Proposed Greater Mooses Tooth

Two Development Project 

Supplemental Environmental Impact Statement for the Alpine Satellite Development Plan 

Joint Record of Decision and Permit Evaluation 

with the U.S. Army Corps of Engineers 

October 2018 

U.S. Department of the Interior 

Bureau of Land Management 
1 

2 3 4 

The Bureau of Land Management Today 

Our Vision 

To enhance the quality of life for all citizens 

through the balanced stewardship of America’s 

public lands and resources. 

Our Mission 

To sustain the health, diversity, and productivity 

of the public lands for the use and enjoyment 

of present and future generations.

DOI-BLM-AK-F010-2016-0042-EIS 

BLM Cover Photos 

1. Aerial of production pad, North Slope 

© ConocoPhillips 

2. Caribou, National Petroleum Reserve, Alaska 

3. Crea Creek flowing into Lake L9819, 

National Petroleum Reserve, Alaska 

4. White-fronted goose, National Petroleum 

Reserve, Alaska 

BLM/AK/PL-19/001+1610+FO200 
Proposed Greater Mooses Tooth Two 

Development Project

Joint Record of Decision and Permit Evaluation 

Bureau of Land Management 

U.S. Army Corps of Engineers 

October 2018 

CONTENTS

Summary ....................................................................................................................................................... 1

Decision ........................................................................................................................................................ 3

Alternatives ................................................................................................................................................... 7

Management Considerations ......................................................................................................................... 9

ANILCA: Section 810 Summary ............................................................................................................... 18

Mitigation and Monitoring .......................................................................................................................... 22

Public Involvement ..................................................................................................................................... 23

Final Agency Action ................................................................................................................................... 24

Assistant Secretary Approval ...................................................................................................................... 24

Corps Approval ........................................................................................................................................... 24

LIST OF APPENDICES

Appendix A: Supplemental Best Management Practices

Appendix B: Modifications and Clarifications

Appendix C: Potential New Mitigation Measures Not Adopted

Appendix D: Corps Determination

Appendix E: Maps

Appendix F: U.S. Fish and Wildlife Service Biological Opinion

SUMMARY 

This document constitutes the Joint Record of Decision (JROD) of the U.S. Department of Interior (DOI)

Bureau of Land Management (BLM) and Department of the Army (DA) Corps of Engineers (Corps), for 

the Greater Mooses Tooth Two Development Project (GMT2 Project) proposed by ConocoPhillips 

Alaska, Inc. (ConocoPhillips, Applicant, or Permittee). The One Federal Decision policy mandated by 

Executive Order 13807 does not expressly apply to the Project, but the BLM and the Corps are 

voluntarily issuing a JROD in the spirit of that Executive Order. 

This JROD outlines the BLM’s and the Corps’ decision, under the National Environmental Policy Act 

(NEPA), to select Alternative A for the Proposed Greater Mooses Tooth Two Development Project, as 

detailed in the August 2018 Final Supplemental Environmental Impact Statement for the Alpine Satellite 

Development Plan (ASDP)for the Proposed Mooses Tooth 2 Development Project (GMT2 Final 

Supplemental EIS) and subject to special conditions and the specified mitigation described below. The 

BLM’s authorities include all components of the Project that occur on BLM-managed lands. The Corps 

authorities are specific to components of the Project proposed to be constructed within waters of the 

United States (WOUS). The decision will allow development of Federal oil and gas leases on BLMmanaged land in the National Petroleum Reserve in Alaska (NPR-A). 

The GMT2 Final Supplemental EIS analyzed ConocoPhillips’s proposal to develop oil accumulations 

from the proposed GMT2 drill pad on BLM-managed lands. The decisions in this JROD are limited to 

Federal lands, and only address authorizations under the jurisdiction of the BLM and the Corps. Access to 

non-Federal lands is subject to landowner approval, and other Federal and State agencies will process 

applications for authorizations under their respective jurisdictions. 

The GMT2 Final Supplemental EIS analyzed a full range of alternatives. These are: 

• Alternative A: ConocoPhillips’s proposed project, involving a multi-well drill pad and associated

facilities located on BLM-managed lands accessed by a gravel road and pipeline connected to the

GMT1 development, CD5, and the Alpine CPF.

• Alternative B: An alternative similar to Alternative A, but which would have an alternate road and

pipeline alignment that traverses the watershed boundary between Fish Creek and the

Tinmiaqsiugvik River drainage basins.

• Alternative C: An alternative which would not include gravel road access to GMT2, and would

require a gravel airstrip and occupied structure pad, and use of annual ice-roads for the life of the

project.

• Alternative D: The “No Action Alternative,” that analyzed the current conditions and expected

future condition if ConocoPhillip’s application for permit to drill and application for discharge

into WOUS would not be approved..

Each action alternative offered a different approach to development while protecting surface resources 

from unnecessary and undue degradation, as required by the Federal Land Policy and Management Act 

(FLPMA). 

All available information related to surface and subsurface resources and impacts was presented in the 

GMT2 Final Supplemental EIS. Environmental modeling was conducted to predict specific impacts 

associated with proposed infrastructure, particularly potential impacts to air quality. The analysis utilized 

knowledge of impacts of past North Slope oil development, and benefited from studies and monitoring 

gained as a result of requirements from the 2004 ASDP Environmental Impact Statement (EIS) ROD. The 

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findings in the GMT2 Final Supplemental EIS are based on an open and collaborative process that 

benefited from close coordination among the scientists and other resource specialists of the BLM, 

cooperating agencies, the DOI/Environmental Protection Agency (EPA)/U.S. Department of Agriculture

Forest Service Air Quality Working Group, and by an ongoing dialogue with North Slope residents, 

particularly those in Nuiqsut (the closest community to the project). The evaluation resulted in a GMT2 

Final Supplemental EIS that provides sufficient detailed analysis to adequately inform the decision 

makers for purposes of this JROD. 

In the GMT2 Draft and Final Supplemental EIS, the BLM identified Alternative A as its Preferred 

Alternative; the Corps did not identify a preferred alternative. The BLM based its preference on the fact 

that the other action alternatives did not result in any appreciable environmental advantage over 

Alternative A. 

As part of its decision to adopt Alternative A in this JROD, the BLM is also implementing a robust 

package of mitigation measures to add to the pre-existing protective measures applicable to all BLMauthorized projects in the NPR-A, including the GMT2 project. In addition to reducing impacts to the 

project area as a whole, and in recognition of the importance of the lease stipulations and best

management practices (BMPs) established by the 2013 NPR-A Integrated Activity Plan (IAP) decision, 

the mitigation package will serve to minimize additional adverse impacts to resources and uses specific to 

the GMT2 project. In developing this mitigation package, the BLM considered its required existing 

protective measures, including previously identified BMPs, existing lease stipulations, and mitigation 

incorporated by the applicant via project design. The GMT2 project is subject to the lease stipulations 

adopted in the 2008 Northeast NPR-A ROD and the BMPs adopted in the 2013 NPR-A IAP/EIS ROD. In 

addition to the BMPs already applicable to the project, in this decision the BLM is adopting new 

measures as Supplemental BMPs designed to further avoid or reduce impacts from the proposed action. 

The BLM decision made in this JROD emphasizes balanced and environmentally responsible 

development, and includes protections for physical and biological resources. The decision also addresses 

local residents’ concerns regarding protection of their subsistence way of life and the subsistence 

resources on which they depend. At the same time, the decision enables leaseholders to reasonably 

develop the petroleum resources from Federally managed and Alaska Native Corporation-owned lands, 

providing revenue to the mineral subsurface estate managers, Arctic Slope Regional Corporation (ASRC) 

and the Federal Government, while helping to meet America’s energy needs. Royalties received by ASRC 

will result in revenues to Alaska Native corporations from shared royalties, and the GMT2 development 

project will also lead to increased revenues to the North Slope Borough, Nuiqsut, and the State of Alaska 

resulting from shared federal royalties, State and local taxes, state-administered NPR-A Impact Fund 

Grants, and other fees. 

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DECISION

Introduction

In August 2015, ConocoPhillips submitted an application to the BLM for issuance of a permit to drill to 

construct, operate, and maintain a drill site, access road, pipelines, and ancillary facilities to support 

development of petroleum resources in the Greater Mooses Tooth Unit. The proposed GMT2 drill site 

location and a majority of the infield road and pipeline route are on BLM-managed lands in the NPR-A. 

The project is located on the North Slope of Alaska, immediately west of the Colville River Delta, 

approximately 11 miles northwest of the village of Nuiqsut. In order to process the applications, the BLM

analyzed the environmental impacts of the proposed project and a reasonable range of alternatives in 

accordance with NEPA, the Council on Environmental Quality NEPA regulations, DOI NEPA regulations, 

and other applicable authorities. 

Background and History of the Proposed Project 

In 1980, Congress authorized petroleum production in the NPR-A and directed DOI to undertake “an 

expeditious program of competitive leasing of oil and gas” in the Reserve (P.L. 96-514). Since 1998, the 

BLM’s management of the NPR-A has been guided by integrated activity plans developed in consultation 

with key stakeholders and the public through the NEPA and Native Alaskan consultation processes. The 

first such plan was the 1998 Northeast NPR-A IAP/EIS, which included the area where GMT2 is 

currently proposed. That plan was amended by the 2008 Northeast NPR-A Supplemental IAP/EIS, which 

in turn was superseded by the 2012 NPR-A IAP/EIS and 2013 NPR-A IAP/EIS ROD that now governs all 

Federal lands in the NPR-A. The plans identified which areas are available to oil and gas leasing, and 

established various protective measures in the form of lease stipulations and BMPs designed to avoid and 

minimize impacts from oil and gas activities. 

As envisioned by the 1998 Northeast NPR-A IAP/EIS, lease sales were held in 1999 and 2002, with 

ConocoPhillips receiving numerous leases, including the lease where the GMT2 drill site is located. 

ConocoPhillips began oil and gas production near the NPR-A on non-Federal lands in 2000 and 2001 

with the construction and operation of facilities known as Alpine CD1 and CD2. In 2002, ConocoPhillips

proposed an Alpine Satellite Development Plan (ASDP) that envisioned development of five satellite 

drilling pads: two in the Colville River Delta adjacent to the NPR-A (CD3 and CD4) and three in the 

NPR-A (CD5, GMT1, and GMT2). Under the ASDP, product from all five pads would be processed at the 

Alpine CPF located at CD1. Although within the boundaries of the NPR-A, CD5 is not on federally 

administered land, but GMT1 and GMT2 – which were known as “CD6” and “CD7” in the 2004 ASDP – 

are located on federally leased tracts. The BLM approved the plan for the two Federal sites in its 2004 

ASDP EIS ROD. The 2004 decision tiered to the 1998 Northeast NPR-A IAP/EIS and also incorporated 

the stipulations adopted in the 1998 Northeast NPR-A IAP/EIS ROD and additional mitigation measures 

to protect potentially affected resources. In 2013, ConocoPhillips submitted the first application for 

permit to drill and an associated right-of-way application for GMT1, resulting in the BLM preparing a 

GMT1 Supplemental EIS (finalized in 2015) to the 2004 ASDP Final EIS. The GMT1 Project was 

approved by the BLM through a ROD signed in February 2015. Although that 2015 Supplemental EIS 

discussed development opportunities at GMT2 as an alternative to GMT1, no application for developing 

the GMT2 site had been filed at that time with the BLM or other permitting entities.

The GMT2 project has evolved since it was first discussed in the 2004 ASDP and its Suppplemental EIS, 

withchanges o the project design due to subsequent decisions (such as the approval of GMT1) and to

reduce impacts to certain resources, and revised estimates of recoverable oil. Specifically, modifications 

include moving the pad location out of the Colville River Special Area, increasing the pad size and the 

number of wells, reducing the road and pipeline length from what was proposed in the GMT1 

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Supplemental EIS (and thereby reducing the amount of fill required and associated impacts to wetlands),

and utilizing the existing ASRC Gravel Mine Site. 

To further evaluate the specific GMT2 project proposed here, an additional supplement to the 2004 ASDP 

Final EIS was prepared. The Federal Register published the Notice of Availability (NOA) for the GMT2 

Draft Supplemental EIS on March 29, 2018, and the NOA for the GMT2 Final Supplemental EIS was 

published on August 31, 2018. 

BLM Management Responsibilities and Requirements in the NPR-A 

As the Federal manager of the NPR-A, the BLM is responsible for land-use authorizations on Federal

land in the NPR-A. The authority for management of NPR-A comes from several statutes including the 

Federal Land Policy and Management Act (FLPMA), the Naval Petroleum Reserves Production Act of 

1976 (NPRPA), as amended by the Department of the Interior Appropriations Act for Fiscal Year 1981 

(P.L. 96-514), and Title VIII of the Alaska National Interest Lands Conservation Act (ANILCA). These 

BLM authorities are further described below: 

• Under FLPMA, the Secretary of the Interior has broad authority to regulate the use, occupancy,

and development of public lands and to take whatever action is required to prevent unnecessary

or undue degradation of public lands (43 U.S.C. 1732).

• The NPRPA, as amended, requires oil and gas leasing in the NPR-A while also requiring

protection of important surface resources and uses. The NPRPA provides the Secretary of the

Interior with the authority to: protect “environmental, fish and wildlife, and historical or scenic

values” in the NPR-A (42 U.S.C. 6503(b)); and provide “conditions, restrictions, and prohibitions

as the Secretary deems necessary or appropriate to mitigate reasonably foreseeable and

significantly adverse effects on the surface resources of the National Petroleum Reserve in

Alaska” (42 U.S.C 6506a(b)).

• Title VIII of ANILCA establishes procedures for Federal land managing agencies to evaluate

impacts on subsistence uses and needs and means to reduce or eliminate such impacts (16 U.S.C.

3120).

Corps Authority in the NPR-A 

The Applicant proposes to discharge fill material into waters of the United States (WOUS), including

wetlands, which require authorization from the Corps. 

This permit action is being undertaken through authority delegated to the District Engineer by 33 CFR 

325.8, pursuant to Section 404 of the Clean Water Act (CWA) (33 USC 1344). 

• The Corps has authority through Section 404 of the CWA to regulate the discharge of dredged or

fill material into WOUS.

Under the Council on Environmental Quality regulations for implementing NEPA (40 CFR 1500-1508), 

the Corps participated in development of the GMT2 Supplemental EIS as a cooperating agency. The 

Corps has reviewed and evaluated the information in the GMT2 Final Supplemental EIS, including all 

supplemental data subsequently provided, in accordance with 40 CFR 1506.3 and 33 CFR 325, appendix 

b, and has found them to be sufficient and accurate assessments, and therefore adopts the EIS as 

appropriate for the purposes of NEPA and the public interest review and alternatives analysis required by 

33 CFR 320.4(b)(4) and 33 CFR 325 Appendix B. 

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Summary of BLM Decision 

This JROD approves the development of the GMT2 project as described in Alternative A of the GMT2 

Final Supplemental EIS. 

This JROD concludes the Supplemental EIS process for the BLM. It fulfills the NEPA requirements 

associated with consideration of ConocoPhillips’s applications to develop oil accumulations on lands the 

BLM has leased to ConocoPhillips. 

The JROD completes the required NEPA process for subsequent issuance of the appropriate BLM permits 

to drill on the GMT2 pad and other authorizations necessary for initial development of the GMT2 project. 

This includes: 

• Construction and operation of the GMT2 drilling and production pad; and

• Construction and operation of a gravel road and a pipeline that will link the GMT2 pad to the

GMT1 pad on BLM-managed lands with the CD5 pad on Kuukpik Corporation land and with the

Alpine Central Production Facility (CPF) on State land.

The location of the GMT2 pad, road, and pipelines are described in Alternative A in the GMT2 Final 

Supplemental EIS (Section 2.5 and Appendix drawings). The pad would measure approximately 14 acres. 

The road accessing GMT2 from GMT1 would be approximately 8.2 miles long. A set of pipelines, power 

and communications lines would be mounted on a series of vertical support members (VSMs) parallel to 

the road. The exact specifications for these facilities may vary slightly from those shown in the GMT2 

Final Supplemental EIS and on application drawings to meet the requirements of permits issued by other 

Federal and State agencies. 

The BLM’s decision approves deviations to one stipulation included in the 2008 Northeast NPR-A 

IAP/EIS ROD and one best management practice (BMP) from the 2013 NPR-A IAP/EIS ROD: 

• Lease Stipulation 41 (now Lease Stipulation E-2): to allow oil infrastructure within

500 feet of water bodies; and

• Best Management Practice E-7(c): to allow less than a 500 foot separation distance between

pipelines and roads.

Additional discussion of the rationale for approving these deviations is included in Section 3, 

Management Considerations. Notwithstanding these deviations, the BLM reaffirms the land use 

authorizations, stipulations, and best management practices established by the 2013 NPR-A IAP decision. 

All other lease stipulations and BMPs in place from the 2008 Northeast NPR-A IAP/EIS ROD and 2013 

NPR-A IAP/EIS ROD, respectively, will remain in place. Additionally, the mitigation measures adopted 

by the 2004 ASDP ROD and have been incorporated into the project by the applicant as design features. 

In addition to project design features, the BLM lease stipulations, and BMPs already applicable to the 

project, the BLM is adopting in this JROD Supplemental BMPs designed to further avoid or reduce 

impacts from this specific action. The Supplemental BMPs are selected from the potential new mitigation 

measures described and analyzed in the relevant resource sections in Chapter 4 of the GMT2 Final 

Supplemental EIS, which were developed through the NEPA process based on suggestions from 

cooperating agencies, stakeholders, the public, and BLM staff. A full description of the adopted 

Supplemental BMPs is provided in Appendix A of this JROD. 

This decision will result in no unnecessary or undue degradation of public lands. Adverse impacts to these 

lands and the uses of these lands are minimized by: 

• lease provisions and stipulations;

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• required 2013 NPR-A IAP/EIS ROD BMPs;

• protections incorporated into the project design (such as the drill pad location outside of Colville

River Special Area);

• Supplemental BMPs developed through the course of the Supplemental EIS and adopted by this

JROD (as described above and in Appendix A); and,

• applicable Federal, State, and North Slope Borough (NSB) laws and regulations.

This decision also adopts the Reasonable and Prudent Measures (RPM) and the implementing Terms and 

Conditions (T&C), included by the U.S. Fish and Wildlife Service (USFWS or Service) in its amended 

Biological Opinion dated September 21, 2018, to protect polar bears (Ursus maritimus), spectacled eiders 

(Somateria fischeri), and Alaska-breeding Steller’s eiders (Polysticta stelleri). The Biological Opinion 

can be found in Appendix F. 

Summary of Corps Decision 

A DA permit pursuant to Section 404 of the CWA (33 USC 1344), is being issued to ConocoPhillips for 

the discharge of fill material into waters of the United States (WOUS), including wetlands. The DA 

permit authorizes the Applicant’s proposed action (Alternative A), as described in the GMT2 Final 

Supplemental EIS. The impacts as a result of the discharge of fill into WOUS and are described in 

Appendix D. This alternative incorporates all practicable avoidance and minimization measures.

A detailed description of proposed activities involving the discharge of fill in WOUS is included in Block 

18 (Nature of Activity) in the December 2017 DA permit application. These activities include fill for 

construction of a gravel access road, drill pad, vehicle pullouts, and Vertical Support Members (VSMs) 

for pipeline and utility support. Principal impacts to WOUS resulting from construction of the Project 

include the placement of 674,300 cubic yards of gravel fill in 77.9 acres of WOUS.

The Corps’ supporting analysis for this JROD is included as Attachment D.

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ALTERNATIVES

The elements of the alternatives presented in the GMT2 Final Supplemental EIS are consistent with the 

purposes of the statutes governing the NPR-A and with the BLM’s responsibilities under FLPMA. The 

action alternatives carried forward from the 2004 ASDP EIS were modified and updated for conditions 

specific to the GMT2 project as currently proposed, and based on the analysis tiered to and incorporated 

by reference from the 2015 GMT1 Supplemental EIS. Each alternative offers a different approach to 

approving ConocoPhillips’s application to produce oil reserves on its leases. The following provides brief

descriptions of the alternatives contained in Chapter 2 of the GMT2 Final Supplemental EIS. 

Alternative A (ConocoPhillips’s Proposed Action and the BLM’s Environmentally Preferred 

Alternative): The proposed 14-acre GMT2 gravel pad would contain 48 drilling and injection wells. An 

8.2-mile gravel road and 8.6-mile elevated pipeline would connect GMT2 to the existing GMT1 pad. 

Produced fluids would be transported by pipeline via GMT1 and CD5 for processing at the existing 

Alpine CPF. Personnel and equipment would be flown to the airstrip at the existing Alpine CPF and 

transported to GMT2 via the gravel road. Gravel used for construction of roads and pads would be 

obtained from the existing ASRC Mine Site. The proposed GMT2 road would require 46 culverts, three 

0.4 acre vehicle pullouts, and no bridges. Aboveground pipelines would be supported on a set of VSMs 

between GMT2 and GMT1; pipelines would be at elevations of at least 7 feet above the tundra. 

Approximately 0.5 miles of pipeline would not meet the minimum mandatory separation of 500 feet from 

fish-bearing waterbodies and would require a deviation from Lease Stipulation 41 (Stipulation E-2 in the 

2013 IAP/EIS ROD). Approximately 2.6 miles of road and pipeline would not be constructed to meet the 

minimum mandatory separation of 500 feet, and require a deviation from BMP E-7(c) in the 2013 

IAP/EIS ROD. Both deviations are described in Management Considerations below. This alternative 

would require up to 53 miles of ice roads during the construction phase of the project. The total gravel 

footprint in USACE jurisdictional waters of the United States for this alternative would be approximately 

78 acres. 

Alternative B: Alternative B would feature the same GMT2 pad location, facility design and operational 

parameters, but would have a different road and pipeline alignment between GMT1 and GMT2 from that 

described in Alternative A. Instead, the road and pipeline follow the watershed boundary between Fish 

Creek and the Tinmiaqsiugvik River, in order to see whether environmental advantages could occur from 

having the road on potentially higher ground. The Alternative B alignment resulted in increasing the road 

length to 9.3 miles and the number of culverts to 50, and the pipeline length to 9.4 miles. Deviations for 

both Lease Stipulation 41 (Stipulation E-2) and BMP E-7(c) would also need to occur for Alternative B. 

The total gravel footprint for this alternative would be approximately 87.2 acres.

Alternative C: In Alternative C, the gravel road between GMT2 and GMT1 would be eliminated and the 

GMT2 production pad would be accessible only by aircraft or ice road. All personnel and equipment 

would be transported to the GMT2 pad via fixed-wing planes and helicopters or a seasonal ice road. The 

pipeline and VSMs would follow the same route and design as described for Alternative A. In addition to 

the facilities and features required for the GMT2 pad in all action alternatives, Alternative C would 

require that certain facilities, services, equipment, and supplies (otherwise provided at CPF) would need 

to be duplicated at or near the drill pad. Notably, the Alternative C pad would require its own 5,000-foot 

gravel airstrip and parking apron, 18.4-acre occupied structure pad to house additional infrastructure, and 

a 0.9-mile gravel access road between the GMT2 pad and the airstrip. Drilling would be supported by a 

crew based in a 225-man camp (workers to support drilling and well tie-in) on the occupied structure pad. 

In addition, a 25-man operation support camp would also be located on the occupied structure pad. This 

alternative would require construction of a 7-mile long annual resupply ice road, through the life of the 

project. The total gravel footprint for this alternative would be approximately 87.4 acres. 

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Alternative D (No Action): Under this alternative, ConocoPhillips’s applications to construct, operate, 

and maintain a drill site, access road, pipelines, and ancillary facilities to support development of 

petroleum resources in the Greater Mooses Tooth Unit would not be approved by the BLM and the 

application to deposit fill in WOUS and impact navigable waterways would not be approved by the 

Corps. No oil would be produced from GMT2 in the near future, and no new roads, airstrips, pipelines, or 

other oil facilities would be constructed beyond what is currently authorized in connection with 

ConocoPhillips’s current development. Under this alternative, the BLM analyzed the current conditions 

and expected future condition in the absence of the GMT2 project. Alternative D is the environmentally 

preferable alternative because it would prevent damage to the biological and physical environment, and 

would best preserve and protect historic, cultural, and natural resources. However, Alternative D is not a 

practicable alternative in the JROD, due to the fact that the BLM cannot select this alternative as its 

decision for GMT2. Once issued, oil and gas leases provide a right of development, subject to reasonable 

regulation. 

8
MANAGEMENT CONSIDERATIONS

The GMT2 Final Supplemental EIS fulfills the obligation of the BLM and its Federal cooperating 

agencies under NEPA, to analyze the environmental impacts of Federal authorizations necessary for 

ConocoPhillips to undertake its proposed GMT2 development. Authorizing ConocoPhillips’s 

development helps address the Nation’s total energy needs. North Slope oil production, centered at 

Prudhoe Bay, is an important component of the Nation’s domestic oil supply. The oil industry has 

discovered and developed other fields to the east and west of Prudhoe Bay. However, production has 

declined from these older fields and development of ConocoPhillips’s project will help offset this decline

and provide a new source of oil for the Trans-Alaska Pipeline System. Moreover, the authorization of 

development of leases in the NPR-A satisfies the purpose of the NPRPA to explore and develop oil and 

gas resources in the NPR-A. Specifically, the NPRPA, as amended, encourages oil and gas leasing in the

NPR-A while requiring protection of important surface resources and uses. Development of satellite oil 

accumulations at GMT2, with appropriate environmental protection measures, is consistent with the 

President’s commitment to expand domestic energy production. 

Federal laws, including the NPRPA, FLPMA, ANILCA, and the Endangered Species Act (ESA), require 

the BLM to protect soil, water, air, vegetation, wildlife, archaeological and paleontological resources, and 

subsistence uses while fulfilling the agency’s multiple-use mission. These resources are protected 

through: 

• lease provisions and stipulations;

• required 2013 NPR-A IAP/EIS ROD BMPs;

• additional protections incorporated into the project design (such as the drill pad location outside

of the Colville River Special Area);

• Supplemental BMPs developed through the course of the Supplemental EIS and adopted by this

JROD (as described above and in Appendix A); and,

• applicable Federal, state, and NSB laws and regulations.

Implementation of applicant-proposed design elements, except where they are inconsistent with the 

adopted decision, is required of the applicant.

Rationale for Adopting Alternative A

Among the alternatives evaluated in the GMT2 Final Supplemental EIS, Alternatives A and B would 

result in fewer overall environmental impacts than Alternative C. Alternatives A and B would have a 

smaller development footprint than Alternative C. Alternative C would not result in impacts associated 

with a gravel road, such as disturbance to wildlife from ground vehicle traffic, impacts to vegetation from 

fugitive road dust, and hydrological impacts due to restriction of surface water flow. However, with 

Alternative C would result in increased noise and adverse impacts to air quality due to increased flights 

and emissions associated with the additional infrastructure required at the drill site. Alternative C would 

also require annual construction of an ice road connection to GMT1, resulting in increased noise, traffic, 

and emissions in and near Nuiqsut and increased surface water withdrawals used to construct ice roads. 

Additionally, Alternative C would not provide residents of Nuiqsut year round access to the GMT2 road, 

thus limiting opportunities for subsistence access. Alternatives B and C have higher estimated capital 

expenditure costs than Alternative A, with Alternative C substantially higher. 

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Alternative D would not allow ConocoPhillips to produce oil from accumulations on its oil and gas leases

and would not fulfill regulatory requirements, legislative direction, national energy policy, or the purpose 

and objectives for which the NPR-A is managed. 

Alternatives A and B are similar in their designs and impacts to most all environmental resources. 

However, Alternative A has a shorter road and an overall smaller development footprint. The shorter road 

and smaller footprint associated with Alternative A result in less impact to wetlands habitat and is the 

BLM’s environmentally preferred alternative. 

As discussed above in the Summary, the BLM identified Alternative A as its preferred alternative in the 

GMT2 Final Supplemental EIS. Given the similarities between Alternatives A and B with respect to 

resource impacts, and the fact that the Corps has determined that Alternative A is the Least 

Environmentally Damaging Practicable Alternative (LEDPA), this JROD adopts Alternative A as the 

federally coordinated decision. 

Consistency with the National Petroleum Reserve in Alaska IAP/EIS 

The NPR-A IAP/EIS ROD issued in 2013 required that numerous protections be provided through lease 

stipulations and BMPs for oil and gas development on Federal lands within the NPR-A. These protections 

address measures to mitigate potential impacts related to waste prevention, handling, and disposal; spills; 

water use; overland moves; facility design and construction, ground transportation; air traffic; oil field 

abandonment; subsistence, orientation program; and other activities. These stipulations and BMPs are 

required for ConocoPhillips’s development, with the exception of deviations approved in this JROD for 

the one stipulation and one BMP discussed below. 

The 2013 NPR-A IAP/EIS ROD lists the current BMPs applicable to oil and gas activities, and provides a 

process whereby an applicant can seek relief from the requirements and standards of a lease stipulation or 

BMP by requesting that the BLM approve a “deviation” from the measure. In this way, the IAP ROD 

provides flexibility to deal with unique aspects of oil and gas development proposals that are impossible 

to know prior to exploratory drilling. In order for a deviation to be approved, the BLM must determine 

that the objectives of the stipulation or BMP will be achieved by the applicant’s alternative proposal.

Consistent with the requirements of the IAP/EIS, this JROD approves deviations from one stipulation and 

one BMP as requested by ConocoPhillips in a letter to the BLM dated October 30, 2017. Notwithstanding 

these deviations, the BLM reaffirms the land use authorizations, stipulations, and best management 

practices established by the 2013 NPR-A IAP decision. 

Deviations are approved in accordance with the following clause from the 2013 IAP/EIS ROD: 

Prior to approving an alternative procedure as part of the authorization, BLM’s staff 

would analyze the proposal and determine if the proposal incorporating the alternative 

procedure would achieve the objectives of the stipulations and best management 

practices. If the BLM determines that the alternative procedure proposed by the applicant 

would meet the stipulation’s or best management practice’s objective, the BLM could 

approve the alternative procedure. If the BLM determines that the alternative procedure 

proposed by the applicant is unlikely to meet the objectives of a stipulation or best 

management practice, the requirements/standards would still be required. However, the 

Authorized Officer may allow a deviation from the objectives and requirement/standard 

in a new decision document supported by additional NEPA analysis. 

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Deviations are hereby approved for the following stipulations/BMPs based upon the above requirements. 

Lease Stipulation E-2 (formerly Lease Stipulation 41) 

Lease Stipulation E-2 of the 2013 NPR-A IAP/EIS ROD states:

Permanent oil and gas facilities, including roads, airstrips, and pipelines, are prohibited 

upon or within 500 feet as measured from the ordinary high water mark of fish-bearing 

water bodies. Essential pipeline and road crossings will be permitted on a case-by-case 

basis. 

Deviation of this stipulation is warranted because compliance is technically infeasible due to the 

hydrology and number of water bodies in the project area, and other measures are required that would 

protect water bodies (e.g., leak detection and use of secondary containment). While much of the major 

infrastructure is located away from lakes and streams, the project area between GMT2 and GMT1 is 

characterized by many small water bodies. As a result, it is not possible in all instances to avoid 

encroachment within 500 feet of every water body, and under Alternative A, the road route would run 

within 500 feet of one fish-bearing lake (Lake M9925). 

The purpose of the 500-foot setback from water bodies is to protect fish, water quality, and aquatic habitat 

from impacts, including oil and fuel spills. On-the-ground inspections of the route of the road and 

pipeline prior to construction, along with existing stream and lake studies, will assist in agency 

determinations on facility design to minimize impacts to water bodies where facilities cannot be placed 

500 feet from water bodies. In addition, aspects of the applicant’s proposed action, such as use of 

containment tanks, tank and pipeline inspections, and other NPR-A IAP/EIS stipulations and BMPs (e.g., 

those dealing with the handling of fuel and other pollutants) substantially reduce the potential for impacts 

to water bodies. Therefore, this decision approves a deviation of Stipulation E-2. 

Best Management Practice E-7(c)

Best Management Practice E-7(c) of the 2013 NPR-A IAP/EIS ROD states:

Pipelines and roads shall be designed to allow the free movement of caribou and the safe, 

unimpeded passage of the public while participating in subsistence activities... 

(c) A minimum distance of 500 feet between pipelines and roads shall be maintained.

Separating roads from pipelines may not be feasible within narrow land corridors

between lakes and where pipelines and roads converge on a drill pad. Where it is not

feasible to separate pipelines and roads, the authorized officer will consider alternative

pipeline routes, designs, and possible burial within the road.

A 500-foot distance between pipelines may not be feasible within narrow land corridors amid lakes and 

where pipelines and roads converge on a drill pad. The route depicted in Map 2.5-1 in the GMT2 Final 

Supplemental EIS is based on topographic maps available to the BLM at the time of the Final 

Supplemental EIS publication. ConocoPhillips has not yet completed its final surveys of the Alternative A

road route, and will be required to maintain a 500-foot separation between the road and pipeline during 

survey and construction of the road where it is technically feasible to do so. 

The purpose of the 500-foot minimum distance between roads and pipelines is to minimize disruption of 

caribou movement and subsistence use. The physical location of GMT2 and its associated road and 

pipeline are not anticipated to have adverse impacts to caribou populations, though caribou may incur 

some disturbance during operations from infrastructure. Supplemental mitigation measures such as traffic 

controls during peak migration season and other design and operation features of the proposed project 

11
will further reduce impacts to subsistence resources. Accordingly the requested deviation from BMP E7(c) is approved. 

Endangered Species Consultation 

Section 7(a)(2) of the ESA requires Federal agencies to consult with the USFWS and the National Marine 

Fisheries Service (NMFS or NOAA Fisheries), as appropriate, to ensure that their actions do not 

jeopardize the continued existence of species listed as threatened or endangered under the ESA, or destroy 

or adversely modify their critical habitat. The NOAA Fisheries, in a letter dated July 20, 2018, concurred 

with the BLM’s determination that this project may affect, but is not likely to adversely affect, federally 

listed threatened, endangered, or candidate species or proposed critical habitat under its jurisdiction for 

Arctic ringed seals and Beringia DPS bearded seals. It also concurred with the BLM’s determination that 

the project would have no effect on the endangered bowhead, humpback, or fin whale. 

The USFWS issued its Biological Opinion (BO) on September 21, 2018. The BO determined that the 

GMT2 project is consistent with the management actions considered in the 2013 IAP/EIS BO; therefore, 

the USFWS determined that GMT2 is not likely to jeopardize the continued existence of spectacled eiders 

or polar bears or to destroy or adversely modify polar bear designated critical habitat. Further, the 

USFWS determined the proposed project is not likely to adversely affect Alaska-breeding Steller’s eiders. 

While USFWS does not anticipate incidental take of Steller’s eiders due to this project, the Incidental 

Take Statement in the 2013 IAP/EIS BO provides coverage under the ESA should Steller’s eiders 

unexpectedly collide with structures associated with GMT2. 

The USFWS determined the level of incidental take for spectacled eiders and polar bears for Alternative A 

in conjunction with the BO, and included Reasonable and Prudent Measures, Terms and Conditions, and 

Conservation Measures that will be applicable to the project for purposes of the Corps’ and the BLM’s 

authorizations. 

Wetlands and Floodplains Executive Orders 

If a proposed action is to be located in a floodplain and/or involves construction in wetlands, then 

Executive Orders 11988 -- Floodplain Management (Floodplains EO) and/or 11990 -- Protection of 

Wetlands (Wetlands EO) may be applicable. As discussed below, these executive orders contain 

requirements that Federal agencies must comply with when evaluating a proposed action, including 

requirements for: public review of proposals, certain findings, adoption of mitigation, and, in the case of 

floodplains, public notice. These requirements may be addressed and satisfied through an agency’s NEPA 

process.

Wetlands (Executive Order 11990) 

Executive Order 11990 concerning the protection of wetlands requires that the BLM and the Corps 

consider factors relevant to the proposal’s effect on the survival and quality of wetlands. Factors to be 

considered include: 

• Public health, safety, and welfare, including water supply, quality, recharge and discharge;

pollution; flood and storm hazards; and sediment and erosion;

• Maintenance of natural systems, including conservation and long term productivity of existing

flora and fauna, species and habitat diversity and stability, hydrologic utility, fish, wildlife,

timber, and food and fiber resources; and,

• Other uses of wetlands in the public interest, including recreation, scientific, and cultural uses.

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The BLM and the Corps are required to avoid undertaking or providing assistance for new construction 

located in wetlands unless the head of the agency finds: 

1. There is no practicable alternative to such construction; and,

2. The proposed action includes all practicable measures to minimize harm to wetlands which may

result from such use. In making this finding the head of the agency may take into account

economic, environmental and other pertinent factors.

The following discussion summarizes the evaluation of impacts to wetlands for Alternative A, and the 

findings that are a result of that evaluation. In addition, the discussion presents specific protective 

mitigation developed to avoid or lessen impacts to wetlands. 

The GMT2 project facilities and proposed drill site are located entirely within the northeastern NPR-A, on 

the North Slope of Alaska, west of the Colville River delta. The project area is depicted on Map 3.1-1 of 

the GMT2 Final Supplemental EIS and in this JROD in Appendix E. The project area extends 

approximately 2.5 miles in radius from proposed project facilities and covers 158,480 acres. Waters and 

wetlands occupy approximately 77 percent of the project study area; water bodies account for 19 percent 

of this total (GMT2 Final Supplemental EIS Table 3.3-1). The dominant wetland cover classes in the 

project study area include wet sedge meadow tundra (22.6 percent), tussock tundra (20.6 percent), and 

moist sedge-shrub tundra (16.4 percent).

Alternative A would result in placement of a gravel pad and road covering about 78 acres (see Table 2.3-2 

Final Supplemental EIS). Indirect impacts from gravel spray and (or) dust deposition evaluated by GIS as 

a 328-foot (100 m) impact zone surrounding gravel infrastructure may impact an additional 

approximately 688.6 acres of jurisdictional waters/wetlands of the United States. All direct and indirect 

impacts would be within potential wetlands. The impacts to vegetation and wetlands are characterized as 

long-term duration; the resource is considered important in context because wetlands are protected by 

legislation; and the geographic extent is considered local and covers only a small proportion of the 

northeastern NPR-A. Because virtually the entire area consists of wetlands, it would not be possible to 

produce the oil reserves on ConocoPhillips’s GMT2 leases without impacting wetlands. 

Wetlands impacts will be mitigated through the BLM lease stipulations and BMPs already applicable to 

the project, design features of Alternative A, and Supplemental BMPs adopted in this JROD. These 

include provisions relevant to ConocoPhillips’s proposal that protect the function and values of wetlands, 

including requirements and mitigating designs:

• waste management, spill prevention and response, and HazMat emergency contingency plans;

• winter travel and protection of soil, vegetation, and streams;

• facility design and requirements that permanent facilities minimize footprint and be reclaimed to

ensure eventual restoration of ecosystem function;

• extraction of gravel and construction of gravel roads, pads, and pipelines in winter using ice

roads, thus minimizing potential impacts to the tundra;

• road watering to help control dust;

• incorporation of the findings of fish surveys and hydrologic modeling into the design of proposed

culverts and subsequent monitoring of culverts and remedial measures based on this monitoring;

and,

• additional leak detection criteria.

Because of the protections identified in the GMT2 Final Supplemental EIS, the GMT2 Final 

Supplemental EIS determined that development and operation of ConocoPhillips’s project would be 

unlikely to significantly impact any wetland plant species or community, cause significant soil loss, or 

result in other than short-term and localized loss of water resources or water quality. Therefore, no 

13
significant impacts are expected that would affect public health, safety, and welfare through changes in 

the supply, quality, recharge or discharge, and pollution of water or, flood and storm hazards or 

sedimentation and erosion. 

This decision includes all practicable measures to minimize harm to wetlands when considering all 

technical, economic, environmental, and other pertinent factors. While Alternatives A and B are similar in 

terms of impacts to wetlands, Alternative A has a smaller gravel footprint than Alternative B. A reduction 

in impacts to hydrology under Alternative C may have resulted from the elimination of a road connection 

to the existing GMT1 pad. While this reduces some of the impacts to the surface, it creates other impacts, 

such as a larger gravel footprint than is required in alternatives with a gravel road. These alternatives 

would rely on air transportation and winter ice road transportation to GMT2. Regular ice road 

construction to these pads can result in impacts to the tundra. A lack of gravel road access to the existing 

Alpine facility would create a need for increased waste and chemical storage that enlarges the pad size 

and could delay spill response actions. Moreover, locating a road parallel to the pipeline facilitates 

pipeline leak detection and spill response, and provides access for any health and safety events at GMT2. 

Therefore, the BLM and the Corps finds that there is currently no practicable alternative to construction 

of the GMT2 project in wetlands and that all practicable measures to minimize harm to wetlands have 

been taken, given the technical, economic, and environmental factors that must be weighed. 

Floodplains (Executive Order 11988) 

Executive Order 11988 concerning the protection of floodplains requires an agency to provide leadership 

and to take action to minimize the impact of floods on human safety, health, and welfare, and to restore 

and preserve the natural and beneficial values served by floodplains in carrying out its responsibilities. In 

carrying out activities required by EO 11988, the agency has the following responsibilities: 

1. Evaluate the potential effects of any actions that may take place in a floodplain; 

2. Ensure that its planning programs and budget requests reflect consideration of flood hazards and 

floodplain management; and, 

3. Prescribe procedures to implement the policies and requirements of EO 11988. 

Additional requirements are as follows: 

4. Before taking an action, each agency shall determine whether the proposed action will occur in a 

floodplain and the evaluation required will be included in any environmental impact statement 

prepared under NEPA. 

5. If an agency has determined to, or proposes to, conduct, support, or allow an action to be located 

in a floodplain, the agency shall consider alternatives to avoid adverse effects and incompatible 

development in the floodplains. If the head of the agency finds that the only practicable 

alternative consistent with the law and with the policy set forth in this executive order requires 

siting in a floodplain, the agency shall, prior to taking action, 

a. design or modify its action in order to minimize potential harm to or within the 

floodplain, consistent with regulations, and, 

b. prepare documentation explaining why the action is proposed to be located in the 

floodplain. 

The long-term effects, both direct and cumulative, on floodplains of ConocoPhillips’s development on 

BLM-managed lands as approved in this JROD are expected to be minor, and would be mitigated to the 

14
greatest extent practicable. More than half of the project study area is located within the Tiŋmiaqsiġvik 

(Ublutuoch) River drainage basin, although the project study area is also located within the Fish Creek 

drainage basin, Judy Creek drainage basin, and the Colville River drainage basin. As with wetlands, total 

avoidance of floodplains is impossible due to the geography and hydrologic features of the project area.

This decision avoids and minimizes impacts to floodplains, including those of Tiŋmiaqsiġvik (Ublutuoch)

River and the Fish Creek, the largest streams within the GMT2 project study area. Culverts are considered 

for all water crossings along the GMT2 road. Culverts will be installed at regularly spaced intervals to 

mitigate the risk of sheet flow interruption and thermokarst. Final design of the culverts for the GMT2-

GMT1 road will also depend on breakup characteristics for those drainages that could affect the roads. 

The impacts of increased stream velocities through culverts during flooding events were addressed in the 

2004 ASDP EIS (See Section 4F.2.2.1). Constricting flows can result in increased stream velocities and a 

higher potential for ice jams, scour, and stream bank erosion. Impeding flows can result in a higher 

potential for bank overflows and floodplain inundation. Alternative A has the potential for long-term 

impacts to local water resources resulting from the placement of new infrastructure. Most impacts are 

related to changes in the drainage pattern, and to a lesser degree stream flow. There also would be shortterm, temporary impacts from ice infrastructure (e.g., roads and pads). However, the intensity of impacts 

is characterized as minor and of localized extent. 

The design of culverts along the GMT2 road will incorporate the findings of fish surveys and hydrologic 

modeling into their design. As part of this decision, ConocoPhillips will be required to undertake 

monitoring of culverts for the three summer seasons following fill placement in accordance with the 

Corps Special condition 5.b. 

Specific measures to protect water resources are provided in the 2013 NPR-A IAP/EIS, which include 

requirements that roads, pipelines, and water crossings be designed to maintain existing hydrology 

including during flood periods. Also, gravel roads, culverts, and bridges must be designed with erosion 

control mechanisms. In addition to BLM lease stipulations and BMPs, project activities that could impact 

water resources will be subject to Federal, State, and local permit requirements. Thus, the facilities 

authorized in this JROD will avoid impacts to floodplains to the maximum extent practicable and will 

have minimal to negligible impacts on the functions and values of floodplains. 

Environmental Justice (Executive Order 12898) 

Executive Order 12898 requires that Federal agencies identify and address, as appropriate, any 

disproportionately high and adverse human health or environmental effects of its programs, policies, and 

activities on minority populations and low-income populations. The GMT2 Final Supplemental EIS 

identified direct and indirect impacts that may affect the community of Nuiqsut, which meets the 

demographic characteristics to be qualified as a minority population. Negative impacts to subsistence that 

were considered in the finding of impacts for Environmental Justice include the project footprint’s direct 

and indirect impact to subsistence use areas, disruption to subsistence hunting activities caused by aircraft 

traffic, reduced access to and user avoidance of traditional subsistence use areas and reduced value of 

traditional subsistence use areas. Also, many residents identify the cumulative effects as the loss of 

traditional land and a sense of being surrounded by infrastructure. This context has substantially elevated 

the consequences of each subsequent development project. 

The pipeline and road between GMT2 and GMT1 could result in an adverse impact to subsistence hunting 

of caribou if the infrastructure were to disturb, displace, or obstruct the movement of caribou in such a 

way that the animals become substantially more difficult to harvest. However, use of the road by local 

resident to assist with subsistence harvests could help to counteract or alleviate these impacts. In the 

unlikely event of a large spill on BLM-managed land that affects, or is perceived by local residents as 

15
affecting, important subsistence resources, impacts would be high and adverse for residents of Nuiqsut. 

Negative sociocultural impacts associated with GMT2 include intra-community conflict, anxiety and 

social disruption related to the permitting process for development, perceived inadequacy of mitigation 

systems, and distress associated with disruptions to the Nuiqsut cultural landscape. Some residents 

identify the flaring of natural gas, the risk of a blowout, and the lack of a clear emergency response plan 

as environmental justice issues. 

Stipulations in the Federal leases and BMPs avoid or mitigate many of these impacts. Relevant 

stipulations include, but are not limited to, those that require ready access to spill cleanup materials, 

minimization of flights in the project area during the peak caribou hunting period, spill response training, 

the separation distance between roads and pipelines (reducing the potential of the combined facilities to 

obstruct caribou movement), and consultation with subsistence users. 

Alternative A and its existing mitigation measures and Supplemental BMPs contribute to avoiding or 

mitigating impacts from disturbance, displacement, or obstruction of caribou movement on BLMmanaged lands to the maximum extent practicable by design features and industry practices, including, 

but not limited to: 

• using a non-reflective finish on all pipelines;

• establishing speed limits, pull-outs, and caravanning requirements on the GMT2-GMT1 road;

and,

• minimizing helicopter flights during peak caribou harvest.

The question of whether environmental justice issues could potentially result from a project is highly 

sensitive to the history or circumstances of a particular community or population. The historical context 

within which environmental justice issues are considered for Nuiqsut includes the cumulative effects of 

oil development near the community. 

Native Alaskan Consultation 

Federally recognized tribes have a special, unique legal and political relationship with the Government of 

the United States as defined by the U.S. Constitution, treaties, statutes, court decisions, and EOs. These 

definitive authorities are also the basis for the Federal Government's obligation to acknowledge the status 

of federally recognized tribes in Alaska.

The BLM initiated government-to-government consultation and Alaska Native Corporation consultation 

processes as required by Presidential Executive Memorandums (April 29, 1994, and November 5, 2009), 

the Department of the Interior Policy on Consultation with Indian Tribes (Dec. 1, 2011), and the 

Department of the Interior Policy on Consultation with ANCSA Corporations (Aug. 10, 2012), with 

letters sent on August 1 2016 to the Native Village of Nuiqsut (NVN), Inupiat Community of the Arctic 

Slope (ICAS), Kuukpik Corporation, and ASRC, entities whose members could be substantially affected 

by the proposed development of GMT2. 

The BLM held government-to-government consultation meetings on a monthly basis with the NVN tribal 

council throughout the NEPA process. Consultation with the tribal council will continue throughout the 

life of the GMT2 project, or until the council no longer wishes to hold consultation meetings. Throughout 

the planning process, comments and issues brought forward through formal government-to-government 

consultation with the NVN tribal council focused on impacts to resources such as subsistence, public 

health, and air quality, appropriate mitigation measures for these impacts, and emergency response 

capabilities in the unlikely event of a blowout or large spill. The BLM engaged in regular consultation 

16
with Kuukpik Corporation and ASRC, primarily through meetings between Corporation representatives 

and BLM/DOI leadership.

Management Decisions by Other Agencies 

The GMT2 Supplemental EIS benefited from suggestions and careful review of the analysis in the 

Supplemental EIS by its cooperating agencies: NVN, ICAS, Corps, USFWS, US Environmental 

Protection Agency (EPA), US Bureau of Ocean Energy Management (BOEM), State of Alaska, and the 

North Slope Borough (NSB). Consultation also occurred during the Supplemental EIS process with 

subject matter experts at the USFWS, National Park Service, BOEM, EPA, and the State of Alaska 

Department of Environmental Conservation (ADEC) in accordance with the June 2011 “Memorandum of 

Understanding among the U.S. Department of Agriculture, U.S. Department of the Interior, and U.S. 

Environmental Protection Agency, Regarding Air Quality Analyses and Mitigation for Federal Oil and 

Gas Decisions through the National Environmental Policy Act Process” to model potential air quality 

impacts the GMT2 development project and to develop appropriate air quality protection measures. The 

BLM also consulted with the USFWS and NOAA Fisheries pursuant to the ESA. 

ConocoPhillips’s proposal is subject to approval by other Federal and State agencies, including many 

cooperating agencies on the GMT2 Final Supplemental EIS such as the North Slope Borough. The 

authorities of these agencies are described in Chapter 1 of the Final Supplemental EIS. 

17
ANILCA: SECTION 810 SUMMARY

The Alaska National Interest Lands Conservation Act (ANILCA) § 810(a) requires that a subsistence 

evaluation be completed for any Federal determination to “withdraw, reserve, lease or otherwise permit 

the use, occupancy or disposition of public lands.” ConocoPhillips’s proposed GMT2 Development 

Project encompasses lands that are owned by the Kuukpik Corporation and the BLM (Federal or public 

lands). The evaluations of the subsistence effects of each alternative only apply to those lands that are 

BLM-managed lands. The ANILCA also requires that this evaluation include findings on three specific 

issues:

• The effect of such use, occupancy, or disposition on subsistence uses and needs;

• The availability of other lands for the purpose sought to be achieved; and

• Other alternatives that reduce or eliminate the use, occupancy, or disposition of public lands

needed for subsistence purposes (16 U.S.C. 3120).

The following discussion summarizes the ANILCA § 810 evaluation for the decision in this JROD. The 

summary is based on the detailed ANILCA § 810 analysis in Appendix B of the GMT2 Final 

Supplemental EIS and tiers from the ANILCA § 810 analysis conducted for the ASDP EIS in 2004. The 

analysis and conclusions presented in the ANILCA § 810 evaluation in the GMT2 Final Supplemental 

EIS also applies to the decision in this JROD. 

Without the Cumulative Case: The effects of Alternative A, adopted in this JROD, fall above the level of 

significantly restricting subsistence use for the community of Nuiqsut due to impacts to caribou and 

furbearer availability; therefore, a positive determination to ANILCA § 810 is required. The GMT1-

GMT2 access road and aircraft traffic may alter late summer and fall movements of caribou in the vicinity 

of Nuiqsut. While the magnitude of the impact with respect to the Teshekpuk Caribou Herd as a whole 

would be small, it could be substantial given the significance of the portion of the herd that ranges close 

to Nuiqsut. Caribou movements could be altered through the life of the project, as high inter-annual 

variability and overall low use makes it unlikely that a caribou would encounter the road multiple times 

during its lifetime and become habituated to it. The extent of the impact could encompass important and 

easily accessible areas used by Nuiqsut hunters, namely along the Colville River and the area west of 

Nuiqsut and south of the proposed road. The basis for this finding relies heavily on the project’s 

proximity to this core subsistence use area. Current research and preliminary reports by subsistence users 

suggest that caribou availability could be impacted. The likelihood of the impact occurring is difficult to 

determine, given the compounding uncertainty associated with caribou’s reactions to roads, hunters’ 

response to changing resource distribution, and natural variation at multiple geographic scales. Wolf and 

wolverine avoidance of infrastructure is well documented, and it is likely that subsistence hunters 

targeting furbearers would need to relocate trap lines due to reduced availability of these resources in the 

vicinity of the GMT2 project areas.

With the Cumulative Case: The ANILCA § 810 evaluation concludes that the Cumulative Case may result 

in a significant restriction to subsistence uses for the community of Nuiqsut due to impacts to caribou and 

furbearer availability and access thereof, and that it may result in a significant restriction to subsistence 

uses for the communities of Utqiagvik, Atqasuk, and Anaktuvuk Pass due to impacts to terrestrial and 

marine subsistence resources and access. This finding requires a positive determination pursuant to 

ANILCA § 810. 

18
The ANILCA § 810 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 hearings in accordance with § 810(a)(1) and (2), 

and makes the three determinations required by § 810(a)(3)(A), (B), and (C). The BLM has found in this 

subsistence evaluation that all the alternatives considered in the GMT2 Final Supplemental EIS, except 

for the No Action alternative, may significantly restrict subsistence uses for the community of Nuiqsut. 

The subsistence evaluation for the cumulative case has also found that all alternatives, including the No 

Action alternative, may significantly restrict subsistence uses for the communities of Nuiqsut, Utqiagvik, 

Atqasuk, and Anaktuvuk Pass. Therefore, the BLM undertook the notice and hearing procedures required 

by ANILCA § 810(a)(1) and (2), as described above, and now must make the three determinations 

required by § 810(a)(3)(A), (B), and (C) and 16 U.S.C. 3120(a)(3)(A), (B), and (C). The BLM has 

determined that the Alternative (Alternative A) adopted in this JROD meets the following requirements 

(16 U.S.C. 3120(a)(3)(A), (B), and (C)) for Federal action that may result in a significant restriction on 

subsistence uses:

1. The significant restriction of subsistence uses is necessary, and consistent with sound

management principles for the utilization of the public lands.

The BLM drafted the GMT2 Supplemental EIS in response to ConocoPhillips’ applications to

develop and produce oil from leases in the Greater Mooses Tooth Unit, and to fulfill the BLM’s

responsibilities to manage these lands under authority of the NPRPA and the Federal Land Policy

and Management Act (FLPMA) while providing protections for specific habitats and site-specific

resources and uses identified and developed through a NEPA process. The GMT2 Supplemental

EIS will provide the opportunity to evaluate options, subject to appropriate conditions, to

construct the necessary infrastructure to produce oil from the Greater Mooses Tooth Unit.

The BLM considered multiple factors with regard to the proposed activity on public lands,

including the comments received during the public meetings and hearings, which stressed the

importance of facilitating Nuiqsut residents’ continued use of the project area and local

preferences for development scenarios that contribute the lowest increase in aircraft traffic. The

BLM determined that Alternative A best fulfills the purpose and need of the proposed action,

while incorporating protective measures that serve to minimize impacts to important subsistence

resources and use areas. Alternative A considers the necessity for economically feasible

development while providing protections to minimize impacts to subsistence resources and uses.

Under Alternative A, the lease stipulations and BMPs that accompany the alternative would be

the primary mitigation measures to reduce the impact of the proposed action on subsistence uses

and resources.

The BLM determined that the significant restriction that may occur under Alternative A, when

considered with all possible impacts of the cumulative case, is necessary, consistent with sound

management principles for the use of these public lands, and for the BLM to fulfill the

management goals of the NPR-A as directed by the 2013 NPR-A IAP/EIS, the NPRPA, and

FLPMA.

2. The proposed activity will involve the minimal amount of public lands necessary to accomplish

the purpose of such use, occupancy, or other disposition.

