alternative A. Negative (-). 

ROW: 2% of use area would be open to ROW location, 

10% would be ROW avoidance areas. This alternative 

would decrease habitat fragmentation and degradation in 

these areas, as compared to Alternative A. Negative (-). 

LM: No overlap in use area and areas with med/high LM 

potential. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

ROW: 4% of use area would be open to ROW location, 

8% would be ROW avoidance areas. This alternative 

would decrease habitat fragmentation and degradation in 

these areas, as compared to Alternative A. Negative (-). 

O-1-43 
BSWI Draft RMP/EIS Appendix O: ANILCA Preliminary Section 810 Evaluation 

Aggregated 

Subsistence 

Use Category 

Species 

Included in 

Aggregated 

Category1 

Annual 

Pounds of 

Resource 

Harvested2 

Alternative A 

Significant Impact? [POSITIVE FINDING?] 

Alternative B 

Significant Impact? [POSITIVE FINDING?] 

Alternative C 

Significant Impact? [POSITIVE FINDING?] 

 

 

 

 

 

 

 

 

 

 

 

 

Alternative D 

Significant Impact? [POSITIVE FINDING?] 

Fishing 

Salmon 

Trout 

Whitefish 

Salmon: 

366.0 

Nonsalmon 

Fish: 

92.4 

LM: The majority of the fishing locations are within a few 

river miles of the village and located on the Kuskokwim 

River. The closest area that is upstream and open to LM 

with med/high potential is approximately 40 river miles 

upstream on the Cheeneetnuk River. Negative (-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

LM: The majority of the fishing locations are within a few 

river miles of the village and located on the Kuskokwim 

River. The closest area is open to LM with med/high 

potential is downstream of the fishing locations (around 

the Red Devil mine). The closest area that is upstream 

and open to LM with med/high potential is approximately 

50 river miles upstream of the Cheeneetnuk River, and 

within the Cheeneetnuk basin (not on the river itself). 

Negative (-). 

OHV: None of the land surrounding the fishing locations 

is restricted for subsistence summer or winter use, though 

there are limits placed on casual summer and winter 

uses. There is a portion of land located upstream in the 

basins of the Cheeneetnuk, Gagaryah, and Swift Rivers 

that limits subsistence winter use to snowmobiles only, 

but there are no mapped fishing locations for this 

community in that portion of the planning area. Therefore, 

there are no access restrictions for subsistence uses and 

the greatest protection against habitat degradation and 

competing uses, as compared to Alternative A. Negative 

(-). 

ROW: There are some portions of land near the village 

fishing locations that would be open to ROWs, though 

they do not appear to block access as the surrounding 

land is either undesignated or is a ROW avoidance area. 

Additionally, the majority of the fishing locations are 

located near the village and would not have access 

impeded by new ROWs. Habitat degradation and 

competition for resources would be minimal as most of 

the BLM land that is nearest to the fishing locations would 

be ROW avoidance areas. Negative (-). 

LM: Same as Alternative A. Negative (-). 

OHV: None of the land surrounding the fishing locations 

is restricted for subsistence summer or winter use, though 

there are limits placed on casual summer use. There is a 

portion of land located upstream in the basins of the 

Cheeneetnuk, Gagaryah, and Swift Rivers that limits 

subsistence winter use to snowmobiles only, but there are 

no mapped fishing locations for this community in that 

portion of the planning area. Therefore, there are no 

access restrictions for subsistence uses and the greatest 

protection against habitat degradation and competing 

uses, as compared to Alternative A. Negative (-). 

ROW: Large portions of the areas upstream of the fishing 

locations for the community would be open to new 

ROWs. Though this would not impede access to these 

locations, the new ROWs could degrade the habitat and 

increase competition to the resource. Fish was the most 

harvested resource for the community. Positive (+). 