The BLM analyzed four alternatives. Alternative D (No Action) would involve the minimal

amount of public lands necessary, but it would not accomplish the purpose of the proposed action,

nor would it fulfill the management goals of the NPR-A as directed by the 2013 NPR-A IAP/EIS,

the NPRPA, or FLPMA. The federal lands that would be impacted are the same under

Alternatives A, B, and C, although physical footprints of each would vary. Alternative C would

19
involve the minimal amount of public lands necessary to accomplish the purpose of the proposed 

action, but it would not meet the requirement outlined in A.4.3. Alternative A would involve the 

minimal amount of public lands necessary to accomplish the purposes of the proposed action 

given that Alternative C does not qualify. Under Alternative B, the GMT1-GMT2 access road 

would be 1.8 miles longer than the road proposed under Alternative A. Therefore, alternative B 

would not involve the minimal amount of public lands necessary to accomplish the proposed 

action. 

Other lands managed by the BLM are too distant to access the Greater Mooses Tooth Unit

reservoir using current drilling technologies. Consideration of other lands, therefore, would not 

accomplish the purpose of the proposed action. 

3. Reasonable steps will be taken to minimize adverse impacts upon subsistence uses and resources

resulting from such actions.

The information acquired through analysis of impacts to subsistence, insight from public

meetings and ANILCA § 810 hearings, meetings with the NPR-A Subsistence Advisory Panel,

and consultation with tribal and local governments were used to analyze the impacts of

Alternatives A, B, C, and D. Several existing mitigation measures would minimize adverse

impacts to subsistence. In addition, ConocoPhillips proposes implementing various voluntary

policies and measures which will further minimize impacts to subsistence. These stipulations,

BMPs, and efforts are summarized herein, but are described in detail in the GMT2 Final

Supplemental EIS § 4.3.4.1, § 4.4.5.6, and Appendix J.

Existing stipulations and BMPs from the 2013 NPR-A IAP/EIS ROD that address subsistence

include measures to ensure the continued health of wildlife, fish, and subsistence resources. Many

of the measures established in the 2013 NPR-A IAP/EIS ROD are intended to ensure the

continued health of fish, wildlife, and subsistence resources. Measures to mitigate impacts to fish

are described in GMT2 Final Supplemental EIS § 4.3.2, those addressing impacts to birds are

described in § 4.3.3, and those addressing impacts to mammals are described in § 4.3.4.

Mitigation measures addressing impacts to water resources and vegetation are described in §

4.2.2 and § 4.3.1 respectively.

Measures to avoid conflict with subsistence users:

• E-1: All roads must be designed, constructed, maintained, and operated to create minimal

environmental impacts and to protect subsistence use and access to subsistence hunting

and fishing areas.

• E-2: Permanent oil and gas facilities, including roads, airstrips, and pipelines, are

prohibited upon or within 500 feet of fish-bearing water bodies.

• E-3: Causeways and docks are prohibited in river mouths or deltas. Artificial gravel

islands and bottom-founded structures are prohibited in river mouths, active stream

channels, or river deltas.

• E-7: Pipelines and roads shall be designed to allow the free movement of caribou and the

safe, unimpeded passage of the public while participating in subsistence activities.

• F-1: Permittee will ensure that aircraft used for permitted activities comply with the

guidelines outlined therein.

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• H-1: Permittee will consult directly with affected communities using the guidelines

outlined therein.

• H-2: Permittee will notify the local search and rescue organizations of proposed seismic

survey locations for that operation season, and will comply with the guidelines therein.

• H-3: Hunting and trapping by the permittee’s employees, agents, and contractors are

prohibited when persons are on “work status”.

• I-1: All personnel involved in oil and gas and related activities shall be provided

information concerning applicable stipulations, BMPs, standards, and specific types of

environmental, social, traditional, and cultural concerns that relate to the region. The

permittee shall ensure that all personnel involved in permitted activities shall attend an

orientation program at least once a year and will consist of the guidelines therein.

ConocoPhillips has implemented voluntary policies and measures to address impacts to 

subsistence under previous authorizations, and proposes similar policies during development and 

operation of the GMT2 site. These include incorporating vehicle pullouts into the design of the 

GMT1-GMT2 access road, which would facilitate egress from the road and access to lands west 

of Nuiqsut. ConocoPhillips consistently attempts to coordinate aircraft operations both internally 

and with other regional oil development companies, and to minimize flights when possible, 

specifically during peak hunting season. 

Given that these lease stipulations, BMPs, and voluntary policies directly protect or address 

subsistence resources and concerns, the BLM determines that any roaded alternative (i.e., 

Alternatives A or B) will include reasonable steps to minimize impacts upon subsistence uses and 

resources.

The BLM has determined that, after consideration of all alternatives, subsistence evaluations, and 

public hearings, such a significant restriction of subsistence uses is necessary, consistent with 

sound management principles for the utilization of this land, and that the selected alternative will 

involve the minimal amount of public lands necessary to accomplish Alternative A. Reasonable 

steps have and will be taken to minimize the adverse impacts upon subsistence uses and resources 

arising from this action. 

21
MITIGATION AND MONITORING

Stipulations and BMPs designed to protect the resources and uses on BLM-managed land were described 

in the 2013 NPR-A IAP/EIS ROD and listed in the GMT2 Final Supplemental EIS in Appendix J. All 

action alternatives incorporated ConocoPhillips’s existing lease stipulations for the Greater Mooses Tooth

Unit, as well as the BMPs in the 2013 NPR-A IAP/EIS ROD. As the GMT2 applicant and primary 

petroleum development company in the Nuiqsut area, ConocoPhillips continues to strive to mitigate 

impacts from flights in its exiting Alpine development field, and contributes financially and otherwise to 

subsistence support programs in the community. ConocoPhillips has also incorporated project design

features in a manner that reduces impacts to subsistence and other resources, detailed in Section 4.7 of the 

Final Supplemental EIS. In addition, this JROD adopts Supplemental BMPs as described in Appendix A. 

It has been determined that all practical means to avoid or minimize environmental harm from the project 

have been adopted in this JROD. 

Monitoring will be undertaken to determine the status of the various resources in the project area, to 

ensure compliance with and enforcement of stipulations, BMPs, and other decisions in this JROD, and to 

measure the effectiveness of protective measures. The 2013 NPR-A IAP/EIS ROD requires applicants to 

fund monitoring to evaluate the effectiveness of project designs and mitigation measures and thereby 

guide BLM’s adaptive management of the area. Additional studies and monitoring would not duplicate 

efforts already being performed by ConocoPhillips. Several monitoring measures, including aircraft data 

monitoring and monitoring measures for subsistence, have been adopted pursuant to the BLM’s existing 

monitoring authority per the 2013 NPR-A IAP/EIS ROD. 

22
PUBLIC INVOLVEMENT

The BLM considered public comments throughout the GMT2 Supplemental EIS planning process. The 

following list highlights major steps in the public involvement process. For more information on public 

involvement, see Chapter 5 of the GMT2 Final Supplemental EIS. 

Scoping: The BLM solicited public scoping comments for 60 days from July 29 through September 27, 

2016. The BLM received comments from private citizens, environmental organizations, and government 

agencies, including the NSB and the NVN. Scoping comments received after the scoping deadline were 

also considered in identifying the range of issues and additional mitigation measures addressed in the 

Supplemental EIS. 

Public Review of the GMT2 Draft Supplemental EIS: The comment period for the GMT2 Draft 

Supplemental EIS was open for 55 days, from March 23 through May 17, 2018. During the public 

comment process, the BLM received a total of 1,333 written communications. 

The BLM held public meetings during the comment period in four North Slope communities, plus

Anchorage, and Fairbanks. Pursuant to ANILCA § 810(a)(1) and (2), the BLM also conducted hearings in 

North Slope communities to gather comments regarding potential impacts to subsistence use resulting 

from the alternatives considered in the GMT2 Supplemental EIS. The public meetings in North Slope 

communities that were also ANILCA § 810 hearings are noted by asterisk. A list of the meetings and 

meeting dates are provided below. In order to capture all relevant comments, the entirety of the public 

meetings in North Slope communities were captured by a court reporter and reviewed for substantive 

comments.

• Monday, April 9: Utqiaġvik *

• Tuesday, April 10: Atqasuk*

• Thursday, April 12: Anaktuvuk Pass *

• Monday, April 16: Anchorage

• Tuesday, April 17: Fairbanks

• Monday, April 30: Nuiqsut*

Comments were received after publication of the Federal Register Notice and distribution of the GMT2 

Final Supplemental EIS on August 31, 2018, and prior to the issuance of the JROD on October 15, 2018. 

The comments came from ConocoPhillips, the EPA, and a coalition of environmental organizations. No 

comments identified any significant new circumstances or information bearing upon the proposed action 

or its impacts. The comments from ConocoPhillips and the EPA contained recommendations for the 

mitigation measures to be adopted and identified minor errors addressed in the errata sheet. Comments 

from the environmental coalition identified areas of the GMT2 Final Supplemental EIS that they felt were 

deficient. In reaching the decisions in this JROD, the BLM, and the Corps reviewed and fully considered 

all comments received. 

In addition to the above, the plan benefited from suggestions and careful review of the analysis in the 

Supplemental EIS by eight cooperating agencies: the North Slope Borough, State of Alaska, Inupiat 

Community of the Arctic Slope, Native Village of Nuiqsut, USFWS, BOEM, USACE, and EPA. 

23
FINAL AGENCY ACTION 

Approval of Authorizations 

It is my decision to approve the development by ConocoPhillips Alaska, Inc., of the Greater Mooses 

Tooth Two (GMT2) Project on SLM-managed lands as described in Alternative A of the GMT2 Final 

Supplemental EIS subject to the tenns, conditions, stipulations, and environmental protection measures 

developed by the DOI. as reflected in this Joint Record of Decision. 

Approved by: 

c:::5J,,..,t. � 

Ted A. Murphy 

Acting State Director 

Bureau of Land Management, Alaska 

Assistant Secretary Approval 

I 

I hereby approve this decision. My approval of this decision constitutes the final decision of the DOI and, 

in accordance with the regulations at 43 CFR 4.410{a)(3), is not subject to appeal under Departmental 

regulations at 43 CFR Part 4 . 

. cph R. Balash 

Assistant Secretary 

Land and Minerals Management, DOI 

Corps Approval 

I find that the issuance of the U.S. Army Corps of Engineers' pennit, as described by regulations published 

in 33 CFR Parts 320 through 332, with the scope of work as described in this document, is based on a 

thorough analysis and evaluation of all issues set forth in this Joint Record of Decision. There are no lessenvironmentally damaging, practicable alternatives available to ConocoPhillips Alaska, Inc., to construct 

the GMT2 Project than that under Alternative A. The issuance of this pem1it is consistent with National 

Policy, statutes, and administrative directives; and on balance, issuance of a Corps' pemlit to construct the 

GMT2 Project is not contrary t the public interest. As explained above, all practicable means to avoid 

and/or minimize wironme t harm from the selected, permitted altemative have been adopted and 

required byte and condi s of this permit. 

David S. Hobbie 

Chief, Regional Regulatory Division, Alaska District 

24
APPENDIX A

SUPPLEMENTAL BEST 

MANAGEMENT PRACTICES

Greater Mooses Tooth 2 Oil and Gas 

Development Project

Joint Record of Decision and Permit Evaluation

Bureau of Land Management

U.S. Army Corps of Engineers

October 2018

APPENDIX A: SUPPLEMENTAL BEST MANAGEMENT PRACTICES

The following list contains the final language of the new supplemental mitigation measures as adopted for 

the GMT2 project. The measures are organized by resource and numbered sequentially. These measures 

will only apply to the GMT2 project (in addition to existing Lease Stipulations and BMPs). However, 

some of the new mitigation measures amend existing BMPs from the 2013 NPR-A IAP/EIS ROD for the 

purposes of GMT2 by adding new paragraphs to them. The Glossary of the GMT2 Final Supplemental 

EIS contains applicable definitions. In some cases, language may have changed from the GMT2 Final 

Supplemental EIS language, and such measures are noted with an asterisk (*). Rationale for these changes 

can be found in Appendix B of this JROD, Modifications and Clarifications. 

The permittee may propose a deviation from these requirements/standards as described above in the 

Decision section. If experience or additional study indicate that a requirement/standard is not achieving or 

is unlikely to achieve its protective objective, or would be less effective than the use of more recently 

proven technology or techniques, the BLM may allow other measures to meet the objective. This would 

be accomplished at the activity-level permitting stage and under the terms of the stipulation or best 

management practice deviation process outlined in the 2013 NPR-A IAP/EIS ROD. 

Atmospheric Environment 

Supplemental Best Management Practice 1: Implementation of Air Quality Monitoring Data Review (new 

subparagraph to BMP A-10)* 

Objective: Address concerns in the local community regarding oversight of air quality.

Requirement/Standard: Permittee will begin providing quarterly air quality monitoring reports and an 

annual trends analysis report on data collected at the Nuiqsut air quality monitoring station. Quarterly 

reports will begin with data collected during the first quarter of calendar year 2019, and the first trends 

analysis report will begin with data collected during calendar year 2019. The permittee will also provide a 

summary of any measured National Ambient Air Quality Standards (NAAQS) exceedance event (if an 

event occurs) at the Nuiqsut air quality monitoring station to the BLM within a reasonable amount of time 

after the event occurs. The format and exact content of the reports will be negotiated with permittee by 

January 30, 2019. 

Potential Benefits and Residual/Unavoidable Impacts: As part of the GMT1 ROD, permittee is 

required to provide funding for monitoring to identify and address concerns related to air quality in the 

Nuiqsut area. Reports from the monitoring station in Nuiqsut are required to be provided to the BLM, the 

State, NSB, and the local community and tribal government pursuant to BMP A-10(h). Members of the 

public have expressed concern over air quality in the project vicinity. Implementing a technical review of 

the monitoring results provides certainty for the BLM and the community that air quality is being 

carefully considered and will help identify any potential project-related impacts that would cause 

exceedances of NAAQS, or fail to protect public health.

Supplemental Best Management Practice 2: Use of Diesel Engines for GMT2 Project* 

Objective: Reduce air quality impacts from diesel engines

Requirement/Standard: Stationary equipment utilizing steady state diesel-fired engines will be 

replaced with engines that meet EPA’s current standards for the manufacture of new diesel engines when 

they have met their useful lifespan and are ready to be replaced. This requirement only applies to 
equipment owned by the permittee in situations where EPA’s new engine standards are technically 

feasible for Arctic operations. 

Potential Benefits and Residual/Unavoidable Impacts: For the emission inventories for Alternative 

A, B, and C, Tier 2 standards were assumed for all diesel-fired engines except for the routine operations 

emergency generator which was noted by ConocoPhillips to be a Tier 4 unit. Tier 4 engines have lower 

emission standards for NOx and PM, therefore resulting in less impacts from those pollutants. Impacts to 

air quality related values (AQRVs; visibility and atmospheric deposition) at Federal Class II areas could 

also be reduced.

Fish, Birds and Terrestrial Mammals 

Supplemental Best Management Practice 3: Ensure Compliance with BMP E-6 

Objective: Ensure that water flowing out of Lake M9925 and moving toward Blackfish Creek is not 

impeded by the road and that upstream fish passage by ninespine stickleback is possible, in accordance 

with requirements laid out in BMP E-6. 

Requirement/Standard: Two weeks before placing culverts, submit to the BLM the technical drawings 

for this area that show the planned placement of culverts as well as the road line and culvert points 

overlain on high-resolution imagery in GIS. 

Potential Benefits and Residual/Unavoidable Impacts: This additional measure will enable the BLM to 

further evaluate pre-construction plans to increase the likelihood that the objective of BMP E-6 is met.

Supplemental Best Management Practice 4: Roadkill Monitoring System for Birds and Wildlife 

Objective: Implement a reporting system to monitor roadkill of birds and other wildlife on transportation 

routes.

Requirement/Standard: The permittee shall provide an annual report to the BLM Arctic District 

Manager and BLM Alaska Wildlife Program Lead reporting roadkill of birds and mammals to help the 

BLM to determine whether preventative measures on vehicle collisions are effective.

Potential Benefits and Residual/Unavoidable Impacts: Knowledge about bird and mammal mortality 

due to vehicle traffic will help managers to develop methods to reduce collision rates with vehicles.

Supplemental Best Management Practice 5: Directional Facility Lighting 

Objective: To prevent episodic bird collisions with infrastructure, especially during migration and 

inclement weather.

Requirement/Standard: All facility external lighting, during all months of the year, shall be designed to 

direct artificial exterior lighting inward and downward or be fitted with shields to reduce reflectivity in 

clouds and fog conditions, unless otherwise required by the Federal Aviation Administration. 

Potential Benefits and Residual/Unavoidable Impacts: Best Management Practice E-10 contained in 

the 2013 NPR-A IAP ROD contains very similar language to this proposed mitigation measure with that 

exception that E-10 is in effect between August 1 and October 31 only. In their comments the USFWS 

pointed out that “Lighted facilities (drill rigs and buildings) can cause episodic bird collisions with 

infrastructure, especially during migration and inclement weather” which is why this new mitigation 

measure removes the timing limitations and extends the BMP to being applicable year round. The benefit 

for including this new mitigation measure is to mitigate the collision risk to birds year round. 
Supplemental Best Management Practice 6: Reporting Requirements for Sightings of Marine Mammals* 

Objective: To comply with reporting requirements outlined in the letter of concurrence from the National 

Marine Fisheries Service (NMFS) dated July 20, 2018. 

Requirement/Standard: Permittee will submit an annual report of all marine mammal observations 

within 250 meters of project activities to NMFS for all project years in which an ice road across the 

Colville River is built to support construction of the GMT2 Project. The report will be submitted within 

one month of the close of the ice road season or July 1, whichever is earlier, and will include: 

• Number of marine mammals observed (by species) within 250 meters of project vehicles, 

equipment, personnel or infrastructure

• Minimum distance between each observed marine mammal and project vehicles, equipment, 

personnel or infrastructure.

• Behavior of observed marine mammals.

• Numbers of marine mammals observed.

• Distribution of marine mammals around the action area (including within 250 meters of project 

vehicles, equipment, personnel or infrastructure).

• Project activities that were occurring within 250 meters of marine mammals at the time each 

marine mammal was observed.

If no marine mammals are observed during the ice road season, permittee will submit a signed letter 

documenting no observations. 

Take is not authorized. If a listed marine mammal is observed to have been harassed, harmed, wounded or 

killed as a result of project activities, the take must be reported within one business day to NMFS and the 

BLM. If ConocoPhillips personnel observe an injured, sick, or dead marine mammal, they will notify the 

NMFS Alaska Region Marine Mammal Stranding Network at 877-925-7333. The ConocoPhillips 

personnel will take photos and record observational data that will be beneficial to the agency, including 

date/time, location, number of animals, event type (e.g., entanglement, dead, floating), species, and any 

behavior if the animal is alive.

Potential Benefits and Residual/Unavoidable Impacts: The BLM and NMFS do not expect that any 

marine mammals will be observed within the project area during the ice road season; however, if marine 

mammals are observed, it would be extremely beneficial for management agencies to know. 

Supplemental Best Management Practice 7: (Adapted from BMP K-5.e.1 and 2): Minimize Potential 

Ground Vehicle Traffic Disturbance of Caribou 

Objective: Minimize disturbance and hindrance of caribou, or alteration of caribou movements, by 

vehicle traffic on the GMT1-GMT2 gravel road during the oestrid fly-relief and fall-migration seasons.

Requirement/Standard: The following ground vehicle traffic restrictions shall apply to permitted 

activities using the GMT1-GMT2 road in the time periods indicated: 

1. Along the GMT1-GMT2 road, from July 16 through November 30, traffic speed shall not exceed 

15 miles per hour when caribou are within 0.5 mile of the road. Additional strategies may include 

limiting trips or using convoys, to the extent practicable. 
2. The permittee or a contractor shall observe caribou movement from July 16 through November 

30 to assess whether or not caribou may be trying to cross the road. Based on the assessment, 

traffic will be stopped temporarily if it is determined that 10 or more caribou are trying to cross 

the road. Sections of road will be evacuated whenever an attempted crossing by a large number of 

caribou appears to be imminent. 

3. The permittee shall submit, prior to road construction, a vehicle use plan that considers these and 

any other appropriate mitigation measures. Adjustments will be required by the Authorized 

Officer if resulting disturbance is determined to be unacceptable.

4. The permittee will consult with the Authorized Officer every three years to determine if the 

seasonal restrictions, and restrictions described in paragraphs 1 and 2 above are still appropriate 

given possible changes in migration patterns. In light of ongoing caribou monitoring, the 

Authorized Officer may modify the restrictions as appropriate to achieve the objectives of this 

measure.

Potential Benefits and Residual/Unavoidable Impacts: Limiting vehicle traffic during caribou 

migration will help reduce impacts and disturbance to caribou. Unavoidable impacts would continue due 

to the presence of the road and continued traffic. 

Sociocultural Systems 

Supplemental Best Management Practice 8: Nuiqsut Area Environmental Information Dissemination* 

Objective: Make data and summary reports derived from local studies easily accessible. 

Requirements/Standard: The permittee will submit reports related to required monitoring studies that 

pertain to the environment within 50 miles of Nuiqsut on BLM-managed land within 2 months of 

finalization. Reports will be submitted to the North Slope Science Initiative (NSSI), who will host a 

specific webpage for Nuiqsut Area Environmental Information where this information will be posted. 

The permittee will notify residents every two months of the availability of new reports or other 

information distributed to NSSI using social media or other means designed for broad dissemination. 

Notifications will include a link to the new documents. If no documents or information are posted in a 

given two month period, no notification is required. The permittee will continue to print copies of reports 

and distribute them to Nuiqsut entities (including, but not restricted to, Trapper School, KSOP, Kuukpik, 

NVN, and City of Nuiqsut). 

At a minimum, the permittee will include all reports related to required monitoring studies that pertain to 

the environment within 50 miles of Nuiqsut on BLM-managed land. The permittee is encouraged to make

other research relevant to the community (research on non-federal land, etc.) accessible in the same 

manner. Environmental studies previously conducted to support GMT2 within 50 miles of Nuiqsut on 

BLM-managed land will be submitted to NSSI by January 2019. 

Potential Benefits and Residual/Unavoidable Impacts: Much of the data used by federal agencies 

conducting NEPA analyses is either information derived from studies and research paid for by the 

applicant, or conducted by agencies (i.e., federal, state and local government entities). There is no 

systematic way that residents can review these studies. This measure would help mitigate confusion over 

which studies are being conducted and what the findings are. 

Although not a part of the BLM requirement/standard, local entities have requested support to engage 

their own contractor who would be responsible for working with local entities and the school to 

disseminate information on the studies and to prepare research summaries that effectively communicate 

research and data in a manner that is understood by residents. 
Subsistence

Supplemental Best Management Practice 9: GMT2 Memorandum of Road Access Agreement* 

Objective: Ensure that residents will have the right to use the GMT2 Access Road throughout the life of 

the project and that residents are aware of the safety policies regarding use of project-associated roads for 

subsistence activities. Ensure that oilfield employees understand the road use agreement and local 

residents’ right to use the road. 

Requirement/Standard: The permittee will provide the community of Nuiqsut with concise policies 

regarding use of the roads associated with the project and hunting prohibitions, if any, along the roads and 

near project components. Permittee will ensure that the road use guidelines are disseminated throughout 

the community. The permittee will also include a presentation on the road use policy in its employee 

orientation, will ensure that sub-contractors have the policy for their employee orientation, and will post 

the policy on the road itself. The policy should also be provided to the BLM for their records. 

Potential Benefits and Residual/Unavoidable Impacts: Clear policies regarding use of project roads for 

subsistence activities will likely reduce misunderstandings about whether and to what extent local 

harvesters can use and/or hunt from the road. Residents will be more likely to use project roads if they are 

well informed about company policies and security restrictions. 

Supplemental Best Management Practice 10: Suspend Non-essential Helicopter Traffic during Peak 

Caribou Hunting Season* 

Objective: To reduce the impacts of helicopter traffic on Nuiqsut caribou hunters and provide 

management consistency between GMT2 and GMT1. 

Requirement/Standard: In consultation with the City of Nuiqsut, the North Slope Borough Department 

of Planning, Native Village of Nuiqsut, Kuukpik Corporation, and the Kuukpik Subsistence Oversight 

Panel, Inc., the BLM will establish an approximately one-month-long period during peak caribou hunting 

when non-essential helicopter flights will be suspended within a predetermined distance of rivers that 

have been documented as caribou subsistence use areas, or limit helicopter traffic during this time to 

established flyways. 

• Current suspension dates for peak caribou harvest are July 15-August 15. Suspension dates may 

be revised every three years upon review of peak caribou season. 

• Ongoing (multi-year, already planned) scientific/environmental studies that depend on access to 

study sites that are already planned could continue if there is no alternative access to sites.

Potential Benefits and Residual/Unavoidable Impacts: Reducing helicopter traffic or limiting the 

geographic area affected by helicopter traffic would reduce the incidence of conflicts between GMT2-

related helicopter traffic and Nuiqsut subsistence activities. However, other operators on the North Slope 

may continue to fly during the suspension period. 

Supplemental Best Management Practice 11: Consultation Regarding Aircraft Communication Protocols 

Objective: Ensure communication protocols for helicopter and fixed-wing air traffic by the permittee are 

adequate in addressing Nuiqsut concerns about the impacts of air traffic on their hunting activities and 

provide management consistency between GMT2 and GMT1. 

Requirement/Standard: In consultation with local hunters and local organizations, the permittee will 

continue to facilitate, improve, and expand communication protocols to inform subsistence users of daily 

flight patterns and identify potential conflict areas during peak hunting times. This consultation should 

include efforts to advertise these communication protocols within the community so that Nuiqsut 

subsistence harvesters are aware of them. The consultation results should be documented, distributed to 
the BLM and other stakeholders, and clearly identify actions to be implemented based on the 

consultation. This mitigation measure requires the continuance of an existing program; the protocols in 

place for GMT1 will be followed for GMT2. 

Potential Benefits and Residual/Unavoidable Impacts: Strong communication protocols with the 

community of Nuiqsut regarding the timing, altitude, and location of air traffic should reduce the 

frequency of these impacts on subsistence users. However, such protocols will not remove impacts of air 

traffic altogether.

Supplemental Best Management Practice 12: Aircraft Data Reporting Requirements* 

Objective: Gather information on aircraft flight paths associated with the GMT2 development.

Requirement/Standard: The permittee will track and record aircraft flight data and provide quarterly 

reports of that data to the BLM in a manner that facilitates meaningful analysis of flight activities. The 

reports will highlight all flights that represent deviations from BMP F-1 and include explanations for any 

deviations. 

The format and exact content of the quarterly flight reports will be negotiated between permittee and the 

BLM Arctic District Manager by December 31, 2018. 

Background, Potential Benefits, and Residual/Unavoidable Impacts: Improved tracking of flight 

paths, altitudes and purposes will enable the BLM to better analyze the effects of GMT2-associated 

aircraft activity. FAA research, as described in Section 4.1.2.5, has found that people are less disturbed by 

helicopter traffic when they understand the reasons for it. The reports will improve the BLM’s and 

industry’s ability to convey to residents the reasons for GMT2-associated aircraft traffic. 

Supplemental Best Management Practice 13: Reduce Flights by Utilizing Unmanned Aerial Vehicles* 

Objective: To reduce the impacts of aircraft traffic on Nuiqsut subsistence activities.

Requirement/Standard: The permittee will begin to employ unmanned aerial vehicles to conduct 

monitoring activities that otherwise require helicopters (i.e., pipeline inspections, studies, and other 

appropriate activities) where feasible. The permittee will consult with the authorized agency every three 

years to determine feasibility of this technology and appropriate monitoring activities for its use. 

Background, Potential Benefits and Residual/Unavoidable Impacts: Much of the ecological 

monitoring required of lessees and permittees is supported by/requested by local residents, but there is 

less understanding and little support for the number of helicopter flights that are required to conduct those 

activities. The potential for using unmanned aerial vehicles for baseline monitoring was discussed at the 

September 2013 NPR-A Subsistence Advisory Panel meeting when a representative of Shell Oil 

announced that that company was experimenting with using them. The Subsistence Advisory Panel was 

supportive of their use to decrease impacts from helicopters. Unmanned aerial vehicles have been utilized 

for oil field studies at Prudhoe Bay, and have the potential for use in the NPR-A. Residents of Nuiqsut 

have requested that the latest technology be used for such studies as soon as and to the greatest extent 

possible in order to alleviate the high number of aircraft flights. The BLM would not have the authority to 

implement this best management practice on lands that are not BLM-managed in the Nuiqsut area, where 

much of the disturbance from aircraft occurs.

Supplemental Best Management Practice 14: Subsistence Monitoring Studies* 

Objective Monitor the impacts of GMT2 development on subsistence patterns, harvests, and associated 

subsistence activities for the community of Nuiqsut. Establish current baseline conditions from which to 

evaluate impacts of GMT2 and effectiveness of BLM mitigation.
Requirement/Standard: 

1. Permittee will provide for a one time mapping study covering all subsistence resources to 

document current subsistence use patterns for Nuiqsut. 

2. The permittee will monitor, through the life of the project, changes in subsistence activities in the 

community of Nuiqsut. The permittee will provide for annual research and monitoring to 

document changes to subsistence patterns and harvest levels resulting from the proposed project. 

Studies commissioned as part of the GMT2 development will be designed with community input and will 

identify changes resulting from the proposed project as well as, at a minimum, monitor impacts to 

caribou, fish, and bird harvests. Monitoring reports, aggregated harvest data, and overall use areas by 

resource will be made available to local residents and the public via the standards established by 

Supplemental BMP 9: Nuiqsut Area Environmental Information Dissemination. 

Researchers will employ adaptive research and monitoring techniques, including flexibility to refine 

monitoring questions based on study findings on a year-to-year basis. Adaptive monitoring will include 

researcher discretion to establish or reformulate local resource expert panels. 

The methodology for the monitoring studies will be approved by the North Slope Borough Department of 

Wildlife Management (NSB DWM) and the NSB DWM will conduct annual initial peer review of the 

monitoring reports. The draft report will also be provided to a local resource panel (e.g., the Nuiqsut 

Caribou Panel) for review and comment, and the permittee may provide comments after initial peer 

review. The contractor will incorporate comments from all entities before releasing a final report.

Potential Benefits and Residual/Unavoidable Impacts: The 2010 BOEM mapping study for all 

subsistence resources (SRB&A 2010a) established valuable baseline data from which to evaluate 

subsistence impacts from oil and gas development. The 2010 mapping study is based on data collected 

1995-2006, thus the data is 12 years old and should not be used as a baseline to monitor impacts of 

GMT2, which will begin construction in 2019. The one time mapping study will include all subsistence

species. 

A subsistence monitoring study would help identify the impacts of GMT2-related activities on Nuiqsut 

subsistence activities. The nine years of data from the Nuiqsut subsistence caribou monitoring project 

(SRB&A 2010a-2018) is a valuable resource for evaluating impacts. The permittee may expand upon the 

Nuiqsut Caribou Subsistence Monitoring Project (initiated in 2008 and proposed for a total length of 10 

years) to include additional resources (e.g., birds, fish) and to document both impacts related to GMT2 

and cumulative impacts. The monitoring program would continue on an annual basis until 2024 and on a 

biennial basis after that. The Subsistence Fishery Monitoring on the Colville River project may be 

expanded to include Fish Creek and extended on a biennial basis. After 2033, the Authorized Officer and 

the permittee may agree to adjust the focus and duration of these subsistence monitoring studies. The 

results of an expanded subsistence monitoring project could be used to develop future mitigation 

measures aimed at lessening the impacts of GMT2 on Nuiqsut harvesters. Subsistence monitoring studies

will continue throughout the life of the project, or until the Authorized Officer determines such studies are 

no longer necessary or prudent.

Supplemental Best Management Practice 15: Design of Road Pullouts and Access Ramps along the 

GMT2 Road* 

Objective: To ensure the GMT2 road pullouts are constructed in advantageous locations and that ramps 

constructed to provide ATV access to and from ground surface are designed to allow maximum benefit to 

local users and to protect tundra damage. 
Requirement/Standard: Prior to construction of the GMT2 Access Road, the permittee will gather input 

from the Native Village of Nuiqsut (NVN) tribal government and the Kuukpik Subsistence Oversight 

Panel (KSOP) regarding the location and design of the three road pullouts and associated access ramps. 

Input from NVN and KSOP will be used by the permittee to ensure that the pullouts are properly located 

along the road to maximize access for subsistence users. Permittee will post the design and location of the 

ramps publicly and provide a mechanism for local community members to comment on the location of the 

ramps. The access ramps should be long and wide enough to allow safe ingress and egress to and from the 

road and/or pullout. In addition, the design of the ramps should account for multi-season subsistence-use 

while minimizing impacts to the adjacent ground surface. This may involve “hardening” of the tundra 

around the bottom of the ramps with geo-block or other acceptable methods. 

Input derived from NVN, KSOP and community members will be provided to the BLM. Concurrence 

from KSOP on final location and design of the pullouts and ramps shall be obtained by the permittee. 

At least once a year for three years after construction, the permittee will hold a public meeting in Nuiqsut 

to discuss use of the access road, pullouts, and ramps to solicit information on their use and any 

improvements that could be made to address health, safety, and access concerns. Permittee may 

incorporate this meeting into another planned public meeting. Permittee will notify the BLM at least two 

weeks prior to the meeting and inform them of the date, time and location of the meeting and will provide 

the BLM with the meeting materials and a summary of the comments received. Information gathered at 

these meetings will be provided to the BLM and KSOP, along with any planned improvements. 

Potential Benefits and Residual/Unavoidable Impacts: Allowing potential users of the pullouts and 

access ramps a role in ramp location and design will ensure that the ramps provide a locally accepted 

mechanism for leaving the road surface and accessing tundra that is safe, feasible, and can minimize 

impacts to subsistence access and aid in search and rescue missions. Regular meetings with local resident 

who use the road will facilitate improved design features or other suggestions that can be incorporated to 

make use of the road, pullouts, and ramps safer and more effective for users and prevent tundra damage. 

Supplemental Best Management Practice 16: Annual Community Ice Road Information* 

Objective: Provide the community of Nuiqsut with information on area ice roads on an annual basis 

Requirement/Standard: Before ice road construction begins, the permittee and contractors associated 

with ice road construction will hold a community meeting to describe the routes and relevant information 

on all ice roads that will be constructed within the GMT2 project area. At the meeting, the permittee will 

distribute copies of maps of that winter’s ice roads. The permittee will also submit the map for publication 

to NSSI and provide notice of availability of the map and a link to the online map on local social media 

(i.e., the Nuisagmiut Facebook group). Permittee will notify the BLM at least two weeks prior to the 

meeting and inform them of the date, time and location of the meeting, and will provide the BLM with the 

meeting materials and a summary of the comments received. 

Potential Benefits and Residual/Unavoidable Impacts: Community members have no official system 

for learning about where ice roads are being constructed each winter and whether there are any relevant 

restrictions on those roads. Many winter hunters use the roads to facilitate access to hunting areas, and 

some may need to plan the locations for trap lines and other subsistence activities that could be affected 

by ice roads. This measure only applies to ice roads within the GMT2 project area, which does not 

adequately address the needs of the community. The permittee is therefore encouraged to include 

information on all ice roads within 50 miles of Nuiqsut. 
Public Health 

Supplemental Best Management Practice 17: Minimize Undue Idling of all Vehicles 

Objective: Reduce air emissions and protect human health.

Requirement/Standard: To the extent practicable, engines of rolling stock (such as pick-up trucks, vans, 

buses, other trucks and trailers, and heavy machinery) used for oil and gas operations will be powered off 

when not in active use. 

Potential Benefits and Residual/Unavoidable Impacts: Prohibiting unnecessary vehicle idling will 

reduce emissions associated with vehicle use, such as carbon monoxide, fine particulate matter, and 

volatile organic compounds. Additionally, this measure will decrease noise impacts associated with the 

GMT2 Project. Projected emissions associated with GMT2, including vehicle exhaust emissions, are 

subject to the regulatory oversight of the Environmental Protection Agency through emission standards 

for engines and vehicles. 

Supplemental Best Management Practice 18: Accident Prevention: Additional Requirement to BMP C-3* 

Objective: Prevent accidents due to snowmachine operators trying to cross ice road bridges after they 

have been removed, breached or slotted in accordance with BMP C-3. 

Requirement/Standard: For ice roads supporting the GMT2 Project, crossing of waterway courses shall 

be made using a low-angle approach. Crossings that are reinforced with additional snow or ice (“bridges”) 

shall be removed, breached or slotted before spring break-up. Trails leading to the snow or ice bridge 

shall be clearly marked on either side of the crossing once it has been removed, breached or slotted. 

Applicant will coordinate with local entities (Kuukpik, NVN, City of Nuiqsut) to establish the best way to 

mark and communicate to Nuiqsut residents when the ice bridges are no longer passable. 

Potential Benefits and Residual/Unavoidable Impacts: Clearly marking trails on either side of a 

crossing that has been removed, breached or slotted will ensure that local users as well as contractors are 

aware that the trail has been compromised and that the crossing should not be used, thereby minimizing 

the likelihood of an accident.

Solid Waste and Hazardous Materials Spills 

Supplemental Best Management Practice 19: Trash Removal and Anti-Littering Campaign 

Objective: Prevent unnecessary or undue degradation of the land.

Requirement/Standard: All solid waste and industry-derived trash originating from permitted activities 

is required to be properly containerized while on site, or removed from the area of operation/activity. 

Objects that have the potential to be left or forgotten (such as duck ponds, containments, or sorbent 

material caches) shall be clearly marked with the name of the company using the object.

The permittee will solicit ideas from the community of Nuiqsut to assist with addressing regular trash 

removal and inadvertent littering (including such things as ice-roads delineation markers, construction 

detritus, etc.) in order to ensure or adopt cost-effective methods that also minimize other identified 

impacts, such as those associated with helicopter use. 

Potential Benefits and Residual/Unavoidable Impacts: Clearly marking movable objects associated 

with industrial development with the name of the company who utilized them will instill a greater sense 

of responsibility in employees in being good neighbors and ensuring the objects are not left or forgotten. 

In addition, it will also allow the permittee, the BLM, and local residents to track and assess the 

effectiveness of workers or contractors in following authorization requirements. By working with the 
community to identify new ideas or suggestions for the removal and handling of trash, the permittee may 

be able to save money while building effective partnerships. 

Supplemental Best Management Practice 20: Oil Spill Response Equipment (new subparagraph to BMP 

A-3) 

Objective: Minimize pollution through effective hazardous-materials contingency planning.

Requirement/Standard: Oil spill response equipment for use in winter conditions must meet the 

following standards: 

a. Equipment must be designed to be effective in Arctic conditions. 

b. Mechanisms must be available to prevent the freezing of response equipment (including the 

equipment used for storing, transferring, and treating recovered fluids) and/or to de-ice it.

Potential Benefits and Residual/Unavoidable Impacts: Potential benefits of these added measures 

above current protections include additional protection for vegetation, wetlands, and other surface 

resources by ensuring response equipment is operational under extreme weather conditions and other 

limiting factors such as ice and snow conditions.

Supplemental Best Management Practice 21: Leak Detection Criteria (new subparagraph to BMP E-4) 

Objective: Implement leak detection systems for GMT2 facilities. 

Requirement/Standard: To the extent practicable, the permittee will provide a specific description of the 

leak detections systems installed on all lines described in the development plan. The descriptions could be 

an addendum to the Alpine C-Plan or a stand-alone document. Monitoring would be via remote continual 

monitoring (e.g., camera or FLIR) of water crossings, or daily on-site visual inspections. The spill 

prevention section of the Alpine C-Plan must contain criteria to prevent and detect slow leaks.

Potential Benefits and Residual/Unavoidable Impacts: Automated and visual on-site leak inspections 

would reduce the extent of spills.
APPENDIX B 

MODIFICATIONS AND 

CLARIFICATIONS

Greater Mooses Tooth 2 Oil and Gas 

Development Project

Joint Record of Decision and Permit Evaluation

Bureau of Land Management

U.S. Army Corps of Engineers

October 2018

APPENDIX B: MODIFICATIONS AND CLARIFICATIONS

The following describes clarifications and minor modifications that the BLM has made in this decision 

and Supplemental BMPs presented in the GMT2 Final Supplemental EIS. (Modifications that have been 

made to correct sentence structure, grammatical errors, sub-paragraph letters, and other non-substantive 

errors are not discussed below.)

• Supplemental BMP #1: This BMP was modified to change the annual reporting requirement to an 

initial report within one year of the JROD date and an updated report in the event of expansion or 

replacement of fuel burning equipment. 

• Supplemental BMP #2: This BMP was modified to adjust the air quality data report format, 

content and timing to better meet the BMP objective. 

• Supplemental BMP #3: This BMP was modified to allow for the technical difficulties of operating

Tier 4 final diesel engines for highly variable speed engines on the North Slope. The exhaust fluid 

system's solution (catalyst diesel exhaust fluid) for highly variable speed engines freezes at 14 

degrees Fahrenheit, making it difficult to regenerate properly in Arctic conditions. This mitigation 

measure was adjusted to apply only to steady state diesel fired engines. 

• Supplemental BMP #7: This BMP was not included in the GMT2 Final Supplemental EIS and 

was included in the JROD to address requirements outlined by the National Marine Fisheries 

Service in their letter of concurrence pursuant to consultation under Section 7 of the Endangered 

Species Act. 

• Supplemental BMP #8: This BMP was modified to match the requirements of the GMT1 ROD to 

ensure that requirements for road use between the Alpine CPF and the GMT2 pad are consistent 

for the CD5-GMT1 road and the GMT1-GMT2 road. 

• Supplemental BMP #9: This BMP was modified to require the permittee to submit studies and 

reports to the North Slope Science Initiative rather than maintain a separate website managed by 

the permittee. The objective of the BMP is better met by having all studies, including government 

funded studies, available in a central location maintained by a government entity. 

• Supplemental BMP #11: This BMP was modified to include the most current dates of the peak 

caribou harvest for the community of Nuiqsut. 

• Supplemental BMP #13: This BMP was modified to provide the BLM flexibility to review and 

adjust the report format and content to better meet the objective of the BMP. 

• Supplemental BMP #14: This BMP was modified to include the words “when feasible” to match 

language from the GMT1 ROD. 

• Supplemental BMP #15: This BMP was modified to clarify the requirements of the monitoring 

studies and the process to be used in reviewing and publishing them. 

• Supplemental BMP #16: This BMP was modified to require the permittee to consult with the 

Native Village of Nuiqsut and the Kuukpik Subsistence Oversight Panel, and dropped the 

requirement to hold a public meeting with a 30-day comment period. 
• Supplemental BMP #17: This BMP was modified to require the permittee to notify the BLM prior 

to the meeting and provide a copy of the presentation and summary of comments received. 

• Supplemental BMP #19: This BMP was modified to clarify that it only applies to ice roads 

supporting the GMT2 Project. 
APPENDIX C 

POTENTIAL MITIGATION 

MEASURES NOT ADOPTED

Greater Mooses Tooth 2 Oil and Gas 

Development Project

Joint Record of Decision and Permit Evaluation

Bureau of Land Management

U.S. Army Corps of Engineers

October 2018

APPENDIX C: POTENTIAL NEW MITIGATION MEASURES NOT ADOPTED

The decision in this JROD includes all practicable means to avoid or minimize environmental harm 

consistent with the purpose and need of the action, including potential impacts associated with cumulative 

impacts. Pursuant to 40 CFR 1505.2(c), the BLM provides the following explanations for not adopting 

the following mitigation measures considered in the GMT2 Final Supplemental EIS as Supplemental 

BMPs. All proposed mitigation measures can be found in Appendix Q of the GMT2 Final Supplemental 

EIS. 

• Potential Mitigation Measure 1 for Soils and Permafrost: This potential mitigation measure would 

have required the permittee to conduct a soil survey that meets the requirements of the Alaska 

Natural Resources Conservation Service Level II soil survey within a 1,000-meter radius of all 

planned gravel infrastructure. This measure is designed to provide the BLM with better data for 

evaluating impacts of future projects; it does not mitigate impacts of GMT2 or provide a 

mechanism to monitor the effectiveness of existing mitigation measures, so it was not adopted. 

• Potential Mitigation Measure 1 for Air Quality: This potential mitigation measure would have 

required the permittee to construct a heated building for vehicle storage in the winter to prevent 

vehicles running 24/7. This measure is not being adopted; potential impacts from GMT2 were 

estimated to be well under the NAAQS at Nuiqsut and the potential benefits of the measure were 

uncertain. More analysis would be required to determine the tradeoffs between emissions 

generated in heating a building vs. emissions generated from running vehicles. 

• Potential Mitigation Measure 3 for Air Quality: This potential mitigation measure would have 

required the permittee to use alternatives to diesel fuel (electrification, natural gas, or gasoline) to 

the extent practicable to reduce the emission of air pollutants. This measure is not being adopted 

because the viability of equipment utilizing these fuel sources is not proven, and the BLM does 

not have the expertise to evaluate the permittee’s determination of practicability. In addition, the 

EPA and Alaska Department of Environmental Quality already regulate best available control 

technology for mobile and stationary sources. 

• Potential Mitigation Measure 5 for Air Quality: This potential mitigation measure would have 

required electrification of all equipment used for GMT2 to the greatest extent practicable. This 

measure is not being adopted because it is too vague to enforce, and making it more prescriptive 

would not be technologically feasible. Electric vehicles are not yet engineered to perform in 

Arctic conditions. 

• Potential Mitigation Measure 6 for Air Quality: This potential mitigation measure would have 

required near real time monitoring of air pollutants at the GMT2 pad and in the community of 

Nuiqsut. It is not being adopted because monitoring and enforcement of air quality standards is 

the purview of the State of Alaska Department of Environmental Conservation. 

• Potential Mitigation Measure 7 for Air Quality: This potential mitigation measure would have 

required the permittee to set up an air quality monitoring station at the GMT2 pad. It is not being 

adopted because it does not mitigate impacts of the GMT2 Project and does not provide 

information about the effectiveness of existing or proposed mitigation measures. 

• Potential Mitigation Measure 9 for Air Quality: This potential mitigation measure would have 

required the use of selective and non-selective catalytic reduction devices for engines, heaters and 

other combustion engines. This measure is not being adopted because selective catalytic 
reduction devices are not technically feasible in the Arctic environment, and it also replicates the 

objectives of the ADEC regulations governing minor air permits. 

• Potential Mitigation Measure 10 for Air Quality: This potential mitigation measure would have 

required the permittee to flare or capture natural gas emitted during hydraulic fracturing and 

pigging operations. This measure is not being adopted because it is not technically feasible to 

flare or capture 100 percent of natural gas during pigging operations, and hydraulic fracturing 

operations are already regulated under the EPA’s 2016 New Source Performance Standards. 

• Potential Mitigation Measure 11 for Air Quality: This potential mitigation measure would have 

required the use of low bleed or no bleed pneumatic devices to reduce the emissions of methane. 

This mitigation is not being adopted because the GMT2 Project will use instrument air rather than 

natural gas as the actuation source for pneumatic devices. 

• Potential Mitigation Measure 1 for Vegetation and Wetlands: This potential mitigation measure 

would have required the permittee to consult with the BLM prior to abandonment and 

reclamation of any portion of the GMT2 Project. This mitigation measure was not adopted 

because it replicates existing regulations governing well abandonment. 

• Potential Mitigation Measure 3 for Birds: This potential mitigation measure would have required 

a 3:1 side slope and perimeter berm during excavation on the ASRC pit. This measure is not 

being adopted because the BLM has no authority to enforce this requirement. The Best 

Management Practices in the NPR-A Integrated Activity Plan only apply to BLM-managed land. 

• Locally Requested Potential Mitigation Measures for Sociocultural Systems: These potential 

mitigation measures would have required the permittee to provide funding for the following 

community services: building a heritage center, cultural and educational programs, administrative 

and technical support for city government, a drug rehabilitation program, a science center, job 

training programs, and housing development. Compensatory mitigation of this type is prohibited

under the BLM’s current guidance, and these measures are related to the impacts of development 

broadly, rather than the impacts of the GMT2 Project in particular. 

• Locally Requested Potential Mitigation Measures for Sociocultural Systems: Search and Rescue 

Funding: This potential mitigation measure would have required the permittee to contribute funds 

to upgrade search and rescue equipment and to increase search and rescue response capabilities in 

Nuiqsut. Although the construction of the GMT1-GMT2 road will facilitate travel further afield 

into the NPR-A and could put additional burdens on local search and rescue in the event of an 

accident, the BLM’s guidance on compensatory mitigation does not allow monetary 

compensation of this nature.

• Locally Requested Potential Mitigation Measures for Sociocultural Systems: A BLM Field 

Office: This potential mitigation measure would have required the BLM to establish a BLM Field 

Office in Nuiqsut staffed by a local who is charged with inspection and enforcement authority on 

behalf of the federal government. This measure is not being adopted because the federal hiring 

and budget process do not allow these decisions to be made in conjunction with a specific project. 

• Locally Requested Potential Mitigation Measures for Sociocultural Systems: Postpone Approval 

of GMT2 Project: This potential mitigation measure would have required the BLM to postpone 

approval of the GMT2 Project until the GMT1 Project was in operation and its effects studied. 

This measure is not being adopted because the BLM is required by Onshore Order 1 to process 

permit applications in a timely manner when they receive them. 
• Potential Mitigation Measure 8 for Subsistence: This potential mitigation measure would have 

required the permittee to develop a Subsistence User Monitoring Plan, which would be approved 

by the Nuiqsut Trilateral groups. The plan would identify subsistence indicators to be monitored 

through the life of the GMT2 Project and would provide a mechanism for adaptive management 

to respond to identified impacts. This measure is not being adopted because there is no way to 

distinguish and adapt to GMT2 specific impacts. 

• Potential Mitigation Measure 9 for Subsistence: This potential mitigation measure would have 

prohibited airboat use for the GMT2 Project. This mitigation measure is not being adopted 

because there are no components of the GMT2 Project that would require airboats. 

• Potential Mitigation Measure 2 for Public Health: This potential mitigation measure would have 

required the permittee to conduct a public health monitoring for the GMT2 Project. This measure 

is not being adopted because public health monitoring is the purview of the State of Alaska and 

North Slope Borough, and would require handling of sensitive information protected under the 

Health Insurance Portability and Accountability Act (HIPPA). 

• Potential Mitigation Measure 3 for Public Health: This potential mitigation measure would have 

required water quality monitoring be conducted by the permittee. Drinking water quality 

protection and monitoring is the purview of the State of Alaska Department of Environmental 

Conservation. 

• Potential Mitigation Measure 2 for Solid Waste and Hazardous Materials: This potential 

mitigation measure would have required the three phase pipeline carrying oil, water and gas from 

GMT2 to the Alpine CPF use the same leak detection technology as sales quality crude pipelines. 

This mitigation measure is not being adopted because it is not technically feasible. Pipeline 

standards are also regulated by the State of Alaska. 

• Potential Mitigation Measure 3 for Solid Waste and Hazardous Materials: This potential 

mitigation measure would have required fuel and hazardous material storage containers with a 

capacity greater than 660 gallons to use impermeable linings and diking capable of containing 

110 percent of the containers’ capacity. This measure is not being adopted because the EPA 

regulations governing fuel and hazardous material storage accomplish the same objective. 

• Potential Mitigation Measure 5 for Solid Waste and Hazardous Materials: This potential 

mitigation measure would have required the permittee to coordinate their design criteria with the 

BLM to ensure that it was sufficient to withstand Arctic conditions. This mitigation measure is 

not being adopted because State of Alaska regulations and other BLM regulations accomplish the 

same objective.

• Potential Mitigation Measure 7 for Solid Waste and Hazardous Materials: This potential 

mitigation measure would have required the development of an industrial disaster response plan 

for the community of Nuiqsut. This mitigation measure duplicates on ongoing process to develop 

a Small Community Emergency Response Plans (SCERP) for the community of Nuiqsut. 

• Potential Mitigation Measure 8 for Solid Waste and Hazardous Materials: This potential 

mitigation measure would have required installation of HEPA and carbon air filters in schools and 

public buildings. This measure is not being required because it does not directly address the 

impacts of GMT2; it is designed to mitigate the impacts of development generally. 

APPENDIX D 

CORPS DETERMINATION

Greater Mooses Tooth 2 Oil and Gas 

Development Project

Joint Record of Decision and Permit Evaluation

Bureau of Land Management

U.S. Army Corps of Engineers

October 2018

APPENDIX D: CORPS DETERMINATION

ATTACHMENT D1

D.1 RESPONSE TO COMMENTS ON CORPS PUBLIC NOTICE POA-2015-486 

The Corps received comments from four entities during the Corps’ 45-day public comment period, March 

23, 2018 -- May 7, 2018. An additional entity provided comments shortly after the close of the comment 

period, and the Corps considered those comments as well. The Corps received no requests for public 

meetings or extension of the comment period. Comments determined substantive are identified below, 

with responses from the Corps. 

D1.1 Alaska Department of Natural Resources, Office of Project Management and 

Permitting 

Comment: Has the US Army Corps of Engineers (Alaska District) determined whether compensatory 

mitigation is required under the 404(b)(1) guidelines, NEPA, or its analysis of the Public Interest Review 

factors?

Corps Response: Extensive avoidance and minimization efforts have been incorporated, as 

project modifications, into the proposed GMT2 project. The Corps has determined that mitigation 

in the form of avoidance and minimization measures are sufficient and compensatory mitigation 

is not required to offset unavoidable impacts to aquatic resources for the GMT2 project. Analysis

and conclusions are provided in the 404(b)(1) guidelines, Public Interest Review, appropriate 

sections of the JROD and GMT2 Final Supplemental EIS, as well as the 404 permit application 

and associated documents. 

Comment: Because there are no known opportunities for wetlands restoration in the same 10-digit HUC, 

OPMP supports investigating potential mitigation projects in the adjacent 10-digit HUC and recommends 

that the Alaska District consider the conscientious effort of the applicant to adopt a watershed-based 

approach in identifying and proposing a compensatory mitigation project that also benefits the potentially 

affected community of Nuiqsut and offsets impacts associated with previous development activities.

Corps Response: The Corps acknowledges the general difficulty in identifying practicable 

compensatory mitigation opportunities on many parts of the Arctic Coastal Plain, and as a 

programmatic issue, we will continue to encourage the identification of compensatory mitigation 

opportunities for project proposals when required. However, as provided in 33 CFR 320.4 (r), 

mitigation can be added to DA permits at the Applicant’s request. The applicant has requested 

that voluntary mitigation be added as a special conditions to the DA permit. The applicant 

requested mitigation plan is included as Attachment D5. 

Comment: The Alaska Department of Natural Resources (DNR) is conducting a desktop-level evaluation 

of known restoration, to include re-establishment and rehabilitation, and enhancement opportunities on 

DNR lands. We acknowledge that there are few to no potential mitigation projects on DNR lands in many 

watersheds on the North Slope, based on our anecdotal understanding of the Alaska District’s current 

position on what constitutes appropriate compensatory mitigation. The regulatory agencies and other 

commenting parties might be better enabled to provide substantive comments on the availability of 

compensatory mitigation projects for GMT2, if the Alaska District were to publish a Special Public 

Notice, Regulatory Guidance Letter, or some other description of what screening criteria are applied to 

potential compensatory mitigation projects, generally.
Corps Response: The Corps appreciates and acknowledges this comment and will continue to 

explore ideas such as this. This is a general regulatory program issue and not resolvable here prior 

to the GMT2 permit decision.

D1.2 Environmental Protection Agency

The EPA’s letter largely provides a history of the project, summation of applicable regulations, and 

recommendation of certain functional assessment methods in regard to the applicant’s voluntary 

compensatory mitigation plan. Avoidance and minimization measures for this project are extensive and 

individual and cumulative impacts to aquatic resources are minimal within the proposed project area; 

therefore the Corps determined compensatory mitigation was not required for the GMT2 project (see 

information and analyses in the 404(b)(1) guidelines, Public Interest Review, appropriate sections of the 

JROD and GMT2 Final Supplemental EIS, as well as the 404 permit application and associated 

documents). As provided in 33 CFR 320.4 (r), mitigation can be added to DA permits at the Applicant’s 

request, which has occurred. The Applicant’s voluntary compensatory mitigation plan is included as 

Attachment D5 of the JROD.

D1.3 Native Village of Nuiqsut 

Comment: The Corps has not met with, nor engaged with, the NVN in a meaningful way. No

representatives from the Corps attended the community meeting on the GMT2 Draft Supplemental 

EIS held in Nuiqsut on April 30, and the Corps has not held any other meetings with the community 

on the project.

Corps Response: The Corps is a Cooperating Agency to the BLM, which is the Lead Federal 

Agency. The BLM held a community meeting in Nuiqsut and coordinated with NVN frequently 

during the Government-to-Government (G2G) consultation process. NVN, as a Cooperating 

Agency, participated with the Corps in multiple Cooperating Agency meetings. The NVN did not 

request additional meetings with the Corps. 

Comment: The Corps should not issue the 404 permit for the GMT2 project. We believe, that like with 

GMT1 and other development projects in the region, GMT2 will have significant negative effects on our 

community. The area where ConocoPhillips proposes to place GMT2's road, pipeline, and pads are 

frequently used for subsistence purposes. We are already experiencing negative impacts from existing 

development in the region and are feeling the effects from infrastructure and development activities 

circling our community. It is not in the public interest for the Corps to allow this project. 

Corps Response: The Corps has noted the comment and believes the information contained in 

the GMT2 Final Supplemental EIS and JROD fully addresses this issue. We acknowledge that the 

NVN impacts are of a different scale than the overall definition of “public”. Based upon the 

information discussed in the PIR section of this JROD (Attachment D3), the Corps finds the 

project to be in the public interest. 

Comment: There are also additional, significant projects like Willow on the horizon. ConocoPhillips is 

moving forward with the permitting process for that project. The Corps should not permit GMT2 until 

after it has additional information on the table related to Willow. That development is likely to tie into 

GMT2 and significantly expand the impacts to our community. There may be other options and 

alternatives to GMT2 that cannot be considered if GMT2 is permitted in isolation instead of in a way that 

takes the full scale of development into consideration. It is not in the public interest for the Corps to 

permit this project at this time.
Corps Response: The Corps has noted the comment and believes the information contained in 

the GMT2 Final Supplemental EIS and the JROD fully addresses this issue. Based upon the 

findings found at in Attachment D3 of the GMT2 JROD, the Corps finds the project is in the 

public interest. 

D1.4 Alaska Wilderness League, Center for Biological Diversity, Defenders of Wildlife, Northern Alaska 

Environmental Center, Sierra Club, and The Wilderness Society 

Comment: The project does not meet the Section 404 Guidelines because it is not in the public interest 

and the Corps does not have sufficient information to determine if the proposal is the Least 

Environmentally Damaging Practicable Alternative. 

Corps Response: Compliance with the 404 (b)(1) Guidelines and the public interest review 

determination are discussed at Section D2 of the JROD.

Comment: Commenters are deeply concerned about the Corps’ premature release of the GMT2 permit 

for public comment. 

Corps Response: The Alaska District (Corps) attempts to issue the public notice as close as 

possible to the Notice of Availability (NOA) of a given Draft EIS, to provide additional 

information for evaluation and comment. The public notice contained sufficient information as 

required by regulation. The 45-day comment period was 15 days longer than typical public notice 

comment periods. Additional information needed to inform the Corps’ decision making was 

adequately provided for in the GMT2 Final Supplemental EIS. 

Comment: The Corps should not issue the permit for GMT2 at this time because it cannot fully assess 

whether the proposal is the LEDPA. 

Corps Response: The GMT2 Final Supplemental EIS, the JROD, and other referenced 

information are sufficient for an adequate comparison of alternatives and a LEDPA determination. 

Comment: The Corps should not issue the permit for GMT2 at this time because it cannot fully assess 

whether the proposal is the LEDPA. In January 2017, ConocoPhillips announced a significant new 

discovery within the Greater Mooses Tooth Unit at Willow, which is located just west of the GMT2

project.

Corps Response: Like the BLM, the Corps has concluded that although the Willow development 

may use GMT2 and Alpine infrastructure to the maximum extent possible, this project has 

independent utility from GMT2 and is not considered a connected action under NEPA. The 

Willow find is sufficiently large that even in the absence of a road connection between GMT2 and 

GMT1, the Willow project could be developed and operated independently. Accordingly, an 

appropriate analysis and determination of a LEDPA for GMT2 can be made independently of 

such an analysis for a future development such as Willow.

Comment: Suspending issuance of the GMT2 permit at this time would also be consistent with the 

Corps’ obligation to consider the public interest in reviewing this project.

Corps Response: The Corps finds that there is sufficient information in the GMT2 Final 

Supplemental EIS for an appropriate analysis of public interest review factors. Based upon the 

information found in Attachment D3 of this JROD, the Corps finds the project is not contrary to 

the public interest.
Comment: The Corps should require that Conoco Phillips adopt further mitigation and design measures 

to address the significant safety concerns likely to result from both heavy industrial use and community 

use of the road.

Corps Response: Safety was considered and addressed as a Public Interest factor in Section D3 

of the JROD. However, the Corps does not have the regulatory authority to require mitigation and 

design measures specific to roadway and vehicle operation.

Comment: The Corps should analyze the potential impacts of climate change on each of the alternatives 

to determine how that alternative should be designed or how mitigation measures should be incorporated 

into that alternative to address the potential impacts from climate change in a region that is experiencing 

the effects of climate change first-hand. 

Corps Response: The proposed activities within the Corps Federal control and responsibility 

would result in a negligible release of greenhouse gases into the atmosphere when compared to 

global greenhouse gas emissions. Greenhouse gas emissions have been shown to contribute to 

climate change Aquatic resources can be sources and/or sinks of greenhouse gases. For instance, 

some aquatic resources sequester carbon dioxide whereas others release methane; therefore, 

authorized impacts to aquatic resources can result in either an increase or decrease in atmospheric 

greenhouse gas. These impacts are considered de minimis. Greenhouse gas emissions associated 

with the Corps federal action may also occur from the combustion of fossil fuels associated with 

the operation of construction equipment, increases in traffic, etc. The Corps has no authority to 

regulate emissions that result from the combustion of fossil fuels. These are subject to federal 

regulations under the Clean Air Act and/or the Corporate Average Fuel Economy (CAFE) 

Program. Greenhouse gas emissions from the Corps action have been weighed against national 

goals of energy independence, national security, and economic development and determined not 

contrary to the public interest. Further information on climate change can be found in Section 

3.2.4 of the GMT2 Final Supplemental EIS.

Comment: The GMT2 project is not in the public interest. The project involves significant, unresolved 

conflicts as to resource use and will result in major adverse impacts to subsistence uses and other values. 

The GMT2 project will extend existing infrastructure directly into the heart of one of Nuiqsut’s primary 

subsistence use areas.

Corps Response: The Corps has determined that the project is not contrary to the public interest, 

based upon the analysis of public interest review factors. See Public Interest Review at section D3 

of the JROD, including subsistence at Section D3.4.1. 

Comment: The GMT2 Draft Supplemental EIS for this project does not adequately account for the 

potential impacts from the gravel mining activities associated with the GMT2 project.

Corps Response: The gravel source for the project, the existing ASRC mine, was evaluated and 

permitted under Corps permit POA-1996-869-M11. The proposed GMT2 development would 

only use approximately 35 acres or 7.5 percent of the recent Phase 3 expansion of the ASRC mine 

under this permit. Further discussion of the gravel mine is found in the GMT2 Final Supplemental 

EIS and the Public Interest Review at section D3 of the JROD. 

D1.5 Kuukpik Corporation 

Kuukpik provided 35 pages of comments to both the Draft Supplemental EIS and the Corps 404 Public 

Notice in one combined letter. The majority of these comments were determined to not be substantive to 

the Corps’ 404 analyses (many of these were responded to by the BLM in Volume 4 of the GMT2 Final 
Supplemental EIS) or similar to comments previously provided and responded to above. Substantive 

comments to our evaluation are provided here. 

Comment: An oil industry project that doesn't factor warming trends into its design is highly likely to face

real (and costly) problems later when the project hasto be updated, expanded, orretro-fitted with design

components that should have been identified during theNEPA process. Such omissions alsomean that

stakeholders(including the Corps in itseffort todetermine the Least Environmentally Damaging Practicable

Alternative (LEDPA)) would not be getting an accurate description of potential impacts and consequences of 

the project. 

Corps Response: The proposed activities within the Corps’ Federal control and responsibility 

likely will result in a negligible release of greenhouse gases into the atmosphere when compared 

to global greenhouse gas emissions. Greenhouse gas emissions have been shown to contribute to 

climate change. Aquatic resources can be sources and/or sinks of greenhouse gases. For instance, 

some aquatic resources sequester carbon dioxide whereas others release methane; therefore, 

authorized impacts to aquatic resources can result in either an increase or decrease in atmospheric

greenhouse gas. These impacts are considered de minimis. Greenhouse gas emissions associated 

with the Corps federal action may also occur from the combustion of fossil fuels associated with 

the operation of construction equipment, increases in traffic, etc. The Corps has no authority to 

regulate emissions that result from the combustion of fossil fuels. These are subject to federal 

regulations under the Clean Air Act and/or the Corporate Average Fuel Economy (CAFE) 

Program. Greenhouse gas emissions from the Corps action have been weighed against national 

goals of energy independence, national security, and economic development and determined not 

contrary to the public interest. Further information on climate change can be found in Section 

3.2.4 of the GMT2 Final Supplemental EIS. 

Comment: A prime example is the evolving understanding of how gravel roads and pads may need to be 

designed to accommodate warming temperatures. Less than a year ago, the Corps of Engineers 

concluded in at least one instance that pads only 35 miles away from GMT2 would need to be about 30-

35 percent thicker than previously constructed (6.4 feet deep instead of the usual 5 feet) in order to

prevent the pads from excessively and unevenly settling into the tundra, which could damage the 

structures and equipment on those pads.

Corps Response: In the applicant’s response to GMT2 public comments, dated August 3, 2018, 

ConocoPhillips responds to a similar comment regarding road thickness: “There is no identified 

need to design and build the roads thicker than the proposed 5 feet minimum, which is sufficient 

for the level and type of traffic expected on the GMT2 road. At the Kuparuk River Unit, where 

drilling rigs are moved at all times of the year, a road specification of 6.5 feet of gravel can be 

desirable to reduce potential for road rutting after spring and late summer rig moves, when

conditions are typically wet. At GMT2, in contrast, rig moves are planned to occur during winter, 

and the 5-foot minimum gravel thickness specification is sufficient.” The Corps does not have 

any design requirements in regard to permafrost conditions. In general, the applicant is 

responsible for the engineering of their projects. 
ATTACHMENT D2

Evaluation of the Discharge of Dredge and Fill Material 

in accordance with the 404(B)(1) Guidelines

(40 CFR 230, Subparts B through H)

The Department of the Army (DA) permit application evaluation requires compliance with the U.S. 

Environmental Protection Agency’s (EPA) Section 404(b)(1) Guidelines (40 CFR 230). The GMT2 Final 

Supplemental EIS contains appropriate analysis of all factors within the Guidelines, except as 

supplemented herein as specifically needed to comply with the Guidelines. 

D2.1 COMPLIANCE WITH THE GUIDELINES (40 CFR 230, Subpart B) 

D2.1.1 Restrictions on Discharge (40 CFR 230.10) 

D2.1.1.1 (40 CFR 230.10(a)) 

The Corps finds that the basic purpose of the GMT2 Project is not water dependent, but that practicable 

alternatives that do not impact waters of the U.S. (WOUS) and / or special aquatic sites (including 

wetlands) do not exist based on the constraints of geography and technology. 

As described in detail in Chapter 2 of the GMT2 Final Supplemental EIS, three action alternatives and a 

no action alternative were identified and described in detail. These four alternatives are summarized on 

page 1 of this document.

An alternative is practicable if it is available and capable of being done after taking into consideration 

cost, existing technology, and logistics in light of the overall project purpose. The Corps determined that 

Alternatives A, B, and C are practicable because these alternatives are believed to be available and can be 

accomplished from a cost, existing technology, and logistics standpoint. 

The No Action Alternative, Alternative D, did not meet the overall project purpose and need, and was not 

carried further for additional analysis by the Corps. 

Environmental Analysis of Practicable Alternatives

Mapping, classification and description of wetland types in the project area is provided in Section 3.3.1 of 

the GMT2 Final Supplemental EIS. Additionally, a wetland delineation and aquatic site assessment was 

prepared by ABR on behalf of the applicant and submitted as part of the Corps 404 permit application. 

Alternative A, Alternative B, and Alternative C would have very similar impacts and only minor 

differences, both direct and indirect, to the same types of WOUS when evaluated on a per-acre basis. The 

key differentiating factor between the three alternatives is the overall acreage of direct impacts (i.e. total 

gravel footprint) between the alternatives (GMT2 Final Supplemental EIS, Sections 4.3.1.4 and 2.9, Table 

14). 

Direct impacts to aquatic resources for each alternative is synonymous with total gravel footprint for this 

project. Alternative A has a total gravel footprint on WOUS of 78 acres, Alternative B has a total gravel 

footprint on WOUS of 87.2 acres, and Alternative C has a total gravel footprint on WOUS of 92 acres. 

Alternative A is identified in Section 4.2.1.1 of the GMT2 Final Supplemental EIS as being the least 

impactful of the action alternatives. 
When comparison of alternatives would not result in discernable or identifiable differences in impacts to 

the aquatic ecosystem, those alternatives may be dismissed from further analysis. With the discernable 

difference of impacts to WOUS between alternatives being total gravel footprint, Alternatives B and C are 

dismissed from further analysis. Alternative A, with the smallest overall acreage of both direct and 

indirect impacts, is carried further for additional analysis to determine compliance with the Guidelines. 

D2.1.1.2 40 CFR 230.10(b) 

No discharge of dredged or fill material shall be permitted if it:

1. Violates any applicable state water quality standard.

The state water quality agency, Alaska Department of Environmental Conservation (ADEC), is 

responsible for issuing or denying a Certificate of Reasonable Assurance for placement of the fill 

material. ADEC issued a Certificate of Reasonable Assurance for Alternative A of the project on 

September 11, 2018. 

2. Violates toxic effluent standards or prohibitions under Section 307 of the Clean Water Act. 

The fill material would come from a local source gravel mine known to be free of human or 

natural pollution. 

3. Jeopardizes the continued existence of any species listed as endangered or threatened under the 

Endangered Species Act of 1973, or their critical habitat. 

The USFWS issued a Biological Opinion BO for Alternative A of the project to both the Corps 

and BLM (Action Agencies) on September 21, 2018 and concluded the project is not likely to 

jeopardize the continued existence of any these species, nor is it likely to destroy or adversely 

modify critical habitat. 

4. Violates any requirement imposed by the Department of Commerce to protect marine sanctuaries 

under Title II of the Marine Protection, Research, and Sanctuaries Act of 1972. 

There are no marine sanctuaries in the proposed project area.

D2.1.1.3 40 CFR 230.10(c)

Except as provided under CWA Section 404(b)(2), no discharge of dredged or fill material shall be 

permitted that will cause or contribute to significant degradation of WOUS. Findings of significant 

degradation related to the proposed discharge shall be based upon appropriate factual determinations, 

evaluations, and tests required by Subparts B and C, after consideration of Subparts C through F. The 

discharge shall not be permitted if it:

1. Causes significant adverse effects through pollutants on human health or welfare, municipal 

water supplies, plankton, fish, shellfish, wildlife, and special aquatic sites. 

These factors for the proposed action have been thoroughly evaluated. See discussion in sections 

D2.5.1–D2.5.4, below. 

2. Causes significant adverse effects through pollutants on life stages of aquatic life and other 

wildlife dependent on aquatic ecosystems. 

See discussion in sections D2.1.2.5, D2.1.2.7, and D.21.2.8 below. 
3. Causes significant adverse effects through pollutants on aquatic ecosystem diversity, productivity, 

and stability to the loss of fish and wildlife habitat or loss of the capacity of a wetland to 

assimilate nutrients, purify water, or reduce wave energy.

See discussion in section D2.2 below. 

4. Causes significant adverse effects through pollutants on recreational, aesthetic, and economic 

values.

See discussion in sections D2.5.1-D2.5.4, below. 

D2.1.1.4 40 CFR 230.10(d)

Except as provided under CWA Section 404(b)(2), no discharge of dredged or fill material shall be 

permitted unless appropriate and practicable steps have been taken that will minimize potential adverse 

impacts of the discharge on the aquatic ecosystem.

Such steps are identified in 40 CFR 230, Subpart H (Actions to Minimize Adverse Effects), discussed 

below in section D2.7.

D2.1.2 Factual Determinations (40 CFR 230.11)

The USACE will determine the potential short-term or long-term effects of a proposed discharge of 

dredged or fill material on the physical, chemical, and biological components of the aquatic environment 

in light of subparts C through F of the Guidelines. Such factual determinations will be used by the 

USACE in making findings of compliance or non-compliance with the restrictions on discharge per 40 

CFR 230.10 (see section D2.1.1 above). The evaluation and testing procedures described in 40 CFR 

230.60 and 40 CFR 230.61 of subpart G (see section D2.6 below) shall be used as necessary to make the 

USACE’s determination.

Sections D2 1.2.1-D2.1.2.8 below present information on the nature and degree of the effects of the 

proposed discharge on the aquatic environment as presented in the GMT2 Final Supplemental EIS and 

information submitted and evaluated as part of the Corps 404 permit application. Measures to mitigate 

potential effects are discussed in section D2.7, below.

D2.1.2.1 PHYSICAL SUBSTRATE DETERMINATIONS (40 CFR 230.11[a])

Section 3.2.1 of the GMT2 Final Supplemental EIS, Terrestrial Environment, describes the existing 

substrate under the proposed project. Section 4.2.1.1 of the GMT2 Final Supplemental EIS, Physiography 

and Geomorphology/Soils and Permafrost, evaluates impacts of the proposed project on the physical 

substrate.

The proposed project would place clean fill material into 78 acres wetland. The area potentially impacted 

by permanent indirect effects, estimated to occur within 328 feet of the proposed project footprint, is 

approximately 688.6 acres. 

The project has incorporated design elements to avoid and minimize impacts to the physical substrate. 

Further reductions to minimize impacts will be realized through use of Best Management Practices 

(BMPs) and permit conditions. 

With proposed design features and inclusion of special conditions, the project would comply with this 

section of the guidelines.
D2.1.2.2 WATER CIRCULATION, FLUCTUATION, AND SALINITY 

DETERMINATIONS (40 CFR 230.11[b]) 

Information regarding the potential impacts of the proposed project activities on water circulation, 

fluctuation, and salinity in the project area is presented in Section 4.2.2 of the GMT2 Final Supplemental 

EIS, Water Resources.

The proposed project would result in long-term alterations to current patterns, water circulation, and 

fluctuation. The construction of gravel pads, gravel roads, ice roads, and VSMs has the potential to lead to 

the formation of impoundments or redirection of surface water flow and may cause deposition or erosion 

of sediment. Cross-drainage culverts would be installed to avoid water impoundments. 

Direct or indirect impacts to salinity gradients are unlikely, as the material from the ASRC Mine Site is 

similar in character to the proposed project site. 

With proposed design features and inclusion of special conditions, the project would comply with this 

section of the guidelines.

D2.1.2.3 SUSPENDED PARTICULATE/TURBIDITY DETERMINATIONS (40 CFR 

230.11[c]) 

Section 4.2.2 of the GMT2 Draft Supplemental EIS, Water Resources, evaluates potential impacts of the 

proposed project in terms of potential changes in turbidity and the kinds and concentrations of suspended 

particulates in the vicinity of the project site.

The proposed project would result in the discharge of 647,300 cyds of coarse mineral fill material, 

composed primarily of sand and gravel, into waters and wetlands. The discharge would occur in winter, 

minimizing direct impacts from increased suspended particulates and turbidity. Indirect impacts could 

include gravel spray, dust deposition, runoff, erosion, or flooding. See section D2.2.2 below for details 

regarding direct and indirect impacts of the proposed fill on suspended particulates and turbidity as 

presented in the GMT2 Final Supplemental EIS.

With proposed design features and inclusion of special conditions, the project would comply with this 

section of the guidelines.

D2.1.2.4 CONTAMINANT DETERMINATIONS (40 CFR 230.11[d])

Construction of gravel infrastructure as part of the proposed project would include placement of clean 

gravel fill that has been determined to be free of contaminants. The ASRC Mine Site is proposed as the 

primary source of gravel fill for the proposed project. The existing ASRC Mine Site has been evaluated 

and previously permitted; therefore, there is no reason to anticipate that the proposed fill material would 

contain contaminants that could affect surrounding water quality or cause State of Alaska water quality 

standards to be exceeded.

With proposed design features and inclusion of special conditions, the project would comply with this 

section of the guidelines.

D2.1.2.5 Aquatic ecosystems and organisms determinations (40 CFR 230.11[e])

Section 4.3.2 of the GMT2 Final Supplemental EIS, Fish, evaluates potential impacts of the proposed 

project on aquatic ecosystems and organisms.
Direct impacts to fish and fish habitat would not occur from the proposed project. Indirect impacts could 

occur to fish and fish habitats adjacent to the proposed project. 

With proposed design features and inclusion of special conditions, the project would comply with this 

section of the guidelines.

D2.1.2.6 Proposed disposal site determinations (40 CFR 230.11[f])

The project does not involve open water disposal of material; this factual determination does not apply. 

D2.1.2.7 Determination of cumulative effects on the aquatic ecosystem (40 CFR 230.11[g]) 

Section 4.6.7.2 of the GMT2 Draft Supplemental EIS, Fish and Fish Habitat, evaluates potential 

cumulative impacts of the proposed project on aquatic ecosystems and organisms.

Permanent impacts to 78 acres of waters and wetlands are expected from the proposed project. 

Reasonably foreseeable future actions include continued hydrocarbon exploration and development on the 

North Slope, as listed in Table 140 of the GMT2 Final Supplemental EIS. 

The placement of the fill material due to the reasonably foreseeable future actions would directly impact 

the physical substrate, water, and vegetation, and also cause indirect impacts to the aquatic ecosystem, 

such as dust deposition along roads contributing to increased turbidity, or snowdrifts along gravel and 

infrastructure that could increase wintertime soil temperatures (GMT2 Final Supplemental EIS, Section 

4.6.4.2). These other potential impacts would be similar to those identified for the proposed project. 

Overall, the project, when combined with past, present, and reasonably foreseeable future projects, with 

the appropriate avoidance, minimization, and permit special conditions, would not result in significant 

adverse cumulative impacts to aquatic resources within the area of cumulative effect (GMT2 Final 

Supplemental EIS, Table 140).

Any proposed future projects requiring a DA permit would be evaluated as separate permit actions, and 

the appropriate environmental analysis, including a cumulative effects analysis, would be required. 

Permitting of these projects would be subject to Section 404 of the CWA, including the Guidelines and/or 

other appropriate laws and regulations. If the appropriate avoidance, minimization, and potential 

compensatory mitigation measures do not result in a project that is in compliance with the above 

regulations, authorization under Section 404 of the CWA could not be granted. 

BMPs and permit special conditions to reduce direct and secondary impacts related to the proposed 

project would serve to reduce cumulative impacts to those same resources. Actions taken to avoid and 

minimize impacts are discussed below.

With proposed design features and inclusion of special conditions, the project would comply with this 

section of the guidelines.

D2.1.2.8 Determination of secondary effects on the aquatic ecosystem (40 CFR 230.11[h]) 

Potential secondary effects on the aquatic ecosystem would be avoided and minimized as described in 

Applicant Proposed Mitigation Statements, and Attachment D, Avoidance, Minimization, and Mitigation 

Measures Table, submitted as part of the DA permit application. 

Secondary effects are effects on an aquatic ecosystem that are associated with a discharge of fill materials, 

but do not result from the actual placement of the dredged or fill material. Secondary effects to the aquatic 

environment include impacts to physical substrate, water quality, vegetation, and aquatic ecosystems and 

organisms.
Secondary effects may include impacts on wetlands, vegetation, and waterbodies as a result of dust, snow 

buildup, impoundments, or thermokarst effects; the disturbance of wildlife populations as a result of noise 

or human activity; or a change in wildlife survival or productivity. Secondary effects could also include 

potential increases in resource competition among aquatic species due to habitat loss resulting from water 

withdrawal, increases in turbidity associated with erosion or discharge, or barriers to movement (USACE 

2015).These impacts are discussed in sections D2.2, D2.3, and D2.4 below.

Consideration of secondary effects also includes the potential for a spill of hydrocarbon or other toxic 

materials. Spills related to construction activities are anticipated to be relatively small in volume, and 

primarily related to vehicle and construction equipment fueling and maintenance. Spills that could occur 

during drilling and operation could result in larger volume spills than construction activities as discussed 

in Section 4.5 of the GMT2 Final Supplemental EIS. 

With proposed design features and inclusion of special conditions, the project would comply with this 

section of the guidelines.

D2.1.3 Findings of Compliance or Non-Compliance with the Restrictions on 

Discharge (40 CFR 230.12) 

On the basis of the Guidelines (Subparts C through G after consideration of Subparts B through H), the 

proposed disposal site for the discharge of dredged or fill material complies with the Section 404 (b)(1) 

Guidelines with the inclusion of the appropriate and practicable discharge conditions to minimize 

pollution or adverse effects to the affected aquatic ecosystem. 

With proposed design features and inclusion of special conditions, the project would comply with this 

section of the guidelines.

D2.2 POTENTIAL IMPACTS ON PHYSICAL AND CHEMICAL 

CHARACTERISTICS OF THE AQUATIC ECOSYSTEM (40 CFR 230, Subpart C) 

D2.2.1 Substrate (40 CFR 230.20) 

The discharge of dredged or fill material can result in changes to the complex physical, chemical, and 

biological characteristics of the substrate. The amount and composition of the discharged material and the 

location, method, and timing of discharges influence the degree of impact on substrates. 

Direct impacts. The proposed project would place fill 78 acres of water and wetland substrates. These 

productive saturated water and wetland organic soil substrates would be converted to upland, and 

permanently lost and replaced with coarse permeable gravel fill material. This would effectively cover the 

substrate surface and inhibit light penetration that allows vegetation to exist, smother existing vegetation, 

and compress the softer substrates through compaction by the weight of the fill material (GMT2 Final 

Supplemental EIS, Section 4.3.1.2).

Direct impacts of the placement of fill on the substrate include compaction and damage to soil during 

construction of gravel pads and roads and installation of VSMs. Construction of the 64.0-acre gravel road 

(including vehicle pullouts) and 14.0-acre GMT2 drill pad represents the majority of the area of impact 

from the proposed project. Although the substrate would be covered with the discharge of fill material, the 

underlying permafrost would remain frozen due to the depth of fill material (minimum of 5 feet thick; 

GMT2 Final Supplemental EIS Section 2.4.3). Pipeline construction would displace soil during 

installation of VSMs. Each new VSM would displace approximately 3.1 square feet of substrate (GMT2 

Final Supplemental EIS Section 4.3.1.2). The project would require approximately 1,000 new VSMs, 
resulting in direct impact to 0.1 acre. VSMs would be installed in winter, and spoil material would be 

collected from the surface for proper disposal. 

Construction of ice roads and pads would cause compression of soils within the direct ice roads and pads 

footprint. This compression would be single-season, and impacts from ice pads, ice roads, and snow trails 

would be negligible to the health of the soils (GMT2 Final Supplemental EIS Section 4.3.1.2). 

Indirect impacts. The ice-rich soils near the fill area may also be indirectly impacted by vegetation 

changes, water impoundment, gravel spray, dust deposition, salinity effects from gravel, snowdrifts, and 

blockage of or changes to natural drainage patterns, resulting in the substrate becoming either wetter or 

drier (GMT2 Final Supplemental EIS, Section 4.2.1.1). Direct or indirect exposure of permafrost to the air 

and sunlight can result in permafrost degradation and thaw settlement (thermokarst). Substrates adjacent 

to proposed pipelines could be indirectly affected by altered snow accumulation patterns and by shading 

of vegetation (GMT2 Final Supplemental EIS Section 4.3.1.2). The area potentially impacted by indirect 

effects from the proposed project, estimated using a 328-foot buffer from proposed gravel fill, is 

approximately 688.6 acres (Table 116 of the GMT2 Final Supplemental EIS). 

With proposed design features and inclusion of special conditions, the project would comply with this 

section of the guidelines.

D2.2.2 Suspended Particulates/Turbidity (40 CFR 230.21)

The discharge of dredged or fill material can result in elevated levels of suspended particulates in the 

water column for varying lengths of time. Impacts to receiving waters are dependent on the nature and 

degree of effect that the proposed discharge would have on the kinds and concentrations of suspended 

particulates, and turbidity in the vicinity of the disposal site.

Direct impacts. Coarse mineral fill material composed primarily of sand and gravel would be discharged 

during winter, when frozen conditions would substantially reduce the introduction of fine materials in the 

fill into the water column. Construction activities associated with placement of fill material may also 

disturb tundra soils and vegetation. Disturbed and exposed soils would be more susceptible to erosion and 

subsequent sedimentation during spring breakup (GMT2 Final Supplemental EIS, Section 4.2.2.2). 

Placement of fill material would occur during winter when soils and vegetation are protected by at least 6 

inches of snow and ice, as required by the NSB. 

Indirect impacts. Increased suspended particulates and turbidity of waterbodies adjacent to the fill 

discharge sites would result from gravel spray, dust deposition, runoff, erosion at fill slopes, or flooding. 

The large waterbody closest to the proposed project is Lake M9925, immediately south of the GMT1 drill 

pad. During the first seasonal thaw period following fill placement, the potential for erosion and siltation 

of waters would increase due to fill material melt, settling, precipitation, and erosion. Flow blockages or 

other obstructions at culverts could lead to decreased water velocity, potentially resulting in inundation 

and increased sedimentation (GMT2 Final Supplemental EIS, Section 4.2.2.2). 

With proposed design features and inclusion of special conditions, the project would comply with this 

section of the guidelines.

D2.2.3 Water (40 CFR 230.22)

The discharge of dredged or fill material can change the chemical, physical, and biological characteristics 

of a receiving water.

Direct impacts. Approximately 78 acres of WOUS and wetlands would be converted to uplands through 

the discharge of fill material. Discharges of gravel fill material into waters would occur for construction 
of the drill pad, access road, vehicle pullouts, and placement of VSMs. Most discharges would occur in 

saturated or moist tundra wetland areas.

Indirect impacts. Water withdrawals for drilling and/or operations may have short-term (lasting only two 

or three single construction seasons) impacts on alkalinity, pH, or oxygen content in the water source. 

Typically, water for drilling and operations would be provided by CD1, using permitted sources. 

Discharges of treated domestic wastewater to the tundra, if needed, would occur in accordance with 

Alaska Pollutant Discharge Elimination System permit requirements, so an increase in fecal coliform 

counts over the naturally occurring concentrations is not expected.

Potential impacts to water resources could occur in the event of an oil spill. Potential impacts to water 

resources resulting from increased suspended particulates and turbidity are addressed above.

With proposed design features and inclusion of special conditions, the project would comply with this 

section of the guidelines.

D2.2.4 Current Patterns and Water Circulation (40 CFR 230.23) and Normal Water 

Fluctuations (40 CFR 230.24) 

Current patterns and water circulation are the physical movements of water in the aquatic ecosystem. The 

discharge of dredged and fill materials can obstruct flow, change the direction of velocity, or change the 

dimensions of a waterbody, including wetland areas. 

Direct impacts. The proposed gravel infrastructure could impact hydrology through changes in natural 

drainage patterns, stream stage and streamflow, and stream velocity. These effects would most likely 

occur as a result of the proposed gravel access road. Gravel fill on tundra could change recharge potential, 

block natural drainage, and change the existing hydrologic regime. Placing fill transversely across grade 

would block the natural drainage of sheet flow runoff, shallow groundwater, stream input, or rain 

catchment. Placing fill transversely across grade may also change snow accumulation patterns, which, in 

turn, may change drainage patterns once the snow melts (GMT2 Final Supplemental EIS, Section 

4.2.2.2). 

The access road is routed west of and within 1.5 miles of the hydraulic divide between the Tiŋmiaqsiġvik 

(Ublutuoch) River hydrologic drainage basin and the Outlet Fish Creek hydrologic drainage basin. The 

road route is parallel to the predominant northeast surface water gradient for both of these hydraulic 

basins. The road route does not cross any of the larger primary creeks or rivers within these drainage 

basins and is not situated in lowlands potentially prone to flooding. The road would include a culvert 

crossing over the small unnamed beaded stream pool outlet draining from Lake M9925. The road route 

traverses the localized hydraulic gradient within the larger hydraulic drainage basin in those areas where 

relatively small surface water flow is generated by contributing surface area located above the elevation 

of the road, and could result in localized increased inundation (flooding) upgradient of the road, and 

decreased inundation downgradient of the road. These localized inundation effects would be small in 

comparison to the potential inundation effects if the road alignment were instead routed transverse to the 

overall northeast surface flow gradient for the hydrologic drainage basin (GMT2 Final Supplemental EIS, 

Section 4.2.2.2). The proposed road has been designed to accommodate predicted water flow by 

incorporating culverts in areas of channelized flow that would sustain both low and high water flows. The 

structures would accommodate fluctuating water levels and maintain circulation and fish passage.

The GMT2 Final Supplemental EIS concludes that impacts on current patterns and water circulation as a 

result of the proposed project would be long term and minor (GMT2 Final Supplemental EIS, Section 

4.2.2.6). 
Indirect impacts. There would be short-term, temporary impacts from ice infrastructure (e.g., roads and 

pads). Only permitted lakes, rivers, or reservoirs (under state temporary water use authorizations and, if 

required, state fish habitat permits) would serve as water sources. As the ice roads melt in spring, the 

water would be dispersed across the road corridors and drain into the many lakes or other areas of natural 

inundation. Construction of ice roads that do not result in the discharge of dredge or fill material, 

including water withdrawal, is not a USACE-regulated activity.

Normal water fluctuations in a natural aquatic system consist of daily, seasonal, and flood fluctuations in 

water level. The discharge of dredged or fill material can alter the normal water-level fluctuations pattern 

of an area, resulting in periods of inundations and exaggerating high and low water stages, or a static nonfluctuating water level.

Direct impacts. The proposed project could alter normal water fluctuations from placement of fill 

material across several drainages. The access road and drill pad fill areas could impede or impound 

downgradient water flow if not adequately bridged and culverted. The proposed gravel road could 

impound springtime breakup sheet flows and shallow groundwater flow, resulting in increased inundation 

(flooding) upgradient and decreased inundation (drying) downgradient of the road. Increased inundation 

adjacent to gravel infrastructure can increase erosion and sedimentation, and can lead to thermokarst or 

creation of deeper, open waterbodies (GMT2 Final Supplemental EIS, Section 4.2.2.2).

Potential impacts to water fluctuations that may be caused by the proposed infrastructure were evaluated 

using a snowmelt water equivalent inundation analysis (GMT2 Final Supplemental EIS, Section 4.2.2.2, 

Table 72). This analysis showed that the maximum area of potentially altered inundation would be 178.6 

acres upgradient and 83.4 acres downgradient from the proposed infrastructure. These potential impacts 

would be minimized by installing cross-drainage culverts to mitigate the risk of sheet flow interruption 

and potential thermokarst. Culvert locations would be located in the field based on observations of sheet 

flow patterns during spring breakup. Cross-drainage culverts would also be placed under the road 

approximately every 500 to 1,000 feet. Approximately 46 cross-drainage culverts would be placed along 

the 8.2-mile gravel access road, although the number ultimately placed will be determined based on field 

observations to optimize their placement in order to maintain natural hydrological conditions (GMT2 

Final Supplemental EIS, Section 4.2.2.4) 

Pipelines would be installed on VSMs. Once installed, above-ground pipelines would have no impact on 

stream and water flow characteristics (GMT2 Final Supplemental EIS, Section 4.2.2.3). 

The GMT2 Final Supplemental EIS concludes that impacts on normal water fluctuations as a result of the 

proposed project would be long term and minor (GMT2 Final Supplemental EIS, Section 4.2.2.6). 

With proposed design features and inclusion of special conditions, the project would comply with this 

section of the Guidelines.

D2.2.5 Salinity Gradients (40 CFR 230.25) 

Salinity gradients primarily occur where saltwater from oceans meets and mixes with freshwater from 

lands. On Alaska’s North Slope, some substrates have a naturally occurring salt component. These 

substrates may be present at the discharge site or at the source of fill materials (USACE 2015 GMT1 

ROD § 5.3.6).

Direct impacts. Alterations to salinity gradients within wetlands, waterbodies, or substrates could occur 

from the construction of ice roads and pads, and gravel infrastructure. Freshwater is used to construct ice 

infrastructure, which could dilute salinity gradients when the ice melts. Placement of gravel for the 

proposed road and pads could increase salinity gradients if saline material were used as fill. Water 
draining off of or leaching through saline material within gravel roads or pads could alter water quality or 

soil properties in the immediate vicinity of the gravel structure. The ASRC Mine gravel is similar in 

character to gravel at the proposed placement sites, and an increase in the salinity of water or soils from 

fill material placement would be unlikely. 

The proposal complies with this factor of the Guidelines. 

D2.3 POTENTIAL IMPACTS ON BIOLOGICAL CHARACTERISTICS OF THE 

AQUATIC ECOSYSTEM (40 CFR 230, Subpart D) 

D2.3.1 Threatened and Endangered Species (40 CFR 230.30) 

The project area is within the known or historic range of the following threatened or endangered species: 

spectacled eider (Somateria fischeri; threatened), Steller’s eider (Polysticta stelleri; threatened), and polar 

bear (Ursus maritimus; threatened). The proposed project is in the established critical habitat of the polar 

bear. The area for evaluation under Section 7 of the ESA includes all areas to be affected directly or 

indirectly by the project and not merely the immediate area involved in the project.

Threatened and endangered species are discussed in Section 4.3.6 of the GMT2 Final Supplemental EIS, 

the USFWS BO (Appendix F, dated September 21, 2018) and above at the Endangered Species Section 

(page 12). 

The USACE has accepted the findings of the BO and included the Terms and Conditions in our evaluation 

and permit conditions to protect listed species. With inclusion of these measures, the proposed project 

complies with this factor of the 404(b)(1) Guidelines. 

D2.3.2 Fish, Crustaceans, Mollusks, and Other Aquatic Organisms in the Food Web 

(40 CFR 230.31)

The discharge of fill material can variously affect populations of fish, crustaceans, mollusks, and other 

food web organisms by direct removal of habitats and release of contaminants.

Direct and indirect impacts to fish and fish habitat would occur from the proposed project near Lake 

M9925, Outlet Fish Creek drainage basin, and the Ublutuoch River drainage basin. Potential direct and 

indirect impacts to freshwater fish could result from barriers to fish passage, erosion, siltation, increased 

turbidity, road dust fallout, water withdrawal from lakes, and possible oil spills and fuel leaks.

The proposed GMT2 access road would include 25.6 acres of fill within the Outlet Fish Creek drainage 

basin and 52.3 acres of fill with in the Ublutuoch River drainage basin. Based on the aquatic site 

assessment functional rankings, the proposed access road would directly impact 4.4 acres of wetland and 

waterbody types that may provide high-value habitat for fish (ABR 2017 Wetland Delineation, Final 

Report 2017).

With proposed design features and inclusion of special conditions, the project would comply with this 

section of the guidelines.
D2.3.3 Other Wildlife (40 CFR 230.32)

The discharge of fill material can result in the loss or change of breeding and nesting areas, escape cover, 

travel corridors, and preferred food sources of resident and transient wildlife species associated with the 

aquatic ecosystem.

The terrestrial mammal species most likely to be affected by the proposed GMT2 Development Project 

include caribou (Rangifer tarandus), grizzly bear (Ursus arctos), Arctic and red foxes (Vulpes lagopus

and V. vulpes), and small mammal species such as Arctic ground squirrels (Urocitellus parryii). While 

muskoxen (Ovibos moschatus) have been observed near the proposed project area, these sightings have 

been extremely sporadic (GMT2 Final Supplemental EIS, Section 3.3.4.1). Consequently, the proposed 

project has very little possibility of disturbing muskox populations (GMT2 Final Supplemental EIS, 

Section 4.3.4.1). 

Use of the proposed project area by caribou from the Teshekpuk herd occurs predominantly during fall 

migration and winter. However, small numbers of caribou are expected in the project area throughout the 

year (GMT2 Final Supplemental EIS, Section 3.3.4.1). In late June to early August, caribou from the 

Teshekpuk herd move across the proposed project area from summer calving areas located near 

Teshekpuk Lake to the Colville River Delta in search of relief from insect harassment. This southeasterly 

movement continues after insect harassment season, until animals from the Teshekpuk herd reach their 

wintering areas located on the south side of the Brooks Mountain Range (GMT2 Final Supplemental EIS, 

Section 3.3.4). However, in general, more caribou are likely to occur in the western portion of the NPR-A 

than in the southeastern section where the Alpine facilities exist and where the proposed project would 

occur (GMT2 Final Supplemental EIS Section 3.3.4). 

Potential impacts to caribou from the proposed GMT2 Development Project would likely be long term 

and of medium intensity (GMT2 Final Supplemental EIS Section 4.3.4.1) but would, overall, be 

considered minor. These potential impacts include: 

• The loss of primarily tussock tundra and moist sedge-shrub tundra, both of which are preferred 

caribou summer habitat, due to the placement of fill (GMT2 Final Supplemental EIS Section 

4.3.4.1) 

• Barriers to movement from the proposed pad, road, and pipeline 

• Disturbance caused by noise, road traffic, and human movements 

• Disturbance from air traffic

• Insect harassment relief

Predators, including grizzly bears and Arctic and red foxes, are also likely to be found in the proposed 

project area. Reliable estimates of population sizes and distributions for these species are not available. 

The primary impacts of the proposed project to these species would be associated disturbance of dens and 

den habitat. These impacts would be of low intensity, but long term (GMT2 Final Supplemental EIS 

Section 4.3.4.1). Attraction to human food waste could result in increased conflicts between humans and 

wildlife, and consequent injury to wildlife due to increased time spent in or around the project area 

(GMT2 Final Supplemental EIS Section 4.3.4.1). In addition, increases in the local populations of 

predatory species, such as grizzly bears and foxes, resulting from attraction to anthropogenic foods, could 

have cascading adverse effects on prey species.

The Applicant has created a Wildlife Avoidance and Interaction Plan that includes strategies and protocols 

to contain and dispose of substances that are potentially attractive to wildlife. When implemented, this 
plan would help mitigate mitigate potentially adverse effects to wildlife from attraction to anthropogenic 

food and waste. 

The project area also contains potential seasonal and year-round habitat for approximately 80 bird species 

(GMT2 Final Supplemental EIS Section 3.3.3,). Impacts of the proposed project to bird species would be 

of low intensity and long term (GMT2 Final Supplemental EIS Section 4.3.3.5). The proposed GMT2 

Development Project would permanently remove 78 acres of potential nesting and breeding habitat due to 

construction of the gravel pads and road. Dust deposition from the gravel pads and road could extend up 

to 328 feet from the edge of the gravel footprint, thus extending the area of bird habitat potentially altered 

to 688.6 acres. 

Other potential impacts to birds from the proposed project include potentially harmful attraction to 

sources of illumination (depending on lighting design); disturbance and displacement from noise, road 

traffic, and human movements associated with gravel placement; and increased nest depredation from 

predator populations attracted to human activities (GMT2 Final Supplemental EIS Section 4.3.3.5). 

With proposed design features and inclusion of special conditions, the project would comply with this 

section of the guidelines.

D2.4 POTENTIAL IMPACTS ON SPECIAL AQUATIC SITES (40 CFR 230, 

Subpart E)

D2.4.1 Sanctuaries and Refuges (40 CFR 230.40)

Sanctuaries and refuges consist of areas designated under state or federal laws or local ordinances to be 

managed principally for the preservation and use of fish and wildlife resources. 

There are no sanctuaries or refuges located in the proposed project area.

D2.4.2 Wetlands (40 CFR 230.41)

Wetlands are present on approximately 99 percent of the project area (GMT2 Final Supplemental EIS, 

Section 4.6.7.1). 

The wetland types and their characteristics are listed below in order based on the amount of acreage that 

would be impacted. Some wetland functions and ecological services provided by the functions are 

described and related to human values for the specific aquatic resource (wetland or water type). Some 

wildlife values per wetland or water type are also described, in recognition of the regional importance for 

wildlife production and subsistence harvesting. Additional information can be found in the wetlands 

delineation report that was included as part of the Corps 404 permit application (ABR Wetland 

Delineation, Final Report 2017).

PEM1/SS1B (Saturated Persistent Emergent and Broad-leaved Deciduous Scrub-Shrub 

Wetland)

These wetlands are among the highest and driest in the proposed project area and are known as moist 

tussock tundra wetlands. They occupy convex micro-relief and gently rolling slopes between drained lake 

basins. They display limited pattern ground features or high center polygons with less than 5 percent 

aerial cover of inundated depressions. These scrub-shrub wetlands are typically dominated by tall grass 

(Eriophorum angustifolium), sedges (Carex bigelowii), and shrubs such as willows (Salix pulchra), dwarf 

birch (Betula glandulosa), and Cassiope (Cassiope tetragona). 
This wetland type offers a high diversity of plant species when compared with inundated wetlands 

dominated by graminoids. Due to the abundance of this wetland type in a large non-fragmented 

landscape, it provides habitat for a variety of common wildlife species in conjunction with other similar 

wetland types in the area. It offers free range for large mammals, and nesting habitat to several bird 

species, including passerine birds, known to nest on the tundra ground. A limitation for some wildlife 

species may be a lower interspacing between surface water and drier vegetated grounds when compared 

to similar wetland types.

These wetlands provide high functions for social use; moderate functions for flood flow regulation; and 

low functions for sediment/toxicant removal, organic matter production/export, threatened and 

endangered species support, and wildlife habitat. These wetlands do not provide shoreline stabilization or 

fish habitat functions. 

The proposed GMT2 Development Project would involve placement of fill in 49.7 acres of PEM1/SS1B 

wetlands. 

PEM1/SS1E (Seasonally Flooded/Saturated Persistent Emergent and Broad-leaved 

Deciduous Scrub-Shrub Wetland)

Relief on this wetland type is dominated by high centered-low relief polygons, low centered polygons, 

and basin wetland complex. These wetlands provide a complex micro-topography supporting good 

surface water/ground interspersion. Surface water is present in low-lying troughs and accounts for 5 to 20 

percent areal cover in the early season, drying out by fall. Vegetation is dominated by Bigelow’s sedge 

(Carex bigelowii) and white mountain avens (Dryas integrifolia). Active layers are relatively shallow, and 

soils have moderate organic horizons. The high centers of the polygons support a more diverse plant 

community consisting of a variety of low and dwarf shrubs and herbs. The combination of wet flooded 

types and moist diverse plant communities increases the value for a wide range of both mammals and 

birds, thus increasing the value of this type for general habitat suitability. 

These wetlands provide high functions for flood flow regulation, wildlife habitat, and social use; 

moderate functions for sediment/toxicant removal and organic matter production/export; and low 

functions for ESA-listed species support. These wetlands do not provide functions for shoreline 

stabilization or fish habitat.

The proposed project would involve placement of fill in 23.7 acres of PEM1/SS1E wetlands.

PEM1F (Semi-permanently Flooded Persistent Palustrine Emergent Wetland)

PEM1F wetlands provide a good mix of surface water and graminoid ground cover on non-patterned or 

low centered polygon micro-relief areas. In the project area, non-patterned and patterned (low center 

polygons with raised edges) wet sedge meadow communities occupy depressions formed in drained lake 

basins or abandoned flood plains. This wetland type is typically flooded throughout the growing season, 

sometimes drying in the early fall. Vegetated communities are dominated by aquatic environment obligate 

sedge species, including water sedge (Carex aquatilis) and tall cottongrass (Eriophorum angustifolium), 

and soils have moderately thick organic layers over sand or loamy sand.

These wetlands are typically a flat or depressional hydrogeomorphic type with a thick organic horizon 

and abundant herbaceous cover. They typically have a low center polygonal surface form, which can 

provide high value in flood storage capacity, sediment, toxicant, and nutrient removal; and organic matter 

production and export. Though not a preferred habitat for spectacled eiders, these wetlands do provide 

habitat for a high diversity of avian species, as well as potential shelter and spawning habitat for fish. 
These wetlands provide high functions for flood flow regulation, sediment/toxicant removal, organic 

matter production/export, fish habitat, and social use; moderate functions for wildlife habitat; and low 

functions for threatened and endangered species support. These wetlands do not provide for shoreline 

stabilization.

The proposed project would involve placement of fill in 4.3 acres of PEM1F wetland. 

PEM1H (Permanently Flooded Emergent Marsh Wetland)

PEM1H wetlands in the proposed project area are found as aquatic vegetation communities occurring 

along the edges of permanently flooded ponds in the area usually dominated by water sedge and tall 

cottongrass or in low-lying drained lake basin complexes. In lake basin complexes, they function 

primarily as depressional wetlands, which are similar in function to thaw ponds, and the dominant species 

present is water sedge. These wetlands provide high function for erosion control because of their 

characteristic thick herbaceous vegetation bordering waterbodies. Avian and mammalian habitat 

suitability was rated as high because, although the plant diversity is low, these wetlands support a wide 

diversity of avian species and are relatively less common on the landscape. 

No fill placement is proposed within this wetland type; however, PEM1H wetlands could be impacted 

indirectly by dust, noise, and potential hydrocarbon leaks or spills. 

PUBH (Permanently Flooded Unconsolidated Bottom Ponds)

Shallow ponds and lakes generally begin to freeze in September, freeze to the bottom by mid-winter, and 

become ice-free between by mid-June to early July, about a month earlier than deeper lakes. Although 

generally shallow, ponds do replenish during spring breakup and store substantive volumes of water 

through summer, decreasing peak flows in the lower sections of the watershed. 

Spectacled eiders feed primarily by dabbling in shallow freshwater or brackish ponds, where they find 

insect larvae, benthic organisms, and aquatic plants or seeds; pre-nesting eiders prefer shallow ponds with 

islands, emergent grasses, and sedges.

PUBH waters provide high functions for fish habitat and social use; moderate functions for flood flow 

regulation, sediment/toxicant removal, ESA-listed species support, and wildlife habitat; and low functions 

for organic matter production/export. PUBH waters also provide important summer rearing fish habitat 

when connected to a stream by a channel or intermittently flooded by nearby streams. They provide 

important habitat to emergent vegetation, invertebrates, and migratory birds due to the earlier availability 

of ice-free areas.

The proposed project would result in a loss of 0.1 acre to PUBH waters. 

Effects on wetlands

The direct effects of the proposed project would result in the loss of aquatic resources from the placement 

of gravel for the following project components: 

Drill Pad -- 14 acres

Access Road -- 8.2 miles, 62.8 acres 

Tundra Access Road Pullouts -- 3 pullouts, 1.2 total acres

Vertical Support Members (VSMs) -- 8.6 miles, 0.1 total acre

Total acreage -- Approximately 78 acres 
Oil and gas development and operation would cause the following long-term impacts: burial of vegetation 

under gravel pads, roads, and airstrips; excavation of materials at mine sites; construction of vertical 

support members for elevated oil pipelines; and excavation of trenches for buried gas and utility lines. 

Construction of gravel pads and roads could also result in indirect effects by altering the moisture regime 

of vegetation near the structures due to dust and snow accumulation and modification of natural drainage 

patterns. Impacts to floodplains could occur from river channel crossings by pipelines and roads, which 

could destroy vegetation where bridge pilings or vertical support members are required for the crossing. 

These factors could combine to warm the soil, deepen thaw, and cause thermokarst adjacent to roads and 

other gravel structures (GMT2 Final Supplemental EIS, Section 4.6.7.1).

Indirect effects of the proposed project would include reductions in aquatic resources’ functionality, 

impacts on the hydrologic regime (wetting or drying), gravel spray and dust effects, subsistence resources 

effects, erosion and siltation, noise effects, visual effects, vegetation community changes, thermokarsting, 

and/or changes in natural drainage patterns. Other indirect effects include displacement of wildlife from 

wetlands habitats, off-road tundra travel during the snow-free season, and potential oil spill impacts 

(USACE 2015 GMT1 ROD § 5.5.2.12). 

To minimize impacts on aquatic resources, the applicant would: 

1. Minimize fill acreage of the gravel pads by project design and equipment layout.

2. Utilize ice roads and pads for construction access.

3. Water gravel roads and pads to control dust generation. 

4. Slot ice roads at stream crossings to maintain natural drainage patterns during breakup.

5. Installing more or relocating culverts as needed after initial construction.

With applicant design features and inclusion of special conditions, the proposed project would comply 

with this factor of the Guidelines.

D2.4.3 Mudflats (40 CFR 230.42)

Mudflats are broad flat areas along the sea coast and in coastal rivers to the head of tidal influence and in 

inland lakes, ponds, and riverine systems. The substrate of mudflats contains organic material and 

particles smaller than sand. They are either unvegetated or vegetated only by algal mats. 

There are no mudflats located in the proposed project area. 

D2.4.4 Vegetated Shallows (40 CFR 230.43)

Vegetated shallows are permanently inundated areas that, under normal circumstances, support 

communities of rooted aquatic vegetation, such as turtle grass and eel grass in estuarine or marine 

systems, as well as a number of freshwater species in rivers and lakes. 

Permanently flooded emergent wetlands (PEM1H) may act as vegetated shallows since they are 

associated with thaw ponds and thaw basins throughout the proposed project area. The proposed project 

would not directly impact vegetated shallows. Indirect impacts to vegetated shallows would total 17.0 

acres. Indirect impacts to vegetated shallows would be minor and associated with gravel spray and dust 

generation within 328 feet of the edge of the access road and pad. 

With proposed design features, the project would comply with this section of the guidelines. 
D2.4.5 Coral Reefs (40 CFR 230.44)

Coral reefs consist of the skeletal deposit, usually of calcareous or silicaceous materials, produced by the 

vital activities of anthozoan polyps or other invertebrate organisms present in growing portions of a reef.

There are no coral reefs located in the proposed project area.

D2.4.6 Riffle And Pool Complexes (40 CFR 230.45) 

Steep gradient sections of streams are sometimes characterized by riffle and pool complexes. Such stream 

sections are recognizable by their hydraulic characteristics.

There are no riffle and pool complexes located in the proposed project area.

D2.5 POTENTIAL EFFECTS ON HUMAN USE CHARACTERISTICS (40 CFR 

23, Subpart F) 

D2.5.1 Municipal and Private Water Supplies (40 CFR 230.50) 

Municipal and private water supplies consist of surface or groundwater that is directed to the intake of a 

municipal or private water supply system.

There are no municipal or private water supplies in the proposed project area.

D2.5.2 Recreational and Commercial Fisheries (40 CFR 230.51)

Recreational and commercial fisheries consist of harvestable fish and other aquatic organisms used by 

man.

The discharge of dredged or fill material can affect the suitability of recreational and commercial fishing 

grounds as habitat for populations of consumable aquatic organisms.

There are no commercial fisheries currently operating within the proposed project area.

Recreational fishing within the project area occurs predominately opportunistically by people in the area, 

primarily for recreational purposes such as big game hunting or float trips. As of 2012, there were no 

commercial sport fishing recreation permit requests or authorizations for the area (BLM 2012 NPR-A 

IAP/EIS § 3.4.6.1). No specific use numbers for sport fishing are available for the project area. Fish 

species sought by visitors include the Arctic char, Arctic grayling, lake trout, northern pike, whitefish, and 

various species of salmon. The majority of recreational fishing takes place in non-winter months. 

The proposed project would result in minimal impacts to recreational fishing during construction, drilling, 

and operations (GMT2 Final Supplemental EIS Section 4.4.4.3). 

With proposed design features, the project would comply with this section of the guidelines. 

D2.5.3 Water-Related Recreation (40 CFR 230.52)

Water-related recreation encompasses activities undertaken for amusement and relaxation. The activities 

include consumptive and non-consumptive uses.

Public recreational use in the project area is low intensity and primarily represented by non-local visitors 

who float the Colville River between Umiat and Nuiqsut (BLM 2018 § 4.4.4.3, p. 410). The project area 

offers opportunity, but limited access, for primitive unconfined recreation, including backpacking and 
hiking, wildlife viewing, hunting, fishing, and boating. No federal, state, or NSB public recreational 

facilities exist in the project area, and the lack of a developed public road system into or through the area 

limits recreational access almost exclusively to charter aircraft during summer or snowmachine/dog sled 

during winter. In 2010, there were 10 special recreational permit holders authorized to conduct 

backpacking, hiking, boating, and other recreational activities within the larger NPR-A area (BLM 2012 

NPR-A IAP/EIS § 3.4.6.). 