LM: Same as Alternative A. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

ROW: Large portions of the areas upstream of the fishing 

locations for the community would be open to new 

ROWs. Though this would not impede access to these 

locations, the new ROWs could degrade the habitat and 

increase competition to the resource. Fish was the most 

harvested resource for the community. Positive (+). 

Gathering Berries 

Plants 9.8 

LM: No overlap in use area and areas with med/high LM 

potential. Negative (-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

LM: No overlap in use area and areas with med/high LM 

potential. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and close to 0% is restricted for 

subsistence winter use to snowmobiles. 9% of the use 

area limits summer casual use to existing trails. This 

same 9% is also limited to snowmobiles only for casual 

winter use. Therefore, there are no access restrictions for 

subsistence uses and the greatest protection against 

habitat degradation and competing uses, as compared to 

Alternative A. Negative (-). 

ROW: 1% of use area would be open to ROW location, 

8% would be ROW avoidance areas, and 0% would be 

ROW exclusion areas. This alternative would minimize 

habitat fragmentation and degradation in these areas, as 

compared to Alternative A. Negative (-). 

LM: No overlap in use area and areas with med/high LM 

potential. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and close to 0% is restricted for 

subsistence winter use. 12% of the use area limits 

summer casual use to existing trails. There is no OHV 

limitation for casual winter use. Therefore, there is no 

access restriction for subsistence uses and greater 

protection against habitat degradation and competing 

uses, as compared to Alternative A. Negative (-). 

ROW: 8% of use area would be open to ROW location, 

1% would be ROW avoidance areas. This alternative 

would minimize habitat fragmentation and degradation in 

these areas, as compared to Alternative A. Negative (-). 

LM: No overlap in use area and areas with med/high LM 

potential. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

ROW: 9% of use area would be open to ROW location. 

This alternative would minimize habitat fragmentation and 

degradation in these areas, as compared to Alternative A. 

Negative (-). 

Notes: 

LM: Locatable minerals with med/high potential 

OHV: travel decisions relating to OHV use 

ROW: Right-of-way decisions 

Impact analysis to determine whether there is a positive or negative finding is based on an assessment of magnitude, duration, extent, likelihood, and intensity. 

1) This column shows which species the BSWI EIS Team has GIS data for at the time of the DEIS release. Communities may have differing sets of data available or may be missing data completely for an aggregated category. In most instances where data sets for "Hunting and Trapping (SLM)" were 

available, the subsistence use area did not specify which species are included in the use area. 

2) Data is from the ADF&G Community Subsistence Information System (CSIS), available at http://www.adfg.alaska.gov/sb/CSIS/ 

O-1-44 
Appendix O: ANILCA Preliminary Section 810 Evaluation BSWI Draft RMP/EIS 

Impact Analysis Results—Unalakleet 

Aggregated 

Subsistence 

Use Category 

Species 

Included in 

Aggregated 

Category1 

Annual 

Pounds of 

Resource 

Harvested2 

Alternative A 

Significant Impact? [POSITIVE FINDING?] 

Alternative B 

Significant Impact? [POSITIVE FINDING?] 

Alternative C 

Significant Impact? [POSITIVE FINDING?] 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Alternative D 

Significant Impact? [POSITIVE FINDING?] 

Hunting and 

Trapping (LLM) 

Moose 

Caribou 110.66 

LM: No overlap in use area and areas with med/high LM 

potential. Negative (-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

LM: No overlap in use area and areas with med/high LM 

potential. Negative (-). 

OHV: 1% of use area is restricted to existing trails for 

summer subsistence use and 23% is restricted for 

subsistence winter use to snowmobiles. Additionally, 

summer subsistence OHV use is prohibited in 4% of the 

use area. For casual use, 31% is limited to existing trails 

in summer and 35% is limited to snowmobiles only for 

winter use. Summer casual OHV access is prohibited in 

5% of the use area. Therefore, there are access 

restrictions for subsistence uses, though this use area 

also has the greatest protection against habitat 

degradation and competing uses, as compared to 

Alternative A. Positive (+). 