Potential effects of the proposed project on water-related recreation include the loss of area available for 

recreational activities and the loss of opportunities to experience wilderness-like values such as 

naturalness and solitude through changes in noise, visual aesthetics, dust, or odor. During winter 

construction for fill placement, the activity and noise would make the project more conspicuous for 

recreationists. Long-term effects of project operation are expected to be greatest within 1 mile of gravel 

roads and 2 miles of the production pad, due to the presence of permanent facilities and associated noise 

(USACE 2015 GMT1 ROD § 5.6.3). 

The proposed project complies with this factor of the Guidelines. 

D2.5.4 Aesthetics (40 CFR 230.53) 

Aesthetics associated with the aquatic ecosystem consist of the perception of beauty by one or a 

combination of the senses of sight, hearing, touch, and smell. Aesthetics of aquatic ecosystems apply to 

the quality of life enjoyed by the general public and property owners (GMT2 Final Supplemental EIS, 

Section 5.6.4). 

The discharge of dredged or fill material can mar the beauty of natural aquatic ecosystems by degrading 

or destroying vital elements that contribute to the compositional harmony or unity, visual distinctiveness, 

or diversity of an area, including property values (GMT2 Final Supplemental EIS, Section 5.6.4). 

Visual Resource Management (VRM) classes have been assigned to lands within the NPR-A, with the 

exception of village-owned lands. The project area falls within VRM Class IV, or private land. VRM 

Class IV is the least restrictive visual classification, allowing high relative change to the existing visual 

character of the area. Developments in VRM IV may attract attention and dominate the view but are still 

mitigated (GMT2 Final Supplemental EIS, Section 4.4.4.6). 

Construction and operation of the proposed project would result in moderate effects to visual resources. 

Construction activities such as gravel placement would have minor impact on visual resources, as most 

construction activities would occur in winter when snow and darkness make viewing these activities 

difficult, and few people other than the workforce are expected to view construction activities, except in a 

transient way (GMT2 Final Supplemental EIS, Section 4.4.4.6). 

The aesthetics impact of the fill material and associated structures would be permanent. During drilling, 

the presence of drill rigs during summer would create a moderate contrast against the surrounding 

landscape at a distance of 5 miles or less by introducing vertical lines. Once production facilities (e.g., 

well houses, miscellaneous buildings) are in place, they would provide a strong contrast with the natural 

landscape (including color). Most buildings would be less than three stories high. Communication towers 

would be much taller than the buildings, at up to 200 feet high, introducing vertical lines into the 

landscape. 

With applicant design features, including construction timing, the proposed project would comply with 

this factor of the Guidelines.
D2.5.5 Parks, National and Historical Monuments, National Seashores, Wilderness 

Areas, Research Sites, and Similar Preserves (40 CFR 230.54) 

Parks, national and historic monuments, national seashores, wilderness areas, research sites, and similar 

preserves consist of areas designated under federal or state laws or local ordinances to be managed for 

their aesthetic, educational, historical, recreational, or scientific value. 

There are no designated or proposed Wild and Scenic Rivers located within the GMT2 Development 

Project area. The proposed project would not be located within or near any federally designated 

wilderness areas, federal lands previously designated for Special Areas, or Land Use Emphasis areas.

There are no parks, national and historic monuments, national seashores, wilderness areas, research sites, 

or similar preserves in the proposed project area.

With proposed design features and inclusion of special conditions, the project would comply with this 

section of the guidelines.

D2.6 EVALUATION AND TESTING (40 CFR 230, SUBPART G)

General Evaluation of Dredged or Fill Material (40 CFR 230.60) 

To determine if additional chemical or biological testing is required, available information regarding the 

source of the proposed dredged and fill material, including prior evaluations, chemical and biological 

tests, scientific research, and past experience must be considered. The following information was 

considered in evaluating the potential presence and biological availability of contaminants in the proposed 

fill material.

The Applicant’s proposed source for fill material is the ASRC Mine Site, located about 4.5 miles eastnortheast of Nuiqsut, Alaska. The ASRC Mine Site is an existing commercial gravel source located on the 

East Channel of the Colville River, and has been evaluated and permitted previously (POA-1996-869-

M11). The mine site vicinity and watershed are not known to be contaminated with chemical or naturally 

occurring pollutants. The watershed is largely undeveloped and pristine in character and is removed from 

sources of pollution to provide reasonable assurance that the material is not a carrier of contaminants 

(USACE 2015 GMT1 ROD § 5.7.1,). 

Physical characteristics of materials. The ASRC Mine Site contains mineral alluvium ranging from 

gravelly sand to sandy gravel to with inter-bedded discontinuous layers of silt. The coarseness of the site’s 

mineral material lends it to be less susceptible to retaining chemical, biological, or other pollutants, as 

compared to organic and/or finer-grained materials. Gravel fill material proposed for placement would be 

“pit run” or in raw form and not screened, crushed, or graded by material size particle. Gravel used for 

construction would be selected by visual and on-site testing and be clean material, free of ice and snow 

concentrations, overburden, clay or silt seams, and organic matter. The desired silt/clay fraction in the 

gravel is 15 percent; however, actual pit run gravel would be used and may vary from this specification 

(USACE 2015 GMT1 ROD § 5.7.1) 

Federal, state, and local records indicating significant introduction of pollutants. Inside the NPR-A, 

hazardous and solid waste locations, including landfills, reserve pits, formerly used defense sites, and 

privately owned sites, have been identified and mapped. No hazardous and solid waste locations are 

located near the proposed fill sources. Sites with potential for hazardous materials and solid waste inside 

and outside the NPR-A (e.g., Nuiqsut community sources, winter travel routes, recreational trails, and oil 

and gas exploration sites) are described by the BLM (GMT2 Final Supplemental EIS, Section 3.1.3). 
Based upon this information, there is no reason to believe the proposed fill material would contain 

contaminants, and the project would comply with this factor of the Guidelines. 

D2.6.1 Chemical, Biological, and Physical Evaluation and Testing (40 CFR 230.61)

The fill material has been excluded from the evaluation procedures of this section based on general 

evaluation in section D2.6 above, which concludes that it would not be expected to contain contaminants.

With proposed design features and inclusion of special conditions, the project would comply with this 

section of the guidelines.

D2.7 ACTIONS TO MINIMIZE ADVERSE EFFECTS (40 CFR 230, Subpart H)

The applicant has implemented mitigation measures to avoid and minimize impacts from the project, as 

detailed in ConocoPhillips 2017 (Attachment C, Applicant Proposed Mitigation Statements, and 

Attachment D, Avoidance, Minimization, and Mitigation Measures Table). 

The proposed project would avoid impacts to WOUS, including wetlands by site design and selection, 

facility relocation, use of existing infrastructure, use and construction of ice roads and pads as opposed to 

additional permanent fill, winter construction activities, avoiding river crossings, installing culverts to 

minimize the chance of standing water, and the avoidance of adding treatment substances to discharged 

gravel material. 

The proposed project would minimize impacts to WOUS, including wetlands, by designing the proposed 

access road connecting GMT1 and GMT2 to maintain the hydrologic flow, using machinery and 

equipment techniques that minimize wetlands impacts, implementing erosion control procedures through 

design and spill prevention and response planning.

With proposed design features and inclusion of special conditions, the project would comply with this 

section of the guidelines.

D2.7.1 Actions concerning the Location of the Discharge (40 CFR 230.70)

The effects of the discharge can be minimized by choosing placement sites that minimize smothering of 

aquatic organisms; by avoiding disruption of periodic water inundation patterns; by minimizing or 

preventing the creation of standing water in areas of normal fluctuation water levels; and by minimizing 

or preventing the drainage of areas subject to such fluctuations. Efforts to minimize and avoid discharge 

impacts are addressed by mitigation measure 16 in ConocoPhillips 2017 (Avoidance, Minimization, and 

Mitigation Measures Table).

Under the proposed project, a total of 674,300 cubic yards of clean fill material would be placed into 

approximately 78 acres of WOUS. The sites for placement of fill would include the GMT2 drill site pad, a 

gravel access road with vehicle pullouts, and the sand slurry mixture for VSM installations. Additional 

details regarding the size and volume of fill by site are discussed above.

The placement sites for construction of the project have been chosen by surveying the topography, water 

drainages, and surface waters to avoid and minimize the effects of the fill material, including smothering 

of aquatic organisms. The route of the access road, location of the drill site pad, and culverts have been 

designed to minimize creation of standing waters and drainage of areas subject to water fluctuation 

(ConocoPhillips 2017: Avoidance, Minimization, and Mitigation Measures Table and Applicant Proposed 

Mitigation Statement). 

The proposed project would comply with this factor of the Guidelines. 
D2.7.2 Actions Concerning the Material to be Discharged (40 CFR 230.71)

The effects of a discharge can be minimized by the treatment of, or limitations on, the material itself and 

the methods used to reduce the availability of pollutants.

The general characteristics of proposed fill material are described above. Discharge of the sand and gravel 

fill material would occur during winter when the material is frozen, and the material would not be subject 

to movements until thaw season, when it would dewater and settle. Some erosion protection would be 

necessary to prevent runoff and siltation of finer components, especially in or near lotic and lentic waters, 

before breakup. The Alpine Facilities Erosion Control Plan has been updated to include GMT2, and 

outlines erosion control methods and procedures to minimize impacts to the aquatic environment. 

Alpine’s Storm Water Pollution and Prevention Plan would be amended to include the GMT2 

Development Project.

The project is designed to avoid adding treatment substances to the discharge materials collected from the 

ASRC Mine Site (ConocoPhillips 2017: Attachment D, Avoidance, Minimization, and Mitigation 

Measures Table). 

With applicant design features and inclusion of special conditions, the proposed project would comply 

with this factor of the Guidelines.

D2.7.3 Actions Controlling the Material after Discharge (40 CFR 230.72) 

The effects of the discharge of dredged or fill material may be controlled by selecting methods and sites 

where the potential for erosion, slumping, or leaching of material into the surrounding aquatic ecosystem 

would be reduced; maintaining and containing discharged materials; and timing the discharge to minimize 

impacts to aquatic resources. The selection of the fill material discharge sites is addressed above.

Fill would be placed during frozen winter conditions, using large side-dump trucks accessed by seasonal 

ice roads. Gravel roads and pads would be watered, as necessary, to minimize dust impacts on the 

vegetation and maintain the roads. Temporary erosion protection would be placed before breakup, 

following the first construction season, to provide protection from a flood event. The temporary erosion 

protection would be replaced with permanent erosion protection once the gravel has been allowed to settle 

and drain (GMT2 Final Supplemental EIS, Section 2.4.9). The Alpine Facilities Erosion Control Plan has 

been updated to include GMT2, and outlines erosion control methods and procedures to minimize impacts 

to the aquatic environment. Alpine’s Storm Water Pollution and Prevention Plan would be amended to 

include GMT2. 

With applicant design features and inclusion of special conditions, the proposed project would comply 

with this factor of the Guidelines.

D2.7.4 Actions Affecting the Method of Dispersion (40 CFR 230.73)

There are no proposed discharges of dredged or fill materials into open waterbodies where materials 

would be dispersed into open water columns or fine materials could migrate any substantial distance. All 

fill would be placed during winter frozen conditions. Discharges into ponds or flooded wetlands where 

the VSM piles would be placed would be solid frozen soils and ice. Excess material from auguring the 

VSM pile holes would be removed and disposed of at an off-site upland location.

With applicant design features and inclusion of special conditions, the proposed project would comply 

with this factor of the Guidelines.
D2.7.5 Actions Related to Technology (40 CFR 230.74) 

Discharges of dredged or fill material should be adapted to the needs of each site and sufficiently 

minimize adverse environmental impacts by use of appropriate equipment and machinery, maintenance, 

techniques, and design of roads and channel-spanning structures and culverts, and by methods of transport 

of the material to be discharged. 

The proposed project includes standard North Slope construction methods and machinery to transport, 

discharge, and spread the fill material in a manner that minimizes impacts to the aquatic environment. The 

design has been adapted to the needs of the fill sites to be minimized. Winter ice roads would be 

constructed parallel to an authorized surveyed road alignment, and frozen material would be dumped and 

spread with machinery designed to not disturb tundra waters and wetlands. Culverts are designed to pass 

stream flow and overland cross drainage in appropriate locations. Final cross-drainage culvert locations 

would be determined more precisely through field work, to better locate low-drainage areas.

Design and techniques to avoid and minimize impacts are found in ConocoPhillips 2017 (Applicant 

Proposed Mitigation Statements, Avoidance, Minimization, and Mitigation Measures). 

The proposed action uses best available technology, methods, maintenance, techniques, and timing to 

minimize adverse impacts caused to the aquatic environment. With inclusion of these measures and 

special conditions, the project complies with this factor of the Guidelines. 

D2.7.6 Actions Affecting Plant and Animal Populations (40 CFR 230.75) 

Minimization of adverse effects of discharges on populations of plants and animals can be achieved by 

avoiding changes in water currents and circulation patterns; selecting and managing discharge sites; 

avoiding unique habitats; and timing discharges to avoid biologically critical time periods. 

The proposed project includes measures to avoid or minimize impacts to aquatic flora and fauna by using 

existing infrastructure and reducing the size of fill areas and pipeline length. Wildlife surveys and habitat 

analyses, including aquatic site assessments, were used to identify and avoid sensitive fish and wildlife 

and unique habitats. Measures have been incorporated into the design and would be incorporated into 

construction elements to prevent or reduce erosion, slumping, runoff, and dust generation from fill areas. 

These can be found in ConocoPhillips 2017 (Applicant Proposed Mitigation Statements and the 

Avoidance, Minimization, and Mitigation Measures Table).

With inclusion of these measures and special conditions, the project complies with this factor of the 

Guidelines. 

D2.7.7 Actions Affecting Human Use (40 CFR 230.76)

Minimization of adverse effects on human use potential may be achieved by preventing damage to 

aesthetically pleasing features of the aquatic viewscapes; avoiding the more important aquatic areas; 

timing discharges to minimize adverse impacts to human use periods; and selecting sites to be compatible 

with human activities. Human use includes public water supplies, water recreation, and aesthetics 

associated with the aquatic ecosystem. The GMT1–GMT2 Access Road would connect with the CD5 

Road, which connects to the Nuiqsut Spur Road, allowing residents to travel further into the NPR-A for 

subsistence hunting and fishing (GMT2 Final Supplemental EIS, Section 4.4.4.2). Nuiqsut residents 

would be authorized to travel subject to coordination rules that provide for the safety of all users. 

The proposed project would be constructed along several aesthetically pleasing aquatic areas, including 

ponds, lakes, creeks, a river, and highly complex water and wetland vegetated sites. The proposed project 

would minimize adverse impacts to human use, to the extent practicable, by locating fill areas away from 
open waters. Preventive measures to avoid unnecessary ground disturbances and water pollution would 

protect the natural aesthetics of the project area. Lighting impacts would be reduced by using lowintensity lighting and shading externally facing building windows (GMT2 Final Supplemental EIS, 

Section 4.4.4.6). 

Mitigation measures to reduce impacts to recreational fishing and subsistence activities include measures 

to minimize impacts to fish and fish habitats, and to minimize noise. Facilities have been designed to 

minimize development and reduce impacts to drainage patterns, reduce impacts to higher value aquatic 

resources, and minimize disruption of caribou movement to protect recreational uses (GMT2 Final 

Supplemental EIS, Section 4.4.4.3). 

With inclusion of these measures, the proposed project complies with this factor of the Guidelines. 

D2.7.8 Other Actions (40 CFR 230.77)

This section includes actions to control runoff of water from fill areas and other discharges from activities 

to be conducted on the fill areas. 

The proposed project involves primarily linear impacts from construction of an access road where water 

runoff would be limited to each side of the narrow road fill. The largest fill area would be the drill site 

where other pollutants would be used in construction, drilling, equipment and vehicle operations, and 

maintenance operations. The activities and materials used for the project would be regulated by the State 

of Alaska for pollution prevention and control during drilling for hydrocarbons and production, as well as 

pipeline maintenance and operation, which would minimize the potential to pollute the fill or runoff to 

adjacent water and wetland areas.

With inclusion of these measures, the proposed project complies with this factor of the Guidelines. 
Attachment D3 

GENERAL POLICIES FOR EVALUATING PERMIT APPLICATIONS (33

CFR 320.4)

The analysis of impacts on the physical, chemical, human, and biological environment is contained in 

BLM’s GMT2 Final Supplemental EIS. The NEPA review of project impacts in the GMT2 Final 

Supplemental EIS also covers many public interest factors. 

D3. PUBLIC INTEREST REVIEW (33 CFR 320.4(a)(1))

The decision of whether to issue a permit will be based on an evaluation of the probable impacts, 

including cumulative impacts, of the proposed activity and its intended use on the public interest. The 

relevant factors are discussed below. 

D3.1 Conservation

Federal laws, EOs, and agency regulations and policy guidance frequently address the need for

conservation of natural resources. The USACE Regulatory Program, by authority, is focused on 

conservation of waters of the U.S., including wetlands. Responsibilities and evaluations for DA permit 

evaluation must include direct and indirect impacts caused by the authorized project. This can include 

many other natural resources. This action would result in negligible impacts to waters and wetlands, fish

and wildlife, vegetation, soils, air, land, minerals, subsistence plants and animals, and hydrocarbons. 

Conservation of natural resources is addressed in the following sections of this Attachment: cultural

resources in section D3.6, fish and wildlife resources in section D3.7, water and water supply in section 

D3.14, energy in section D3.16, and minerals in section D3.19. 

D3.2 Economics 

Although it is presumed, under the Corps’ permit regulations, that a private enterprise’s proposal is 

economically viable when a private enterprise makes an application for a DA permit, the district engineer

may make an independent review of the need for the project from the perspective of the overall public 

interest. In this instance, facility construction and drilling are expected to cost approximately $1.5 billion. 

These expenditures would increase economic activity at a state, borough, and local level to varying

degrees. The overall effect on the economies is expected to be relatively minor. Development of the 

GMT2 facility would create temporary jobs during construction. The peak workforce during each winter 

construction period for the proposed project is estimated at 700. The proposed project could have an 

indirect positive effect on local area employment through increased NSB and city tax revenues. It would 

also have a positive indirect effect through increased Kuukpik Corporation or ASRC dividends from 

increased revenues from project-related construction contracts, land use agreements, and royalties. Taxes

and royalties from oil sales, state corporate income taxes, property taxes, bed taxes, and other fees would

benefit the City of Nuiqsut, NSB, the State of Alaska, and Native corporations. The City of Nuiqsut is 

projected to benefit from increased bed tax revenue resulting from higher hotel occupancy during 

construction and operation phases of the proposed project. The State of Alaska receives lease sale 

revenues, royalties, and other revenues from oil production in the NPR-A. The State of Alaska and the 

NSB would receive property tax payments based on the assessed value of taxable oil infrastructure 

facilities estimated at approximately. Economic and sociocultural effects of past and present oil and gas 

activities have been both positive and negative. Completion of the Nuiqsut Spur Road would allow 

residents of Nuiqsut to travel via road to employment opportunities at Alpine or GMT1 and provide 

residents with improved access to subsistence resources. Further development within the Alpine Field, 
GMT1, and GMT2 would increase revenues for Kuukpik as a result of land use agreements and would 

benefit ASRC through oil and gas royalties. 

The proposed action would have beneficial effects on the Village, Borough, and State economies and 

employment opportunities. 

D3.3 Aesthetics 

Based on the analysis described in section 3.4.5.3 of the GMT2 Final Supplemental EIS, and with 

consideration for actions taken to minimize impacts, BLM determined that negative impacts to aesthetics 

would be moderate. Noticeable disturbances to visual resources in the aesthetic viewshed would likely be 

seen up to 2.5 miles from project developments (BLM 2018 § 4.4.4.6). 

Based on the analysis described in section 3.4.5.3 of the GMT2 Final Supplemental EIS, and with 

consideration for actions taken to minimize impacts, it is determined that impacts to aesthetics would be 

negligible.

D3.4 General Environmental Concerns 

Concerns that may be addressed under “general environmental concerns” include those not addressed in 

other sections of this document, such as subsistence, climate change, general health, air quality, noise, and 

prime and unique farmland and are addressed below: 

D3.4.1 SUBSISTENCE 

Primary impacts to subsistence and traditional use activities in the community of Nuiqsut include 

reducing the availability of subsistence resources, changing access to subsistence use areas (both positive 

and negative effects), hunter avoidance of industrial areas, and reducing overall community participation 

in subsistence activities.

These impacts could result in: increased investments in time, money, fuel, and equipment required to 

obtain subsistence resources; changes in hunting success; and changes in community cohesion. Access to 

subsistence harvest areas by road increases accessibility to some areas and may result in reduced 

investment costs to obtain some subsistence resources. Negative effects could also occur as a result of an 

oil spill depending upon the size and location of the spill. 

Nuiqsut residents would experience direct impacts to subsistence use areas, particularly areas used for 

harvesting caribou, geese, and furbearers. Project construction would result in the direct loss of 

subsistence use areas. The access road would be used by subsistence hunters and pullouts for safety and 

parking would be provided. Some impacts to winter fishing activities may also occur. Subsistence 

harvesters often avoid areas of development due to concerns about contamination and discomfort with 

hunting near human or industrial activity. However, the proposed project would also provide beneficial 

effects by increased year-round access to subsistence resource areas.

Subsistence activities play a very important role in the sociocultural environment of Nuiqsut. Adverse 

impacts to specific subsistence resources are important in context and a high concern to the local residents 

who rely on these resources for food supplies. 

Subsistence mitigation measures have been included in the design, construction, and operation of the 

proposed project to reduce impacts to subsistence resources and resource availability. Impacts to 

subsistence activities and resources are mitigated also through the BLM stipulations and BMPs. The 
applicant has also developed processes to consult with subsistence users on daily planned oil and gas 

activities to avoid interference with subsistence activities. 

Adverse impacts to subsistence resources and harvesters would be largest during the construction phase, 

particularly during the winter within the linear project areas. Summer construction activities at the culvert 

locations and drillsite would also affect subsistence resources and harvesters. Disturbances to fish and 

wildlife resources and harvesters would then diminish with the transition from construction to operations 

when traffic, noise, and construction activities are less. Access to subsistence hunting areas by Nuiqsut 

residents would increase with all-season roads provided by the applicant's GMT1 to GMT2 Access Road. 

More specific analysis is provided in Section 4.4.5 of the GMT2 Final Supplemental EIS. Based on this 

information impacts to subsistence activities are believed to be neutral.

D3.4.2 CLIMATE CHANGE 

The proposed activities within the Corps federal control and responsibility likely will result in a negligible 

release of greenhouse gases into the atmosphere when compared to global greenhouse gas emissions.

Greenhouse gas emissions have been shown to contribute to climate change. Aquatic resources can be 

sources and/or sinks of greenhouse gases. For instance, some aquatic resources sequester carbon dioxide 

whereas others release methane; therefore, authorized impacts to aquatic resources can result in either an 

increase or decrease in atmospheric greenhouse gas. These impacts are considered de minimis. 

Greenhouse gas emissions associated with the Corps federal action may also occur from the combustion 

of fossil fuels associated with the operation of construction equipment, increases in traffic, etc. The Corps 

has no authority to regulate emissions that result from the combustion of fossil fuels. These are subject to 

federal regulations under the Clean Air Act and/or the Corporate Average Fuel Economy (CAFE) 

Program. Greenhouse gas emissions from the Corps action have been weighed against national goals of 

energy independence, national security, and economic development and determined not contrary to the 

public interest. 

D3.4.3 GENERAL HEALTH 

Rapid modernization has led to significant changes in diet, housing, employment, and traditional culture 

of North Slope communities (BLM 2018 § 4.6.8.10). This has led to both positive and negative health 

changes. Positive health changes include an increase in life expectancy, a decrease in infant mortality and 

infectious disease rates, and improvements in health care services, public health programs, and municipal 

health infrastructure such as sanitation and water treatment facilities (BLM 2018 § 4.6.8.10). This same 

transition has also led to negative health outcomes, including increases in chronic diseases such as cancer, 

cardiovascular disease, and metabolic disorders, and increases in alcohol and substance misuse, suicide, 

violence, and other social dysfunctions (BLM 2018 § 4.6.8.10). 

Health-related air quality concerns in rural Alaska villages include diesel emissions, indoor air quality, 

road dust, solid waste burning, and wood smoke. Residents in the NSB have also expressed concern about 

air pollution generated by nearby oil and gas extraction activities (BLM 2018 § 3.4.7.1). Air pollution 

assessments have found pollutants in the vicinity of Nuiqsut to be below National Ambient Air Quality 

Standards ([NAAQS]; BLM 2018 § 3.4.7.1), and air monitoring data are not available to support claims 

that industrial development from oil and gas is contributing to air quality concerns. Instances of asthma 

and cancer are lower in North Slope communities than the statewide average (BLM 2018 § 3.4.7.1), 

despite higher rates of cigarette and smokeless tobacco use. Food security is of large concern to North 

Slope communities. While some communities report high rates of food insecurity, Nuiqsut is one of the 

most food-secure communities on the North Slope (BLM 2018 § 3.4.7). 
Direct and indirect impacts of oil and gas development on public health could include potential changes in 

diet and nutrition from the introduction of commercial food products, environmental exposures, infectious 

diseases due to an influx of non-local workers, safety, acculturative stresses, economic impacts, and 

changes in the capacity of local health care services (BLM 2018 § 4.4.6.1). 

D3.4.4 AIR QUALITY 

The proposed GMT2 Development Project will require air permits from the ADEC. The NPR-A is 

designated as unclassified under NAAQS and Alaska Ambient Air Quality Standards (AAAQS); however, 

the area is assumed to be in attainment including attainment of the particulate matter (PM) standards. Air 

quality is generally good, due to the few sources of both man-made and naturally occurring emissions and 

the dispersion by prevailing winds. West of the Colville River, existing emission sources include diesel 

fired generators, engines, heaters and vehicle traffic in Nuiqsut. The majority of housing in Nuiqsut is 

heated by natural gas and the primary power source is natural gas fired. Arctic haze generated in Europe 

and Russia is periodically observed. The applicant has collected criteria pollutant ambient monitoring data 

in Nuiqsut since 1999. This data was reviewed as needed by ADEC to support Alpine-related permitting.

Construction emissions would consist of fuel combustion related to heavy equipment used in site 

preparation and construction, smaller support equipment (such as heaters), and fugitive dust sources. 

Drilling emissions would run concurrently with a portion of the construction phase. During and after 

construction, electric power would be provided to the site from existing, off-site generation, which would 

limit total project site emissions.

Operational emissions would be low as few permanent stationary source emission units are proposed for 

installation after the completion of construction. Ongoing emissions would include a heater, fugitive dust 

from vehicle travel to transport workers and materials to the site, and minor fugitive emission of field gas 

from equipment and pipeline components. Production activities would also include periodic well 

interventions and potential well infill drilling which would require fuel fired heaters, boilers, engines, 

temporary storage tanks for flow back fluids, and additional mobile sources. 

Detailed analysis of Air Quality can be found in Section 4.2.3.2 of the GMT2 Final Supplemental EIS. 

The Corps finds that the effects of the project would be neutral. 

D3.4.5 NOISE 

Noise in the project area is described in terms of potential effects as unwanted sound resulting from 

project-related activities. Noise disturbance would result from two principal noise-generating sources: 

stationary and mobile activities. The acoustical environment is also subject to natural sounds caused by 

wildlife, wind, human activities, and flowing water (BLM 2018 § 3.2.3.6). 

Equipment operation for drilling and construction would contribute to increased levels of noise in the 

project area. The proposed GMT2 Development Project area is remote and sparsely populated, with few 

anthropogenic-derived sources of noise (USACE 2015). Proposed GMT2 Development Project activities, 

in addition to construction at GMT1, may result in temporary impacts to ambient noise levels in the 

project area.

Noise levels are anticipated to be consistent with other North Slope oil production facilities once 

production and development operations commence. As noted in BLM (2018 § 3.2.3.6,), human-caused 

noise emissions were attributable primarily to aircraft during 2016 field studies.
Based on these effects, and with consideration for actions taken to minimize impacts, overall impacts to 

noise are anticipated to be negligible. These impacts are within the range described and incorporated by 

reference in BLM (2004 § 4.2.3.3). Overall impacts to noise are anticipated to be minor. A summary of 

noise generated by the construction, drilling, and operation of the proposed project is provided in BLM 

(2018 § 4.2.3.3). 

D3.4.6 PRIME AND UNIQUE FARMLAND 

Federal agencies must consider adverse effects of their programs on the preservation of farmland and 

consider alternative actions, as appropriate, that could lessen such adverse effects. Based on information 

published by the Natural Resources Conservation Service, there are no designated prime and unique 

farmlands in the State of Alaska. The proposed project would have no adverse effects on prime and 

unique farmlands. 

D3.5 Wetlands 

The proposed project would involve placement of permanent fill in approximately 78 acres of wetlands. 

Descriptions and effects of this fill are discussed in Section D.4.2. With project design and permit 

conditions, the Corps finds that the effects of the project would be neutral. 

D3.6 Historic Properties 

There are no known historic properties, Alaska Heritage Resources Survey sites, or Traditional Land Use 

Inventory sites within the direct area of potential effect of the proposed project. Three Traditional Land 

Use Inventory sites are located within the 2.5-mile buffer, but are unlikely to experience any substantial or 

prolonged disturbance. Two more Traditional Land Use Inventory sites are located at the far northwestern 

margin of the 5-mile buffer and would experience minor, local, temporary noise and visual impacts (BLM 

2018 § 4.6.8.1, p. 511).

The GMT2 Final Supplemental EIS analysis resulted in a determination of “No Historic Properties 

Affected” (36 CFR 800.4[d][1]) under Section 106 of the NHPA. 

D3.7 Fish And Wildlife Values (33 CFR 320.4 (c))

Potential impacts by the proposed project on fish and wildlife values are discussed in sections D2.3.1, 

D2.3.2 and D2.3.3. 

The Corps finds that the project would not have adverse effects on fish and wildlife values. 

D3.8 Flood Hazards (33 CFR 320.4 (a)(1)) 

There are no streams along the GMT2 proposed road and pipeline corridor. There are no new stream or 

river crossings proposed for the GMT2 Development Project, although smaller, seasonally flooded areas 

would be crossed. The road is designed to maintain existing hydrology during flood periods. There are no 

human settlements or infrastructure within the potential upstream inundation area for the proposed project 

(BLM 2018, Map 4.2-2). 

With the project location outside of open water, project design to maintain natural drainage patterns and 

permit special conditions, the Corps finds that the effects of the project would be neutral. 
D3.9 Floodplain Values

There are floodplain values associated with the proposed actions. The land form and topography of 

project area is a coastal plain with very low reliefs. The project area’s floodplain’s most important value 

is for accommodating the passage of high water flows, and rehydration of wetlands, ponds, and lakes. 

With the proper positioning and maintenance of culverts, floodplain values would remain much the same 

and impacts would be minor. 

With the project location outside of open water, project design to maintain natural drainage patterns and 

permit special conditions, the Corps finds that the effects of the project would be neutral. 

D3.10 Land Use 

The proposed GMT2 drill site, road, and pipeline corridors are located on federal land and private land 

held by Kuukpik within the northeastern portion of the NPR-A (BLM 2018 § 3.4.5). The northern portion 

of the pipeline corridor between CD1 and CD4N is on land owned by the State of Alaska and managed by 

the Alaska Department of Natural Resources. Kuukpik owns land along the southern portion of the 

pipeline corridor between CD1 and CD4N and from CD4N to CD5 (BLM 2018 § 4.1.1). 

The NPRPA encourages oil and gas leasing in the NPR-A while requiring protection of important surface 

resources and uses (BLM 2018 § 1.3). The NSB would manage the rezoning process to declare the project 

area a Resource Development District via a Master Plan. Land owned by Kuukpik is designated for mixed 

use, including the oil and gas production facilities associated with the Alpine Field (BLM 2014 § 4.4.4). 

Each non-federal landowner has its own permitting or approval processes that provide for resource 

development and associated infrastructure development to be recognized as a land use for the site while 

also being protective of the overall environment and other potential surface use by local residents and 

wildlife. All future resource development land use would be subject to the permits and approvals process 

with federal, state, and local authorities.

With project design and permit special conditions, the Corps finds that the effects of the project would be 

neutral. 

D3.11 Navigation 

No navigable water ways exist within the project area. No crossing of potentially navigable streams or 

rivers are proposed for the GMT2 Development Project (BLM 2018 § 2.5.4.1). 

D3.12 Shore Erosion and Accretion 

Marine waters do not occur in the project area, and no direct impacts to the physical conditions or the 

processes within the estuarine or nearshore environments are expected. The project area is located more 

than 5 miles inland from the Beaufort Sea. Shoreline erosion and accretion in the project vicinity may 

occur on relatively small, shallow, inland freshwater ponds and lakes from windstorms. The proposed 

GMT2 Development Project would not impact these waters.

D3.13 Recreation 

Public recreational use in the project study area is low intensity and primarily limited to non-local visitors 

(BLM 2018 § 4.6.8.5) Public access to the project area is limited to those who access the community of 

Nuiqsut by aircraft landing at the Native Village of Nuiqsut airport or small, fixed-wing aircraft that can 

land on the tundra, and there are no developed recreation facilities within the NPR-A (BLM 2018 
§ 3.4.5.2). Activities that do not interfere with the NPR-A’s purpose are permitted by the BLM under 

special recreation permits. The identified locations for the GMT1–GMT2 pipeline and GMT2 pad are on 

wholly undeveloped land. 

Water-related recreation in the vicinity is low intensity and primarily represented by non-local visitors 

that float the Colville River between Umiat and Nuiqsut (BLM 2018 § 4.4.4.3). Potential effects of the 

proposed GMT2 Development Project on water-related recreation include the loss of area available for 

recreational activities and the loss of opportunities to experience wilderness-like values such as 

naturalness and solitude through changes in noise, visual aesthetics, dust, or odor. However, the project is 

not within a federally designated wilderness area, is not adjacent to an existing wilderness area, and does 

not include lands recommended for wilderness designation (BLM 2018 § 4.4.4.5). During winter 

construction for fill placement, the activity and noise would make the project more conspicuous for 

recreationists. Impacts to water-related recreation would be negligible. There are no designated or 

proposed Wild and Scenic Rivers located in the GMT2 Development Project area (BLM 2018 § 3.4.5.2). 

Refer to section D2.5.2 above for discussion regarding recreational fishing. 

The Corps finds that the project would have negligible effects on recreation.

D3.14 Water Supply and Conservation 

Water supply for the proposed GMT2 Development Project would come from local surface waters 

sourced during construction, drilling, and production. Ice chips and freshwater for construction would 

come from local lakes as permitted by State of Alaska regulatory agencies, primarily within the NPR-A. 

Water for ice road and pad construction, drilling, and potable water would be withdrawn from lakes in the 

vicinity of the project area as authorized with state temporary water use authorizations and state fish 

habitat permits. Large quantities of water for construction of ice roads and pads would be needed for 

winter construction. Drilling and operations would also require large quantities of fresh water. 

Construction (including construction and maintenance of ice roads and pads, and camp water usage) 

would occur over either two or three ice road construction seasons. The two-year schedule would require 

approximately 122.7 million gallons (MG) of fresh water in Year 1 and 116.3 MG in Year 2. The threeyear schedule would require approximately 65.8 MG of fresh water in Year 0, 61.6 MG in Year 1, and 

116.3 MG in Year 2. Drilling (including drilling needs, camp support, and miscellaneous requirements) 

would require approximately 19.8 MG per year, totaling 140.6 MG over 7.1 drilling years. Postconstruction operations (for a 2-acre ice pad every year after first oil) would require 0.5 MG per year, 

totaling 15 MG over 30 operation years. The approximate total water usage of the proposed project would 

be 395 MG for a two-year ice road construction schedule, or 400 MG for a three-year schedule. 

Freshwater would be required for domestic use at remote construction camps as well as for construction 

and maintenance of ice roads and pads. Potable water requirements are based on a demand of 100 gallons 

per day per person (estimated up to 100 people at a remote camp), totaling approximately 10,000 gallons 

per day during construction seasons. Freshwater may be used for hydrostatic testing.

The water use during the road and pipeline construction and drilling would put large demands on local 

freshwater sources. After completion of drilling, when full operations begin, the freshwater demand from 

local lakes would substantially reduce. When the pipeline is operational, produced water from the ACF 

would be delivered to the GMT2 drill site for use. Water withdrawals are regulated by the State of Alaska, 

limiting the amount of water removed from each withdrawal location so as to not adversely impact the 

resource. Ice chips are used from lake surfaces and water pumped from below the lake surface. The 

withdrawal areas would be recharged each year at breakup flooding periods. 
The Corps finds that the project would have no adverse effects on water supply and conservation. 

D3.15 Water Quality 

Potential impacts to water quality are discussed in sections D2 1.1.2, D2 1.2.4, and D2 1.2.8 above. 

With conditions on fill placement, containment, and indirect impacts caused by runoff siltation, dust, 

snow removal operations, and gravel spray from vehicle use, water quality would be maintained. 

The Alaska Department of Environmental Quality issued water quality certification on September 11, 

2018. 

With the project location outside of open water, project design to maintain natural drainage patterns and 

permit special conditions, the Corps finds that the effects of the project would be neutral. 

D3.16 Energy Conservation and Development 

The proposed project would require large amounts of fuel for the first 2 years of construction during 

gravel fill and pipeline infrastructure placement. Fuel is necessary to operate vehicles and heavy 

machinery, as well as aircraft, electric generators, and other equipment. As construction ends, less fuel is 

anticipated for drilling and operations needs. Drilling would require more fuel than the production phase, 

and small amounts of fuel would be needed to transport personnel for operations and maintenance work 

during the production phase (USACE 2015). Energy needs of the proposed GMT2 Development Project 

would be powered via the existing Alpine electrical power system, using power lines suspended from 

pipeline horizontal support members via messenger cable. The on-site drill rig would be fueled by ultralow sulfur diesel until a permanent GMT2 power supply is commissioned. 

The NPRPA directs the U.S. Department of the Interior to undertake “an expeditious program of 

competitive leasing of oil and gas” in the NPR-A. The GMT2 Development Project helps satisfy the 

purpose to develop oil and gas resources in the NPR-A. The GMT2 Development Project would produce 

three-phase hydrocarbons (oil, gas, and water) that would be carried by pipeline to the ACF at CD1. 

Sales-quality crude oil produced would be transported from CD1 via the existing Alpine Sales Oil 

Pipeline and Kuparuk Pipeline to the Trans-Alaska Pipeline for shipment to market (BLM 2018 § 1.3). 

Development and production of hydrocarbons from GMT2 would produce resources needed to help meet 

U.S. domestic energy demand. Development would also help offset declines in production from the 

Alaska North Slope, as well as providing other economic benefits (BLM 2018 § 1.3). The amount of fuel 

consumed for the proposed project is not expected to cause shortages to local or regional communities 

(USACE 2015). 

Crude oil from ancient geologic formations underground would be produced by the proposed project for 

business profits for approximately 30 years to supply the U.S. domestic raw hydrocarbon market. Crude 

oil energy resources would not be conserved but would be extracted by the latest technological methods 

to obtain all recoverable oil. No energy conservation of crude oil would occur. Substantial quantities of 

energy resources would be developed.

The Corps finds that the project would have a beneficial effect on energy conservation and development. 

D3.17 Safety 

Industrial oil and gas construction, drilling, and operational activities in the Arctic can be hazardous to 

humans due to extreme weather conditions (e.g., cold, wet, dark, windy), machinery operations, 
transportations, wildlife, and other factors. The Applicant would follow safety precautions to ensure safe 

conditions for all employees, contractors, and visitors. Construction and operational activities would 

follow standard North Slope safety practices, as outlined in the 2018 Alaska Safety Handbook and 

Applicant internal policies. The Applicant would provide employees with safety training and frequent 

safety meetings.

Providing safe conditions for facility users includes construction of an all-season access road connection 

between the drill site and the emergency response facilities available at the ACF. Facilities at the ACF 

include medical emergency response equipment and personnel, fire and hazardous material response and 

personnel, and other hydrocarbon spill and emergency response equipment and personnel. Ground access 

would allow transport for lifesaving or medical evacuation of on-site personnel.

The access road would provide for pipeline or well control incidents to deploy personnel and equipment 

to the drill site. The orientation of the gravel access road near parallel to the production pipeline would 

facilitate pipeline inspection, providing a more rapid detection of leaks or other problems that could cause 

a spill incident.

The Corps finds that the project would have neutral effects on safety.

D3.18 Food and Fiber Production 

Frozen soils and limited growing seasons in Arctic climates are not conducive to food and fiber 

production. Soils are saturated, and no forests or agricultural lands are present in the proposed project 

area. There is no commercial cultivation of food or fiber across the Arctic Coastal Plain, although 

subsistence activities such as harvesting wild plants and berries do occur. 

The Corps finds that the project would have neutral effects on food and fiber production.

D3.19 Mineral Needs 

The proposed GMT2 Development Project would require large quantities of gravel mineral materials and 

sand to construct the drill pad and access road and place pipeline VSMs. The existing ASRC Mine Site 

would serve as the proposed project’s gravel source. Approximately 671,300 cubic yards of gravel would 

be needed to construct the proposed pads and access road (BLM 2018 § 4.3.2.1) with an additional 3,000 

cubic yards of sand/slurry mixture needed to support pipeline VSM infrastructure. The ASRC Mine Site is 

not known to be contaminated and has been used as a resource for recent infrastructure projects in the 

local area, including CD5, the Nuiqsut Spur Road, and GMT1, which began construction in February 

2017 (BLM 2018 § 2.4.6). 

The proposed project has been minimized to construct the development footprint with the least amount of 

mineral resources, as it reduces project costs and environmental impacts. ASRC maintains an existing 

USACE permit (POA-1996-869-M11, independent of this proposed project) and is responsible for 

reclamation of the gravel extraction site based on its permit. 

The Arctic Coastal Plain is largely composed of sand and gravel alluvium. The proposed project would 

not provide for mineral needs of others; it would only consume them for fill area construction. The 

material could be retrieved and reused for similar purposes if and when the proposed project became 

abandoned. The Corps finds that the project would have negligible adverse effects on mineral needs.
D3.20 Considerations of Property Ownership 

Authorization of work or structures by USACE does not convey a property right, nor authorize any injury 

to property or invasion of other rights. 

The Applicant is responsible for acquiring authorizations from all property owners for work associated 

with the GMT2 Project. 

The Corps finds that the proposed GMT 2 project would be consistent with land use on the North Slope, 

provided the applicant obtains and adheres to all property owner stipulations. 

D3.21 Needs and Welfare of the People 

Development and production of hydrocarbons from GMT2 would produce resources needed to help meet 

U.S. domestic energy demand. Development would also help offset declines in production from the 

Alaska North Slope and provide benefits to local, state, and national economies through local hire for jobs 

created during construction and operations, tax revenues, revenue sharing, and royalties to the federal 

government and Alaska Native Claims Settlement Act corporations (BLM 2018 § 1.3). Impacts to NVN 

and subsistence are discussed above at D3.4.1. 

The Corps finds that the effects of the project would be neutral to the needs and welfare of the people. 

D3.22 Recommended Public Interest Determination 

The public need is for the development of facilities that can produce petroleum products that are used 

across the nation, and for the economic benefits generated by tax revenues from labor and purchases of 

goods and services necessary for the proposed construction. The private need for the proposed project is 

for the economic benefit of the applicant which would result from the petroleum production that would 

occur at the proposed project as well as for the economic benefit of the private landowners within the 

proposed project area. There are no unresolved conflicts as to resource use. Practicable alternatives are 

evaluated in Section D2.1, above. As discussed above, the project area is suited to the public uses of 

recreation and subsistence. The area has also been designated for use in oil and gas development, which is 

being proposed by a private applicant. The benefits resulting from the proposed project, namely the 

production of oil and gas, would last as long as the underlying petroleum resource remained productive. 

The detrimental effects of the proposed discharges of fill would be long term to permanent within the 

footprint of the proposed project. If the development is ever closed, then the permittee would be required 

to restore areas to their previous conditions. The proposed project would result in the long term to 

permanent loss of the functions and values, including recreation and subsistence, which are provided by 

the existing wetlands and waters in the project area. 

Based on the public interest review herein, and inclusion of the above special conditions on the DA 

permit, the beneficial effects of the project outweigh the detrimental effects on the public interest. The 

project is not contrary to the public interest. 
ATTACHMENT D4

COMPLIANCE WITH

ENVIRONMENTAL REQUIREMENTS 

D4.1 Clean Water Act (33 U.S.C. 1341) Section 401 Certificate of Reasonable 

Assurance (33 CFR 320.4[D]) 

The ADEC issued a conditioned 401 Water Quality Certification for the placement of the fill material for 

the Applicant's proposed Project on September 11, 2018 (Alternative A, described in our Public Notice); 

see Attachment B6 -- State of Alaska Certificate of Reasonable Assurance for the GMT2 project.

D4.2 Coastal Zone Management Consistency Determination (33 CFR 320.4[H]) 

By operation of Alaska State law, the federally approved Alaska Coastal Management Program expired on 

July 1, 2011, resulting in a withdrawal from participation in the Coastal Zone Management Act’s (CZMA) 

National Coastal Management Program. The CZMA federal consistency provision, section 307, no longer 

applies in Alaska. Federal Register Notice published July 7, 2011, Volume 76, No. 130, page 39857. 

D4.3 Endangered Species Act of 1973 (16 U.S.C. 1531) 

Impacts to endangered species and the outcome of consultation with the USFWS are discussed under 

Subpart D (Attachment D2.3 and Attachment D6, and Section 4.3.6 of the GMT2 Final Supplemental 

EIS).

A Biological Opinion that the action “may affect, but is not likely to adversely affect listed species or their 

critical habitat” was provided by the USFWS to the BLM and Corps. The Department of the Army permit 

would be conditioned to require compliance with all of the mandatory terms and conditions associated 

with incidental take of the BO.

ESA consultation is complete. 

D4.4 Fish and Wildlife Coordination Act (16 U.S.C. 661) 

Coordination with the USFWS, NMFS, and ADF&G, and completion of the process and analyses 

contained within the JROD and signature by the authorizing official completes the Corps’ Fish and 

Wildlife Coordination Act responsibilities.

D4.5 Magnuson-Stevens Fishery Conservation and Management Act (Public Law 

94-265) 

No marine or estuarine essential fish habitat impacts are probable based on the scope of the proposed 

action. Further discussion is found in Appendix E of the GMT2 Final Supplemental EIS.

Signature of this JROD by the authorizing official completes the Corps’ responsibilities under this act.

D4.6 National Environmental Policy Act of 1969 (42 Usc 4321 – 4347) 

Signature of this JROD by the authorizing official completes the Corps’ NEPA requirements and

responsibilities.
D4.7 NATIONAL HISTORIC PRESERVATION ACT OF 1966 (16 USC 470 ET 

SEQ.) 

Completion of consultation with the Alaska Office of History and Archaeology and signature of the 

Programmatic Agreement completes the Corps’ NHPA requirements. 

D4.8 Clean Water Act (33 U.S.C. 1251 et seq. 404[B][1] Guidelines 40 CFR 230 

Subpart B)

Completion of the process and analysis contained within the JROD (Attachment D2) completes the 

Corps’ 404(b)(1) requirements.

D4.9 Clean Water Act (33 U.S.C. 1251 et seq.) Section 404 (33 U.S.C. 1344) 

Completion of the process and analysis contained within the JROD and signature by the authorizing 

official completes the Corps’ CWA 404 requirements. 

D4.11 Marine Mammal Protection Act of 1972 (16 U.S.C 1361 et seq., 1401-1407, 

1538, 4107) 

The Proposed Action does not involve the transport of dredged material for disposal or any construction 

in marine waters. 

D4.12 Executive Order 13175 Consultation and Coordination with Indian Tribal 

Governments 

This EO was designed to establish regular and meaningful consultation and collaboration with tribal 

officials in the development of federal policies that have tribal implications and to strengthen the U.S. 

government-to-government relationships with Indian tribes. 

A summary of consultation efforts by the BLM is included in the GMT2 Final Supplemental EIS Section 

5.1.2 (Tribal Consultation) and pages 21-22 of the JROD.

The Corps received one comment letter from the Native Village of Nuiqsut during the public notice 

period. The Corps is a Cooperating Agency to the BLM, which is the Lead Federal Agency. The BLM 

held a community meeting in Nuiqsut, and coordinated with NVN frequently during the Government-toGovernment (G2G) consultation process. NVN, as a Cooperating Agency, participated with the Corps in 

multiple Cooperating Agency meetings. A request for a face-to-face meeting or other direct coordination 

between the Corps and NVN was not made.

Consultation with federally recognized Tribes and completion of the process and analysis contained 

within this document and signature by the authorizing official completes the Corps’ Executive Order 

13175 requirements. 

D4.13 Clean Air Act (42 U.S.C. 7401 – 7671 Section 176[C]) 

The proposed permit action has been analyzed for conformity applicability pursuant to regulations 

implementing Section 176(c) of the Clean Air Act. It has been determined that the activities proposed 

under this permit would not exceed de minimis levels of direct or indirect emissions of a criteria pollutant 

or its precursors and are exempted by 40 CFR Part 93.153. Any later indirect emissions are generally not 

within the Corps’ continuing program responsibility and generally cannot be practicably controlled by the 

Corps. 
D4.14 Executive Order 12898 (Environmental Justice) 

The community of Nuiqsut, as discussed in Section 3.3.2.4, meets the demographic characteristics to be 

qualified as a minority population, and requires evaluation for disproportionate impacts under 

environmental justice. Specific impacts to this population are discussed in pages 21-22 of the JROD and 

GMT2 Final Supplemental EIS sections 3.4.8 and 4.4.7. 

Stipulations in the Federal leases and BMPs avoid or mitigate many of these impacts. Relevant 

stipulations include, but are not limited to, those that require ready access to spill cleanup materials, 

minimization of flights in the project area during the peak caribou hunting period, spill response training, 

the separation distance between roads and pipelines (reducing the potential of the combined facilities to 

obstruct caribou movement), and consultation with subsistence users. 

In accordance with Title Ill of the Civil Right Act of 1964 and Executive Order 12898, it has been 

determined that the project would not directly or through contractual or other arrangements, use criteria, 

methods, or practices that discriminate on the basis of race, color, or national origin nor would it have a 

disproportionate effect on minority or low-income communities. 

Completion of the process and analysis contained within this JROD and GMT2 Final Supplemental EIS 

and signature by the authorizing official completes the Corps Executive Order 12898 requirements. 

D4.15 Executive Order 11988 (Flood Plain Management) 

See Attachment D3, Section D3.9. The Proposed Action would not be constructed in designated

floodplains and would not create flood hazards in floodplains. Completion of the process and analysis 

contained within this JROD and signature by the authorizing official completes the Corps Executive 

Order 11988 requirements.

D4.16 Executive Order 13112, Invasive Species 

BLM requirement Best Management Practice (BMP) M2 requires that measures to be taken to prevent the 

introduction, or spread, of non-native, invasive plant species in NPR-A.

Completion of the process and analysis contained within this JROD and signature by the authorizing 

official completes the Corps Executive Order 13112 requirements.

D4.18 Other Federal, State and/or Local Authorizations (if issued)

ADEC – Certificate of Reasonable Assurance (POA-2015-486) 

Date Issued: 9/11/2018

Conditions for issuance: Yes

D4.19 Significant National Issues (33 CFR 325.2[A][6]) 

Corps’ regulations state that if a district engineer makes a decision on a permit application that is

contrary to State or local decisions, the district engineer will include in the decision document the 

significant national issues, and explain how they are overriding in importance.

This decision document and final decision are not contrary to State or local decisions, and there are no 

significant issues of overriding national importance. 
ATTACHMENT D5 

MITIGATION (33 CFR 320.4(r)) 

The Corps has responsibility to consider mitigation (which includes avoiding, minimizing, rectifying, 

reducing, or compensating for resources losses) throughout the permit application review process. 

Mitigation requirements fall into three categories, per 33 CFR 320.4(r): 

1. Project modifications to minimize adverse project impacts;

2. Mitigation measures to ensure compliance with the 404(b)(1) Guidelines; and,

3. Measures required to ensure that the project is not contrary to the public interest, to the extent 

they are reasonable and justified.

“All compensatory mitigation will be for significant resource losses which are specifically identifiable, 

reasonably likely to occur, and of importance to the human or aquatic environment.” (33 CFR 320.4 

R(2))

The placement of sites for construction of the project have been chosen by surveying the topography, 

water drainages, and surface waters to avoid and minimize the effects of the fill material, including 

smothering of aquatic organisms. The route of the access road, location of the drill site pad, and culverts 

have been located to avoid open water and designed to maintain natural drainage patterns. Due to the 

abundance of wetlands in the project area, avoiding discharges into WOUS is not practicable.

Specifically, avoidance and minimization measures include: 

1. Designing the GMT2 Development Project so that all power lines and communication cables 

will be hung underneath the horizontal support members via messenger cables to avoid the 

need to install power poles, thereby eliminating the potential impact to vegetation and 

wetlands for this aspect of the project’s infrastructure.

2. Using existing infrastructure to the maximum extent practicable.

3. Using ice roads and pads for construction and drilling activities and limiting construction to 

the winter season.

4. Avoiding locations having unique habitat or other value, including critical habitat of 

threatened or endangered species. 

5. Relocating the GMT2 road and drill site out of the Colville River Special Area and avoiding 

the Fish Creek setback.

6. Avoiding river and stream crossings.

The project has avoided and minimized impacts to the extent practicable. 

The GMT2 project would result in the unavoidable loss of 78 acres of wetlands, spanning both the Outlet 

Fish Creek and Ublutuoch River watersheds. A 10 digit Hydrologic Unit Code (HUC) size was utilized 

for watershed analysis. No anthropogenic impacts have occurred in the Outlet Fish Creek watershed. 

Existing and quantifiable anthropogenic impacts have occurred in the Ublutuoch River watershed as a 

result of the previously permitted and constructed GMT1 project. Accounting for this existing 

disturbance, and including both direct and indirect impacts from the GMT2 project, total anthropogenic 

disturbance would be 0.34% of the Outlet Fish Creek watershed and 0.23% of the Ublutuoch River 

watershed. See Table 1, below. 
Table 1. Total Anthropogenic Disturbance in Subject Watersheds.

Subject Watersheds

Hydrologic Basin

1906020507

Outlet Fish Creek

1906020506-

Ublutuoch River

Total Watershed Area 137,576 acres 150,954 acres

Aquatic Resource Coverage 135,486 acres 150,938 acres

Existing Impervious Cover 0 acres 42 acres 

GMT2 Direct Impact to Watershed 52.3 acres1 (0.04%) 25.6 acres1 (0.02%)

GMT2 Indirect Impact to watershed 413.16 acres 275.52 acres

Cumulative Anthropogenic Disturbance 

w/ GMT 2

465.9 acres (0.34%) 343.12 acres (0.23 %)2

1 Approximate footprint per watershed

2 Includes 42 acre existing impervious cover (GMT1) 

In addition to evaluating the anthropogenic disturbance in the proposed GMT2 watersheds, the Corps 

considered the following:

• The watersheds do not have indicators of being degraded (i.e. impaired, listed under CWA 303(d) 

or identified in a watershed management plan). 

• The wetlands within the proposed project areas are not rare on the North Slope or within the 

Arctic Coastal Plain. 

• Designated critical habitat for the Polar Bear exists within the action area, but the GMT2 project 

footprint itself is located approximately 4 miles southwest of the nearest designated critical 

habitat (USFWS 2018 Figure 9) and will not directly impact it. 

• The project does not involve the placement of fill in intertidal waters associated with special 

aquatic sites.

• No anadromous waters will be impacted by the project. One fish bearing lake, M9925, has a 

small unnamed beaded drainage stream which will be crossed with a culvert designed for passage 

of ninespine stickleback (2018 BLM FSEIS). This impact will not be more than minimal.

• The project is not federally funded, so compensatory mitigation is not required under Executive 

Order 11990. 

• Measureable changes in aquatic resource functions would not occur as a result of individual or 

cumulative impacts. 

Based on consideration of the above information, including the 404 (b)(1) guidelines, public interest 

review factors, avoidance and minimization measures, and compliance with other environmental laws, the 

Corps has determined that the project would not result in significant resource losses that are specifically 

identifiable, reasonably likely to occur, and of importance to the human or aquatic environment. 