ROW: 4% of use area would be open to ROW location, 

25% would be ROW avoidance areas, and 7% would be 

ROW exclusion areas. This alternative would minimize 

habitat fragmentation and degradation in these areas, as 

compared to Alternative A. Negative (-). 

LM: No overlap in use area and areas with med/high LM 

potential. Negative (-). 

OHV: 0% of use area is restricted to existing trails for 

summer subsistence use and 21% is restricted for 

subsistence winter use to snowmobiles. Additionally, 

summer subsistence OHV use is prohibited in 5% of the 

use area. For casual use, 31% is limited to existing trails 

in summer and 21% is limited to snowmobiles only for 

winter use. Therefore, there are access restrictions for 

subsistence uses, though this use area also has the 

greater protection against habitat degradation and 

competing uses, as compared to Alternative A. Positive 

(+). 

ROW: 9% of use area would be open to ROW location, 

26% would be ROW avoidance areas. This alternative 

would decrease habitat fragmentation and degradation in 

these areas, as compared to Alternative A. Negative (-). 

LM: No overlap in use area and areas with med/high LM 

potential. Negative (-). 

OHV: 4% of use area is restricted for summer 

subsistence use and 4% is restricted for winter 

subsistence use. 4% of summer casual use is restricted 

to existing trails and 4% of winter casual use is restricted 

to snowmobiles only. This is the same impact as 

Alternative A. Therefore, there are access restrictions for 

subsistence uses, though this use area also has the 

greater protection against habitat degradation and 

competing uses, as compared to Alternative A. Positive 

(+). 

ROW: 14% of use area would be open to ROW location, 

20% would be ROW avoidance areas, and 2% would 

allow ROWs on a case-by-case basis. This alternative 

has areas open to ROWs that exceed the threshold for 

impacts. Positive (+). 

LM: No overlap in use area and areas with med/high LM 

potential. Negative (-). LM: No overlap in use area and areas with med/high LM 

potential. Negative (-). LM: No overlap in use area and areas with med/high LM 

potential. Negative (-). 

Hunting and 

Trapping (SLM) No data 1.11 

LM: No overlap in use area and areas with med/high LM 

potential. Negative (-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

OHV: 0% of use area is restricted to existing trails for 

summer subsistence use and 44% is restricted for 

subsistence winter use to snowmobiles. Additionally, 

summer subsistence OHV use is prohibited in 1% of the 

use area. For casual use, 62% is limited to existing trails 

in summer and 62% is limited to snowmobiles only for 

winter use. Summer casual OHV access is prohibited in 

1% of the use area. Therefore, there are access 

restrictions for subsistence uses, though this use area 

also has the greatest protection against habitat 

degradation and competing uses, as compared to 

Alternative A. Positive (+). 

OHV: 0% of use area is restricted to existing trails for 

summer subsistence use and 44% is restricted for 

subsistence winter use to snowmobiles. Additionally, 

summer subsistence OHV use is prohibited in 1% of the 

use area. For casual use, 62% is limited to existing trails 

in summer and 44% is limited to snowmobiles only for 

winter use. Therefore, there are access restrictions for 

subsistence uses, though this use area also has the 

greater protection against habitat degradation and 

competing uses, as compared to Alternative A. Positive 

(+). 

OHV: 1% of use area is restricted for summer 

subsistence use and 1% is restricted for winter 

subsistence use. 1% of summer casual use is restricted 

to existing trails and 1% of winter casual use is restricted 

to snowmobiles only. This is the same impact as 

Alternative A. Therefore, there are access restrictions for 

subsistence uses, though this use area also has the 

greater protection against habitat degradation and 

competing uses, as compared to Alternative A. Positive 

(+). 

Positive (+). 

ROW: 2% of use area would be open to ROW location, 

44% would be ROW avoidance areas, and 16% would be 

ROW exclusion areas. This alternative would minimize 

habitat fragmentation and degradation in these areas, as 

compared to Alternative A. Negative (-). 

ROW: 12% of use area would be open to ROW location, 

50% would be ROW avoidance areas. This alternative 

would decrease habitat fragmentation and degradation in 

these areas, as compared to Alternative A, but is over the 

threshold for impacts. Positive (+). 

ROW: 22% of use area would be open to ROW location, 

40% would be ROW avoidance areas, and 1% would 

allow ROWs on a case-by-case basis. This alternative 

has areas open to ROWs that exceed the threshold for 

impacts. Positive (+). 

Fishing No data 

Salmon: 

264.07 

Nonsalmon 

Fish: 

108.48 

LM: No overlap in use area and areas with med/high LM 

potential. Negative (-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

LM: No overlap in use area and areas with med/high LM 

potential. Negative (-). 

OHV: Subsistence OHV restrictions and prohibitions 

would limit access for subsistence uses in the community. 

Positive (+). 

ROW: Areas open to ROW development lie close to 

known fishing locations near Norton Sound and the 

Unalakleet and North Rivers. This could cause habitat 

degradation and introduce competing users into the area. 

Positive (+). 

LM: No overlap in use area and areas with med/high LM 

potential. Negative (-). 

OHV: Subsistence OHV restrictions and prohibitions 

would limit access for subsistence uses in the community. 

Positive (+). 

ROW: Areas open to ROW development lie close to 

known fishing locations near Norton Sound and the 

Unalakleet and North Rivers. This could cause habitat 

degradation and introduce competing users into the area. 

Positive (+). 

LM: No overlap in use area and areas with med/high LM 

potential. Negative (-). 

OHV: OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

ROW: Areas open to ROW development lie close to 

known fishing locations near Norton Sound and the 

Unalakleet and North Rivers. This could cause habitat 

degradation and introduce competing users into the area. 

Positive (+). 

O-1-45 
BSWI Draft RMP/EIS Appendix O: ANILCA Preliminary Section 810 Evaluation 

Aggregated 

Subsistence 

Use Category 

Species 

Included in 

Aggregated 

Category1 

Annual 

Pounds of 

Resource 

Harvested2 

Alternative A 

Significant Impact? [POSITIVE FINDING?] 

Alternative B 

Significant Impact? [POSITIVE FINDING?] 

Alternative C 

Significant Impact? [POSITIVE FINDING?] 

 

 

 

 

 

 

 

 

Alternative D 

Significant Impact? [POSITIVE FINDING?] 

Gathering No data 6.38 

LM: No overlap in use area and areas with med/high LM 

potential. Negative (-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

LM: No overlap in use area and areas with med/high LM 

potential. Negative (-). 

OHV: No overlap in the use area and areas with OHV 

decisions. Negative (-). 

LM: No overlap in use area and areas with med/high LM 

potential. Negative (-). 

OHV: No overlap in the use area and areas with OHV 

decisions. Negative (-). 

LM: No overlap in use area and areas with med/high LM 

potential. Negative (-). 

OHV: OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

ROW: No overlap in the use area and areas with ROW 

decisions. Negative (-). 

ROW: No overlap in the use area and areas with ROW 

decisions. Negative (-). 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

ROW: No overlap in the use area and areas with ROW 

decisions. Negative (-). 

Notes: 

LM: Locatable minerals with med/high potential 

OHV: travel decisions relating to OHV use 

ROW: Right-of-way decisions 

Impact analysis to determine whether there is a positive or negative finding is based on an assessment of magnitude, duration, extent, likelihood, and intensity. 

Available data for the Community of Unalakleet did not include hunting (birds) subsistence use areas. 

1) This column shows which species the BSWI EIS Team has GIS data for at the time of the DEIS release. Communities may have differing sets of data available or may be missing data completely for an aggregated category. In most instances where data sets for "Hunting and Trapping (SLM)" were 

available, the subsistence use area did not specify which species are included in the use area. 