Although the project would result in the loss of 78 acres of wetlands, the work would result in minimal 

loss of aquatic function, with the inclusion of avoidance and minimization measures, including controls to

minimize effects, such as best management practices (BMPs) and permit conditions. Based on this 

information, the Corps has determined that mitigation in the form of avoidance and minimization (including 

special conditions and BMPs) is sufficient and compensatory mitigation is not required. 
APPLICANT REQUESTED MITIGATION

As stated in the regulations at 33 CFR 320.4(r), the Corps may include additional mitigation measures at 

the applicant’s request. The applicant has requested the Corps include, as a special condition to the 

permit, a project to help restore stream flow at an existing culvert bank located south of the City of 

Nuiqsut, North Slope Borough, Alaska. The Corps has included the mitigation plan as a special condition 

of the permit, which is included as Attachment D5.1. 

GREATER MOOSES TOOTH TWO (GMT2) 

DEVELOPMENT PROJECT PERMITTEE 

RESPONSIBLE WETLANDS MITIGATION PLAN 

NATIONAL PETROLEUM RESERVE-ALASKA 

Prepared for: 

ConocoPhillips Alaska, Inc. 

Anchorage, AK 

August 2018
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Wetlands Mitigation Plan 

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i August 2018 
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TABLE OF CONTENTS 

Section Page

1.0 INTRODUCTION..............................................................................................................1

2.0 OBJECTIVES ....................................................................................................................1

3.0 SITE SELECTION ............................................................................................................2

3.1 Watershed Needs .....................................................................................................2

3.2 Onsite Alternatives...................................................................................................3

3.3 Other Restoration Alternatives or Land Preservation Opportunities .......................3

3.4 Practicability of Results Being Ecologically Self-Sustaining ..................................3

4.0 SITE PROTECTION INSTRUMENT ............................................................................3

5.0 BASELINE INFORMATION...........................................................................................3

5.1 GMT2 Baseline Information ....................................................................................3

5.2 Fresh Water Road Restoration Site Baseline Information .......................................5

6.0 MITIGATION CREDIT .................................................................................................10

7.0 MITIGATION WORK PLAN........................................................................................10

7.1 Fresh Water Road Restoration Work Plan .............................................................10

8.0 MAINTENANCE PLAN.................................................................................................11

9.0 PERFORMANCE STANDARDS...................................................................................11

10.0 MONITORING PLAN ....................................................................................................11

11.0 LONG-TERM MANAGEMENT ...................................................................................11

12.0 ADAPTIVE MANAGEMENT .......................................................................................11

13.0 FINANCIAL ASSURANCE ...........................................................................................11

14.0 REFERENCES.................................................................................................................12

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APPENDICES 

Appendix 

Appendix A – Figures 

Appendix B – HDL 2016 Project Analysis Report 

Appendix C – Letter Agreement Between CPAI and NSB 

Appendix D – ABR GMT2 Wetlands Delineation 

Appendix E – ANSRAM Data Sheets and Debit-Credit Calculation 

TABLES 

Table 1.- GMT2 Baseline FCI Scores 4

Table 2.- Post GMT2 FCI Scores 5

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ACRONYM LIST 

ABR ABR, Inc.- Environmental Research & Services

ANSRAM Alaska North Slope Rapid Assessment Method 

ASA Aquatic Site Assessment 

ASRC Arctic Slope Regional Corporation 

CPAI ConocoPhillips Alaska, Inc. 

DA Department of the Army 

FCI Functional Capacity Index 

GMT 2 Greater Mooses Tooth 2 

HDL Hattenburg Dilley & Linnell 

HUC Hydrologic Unit Code 

NSB North Slope Borough 

NWI National Wetland Inventory 

PRM Permittee Responsible Mitigation

USACE U.S. Army Corps of Engineers 

USFWS United States Fish and Wildlife Service

WOUS Waters of the U.S. 

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1.0 INTRODUCTION 

ConocoPhillips Alaska, Inc. (CPAI) is seeking a Department of the Army (DA) permit 

authorization from the U.S. Army Corps of Engineers (USACE) to construct the Greater 

Mooses Tooth Two (GMT2) development project, consisting of a drill site, access road, 

pipelines, and ancillary facilities to support development of petroleum reserves within the 

Greater Mooses Tooth Unit. The proposed work involves the placement of clean fill 

material on 78.1 acres, 77.9 acres of which are Waters of the U.S. (WOUS). A Vicinity 

map showing the location of the GMT2 Project is included in Appendix A, Figure 1. 

2.0 OBJECTIVES 

The overall objective of this Permittee Responsible Mitigation (PRM) plan is to

demonstrate how CPAI proposes to mitigate for unavoidable wetlands impacts at GMT2

through permittee responsible wetlands restoration. In addition to the avoidance and 

minimization measures incorporated into the design of GMT2, the proposed restoration

project presented in this PRM plan provides wetlands uplift near the GMT2 project site.

The mitigation project will restore important key functions to a riverine wetland system

associated with a fresh water access road (Fresh Water Road) in Nuiqsut, Alaska. In 

addition, the project will provide safe and continuous access to Nuiqsut’s fresh water

supply reservoir. Safe and continual access to the reservoir is currently jeopardized by 

recurring flooding and road damage that occurs during breakup. 

The current culvert battery crossing associated with the Fresh Water Road is undersized, 

resulting in ice damming and road over-topping during spring breakup flood events. The

gravel road prism over the culverts has been significantly damaged from the over-topping 

and is contributing to gravel deposition and excess sediment load to the riverine system.

The undersized culverts and altered flows contribute to degraded aquatic function and alter 

the system’s hydrologic and sediment transport functions. 

The Fresh Water Road restoration project will restore important key riverine wetland 

function to 35.8 acres (0.30 acres more than currently exists) of lower perennial stream and 

abutting palustrine wetlands, as well as alleviate ice damming associated with annual

breakup discharges. This functional uplift will be achieved through restoring natural flows 

by: 1) upgrading the crossing to reflect normal flow conditions to restore flood flow 

alteration function and improve general habitat suitability; 2) removing gravel that has 

washed downstream to improve sediment removal function and afford vegetation growth;

and 3) elevating the road crossing above anticipated spring breakup flood elevations to 

protect from road washouts during breakup. This restoration project would provide direct 

benefit to a resident fish bearing stream and abutting wetlands that discharge directly to the 

Nigliq Channel of the Colville River. These improvements would protect a crucial Nuiqsut 

transportation corridor providing access to Nuiqsut’s fresh water supply. A Restoration 

Site Overview Map is included in Appendix A, Figure 2. 

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3.0 SITE SELECTION 

The proposed Fresh Water Road restoration site is in the village of Nuiqsut, Alaska, and is 

identified on the Vicinity Map (Figure 1) and Overview Map (Figure 2) in Appendix A. 

The North Slope Borough (NSB) contracted Hattenburg, Dilley, and Linnell (HDL) to

complete a Project Analysis Report (PAR) (Appendix B) for the crossing in 2016 (HDL 

2016). HDL reported that the crossing appears within the floodplain of the Colville River 

and that it has undersized culverts which result in the roadway getting over-topped during 

high spring breakup flows. 

The factors considered during the mitigation site selection process include the following: 

 Watershed and community needs; 

 Onsite alternatives; 

 Other restoration alternatives or land preservation opportunities near the 

watershed; and 

 Practicability of accomplishing an ecologically self-sustaining mitigation 

project. 

3.1 Watershed Needs 

The GMT2 impacts occur along the drainage divide between the following 10-digit 

Hydrologic Unit Code (HUC) watersheds: 

 1906020507 - Outlet Fish Creek 

 1906020506 - Ublutuoch River 

The Outlet Fish Creek watershed occupies 137,576.89 acres, and the Ublutuoch River 

watershed occupies 150,954.37 acres. The GMT2 project will impact 52.3 acres of 

wetlands in the Outlet Fish Creek, and 25.6 acres of wetlands in the Ublutuoch River 

watersheds, for a total of 77.9 acres of wetlands impacts. These two watersheds contain

very little current development and are made up almost entirely of jurisdictional WOUS, 

including wetlands. The total current development and proposed GMT2 development in 

these watersheds will be 88.9 acres and 90.1 acres, respectively (Figure 3, Appendix A). 

This is equivalent to 0.06 percent total anthropogenic impacts in each of the 10-digit HUCs; 

therefore, these watersheds are not considered impaired. 

The proposed restoration project is in the adjacent Colville River Delta-Frontal Harrison 

Bay watershed (HUC-1906030413). This watershed occupies 303,614.25 acres and 

contains the village of Nuiqsut and the gravel infrastructure development associated with

the village, transportation corridors, and gravel mining. The immediate area around 

Nuiqsut and the mitigation project site drain to the Nigliq Channel of the Colville River, 

an important subsistence resource for the area. CPAI has consulted the NSB to discuss the

needs of Nuiqsut and the importance of completing this project. The proximity of the

mitigation site to Nuiqsut creates an opportunity to provide wetlands and water-related 

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benefits to the community that is nearest to the GMT2 project and to wetland and water 

resources used by the community. A copy of the letter agreement documenting CPAI’s 

discussions with the NSB is provided as Appendix C to this Mitigation Plan. 

3.2 Onsite Alternatives 

Mitigation opportunities at the GMT2 project site were considered, but the lack of 

development in the abutting and adjacent wetlands affords no opportunities for wetlands 

restoration, or creation onsite or in the same watershed. As shown on Figure 3 (Appendix 

A), these two watersheds would only have 0.06 percent anthropogenic impacts from 

development after GMT2 is constructed. 

3.3 Other Restoration Alternatives or Land Preservation Opportunities 

Other options were explored but nothing was identified that had a similar combination of 

proximity to the GMT2 project area, actual wetlands functional uplift, positive community

impact and community support, and economic practicability. Land preservation 

opportunities were explored but are very limited, provide no wetlands uplift, are

commercially complex, and lack the broad support of a restoration program. 

3.4 Practicability of Results Being Ecologically Self-Sustaining 

The proposed improvements to the Fresh Water Road will follow acceptable practices of 

arctic engineering and design. Regular monitoring, coupled with routine maintenance 

activities and returning the riverine system to normal flows, will result in an ecologically

self-sustaining restoration project. 

4.0 SITE PROTECTION INSTRUMENT 

CPAI has discussed this mitigation project with the NSB. CPAI does not own the land 

proposed for restoration activities and does not have the ability to establish a perpetual 

protection instrument. The site is managed by the local government (NSB). The mitigation

project does not face threats that are deemed to require site protection beyond the 

stewardship provided by the NSB. 

5.0 BASELINE INFORMATION 

5.1 GMT2 Baseline Information 

ABR, Inc. - Environmental Research & Services (ABR) performed wetlands habitat 

mapping for the GMT2 project and submitted that information to CPAI in a July 2017 

wetland delineation and desktop mapping verification report (ABR, 2017). The ABR report 

(Appendix D) contains detailed wetlands mapping and habitat descriptions for the proposed 

GMT2 impact area, which is included in a larger immediate study area investigated by 

ABR. 

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ABR reported that the GMT2 study area contains typical tundra habitats composed of

dwarf shrub and emergent vascular plants within saturated and seasonally flooded 

palustrine wetlands. The study area also comprises two shallow open-water pond systems 

with poor littoral zones. ABR stated that the pond systems are likely remnants of drained 

lake basins, which are prevalent on the North Slope. 

The ABR report concludes that the GMT2 project will impact 77.8 acres (rounded to the

nearest 0.1 acre) of palustrine wetlands and a 0.1-acre pond habitat for a total of 77.9 acres 

of jurisdictional WOUS impacted. ABR reports that the GMT2 project will also impact 0.2 

acres of non-jurisdictional uplands. 

CPAI performed an Aquatic Site Assessment (ASA) based on the Arctic Slope Regional 

Corporation (ASRC) Alaska North Slope Rapid Assessment Method (ANSRAM) for each 

wetlands class impacted by the GMT2 project to determine the baseline level of functional

capacity and the post-project impacts to those watershed functions after GMT2 is 

constructed. ANSRAM determined that the key functions being provided by the wetlands 

prior to constructing GMT2 are: 

 Flood flow alteration; 

 Nutrient and toxicant removal; 

 Production of organic matter and its export; 

 General habitat suitability; and

 Native plant richness. 

The overall baseline Functional Capacity Index (FCI) score for each wetland class is shown 

below in Table 1. 

Table 1. GMT2 Baseline FCI Scores 

Wetlands Class FCI Score Acres 

PEM1F 0.781 4.3 

PEM1SS1B 0.682 49.8 

PEM1SS1E 0.799 23.7 

PUBH 0.814 0.1 

0.0 = Low Functional Capacity/ 1.0 = High Functional Capacity 

The overall FCI scores determined by ANSRAM for each wetlands type after GMT2 

construction are shown below in Table 2. The FCI scores indicate that while permanent 

gravel will be placed for the construction of GMT2 and result in reduced wetland function, 

the loss of function in the watershed will be partial rather than total because of the 

minimization measures incorporated into the GMT2 project, such as culverts to preserve

water flow and sufficient gravel to minimize thermokarsting. 

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Table 2. Post GMT2 FCI Scores 

Wetlands Class FCI Score Acres 

PEM1F 0.618 4.3 

PEM1SS1B 0.542 49.8 

PEM1SS1E 0.677 23.7 

PUBH 0.710 0.1 

0.0 = Low Functional Capacity/ 1.0 = High Functional Capacity 

Copies of the ANSRAM data sheets showing the individual evaluation metrics and the 

individual FCI for each function are included in Appendix E. 

5.2 Fresh Water Road Restoration Site Baseline Information 

A formal wetland delineation has not been completed for the Fresh Water Road restoration

site. The wetlands proposed for restoration were delineated from the desktop using United 

States Fish and Wildlife Service (USFWS) National Wetland Inventory (NWI) mapping

(USFWS, 2017). NWI mapping was further adapted using current aerial photography and 

information contained within the 2016 PAR. The extent of the desktop mapping is depicted 

in Appendix A, Figure 2. 

The desktop delineation indicates the Fresh Water Road restoration site currently consists 

of 35.5 acres of lower perennial riverine habitat (mapped to 20 foot above mean sea level), 

with palustrine emergent littoral zones and inclusions (R2EM2/UBH). The upstream

portion of the system is delineated to the approximate extent of estimated maximum annual

breakup flooding elevation presented in the 2016 PAR. The downstream portion of the 

restoration site terminates at another culvert crossing. 

The 2016 PAR identified the restoration site as a culverted crossing over a series of kettle 

ponds that provides access to the community’s water supply located 1.2 miles south of 

Nuiqsut. HDL reported that a 16-foot wide gravel roadway crosses the unnamed drainage. 

HDL also reported that the culverts were installed after an existing bridge failed. The 

crossing consists of three 48-inch diameter by 40-foot long galvanized corrugated steel

culverts, armored at the inlets and outlets with sandbags. The crossing primarily drains 9.5 

square miles and conveys snowmelt and permafrost thaw. The stream has a mild hydraulic 

gradient of 0.4% and connects with the main channel of an unnamed stream that is 

approximately 500 feet downstream of the road crossing. The unnamed stream drains to

the Nigliq Channel of the Colville River. HDL reported that the road crossing at the 

proposed restoration site experiences regular over-topping caused by high spring breakup 

flows, ice damming, and currently undersized culverts. 

This flooding has contributed to road damage which results in excess gravel and sediment

deposition downstream of the crossing. This deposition has resulted in channel constriction 

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GMT2 Development Project 

Wetlands Mitigation Plan 

downstream of the culverts and removal of shoreline vegetation and wetlands habitat. 

Additional impacts resulting from repeated inundation may be experienced upstream to the 

limit of reported flood elevations. The upstream portion also discharges from Nuiqsut 

airport; therefore, flooding could jeopardize the runway during spring breakup. 

CPAI performed a baseline desktop ASA for the site using the ASRC ANSRAM to be 

consistent with the ASA performed for the GMT2 impact site. The ANSRAM determined 

that the key functions currently being provided by the riverine systems are: 

 Nutrient and toxicant removal; 

 General fish habitat; 

 Native plant richness; and 

 Production of organic matter and its export. 

ANSRAM determined that several functions were underperforming due to the condition of 

the culverts and the gravel deposition downstream from annual flood events. The functions 

that are underperforming and in need of uplift are: 

 Sediment removal; 

 Erosion and shoreline stabilization; 

 General habitat suitability; 

 Educational value; and 

 Uniqueness and heritage. 

ANSRAM determined that the overall baseline FCI score for the system is 0.651. 

ANSRAM determined that addressing the issues at the crossing would provide significant 

uplift to the degraded functions listed above, and that the post-restoration project would 

result in an overall FCI score of 0.947, which is a ~45 percent increase in function across

the system. Additionally, the restoration project would add 0.30 acres to the system by 

returning the crossing to normal flow patterns and removing gravel deposited downstream.

The ANSRAM data sheets showing the pre- and post-restoration site functional capacity 

for each measured function are included in Appendix E. 

Photographs of the restoration site taken during the summer of 2017 are below: 

6 August 2018 
GMT2 Development Project 

Wetlands Mitigation Plan 

Photo 1. View along roadway and crossing, looking south. 

Photo 2. View along roadway and crossing, looking north. 

7 August 2018 
GMT2 Development Project 

Wetlands Mitigation Plan 

Photo 3. View looking south at upstream side of culverts. 

Photo 4. Looking north at downstream side of culverts. The gravel in the 

stream is from road washouts. 

8 August 2018 
GMT2 Development Project 

Wetlands Mitigation Plan 

Photo 5. View of upstream side of culverts and sand bag armoring in 

creek and road embankment. 

Photo 6. View downstream from road surface with gravel in stream. 

9 August 2018 
 

 

GMT2 Development Project 

Wetlands Mitigation Plan 

6.0 MITIGATION CREDIT 

The Fresh Water Road restoration project would benefit 35.8 acres of lower perennial 

stream channel and abutting wetlands. Mitigation would be provided by removing the 

gravel that has been washed downstream and restoring the crossing to natural flow 

conditions. The crossing restoration will involve widening the stream to its pre-disturbance 

ordinary high-water width. The restoration project will provide an approximate 0.30-acre 

increase in wetland surface area over the existing 35.5-acre habitat. The gravel removal

will allow shoreline palustrine wetlands to form. 

Road integrity will be restored by strengthening the embankments and raising the road 

grade above anticipated flood elevations, which will reduce the existing effects that the 

road has on the channel. Upstream channel deformation will likely subside given that

excessive ponding from ice damming would be mitigated. Sediment transport function 

downstream will also be realized once natural flows and channel dimensions are restored

at the crossing. 

CPAI used the FCI score from ANSRAM to determine a debit from GMT2, using the 

USACE Credit-Debit Procedure. The debit-credit calculation determined that GMT2 

would result in 10.5 debits and that the restoration site would result in 10.7 credits, thus 

returning slightly more than a 1:1 mitigation ratio. A copy of the calculation is included in

Appendix E. 

7.0 MITIGATION WORK PLAN 

7.1 Fresh Water Road Restoration Work Plan 

CPAI proposes to enter into a contractual agreement with the NSB and plans to complete 

the Fresh Water Road restoration project within the time frame that GMT2 is constructed, 

which is estimated to be complete by October 2021. The work will include removal of the

existing culvert battery and restoring the stream to normal flow patterns. The actual design 

of the crossing is estimated to be complete by December 31, 2018 and will be submitted to 

the Corps as an addendum to this PRM plan by March 31, 2019. 

The nature of the work and soils in the area lend themselves to construction during multiple 

seasons. CPAI will mobilize and demobilize materials and equipment for all construction

activities. Ice roads will be used during winter activities. CPAI will work closely with the 

NSB and Nuiqsut for specific construction activity timing. 

The excess gravel deposited downstream due to recent flood events will be removed as part 

of this effort. The gravel, depending on the quality, could be reused in road grade 

improvements. Gravel that cannot be used will be deposited in an upland location. 

Vegetation along the shoreline will be allowed to develop naturally where gravel is

removed. 

10 August 2018 
 

GMT2 Development Project 

Wetlands Mitigation Plan 

8.0 MAINTENANCE PLAN 

Land at the Fresh Water Road restoration site is owned and managed by the NSB. The NSB 

will be responsible for all maintenance at the site after the repair is completed. 

9.0 PERFORMANCE STANDARDS 

The design will restore normal flows and remove the excess sedimentation downstream of 

the crossing. Upstream portions of the stream will experience a reduction in flood 

elevations and ice damming during breakup. This will alleviate the potential for shoreline

erosion and ice gouging. Scour below the crossing will be mitigated by restoring normal 

flow patterns. 

Importantly, an improved crossing would also provide year-round community access to the 

fresh water supply south of the crossing. The threat of flooding to the airport runway will 

be reduced. Any other use of the road crossing, such as for access to subsistence or 

recreational activities, will also be improved. 

Other design and performance standards will be established by agreement with the NSB. 

10.0 MONITORING PLAN 

CPAI will confirm the efficacy of the repairs during the first breakup season following 

completion of those repairs. This confirmation will include documentation that the integrity

of the road prism and new crossing are maintained and that normal flows are being

experienced. The findings from this monitoring effort will be retained by CPAI and used 

in the determination of whether adaptive management is necessary. 

11.0 LONG-TERM MANAGEMENT 

The NSB will be responsible for all long-term management of the crossing. 

12.0 ADAPTIVE MANAGEMENT 

The NSB will be responsible for any adaptive management at the crossing. 

13.0 FINANCIAL ASSURANCE 

CPAI will ensure that the project, as explained in this document, is executed. The NSB will 

be responsible for financial assurance related to future maintenance and monitoring. 

11 August 2018 
 

GMT2 Development Project 

Wetlands Mitigation Plan 

14.0 REFERENCES 

ABR, Inc.- Environmental Research & Services (ABR). 2017. Wetland Delineation and 

Desktop Mapping Verification for the Greater Mooses Tooth 2 Development 

Project, Alternative A-2015. 2017. 

Hattenburg Dilley & Linnell (HDL). 2016. Project Analysis Report, Nuiqsut Repair 

Bridge Crossings. 2016.

United States Fish & Wildlife Service (USFWS). 2017 Nation.al Wetland Inventory 

Mapping website. 2017. https://www.fws.gov/wetlands/data/Mapper.html. 

12 August 2018 
GMT2 Development Project 

Wetlands Mitigation Plan 

APPENDICES 
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APPENDIX A 

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August 3, 2018 

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APPENDIX B 

HDL 2016 PROJECT ANALYSIS REPORT 

 

 

 

 

 

 

PROJECT ANALYSIS REPORT 

Nuiqsut Repair 

Bridge Crossings 

 North Slope Borough 

Department of Public Works 

Capital Improvement 

Program Management 

Prepared by: 

3335 Arctic Boulevard, Suite 100 

 Anchorage, Alaska 99503 

February 10, 2016 

 

 

NUIQSUT REPAIR BRIDGE CROSSINGS 

PROJECT ANALYSIS REPORT 

CIP No. 68-041 

Borough Contract No. 2015-205 

Prepared for: 

North Slope Borough 

Department of Capital Improvement Program Management 

Bernadette Fischer, Program Manager 

Prepared by: 

Scott Hattenburg, PE/Principal 

Adam Bruscher, Project Engineer 

Hattenburg Dilley and Linnell, LLC 

Engineering Consultants 

3335 Arctic Boulevard, Suite 100 

Anchorage, Alaska 99503 

(907) 564-2120 

HDL Project: 15-031-02 

February 10, 2016 

 

 

 

 

 

 

 

North Slope Borough 

Nuiqsut Repair Bridge Crossings Project Analysis Report 

TABLE OF CONTENTS 

1.0 INTRODUCTION ............................................................................................................................ 1 

1.1 Project Purpose and Objective ...................................................................................................... 1 

1.2 Scope ........................................................................................................................................... 1 

1.3 Project Location............................................................................................................................ 1 

1.4 Background .................................................................................................................................. 3 

1.5 Crossing Evaluation....................................................................................................................... 3 

1.5.1 Lower Stream Crossing (Site 1) ....................................................................................... 3 

1.5.2 Upper Stream Crossing (Site 2) ....................................................................................... 5 

1.5.3 Tributary Stream Crossing (Site 3)................................................................................... 6 

1.6 Flood and Stage Frequency............................................................................................................ 8 

1.7 Drainage and Hydraulics................................................................................................................ 8 

1.8 Soil Conditions.............................................................................................................................. 9 

1.9 Material Source .......................................................................................................................... 10 

1.9.1 Gravel.......................................................................................................................... 10 

1.9.2 Riprap.......................................................................................................................... 10 

1.10 Roadway Design Criteria ............................................................................................................. 10 

1.11 Design Standards and Guidelines................................................................................................. 11 

2.0 ALTERNATIVES............................................................................................................................ 12 

2.1 Alternative 1A – Remove Crossing and Salvage Useable Materials ................................................ 12 

2.2 Alternative 1B - Do Nothing......................................................................................................... 12 

2.3 Alternative 2A – New Bridge Crossing, Elevate Above Ordinary High Water.................................. 13 

2.4 Alternative 2B – New Culverts, Minor Elevation Change ............................................................... 14 

2.5 Alternative 2C – Do Nothing ........................................................................................................ 15 

2.6 Alternative 3A – Armor Existing Structure, No Elevation Change .................................................. 15 

2.7 Alternative 3B – Install New Circular Culverts, Elevate Roadway 3 Feet ........................................ 16 

2.8 Alternative 3C – Install New Arched Culvert, Elevate Road 4.5 Feet .............................................. 16 

2.9 Alternative 3D – Do Nothing ........................................................................................................ 17 

2.10 Other Alternatives Considered .................................................................................................... 18 

2.10.1 Elevate Bridge at Site 2 Above Extreme High Water ...................................................... 18 

2.10.2 Precast Concrete Girders .............................................................................................. 18 

2.10.3 Elevate the Entire Road to the Boat Ramp Above Extreme High Water .......................... 18 

3.0 CONSTRUCTION METHODS .......................................................................................................... 18 

3.1 Construction Methods for Culverts .............................................................................................. 19 

3.1.1 Site 2 ........................................................................................................................... 19 

3.1.2 Site 3 ........................................................................................................................... 19 

3.2 Construction Methods for the Bridge........................................................................................... 20 

4.0 MAINTENANCE AND OPERATION................................................................................................. 20 

5.0 ENVIRONMENTAL CONSIDERATIONS AND PERMITTING REQUIREMENTS ...................................... 20 

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North Slope Borough 

Nuiqsut Repair Bridge Crossings Project Analysis Report 

6.0 ESTIMATE OF PROBABLE COSTS ................................................................................................... 23 

6.1 Capital Cost ................................................................................................................................ 23 

6.2 Operation and Maintenance Costs............................................................................................... 24 

7.0 FINDINGS.................................................................................................................................... 25 

8.0 RECOMMENDATIONS.................................................................................................................. 25 

9.0 REFERENCES ............................................................................................................................... 26 

LIST OF FIGURES 

Figure 1: Project Location Map .............................................................................................................. 1 

Figure 2: Site Location Map ................................................................................................................... 2 

Figure 3: Site 1 Culverts ......................................................................................................................... 4 

Figure 4: Failed Bridge at Site 2 .............................................................................................................. 5 

Figure 5: Bridge Abutments at Site 2 ...................................................................................................... 6 

Figure 6: Site 3 Crossing Looking South .................................................................................................. 7 

Figure 7: Site 3 Culverts - Downstream Face........................................................................................... 7 

Figure 8: Upper Stream Crossing (Site 2), High Water Debris Line............................................................ 8 

LIST OF TABLES 

Table 1: Nigliq Channel Historical Summary of Peak WSE CD5 Road........................................................ 3 

Table 2: Roadway Design Criteria......................................................................................................... 10 

Table 3: Upper Stream Crossing Model Results .................................................................................... 14 

Table 4: Tributary Culvert Model Results ............................................................................................. 16 

Table 5: Tributary Culvert Model Results ............................................................................................. 17 

Table 6: Recommended Regulatory and Permitting Tasks ..................................................................... 22 

Table 7: Capital Cost Summary ............................................................................................................ 24 

APPENDICES 

Appendix A: Capital Cost Estimates 

Appendix B: Concept Drawings for Upper Stream Crossing (Site 2) 

Appendix C: Concept Drawings for Tributary Stream Crossing (Site 3) 

Appendix D: HDL Site Inspection Report 

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North Slope Borough 

Nuiqsut Repair Bridge Crossings Project Analysis Report 

EXECUTIVE SUMMARY 

The purpose of this study is to provide the North Slope Borough (Borough) with feasible 

alternatives and costs for the repair and/or replacement of three bridge and culvert crossings in 

Nuiqsut, Alaska. The three crossings at Sites 1, 2, and 3 have failed or require yearly 

reconstruction and maintenance. 

The Lower Stream Crossing (Site 1) is a temporary culvert crossing approximately 300 feet from 

the Nigliq Channel. Currently, it provides the only access to the City’s boat ramp and material 

source stockpile. This crossing requires complete reconstruction after the high water and ice 

jamming events every spring. 

The Upper Stream Crossing (Site 2) consists of a 42-foot steel bridge constructed in 1974. This 

crossing originally provided access to the old airport, and now the village boat ramp and 

material source stockpile. Reports indicate it failed a couple of years ago. The lower stream 

crossing at Site 1 was built when the bridge failed. 

The Tributary Stream Crossing (Site 3) is a culvert crossing approximately 6,200 feet upstream 

from the Nigliq Channel that provides the only access to the community’s water source. This 

crossing was installed after a previous bridge failure and has required minimal maintenance 

with sandbags after seasonal flooding. 

Alternatives for each of the crossings were analyzed. Our findings, recommendations and the 

costs of PAR alternatives are shown Table EX-1 below. 

FINDINGS 

1. All three sites are in the flood plain of the Colville River and are subject to overtopping and 

ice jamming. 

2. Little flood information exists for Nuiqsut and the Corps of Engineers has not established a 

flood datum for Nuiqsut. 

3. A flood study and stream monitoring is needed to determine flood recurrence intervals and 

flood elevations. 

4. Debris lines near Site 2 suggest seasonal floodwaters and ice floes overtop the bridge by 

approximately 2 feet annually and by approximately 8.5 feet during extreme flood events. 

5. The Site 3 culverts are undersized and overtop annually but requires only minor sandbag 

repair after the high water recedes. 

6. Debris lines near Site 3, suggests that the roadway overtops by approximately 4.5 feet 

during extreme high water events. 

EX-1 
 

 

North Slope Borough 

Nuiqsut Repair Bridge Crossings Project Analysis Report 

RECOMMENDATIONS 

1. Conduct a flood study and stream monitoring study to determine flood recurrence intervals 

and flood elevations. 

2. Conduct a geotechnical investigation to determine engineering and thermal properties of 

soils at the sites to allow for proper design. 

3. At the Lower Stream Crossing (Site 1), remove the crossing after the Site 2 crossing is 

restored: Alternative 1A – Remove Crossing and Salvage Useable Materials. 

4. At the Upper Stream Crossing (Site 2), remove the existing bridge and install three 120-inch 

culverts: Alternative 2B – New Culverts, Minor Elevation Change. 

5. At the Tributary Stream Crossing (Site 3), install three new 72-inch culverts to provide allseason access to the water source lake: Alternative 3B – Install New Circular Culverts, 

Elevate Roadway 3 Feet. 

Table EX-1 – Capital Cost Summary 

Alternative Capital Cost Useful Life 

1A. Remove Crossing and Salvage Useable Materials  1$

1B. Do Nothing  1$

2A. New Bridge Crossing, Elevate Above Ordinary High 

Water  \HDUV

2B. New Culverts, Minor Elevation Change  \HDUV

2C. Do Nothing  1$

3A. Armor Existing Culverts, No Elevation Change  \HDUV

3B. Install New Circular Culverts, Elevate Roadway 3 Feet  \HDUV

3C. Install New Arched Culvert, Elevate Roadway 4.5 Feet  \HDUV

3D. Do Nothing  1$

EX-2 
Figure 1: Project Location Map 

 

 

 

 

 

 

 

North Slope Borough 

Nuiqsut Repair Bridge Crossings Project Analysis Report 

1.0 INTRODUCTION 

Hattenburg Dilley and Linnell, LLC (HDL) was retained by the North Slope Borough (Borough) 

Department of Capital Improvement Program Management (CIPM) to provide a Project Analysis 

Report (PAR) for the reconstruction of three drainage channel crossings at Nuiqsut, Alaska. The 

crossings include two culverts and one bridge crossing on the same unnamed drainage. 

Breakup flood events damage the structures, causing annual repairs and prevent access to the 

village water source, boat ramp, and material source stockpile. 

1.1 Project Purpose and Objective 

The purpose of this project is to provide the Borough with feasible solutions and costs for the 

reconstruction of the three drainage channel crossings at Nuiqsut. 

1.2 Scope 

The scope of this PAR includes analyzing the existing site conditions at each of the three sites, 

developing feasible bridge and culvert crossing alternatives, developing recommendations for 

repair and/or replacement, and developing a budgetary cost estimate for each alternative. The 

analysis of the alternatives considers cost, scheduling, phasing of work, material delivery, lead 

time, impacts on access, and other pertinent criteria determined during the study. HDL worked 

closely with the Borough and village public works staff to determine the history of failures and 

operational and maintenance issues. 

1.3 Project Location 

The project sites are located on the 

village road system at Nuiqsut, Alaska. 

Nuiqsut is located 35 miles from the 

Beaufort Sea coast on the west bank of 

the Nigliq Channel near the Colville River 

Delta (CRD). The village is located at 

70°13’00” North and 151°00’00” West. 

The climate is arctic and dominated by 

extreme temperatures, wind, long 

daylight hours in the summer and 

extended periods of darkness during the 

winter. Temperatures range from -56 to 

78°F with the daily minimum 

temperature below freezing 297 days per 

year. Annual precipitation is minimal and 

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North Slope Borough 

Nuiqsut Repair Bridge Crossings Project Analysis Report 

averages around 5 inches with an annual snowfall of 20 inches. 

This study evaluates three crossings - two culvert crossings and one failed bridge crossing 

located on an unnamed drainage channel. See Figure 2. 

Figure 2: Site Location Map 

The Lower Stream Crossing (Site 1) is a temporary culvert crossing approximately 300 feet from 

the Nigliq Channel. Currently, it provides the only access to the City’s boat ramp and material 

source stockpile. This crossing requires complete reconstruction after the high water and ice 

jamming events every spring. The Upper Stream Crossing (Site 2) is a bridge constructed in 1974 

approximately 1,550 feet upstream from Nigliq Channel. 

This crossing originally provided access to the village boat ramp and material source stockpile, 

but has not been operational for the past couple of years. The lower stream crossing was 

established upon failure of this structure. 

The Tributary Stream Crossing (Site 3) is a culvert crossing approximately 6,200 feet upstream 

from the Nigliq Channel that provides the only access to the community’s water source. 

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North Slope Borough 

Nuiqsut Repair Bridge Crossings Project Analysis Report 

1.4 Background 

The Colville River is the largest river basin north of the Brooks Range draining nearly 23,500 

square miles. (Baker, 2013 Colville River Delta Spring Breakup Monitoring & Hydrologic 

Assessment). Spring breakup on the Colville River is dominated by ice jams, glaciering, large ice 

floes, and high flow rates for an approximate 3 week period each spring. The three crossings 

are located on an unnamed stream channel adjacent to the Nigliq Channel. See Figure 2. The 

crossings are located in the flood plain of the Colville River. 

ConocoPhillips has studied the timing and breakup of the CRD flooding since 2002, including the 

Nigliq Channel. ConocoPhillips has four stream monitoring stations (MON20, MON22, MON23 

and MON28), on the Nigliq Channel downstream of Nuiqsut. Approximately 1.5 miles 

downstream from Nuiqsut the Nigliq Channel branches into another minor side channel, the 

Nigliagvik Channel. Peak discharge and water surface elevation in the Nigliq Channel has been 

monitored at the ice road crossing to CD5 between MON20 and MON23 since 2009. Peak 

annual discharges and water surface elevations (WSE) are shown in Table 1. The WSE is based 

on the British Petroleum Mean Sea Level (BPMSL) vertical datum. The scope of this study 

excluded any surveying, ties, or extrapolation to the BPMSL vertical datum. 

Table 1: Nigliq Channel Historical Summary of Peak WSE CD5 Road 

Year Peak Indirect 

Discharge (cfs) 

Peak WSE (ft 

BPMSL) 

2014 66,000 9.38 

2013 110000 12.42 

2012 94,000 8.82 

2011 141,000 9.89 

2010 134,000 9.65 

2009 57,000 7.91 

Source Baker, 2013 CRD Spring Breakup Monitoring and Hydrologic 

Assessment 

1.5 Crossing Evaluation 

1.5.1 Lower Stream Crossing (Site 1) 

The Lower Stream Crossing at Site 1 is a culvert crossing constructed after the upstream bridge 

failed. See Figure 3. The road was rerouted and culverts were installed approximately 1,250 

feet downstream from the bridge to provide access to the boat ramp and village material 

source stockpile. The temporary culvert crossing is two 48-inch corrugated metal pipes (CMP) 

42-feet in length. These pipes sit atop another series of five to seven buried steel pipes that are 

estimated to range in sizes from 18-inch to 24-inch. A 16-foot wide gravel roadway crosses the 

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North Slope Borough 

Nuiqsut Repair Bridge Crossings Project Analysis Report 

existing 48-inch diameter culverts. Due to the proximity of the lower stream crossing to the 

Nigliq Channel (approximately 300-feet) it is subjected to major damage during the spring 

breakup events and often times has to be reconstructed when the water levels recede. 

Currently, it provides the only access to the community boat ramp and material source 

stockpile. This low profile road is approximately three feet above the surrounding terrain. This 

crossing is reported to fail almost every spring from overtopping, high flows and ice floes which 

erode the gravel embankment and scours around the culverts. 

Figure 3: Site 1 Culverts 

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North Slope Borough 

Nuiqsut Repair Bridge Crossings Project Analysis Report 

1.5.2 Upper Stream Crossing (Site 2) 

The Upper Stream Crossing at Site 2 is a steel bridge constructed in 1974. This crossing 

originally provided the access to the old airport in the 1970s and then the village boat ramp and 

material source stockpile until its failure a few years ago. The bridge is a steel girder bridge 

supported by steel H-piles with abutments retained by timber lagging between piles. The bridge 

span length is 42 feet, measured from end of girder to end of girder. The bridge has a 14-foot 

wide overall deck width and decking consists of 2 x 8-inch treated timbers bolted together and 

attached to the steel girders. Railing consists of 12 x 12-inch timber posts and galvanized 

guardrail. 

Figure 4: Failed Bridge at Site 2 

The decking, girders and guardrail have failed. See Figure 4. Physical evidence from debris 

lines indicate that the Colville River spring flood waters overtop the bridge and the bridge 

elements have failed from the hydraulic pressures and/or impacts from ice floes. The steel pile 

and timber abutments have survived 40 years with only minor damage and displacement. See 

Figure 5. Steel elements show heavy surficial rust. 

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North Slope Borough 

Nuiqsut Repair Bridge Crossings Project Analysis Report 

Figure 5: Bridge Abutments at Site 2 

1.5.3 Tributary Stream Crossing (Site 3) 

The Tributary Stream Crossing at Site 3 is a culvert crossing that provides access to the 

community’s water supply - a fresh water lake located 1.2 miles south of the village. The 16-

foot wide gravel roadway crosses the unnamed drainage that is estimated to be approximately 

250 feet wide and 15 feet deep. The road profile sags approximately 11 feet at the culverts. 

Culverts were reportedly installed after a previous bridge failed. 

The crossing consists of three 48-inch diameter by 40-foot long galvanized corrugated steel 

culverts. See Figures 6 and 7. Physical evidence of a debris line and anecdotal information 

indicate the roadway overtops yearly at spring breakup. To help protect the structure, the 

Borough has armored the inlets and outlets with sandbags. According to the Public Works 

Supervisor for Nuiqsut, the addition of sandbags has greatly extended the life of the structure. 

The condition of the sandbags is fair. The sandbags are easily accessible to vandalism. This 

crossing requires minimal maintenance and reconstruction after spring breakup, according to 

local public works staff. 

The crossing appears to be in the floodplain of the Colville River, but primarily drains snowmelt 

in a basin defined later in this report south and west of Nuiqsut. The overtopping is likely 

caused by high spring breakup flows and undersized culverts. 

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North Slope Borough 

Nuiqsut Repair Bridge Crossings Project Analysis Report 

Figure 6: Site 3 Crossing Looking South 

Figure 7: Site 3 Culverts - Downstream Face 

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North Slope Borough 

Nuiqsut Repair Bridge Crossings Project Analysis Report 

1.6 Flood and Stage Frequency 

Since all of the crossings are located within the Colville River floodplain, flood and stage 

frequency depend heavily on Colville River hydrology. From 1992 to 2014, the measured peak 

flow ranged from 159,000 – 590,000 cfs, with an 

average peak discharge of 294,000 cfs. The peak 

stage varied between 12.20 – 20.69 feet (BPMSL), 

with an average historical peak of 16.79 feet 

(BPMSL). The earliest seasonal occurrence of peak 

flow was May 16, and the latest was June 11. 

Colville River data collected for ConocoPhillips has 

limited applicability to Nuiqsut. Water surface 

elevations refer to a proprietary vertical datum, 

BPMSL, which prevented calibration of elevation 

data collected by HDL and others. Additionally the 

ConocoPhillips studies did not include a monitoring 

station immediately in the vicinity of Nuiqsut. 

Thus, there is no record of peak flow stage and 

discharge that accounts for isolated seasonal flow 

events caused by ice jams in the Nigliq Channel at 

Nuiqsut. 

For the crossings in this report, peak flood stage 

was determined by examining surrounding terrain 

for evidence of past high water events, such as woody Figure 8: Upper Stream Crossing (Site 2), High Water 

debris deposited at a consistent elevation. See Figure Debris Line 

8. We found two locations with evidence of debris 

from high water events. We estimated that the lower of the two debris lines represented a 

normal high water event due to the large amount of debris in the area. The relative elevation 

of this debris line was approximately 2-feet higher than the centerline of the bridge deck. We 

estimated the higher of the debris lines represented an extreme high water event. This debris 

line was measured to be approximately 8.5-feet higher than the bridge deck. 

For the comparison of alternatives, peak discharges, calculated by USGS regression equations, 

were used to estimate the preliminary bridge and culvert sizes. Determination of actual peak 

stage and discharge for design should include installation of stream gages at each of the 

crossings in question and the conduction of a flood study. 

1.7 Drainage and Hydraulics 

Sites 1 and 2 are located on an unnamed stream that meanders north from the drinking water 

supply to its outfall at the Nigliq channel. The drainage area upstream of the crossings is 

approximately 24.5 square miles. The hydraulic gradient of the channel is extremely mild at 

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North Slope Borough 

Nuiqsut Repair Bridge Crossings Project Analysis Report 

approximately 0.07%. The upstream watershed consists of flat, sparsely vegetated tundra with 

many permafrost lakes and ponds. 

Site 3 drains an area of 9.5 square miles, and conveys snowmelt and permafrost thaw that 

collects in a series of kettle ponds south of the Nuiqsut airport runway. The tributary has a mild 

hydraulic gradient of 0.4%, and connects with the main channel of the unnamed stream 

approximately 500 feet downstream of the road crossing. 

The hydraulics at each crossing are heavily influenced by the Colville River. As the Colville rises 

during spring breakup, a backwater effect can be created as culvert outlets become submerged 

or blocked by ice. The compromise in culvert capacity causes a rise in the headwater elevation, 

and in some cases, total inundation of the roadway. 

Culvert design criteria should comply with the Alaska Highway Drainage Manual, Alaska 

DOT&PF, June 13, 2006. 

Bridge hydraulic design criteria are provided in Sections 10.2 and 10.3 of the Alaska Highway 

Drainage Manual. The primary design constraint is maintaining a minimum of 3 feet of vertical 

clearance for passage of ice and debris at the design flow. 

1.8 Soil Conditions 

The project area is located in the Arctic Coastal Plain. The coastal plain is typically poorly 

drained and consequently marshy in the summer. Permafrost is known to exist from 800 -

1,000 feet below the ground surface. Soil conditions are unknown at these sites, but are 

generally assumed to be ice-rich, fine-grained soils with a thawed active layer of 1 to 3 feet in 

virgin undisturbed tundra, 6 to 10 feet in gravelly material, and deeper in the vicinity of stream 

channels where thaw bulbs are known to exist. 

A geotechnical evaluation has not been performed as part of this contract, but should be 

performed prior to design and construction. A full geotechnical investigation should be 

conducted including a subsurface boring program to the depth of expected foundations with 

subsurface temperature measurements and laboratory testing. At a minimum, one boring 

should be performed per substructure and one boring per 50 linear feet of wingwall. Borings 

should include Standard Penetration Testing (SPT) in unfrozen soils and macro-coring, or 

equivalent sampling in frozen soils to retrieve samples of the frozen soil and ice. The subsurface 

temperature should be measured using thermistors to a depth of 10 feet below expected 

foundations. Laboratory testing should include grain size distribution analyses, moisture 

content, Atterberg limits (if applicable), and salinities. A grain size distribution analysis and 

proctor test should be performed on the anticipated fill material. In addition, samples of the 

stream bed materials should be collected to support evaluation of the scour potential. 

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North Slope Borough 

Nuiqsut Repair Bridge Crossings Project Analysis Report 

1.9 Material Source 

Gravel and riprap are the two main aggregate materials needed for the project. 

1.9.1 Gravel 

The Borough’s material source stockpile is located approximately 0.5 miles east of the project 

areas on the south bank of the Nigliq Channel. See Figure 2. The stockpile contains 

approximately 150,000 cubic yards (CY) of sandy gravelly material and is suitable for 

constructing roadway embankments. The material was extracted 4.5 miles east of the project 

area on the east bank of the main channel of the Colville River. The Borough indicates the 

material was delivered to the stockpile in the winter of 2014/2015 for $40 per CY; 70,000 CY of 

this material is dedicated to the Colville River Access Road project. We understand the 

remaining 80,000 CY is available for Borough public works needs. 

1.9.2 Riprap 

There are no known local sources of rock for riprap. Most armor stone on the North Slope 

comes from Cape Nome or Dutch Harbor via ocean barge. The nearest upland source is Atigun 

Pass. Atigun Pass riprap would be mined and transported to Prudhoe Bay via the Dalton 

Highway and then to Nuiqsut via ice roads. The cost is estimated to be about $375 per CY in 

place - which is less than barged riprap. 

1.10 Roadway Design Criteria 

Roadway design Criteria are set forth in Table 2. 

Table 2: Roadway Design Criteria 

ELEMENT VALUE SOURCE 

Construction Classification 

Design Functional Classification 

Improvement of Existing Road 

Very Low-Volume Local Road / Rural Minor 

Access Road AASHTO GDVLVLR 2001 

Design Year 2036 

AADT Construction Year (2016) 

Mid-Design Year (2025) 

Design Year (2035) 

<400 

<400 

<400 

Design Hourly Volume (DHV) 

Directional Split (%D)

(%T)

Equiv. Single Axle Load (ESAL)

Pavement Design Year

<400 

50/50 

50% 

 N/A 

 N/A 

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North Slope Borough 

Nuiqsut Repair Bridge Crossings Project Analysis Report 

Design Vehicle

Design Speed (Terrain) 

Stopping Sight Distance 

Maximum Allowable Grade 

Minimum Allowable Grade 

Minimum Radius of Curvature 

Minimum K-Value for 

Vertical Curves 

Number of Roadways

Width of Traveled Way

Width of Shoulder

Surface Treatment

Side Slope Ratios 

Degree of Access Control

Median Treatment

Illumination:

Curb Usage and Type

Bicycle/ Pedestrian Provisions

 N/A 

25 mph (Level) 

250 (Assumed “Higher Risk” & 

doubled per p.52 

7% 

0.5% 

210 ft with Tc=0.4 (wet earth) 

Crest = 29 

Sag = 26 

 1 lane 

 16 ft 

 N/A 

 N/A 

Fore: 2H:1V 

Back: 2H:1V 

 N/A 

 N/A 

 N/A 

 N/A 

 N/A 

AASHTO GDVLVLR 2001, p. 52 & Ex. 8, 

p.34 

AASHTO PGDHS 2011, Tbl. 5.2, pg. 5-3 

AASHTO GDVLVLR 2001, p. 51 

AASHTO GDVLVLR 2001, Ex. 12, pg. 39 

AASHTO PGDHS 2011, Tbl. 5.3, pg. 5-4 

1.11 Design Standards and Guidelines 

Design standards should comply with the following publications: 

x Guidelines for Geometric Design of Very Low-Volume Local Roads (ADT ≤ 400), American 

Association of State Highway and Transportation Officials (AASHTO), 2001. 

x A Policy on Geometric Design of Highways and Streets (PGDHS or “Green Book”), AASHTO, 2001. 

x Bridge LRFD Design Specifications, AASHTO, 2014. 

x Alaska Highway Drainage Manual, Alaska Department of Transportation and Public Facilities 

(ADOT&PF). 

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North Slope Borough 

Nuiqsut Repair Bridge Crossings Project Analysis Report 

2.0 ALTERNATIVES 

The following feasible alternatives are considered. 

Site 1 

x Alternative 1A - Remove Crossing and Salvage Useable Materials 

x Alternative 1B - Do Nothing 

Site 2 

x Alternative 2A - New Bridge Crossing, Elevate Above Ordinary High Water 

x Alternative 2B - New Culverts, Minor Elevation Change 

x Alternative 2C - Do Nothing 

Site 3 

x Alternative 3A - Armor Existing Culverts, No Elevation Change 

x Alternative 3B - Install New Circular Culverts, Elevate Roadway 3 Feet 

x Alternative 3C - Install New Arched Culvert, Elevate Roadway 4.5 Feet 

x Alternative 3D - Do Nothing 

2.1 Alternative 1A – Remove Crossing and Salvage Useable Materials 

Alternative 1A consists of removing the lower stream crossing at Site 1 and salvaging the 

aggregate and two 48-inch culverts. The crossing is within 300 feet of the Nigliq Channel and is 

mostly affected by high flows in the Nigliq Channel. The crossing is reconstructed every spring. 

The banks of the stream and streambed would be reshaped and blended to match the existing 

contours to help facilitate the flow. Removing this crossing would eliminate a 

maintenance/reconstruction project every spring. Removing the crossing at Site 1 cannot occur 

until the crossing at Site 2 is reconstructed. 

2.2 Alternative 1B - Do Nothing 

Alternative 1B is to leave the lower stream crossing at Site 1 in place. If Alternative 1B is 

selected, the crossing will likely blow out within one year making the road to the boat ramp and 

material source stockpile impassible. 

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North Slope Borough 

Nuiqsut Repair Bridge Crossings Project Analysis Report 

2.3 Alternative 2A – New Bridge Crossing, Elevate Above Ordinary High Water 

This alternative consists of a one lane modular bridge on a steel pile foundation. The proposed 

superstructure would be a prefabricated modular bridge with an estimated deadload of 34-kips. 

The bridge would be designed to withstand loading conditions consistent with AASHTO’s HL-93 

loading condition, which is defined as lane load plus design truck load. In accordance with the 

Guidelines for Geometric Design of Very Low-Volume Local Roads (ADT ≤ 400) the 

recommended bridge width is 15 feet. This bridge would be constructed at the previous 

location and the span would remain unchanged at 42 feet. Prior to any new construction, the 

existing bridge would be removed and all salvageable materials delivered to the city landfill. 

The existing piles would be pulled using a vibratory hammer, and new piles driven at the same 

approximate location. 

To allow passage of debris, the bottom chord of the new modular bridge would be elevated to a 

height of 3-feet above the ordinary high water mark per the recommendation of the Alaska 

Highway Drainage Manual. The deck height of the new bridge is estimated to be about 8 feet 

above that of the previous bridge. Based on the debris lines observed in the field, the 

additional height of this bridge would keep the structure from being impacted during ordinary 

high water events and spring ice jams, but not extreme flooding. Elevating the new structure 

would require reconstruction of the approaches. 

According to the Alaska Highway Preconstruction Manual, bridge railings must comply with 

NCHRP 350 test level 2 or 3. To increase bridge rail performance the test level 3 railing should 

be considered. 

Per the AASHTO Guidelines for Geometric Design of Very Low-Volume Local Roads (ADT ≤ 400) 

the use of guardrails or other traffic barriers are not recommended and deemed impractical for 

use on roads with very low traffic volumes. 

For the purposes of developing a cost estimate, we assumed an active layer of 8 to 10 feet and 

HP 14 x 117, grade 50, steel H-piles spaced at approximate 6 feet and driven to a depth of 50 

feet below the ground surface. It is anticipated that the piles would be driven in the same 

general location as the existing piling. In permafrost, piles will likely require predrilling. 

With an anticipated embankment height of 18 feet, abutments would consist of the H-piles, 8-

inch x 8-inch treated timber lagging and horizontal steel rod tiebacks and deadmen to restrain 

lateral earth pressures. A steel pile cap would support the modular bridge and should be 

designed to resist the force of ice jams should the ordinary high water mark be exceeded. 

Riprap armoring would be installed on approach slopes and along the abutment toe to resist 

erosion and scour. See the concept drawings in Appendix B. 

This alternative would elevate the bridge above the estimated ordinary high water mark, but 

could be expected to overtop occasionally and be damaged by extreme flood events on the 

Colville River. Approach slope armor may be displaced by large ice floes and would require 

maintenance. Stream gaging and flood study would be needed to estimate the recurrence 

13 
 

 

 

 

 

 

 

North Slope Borough 

Nuiqsut Repair Bridge Crossings Project Analysis Report 

interval and flood stages for a proper bridge design at Site 2. The roadway from the boat ramp 

to the village would intentionally not be elevated to allow flood waters and ice floes to pass 

around the bridge and approaches and avoid having the roadway act as a dam. 

2.4 Alternative 2B – New Culverts, Minor Elevation Change 

Alternative 2B consists of installing three 120-inch diameter galvanized steel culverts. Sheet 

piling should be considered under culverts at both ends to prevent piping around the bottom of 

culverts. Rigid insulation would be installed under culverts to avoid thaw settlements. Prior to 

any new construction, the existing bridge would be removed and all materials disposed of at 

the landfill. Existing piles would be pulled or cut off below grade. 

A preliminary hydraulic analysis was performed to compare the existing condition to three 10-

foot diameter culverts with headwalls. HEC-RAS modeling software was used to develop 

hydraulic models based on elevations recorded during the site visit. The complexity of the 

hydraulic processes associated with the ice jams in the Colville River Drainage limits the ability 

to validate the modeling, but it allows for a general comparison between the existing structure 

and a proposed structure. 

Based on the Alaska Department of Transportation’s listed design value for bridges in flood 

hazard areas, the 100-year peak flow was selected as the design flow. This flow was calculated 

using USGS regression equations. The model assumed that the bridges or culverts would have a 

2-foot blockage due to icing. The results are depicted in Table 3. 

Table 3: Upper Stream Crossing Model Results 

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The results suggest that installing three 120-inch culverts would increase freeboard by 2.4 feet 

and nearly double the flow capacity. 

This Alternative assumes there is no benefit to elevating the crossing because the roadways 

have flooded. Finished grade over the culverts would approximately match that of the existing 

bridge approaches with 2 feet of minimum cover over new culverts. 

To prevent piping under the culverts, a sheet pile wall would be installed at the inlet and outlet 

ends to prevent piping under the culvert bottoms. The culverts would be bolted to a steel 

14 
 

 

 

 

 

 

 

North Slope Borough 

Nuiqsut Repair Bridge Crossings Project Analysis Report 

angle which is in turn secured to the sheet piling. The sheet piling wall shall be cut to 

accommodate the bottom of the culvert and driven to refusal at the permafrost interface. 

The crossing would be armored with 32-inches of Class II riprap from the toe of the slope to the 

shoulder of the road. This armor toes should be keyed in at the bottoms and ends to prevent 

edge scour. A riprap apron should extend 15-feet in front of the inlet and outlet ends of the 

culverts. 

Approach slope armor may be displaced by large ice floes and would require some 

maintenance but less than an elevated bridge. Stream gaging and flood study would be needed 

to estimate the flood recurrence intervals and stages for design. The roadways and crossings 

would flood more frequently than the Alternative 2A, the elevated bridge. 

2.5 Alternative 2C – Do Nothing 

Currently, half of the bridge decking is missing and a wooden barricade with a single warning 

sign is the only safety measure implemented. Leaving the site as-is is a potential hazard and 

liability for the Borough and therefore this alternative is not recommended. The bridge and 

abutments should be removed and the slopes graded to match the existing contours. 

2.6 Alternative 3A – Armor Existing Structure, No Elevation Change 

During HDL’s site visit in August 2015, it was observed that very little flow was active through 

the culverts at Site 3. However, a high water debris line was discovered upstream of the 

crossing. This upstream debris line was measured at approximately 4.5 feet above the crest of 

the road at the culverts. Downstream of the crossing, a high water debris line was observed 

approximately 2 feet below the top of the road. Based on the debris lines, there appears to be a 

significant backwater buildup during peak flows resulting in roadway overtopping and erosion 

damage. This effect can be mitigated through hydraulic improvements at the crossing. This 

alternative, however, makes no improvement to the crossing’s hydraulic issues but includes 

armoring the existing culverts and installing a minimum of 32 inches of Class II riprap. The 

embankment slopes would be armored and culvert ends armored 15 feet in front of the culvert 

ends to a width 4 feet on either side of the outside of the culvert. This alternative does not 

mitigate the backwater buildup during peak flows, but addresses erosion and damage sustained 

during these periods. Once the waters have receded there may still be a need for minor 

maintenance. 

This alternative would be prone to flooding during breakup and would not provide all season 

access to the water source lake. This alternative is not recommended if all season access to the 

water source lake is required. 

15 
 

 

 

 

 

North Slope Borough 

Nuiqsut Repair Bridge Crossings Project Analysis Report 

2.7 Alternative 3B – Install New Circular Culverts, Elevate Roadway 3 Feet 

Alternative 3B consists of installing three 72-inch circular culverts at Site 3, raising road grade 

approximately 3 feet, and armoring slopes and aprons similar to Alternative 2B. Rigid insulation 

would be installed under culverts to reduce thaw settlements. To prevent piping under the 

culvert bottoms, a sheet pile wall would be installed at the inlet and outlet ends of the culverts. 

The culverts shall be bolted to an angle and secured to the sheet piling. The sheet piling would 

be trimmed to accommodate the shape of the culvert. Slopes and inlet and outlet aprons 

would be armored with 32-inches of Class II riprap. The aprons would extend 15 feet in front of 

the culverts. 

A hydraulic analysis was performed to compare the existing conditions to the recommendation 

using HY-8 modeling software. It should be noted that the complexity of the hydraulic process 

associated with ice jams in the Colville River Drainage limits the ability to validate modeling 

results; however, a performance comparison between the existing and proposed condition is 

useful. 

Based on the Alaska Department of Transportation’s design value for low usage secondary 

highways, the 10-year peak flow was used as the design flow to analyze the tributary stream 

crossing. The results are depicted in Table 4 below. USGS regression equations were used to 

calculate the flow and it was assumed that the culverts would have a 2-foot blockage due to 

icing. 

Table 4: Tributary Culvert Model Results

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The results suggest that upgrading to three 72-inch diameter circular culverts would reduce the 

backwater elevation by several feet and may significantly reduce the probability of overtopping. 

The alternative would provide all season access to the water source lake. This alternative is 

recommended. 

2.8 Alternative 3C – Install New Arched Culvert, Elevate Road 4.5 Feet 

Alternative 3C consists of installing a single 100-inch by 154-inch arched culvert, rigid insulation, 

a sheet pile cutoff wall and slope and apron armoring. Similar to Alternatives 3A and 3B, the 

slopes and aprons would be armored with 32-inches of Class II riprap. The apron would 

16 
 

 

 

 

 

 

 

North Slope Borough 

Nuiqsut Repair Bridge Crossings Project Analysis Report 

measure approximately 15-feet by 27-feet in front of culvert inlets and outlets. To achieve the 

recommended minimum culvert cover of 2 feet, the existing roadway grade would have to be 

raised by 1.2 feet. In order to mitigate overtopping, similar to Alternative 3B (using the Q10 

backwater information) the roadway should be raised 4.3 feet. Elevating the roadway would 

enable the road to be useable during spring breakup. 

A preliminary hydraulic analysis was performed similar to Alternatives 3A and 3B. Based on the 

Alaska DOT’s design value for low usage secondary highways, the 10-year peak flow was used 

as the design flow to analyze the tributary stream crossing. The results are depicted in Table 5 

below. USGS regression equations were used to calculate the flow and it was assumed that the 

culverts would have a 2-foot blockage due to icing. 

Table 5: Tributary Culvert Model Results 

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The results suggest upgrading to a single 100-inch by 154-inch arched culvert would reduce the 

backwater elevation by a couple of feet and would reduce the occurrence of overtopping. 

This alternative may be feasible, but its design should take special precautions to insulate the 

foundation under the arched culvert to prevent frost jacking. Arched culverts are susceptible to 

failure from frost jacking because of their flat bottom. Recently, a similar multiplate arched 

culvert in Buckland failed when the bottom jacked, while a circular multiplate structure 

alongside it performed satisfactorily. It is reported that an ice lense formed underneath, 

causing the bottom to buckle. For this reason, additional insulation should be added to prevent 

ice lenses from forming under the arch. 

2.9 Alternative 3D – Do Nothing 

Alternative 3D leaves the existing crossing as is. With minor spring time repairs this crossing 

may be useable for years, but will eventually fail due to damage sustained during high water 

events and ice jamming activities. If the Borough desires all season access to the water source 

lake, this option is not recommended. 

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North Slope Borough 

Nuiqsut Repair Bridge Crossings Project Analysis Report 

2.10 Other Alternatives Considered 

Other alternatives were considered, but deemed not feasible for technical or economic 

reasons. 

2.10.1 Elevate Bridge at Site 2 Above Extreme High Water 

Elevating the bridge at Site 2 above the extreme high water event was considered, but deemed 

not practical or feasible. This alternative would require extremely high, roughly 24.5–foot, 

abutment walls and extended approaches. Building abutments and approaches of this 

magnitude would require massive amounts of fill material and gravel, which would be 

expensive and complicated. Elevating the bridge to this extreme would pose no benefit to the 

community as the surrounding access roads would be inundated and the bridge would not be 

of any benefit to the general public. For cost estimate breakdown see Page 10 of Appendix A. 

2.10.2 Precast Concrete Girders 

A bulb-T prestressed concrete bridge was considered for Site 2, but deemed not economically 

feasible due to the short span. According to a local prestressed concrete manufacturer, a short 

50-foot span with a 14 to 16 foot deck width, three 42-inch bulb-T prestressed concrete 

girders would not be competitive with modular steel bridges of an equivalent size. The 

concrete would also be more susceptible to ice damage because of the girder depth, and the 

bulbs lesser lateral strength when compared to a steel bridge. 

2.10.3 Elevate the Entire Road to the Boat Ramp Above Extreme High Water 

Elevating and armoring the 3200 feet of road to the boat ramp and bridge at Site 2 above 

extreme high water was considered, but the high cost, estimated to be $20M to $30M for the 

28,800 CY of riprap and 92,800 CY of gravel fill was deemed not economically feasible. 

Elevating the entire road and bridge would hydraulically act as a dam for Colville River flood 

waters and would be prone to flood damage. The high cost compared to the benefit of 

providing access to the boat ramp and material source during flood events makes this concept 

not feasible. 

3.0 CONSTRUCTION METHODS 

The nature of the work and soils in the area lend itself to construction during multiple seasons. 

The mobilization/demobilization of materials and equipment on the ice road coupled with 

winter and summer construction activities will extend construction over the course of one year. 

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North Slope Borough 

Nuiqsut Repair Bridge Crossings Project Analysis Report 

Construction access at Site 3 is governed by the need for access to the village’s water source. 

The 3rd or 4th week of June the city begins pumping water from the lake and pumps 

continuously until the tanks are full, which is typically around the 1st week of September. The 

shutdown date varies according to weather. Freezing of the waterline ends the pumping 

season. During the pumping season, the water system operators require unrestricted access to 

service pumps and monitor the operation. 

3.1 Construction Methods for Culverts 

3.1.1 Site 2 

The existing bridge should be removed and all salvageable materials shall be delivered to the 

Borough. The existing piles may be able to be pulled, salvaged, and returned to the City; 

otherwise, the piling should be cut two feet below grade. In late fall, the sheet pile walls should 

be installed when the active layer is at its maximum depth. These walls are to be driven 

through the active layer and to refusal in the permafrost layer below. The sheet pile walls 

should be left high, about to the spring line of the culverts. Under frozen ground conditions, 

the Contractor would excavate and install a layer of rigid insulation and install approximately 4-

feet of sacrificial fill material to protect the crossing during spring runoff and breakup. After 

breakup, culverts would be installed and remaining thawed fill placed and compacted under 

low flow conditions. The sheet piles would be trimmed and attached to culverts using a double 

rolled angle. Fill slopes should be armored with Class II riprap 32-inches deep over a geotextile 

fabric with keyed edges. The culvert inlets would be armored with a riprap apron. 

3.1.2 Site 3 

Due to the average historical high water date of the Colville River on May 31st, and the need for 

access to the water source lake by the 3rd week in June, winter construction methods will need 

to be employed. In late fall, the existing culverts and fill would be removed and sheet pile walls 

installed similar to Site 2. Sheet piles would be cut to an elevation about 6 inches above the 

invert of the inlet and outlet of the culverts. Then under frozen ground conditions, excavation 

would occur to the bottom of insulation, insulation installed, then fill brought back up to the 

bedding depth of the culvert inverts. The culverts, fill, geotextile, and riprap could be placed 

under frozen ground conditions, if dry granular material could be properly placed and 

compacted; or the contractor could place temporary riprap to protect during breakup and 

complete the project under thawed conditions. The sheet piles would be trimmed and attached 

to culverts using a double rolled angle. Fill slopes should be armored with Class II riprap 32-

inches deep over a geotextile fabric with keyed edges. The culvert inlets would be armored 

with a riprap apron. 

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North Slope Borough 

Nuiqsut Repair Bridge Crossings Project Analysis Report 

3.2 Construction Methods for the Bridge 

The removal of the existing bridge structure is needed to construct the bridge. The existing 

bridge should be removed and all salvageable materials shall be delivered to the Borough. The 

existing piles should be pulled, salvaged, and returned to the City, or the bridge offset to miss 

existing piles. 

Gravel approaches would be removed to the extent required to drive piles and construct 

deadmen anchors. New H-piles would be predrilled with an undersized pilot hole and driven to 

depth. Near-water work should be avoided until spring breakup high flows have receded. 

The abutments and wing walls, consisting of piles, treated-timber lagging and deadman 

anchors, would be constructed during thawing conditions to help ensure proper placement and 

compaction of fills. The pile caps, elastomeric bearing pads, backwall, bridge structure, and 

appurtenances would be installed when environmental conditions allow for proper welding and 

connection installation. 

4.0 MAINTENANCE AND OPERATION

Yearly maintenance may be required at Sites 2 and 3 to ensure the longevity of the crossings. 

Erosion control and bank stabilization will need to be maintained and repaired in a timely 

manner to protect the structures in place. These structures will be subject to flooding and 

overtopping during extreme events and will need to be repaired and rearmored, if needed. If 

normal maintenance is not conducted in a timely fashion the structures may prematurely fail. 

It is recommended to inspect culverts on an annual basis and after extreme events. The 

National Bridge Inspection Standards (NBIS) recommends that bridges should be inspected 

every two years and that the maximum interval between inspections should not exceed four 

years. 

5.0 ENVIRONMENTAL CONSIDERATIONS AND PERMITTING REQUIREMENTS 

HDL conducted preliminary environmental research using the most current available data from 

state and federal agencies to identify environmental resources in the vicinity of the proposed 

project. The purpose of the preliminary research was to assist in identifying permitting and 

regulatory requirements to ensure environmental considerations are adequately addressed in 

developing any of the "action" alternatives for the proposed project. Environmental categories 

with resources potentially present in the project area are discussed below. 

National Environmental Policy Act (NEPA) Review 

The funding source for the proposed project will dictate the type of environmental 

documentation necessary to satisfy state and federal requirements and/or authorizations. 

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North Slope Borough 

Nuiqsut Repair Bridge Crossings Project Analysis Report 

Should federal funds be used, the federal agency appropriating the funds would likely assume 

the role of lead federal agency and would be responsible for development of appropriate NEPA 

documentation. NEPA documentation would outline potential impacts to the natural and manmade environment. 

Should the project be entirely state funded, the NSB’s primary environmental documentation 

will be the environmental review conducted for this PAR, which identifies potential 

environmental impacts and outlines permits and authorizations needed for the project. A NSB 

or state-funded project triggers the NEPA process when a federal permit is required, such as a 

U.S. Army Corps of Engineers (USACE) Section 404 permit for impacts to wetlands. This 

environmental review may be used by the USACE to streamline their NEPA documentation 

efforts and potentially decrease the amount of time necessary in receiving authorization. 

Wetlands & Waters of the U.S. 

A review of the U.S. Fish & Wildlife Service (USFWS) National Wetlands Inventory and recent 

satellite imagery indicates the project area contains wetlands under USACE jurisdiction. It is 

anticipated that the project will impact wetlands, and will require authorization under a 

Nationwide Permit and submittal of a Pre-Construction Notification to USACE. Should the 

project disturb more than 0.50 acre of wetlands, an Individual Permit application would be 

required. 

Construction of the proposed project will involve the discharge of construction storm water 

into waters of the U.S. Should the project involve more than one acre of disturbed ground, 

coverage under the Alaska Department of Environmental Conservation’s Alaska Pollutant 

Discharge Elimination Systems (APDES) Construction General Permit for stormwater discharges 

would be required. 

Cultural, Historic, Pre-Historic, & Archaeological Resources 

The likelihood of disturbing previously unknown cultural, historic, pre-historic, or archaeological 

resources within the project areas is low since the areas have been previously disturbed by 

construction of existing infrastructure. The project will require a Certificate of Traditional Land 

Use Inventory (TLUI) Clearance from the NSB Department of Inupiat History, Language, and 

Culture (IHLC). 

Should the project receive state or federal funding, consultation with the Alaska Office of 

History and Archaeology under the Alaska Historic Preservation Act, or State Historic 

Preservation Officer (SHPO) under Section 106 of the National Historic Preservation Act, would 

be required. 

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Nuiqsut Repair Bridge Crossings Project Analysis Report 

Fish & Wildlife: 

Threatened & Endangered Species 

Initial project scoping conducted using USFWS’s Information, Planning, and Conservation 

System tool indicates there is one species, the polar bear (Ursus maritimus), listed as 

threatened under the Endangered Species Act (ESA) that is known to inhabit the project area. 

There are no endangered or candidate species or designated critical habitats located in the 

project area. Consultation with the USFWS under Section 7 of the ESA would be required if 

federal funding is received for construction. 

Migratory Birds 

The project is located in areas that have been heavily disturbed; however, shrub and grassvegetated areas are present. To avoid disturbance to migratory birds, USFWS recommends 

avoiding clearing from June 1st through August 10th. 

Anadromous Fish Streams 

A review of the Alaska Department of Fish and Game’s (ADF&G) Anadromous Waters Catalog 

(AWC) indicates the project is located on the Nigliq Channel, a tributary of the Colville River, 

which is listed as supporting several species of anadromous fishes. Consultation with ADF&G 

during the design phase of the project is recommended to determine whether fish may be 

present in the project area and if a Fish Habitat Permit will be required. 

Land Ownership 

According the Alaska Division of Community and Regional Affairs’ Community Map for Nuiqsut, 

the project would be located on a combination of lands owned by the Borough, City of Nuiqsut, 

and Kuukpik Corporation. The project will require easements or rights-of-way prior to 

construction. 

Environmental Permitting Summary & Recommendations 

Table 6 below summarizes environmental data and permit requirements for development. 

Table 6: Recommended Regulatory and Permitting Tasks 

NSB Land Management 

Regulations (LMR) 

Development Permit. (fee waived for NSB projects). 

Wetlands, Waters of the 

U.S, & Navigable Waters 

Jurisdictional wetlands located within project areas. Section 404 

Nationwide Permit/Pre-Construction Notification required. 

APDES Construction General required if disturbed area is 1 or 

more acre ($490 fee). 

22 
 

 

 

 

 

 

North Slope Borough 

Nuiqsut Repair Bridge Crossings Project Analysis Report 

Cultural, Historic, PreHistoric, & Archaeological 

Resources 

Low potential to encounter historic sites; IHLC's Certificate of 

TLUI Clearance required (fee waived for NSB projects). 

Consultation with OHA/SHPO required depending on funding 

source. 

Threatened & Endangered 

Species 

Polar bear listed as Threatened under ESA. Consultation with 

USFWS required if federally funded. 

Migratory Birds No vegetation clearing between June 1st and August 10th 

recommended. 

Anadromous Fish Streams No AWC-listed anadromous fish habitat in project area; Nigliq 

Channel of Colville River is approximately 500 feet downstream 

of Site 1. Consultation with ADF&G recommended during design. 

Land Ownership Confirm existing or provide easements or rights-of-way for work 

on NSB, City of Nuiqsut, and Kuukpik Corporation lands. 

6.0 ESTIMATE OF PROBABLE COSTS 

6.1 Capital Cost 

Capital costs for the three sites have been prepared based on the analysis provided herein for 

each of the sites, details of which are provided in Appendix A and summarized in Table 7. 

Capital cost estimates are based on the following general assumptions: 

1. Work will be competitively bid. 

2. Seasonal ice road between Prudhoe Bay and Nuiqsut will be available and constructed 

by industry. 

3. Materials and equipment will mobilize and demobilize via ice road. 

4. A site for material staging and equipment storage will be provided at no cost to the 

contractor. 

5. The Borough stockpiled gravel will be available at no cost. 

6. Piling will be predrilled in permafrost. 

7. Sheet piling will be driven through the thawed active layer to refusal in the permafrost. 

23 
 

 

North Slope Borough 

Nuiqsut Repair Bridge Crossings Project Analysis Report 

8. Construction shall occur during times of low to no flow. 

9. Dewatering will be necessary when working at or below the water levels in the 

surrounding area. 

10. Labor assumed to be at Title 36 wage rates. 

11. No crushed aggregate surfacing is required for road surfacing. 

12. Alternative 1A work will be performed upon completion of Site 2 work by the same 

Contractor. 

Table 7: Capital Cost Summary 

Alternative Capital Cost Useful Life 

1A. Remove Crossing and Salvage Useable Materials  1$

1B. Do Nothing  1$

2A. New Bridge Crossing, Elevate Above Ordinary High 

Water  \HDUV

2B. New Culverts, Minor Elevation Change  \HDUV

2C. Do Nothing  1$

3A. Armor Existing Culverts, No Elevation Change  \HDUV

3B. Install New Circular Culverts, Elevate Roadway 3 Feet  \HDUV

3C. Install New Arched Culvert, Elevate Roadway 4.5 Feet  \HDUV

3D. Do Nothing  1$

6.2 Operation and Maintenance Costs 

Operation and maintenance (O&M) costs are expected to include minor riprap restoration 

annually from ice floes; except after extreme flood events which may cause significant damage. 

O&M costs can be minimized by keeping embankments sloped and low profile to minimize 

hydraulic impacts and restoration costs. 

24 
 

 

 

North Slope Borough 

Nuiqsut Repair Bridge Crossings Project Analysis Report 

7.0 FINDINGS 

1. All three sites are in the flood plain of the Colville River and are subject to overtopping 

and ice jamming. 

2. Little flood information exists for Nuiqsut and the Corps of Engineers has not established 

a flood datum for Nuiqsut. 

3. A flood study and stream monitoring is needed to determine flood recurrence intervals 

and flood elevations. 

4. Debris lines near Site 2 suggest seasonal floodwaters and ice floes overtop the bridge by 

approximately 2 feet annually and by approximately 8.5 feet during extreme flood 

events. 

5. The Site 3 overtops annually but requires only minor sandbag repair after the high water 

recedes. 

6. Debris lines near Site 3 suggest that the roadway overtops by approximately 4.5 feet 

during extreme high water events. 

8.0 RECOMMENDATIONS 

1. Conduct a flood study and stream monitoring study to determine flood recurrence 

intervals and flood elevations. 

2. Conduct a geotechnical investigation to determine engineering and thermal properties 

of soils at the sites to allow for proper design. 

3. At the Lower Stream Crossing (Site 1), remove the crossing after the Site 2 crossing is 

restored: Alternative 1A – Remove Crossing and Salvage Useable Materials. 

4. At the Upper Stream Crossing (Site 2), remove the existing bridge and install three 120-

inch culverts: Alternative 2B – New Culverts, Minor Elevation Change. 

5. At the Tributary Stream Crossing (Site 3), install three new 72-inch culverts to provide 

all-season access to the water source lake: Alternative 3B – Install New Circular 

Culverts, Elevate Roadway 3 Feet. 

25 
 

 

 

 

North Slope Borough 

Nuiqsut Repair Bridge Crossings Project Analysis Report 

9.0 REFERENCES 

1. A Policy on Geometric Design of Highways and Streets, (PGDHS or “Green Book”) 

AASHTO, 2011. 

2. Alaska Highway Drainage Manual, Alaska DOT&PF. June 13, 2006. 

3. Baker. 2013 Colville River Delta Spring Breakup Monitoring & Hydrologic Assessment. 

4. Big R Bridge. Standard 4 1⁄4” Steel Deck 30’ to 80’ x 14’ or 16’ Single Lane Bridge – Bridge 

Detail, December 7, 2015. 

5. "Bridges & Structures." Revisions to the National Bridge Inspection Standards (NBIS). 

N.p., n.d. Web. 07 Dec. 2015. 

6. Guidelines for Geometric Design of Very Low-Volume Local Roads (ADT ≤ 400). 

American Association of State Highway and Transportation Officials (AASHTO), 2001. 

7. Green, Ken. NSB CIPM Project Administrator, Personal communication regarding 

material source stockpile, December 2015.Nukapigak, Thomas. Nuiqsut Public Works 

Superintendent, Personal Communication, August and November 2015. 

8. Roadside Design Guide. AASHTO, 2011. 

9. "Village of Nuiqsut | ICAS." ICAS. Web. 16 Sept. 2015. 

26 
 

 

North Slope Borough 

Nuiqsut Repair Bridge Crossings Project Analysis Report 

APPENDIX A 

COST ESTIMATE 

Nuiqsut Repair Bridge Crossing PAR 

2/10/2016 

Alternative 1A - Remove Crossing and Salvage Useable Materials 

ITEM QUANTITY DESCRIPTION UNIT PRICE TOTAL PRICE 

1 1 L.S. Temp Erosion and Pollution Control 20,000.00 20,000 

2 1 L.S. Remove 2-48" CMPs 25,000.00 25,000 

3 1 L.S. Remove 5-7 18"-24" Burried Steel Pipes 25,000.00 25,000 

4 1 L.S. Reshaping and Bank Stabilization 45,000.00 45,000 

5 1 L.S. Salvagable Material 15,000.00 15,000 

Subtotal Construction $130,000 

Land Acquisition 

City Administration 

Design 

Construction Management 

Project Contingency 

3 Years Inflation 

@ 5% 

@ 12% 

@ 15% 

@ 15% 

@ 3% 

0 

6,500 

15,600 

19,500 

19,500 

12,100 

Subtotal $203,200 

Alt 1A Page 1 of 10 Prepared by HDL Engineering 
ITEM QUANTITY DESCRIPTION UNIT PRICE TOTAL PRICE 

Subtotal Construction $0 

Land Acquisition 

City Administration 

Design 

Construction Management 

Project Contingency 

1 Years Inflation 

@ 5% 

@ 12% 

@ 15% 

@ 15% 

@ 3% 

0 

0 

0 

0 

0 

0 

Subtotal $0 

Nuiqsut Repair Bridge Crossing PAR 

2/10/2016 

Alternative 1B - Do Nothing 

Alt 1B Page 2 of 10 Prepared by HDL Engineering 
Nuiqsut Repair Bridge Crossing PAR 

2/10/2016 

Alternative 2A - New Bridge Crossing, Elevate Above Ordinary High Water 

ITEM QUANTITY DESCRIPTION UNIT PRICE TOTAL PRICE 

1 1 L.S. Mobilization/Demobilization 286,000.00 286,000 

2 1 L.S. Temp Erosion and Pollution Control 75,000.00 75,000 

3 1 L.S. Construction Surveying 90,000.00 90,000 

4 1 L.S. Remove Piling, Abutments, and Superstrucure 75,000.00 75,000 

5 1 L.S. Modular Bridge (FOB Seattle) 54,600.00 54,600 

6 1 L.S. Modular Bridge Assembly 20,000.00 20,000 

7 17 Tons Barging of Bridge Structure (SEA to PUD) 1,000.00 17,000 

8 332,000 Lbs. HP14x117 Piling, Grade 50 (2840l.f.) 1.00 332,000 

9 20 Days Install H Piles 18,000.00 360,000 

10 9,000 Lbs. Pile Caps, Backwall, and Bearing Plates 1.00 9,000 

11 2,700 B.F. 8x8 PT Timber 2.00 5,400 

12 432 L.F. Tie Back Anchors 50.00 21,600 

13 12 Each Deadmen 10,000.00 120,000 

14 290 C.Y. Excavation 50.00 14,500 

15 3,960 C.Y. Gravel Fill 50.00 198,000 

16 1,500 S.Y. Geotextile Fabric 5.00 7,500 

17 1,000 C.Y. Rip Rap 375.00 375,000 

18 13 Loads Trucking (Anc. to Nui.) 10,000.00 130,000 

Subtotal Construction $2,190,600 

Land Acquisition 

City Administration 

Design 

Construction Management 

Project Contingency 

3 Years Inflation 

@ 5% 

@ 12% 

@ 15% 

@ 15% 

@ 3% 

0 

109,500 

262,900 

328,600 

328,600 

203,100 

Subtotal $3,423,300 

Alt 2A Page 3 of 10 Prepared by HDL Engineering 
Nuiqsut Repair Bridge Crossing PAR 

2/10/2016 

Alternative 2B - New Culverts, Minor Elevation Change 

ITEM QUANTITY DESCRIPTION UNIT PRICE TOTAL PRICE 

1 1 L.S. Mobilization/Demobilization 268,000.00 268,000 

2 1 L.S. Temp Erosion and Pollution Control 50,000.00 50,000 

3 1 L.S. Construction Surveying 90,000.00 90,000 

4 1 L.S. Remove Piling, Abutments, and Superstrucure 75,000.00 75,000 

5 195 L.F. 3 - 120" Φ CMP 1,800.00 351,000 

6 6 Each End Section 4,000.00 24,000 

7 55,000 Lbs. Sheet Piling (1550 S.f.) 1.00 55,000 

8 15 Days Install Sheet Piling 18,000.00 270,000 

9 500 Lbs. 8"x4"x9/16" Rolled Angle H.D.G. 6.00 3,000 

10 72 L.F. Tieback Anchors 50.00 3,600 

11 4 Each Deadmen 7,500.00 30,000 

12 19,500 B.F. 4" Rigid Insulation 12.00 234,000 

13 610 C.Y. Excavation 50.00 30,500 

14 1,600 C.Y. Gravel Fill 50.00 80,000 

15 1,030 C.Y. Riprap 375.00 386,250 

16 1,500 S.Y. Geotextile Fabric 5.00 7,500 

17 10 Loads Trucking (Anc. to Nui.) 10,000.00 100,000 

Subtotal Construction $2,057,850 

Land Acquisition 0 

City Administration @ 5% 102,900 

Design @ 12% 246,900 

Construction Management @ 15% 308,700 

Project Contingency @ 15% 308,700 

3 Years Inflation @ 3% 190,800 

Subtotal $3,215,850 

Alt 2B Page 4 of 10 Prepared by HDL Engineering 
Nuiqsut Repair Bridge Crossing PAR 

2/10/2016 

Alternative 2C - Do Nothing (Remove Bridge) 

ITEM QUANTITY DESCRIPTION UNIT PRICE TOTAL PRICE 

1 1 L.S. Mobilization/Demobilization 40,000.00 40,000 

2 1 L.S. Temp Erosion and Pollution Control 75,000.00 75,000 

3 1 L.S. Remove Piling, Abutments, and Superstrucure 75,000.00 75,000 

4 1 L.S. Reshaping and Bank Stabilization 50,000.00 50,000 

Subtotal Construction $240,000 

Land Acquisition 

City Administration 

Design 

Construction Management 

Project Contingency 

3 Years Inflation 

@ 5% 

@ 15% 

@ 20% 

@ 20% 

@ 3% 

0 

12,000 

36,000 

48,000 

48,000 

22,300 

Subtotal $406,300 

Alt 2C Page 5 of 10 Prepared by HDL Engineering 
Nuiqsut Repair Bridge Crossing PAR 

2/10/2016 

Alternative 3A - Armor Existing Culverts, No Elevation Change 

ITEM QUANTITY DESCRIPTION UNIT PRICE TOTAL PRICE 

1 1 L.S. Mobilization/Demobilization 250,000.00 250,000 

2 1 L.S. Temp Erosion and Pollution Control 50,000.00 50,000 

3 1 L.S. Slope Grading 85,000.00 85,000 

4 1,425 C.Y. Riprap 375.00 534,400 

5 2,420 S.Y. Geotextile Fabric 5.00 12,100 

Subtotal Construction $931,500 

Land Acquisition 

City Administration 

Design 

Construction Management 

Project Contingency 

3 Years Inflation 

@ 5% 

@ 12% 

@ 15% 

@ 20% 

@ 3% 

0 

46,600 

111,800 

139,700 

186,300 

86,400 

Subtotal $1,502,300 

Alt 3A Page 6 of 10 Prepared by HDL Engineering 
Nuiqsut Repair Bridge Crossing PAR 

2/10/2016 

Alternative 3B - Install New Circular Culverts, Elevate Roadway 3 Feet 

ITEM QUANTITY DESCRIPTION UNIT PRICE TOTAL PRICE 

1 1 L.S. Mobilization/Demobilization 280,000.00 280,000 

2 1 L.S. Temp Erosion and Pollution Control 50,000.00 50,000 

3 1 L.S. Construction Surveying 90,000.00 90,000 

4 1 L.S. Remove Old Culverts 25,000.00 25,000 

5 195 L.F. 72" CMP 1,200.00 234,000 

6 6 Each End Sections 3,000.00 18,000 

7 34,000 Lbs. Sheet Piling (1000 S.f) 1.00 34,000 

8 15 Days Install Sheet Piling 18,000.00 270,000 

9 500 Lbs. 8"x4"x9/16" Rolled Angle H.D.G. 6.00 3,000 

10 72 L.F. Tieback Anchors 50.00 3,600 

11 4 Each Deadmen 7,500.00 30,000 

12 12,400 B.F. 4" Rigid Insulation 12.00 148,800 

13 1,280 C.Y. Excavation 50.00 64,000 

14 2,740 C.Y. Gravel Fill 50.00 137,000 

15 1,735 C.Y. Riprap 375.00 650,625 

16 1,390 S.Y. Geotextile Fabric 5.00 6,950 

17 10 Loads Trucking (Anc. to Nui.) 10,000.00 100,000 

Subtotal Construction $2,144,975 

Land Acquisition 

City Administration 

Design 

Construction Management 

Project Contingency 

3 Years Inflation 

@ 5% 

@ 12% 

@ 15% 

@ 15% 

@ 3% 

0 

107,200 

257,400 

321,700 

321,700 

198,900 

Subtotal $3,351,875 

Alt 3B Page 7 of 10 Prepared by HDL Engineering 
Nuiqsut Repair Bridge Crossing PAR 

2/10/2016 

Alternative 3C - Install New Arched Culvert, Elevate Roadway 4.5 Feet 

ITEM QUANTITY DESCRIPTION UNIT PRICE TOTAL PRICE 

1 1 L.S. Mobilization/Demobilization 328,000.00 328,000 

2 1 L.S. Temp Erosion and Pollution Control 50,000.00 50,000 

3 1 L.S. Construction Surveying 90,000.00 90,000 

4 1 L.S. Remove Old Culverts 25,000.00 25,000 

5 72 L.F. 100-inch x 154-inch Pipe Arch Culvert 1,800.00 129,600 

6 2 Each End Sections 4,000.00 8,000 

7 40,000 Lbs. Sheet Piling (1130 S.F.) 1.00 40,000 

8 15 Days Install Sheet Piling 18,000.00 270,000 

9 1,000 Lbs. 8"x4"x9/16" Rolled Angle H.D.G. 3.00 3,000 

10 72 L.F. Tieback Anchors 50.00 3,600 

11 4 Each Deadmen 7,500.00 30,000 

12 30,800 B.F. 4" Rigid Insulation 12.00 369,600 

13 1,500 C.Y. Excavation 50.00 75,000 

14 3,300 C.Y. Gravel Fill 50.00 165,000 

15 2,190 C.Y. Riprap 375.00 821,250 

16 1,660 S.Y. Geotextile Fabric 5.00 8,300 

17 10 Loads Trucking (Anc. to Nui.) 10,000.00 100,000 

Subtotal Construction $2,516,350 

Land Acquisition 

City Administration 

Design 

Construction Management 

Project Contingency 

3 Years Inflation 

@ 5% 

@ 12% 

@ 15% 

@ 15% 

@ 3% 

0 

125,800 

302,000 

377,500 

377,500 

233,300 

Subtotal $3,932,450 

Alt 3C Page 8 of 10 Prepared by HDL Engineering 
ITEM QUANTITY DESCRIPTION UNIT PRICE TOTAL PRICE 

Subtotal Construction $0 

Land Acquisition 

City Administration 

Design 

Construction Management 

Project Contingency 

1 Years Inflation 

@ 5% 

@ 12% 

@ 15% 

@ 15% 

@ 3% 

0 

0 

0 

0 

0 

0 

Subtotal $0 

Nuiqsut Repair Bridge Crossing PAR 

2/10/2016 

Alternative 3D - Do Nothing 

Alt 3D Page 9 of 10 Prepared by HDL Engineering 
Nuiqsut Repair Bridge Crossing PAR 

2/10/2016 

Elevate Bridge at Site 2 Above Extreme High Water - See Section 2.10.1 pg 18 

ITEM QUANTITY DESCRIPTION UNIT PRICE TOTAL PRICE 

1 1 L.S. Mobilization/Demobilization 2,300,000.00 2,300,000 

2 92,800 C.Y. Gravel Fill 50.00 4,640,000 

3 28,824 C.Y. Riprap 375.00 10,809,000 

4 42,000 S.Y. Geotextile Fabric 5.00 210,000 

Subtotal Construction $17,959,000 

Land Acquisition 

City Administration 

Design 

Construction Management 

Project Contingency 

1 Years Inflation 

@ 5% 

@ 12% 

@ 15% 

@ 15% 

@ 3% 

0 

898,000 

2,155,100 

2,693,900 

2,693,900 

538,800 

Subtotal $26,938,700 

E.H.W.M Page 10 of 10 Prepared by HDL Engineering 
 

 

North Slope Borough 

Nuiqsut Repair Bridge Crossing Project Analysis Report 

APPENDIX B 

CONCEPT DRAWINGS FOR UPPER STREAM CROSSING (SITE 2) 

1 

2A.1 SCALE: 1"=50' 

2 

2A.1 SCALE: N.T.S 
1 

2A.1 SCALE: 1"=50' 

2 

2A.1 SCALE: N.T.S 
1 

2B/3B.2 SCALE: N.T.S 

3 

2B/3B.2 SCALE: N.T.S 

2B/3B.2 SCALE: N.T.S 

2 

 

 

North Slope Borough 

Nuiqsut Repair Bridge Crossing Project Analysis Report 

APPENDIX C 

CONCEPT DRAWINGS FOR TRIBUTARY STREAM CROSSING (SITE 3) 

1 

3B.1 SCALE: 1"=20' 

2 

3B.1 SCALE: N.T.S 
1 

2B/3B.2 SCALE: N.T.S 

3 

2B/3B.2 SCALE: N.T.S 

2B/3B.2 SCALE: N.T.S 

2 
1 

3C.1 SCALE: 1"=20' 

2 

3C.1 SCALE: N.T.S 
1 

3C.2 SCALE: N.T.S 

3 

1.1 SCALE: N.T.S 

3C.2 SCALE: N.T.S 

2 
 

 

North Slope Borough 

Nuiqsut Repair Bridge Crossing Project Analysis Report 

APPENDIX D 

HDL SITE INSPECTION REPORT 

 

 

 

 

 

 

 

 

MEMORANDUM 

CIVIL 

ENGINEERING 

GEOTECHNICAL 

ENGINEERING 

TRANSPORTATION 

ENGINEERING 

ENVIRONMENTAL 

SERVICES 

PLANNING 

SURVEYING 

CONSTRUCTION 

ADMINSTRATION 

MATERIAL 

TESTING 

RIGHT-OF-WAY 

SERVICES 

DATE: September 8, 2015 

TO: Jack Frantz, North Slope Borough Project Administrator 

FROM: Adam Bruscher, Project Engineer 

RE: August 20-21, NSB PAR Bridge Crossing Repair - Nuiqsut Site Inspection 

On Thursday August 20, 2015, I departed Anchorage with Scott Hattenburg and Kyle Albert 

of Hattenburg Dilley & Linnell via Alaska Airlines at 7:35 AM and arrived in Prudhoe Bay at 

9:17 AM. We departed Prudhoe Bay at 1:30 PM via Ravn Alaska and arrived in Nuiqsut at 

1:50 PM. Upon arriving in Nuiqsut we were greeted by Kuukpik Hotel staff and transported 

to Kuukpikmiut Subsistence Oversight Panel Inc. for our vehicle rental. Upon obtaining the 

vehicle rental we checked into our rooms at the Kuukpik Hotel. 

Temperatures were in the low-40°Fs during the day and mid-30°Fs at night. Conditions 

were overcast during the site visit. 

The purpose for the trip was to investigate and gather the field information necessary to 

prepare a Project Analysis Report (PAR) for the North Slope Borough (Borough) to repair 

two temporary culvert crossings and one failed bridge crossing (Figure 1). During our visit 

to Nuiqsut we also completed an as-built survey of the PAPI pads for the Nuiqsut Airport. 

Figure 1: project location map 

Upon departing the hotel we spoke with Thomas, the Public Works Supervisor for Nuiqsut. 

He mentioned that extreme high water events occur during the spring ice breakup and the 

only visible landmark is the gravel pile located 0.7 miles east of the village and a knoll 0.1 

miles east of the village (Figure 1). He also informed us that the backwater from the Colville 

River causes the water level to rise well above the access road, thus annually washing out 

the lower stream crossing by the boat launch. The tributary stream crossing south of the 

airport is armored with sandbags and though it overtops annually, it has not washed out. 

3335 Arctic Boulevard Suite 100 • Anchorage Alaska 99503 • Phone: 907.564.2120 • Fax: 907.564.2122 

202 W. Elmwood Avenue • Palmer Alaska 99645 • Phone: 907.746.5230 • Fax: 907.746.5231 
 

 

 

 

 

 

 

RE: August 20-21, 2015 Nuiqsut Inspection Report 

September 2, 2015 

Page 2 of 3 

For the remainder of the day on August 20th we performed a preliminary investigation of 

the three stream crossings and as a separate project as-built the newly constructed PAPI 

pads at the airport. 

On August 21st we started our field work at the temporary culvert crossing on the boat ramp 

access road. We gathered measurements on the existing pipes, roadway dimensions. We 

setup a level and took field measurements on the top of the roadway, top of pipes and water 

level at the culverts. We collected a cross section of the stream 100 feet upstream of the 

bridge, recording relative elevations at 10’ intervals. 

Figure 2: Temporary culvert crossing, Road to the Boat Launch, two 48-inch CMPs 

Next we visited the failed bridge location. We noted the condition of the bridge, what failed, 

and the sizes and dimension of the structural components of the bridge. We setup a level 

and took relative elevation measurements on the centerline of the bridge deck, the water 

surface, channel bottom, and centerline of the road 75 feet East and West of the structure. 

To better understand the channel hydraulics we recorded a reference cross section roughly 

250 feet downstream of the bridge. 

Figure 3: Failed 42-foot span Bridge, Road to Boat Launch 

The last structure we visited was the tributary stream crossing south of the airport on the 

road to the water source. We gathered data in a similar fashion to the first culvert crossing 

and noted the dimensions of the existing pipes and roadway widths. A level was used to 

determine relative heights for the top of the roadway, culverts, and water surface. A 

reference cross section was collected 100 feet upstream of the crossing. High water debris 
 

 

 

 

 

 

RE: August 20-21, 2015 Nuiqsut Inspection Report 

September 2, 2015 

Page 3 of 3 

lines were located at the edges of the cross-section. The road embankment at this crossing 

was armored with sandbags that appeared to help protect the structure from erosion. 

Figure 4: Temporary culvert crossing – Road to Water Source, 

three 48-inch diameter CMPs 

Upon completing visits to all three structures, we revisited the failed bridge location and 

investigated surrounding areas to locate the high water debris lines. We found two locations 

with evidence of debris from high water events. We estimated that the lower of the two 

debris lines represented a normal high water event due to the large amount of debris in the 

area. The relative elevation of this debris line was approximately 2 feet higher than the 

centerline of the bridge deck. We estimated the higher of the debris lines represented an 

extreme high water event. This debris line was measured to be approximately 8.5 feet 

higher than the bridge deck. 

Figure 5: High water debris line 

After documenting the location and relative elevations of the high water lines we gathered 

our equipment, departed from Nuiqsut at 3:50 PM and arrived in Anchorage at 8:39 PM. 

\\hdlalaska.com\HDL\jobs\15-031 North Slope Borough PARs 2015 Term (NSB)\02 - NUI Bridge Crossing Repairs\Site Visit\August 20 21 NSB PAR Bridge Crossing Repair - 

Nuiqsut Site Inspection.docx 
GMT2 Development Project 

Wetlands Mitigation Plan 

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GMT2 Development Project 

Wetlands Mitigation Plan 

APPENDIX C 

LETTER AGREEMENT BETWEEN CPAI AND NSB 
ConocriPhillips 

Alaska 

March 1, 2018 

Harry K. Brower, Jr., Mayor 

North Slope Borough 

P.O. Box 69 

Utqiagvik, Alaska 99723 

Re: Nuiqsut Freshwater Lake Road Culvert Replacement 

Dear Mayor Brower: 

This letter is intended to clarify and document the oral discussions among ConocoPhillips Alaska, Inc., 

("CPAI") staff and the North Slope Borough ("NSB") staff about replacing culverts that pass a beaded 

stream through the road to the Nuiqsut freshwater lake. To confirm that CPAI and NSB share a common 

understanding of how the proposed project will proceed, we ask that you countersign this letter in the 

space provided below. 

The culvert battery at issue is located about 6,200 feet upstream from the Nigliq Channel and is 

identified at Site 3 in the NSB's Project Analysis Report (PAR) dated February 10, 2016 and prepared by 

Hattenburg, Dilley, and Linnell of Anchorage, Alaska. At this location, the gravel road has washed out 

repeatedly during high water events, resulting in a degraded stream function and fish passage. 

According to the PAR, this section of roadway overtops during break-up events and the risk of 

overtopping could be substantially reduced by raising the height of the road and increasing the volume 

of hydrologic flow beneath it by, for example, replacing the existing culverts with a new flow through 

design that could be as simple as a larger culvert battery, though detailed engineering would be needed 

to support final project design. NSB recognizes that an improved stream crossing is desirable. 

CPAI has identified improved waterflow at this location as a valuable wetland restoration project that 

would merit credit as compensatory mitigation under the U.S. Army Corp of Engineers ("USACE") 

Section 404 permitting program in connection with our GMT2 development. CPAI has had preliminary 

planning discussions with USACE, Kuukpik Corporation, NSB, and others to develop this project. The 

next step is to engage an engineering firm to prepare a preliminary design. CPAI is prepared to do this, 

based on the following key points of mutual agreement: 

1. NSB understands that CPAI is proposing to perform a culvert replacement or other project to 

improve water flow at the road crossing, for the purpose of getting credit from the USACE as 

compensatory mitigation in connection with a Section 404 permit for the GMT2 project. 

Implementation of this project depends on getting approvals from USACE and others as 

necessary to fulfill the purpose of this project. 

Stephen Thatcher 

Manager 

Western North Slope Development 

Post Office Box 100360 

Anchorage, Alaska 99510 

ATO-1770 

Phone 907.263.4464 

Stephen.Thatcher@conocophillips.com 
Harry K. Brower, Jr., Mayor 

March 3, 2018 

Page 2 

2. NSB and CPAI expect to enter into good faith discussions in the future with the goal of entering; 

into a binding agreement about project specifications, payment obligations, liabilities, and 

related issues. The basic proposal is that CPAI would pay for most or all of the project costs, and 

the NSB would assume ownership, maintenance obligations, and any liability for the new 

crossing after determining that it meets project specifications. Implementation of the project 

will depend on reaching timely agreement on the necessary terms and conditions. 

3. CPAI plans to engage an engineering firm in March 2018 to prepare a preliminary design and 

prepare permit application documents. CPAI will bear the full cost of this preliminary design. 

4. CPAI also plans to engage an engineering firm to perform hydrology field studies during the 

summer of 2018 to gather information necessary for final project design. The decision regarding 

whether or not to execute final project design will be made shortly after receiving the 

preliminary design and hydrology field studies reports. 

5. If CPAI ultimately does not proceed with this project, but the NSB wishes to have the benefit of 

preliminary design work or summer hydrology studies funded by CPAI, CPAI will allow NSB to 

purchase the work at cost. 

Details on these issues are being discussed primarily by Brad Thomas for CPAI and Bob Shears for NSB. 

Please countersign below to confirm that NSB agrees with the basic project structure described in this 

letter. We will then move forward incrementally to flesh out the full project details, with the goal of 

ultimately having a concise but comprehensive written agreement between CPAI and NSB. 

Yours truly, 

~~Stephen Thatcher 

On behalf of NSB, I agree with the key points of understanding set forth above: 

Harry K. Brower, Jr., Mayor Date 
GMT2 Development Project 

Wetlands Mitigation Plan 

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GMT2 Development Project 

Wetlands Mitigation Plan 

APPENDIX D 

ABR GMT2 WETLANDS DELINEATION 












































GMT2 Development Project 

Wetlands Mitigation Plan 

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GMT2 Development Project 

Wetlands Mitigation Plan 

APPENDIX E 

ANSRAM DATASHEETS AND DEBIT-CREDIT CALCULATION 
GMT2 Development Project 

Wetlands Mitigation Plan 

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GMT2 ANSRAM PRE-CONSTRUCTION 

Wetland Functions and Values Evaluation Questions Unique ID: GMT2_P E 

HGM Class: Flats 

Cowardin Class: PEM1F 

Size (acres): 4.3 

Disturbance Category: 0 

A. Exceptional Habitat Designation Y or N 

1. Is wetland located within an area considered to be irreplaceable, or does it have unique habitat not found anywhere else on the North 

Slope (i.e., Teshukpuk Lake Surface Protection Area, Colville iver Delta, Beaufort Sea Coastal Marsh) N 

2. Is wetland located within an area considered by any regulatory agency to be an Aquatic esource of National Importance (A NI) N 

B. Flood Flow Alteration Y or N or N/A 

1. Wetland occurs in the upper portion of its watershed Y 

2. Wetland is relatively flat area and is capable of retaining higher volumes of water during storm events than under normal rainfall Y 

3. Wetland is a closed system N 

4. If flow through, wetland has constricted outlet with signs of fluctuating water levels, algal mats, and/or lodged debris Y 

5. Wetland contains a dense herbaceous layer (>70% cover) or woody vegetation N 

6. Wetland receives floodwater from an adjacent water course at least once every 10 years Y 

7. Floodwaters come as sheet flow rather than channel flow Y 

C. Sediment Removal: If moving waters consider only statements 1 and 2 Y or N or N/A 

1. Sources of excess sediment are present up gradient of the wetland N 

2. Is wetland influenced by slow-moving water and/or a deepwater habitat N 

3. Is herbaceous vegetation present (>50% cover) Y 

4. Interspersion of vegetation and surface water is moderate in wetland presently or during flooding at least once ever 10 years Y 

5. Sediment deposits are present in wetland (observation or noted in application materials) Y 

D. Nutrient and Toxicant Removal Y or N or N/A 

1. Sources of excess nutrients (fertilizers) and toxicants (pesticides and heavy metals) are present up gradient and able to influence the 

wetland N/A 

2. Wetland is inundated or has indicators that flooding is a seasonal event during the growing season by visual observation, or indicated by 

other hydrological data source Y 

3. Wetland has at least 30% aerial cover of live vegetation Y 

E. Erosion Control and Shoreline Stabilization Y or N or N/A 

1. Wetland has dense, energy absorbing vegetation (>70%) bordering the water course and no evidence of erosion N/A 

2. An herbaceous layer is part of this dense vegetation N/A 

3. Shrubs able to withstand erosive flood events N/A 

F. Production of Organic Matter and its Export Y or N or N/A 

1. Wetland has at least 30% aerial cover of herbaceous vegetation Y 

2. Woody plants in wetland are mostly deciduous Y 

3. Interspersion of vegetation and surface water is high in wetland Y 

4. Wetland is inundated or has indicators that flooding is a seasonal event during the growing season Y 

5. Wetland has outlet from which organic matter is flushed Y 

G. General Habitat Suitability Y or N or N/A 

1. Is wetland located greater than 300-feet from existing development Y 

2. Undeveloped upland buffers abutting wetland N/A 

3. Wetland part of a larger wetland complex, not fragmented Y 

4. Diversity of plant species is apparent (> or = 5 species with at least 10% cover each) Y 

5. Evidence of wildlife use Y 

6. Wetland has a moderate degree of cowardin class interspersion Y 

H. General Fish Habitat Y or N or N/A 

1. Wetland has perennial or intermittent surface-water connection to a fish-bearing water body N/A 

2. Does wetland provide overwintering habitat for fish N/A 

3. Documented presence of fish N/A 

4. Herbaceous and/or woody vegetation is present in wetland and/or buffer to provide cover, shade, and/or detrital matter N/A 

5. Spawning areas are present (aquatic vegetation and/or gravel beds) N/A 

6. Juvenile rest areas N/A 

I. Native Plant Richness Y or N or N/A 

1. Dominant and codominant plants are native Y 

2. Wetland contains two or more Cowardin Classes Y 

3. Wetland has two or more strata of vegetation Y 

J. Educational or Scientific Value Y or N or N/A 

1. Site has scientific or educational use N 

2. Wetland is in public ownership Y 

3. Accessible trails available N 

4. Is the area a known recreation area Y 

5. Subsistence (berry picking, fishing, hunting) Y 

K. Uniqueness and Heritage Y or N or N/A 

1. Wetland contains documented occurrence of a state or federally listed threatened or endangered species N 

2. Wetland contains documented critical habitat, high quality ecosystems, or priority species respectively designated by the U.S. Fish and 

Wildlife Service N 

3. Wetland has biological, geological, or other features that are determined rare N 

4. Wetland has been determined significant because it provides functions scarce for the area N 

5. Are there known or reported cultural resources in the area N/A 

6. Is the area a known subsistence/recreation/living area Y 

7. Wetland complex contains one or more of the following habitats:

 a) Tall shrub habitat (>.5ft in height) dominated by Salix spp. 

b) Aquatic herb habitat dominated by Arctophila fulva. 

c) Semi-permanently flooded to permanently flooded vegetated portions of drained lake basins 

d) Anadromous fish overwintering habitat 

e) Patterned wet sedge meadow and low center polygons 

f) High center polygon complex 

g) iverine coastal mudflats 

h) Non-patterned wet meadow adjacent to streams and river bluffs. Y 

Functional Sheet 1 of 3 
GMT2_P E 

Flats 

PEM1F 

4.3 

Raw Score Weighted Score 

Flood Flow Alteration Disturbance Activities 

1 1 Disturbance Category 0 

2 1 

3 0 Disturbance Category Impact Factor 

4 1 0 = 1 

5 0 1 = 0.99 

6 1 2 = 0.95 

7 1 3 = 0.9 

Total 0.714 

Sediment Removal Disturbance Impact Factor 1 

1 0 

2 0 

3 1 

4 1 

5 1 

Total 0.600 

Nutrient and Toxicant Removal 

1 N/A 

2 1 

3 1 

Total 1.000 

Erosion Control and Shoreline Stabilization 

1 N/A 

2 N/A 

3 N/A 

Total N/A 

Production of Organic Matter and its Export 

1 1 

2 1 

3 1 

4 1 

5 1 

Total 1.000 

General Habitat Suitability 

1 1 

2 N/A 

3 1 

4 1 

5 1 

6 1 

Total 1.000 

General Fish Habitat 

1 N/A 

2 N/A 

3 N/A 

4 N/A 

5 N/A 

6 N/A 

Total N/A 

Native Plant Richness 

1 1 

2 1 

3 1 

Total 1.000 

Educational or Scientific Value 

1 0 

2 1 

3 0 

4 1 

5 1 

Total 0.600 

Uniqueness and Heritage 

1 0 

2 0 

3 0 

4 0 

5 N/A 

6 1 

7 1 

Total 0.333 

Unique ID: 

HGM Class: 

Cowardin Class: 

Size (acres): 

Wetland Functions and Values Results 

Functional Sheet 2 of 3 
Unique ID GMT2_PRE 

0 

Flood Flow Alteration 0.714 

Sediment Removal 0.600 

Nutrient and Toxicant Removal 1.000 

Erosion Control and Shoreline Stabilization N/A 

Production of Organic Matter and its Export 1.000 

General Habitat Suitability 1.000 

General Fish Habitat N/A 

Native Plant Richness 1.000 

Educational or Scientific Value 0.600 

Uniqueness and Heritage 0.333 

Total 6.248 

Standardization 

8 

0.781 

0.781 

Overall Functional Score (Category) 0.76 - 1.00 I Highest I 

0.51 - 0.75 II 

0.26 - 0.50 III 

0 - 0.25 IV Lowest 

Notes: 

1) Scores for each category component, 0 = no and 1 = yes. 

2) Not all functional categories will be applicable to each wetland functional assessment. 

For example, General Fish Habitat is only applicable to wetlands that are fish-bearing waters. 

Functional categories that are not applicable will be treated as NA (not applicable), which means there is no score for 

that component. No score is not the same as 0, which would erroneously reduce the total score. 

Accordingly, the maximum total score will be reduced by 1 point for each functional category that is not applicable. 

For example, if General Fish Habitat does not apply, then the Total # of functions assessed is 9. 

3) NA = an item that is currently not applicable, but could be applicable at a future time if more data are available. 

4) See impacted area assessment worksheet for determination of disturbance activities. 

Apply the correct impact factor to the disturbance category. 

Weighted Score 

Total # of functions assessed 

Standardized Total 

Wetland Functions and Values Results (cont.) 