2) Data is from the ADF&G Community Subsistence Information System (CSIS), available at http://www.adfg.alaska.gov/sb/CSIS/ 

O-1-46 
Appendix O: ANILCA Preliminary Section 810 Evaluation BSWI Draft RMP/EIS 

Impact Analysis Results—Upper Kalskag 

Aggregated 

Subsistence 

Use Category 

Species 

Included in 

Aggregated 

Category1 

Annual 

Pounds of 

Resource 

Harvested2 

Alternative A 

Significant Impact? [POSITIVE FINDING?] 

Alternative B 

Significant Impact? [POSITIVE FINDING?] 

Alternative C 

Significant Impact? [POSITIVE FINDING?] 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Alternative D 

Significant Impact? [POSITIVE FINDING?] 

LM: Close to 0% of the use area overlaps with areas with 

med/high LM potential. Negative (-). 

LM: Close to 0% of the use area overlaps with areas with 

med/high LM potential. Negative (-). 

LM: Close to 0% of the use area overlaps with areas with 

med/high LM potential. Negative (-). 

Hunting and 

Trapping (LLM) 

Black Bear 

Caribou 

Moose 

46.4 

LM: Close to 0% of the use area overlaps with areas with 

med/high LM potential. Negative (-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

OHV: 0% of use area is restricted for summer 

subsistence use and close to 0% is restricted for 

subsistence winter use to snowmobiles. 11% of the use 

area limits summer casual use to existing trails. This 

same 11% is also limited to snowmobiles only for casual 

winter use. Therefore, there are no access restrictions for 

subsistence uses and the greatest protection against 

habitat degradation and competing uses, as compared to 

Alternative A. Negative (-). 

ROW: 2% of use area would be open to ROW location, 

9% would be ROW avoidance areas, and 1% would be 

ROW exclusion areas. This alternative would minimize 

habitat fragmentation and degradation in these areas, as 

compared to Alternative A. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter use. 11% 

of the use area limits summer casual use to existing trails. 

There is no OHV limitation for casual winter use. 

Therefore, there is no access restriction for subsistence 

uses and the greater protection against habitat 

degradation and competing uses, as compared to 

Alternative A. Negative (-). 

ROW: 7% of use area would be open to ROW location, 

4% would be ROW avoidance areas, and close to 0% 

would be ROW avoidance areas for linear realty. This 

alternative would minimize habitat fragmentation and 

degradation in these areas, as compared to Alternative A. 

Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

ROW: 11% of use area would be open to ROW location, 

close to 0% would be ROW avoidance areas. This 

alternative would minimize habitat fragmentation and 

degradation in these areas, as compared to Alternative A, 

but is above the threshold for impacts. Additionally, LLM 

is one of the most heavily harvested resources in the 

community. Positive (+). 

Hunting and 

Trapping (SLM) SLM 7.9 

LM: No overlap in use area and areas with med/high LM 

potential. Negative (-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

LM: No overlap in use area and areas with med/high LM 

potential. Negative (-). 

OHV: No overlap in use area and OHV decisions. 

Negative (-). 

ROW: No overlap in use area and areas with ROW 

decisions. Negative (-). 

LM: No overlap in use area and areas with med/high LM 

potential. Negative (-). 

OHV: No overlap in use area and OHV decisions. 

Negative (-). 

ROW: No overlap in use area and areas with ROW 

decisions. Negative (-). 

LM: No overlap in use area and areas with med/high LM 

potential. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

ROW: No overlap in use area and areas with ROW 

decisions. Negative (-). 

LM: No overlap in use area and areas with med/high LM 

LM: No overlap in use area and areas with med/high LM 

potential. Negative (-). LM: No overlap in use area and areas with med/high LM 

potential. Negative (-). 

LM: No overlap in use area and areas with med/high LM 

potential. Negative (-). 

Hunting (Birds) Ducks 

Geese 0.0 

potential. Negative (-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

OHV: 0% of use area is restricted for summer 

subsistence use and close to 0% is restricted for 

subsistence winter use to snowmobiles. Close to 0% of 

the use area limits summer casual use to existing trails. 