Exceptional Habitat Designation 

Total (Including Disturbance and Exceptional Habitat) 

Functional Sheet 3 of 3 
Wetland Functions and Values Evaluation Questions Unique ID: GMT2_P E 

HGM Class: Flats 

Cowardin Class: pem1ss1b 

Size (acres): 49.8 

Disturbance Category: 0 

A. Exceptional Habitat Designation Y or N 

1. Is wetland located within an area considered to be irreplaceable, or does it have unique habitat not found anywhere else on the North 

Slope (i.e., Teshukpuk Lake Surface Protection Area, Colville iver Delta, Beaufort Sea Coastal Marsh) N 

2. Is wetland located within an area considered by any regulatory agency to be an Aquatic esource of National Importance (A NI) N 

B. Flood Flow Alteration Y or N or N/A 

1. Wetland occurs in the upper portion of its watershed Y 

2. Wetland is relatively flat area and is capable of retaining higher volumes of water during storm events than under normal rainfall N 

3. Wetland is a closed system N 

4. If flow through, wetland has constricted outlet with signs of fluctuating water levels, algal mats, and/or lodged debris N 

5. Wetland contains a dense herbaceous layer (>70% cover) or woody vegetation Y 

6. Wetland receives floodwater from an adjacent water course at least once every 10 years Y 

7. Floodwaters come as sheet flow rather than channel flow Y 

C. Sediment Removal: If moving waters consider only statements 1 and 2 Y or N or N/A 

1. Sources of excess sediment are present up gradient of the wetland N 

2. Is wetland influenced by slow-moving water and/or a deepwater habitat N 

3. Is herbaceous vegetation present (>50% cover) Y 

4. Interspersion of vegetation and surface water is moderate in wetland presently or during flooding at least once ever 10 years N 

5. Sediment deposits are present in wetland (observation or noted in application materials) N 

D. Nutrient and Toxicant Removal Y or N or N/A 

1. Sources of excess nutrients (fertilizers) and toxicants (pesticides and heavy metals) are present up gradient and able to influence the 

wetland N/A 

2. Wetland is inundated or has indicators that flooding is a seasonal event during the growing season by visual observation, or indicated by 

other hydrological data source Y 

3. Wetland has at least 30% aerial cover of live vegetation Y 

E. Erosion Control and Shoreline Stabilization Y or N or N/A 

1. Wetland has dense, energy absorbing vegetation (>70%) bordering the water course and no evidence of erosion N/A 

2. An herbaceous layer is part of this dense vegetation N/A 

3. Shrubs able to withstand erosive flood events N/A 

F. Production of Organic Matter and its Export Y or N or N/A 

1. Wetland has at least 30% aerial cover of herbaceous vegetation Y 

2. Woody plants in wetland are mostly deciduous Y 

3. Interspersion of vegetation and surface water is high in wetland N/A 

4. Wetland is inundated or has indicators that flooding is a seasonal event during the growing season N 

5. Wetland has outlet from which organic matter is flushed Y 

G. General Habitat Suitability Y or N or N/A 

1. Is wetland located greater than 300-feet from existing development Y 

2. Undeveloped upland buffers abutting wetland N/A 

3. Wetland part of a larger wetland complex, not fragmented Y 

4. Diversity of plant species is apparent (> or = 5 species with at least 10% cover each) Y 

5. Evidence of wildlife use Y 

6. Wetland has a moderate degree of cowardin class interspersion Y 

H. General Fish Habitat Y or N or N/A 

1. Wetland has perennial or intermittent surface-water connection to a fish-bearing water body N/A 

2. Does wetland provide overwintering habitat for fish N/A 

3. Documented presence of fish N/A 

4. Herbaceous and/or woody vegetation is present in wetland and/or buffer to provide cover, shade, and/or detrital matter N/A 

5. Spawning areas are present (aquatic vegetation and/or gravel beds) N/A 

6. Juvenile rest areas N/A 

I. Native Plant Richness Y or N or N/A 

1. Dominant and codominant plants are native Y 

2. Wetland contains two or more Cowardin Classes Y 

3. Wetland has two or more strata of vegetation Y 

J. Educational or Scientific Value Y or N or N/A 

1. Site has scientific or educational use N 

2. Wetland is in public ownership Y 

3. Accessible trails available N 

4. Is the area a known recreation area Y 

5. Subsistence (berry picking, fishing, hunting) Y 

K. Uniqueness and Heritage Y or N or N/A 

1. Wetland contains documented occurrence of a state or federally listed threatened or endangered species N 

2. Wetland contains documented critical habitat, high quality ecosystems, or priority species respectively designated by the U.S. Fish and 

Wildlife Service N 

3. Wetland has biological, geological, or other features that are determined rare N 

4. Wetland has been determined significant because it provides functions scarce for the area N 

5. Are there known or reported cultural resources in the area N/A 

6. Is the area a known subsistence/recreation/living area Y 

7. Wetland complex contains one or more of the following habitats:

 a) Tall shrub habitat (>.5ft in height) dominated by Salix spp. 

b) Aquatic herb habitat dominated by Arctophila fulva. 

c) Semi-permanently flooded to permanently flooded vegetated portions of drained lake basins 

d) Anadromous fish overwintering habitat 

e) Patterned wet sedge meadow and low center polygons 

f) High center polygon complex 

g) iverine coastal mudflats 

h) Non-patterned wet meadow adjacent to streams and river bluffs. Y 

Functional Sheet 1 of 3 
GMT2_P E 

Flats 

pem1ss1b 

49.8 

Raw Score Weighted Score 

Flood Flow Alteration Disturbance Activities 

1 1 Disturbance Category 0 

2 0 

3 0 Disturbance Category Impact Factor 

4 0 0 = 1 

5 1 1 = 0.99 

6 1 2 = 0.95 

7 1 3 = 0.9 

Total 0.571 

Sediment Removal Disturbance Impact Factor 1 

1 0 

2 0 

3 1 

4 0 

5 0 

Total 0.200 

Nutrient and Toxicant Removal 

1 N/A 

2 1 

3 1 

Total 1.000 

Erosion Control and Shoreline Stabilization 

1 N/A 

2 N/A 

3 N/A 

Total N/A 

Production of Organic Matter and its Export 

1 1 

2 1 

3 N/A 

4 0 

5 1 

Total 0.750 

General Habitat Suitability 

1 1 

2 N/A 

3 1 

4 1 

5 1 

6 1 

Total 1.000 

General Fish Habitat 

1 N/A 

2 N/A 

3 N/A 

4 N/A 

5 N/A 

6 N/A 

Total N/A 

Native Plant Richness 

1 1 

2 1 

3 1 

Total 1.000 

Educational or Scientific Value 

1 0 

2 1 

3 0 

4 1 

5 1 

Total 0.600 

Uniqueness and Heritage 

1 0 

2 0 

3 0 

4 0 

5 N/A 

6 1 

7 1 

Total 0.333 

Unique ID: 

HGM Class: 

Cowardin Class: 

Size (acres): 

Wetland Functions and Values Results 

Functional Sheet 2 of 3 
Unique ID GMT2_PRE 

0 

Flood Flow Alteration 0.571 

Sediment Removal 0.200 

Nutrient and Toxicant Removal 1.000 

Erosion Control and Shoreline Stabilization N/A 

Production of Organic Matter and its Export 0.750 

General Habitat Suitability 1.000 

General Fish Habitat N/A 

Native Plant Richness 1.000 

Educational or Scientific Value 0.600 

Uniqueness and Heritage 0.333 

Total 5.455 

Standardization 

8 

0.682 

0.682 

Overall Functional Score (Category) 0.76 - 1.00 I Highest II 

0.51 - 0.75 II 

0.26 - 0.50 III 

0 - 0.25 IV Lowest 

Notes: 

1) Scores for each category component, 0 = no and 1 = yes. 

2) Not all functional categories will be applicable to each wetland functional assessment. 

For example, General Fish Habitat is only applicable to wetlands that are fish-bearing waters. 

Functional categories that are not applicable will be treated as NA (not applicable), which means there is no score for 

that component. No score is not the same as 0, which would erroneously reduce the total score. 

Accordingly, the maximum total score will be reduced by 1 point for each functional category that is not applicable. 

For example, if General Fish Habitat does not apply, then the Total # of functions assessed is 9. 

3) NA = an item that is currently not applicable, but could be applicable at a future time if more data are available. 

4) See impacted area assessment worksheet for determination of disturbance activities. 

Apply the correct impact factor to the disturbance category. 

Weighted Score 

Total # of functions assessed 

Standardized Total 

Total (Including Disturbance and Exceptional Habitat) 

Wetland Functions and Values Results (cont.) 

Exceptional Habitat Designation 

Functional Sheet 3 of 3 
Wetland Functions and Values Evaluation Questions Unique ID: GMT2_P E 

HGM Class: Flats 

Cowardin Class: pem1ss1e 

Size (acres): 23.7 

Disturbance Category: 0 

A. Exceptional Habitat Designation Y or N 

1. Is wetland located within an area considered to be irreplaceable, or does it have unique habitat not found anywhere else on the North 

Slope (i.e., Teshukpuk Lake Surface Protection Area, Colville iver Delta, Beaufort Sea Coastal Marsh) N 

2. Is wetland located within an area considered by any regulatory agency to be an Aquatic esource of National Importance (A NI) N 

B. Flood Flow Alteration Y or N or N/A 

1. Wetland occurs in the upper portion of its watershed Y 

2. Wetland is relatively flat area and is capable of retaining higher volumes of water during storm events than under normal rainfall Y 

3. Wetland is a closed system N 

4. If flow through, wetland has constricted outlet with signs of fluctuating water levels, algal mats, and/or lodged debris Y 

5. Wetland contains a dense herbaceous layer (>70% cover) or woody vegetation Y 

6. Wetland receives floodwater from an adjacent water course at least once every 10 years Y 

7. Floodwaters come as sheet flow rather than channel flow Y 

C. Sediment Removal: If moving waters consider only statements 1 and 2 Y or N or N/A 

1. Sources of excess sediment are present up gradient of the wetland N 

2. Is wetland influenced by slow-moving water and/or a deepwater habitat N 

3. Is herbaceous vegetation present (>50% cover) Y 

4. Interspersion of vegetation and surface water is moderate in wetland presently or during flooding at least once ever 10 years Y 

5. Sediment deposits are present in wetland (observation or noted in application materials) Y 

D. Nutrient and Toxicant Removal Y or N or N/A 

1. Sources of excess nutrients (fertilizers) and toxicants (pesticides and heavy metals) are present up gradient and able to influence the 

wetland N/A 

2. Wetland is inundated or has indicators that flooding is a seasonal event during the growing season by visual observation, or indicated by 

other hydrological data source Y 

3. Wetland has at least 30% aerial cover of live vegetation Y 

E. Erosion Control and Shoreline Stabilization Y or N or N/A 

1. Wetland has dense, energy absorbing vegetation (>70%) bordering the water course and no evidence of erosion N/A 

2. An herbaceous layer is part of this dense vegetation N/A 

3. Shrubs able to withstand erosive flood events N/A 

F. Production of Organic Matter and its Export Y or N or N/A 

1. Wetland has at least 30% aerial cover of herbaceous vegetation Y 

2. Woody plants in wetland are mostly deciduous Y 

3. Interspersion of vegetation and surface water is high in wetland Y 

4. Wetland is inundated or has indicators that flooding is a seasonal event during the growing season Y 

5. Wetland has outlet from which organic matter is flushed Y 

G. General Habitat Suitability Y or N or N/A 

1. Is wetland located greater than 300-feet from existing development Y 

2. Undeveloped upland buffers abutting wetland N/A 

3. Wetland part of a larger wetland complex, not fragmented Y 

4. Diversity of plant species is apparent (> or = 5 species with at least 10% cover each) Y 

5. Evidence of wildlife use Y 

6. Wetland has a moderate degree of cowardin class interspersion Y 

H. General Fish Habitat Y or N or N/A 

1. Wetland has perennial or intermittent surface-water connection to a fish-bearing water body N/A 

2. Does wetland provide overwintering habitat for fish N/A 

3. Documented presence of fish N/A 

4. Herbaceous and/or woody vegetation is present in wetland and/or buffer to provide cover, shade, and/or detrital matter N/A 

5. Spawning areas are present (aquatic vegetation and/or gravel beds) N/A 

6. Juvenile rest areas N/A 

I. Native Plant Richness Y or N or N/A 

1. Dominant and codominant plants are native Y 

2. Wetland contains two or more Cowardin Classes Y 

3. Wetland has two or more strata of vegetation Y 

J. Educational or Scientific Value Y or N or N/A 

1. Site has scientific or educational use N 

2. Wetland is in public ownership Y 

3. Accessible trails available N 

4. Is the area a known recreation area Y 

5. Subsistence (berry picking, fishing, hunting) Y 

K. Uniqueness and Heritage Y or N or N/A 

1. Wetland contains documented occurrence of a state or federally listed threatened or endangered species N 

2. Wetland contains documented critical habitat, high quality ecosystems, or priority species respectively designated by the U.S. Fish and 

Wildlife Service N 

3. Wetland has biological, geological, or other features that are determined rare N 

4. Wetland has been determined significant because it provides functions scarce for the area N 

5. Are there known or reported cultural resources in the area N/A 

6. Is the area a known subsistence/recreation/living area Y 

7. Wetland complex contains one or more of the following habitats:

 a) Tall shrub habitat (>.5ft in height) dominated by Salix spp. 

b) Aquatic herb habitat dominated by Arctophila fulva. 

c) Semi-permanently flooded to permanently flooded vegetated portions of drained lake basins 

d) Anadromous fish overwintering habitat 

e) Patterned wet sedge meadow and low center polygons 

f) High center polygon complex 

g) iverine coastal mudflats 

h) Non-patterned wet meadow adjacent to streams and river bluffs. Y 

Functional Sheet 1 of 3 
GMT2_P E 

Flats 

pem1ss1e 

23.7 

Raw Score Weighted Score 

Flood Flow Alteration Disturbance Activities 

1 1 Disturbance Category 0 

2 1 

3 0 Disturbance Category Impact Factor 

4 1 0 = 1 

5 1 1 = 0.99 

6 1 2 = 0.95 

7 1 3 = 0.9 

Total 0.857 

Sediment Removal Disturbance Impact Factor 1 

1 0 

2 0 

3 1 

4 1 

5 1 

Total 0.600 

Nutrient and Toxicant Removal 

1 N/A 

2 1 

3 1 

Total 1.000 

Erosion Control and Shoreline Stabilization 

1 N/A 

2 N/A 

3 N/A 

Total N/A 

Production of Organic Matter and its Export 

1 1 

2 1 

3 1 

4 1 

5 1 

Total 1.000 

General Habitat Suitability 

1 1 

2 N/A 

3 1 

4 1 

5 1 

6 1 

Total 1.000 

General Fish Habitat 

1 N/A 

2 N/A 

3 N/A 

4 N/A 

5 N/A 

6 N/A 

Total N/A 

Native Plant Richness 

1 1 

2 1 

3 1 

Total 1.000 

Educational or Scientific Value 

1 0 

2 1 

3 0 

4 1 

5 1 

Total 0.600 

Uniqueness and Heritage 

1 0 

2 0 

3 0 

4 0 

5 N/A 

6 1 

7 1 

Total 0.333 

Unique ID: 

HGM Class: 

Cowardin Class: 

Size (acres): 

Wetland Functions and Values Results 

Functional Sheet 2 of 3 
Unique ID GMT2_PRE 

0 

Flood Flow Alteration 0.857 

Sediment Removal 0.600 

Nutrient and Toxicant Removal 1.000 

Erosion Control and Shoreline Stabilization N/A 

Production of Organic Matter and its Export 1.000 

General Habitat Suitability 1.000 

General Fish Habitat N/A 

Native Plant Richness 1.000 

Educational or Scientific Value 0.600 

Uniqueness and Heritage 0.333 

Total 6.390 

Standardization 

8 

0.799 

0.799 

Overall Functional Score (Category) 0.76 - 1.00 I Highest I 

0.51 - 0.75 II 

0.26 - 0.50 III 

0 - 0.25 IV Lowest 

Notes: 

1) Scores for each category component, 0 = no and 1 = yes. 

2) Not all functional categories will be applicable to each wetland functional assessment. 

For example, General Fish Habitat is only applicable to wetlands that are fish-bearing waters. 

Functional categories that are not applicable will be treated as NA (not applicable), which means there is no score for 

that component. No score is not the same as 0, which would erroneously reduce the total score. 

Accordingly, the maximum total score will be reduced by 1 point for each functional category that is not applicable. 

For example, if General Fish Habitat does not apply, then the Total # of functions assessed is 9. 

3) NA = an item that is currently not applicable, but could be applicable at a future time if more data are available. 

4) See impacted area assessment worksheet for determination of disturbance activities. 

Apply the correct impact factor to the disturbance category. 

Weighted Score 

Total # of functions assessed 

Standardized Total 

Total (Including Disturbance and Exceptional Habitat) 

Wetland Functions and Values Results (cont.) 

Exceptional Habitat Designation 

Functional Sheet 3 of 3 
Wetland Functions and Values Evaluation Questions Unique ID: GMT2_P E 

HGM Class: Depressional 

Cowardin Class: pubh 

Size (acres): 0.1 

Disturbance Category: 0 

A. Exceptional Habitat Designation Y or N 

1. Is wetland located within an area considered to be irreplaceable, or does it have unique habitat not found anywhere else on the North 

Slope (i.e., Teshukpuk Lake Surface Protection Area, Colville iver Delta, Beaufort Sea Coastal Marsh) N 

2. Is wetland located within an area considered by any regulatory agency to be an Aquatic esource of National Importance (A NI) N 

B. Flood Flow Alteration Y or N or N/A 

1. Wetland occurs in the upper portion of its watershed Y 

2. Wetland is relatively flat area and is capable of retaining higher volumes of water during storm events than under normal rainfall Y 

3. Wetland is a closed system Y 

4. If flow through, wetland has constricted outlet with signs of fluctuating water levels, algal mats, and/or lodged debris N/A 

5. Wetland contains a dense herbaceous layer (>70% cover) or woody vegetation N/A 

6. Wetland receives floodwater from an adjacent water course at least once every 10 years Y 

7. Floodwaters come as sheet flow rather than channel flow Y 

C. Sediment Removal: If moving waters consider only statements 1 and 2 Y or N or N/A 

1. Sources of excess sediment are present up gradient of the wetland N 

2. Is wetland influenced by slow-moving water and/or a deepwater habitat Y 

3. Is herbaceous vegetation present (>50% cover) N/A 

4. Interspersion of vegetation and surface water is moderate in wetland presently or during flooding at least once ever 10 years N/A 

5. Sediment deposits are present in wetland (observation or noted in application materials) Y 

D. Nutrient and Toxicant Removal Y or N or N/A 

1. Sources of excess nutrients (fertilizers) and toxicants (pesticides and heavy metals) are present up gradient and able to influence the 

wetland N/A 

2. Wetland is inundated or has indicators that flooding is a seasonal event during the growing season by visual observation, or indicated by 

other hydrological data source Y 

3. Wetland has at least 30% aerial cover of live vegetation N/A 

E. Erosion Control and Shoreline Stabilization Y or N or N/A 

1. Wetland has dense, energy absorbing vegetation (>70%) bordering the water course and no evidence of erosion N/A 

2. An herbaceous layer is part of this dense vegetation N/A 

3. Shrubs able to withstand erosive flood events N/A 

F. Production of Organic Matter and its Export Y or N or N/A 

1. Wetland has at least 30% aerial cover of herbaceous vegetation N/A 

2. Woody plants in wetland are mostly deciduous N/A 

3. Interspersion of vegetation and surface water is high in wetland N/A 

4. Wetland is inundated or has indicators that flooding is a seasonal event during the growing season N/A 

5. Wetland has outlet from which organic matter is flushed N/A 

G. General Habitat Suitability Y or N or N/A 

1. Is wetland located greater than 300-feet from existing development Y 

2. Undeveloped upland buffers abutting wetland N/A 

3. Wetland part of a larger wetland complex, not fragmented Y 

4. Diversity of plant species is apparent (> or = 5 species with at least 10% cover each) N/A 

5. Evidence of wildlife use Y 

6. Wetland has a moderate degree of cowardin class interspersion N/A 

H. General Fish Habitat Y or N or N/A 

1. Wetland has perennial or intermittent surface-water connection to a fish-bearing water body N/A 

2. Does wetland provide overwintering habitat for fish N/A 

3. Documented presence of fish N/A 

4. Herbaceous and/or woody vegetation is present in wetland and/or buffer to provide cover, shade, and/or detrital matter N/A 

5. Spawning areas are present (aquatic vegetation and/or gravel beds) N/A 

6. Juvenile rest areas N/A 

I. Native Plant Richness Y or N or N/A 

1. Dominant and codominant plants are native Y 

2. Wetland contains two or more Cowardin Classes N/A 

3. Wetland has two or more strata of vegetation N/A 

J. Educational or Scientific Value Y or N or N/A 

1. Site has scientific or educational use N 

2. Wetland is in public ownership Y 

3. Accessible trails available N 

4. Is the area a known recreation area Y 

5. Subsistence (berry picking, fishing, hunting) Y 

K. Uniqueness and Heritage Y or N or N/A 

1. Wetland contains documented occurrence of a state or federally listed threatened or endangered species N 

2. Wetland contains documented critical habitat, high quality ecosystems, or priority species respectively designated by the U.S. Fish and 

Wildlife Service Y 

3. Wetland has biological, geological, or other features that are determined rare N 

4. Wetland has been determined significant because it provides functions scarce for the area N 

5. Are there known or reported cultural resources in the area N 

6. Is the area a known subsistence/recreation/living area Y 

7. Wetland complex contains one or more of the following habitats:

 a) Tall shrub habitat (>.5ft in height) dominated by Salix spp. 

b) Aquatic herb habitat dominated by Arctophila fulva. 

c) Semi-permanently flooded to permanently flooded vegetated portions of drained lake basins 

d) Anadromous fish overwintering habitat 

e) Patterned wet sedge meadow and low center polygons 

f) High center polygon complex 

g) iverine coastal mudflats 

h) Non-patterned wet meadow adjacent to streams and river bluffs. Y 

Functional Sheet 1 of 3 
GMT2_P E 

Depressional 

pubh 

0.1 

Raw Score Weighted Score 

Flood Flow Alteration Disturbance Activities 

1 1 Disturbance Category 0 

2 1 

3 1 Disturbance Category Impact Factor 

4 N/A 0 = 1 

5 N/A 1 = 0.99 

6 1 2 = 0.95 

7 1 3 = 0.9 

Total 1.000 

Sediment Removal Disturbance Impact Factor 1 

1 0 

2 1 

3 N/A 

4 N/A 

5 1 

Total 0.667 

Nutrient and Toxicant Removal 

1 N/A 

2 1 

3 N/A 

Total 1.000 

Erosion Control and Shoreline Stabilization 

1 N/A 

2 N/A 

3 N/A 

Total N/A 

Production of Organic Matter and its Export 

1 N/A 

2 N/A 

3 N/A 

4 N/A 

5 N/A 

Total N/A 

General Habitat Suitability 

1 1 

2 N/A 

3 1 

4 N/A 

5 1 

6 N/A 

Total 1.000 

General Fish Habitat 

1 N/A 

2 N/A 

3 N/A 

4 N/A 

5 N/A 

6 N/A 

Total N/A 

Native Plant Richness 

1 1 

2 N/A 

3 N/A 

Total 1.000 

Educational or Scientific Value 

1 0 

2 1 

3 0 

4 1 

5 1 

Total 0.600 

Uniqueness and Heritage 

1 0 

2 1 

3 0 

4 0 

5 0 

6 1 

7 1 

Total 0.429 

Unique ID: 

HGM Class: 

Cowardin Class: 

Size (acres): 

Wetland Functions and Values Results 

Functional Sheet 2 of 3 
Unique ID GMT2_PRE 

0 

Flood Flow Alteration 1.000 

Sediment Removal 0.667 

Nutrient and Toxicant Removal 1.000 

Erosion Control and Shoreline Stabilization N/A 

Production of Organic Matter and its Export N/A 

General Habitat Suitability 1.000 

General Fish Habitat N/A 

Native Plant Richness 1.000 

Educational or Scientific Value 0.600 

Uniqueness and Heritage 0.429 

Total 5.695 

Standardization 

7 

0.814 

0.814 

Overall Functional Score (Category) 0.76 - 1.00 I Highest I 

0.51 - 0.75 II 

0.26 - 0.50 III 

0 - 0.25 IV Lowest 

Notes: 

1) Scores for each category component, 0 = no and 1 = yes. 

2) Not all functional categories will be applicable to each wetland functional assessment. 

For example, General Fish Habitat is only applicable to wetlands that are fish-bearing waters. 

Functional categories that are not applicable will be treated as NA (not applicable), which means there is no score for 

that component. No score is not the same as 0, which would erroneously reduce the total score. 

Accordingly, the maximum total score will be reduced by 1 point for each functional category that is not applicable. 

For example, if General Fish Habitat does not apply, then the Total # of functions assessed is 9. 

3) NA = an item that is currently not applicable, but could be applicable at a future time if more data are available. 

4) See impacted area assessment worksheet for determination of disturbance activities. 

Apply the correct impact factor to the disturbance category. 

Weighted Score 

Total # of functions assessed 

Standardized Total 

Total (Including Disturbance and Exceptional Habitat) 

Wetland Functions and Values Results (cont.) 

Exceptional Habitat Designation 

Functional Sheet 3 of 3 
GMT2 ANSRAM POST-CONSTRUCTION 

Wetland Functions and Values Evaluation Questions Unique ID: GMT2_P st 

HGM Class: Flats 

Cowardin Class: PEM1F 

Size (acres): 4.3 

Disturbance Category: 2 

A. Exceptional Habitat Designation Y or N 

1. Is wetland l cated within an area c nsidered t be irreplaceable, r d es it have unique habitat n t f und anywhere else n the N rth 

Sl pe (i.e., Teshukpuk Lake Surface Pr tecti n Area, C lville River Delta, Beauf rt Sea C astal Marsh) N 

2. Is wetland l cated within an area c nsidered by any regulat ry agency t be an Aquatic Res urce f Nati nal Imp rtance (ARNI) N 

B. Flood Flow Alteration Y or N or N/A 

1. Wetland ccurs in the upper p rti n f its watershed Y 

2. Wetland is relatively flat area and is capable f retaining higher v lumes f water during st rm events than under n rmal rainfall N 

3. Wetland is a cl sed system N 

4. If fl w thr ugh, wetland has c nstricted utlet with signs f fluctuating water levels, algal mats, and/ r l dged debris Y 

5. Wetland c ntains a dense herbace us layer (>70% c ver) r w dy vegetati n N 

6. Wetland receives fl dwater fr m an adjacent water c urse at least nce every 10 years Y 

7. Fl dwaters c me as sheet fl w rather than channel fl w Y 

C. Sediment Removal: If moving waters consider only statements 1 and 2 Y or N or N/A 

1. S urces f excess sediment are present up gradient f the wetland N 

2. Is wetland influenced by sl w-m ving water and/ r a deepwater habitat N 

3. Is herbace us vegetati n present (>50% c ver) N 

4. Interspersi n f vegetati n and surface water is m derate in wetland presently r during fl ding at least nce ever 10 years Y 

5. Sediment dep sits are present in wetland ( bservati n r n ted in applicati n materials) Y 

D. Nutrient and Toxicant Removal Y or N or N/A 

1. S urces f excess nutrients (fertilizers) and t xicants (pesticides and heavy metals) are present up gradient and able t influence the 

wetland N/A 

2. Wetland is inundated r has indicat rs that fl ding is a seas nal event during the gr wing seas n by visual bservati n, r indicated by 

 ther hydr l gical data s urce Y 

3. Wetland has at least 30% aerial c ver f live vegetati n N 

E. Erosion Control and Shoreline Stabilization Y or N or N/A 

1. Wetland has dense, energy abs rbing vegetati n (>70%) b rdering the water c urse and n evidence f er si n N/A 

2. An herbace us layer is part f this dense vegetati n N/A 

3. Shrubs able t withstand er sive fl d events N/A 

F. Production of Organic Matter and its Export Y or N or N/A 

1. Wetland has at least 30% aerial c ver f herbace us vegetati n N 

2. W dy plants in wetland are m stly decidu us Y 

3. Interspersi n f vegetati n and surface water is high in wetland Y 

4. Wetland is inundated r has indicat rs that fl ding is a seas nal event during the gr wing seas n Y 

5. Wetland has utlet fr m which rganic matter is flushed Y 

G. General Habitat Suitability Y or N or N/A 

1. Is wetland l cated greater than 300-feet fr m existing devel pment N 

2. Undevel ped upland buffers abutting wetland N/A 

3. Wetland part f a larger wetland c mplex, n t fragmented N 

4. Diversity f plant species is apparent (> r = 5 species with at least 10% c ver each) Y 

5. Evidence f wildlife use Y 

6. Wetland has a m derate degree f c wardin class interspersi n Y 

H. General Fish Habitat Y or N or N/A 

1. Wetland has perennial r intermittent surface-water c nnecti n t a fish-bearing water b dy N/A 

2. D es wetland pr vide verwintering habitat f r fish N/A 

3. D cumented presence f fish N/A 

4. Herbace us and/ r w dy vegetati n is present in wetland and/ r buffer t pr vide c ver, shade, and/ r detrital matter N/A 

5. Spawning areas are present (aquatic vegetati n and/ r gravel beds) N/A 

6. Juvenile rest areas N/A 

I. Native Plant Richness Y or N or N/A 

1. D minant and c d minant plants are native Y 

2. Wetland c ntains tw r m re C wardin Classes Y 

3. Wetland has tw r m re strata f vegetati n Y 

J. Educational or Scientific Value Y or N or N/A 

1. Site has scientific r educati nal use Y 

2. Wetland is in public wnership Y 

3. Accessible trails available Y 

4. Is the area a kn wn recreati n area Y 

5. Subsistence (berry picking, fishing, hunting) Y 

K. Uniqueness and Heritage Y or N or N/A 

1. Wetland c ntains d cumented ccurrence f a state r federally listed threatened r endangered species N 

2. Wetland c ntains d cumented critical habitat, high quality ec systems, r pri rity species respectively designated by the U.S. Fish and 

Wildlife Service N 

3. Wetland has bi l gical, ge l gical, r ther features that are determined rare N 

4. Wetland has been determined significant because it pr vides functi ns scarce f r the area N 

5. Are there kn wn r rep rted cultural res urces in the area N/A 

6. Is the area a kn wn subsistence/recreati n/living area Y 

7. Wetland c mplex c ntains ne r m re f the f ll wing habitats:

 a) Tall shrub habitat (>.5ft in height) d minated by Salix spp. 

b) Aquatic herb habitat d minated by Arct phila fulva. 

c) Semi-permanently fl ded t permanently fl ded vegetated p rti ns f drained lake basins 

d) Anadr m us fish verwintering habitat 

e) Patterned wet sedge mead w and l w center p lyg ns 

f) High center p lyg n c mplex 

g) Riverine c astal mudflats 

h) N n-patterned wet mead w adjacent t streams and river bluffs. Y 

Functi nal Sheet 1 f 3 
GMT2_P st 

Flats 

PEM1F 

4.3 

Raw Score Weighted Score 

Flood Flow Alteration Disturbance Activities 

1 1 Disturbance Categ ry 2 

2 0 

3 0 Disturbance Categ ry Impact Fact r 

4 1 0 = 1 

5 0 1 = 0.99 

6 1 2 = 0.95 

7 1 3 = 0.9 

Total 0.571 

Sediment Removal Disturbance Impact Fact r 0.95 

1 0 

2 0 

3 0 

4 1 

5 1 

Total 0.400 

Nutrient and Toxicant Removal 

1 N/A 

2 1 

3 0 

Total 0.500 

Erosion Control and Shoreline Stabilization 

1 N/A 

2 N/A 

3 N/A 

Total N/A 

Production of Organic Matter and its Export 

1 0 

2 1 

3 1 

4 1 

5 1 

Total 0.800 

General Habitat Suitability 

1 0 

2 N/A 

3 0 

4 1 

5 1 

6 1 

Total 0.600 

General Fish Habitat 

1 N/A 

2 N/A 

3 N/A 

4 N/A 

5 N/A 

6 N/A 

Total N/A 

Native Plant Richness 

1 1 

2 1 

3 1 

Total 1.000 

Educational or Scientific Value 

1 1 

2 1 

3 1 

4 1 

5 1 

Total 1.000 

Uniqueness and Heritage 

1 0 

2 0 

3 0 

4 0 

5 N/A 

6 1 

7 1 

Total 0.333 

Wetland Functions and Values Results 

Unique ID: 

HGM Class: 

Cowardin Class: 

Size (acres): 

Functi nal Sheet 2 f 3 
Unique ID GMT2_Post 

0 

Flood Flow Alteration 0.571 

Sediment Removal 0.400 

Nutrient and Toxicant Removal 0.500 

Erosion Control and Shoreline Stabilization N/A 

Production of Organic Matter and its Export 0.800 

General Habitat Suitability 0.600 

General Fish Habitat N/A 

Native Plant Richness 1.000 

Educational or Scientific Value 1.000 

Uniqueness and Heritage 0.333 

Total 5.205 

Standardization 

8 

0.651 

0.618 

Overall Functional Score (Category) 0.76 - 1.00 I Highest II 

0.51 - 0.75 II 

0.26 - 0.50 III 

0 - 0.25 IV L west 

Notes: 

1) Sc res f r each categ ry c mp nent, 0 = n and 1 = yes. 

2) N t all functi nal categ ries will be applicable t each wetland functi nal assessment. 

F r example, General Fish Habitat is nly applicable t wetlands that are fish-bearing waters. 

Functi nal categ ries that are n t applicable will be treated as NA (n t applicable), which means there is n sc re f r 

that c mp nent. N sc re is n t the same as 0, which w uld err ne usly reduce the t tal sc re. 

Acc rdingly, the maximum t tal sc re will be reduced by 1 p int f r each functi nal categ ry that is n t applicable. 

F r example, if General Fish Habitat d es n t apply, then the T tal # f functi ns assessed is 9. 

3) NA = an item that is currently n t applicable, but c uld be applicable at a future time if m re data are available. 

4) See impacted area assessment w rksheet f r determinati n f disturbance activities. 

Apply the c rrect impact fact r t the disturbance categ ry. 

Total (Including Disturbance and Exceptional Habitat) 

Weighted Score 

T tal # f functi ns assessed 

Standardized Total 

Wetland Functions and Values Results (cont.) 

Exceptional Habitat Designation 

Functi nal Sheet 3 f 3 
Wetland Functions and Values Evaluation Questions Unique ID: GMT2_P st 

HGM Class: Flats 

Cowardin Class: pem1ss1b 

Size (acres): 49.8 

Disturbance Category: 2 

A. Exceptional Habitat Designation Y or N 

1. Is wetland l cated within an area c nsidered t be irreplaceable, r d es it have unique habitat n t f und anywhere else n the N rth 

Sl pe (i.e., Teshukpuk Lake Surface Pr tecti n Area, C lville River Delta, Beauf rt Sea C astal Marsh) N 

2. Is wetland l cated within an area c nsidered by any regulat ry agency t be an Aquatic Res urce f Nati nal Imp rtance (ARNI) N 

B. Flood Flow Alteration Y or N or N/A 

1. Wetland ccurs in the upper p rti n f its watershed Y 

2. Wetland is relatively flat area and is capable f retaining higher v lumes f water during st rm events than under n rmal rainfall N 

3. Wetland is a cl sed system N 

4. If fl w thr ugh, wetland has c nstricted utlet with signs f fluctuating water levels, algal mats, and/ r l dged debris N 

5. Wetland c ntains a dense herbace us layer (>70% c ver) r w dy vegetati n N 

6. Wetland receives fl dwater fr m an adjacent water c urse at least nce every 10 years Y 

7. Fl dwaters c me as sheet fl w rather than channel fl w Y 

C. Sediment Removal: If moving waters consider only statements 1 and 2 Y or N or N/A 

1. S urces f excess sediment are present up gradient f the wetland N 

2. Is wetland influenced by sl w-m ving water and/ r a deepwater habitat N 

3. Is herbace us vegetati n present (>50% c ver) Y 

4. Interspersi n f vegetati n and surface water is m derate in wetland presently r during fl ding at least nce ever 10 years N 

5. Sediment dep sits are present in wetland ( bservati n r n ted in applicati n materials) N 

D. Nutrient and Toxicant Removal Y or N or N/A 

1. S urces f excess nutrients (fertilizers) and t xicants (pesticides and heavy metals) are present up gradient and able t influence the 

wetland N/A 

2. Wetland is inundated r has indicat rs that fl ding is a seas nal event during the gr wing seas n by visual bservati n, r indicated by 

 ther hydr l gical data s urce Y 

3. Wetland has at least 30% aerial c ver f live vegetati n N 

E. Erosion Control and Shoreline Stabilization Y or N or N/A 

1. Wetland has dense, energy abs rbing vegetati n (>70%) b rdering the water c urse and n evidence f er si n N/A 

2. An herbace us layer is part f this dense vegetati n N/A 

3. Shrubs able t withstand er sive fl d events N/A 

F. Production of Organic Matter and its Export Y or N or N/A 

1. Wetland has at least 30% aerial c ver f herbace us vegetati n N 

2. W dy plants in wetland are m stly decidu us Y 

3. Interspersi n f vegetati n and surface water is high in wetland N/A 

4. Wetland is inundated r has indicat rs that fl ding is a seas nal event during the gr wing seas n N 

5. Wetland has utlet fr m which rganic matter is flushed Y 

G. General Habitat Suitability Y or N or N/A 

1. Is wetland l cated greater than 300-feet fr m existing devel pment N 

2. Undevel ped upland buffers abutting wetland N/A 

3. Wetland part f a larger wetland c mplex, n t fragmented N 

4. Diversity f plant species is apparent (> r = 5 species with at least 10% c ver each) Y 

5. Evidence f wildlife use Y 

6. Wetland has a m derate degree f c wardin class interspersi n Y 

H. General Fish Habitat Y or N or N/A 

1. Wetland has perennial r intermittent surface-water c nnecti n t a fish-bearing water b dy N/A 

2. D es wetland pr vide verwintering habitat f r fish N/A 

3. D cumented presence f fish N/A 

4. Herbace us and/ r w dy vegetati n is present in wetland and/ r buffer t pr vide c ver, shade, and/ r detrital matter N/A 

5. Spawning areas are present (aquatic vegetati n and/ r gravel beds) N/A 

6. Juvenile rest areas N/A 

I. Native Plant Richness Y or N or N/A 

1. D minant and c d minant plants are native Y 

2. Wetland c ntains tw r m re C wardin Classes Y 

3. Wetland has tw r m re strata f vegetati n Y 

J. Educational or Scientific Value Y or N or N/A 

1. Site has scientific r educati nal use Y 

2. Wetland is in public wnership Y 

3. Accessible trails available Y 

4. Is the area a kn wn recreati n area Y 

5. Subsistence (berry picking, fishing, hunting) Y 

K. Uniqueness and Heritage Y or N or N/A 

1. Wetland c ntains d cumented ccurrence f a state r federally listed threatened r endangered species N 

2. Wetland c ntains d cumented critical habitat, high quality ec systems, r pri rity species respectively designated by the U.S. Fish and 

Wildlife Service N 

3. Wetland has bi l gical, ge l gical, r ther features that are determined rare N 

4. Wetland has been determined significant because it pr vides functi ns scarce f r the area N 

5. Are there kn wn r rep rted cultural res urces in the area N/A 

6. Is the area a kn wn subsistence/recreati n/living area Y 

7. Wetland c mplex c ntains ne r m re f the f ll wing habitats:

 a) Tall shrub habitat (>.5ft in height) d minated by Salix spp. 

b) Aquatic herb habitat d minated by Arct phila fulva. 

c) Semi-permanently fl ded t permanently fl ded vegetated p rti ns f drained lake basins 

d) Anadr m us fish verwintering habitat 

e) Patterned wet sedge mead w and l w center p lyg ns 

f) High center p lyg n c mplex 

g) Riverine c astal mudflats 

h) N n-patterned wet mead w adjacent t streams and river bluffs. Y 

Functi nal Sheet 1 f 3 
GMT2_P st 

Flats 

pem1ss1b 

49.8 

Raw Score Weighted Score 

Flood Flow Alteration Disturbance Activities 

1 1 Disturbance Categ ry 2 

2 0 

3 0 Disturbance Categ ry Impact Fact r 

4 0 0 = 1 

5 0 1 = 0.99 

6 1 2 = 0.95 

7 1 3 = 0.9 

Total 0.429 

Sediment Removal Disturbance Impact Fact r 0.95 

1 0 

2 0 

3 1 

4 0 

5 0 

Total 0.200 

Nutrient and Toxicant Removal 

1 N/A 

2 1 

3 0 

Total 0.500 

Erosion Control and Shoreline Stabilization 

1 N/A 

2 N/A 

3 N/A 

Total N/A 

Production of Organic Matter and its Export 

1 0 

2 1 

3 N/A 

4 0 

5 1 

Total 0.500 

General Habitat Suitability 

1 0 

2 N/A 

3 0 

4 1 

5 1 

6 1 

Total 0.600 

General Fish Habitat 

1 N/A 

2 N/A 

3 N/A 

4 N/A 

5 N/A 

6 N/A 

Total N/A 

Native Plant Richness 

1 1 

2 1 

3 1 

Total 1.000 

Educational or Scientific Value 

1 1 

2 1 

3 1 

4 1 

5 1 

Total 1.000 

Uniqueness and Heritage 

1 0 

2 0 

3 0 

4 0 

5 N/A 

6 1 

7 1 

Total 0.333 

Wetland Functions and Values Results 

Unique ID: 

HGM Class: 

Cowardin Class: 

Size (acres): 

Functi nal Sheet 2 f 3 
Unique ID GMT2_Post 

0 

Flood Flow Alteration 0.429 

Sediment Removal 0.200 

Nutrient and Toxicant Removal 0.500 

Erosion Control and Shoreline Stabilization N/A 

Production of Organic Matter and its Export 0.500 

General Habitat Suitability 0.600 

General Fish Habitat N/A 

Native Plant Richness 1.000 

Educational or Scientific Value 1.000 

Uniqueness and Heritage 0.333 

Total 4.562 

Standardization 

8 

0.570 

0.542 

Overall Functional Score (Category) 0.76 - 1.00 I Highest II 

0.51 - 0.75 II 

0.26 - 0.50 III 

0 - 0.25 IV L west 

Notes: 

1) Sc res f r each categ ry c mp nent, 0 = n and 1 = yes. 

2) N t all functi nal categ ries will be applicable t each wetland functi nal assessment. 

F r example, General Fish Habitat is nly applicable t wetlands that are fish-bearing waters. 

Functi nal categ ries that are n t applicable will be treated as NA (n t applicable), which means there is n sc re f r 

that c mp nent. N sc re is n t the same as 0, which w uld err ne usly reduce the t tal sc re. 

Acc rdingly, the maximum t tal sc re will be reduced by 1 p int f r each functi nal categ ry that is n t applicable. 

F r example, if General Fish Habitat d es n t apply, then the T tal # f functi ns assessed is 9. 

3) NA = an item that is currently n t applicable, but c uld be applicable at a future time if m re data are available. 

4) See impacted area assessment w rksheet f r determinati n f disturbance activities. 

Apply the c rrect impact fact r t the disturbance categ ry. 

Weighted Score 

T tal # f functi ns assessed 

Standardized Total 

Total (Including Disturbance and Exceptional Habitat) 

Wetland Functions and Values Results (cont.) 

Exceptional Habitat Designation 

Functi nal Sheet 3 f 3 
Wetland Functions and Values Evaluation Questions Unique ID: GMT2_P st 

HGM Class: Flats 

Cowardin Class: pem1ss1e 

Size (acres): 23.7 

Disturbance Category: 2 

A. Exceptional Habitat Designation Y or N 

1. Is wetland l cated within an area c nsidered t be irreplaceable, r d es it have unique habitat n t f und anywhere else n the N rth 

Sl pe (i.e., Teshukpuk Lake Surface Pr tecti n Area, C lville River Delta, Beauf rt Sea C astal Marsh) N 

2. Is wetland l cated within an area c nsidered by any regulat ry agency t be an Aquatic Res urce f Nati nal Imp rtance (ARNI) N 

B. Flood Flow Alteration Y or N or N/A 

1. Wetland ccurs in the upper p rti n f its watershed Y 

2. Wetland is relatively flat area and is capable f retaining higher v lumes f water during st rm events than under n rmal rainfall N 

3. Wetland is a cl sed system N 

4. If fl w thr ugh, wetland has c nstricted utlet with signs f fluctuating water levels, algal mats, and/ r l dged debris Y 

5. Wetland c ntains a dense herbace us layer (>70% c ver) r w dy vegetati n N 

6. Wetland receives fl dwater fr m an adjacent water c urse at least nce every 10 years Y 

7. Fl dwaters c me as sheet fl w rather than channel fl w Y 

C. Sediment Removal: If moving waters consider only statements 1 and 2 Y or N or N/A 

1. S urces f excess sediment are present up gradient f the wetland N 

2. Is wetland influenced by sl w-m ving water and/ r a deepwater habitat N 

3. Is herbace us vegetati n present (>50% c ver) N 

4. Interspersi n f vegetati n and surface water is m derate in wetland presently r during fl ding at least nce ever 10 years Y 

5. Sediment dep sits are present in wetland ( bservati n r n ted in applicati n materials) Y 

D. Nutrient and Toxicant Removal Y or N or N/A 

1. S urces f excess nutrients (fertilizers) and t xicants (pesticides and heavy metals) are present up gradient and able t influence the 

wetland N/A 

2. Wetland is inundated r has indicat rs that fl ding is a seas nal event during the gr wing seas n by visual bservati n, r indicated by 

 ther hydr l gical data s urce Y 

3. Wetland has at least 30% aerial c ver f live vegetati n Y 

E. Erosion Control and Shoreline Stabilization Y or N or N/A 

1. Wetland has dense, energy abs rbing vegetati n (>70%) b rdering the water c urse and n evidence f er si n N/A 

2. An herbace us layer is part f this dense vegetati n N/A 

3. Shrubs able t withstand er sive fl d events N/A 

F. Production of Organic Matter and its Export Y or N or N/A 

1. Wetland has at least 30% aerial c ver f herbace us vegetati n N 

2. W dy plants in wetland are m stly decidu us Y 

3. Interspersi n f vegetati n and surface water is high in wetland Y 

4. Wetland is inundated r has indicat rs that fl ding is a seas nal event during the gr wing seas n Y 

5. Wetland has utlet fr m which rganic matter is flushed Y 

G. General Habitat Suitability Y or N or N/A 

1. Is wetland l cated greater than 300-feet fr m existing devel pment N 

2. Undevel ped upland buffers abutting wetland N/A 

3. Wetland part f a larger wetland c mplex, n t fragmented N 

4. Diversity f plant species is apparent (> r = 5 species with at least 10% c ver each) Y 

5. Evidence f wildlife use Y 

6. Wetland has a m derate degree f c wardin class interspersi n Y 

H. General Fish Habitat Y or N or N/A 

1. Wetland has perennial r intermittent surface-water c nnecti n t a fish-bearing water b dy N/A 

2. D es wetland pr vide verwintering habitat f r fish N/A 

3. D cumented presence f fish N/A 

4. Herbace us and/ r w dy vegetati n is present in wetland and/ r buffer t pr vide c ver, shade, and/ r detrital matter N/A 

5. Spawning areas are present (aquatic vegetati n and/ r gravel beds) N/A 

6. Juvenile rest areas N/A 

I. Native Plant Richness Y or N or N/A 

1. D minant and c d minant plants are native Y 

2. Wetland c ntains tw r m re C wardin Classes Y 

3. Wetland has tw r m re strata f vegetati n Y 

J. Educational or Scientific Value Y or N or N/A 

1. Site has scientific r educati nal use Y 

2. Wetland is in public wnership Y 

3. Accessible trails available Y 

4. Is the area a kn wn recreati n area Y 

5. Subsistence (berry picking, fishing, hunting) Y 

K. Uniqueness and Heritage Y or N or N/A 

1. Wetland c ntains d cumented ccurrence f a state r federally listed threatened r endangered species N 

2. Wetland c ntains d cumented critical habitat, high quality ec systems, r pri rity species respectively designated by the U.S. Fish and 

Wildlife Service N 

3. Wetland has bi l gical, ge l gical, r ther features that are determined rare N 

4. Wetland has been determined significant because it pr vides functi ns scarce f r the area N 

5. Are there kn wn r rep rted cultural res urces in the area N/A 

6. Is the area a kn wn subsistence/recreati n/living area Y 

7. Wetland c mplex c ntains ne r m re f the f ll wing habitats:

 a) Tall shrub habitat (>.5ft in height) d minated by Salix spp. 

b) Aquatic herb habitat d minated by Arct phila fulva. 

c) Semi-permanently fl ded t permanently fl ded vegetated p rti ns f drained lake basins 

d) Anadr m us fish verwintering habitat 

e) Patterned wet sedge mead w and l w center p lyg ns 

f) High center p lyg n c mplex 

g) Riverine c astal mudflats 

h) N n-patterned wet mead w adjacent t streams and river bluffs. Y 

Functi nal Sheet 1 f 3 
GMT2_P st 

Flats 

pem1ss1e 

23.7 

Raw Score Weighted Score 

Flood Flow Alteration Disturbance Activities 

1 1 Disturbance Categ ry 2 

2 0 

3 0 Disturbance Categ ry Impact Fact r 

4 1 0 = 1 

5 0 1 = 0.99 

6 1 2 = 0.95 

7 1 3 = 0.9 

Total 0.571 

Sediment Removal Disturbance Impact Fact r 0.95 

1 0 

2 0 

3 0 

4 1 

5 1 

Total 0.400 

Nutrient and Toxicant Removal 

1 N/A 

2 1 

3 1 

Total 1.000 

Erosion Control and Shoreline Stabilization 

1 N/A 

2 N/A 

3 N/A 

Total N/A 

Production of Organic Matter and its Export 

1 0 

2 1 

3 1 

4 1 

5 1 

Total 0.800 

General Habitat Suitability 

1 0 

2 N/A 

3 0 

4 1 

5 1 

6 1 

Total 0.600 

General Fish Habitat 

1 N/A 

2 N/A 

3 N/A 

4 N/A 

5 N/A 

6 N/A 

Total N/A 

Native Plant Richness 

1 1 

2 1 

3 1 

Total 1.000 

Educational or Scientific Value 

1 1 

2 1 

3 1 

4 1 

5 1 

Total 1.000 

Uniqueness and Heritage 

1 0 

2 0 

3 0 

4 0 

5 N/A 

6 1 

7 1 

Total 0.333 

Wetland Functions and Values Results 

Unique ID: 

HGM Class: 

Cowardin Class: 

Size (acres): 

Functi nal Sheet 2 f 3 
Unique ID GMT2_Post 

0 

Flood Flow Alteration 0.571 

Sediment Removal 0.400 

Nutrient and Toxicant Removal 1.000 

Erosion Control and Shoreline Stabilization N/A 

Production of Organic Matter and its Export 0.800 

General Habitat Suitability 0.600 

General Fish Habitat N/A 

Native Plant Richness 1.000 

Educational or Scientific Value 1.000 

Uniqueness and Heritage 0.333 

Total 5.705 

Standardization 

8 

0.713 

0.677 

Overall Functional Score (Category) 0.76 - 1.00 I Highest II 

0.51 - 0.75 II 

0.26 - 0.50 III 

0 - 0.25 IV L west 

Notes: 

1) Sc res f r each categ ry c mp nent, 0 = n and 1 = yes. 

2) N t all functi nal categ ries will be applicable t each wetland functi nal assessment. 

F r example, General Fish Habitat is nly applicable t wetlands that are fish-bearing waters. 

Functi nal categ ries that are n t applicable will be treated as NA (n t applicable), which means there is n sc re f r 

that c mp nent. N sc re is n t the same as 0, which w uld err ne usly reduce the t tal sc re. 

Acc rdingly, the maximum t tal sc re will be reduced by 1 p int f r each functi nal categ ry that is n t applicable. 

F r example, if General Fish Habitat d es n t apply, then the T tal # f functi ns assessed is 9. 

3) NA = an item that is currently n t applicable, but c uld be applicable at a future time if m re data are available. 

4) See impacted area assessment w rksheet f r determinati n f disturbance activities. 

Apply the c rrect impact fact r t the disturbance categ ry. 

Weighted Score 

T tal # f functi ns assessed 

Standardized Total 

Total (Including Disturbance and Exceptional Habitat) 

Wetland Functions and Values Results (cont.) 

Exceptional Habitat Designation 

Functi nal Sheet 3 f 3 
Wetland Functions and Values Evaluation Questions Unique ID: GMT2_P st 

HGM Class: Depressi nal 

Cowardin Class: pubh 

Size (acres): 0.1 

Disturbance Category: 2 

A. Exceptional Habitat Designation Y or N 

1. Is wetland l cated within an area c nsidered t be irreplaceable, r d es it have unique habitat n t f und anywhere else n the N rth 

Sl pe (i.e., Teshukpuk Lake Surface Pr tecti n Area, C lville River Delta, Beauf rt Sea C astal Marsh) N 

2. Is wetland l cated within an area c nsidered by any regulat ry agency t be an Aquatic Res urce f Nati nal Imp rtance (ARNI) N 

B. Flood Flow Alteration Y or N or N/A 

1. Wetland ccurs in the upper p rti n f its watershed Y 

2. Wetland is relatively flat area and is capable f retaining higher v lumes f water during st rm events than under n rmal rainfall N 

3. Wetland is a cl sed system Y 

4. If fl w thr ugh, wetland has c nstricted utlet with signs f fluctuating water levels, algal mats, and/ r l dged debris N/A 

5. Wetland c ntains a dense herbace us layer (>70% c ver) r w dy vegetati n N/A 

6. Wetland receives fl dwater fr m an adjacent water c urse at least nce every 10 years Y 

7. Fl dwaters c me as sheet fl w rather than channel fl w Y 

C. Sediment Removal: If moving waters consider only statements 1 and 2 Y or N or N/A 

1. S urces f excess sediment are present up gradient f the wetland N 

2. Is wetland influenced by sl w-m ving water and/ r a deepwater habitat Y 

3. Is herbace us vegetati n present (>50% c ver) N/A 

4. Interspersi n f vegetati n and surface water is m derate in wetland presently r during fl ding at least nce ever 10 years N/A 

5. Sediment dep sits are present in wetland ( bservati n r n ted in applicati n materials) Y 

D. Nutrient and Toxicant Removal Y or N or N/A 

1. S urces f excess nutrients (fertilizers) and t xicants (pesticides and heavy metals) are present up gradient and able t influence the 

wetland N/A 

2. Wetland is inundated r has indicat rs that fl ding is a seas nal event during the gr wing seas n by visual bservati n, r indicated by 

 ther hydr l gical data s urce Y 

3. Wetland has at least 30% aerial c ver f live vegetati n N/A 

E. Erosion Control and Shoreline Stabilization Y or N or N/A 

1. Wetland has dense, energy abs rbing vegetati n (>70%) b rdering the water c urse and n evidence f er si n N/A 

2. An herbace us layer is part f this dense vegetati n N/A 

3. Shrubs able t withstand er sive fl d events N/A 

F. Production of Organic Matter and its Export Y or N or N/A 

1. Wetland has at least 30% aerial c ver f herbace us vegetati n N/A 

2. W dy plants in wetland are m stly decidu us N/A 

3. Interspersi n f vegetati n and surface water is high in wetland N/A 

4. Wetland is inundated r has indicat rs that fl ding is a seas nal event during the gr wing seas n N/A 

5. Wetland has utlet fr m which rganic matter is flushed N/A 

G. General Habitat Suitability Y or N or N/A 

1. Is wetland l cated greater than 300-feet fr m existing devel pment N 

2. Undevel ped upland buffers abutting wetland N/A 

3. Wetland part f a larger wetland c mplex, n t fragmented N 

4. Diversity f plant species is apparent (> r = 5 species with at least 10% c ver each) N/A 

5. Evidence f wildlife use Y 

6. Wetland has a m derate degree f c wardin class interspersi n N/A 

H. General Fish Habitat Y or N or N/A 

1. Wetland has perennial r intermittent surface-water c nnecti n t a fish-bearing water b dy N/A 

2. D es wetland pr vide verwintering habitat f r fish N/A 

3. D cumented presence f fish N/A 

4. Herbace us and/ r w dy vegetati n is present in wetland and/ r buffer t pr vide c ver, shade, and/ r detrital matter N/A 

5. Spawning areas are present (aquatic vegetati n and/ r gravel beds) N/A 

6. Juvenile rest areas N/A 

I. Native Plant Richness Y or N or N/A 

1. D minant and c d minant plants are native Y 

2. Wetland c ntains tw r m re C wardin Classes N/A 

3. Wetland has tw r m re strata f vegetati n N/A 

J. Educational or Scientific Value Y or N or N/A 

1. Site has scientific r educati nal use Y 

2. Wetland is in public wnership Y 

3. Accessible trails available Y 

4. Is the area a kn wn recreati n area Y 

5. Subsistence (berry picking, fishing, hunting) Y 

K. Uniqueness and Heritage Y or N or N/A 

1. Wetland c ntains d cumented ccurrence f a state r federally listed threatened r endangered species N 

2. Wetland c ntains d cumented critical habitat, high quality ec systems, r pri rity species respectively designated by the U.S. Fish and 

Wildlife Service Y 

3. Wetland has bi l gical, ge l gical, r ther features that are determined rare N 

4. Wetland has been determined significant because it pr vides functi ns scarce f r the area N 

5. Are there kn wn r rep rted cultural res urces in the area N 

6. Is the area a kn wn subsistence/recreati n/living area Y 

7. Wetland c mplex c ntains ne r m re f the f ll wing habitats:

 a) Tall shrub habitat (>.5ft in height) d minated by Salix spp. 

b) Aquatic herb habitat d minated by Arct phila fulva. 

c) Semi-permanently fl ded t permanently fl ded vegetated p rti ns f drained lake basins 

d) Anadr m us fish verwintering habitat 

e) Patterned wet sedge mead w and l w center p lyg ns 

f) High center p lyg n c mplex 

g) Riverine c astal mudflats 

h) N n-patterned wet mead w adjacent t streams and river bluffs. Y 

Functi nal Sheet 1 f 3 
GMT2_P st 

Depressi nal 

pubh 

0.1 

Raw Score Weighted Score 

Flood Flow Alteration Disturbance Activities 

1 1 Disturbance Categ ry 2 

2 0 

3 1 Disturbance Categ ry Impact Fact r 

4 N/A 0 = 1 

5 N/A 1 = 0.99 

6 1 2 = 0.95 

7 1 3 = 0.9 

Total 0.800 

Sediment Removal Disturbance Impact Fact r 0.95 

1 0 

2 1 

3 N/A 

4 N/A 

5 1 

Total 0.667 

Nutrient and Toxicant Removal 

1 N/A 

2 1 

3 N/A 

Total 1.000 

Erosion Control and Shoreline Stabilization 

1 N/A 

2 N/A 

3 N/A 

Total N/A 

Production of Organic Matter and its Export 

1 N/A 

2 N/A 

3 N/A 

4 N/A 

5 N/A 

Total N/A 

General Habitat Suitability 

1 0 

2 N/A 

3 0 

4 N/A 

5 1 

6 N/A 

Total 0.333 

General Fish Habitat 

1 N/A 

2 N/A 

3 N/A 

4 N/A 

5 N/A 

6 N/A 

Total N/A 

Native Plant Richness 

1 1 

2 N/A 

3 N/A 

Total 1.000 

Educational or Scientific Value 

1 1 

2 1 

3 1 

4 1 

5 1 

Total 1.000 

Uniqueness and Heritage 

1 0 

2 1 

3 0 

4 0 

5 0 

6 1 

7 1 

Total 0.429 

Wetland Functions and Values Results 

Unique ID: 

HGM Class: 

Cowardin Class: 

Size (acres): 

Functi nal Sheet 2 f 3 
Unique ID GMT2_Post 

0 

Flood Flow Alteration 0.800 

Sediment Removal 0.667 

Nutrient and Toxicant Removal 1.000 

Erosion Control and Shoreline Stabilization N/A 

Production of Organic Matter and its Export N/A 

General Habitat Suitability 0.333 

General Fish Habitat N/A 

Native Plant Richness 1.000 

Educational or Scientific Value 1.000 

Uniqueness and Heritage 0.429 

Total 5.229 

Standardization 

7 

0.747 

0.710 

Overall Functional Score (Category) 0.76 - 1.00 I Highest II 

0.51 - 0.75 II 

0.26 - 0.50 III 

0 - 0.25 IV L west 

Notes: 

1) Sc res f r each categ ry c mp nent, 0 = n and 1 = yes. 