This same close to 0% is also limited to snowmobiles only 

for casual winter use. Therefore, there are no access 

restrictions for subsistence uses and the greatest 

protection against habitat degradation and competing 

uses, as compared to Alternative A. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter use. Close 

to 0% of the use area limits summer casual use to 

existing trails. There is no OHV limitation for casual winter 

use. Therefore, there is no access restriction for 

subsistence uses and the greater protection against 

habitat degradation and competing uses, as compared to 

Alternative A. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

Positive (+). 

ROW: Close to 0% of the use area overlaps with ROW 

decisions. Negative (-). 

ROW: Close to 0% of the use area overlaps with ROW 

decisions. Negative (-). 

ROW: Close to 0% of the use area overlaps with ROW 

decisions. Negative (-). 

O-1-47 
BSWI Draft RMP/EIS Appendix O: ANILCA Preliminary Section 810 Evaluation 

Aggregated 

Subsistence 

Use Category 

Species 

Included in 

Aggregated 

Category1 

Annual 

Pounds of 

Resource 

Harvested2 

Alternative A 

Significant Impact? [POSITIVE FINDING?] 

Alternative B 

Significant Impact? [POSITIVE FINDING?] 

Alternative C 

Significant Impact? [POSITIVE FINDING?] 

 

 

 

 

 

 

 

 

 

Alternative D 

Significant Impact? [POSITIVE FINDING?] 

Fishing 

Salmon 

Trout 

Whitefish 

Salmon: 

198.8 

Nonsalmon 

Fish: 

48.3 

LM: Med/high areas open to LM mining are located 

approximately 6 river miles upstream on Ophir Creek of 

numerous fishing locations in Whitefish Lake. Fish make 

up approximately 71% of the harvested subsistence 

resources for the community (in lbs.) based on 2009 data. 

Access is not likely to be impacted, but mining could 

result in degradation of resources and increased 

competition. Positive (+). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

LM: Med/high areas open to LM mining are located 

approximately 6 river miles upstream on Ophir Creek of 

numerous fishing locations in Whitefish Lake. 

Additionally, more open areas are located upstream on 

the Kuskokwim River. Fish make up approximately 71% 

of the harvested subsistence resources for the community 

(in lbs.) based on 2009 data. Access is not likely to be 

impacted, but mining could result in degradation of 

resources and increased competition. The impacts would 

be greater than Alternative A as more areas are open. 

Positive (+). 

OHV: None of the surrounding area would have 

limitations to winter or summer subsistence OHV use, so 

no impacts to access. This alternative also has the 

greatest limitations to casual summer and winter OHV 

use (limited to existing trails for summer use, and limited 

to only snowmobiles in winter), so it is more protective of 

resources than Alternative A. Negative (-). 

ROW: Some areas open to ROW placement around the 

Crooked Creek area, which has a few fishing locations for 

the community. However, the majority of fishing locations 

are not near areas open to ROW placement and do not 

appear to block access. Negative (-). 

LM: Med/high areas open to LM mining are located 

approximately 6 river miles upstream on Ophir Creek of 

numerous fishing locations in Whitefish Lake. 

Additionally, more open areas are located upstream on 

the Kuskokwim River. Fish make up approximately 71% 

of the harvested subsistence resources for the community 

(in lbs.) based on 2009 data. Access is not likely to be 

impacted, but mining could result in degradation of 

resources and increased competition. The impacts would 

be greater than Alternative A as more areas are open. 

Positive (+). 

OHV: None of the surrounding area would have 

limitations to winter or summer subsistence OHV use, so 

no impacts to access. This alternative also has limitations 

to casual summer OHV use (limited to existing trails for 

summer use) but no limitations on casual winter OHV 

use. It is more protective of resources than Alternative A. 

Negative (-). 

ROW: Some areas open to ROW placement around the 

Crooked Creek area, which has a few fishing locations for 

the community. There are more open areas upstream of 

Ophir Creek, which flows into Whitefish Lake, which is a 

heavily used area for fishing. Open areas near 

Kuskokwim River are near fishing locations upstream of 

the community. These areas could lead to resource and 

habitat degradation, as well as increased competition for 

resources. Fish is the most heavily harvested subsistence 

resource for the community. Positive (+). 

LM: Same as Alternative C. Positive (+). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

ROW: Same as Alternative C. Positive (+). 

LM: No overlap in use area and areas with med/high LM 

potential. Negative (-). LM: No overlap in use area and areas with med/high LM 

potential. Negative (-). LM: No overlap in use area and areas with med/high LM 

Gathering Berries 

Plants 36.2 

LM: No overlap in use area and areas with med/high LM 

potential. Negative (-). 

OHV: No access impacts to resources. Potential impact 

to resources from competing uses and degradation of 

habitat because OHV use is unrestricted. Positive (+). 

ROW: No ROW exclusion areas, and all ROWs allowed 

on a case-by-case basis. This has the potential to 

fragment habitats and degrade subsistence resources. 

Positive (+). 

OHV: 0% of use area is restricted for summer 

subsistence use and close to 0% is restricted for 

subsistence winter use to snowmobiles. 22% of the use 

area limits summer casual use to existing trails. This 

same 22% is also limited to snowmobiles only for casual 

winter use. Therefore, there are no access restrictions for 

subsistence uses and the greatest protection against 

habitat degradation and competing uses, as compared to 

Alternative A. Negative (-). 

ROW: 20% of use area would be open to ROW location, 

2% would be ROW avoidance areas, and 0% would be 

ROW exclusion areas. This alternative would minimize 

habitat fragmentation and degradation in these areas, as 

compared to Alternative A, but is above the threshold for 

impacts. Gathering resources is also one of the most 

heavily harvested resources for the community. Positive 

(+). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter use. 22% 

of the use area limits summer casual use to existing trails. 

There is no OHV limitation for casual winter use. 

Therefore, there is no access restriction for subsistence 

uses and the greater protection against habitat 

degradation and competing uses, as compared to 

Alternative A. Negative (-). 

ROW: 20% of use area would be open to ROW location, 

2% would be ROW avoidance areas, and 0% would be 

ROW exclusion areas. This alternative would minimize 

habitat fragmentation and degradation in these areas, as 

compared to Alternative A, but is above the threshold for 

impacts. Gathering resources is also one of the most 

heavily harvested resources for the community. Positive 

(+). 

potential. Negative (-). 

OHV: 0% of use area is restricted for summer 

subsistence use and 0% is restricted for winter 

subsistence use. However, summer casual use is not 

restricted to existing trails, which could lead to 

degradation of habitat and conflict from competing uses. 

Winter casual use is not restricted to snowmobiles only, 

so the entire use area is open to all winter OHV uses. 

This is the same impact as Alternative A. Positive (+). 

ROW: 22% of use area would be open to ROW location. 

This alternative could impact gathering resources by 

degrading habitat and allowing for new users to compete 

for resources. It is above the threshold for impacts. 

Gathering resources is also one of the most heavily 

harvested resources for the community. Positive (+). 

Notes: 

LM: Locatable minerals with med/high potential 

OHV: travel decisions relating to OHV use 

ROW: Right-of-way decisions 

Impact analysis to determine whether there is a positive or negative finding is based on an assessment of magnitude, duration, extent, likelihood, and intensity. 

1) This column shows which species the BSWI EIS Team has GIS data for at the time of the DEIS release. Communities may have differing sets of data available or may be missing data completely for an aggregated category. In most instances where data sets for "Hunting and Trapping (SLM)" were 

available, the subsistence use area did not specify which species are included in the use area. 

2) Data is from the ADF&G Community Subsistence Information System (CSIS), available at http://www.adfg.alaska.gov/sb/CSIS/ 

O-1-48