2) N t all functi nal categ ries will be applicable t each wetland functi nal assessment. 

F r example, General Fish Habitat is nly applicable t wetlands that are fish-bearing waters. 

Functi nal categ ries that are n t applicable will be treated as NA (n t applicable), which means there is n sc re f r 

that c mp nent. N sc re is n t the same as 0, which w uld err ne usly reduce the t tal sc re. 

Acc rdingly, the maximum t tal sc re will be reduced by 1 p int f r each functi nal categ ry that is n t applicable. 

F r example, if General Fish Habitat d es n t apply, then the T tal # f functi ns assessed is 9. 

3) NA = an item that is currently n t applicable, but c uld be applicable at a future time if m re data are available. 

4) See impacted area assessment w rksheet f r determinati n f disturbance activities. 

Apply the c rrect impact fact r t the disturbance categ ry. 

Weighted Score 

T tal # f functi ns assessed 

Standardized Total 

Total (Including Disturbance and Exceptional Habitat) 

Wetland Functions and Values Results (cont.) 

Exceptional Habitat Designation 

Functi nal Sheet 3 f 3 
RIVERINE ANSRAM PRE-CONSTRUCTION 

Wetland Functions and Values Evaluation Questions Unique ID: Riverine Pre 

HGM Class: Riverine 

Cowardin Class: r2 

Size (acres): 35.3 

Disturbance Category: 3 

A. Exceptional Habitat Designation Y or N 

1. Is wetland located within an area considered to be irreplaceable, or does it have unique habitat not found anywhere else on the North 

Slope (i.e., Teshukpuk Lake Surface Protection Area, Colville River Delta, Beaufort Sea Coastal Marsh) N 

2. Is wetland located within an area considered by any regulatory agency to be an Aquatic Resource of National Importance (ARNI) N 

B. Flood Flow Alteration Y or N or N/A 

1. Wetland occurs in the upper portion of its watershed N 

2. Wetland is relatively flat area and is capable of retaining higher volumes of water during storm events than under normal rainfall N 

3. Wetland is a closed system N/A 

4. If flow through, wetland has constricted outlet with signs of fluctuating water levels, algal mats, and/or lodged debris Y 

5. Wetland contains a dense herbaceous layer (>70% cover) or woody vegetation Y 

6. Wetland receives floodwater from an adjacent water course at least once every 10 years Y 

7. Floodwaters come as sheet flow rather than channel flow N 

C. Sediment Removal: If moving waters consider only statements 1 and 2 Y or N or N/A 

1. Sources of excess sediment are present up gradient of the wetland Y 

2. Is wetland influenced by slow moving water and/or a deepwater habitat N 

3. Is herbaceous vegetation present (>50% cover) N/A 

4. Interspersion of vegetation and surface water is moderate in wetland presently or during flooding at least once ever 10 years N/A 

5. Sediment deposits are present in wetland (observation or noted in application materials) N/A 

D. Nutrient and Toxicant Removal Y or N or N/A 

1. Sources of excess nutrients (fertilizers) and toxicants (pesticides and heavy metals) are present up gradient and able to influence the 

wetland N/A 

2. Wetland is inundated or has indicators that flooding is a seasonal event during the growing season by visual observation, or indicated by 

other hydrological data source Y 

3. Wetland has at least 30% aerial cover of live vegetation Y 

E. Erosion Control and Shoreline Stabilization Y or N or N/A 

1. Wetland has dense, energy absorbing vegetation (>70%) bordering the water course and no evidence of erosion N 

2. An herbaceous layer is part of this dense vegetation Y 

3. Shrubs able to withstand erosive flood events Y 

F. Production of Organic Matter and its Export Y or N or N/A 

1. Wetland has at least 30% aerial cover of herbaceous vegetation Y 

2. Woody plants in wetland are mostly deciduous Y 

3. Interspersion of vegetation and surface water is high in wetland Y 

4. Wetland is inundated or has indicators that flooding is a seasonal event during the growing season Y 

5. Wetland has outlet from which organic matter is flushed N 

G. General Habitat Suitability Y or N or N/A 

1. Is wetland located greater than 300 feet from existing development N 

2. Undeveloped upland buffers abutting wetland N 

3. Wetland part of a larger wetland complex, not fragmented N 

4. Diversity of plant species is apparent (> or = 5 species with at least 10% cover each) Y 

5. Evidence of wildlife use Y 

6. Wetland has a moderate degree of cowardin class interspersion Y 

H. General Fish Habitat Y or N or N/A 

1. Wetland has perennial or intermittent surface water connection to a fish bearing water body Y 

2. Does wetland provide overwintering habitat for fish N/A 

3. Documented presence of fish Y 

4. Herbaceous and/or woody vegetation is present in wetland and/or buffer to provide cover, shade, and/or detrital matter Y 

5. Spawning areas are present (aquatic vegetation and/or gravel beds) Y 

6. Juvenile rest areas Y 

I. Native Plant Richness Y or N or N/A 

1. Dominant and codominant plants are native Y 

2. Wetland contains two or more Cowardin Classes Y 

3. Wetland has two or more strata of vegetation Y 

J. Educational or Scientific Value Y or N or N/A 

1. Site has scientific or educational use N 

2. Wetland is in public ownership N 

3. Accessible trails available Y 

4. Is the area a known recreation area Y 

5. Subsistence (berry picking, fishing, hunting) Y 

K. Uniqueness and Heritage Y or N or N/A 

1. Wetland contains documented occurrence of a state or federally listed threatened or endangered species Y 

2. Wetland contains documented critical habitat, high quality ecosystems, or priority species respectively designated by the U.S. Fish and 

Wildlife Service Y 

3. Wetland has biological, geological, or other features that are determined rare N 

4. Wetland has been determined significant because it provides functions scarce for the area N 

5. Are there known or reported cultural resources in the area N/A 

6. Is the area a known subsistence/recreation/living area Y 

7. Wetland complex contains one or more of the following habitats:

 a) Tall shrub habitat (>.5ft in height) dominated by Salix spp. 

b) Aquatic herb habitat dominated by Arctophila fulva. 

c) Semi permanently flooded to permanently flooded vegetated portions of drained lake basins 

d) Anadromous fish overwintering habitat 

e) Patterned wet sedge meadow and low center polygons 

f) High center polygon complex 

g) Riverine coastal mudflats 

h) Non patterned wet meadow adjacent to streams and river bluffs. Y 

Functional Sheet 1 of 3 
Riverine Pre 

Riverine 

r2 

35.3 

Raw Score Weighted Score 

Flood Flow Alteration Disturbance Activities 

1 0 Disturbance Category 3 

2 0 

3 N/A Disturbance Category Impact Factor 

4 1 0 = 1 

5 1 1 = 0.99 

6 1 2 = 0.95 

7 0 3 = 0.9 

Total 0.500 

Sediment Removal Disturbance Impact Factor 0.9 

1 1 

2 0 

3 N/A 

4 N/A 

5 N/A 

Total 0.500 

Nutrient and Toxicant Removal 

1 N/A 

2 1 

3 1 

Total 1.000 

Erosion Control and Shoreline Stabilization 

1 0 

2 1 

3 1 

Total 0.667 

Production of Organic Matter and its Export 

1 1 

2 1 

3 1 

4 1 

5 0 

Total 0.800 

General Habitat Suitability 

1 0 

2 0 

3 0 

4 1 

5 1 

6 1 

Total 0.500 

General Fish Habitat 

1 1 

2 N/A 

3 1 

4 1 

5 1 

6 1 

Total 1.000 

Native Plant Richness 

1 1 

2 1 

3 1 

Total 1.000 

Educational or Scientific Value 

1 0 

2 0 

3 1 

4 1 

5 1 

Total 0.600 

Uniqueness and Heritage 

1 1 

2 1 

3 0 

4 0 

5 N/A 

6 1 

7 1 

Total 0.667 

Wetland Functions and Values Results 

Unique ID: 

HGM Class: 

Cowardin Class: 

Size (acres): 

Functional Sheet 2 of 3 
Unique ID Riverine-Pre 

0 

Flood Flow Alteration 0.500 

Sediment Removal 0.500 

Nutrient and Toxicant Removal 1.000 

Erosion Control and Shoreline Stabilization 0.667 

Production of Organic Matter and its Export 0.800 

General Habitat Suitability 0.500 

General Fish Habitat 1.000 

Native Plant Richness 1.000 

Educational or Scientific Value 0.600 

Uniqueness and Heritage 0.667 

Total 7.233 

Standardization 

10 

0.723 

0.651 

Overall Functional Score (Category) 0.76 1.00 I Highest II 

0.51 0.75 II 

0.26 0.50 III 

0 0.25 IV Lowest 

Notes: 

1) Scores for each category component, 0 = no and 1 = yes. 

2) Not all functional categories will be applicable to each wetland functional assessment. 

For example, General Fish Habitat is only applicable to wetlands that are fish bearing waters. 

Functional categories that are not applicable will be treated as NA (not applicable), which means there is no score for 

that component. No score is not the same as 0, which would erroneously reduce the total score. 

Accordingly, the maximum total score will be reduced by 1 point for each functional category that is not applicable. 

For example, if General Fish Habitat does not apply, then the Total # of functions assessed is 9. 

3) NA = an item that is currently not applicable, but could be applicable at a future time if more data are available. 

4) See impacted area assessment worksheet for determination of disturbance activities. 

Apply the correct impact factor to the disturbance category. 

Weighted Score 

Total # of functions assessed 

Standardized Total 

Total (Including Disturbance and Exceptional Habitat) 

Wetland Functions and Values Results (cont.) 

Exceptional Habitat Designation 

Functional Sheet 3 of 3 

RIVERINE ANSRAM POST-CONSTRUCTION 

Wetland Functions and Values Evaluation Questions Unique ID: Riverine Post 

HGM Class: Riverine 

Cowardin Class: r2 

Size (acres): 35.8 

Disturbance Category: 0 

A. Exceptional Habitat Designation Y or N 

1. Is wetland located within an area considered to be irreplaceable, or does it have unique habitat not found anywhere else on the North 

Slope (i.e., Teshukpuk Lake Surface Protection Area, Colville River Delta, Beaufort Sea Coastal Marsh) N 

2. Is wetland located within an area considered by any regulatory agency to be an Aquatic Resource of National Importance (ARNI) N 

B. Flood Flow Alteration Y or N or N/A 

1. Wetland occurs in the upper portion of its watershed Y 

2. Wetland is relatively flat area and is capable of retaining higher volumes of water during storm events than under normal rainfall Y 

3. Wetland is a closed system N/A 

4. If flow through, wetland has constricted outlet with signs of fluctuating water levels, algal mats, and/or lodged debris Y 

5. Wetland contains a dense herbaceous layer (>70% cover) or woody vegetation Y 

6. Wetland receives floodwater from an adjacent water course at least once every 10 years Y 

7. Floodwaters come as sheet flow rather than channel flow Y 

C. Sediment Removal: If moving waters consider only statements 1 and 2 Y or N or N/A 

1. Sources of excess sediment are present up gradient of the wetland Y 

2. Is wetland influenced by slow-moving water and/or a deepwater habitat Y 

3. Is herbaceous vegetation present (>50% cover) N/A 

4. Interspersion of vegetation and surface water is moderate in wetland presently or during flooding at least once ever 10 years N/A 

5. Sediment deposits are present in wetland (observation or noted in application materials) N/A 

D. Nutrient and Toxicant Removal Y or N or N/A 

1. Sources of excess nutrients (fertilizers) and toxicants (pesticides and heavy metals) are present up gradient and able to influence the 

wetland N/A 

2. Wetland is inundated or has indicators that flooding is a seasonal event during the growing season by visual observation, or indicated by 

other hydrological data source Y 

3. Wetland has at least 30% aerial cover of live vegetation Y 

E. Erosion Control and Shoreline Stabilization Y or N or N/A 

1. Wetland has dense, energy absorbing vegetation (>70%) bordering the water course and no evidence of erosion Y 

2. An herbaceous layer is part of this dense vegetation Y 

3. Shrubs able to withstand erosive flood events Y 

F. Production of Organic Matter and its Export Y or N or N/A 

1. Wetland has at least 30% aerial cover of herbaceous vegetation Y 

2. Woody plants in wetland are mostly deciduous Y 

3. Interspersion of vegetation and surface water is high in wetland Y 

4. Wetland is inundated or has indicators that flooding is a seasonal event during the growing season Y 

5. Wetland has outlet from which organic matter is flushed Y 

G. General Habitat Suitability Y or N or N/A 

1. Is wetland located greater than 300-feet from existing development Y 

2. Undeveloped upland buffers abutting wetland N 

3. Wetland part of a larger wetland complex, not fragmented Y 

4. Diversity of plant species is apparent (> or = 5 species with at least 10% cover each) Y 

5. Evidence of wildlife use Y 

6. Wetland has a moderate degree of cowardin class interspersion Y 

H. General Fish Habitat Y or N or N/A 

1. Wetland has perennial or intermittent surface-water connection to a fish-bearing water body Y 

2. Does wetland provide overwintering habitat for fish N/A 

3. Documented presence of fish Y 

4. Herbaceous and/or woody vegetation is present in wetland and/or buffer to provide cover, shade, and/or detrital matter Y 

5. Spawning areas are present (aquatic vegetation and/or gravel beds) Y 

6. Juvenile rest areas Y 

I. Native Plant Richness Y or N or N/A 

1. Dominant and codominant plants are native Y 

2. Wetland contains two or more Cowardin Classes Y 

3. Wetland has two or more strata of vegetation Y 

J. Educational or Scientific Value Y or N or N/A 

1. Site has scientific or educational use Y 

2. Wetland is in public ownership N 

3. Accessible trails available Y 

4. Is the area a known recreation area Y 

5. Subsistence (berry picking, fishing, hunting) Y 

K. Uniqueness and Heritage Y or N or N/A 

1. Wetland contains documented occurrence of a state or federally listed threatened or endangered species Y 

2. Wetland contains documented critical habitat, high quality ecosystems, or priority species respectively designated by the U.S. Fish and 

Wildlife Service Y 

3. Wetland has biological, geological, or other features that are determined rare N 

4. Wetland has been determined significant because it provides functions scarce for the area Y 

5. Are there known or reported cultural resources in the area N/A 

6. Is the area a known subsistence/recreation/living area Y 

7. Wetland complex contains one or more of the following habitats:

 a) Tall shrub habitat (>.5ft in height) dominated by Salix spp. 

b) Aquatic herb habitat dominated by Arctophila fulva. 

c) Semi-permanently flooded to permanently flooded vegetated portions of drained lake basins 

d) Anadromous fish overwintering habitat 

e) Patterned wet sedge meadow and low center polygons 

f) High center polygon complex 

g) Riverine coastal mudflats 

h) Non-patterned wet meadow adjacent to streams and river bluffs. Y 

Functional Sheet 1 of 3 
Riverine Post 

Riverine 

r2 

35.8 

Raw Score Weighted Score 

Flood Flow Alteration Disturbance Activities 

1 1 Disturbance Category 0 

2 1 

3 N/A Disturbance Category Impact Factor 

4 1 0 = 1 

5 1 1 = 0.99 

6 1 2 = 0.95 

7 1 3 = 0.9 

Total 1.000 

Sediment Removal Disturbance Impact Factor 1 

1 1 

2 1 

3 N/A 

4 N/A 

5 N/A 

Total 1.000 

Nutrient and Toxicant Removal 

1 N/A 

2 1 

3 1 

Total 1.000 

Erosion Control and Shoreline Stabilization 

1 1 

2 1 

3 1 

Total 1.000 

Production of Organic Matter and its Export 

1 1 

2 1 

3 1 

4 1 

5 1 

Total 1.000 

General Habitat Suitability 

1 1 

2 0 

3 1 

4 1 

5 1 

6 1 

Total 0.833 

General Fish Habitat 

1 1 

2 N/A 

3 1 

4 1 

5 1 

6 1 

Total 1.000 

Native Plant Richness 

1 1 

2 1 

3 1 

Total 1.000 

Educational or Scientific Value 

1 1 

2 0 

3 1 

4 1 

5 1 

Total 0.800 

Uniqueness and Heritage 

1 1 

2 1 

3 0 

4 1 

5 N/A 

6 1 

7 1 

Total 0.833 

Unique ID: 

HGM Class: 

Cowardin Class: 

Size (acres): 

Wetland Functions and Values Results 

Functional Sheet 2 of 3 
Unique ID Riverine_Post 

0 

Flood Flow Alteration 1.000 

Sediment Removal 1.000 

Nutrient and Toxicant Removal 1.000 

Erosion Control and Shoreline Stabilization 1.000 

Production of Organic Matter and its Export 1.000 

General Habitat Suitability 0.833 

General Fish Habitat 1.000 

Native Plant Richness 1.000 

Educational or Scientific Value 0.800 

Uniqueness and Heritage 0.833 

Total 9.467 

Standardization 

10 

0.947 

0.947 

Overall Functional Score (Category) 0.76 - 1.00 I Highest I 

0.51 - 0.75 II 

0.26 - 0.50 III 

0 - 0.25 IV Lowest 

Notes: 

1) Scores for each category component, 0 = no and 1 = yes. 

2) Not all functional categories will be applicable to each wetland functional assessment. 

For example, General Fish Habitat is only applicable to wetlands that are fish-bearing waters. 

Functional categories that are not applicable will be treated as NA (not applicable), which means there is no score for 

that component. No score is not the same as 0, which would erroneously reduce the total score. 

Accordingly, the maximum total score will be reduced by 1 point for each functional category that is not applicable. 

For example, if General Fish Habitat does not apply, then the Total # of functions assessed is 9. 

3) NA = an item that is currently not applicable, but could be applicable at a future time if more data are available. 

4) See impacted area assessment worksheet for determination of disturbance activities. 

Apply the correct impact factor to the disturbance category. 

Weighted Score 

Total # of functions assessed 

Standardized Total 

Total (Including Disturbance and Exceptional Habitat) 

Wetland Functions and Values Results (cont.) 

Exceptional Habitat Designation 

Functional Sheet 3 of 3 

GMT2 DEBIT-CREDIT CALCULATION 

1.00 

1.00 

Impact Acres 77.9 

Total Debits 10.5 

total acres Req. 35.8 

total credit 10.7 

D bit/Cr dit Balanc 

Credit Calculation (Nuiqsut Stream PRM Restoration) 

WAA1_Crossing Acres 

35.8 

fci pre= 0.65 160 

fci post 0.95 

fci delta 0.30 

t= 

es= 

paf= 0.00 

pa= 0 

adj Delta 0.30 

risk 

time lag 

credit 10.7 

pem1f 

Impact Acres 4.3 

fci pre 0.78 t= 

fci post 0.62 es= 

Fci Delta 0.16 paf= 

Total Debit 0.69 ` pa= 

adj Delta= 

pem1ss1b fci= 

Impact Acres 49.8 fci delta 

fci pre 0.68 WAA= 

fci post 0.54 credit= 

Fci Delta 0.14 Debit= 

Total Debit 6.97 

pem1ss1e 

Impact Acres 23.7 

fci pre 0.80 

fci post 0.68 

Fci Delta 0.12 

Total Debit 2.8 

Impact Acres 0.1 

fci pre 0.81 

fci post 0.71 

fci delta 0.10 

Total Debit 0.01 

Total Acres 77.9 

Total D bits 10.5 

D bit Cr dit Calculation-GMT2 

pubh 

Debit Calculation 

Inputs 

Outputs 

Threat 

Environmental Significance 

Preservation adjustment factor (t+es) 

Preservation Adjusted (paf x fci Delta) 

pa adjusted for time lag and risk 

Functional Capcity index 

pre fci - post fci 

Wetlands Assessment Area 

adj delta x acres 

fci delta x impact acres 

GMT2 D bit Cr dit Calculation 
ATTACHMENT D6
ATTACHMENT D.6 

Special Permit Conditions and Rationales.

The following special conditions will be included in the Department of the Army (DA) permit to

ensure the project is not contrary to the public interest [33 CFR 320.4(r)], and to ensure the project

complies with the 404 (b)(1) Guidelines [40 CFR 230.1O(d)], or at the permittee's request. 

Pre-construction Meeting.

1. The permittee shall convene a pre-construction meeting, with their contractor representatives

present, a minimum of 15-days prior to the discharge of fill material into waters of the US

authorized under this DA permit. The permittee shall invite the USACE, and appropriate

federal, state, and borough resource or regulatory agencies within 10-days of the meeting

date. The permittee shall provide copies of this DA permit and all attachments to all

contractor representatives who shall make the permit copies available in the field during

construction activities.

Rationale: To ensure clarification of all permit requirements with the permittee and their

contractors. 33 CFR 325

Applicant Requested CompensatoryMitigation.

2. As provided in 33 CFR 320.4 (r)(2), additional mitigation may be added to Department of the 

Army permit conditions at the applicant’s request. Per your request, the Nuiqsut Freshwater 

Road Restoration Site mitigation plan, as submitted by letter dated 3 August 2018, is included 

as a special condition of the DA permit. Prior to construction, the final design of the project 

will be submitted for review and approval via standard mail to U.S. Army Corps of Engineers, 

Regulatory Division, P.O Box 6898 JBER, Alaska 99506-0898, or electronically to 

regpagemaster@usace.army.mil (not to exceed 10 MB). No work shall take place until you 

have received approval from this office.

Fill Discharges.

3.a. The Permittee shall use only clean fill material for this project. The fill material shall be free 

from items such as trash, debris, automotive parts, asphalt, construction materials, concrete 

blocks with exposed reinforcement bars, and soils contaminated with any toxic substance, in 

toxic amounts in accordance with Section 307 of the Clean Water Act.

Rationale. Discharges of pollutants, other than the clean mineral fill material, is not authorized 

and would cause additional adverse impacts to the aquatic environment. 40 CFR 230 and 33

CFR 325

3.b. All authorized fill area boundaries shall be surveyed and be clearly delineated (staked,

flagged, or posted) prior to the discharge. No fill material, supplies, or construction materials

shall be stockpiled on wetlands outside of the authorized fill areas. Transportation vehicles

and equipment shall not be operated outside of the authorized fill areas, except as authorized

by the State of Alaska and/or North Slope Borough to construct and operate on winter ice pads

and/or roads or for tundra travel with specially designed and approved low tundra impact
vehicles. Road and fill pad surfaces and slopes shall be maintained without discharging fill 

material outside of permitted fill embankments into waters of the US.

Rationale: This condition is required to avoid adverse impacts to adjacent wetlands as a result of 

the permitted project (33 CFR 320.4(b)(1), 33 CFR 320.4(r)(1), and 40 CFR 230.41). 

3.c. Snow and ice clearing operations must prevent vegetation, soil, or debris from being

discharged into waters of the US outside of all authorized fill areas.

Rationale. Rationale: This condition is required to avoid adverse impacts to adjacent wetlands as 

a result of the permitted project (33 CFR 320.4(b)(1), 33 CFR 320.4(r)(1), and 40 CFR 230.41).

3.d. All authorized discharges, except those to place, adjust, or relocate culverts, shall be

completed during frozen winter conditions during the State of Alaska and/or North Slope

Borough approved winter tundra construction/travel season. Discharges necessary to install

additional culverts, correct culvert positions, and adjust culvert settings may occur outside of

the approved winter tundra construction/travel season, except in circumstances which are

contrary to the Terms and Conditions of the USFWS’ September 21, 2018 Biological Opinion 

(below).

Rationale. The discharge of fill materials and related construction activities during the winter

season and on ice roads and pads greatly reduces the adverse impacts to the aquatic

resources, fish and wildlife resources, and the general environment. 40 CFR 230 and 33 CFR

325

3.e. All fill slopes shall be immediately stabilized to prevent erosional impacts to the aquatic

environment. Active sloughing of fill material, increased water turbidity, accumulation of

sediment in waters and wetlands, and erosion on slopes or around culverts shall be indicators

fill slope stabilization is not adequate.

Rationale. This condition is required to ensure that areas outside of the permitted area are 

protected from sediment caused by erosion, slumping, or lateral displacement of surrounding 

bottom deposits until the site is permanently stabilized (33 CFR 320.4(b), 40 CFR 230.20(b), 40 

CFR 230.21, and 40 CFR 230.72(a)).

3.f. If placement of the access road fill material is not completed within any winter season,

sufficient openings shall be provided in the roadbed to maintain natural drainage flows

and overland cross-drainage. Road opening widths shall be of sufficient size to prevent scour 

of the adjacent tundra wetlands. 

Rationale. This condition is required to minimize impacts to adjacent wetlands and other 

waters of the U.S. as a result of the permitted project (33 CFR 320.4(b) and (l) and 40 CFR 

230.41).This condition is included to protect water quality and fish and wildlife habitats. 40

CFR 230, 33 CFR 320

3.g As-Built Certification: Within 60 days of completion of the work authorized by this permit, 

the Permittee shall submit as-built drawings of the authorized work and a completed “As-Built

Certification By Professional Engineer” form to the U.S. Army Corps of Engineers, 
Regulatory Division, P.O Box 6898 JBER, Alaska 99506-0898, or electronically to 

regpagemaster@usace.army.mil (not to exceed 10 MB). The as-built drawings shall be signed 

and sealed by a registered professional engineer and include the following: 

a) A plan view drawing of the location of the authorized work footprint, as shown on the 

permit drawings, with transparent overlay of the work as constructed in the same scale as

the permit drawings on 81⁄2-inch by 1inch sheets or PDF. The plan view drawing should 

show all "earth disturbance," including wetland impacts and water management structures.

b) A list of any deviations between the work authorized by this permit and the work as 

constructed. In the event that the completed work deviates, in any manner, from the

authorized work, describe on the attached “As-Built Certification By Professional 

Engineer” form the deviations between the work authorized by this permit and the work as 

constructed. Clearly indicate on the as-built drawings any deviations that have been listed. 

Please note that the depiction and/or description of any deviations on the drawings and/or 

“As-Built Certification By Professional Engineer” form does not constitute approval of 

any deviations by the Corps.

c) Include the Department of the Army permit number on all sheets submitted.

Threatened and Endangered Species (Terms and Conditions for Endangered Species 

Act Compliance)

Biological Opinion: This permit does not authorize the Permittee to take an endangered species, in 

particular the Polar Bear, Spectacled Eider, and Alaska-breeding Steller’s Eider. In order to legally take a 

listed species, the Permittee must have separate authorization under the Endangered Species Act (ESA)

(e.g., an ESA Section 10 permit, or a BO under ESA Section 7, with “incidental take” provisions with 

which you must comply). 

The enclosed Biological Opinion (BO) contains mandatory terms and conditions to implement the 

reasonable and prudent measures that are associated with “incidental take” that is also specified in the BO. 

Authorization under this permit is conditional upon compliance with all of the mandatory terms and 

conditions associated with incidental take of the enclosed BO, which terms and conditions are incorporated 

by reference in this permit. Failure to comply with the terms and conditions associated with incidental take 

of the BO, where a take of the listed species occurs and would constitute an unauthorized take, would also 

constitute noncompliance with this permit. The United States Fish and Wildlife Service is the appropriate 

authority to determine compliance with the terms and conditions of its BO, and with the ESA. 

Hydrology.

5.a. Existing (natural) drainage patterns shall be maintained throughout all construction and 

operation periods by the installation of culverts in all authorized fill areas in sufficient number 

and size to prevent ponding, dewatering, water diversion between watersheds, or concentrating 

runoff flows. Important field surveying, planning, and design work must ensure the placement

of culverts along the access road are not effected by hydrologic changes due to project

construction. 

Rationale. This condition is included to protect important watersheds for water quality, 

vegetation and soils, and fish and wildlife habitats. 40 CFR 230, 33 CFR 320.
5.b. The permittee shall prepare and submit a culvert monitoring report to the USACE, for the 3 

summer seasons following fill placement authorized in this DA permit. The reports shall be

submitted prior to July 30 of each year. The report shall include photographs of all road and

pad areas to demonstrate the hydrologic conditions at spring break-up time and post break-up

(summer conditions). The report shall include an evaluation of all areas where additional 

culverts are necessary to retain existing drainage patterns and where culvert maintenance,

repair, upgrade, setting adjustments, or replacement are necessary. The culvert/drainage

corrective work shall be completed by freeze-up within the same summer season the drainage

problems are identified. Evidence of ponding, drying, erosion, or stream channel changes

adjacent to authorized fill areas are indicators of necessary corrective action. Culverts shall be

marked to facilitate snow removal operations to prevent excessive deposition of snow into

creeks and drainage areas. Culverts shall be maintained to adequately convey surface waters

throughout the life of the project (access road use).

Rationale. This condition is included to ensure water flow through the culvert is adequate for

all flows at all times without causing erosional changes to the channel, including up and

downstream reaches of the crossing; retain the substrate, banks, and vegetation; and provide

for fish passage. The hydrologic regime protects water quantity and quality, vegetation, soils,

and fish and wildlife habitats. 40 CFR 230, 33 CFR 320.

5.c. Design of the culverted road crossing at the Lake M9925 outfall stream crossing shall be

coordinated with the BLM, ADFG, and USACE to insure adequate fish passage. Final detailed

design figures shall be provided to the to the U.S. Army Corps of Engineers, Regulatory 

Division, P.O Box 6898 JBER, Alaska 99506-0898, or electronically to 

regpagemaster@usace.army.mil (not to exceed 10 MB). 

Rationale. This condition is included to insure adequate and continued fish passage, particularly

for ninespine stickleback. Retaining the hydrologic regime also protects water quality, 

vegetation, and soils. 40 CFR 230, 33 CFR 320

Gravel, Dust, and Snow.

6. a. The permittee shall comply with the latest version of the Alpine Facilities Erosion Control PlanGreater Mooses Tooth, Revised.

6.b. The permittee shall ensure pollution to aquatic resources from road gravel spray and fine

airborne fill particle dust discharges are minimized to the maximum extent practicable. Dust 

abatement practices, during dust prone weather and/or seasonal conditions, must be performed

for the life of the project (use of the road). Compliance with this condition shall be determined

by visible dust and gravel presence on tundra wetland areas adjacent to the authorized fill

areas.

Rationale. This condition is included to protect water quality and fish and wildlife habitats from

secondary impacts. 40 CFR 230, 33 CFR 320.

Cease to Maintain or Abandon.

7. Should the permittee decide to cease to maintain, use, or to abandon the authorized fill and pipeline, 

VSMs authorized under this DA permit, the USACE shall be notified by written communication 

and in compliance with General Condition 2 of this DA permit. Cease to maintain, use, and 

abandon are defined as non-use of the facilities, or portions thereof, for a period of 5 consecutive
years. If any authorized fill areas or pipeline sections are determined to be unmaintained, used, or

abandoned, a fill and/or structure removal and site rehabilitation plan (Rehab Plan) shall be 

submitted to the USACE within 120 days of abandonment. The plan shall include, at a minimum:

goals and objectives, site treatments, performance standards, reporting, remedial work plans, and

monitoring to ensure performance standards are met. The plan shall include an objective of 

restoring fish and wildlife habitat. 

Rationale: This condition is necessary to make a determination following General Condition 2 and

4 of this permit and 33 CFR 325 (Appendix A).

Department of Environmental 

Conservation 

DIVISION OF WATER 

Wastewater Discharge Authorization Program 

555 Cordova Street 

Anchorage, Alaska 99501-2617

Main: 907.269.6285 

Fax: 907.334.2415 

September 11, 2018 www.dec.alaska.gov/water/wwdp 

ConocoPhillips Alaska, Inc (CPAI) 

Attention: Mr. Brad Thomas 

P.O. Box 100360 

Anchorage, AK 99510 

Re: CPAI, Greater Moose’s Tooth Two (GMT2) 

POA-2015-486, Colville River 

Dear Mr. Thomas: 

In accordance with Section 401 of the Federal Clean Water Act of 1977 and provisions of the Alaska 

Water Quality Standards, the Department of Environmental Conservation (DEC) is re-issuing the 

enclosed Certificate of Reasonable Assurance for placement of dredged and/or fill material in waters of 

the U.S., including wetlands and streams, associated with the development of the Greater Moose’s 

Tooth Two, northwest of Nuiqsut, Alaska. 

DEC regulations provide that any person who disagrees with this decision may request an informal 

review by the Division Director in accordance with 18 AAC 15.185 or an adjudicatory hearing in 

accordance with 18 AAC 15.195 – 18 AAC 15.340. An informal review request must be delivered to the 

Director, Division of Water, 555 Cordova Street, Anchorage, AK 99501, within 20 days of the permit 

decision. Visit http://dec.alaska.gov/commish/ReviewGuidance.htm for information on 

Administrative Appeals of Department decisions. 

An adjudicatory hearing request must be delivered to the Commissioner of the Department of 

Environmental Conservation, 410 Willoughby Avenue, Suite 303, PO Box 111800, Juneau, AK 99811-

1800, within 30 days of the permit decision. If a hearing is not requested within 30 days, the right to 

appeal is waived. 

By copy of this letter we are advising the U.S. Army Corps of Engineers of our actions and enclosing a 

copy of the certification for their use. 

Sincerely, 

James Rypkema 

Program Manager, Storm Water and Wetlands 

Enclosure: 401 Certificate of Reasonable Assurance 

cc: (with encl.) 

Steve Moore, USACE, Anchorage USFWS Field Office Fairbanks 

Jack Winters, ADF&G Matt LaCroix, EPA Operations, Anchorage 
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STATE OF ALASKA 

DEPARTMENT OF ENVIRONMENTAL CONSERVATION 

CERTIFICATE OF REASONABLE ASSURANCE 

In accordance with Section 401 of the Federal Clean Water Act (CWA) and the Alaska Water Quality 

Standards (18 AAC 70), a Certificate of Reasonable Assurance, is reissued to ConocoPhillips Alaska, 

Inc. (CPAI), Attention: Mr. Brad Thomas, at P.O. Box 100360, Anchorage, AK 99510, for placement 

of dredged and/or fill material in waters of the U.S. including wetlands and streams in association with 

the development of the Greater Moose’s Tooth Two, northwest of Nuiqsut, Alaska.

The entirety of the project is located on the Arctic Coastal Plain of Alaska in the National Petroleum 

Reserve–Alaska near the Beaufort Sea and west of the Colville River, approximately 12 miles northwest 

of Nuiqsut, Alaska. The applicant’s stated purpose is to construct a road-accessible drill site, associated 

pipelines, and ancillary facilities to safely develop, produce, and transport hydrocarbons from the 

GMT2 reservoir to the existing Alpine Central Processing Facility (ACF) at Colville Delta 1 (CD1) and 

eventually to market at a reasonable rate of financial return. The project would produce 3-phase 

hydrocarbons (oil, gas, and water) which would be carried by pipeline to the ACF at CD1 for 

processing. Sales-quality crude oil produced at the ACF would be transported from CD1 via the 

existing Alpine Sales Oil Pipeline and Kuparuk Pipeline to the Trans-Alaska Pipeline System (TAPS) 

for shipment to market. 

CPAI proposes the placement of 674,300 cubic yards (cy) of clean fill material into 78.1 acres, of which 

77.9 acres are WOUS, including wetlands (see Table 1 below), to construct: 

 An 8.2-mile gravel access road (62.8 acres total; 62.6 acres in WOUS);

 A drill pad with 48-well capacity at GMT2 (14.0 acres in WOUS);

 Three vehicle pullout pads (0.4 acre each in WOUS) for safety and subsistence activity access;

and

 Vertical Support Members (VSM) for 8.6-mile pipeline from GMT1 to GMT2 (total fill

footprint of 0.1 acre in WOUS).

The GMT2 Development Project would produce oil, gas, and water that would be carried from the 

GMT2 drill site to Greater Moose’s Tooth One (GMT1) via new pipelines. From GMT1, produced 

fluids would be transported via the permitted GMT1 pipeline to the Colville River Delta 5 (CD5) pad. 

From CD5, produced fluids from GMT2 would be transported via a new pipeline placed on existing 

VSMs to the ACF at CD1 for processing. Sales-quality crude processed at the ACF would be 

transported from CD1 via the existing Alpine Sales Oil Pipeline and Kuparuk Pipeline to the Trans 

Alaska Pipeline System for shipment to market. Miscible injectant (MI), injection water, and lean gas 

would be delivered by both proposed and existing/permitted pipelines to the GMT2 dill site from 

CD1/ACF. The proposed drill site would be operated and maintained by Alpine staff and supported 

using CD1/ACF infrastructure. 

Construction of the GMT2 Development Project facilities would occur over either two or three ice 

road seasons. The schedule would likely be selected in mid-2018, although may be modified as detailed 

design progresses. However, the identified work would generally occur in the indicated seasons and 

sequence. 
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A state issued water quality certification is required under Section 401 because the proposed activity will 

be authorized by a U.S. Army Corps of Engineers permit (POA-2015-486) and a discharge of pollutants 

to waters of the U.S. located in the State of Alaska may result from the proposed activity. Public notice 

of the application for this certification was given as required by 18 AAC 15.180 in the Corps Public 

Notice POA-2015-486 posted from March 23, 2018 to May 7, 2018. 

The proposed activity is located within: 

 Sections 1, 11, 12, 14, 22, 23, 27, 32-34 of Township (T) 10 North (N), Range (R) 2 East (E),

Umiat Meridian (UM);

 Section 6 of T. 10 N., R. 3 E., UM;

 Sections 24-28, 31-33 of T. 11 N., R. 3 E., UM;

 Sections 12-19 of T. 11 N., R. 4 E., UM;

 Sections 5-7 of T. 11 N., R. 5 E., UM;

 U.S. Geological Survey Quadrangle Maps Harrison Bay A-2 and Harrison Bay A-3, 70.1730°

North, -150.6934° West (GMT2 Drill Pad).

The geographic start of the proposed project is the existing GMT1 drill site gravel pad: Latitude 

70.256952° and Longitude -151.479496°; the end of the proposed project is the proposed GMT 2 drill 

site gravel pad: Latitude 70.1730° and Longitude -150.6934°. 

The Department of Environmental Conservation (DEC) reviewed the application and certifies that 

there is reasonable assurance that the proposed activity, as well as any discharge which may result, will 

comply with applicable provisions of Section 401 of the CWA and the Alaska Water Quality Standards, 

18 AAC 70, provided that the following additional measures are adhered to. 

1. Reasonable precautions and controls must be used to prevent incidental and accidental discharge

of petroleum products or other hazardous substances. Fuel storage and handling activities for

equipment must be sited and conducted so there is no petroleum contamination of the ground,

subsurface, or surface waterbodies.

2. During construction, spill response equipment and supplies such as sorbent pads shall be

available and used immediately to contain and cleanup oil, fuel, hydraulic fluid, antifreeze, or

other pollutant spills. Any spill amount must be reported in accordance with Discharge

Notification and Reporting Requirements (AS 46.03.755 and 18 AAC 75 Article 3). The applicant

must contact by telephone the DEC Area Response Team for Northern Alaska at (907) 451-2121

during work hours or 1-800-478-9300 after hours. Also, the applicant must contact by telephone

the National Response Center at 1-800-424-8802.

3. Construction equipment shall not be operated below the ordinary high water mark if equipment is

leaking fuel, oil, hydraulic fluid, or any other hazardous material. Equipment shall be inspected on

a daily basis for leaks. If leaks are found, the equipment shall not be used and pulled from service

until the leak is repaired.

4. All work areas, material access routes, and surrounding wetlands involved in the construction

project shall be clearly delineated and marked in such a way that equipment operators do not

operate outside of the marked areas.
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5. Natural drainage patterns shall be maintained, to the extent practicable, without introducing

ponding or drying.

6. Excavated or fill material, including overburden, shall be placed so that it is stable, meaning after

placement the material does not show signs of excessive erosion. Indicators of excess erosion

include: gullying, head cutting, caving, block slippage, material sloughing, etc. The material must

be contained with siltation best management practices (BMPs) to preclude reentry into any waters

of the U.S., which includes wetlands.

7. Include the following BMPs to handle storm water and total storm water volume discharges as

they apply to the site:

a. Divert storm water from off-site around the site so that it does not flow onto the project site

and cause erosion of exposed soils;

b. Slow down or contain storm water that may collect and concentrate within a site and cause

erosion of exposed soils;

c. Place velocity dissipation devices (e.g., check dams, sediment traps, or riprap) along the length

of any conveyance channel to provide a non-erosive flow velocity. Also place velocity

dissipation devices where discharges from the conveyance channel or structure join a water

course to prevent erosion and to protect the channel embankment, outlet, adjacent stream

bank slopes, and downstream waters.

8. Fill material must be clean sand, gravel or rock, free from petroleum products and toxic

contaminants in toxic amounts.

9. Any disturbed ground and exposed soil not covered with fill must be stabilized and re-vegetated

with endemic species, grasses, or other suitable vegetation in an appropriate manner to minimize

erosion and sedimentation, so that a durable vegetative cover is established in a timely manner.

This certification expires five (5) years after the date the certification is signed. If your project is not 

completed by then and work under U.S Army Corps of Engineers Permit will continue, you must 

submit an application for renewal of this certification no later than 30 days before the expiration date 

(18 AAC 15.100). 

Date: September 11, 2018 

James Rypkema, Program Manager 

Storm Water and Wetlands 
APPENDIX E 

MAPS

Greater Mooses Tooth 2 Oil and Gas 

Development Project

Joint Record of Decision and Permit Evaluation

Bureau of Land Management

U.S. Army Corps of Engineers

October 2018

Record of Decision

U.S. DEPARTMENT OF THE INTERIOR | BUREAU OF LAND MANAGEMENT | ALASKA | GMT-2 SEIS

 GMT-2 Project Layout

Ublutuoch River 

(Tinmiaqsiugvik)

Colville River

Fish Creek 

(Uvlutuuq)

Nechelik Channel

GMT 1

CD2

CD4

CD5

CD1

Gravel Source

Nuiqsut

GMT2

No warranty is made by the Bureau of Land 

Management as to the accuracy, reliability, or

completeness of these data for individual or 

aggregate use with other data. Original data

were compiled from various sources. This

information may not meet National Map Accuracy

Standards. This product was developed through

digital means and may be updated without 

notification.

GMT-2 Permitted

Infrastructure

Alt A. Pipeline

Alt. A Road

Alt. A Pad

Existing & GMT- 1

Permitted

Infrastructure

Pipeline

Road

Gravel Source

Pad

Map 1

0 1 2 3 Miles

Land Status

BLM (Nativeselected)

Bureau of Land

Management

Alaska Native Lands

Patented or Interim

Conveyed

State of Alaska

Alaska Native

Allotment

Water

National Petroleum

Reserve in Alaska

Boundary

Ice Road

Construction Ice

Road - Year 0

Construction Ice

Road - Year 1

Construction Ice

Road - Year 2

(slight offsets applied for visualization purposes)

Project Study Area

zgoLBL 

=oN ONIMV~a =oN sor ens :ON eor 

I 

ENGINEERS, INC. 

REFERENCE DWG NO /SHT NO: 

REMOVE EXISTING--~~~L 

EMBANKMENT AND 

CULVERT BATTERY 

NEW FOOTPRINT, TYP 

ECM NO: 

CC NO: 

------------------------1----+---+------------------+---+---+---+--+------<CADD FILE NO. 

y 

ConocoPhillips 

Alaska, Inc. 

-----

0 30 60 90 120 FT 

ENVIRONMENTAL IMPACT SUMMARY 

NEW FILL MATERIAL: 

EXCAVATED MATERIAL: 

NEW GRAVEL/RIPRAP FOOTPRINT: 

RECLAIMED FOOTPRINT: 

8000 CY 

1400 CY 

0.25AC 

0.10 AC 

'QUANTITIES BASED ON LIDAR SURFACE DATA. SURVEY DATA IS NOT YET 

AVAILABLE 

FORM, DS12El'11> 

MODULE: UNIT: 

NUIQSUT CULVERT BATTERY REPLACEMENT PROJECT 

SPILL-lHROUGH BRIDGE IMPACT SUMMARY 

SUB JOB NO: DRAWING NO. PART: REV: 

CED-XXXX-XXX 001 OF 1 

APPENDIX F 

U.S. FISH AND WILDLIFE 

SERVICE

Biological Opinion

Greater Mooses Tooth 2 Oil and Gas 

Development Project

Joint Record of Decision and Permit Evaluation

Bureau of Land Management

U.S. Army Corps of Engineers

October 2018

United States Department of the Interior

U.S. FISH AND WILDLIFE SERVICE

Fairbanks Fish and Wildlife Field Office

101 12th Avenue, Room 110

Fairbanks, Alaska 99701

September 21, 2018

 

Ted Murphy

Acting State Director

Bureau of Land Management

222 W 7th Avenue #13

Anchorage, Alaska 99513

Ryan Winn

North Section Chief

U.S. Army Corps of Engineers

Alaska District Regulatory Division

P.O. Box 6898

JBER, Alaska 99506-0898

Dear Mr. Murphy and Mr. Winn,

This document transmits the U.S. Fish and Wildlife Service’s (Service) final Biological Opinion 

(BO) on a proposal by the Bureau of Land Management (BLM), in partnership with the U.S. 

Army Corp of Engineers (USACE), to issue permits to ConocoPhillips Alaska, Inc. (CPAI) for 

construction and operation of the Greater Moose’s Tooth 2 Development (GMT2) on lands 

managed by BLM within the National Petroleum Reserve – Alaska (NPRA). 

This BO describes the effects of this action on threatened spectacled eiders (Somateria fischeri), 

Alaska-breeding Steller’s eiders (Polysticta stelleri), polar bears (Ursus maritimus), and 

designated polar bear critical habitat, pursuant to section 7 of the Endangered Species Act of 

1973 (ESA), as amended (16 U.S.C. 1531 et seq.). We used information provided in the draft 

environmental impact statement (DEIS), BLM’s Biological Assessment (BA), previous BOs,

communications with BLM and USACE, other Service documents, and published and 

unpublished literature to develop this BO. 

Section 7(a)(2) of the ESA states that Federal agencies must ensure that their activities are not 

likely to: 

 Jeopardize the continued existence of any listed species, or 

 Result in the destruction or adverse modification of designated critical habitat. 

The Service has determined the proposed action may affect, but is not likely to adversely affect 

Alaska-breeding Steller’s eiders, but is likely to adversely affect spectacled eiders, polar bears, 

and designated polar bear critical habitat. 

Biological Opinion on the Effects of 

Greater Moose’s Tooth 2 Oil and Gas Development 

 in the National Petroleum Reserve-Alaska 

on the Spectacled Eider, Alaska-breeding Steller’s Eider, Polar Bear, and 

Polar Bear Critical Habitat

Consultation with: 

U.S. Bureau of Land Management 

Arctic District Office 

Fairbanks, Alaska 

and 

U.S. Army Corps of Engineers 

Alaska District 

Anchorage, Alaska 

Prepared by: 

U.S. Fish and Wildlife Service 

Fairbanks Fish and Wildlife Field Office 

101 12th Ave, Room 110 

Fairbanks, Alaska 99701 

September 21, 2018 
2

TABLE OF CONTENTS 

Introduction ....................................................................................................................3

Effect Determination for Steller’s Eiders ..........................................................5

Description of the Action Area ......................................................................................5

Description of the Proposed Action ...............................................................................5

Minimization Measures .....................................................................................9

Status of the Species and Critical Habitat ....................................................................14

Spectacled eider ...............................................................................................14

 Polar bear .........................................................................................................18

 Polar bear critical habitat .................................................................................26

Environmental Baseline ...............................................................................................28

Spectacled eiders ..............................................................................................28

 Polar Bear.........................................................................................................37

 Polar bear critical habitat .................................................................................39

Effects of the Action ....................................................................................................42

Effects to spectacled eiders ..............................................................................42

 Polar Bear.........................................................................................................51

 Polar bear critical habitat .................................................................................55

Cumulative Effects.......................................................................................................59

Conclusion ...................................................................................................................59

Spectacled eider ...............................................................................................60

 Polar Bear.........................................................................................................60

 Polar bear critical habitat .................................................................................62

Incidental Take Statement............................................................................................63

Spectacled eider ...............................................................................................64

 Polar Bear.........................................................................................................64

Reasonable and Prudent Measures ...............................................................................65

Conservation Recommendations .................................................................................68

Reinitiation Notice .......................................................................................................69

Literature Cited ............................................................................................................70

Appendix A- Deviations Requested by CPAI .............................................................90
3

INTRODUCTION 

This document transmits the U.S. Fish and Wildlife Service’s (Service) biological opinion (BO) 

on the potential effects of a proposal by the U.S. Bureau of Land Management (BLM) and the 

U.S. Army Corps of Engineers (USACE) to issue permits to ConocoPhillips Alaska, Inc. (CPAI) 

for construction and operation of a satellite oil production development, Greater Moose’s Tooth2 (GMT-2), in the Greater Moose’s Tooth Unit (GMTU) in the National Petroleum ReserveAlaska (NPR-A). 

This BO evaluates the potential effects of the proposed action upon spectacled eiders (Somateria 

fischeri), Alaska-breeding Steller’s eiders (Polysticta stelleri), polar bears (Ursus maritimus),

and polar bear critical habitat, pursuant to section 7 of the Endangered Species Act (ESA) of 

1973, as amended (16 U.S.C. 1531 et seq.). We used information provided in the Biological 

Assessment (BA; BLM 2018a), the Draft Supplemental Environmental Impact Statement 

(DSEIS; BLM 2018b), previous BOs, communications with BLM, other Service documents, and 

published and unpublished literature to develop this BO. It is important to note that our 

evaluation focuses exclusively on the potential effects of the Preferred Alternative, and further 

consultation may be required if the action that is ultimately authorized deviates from the 

Preferred Alternative in a manner that increases the impacts to listed species or designated 

critical habitat. 

Section 7(a)(2) of the ESA requires that all Federal agencies must ensure that their actions are 

not likely to: 

 Jeopardize the continued existence of any listed species; or 

 Result in the destruction or adverse modification of designated critical habitat. 

The Service has determined that the proposed action may affect, but is not likely to adversely 

affect, Alaska-breeding Steller’s eiders, but is likely to adversely affect spectacled eiders, polar 

bears, and designated polar bear critical habitat. Following a more comprehensive review of the 

status and environmental baseline of spectacled eiders, polar bears, and polar bear critical 

habitat, and an analysis of potential effects and cumulative effects of the proposed action to these 

listed entities, the Service has concluded the proposed action is not likely to jeopardize the 

continued existence of spectacled eiders or polar bears, and is not likely to destroy or adversely 

affect polar bear critical habitat. 

Project and Consultation History 

Planning efforts for GMT-2 began more than a decade ago. As proposed, GMT-2 (Figure 1) 

would be a satellite development, connected by permanent gravel road and pipeline to GMT-1 

and a series of five nearby satellite developments within the Alpine development complex in the 

Colville River Unit (CRU), individually identified as Colville Delta 1 to 5 (hereafter CD1, CD2, 

CD3, CD4, and CD5). The satellite oil development at GMT-2 was previously described and 

evaluated as part of the Alpine Satellites Development in an environmental impact statement 

(BLM 2004a), a biological assessment (Johnson et al. 2004), and a biological opinion (USFWS 

2004). Following the issuance of the Alpine Satellite Development Plan EIS and Record of 

Decision (BLM 2004a and 2004b), subsequent exploration established that the two satellites in 

NPR-A, which were originally identified as CD-6 and CD-7, were not in the CRU, but were 

within a separate unit, which was subsequently classified as the GMTU. CPAI requested that the 
4

BLM designate and approve the proposed GMTU so CPAI could perform exploration and 

development operations in an efficient and logical manner under a unit plan of development. 

CD-6 and CD-7 were then renamed GMT-1 and GMT-2, respectively. 

In 2013, the BLM adopted its Record of Decision (ROD) for the NPR-A Integrated Activity 

Plan/Environmental Impact Statement (IAP/EIS) (BLM 2013). The IAP ROD (BLM 2013) 

allocates lands available and unavailable for oil and gas leasing, exploration, and development 

and includes best management practices (BMPs) and lease stipulations that minimize impacts of 

these activities. The IAP/EIS (BLM 2012) included a development scenario, and on February 5, 

2013, the Service issued the Biological Opinion for the National Petroleum Reserve – Alaska 

Integrated Activity Plan, 2013 (IAP BO, USFWS 2013) for potential effects to listed species 

resulting from implementation of the IAP. We concluded that the scenario, including the BMPs 

and lease stipulations, was not likely to jeopardize the continued existence of Alaska-breeding 

Steller’s eiders, spectacled eiders, or polar bears. We also provided the BLM with an Incidental 

Take Statement for Alaska-breeding Steller’s eiders and spectacled eiders. 

The current GMT-2 drill pad location (BLM 2018b) has changed from previously identified 

locations described in BLM 2004, 2012, and 2014. The currently proposed GMT-2 pad location 

now occurs outside the Colville River Special Area to minimize potential impacts to peregrine 

falcons. The proposed location is 0.9 mile north of the 2012/2014 location and 0.11 mile north of 

the Colville River Special Area boundary. The current and previous proposed pad locations are 

shown on Map 2.1-1 of the DSEIS (BLM 2018b). 

Potential impacts of the Proposed Action were evaluated in the context of the status and 

environmental baseline of the species to provide an aggregative analysis of impacts to listed 

species. Our analysis includes potential direct and indirect effects, cumulative effects, and effects 

of interrelated and interdependent actions on listed species in the Action Area, including effects 

of BMPs and lease stipulations that would govern management of GMT-2. Although this 

consultation and BO do not tier to the existing IAP or associated BO, we view the proposed 

action and the associated impact analyses in the context of the IAP under which the proposed 

action would be authorized and managed, and incorporate the IAP/EIS (BLM 2012) and IAP BO

(USFWS 2013) as references in their entirety. 

The process for authorizing take (incidental or intentional) for marine mammals such as polar 

bears differs from that used to authorize incidental take of other threatened and endangered 

species. Although we have enumerated the extent of anticipated incidental take of polar bears, 

the Service is not authorizing incidental take of polar bears under the ESA in this BO. Consistent 

with the ESA and regulations at 50 CFR §402.14(i) Appendix (A), incidental take statements for 

marine mammals are not included in formal consultations until regulations, authorizations, or 

permits under the Marine Mammal Protection Act (MMPA) and/or its 2007 amendments are in 

effect. Once incidental take of polar bears is authorized under the MMPA, incidental take that 

results from actions conducted in compliance with all requirements and stipulations set forth in 

the MMPA authorization will also be considered to be authorized under the ESA. To date, CPAI 

has consistently obtained authorization under the MMPA for incidental take of polar bears for 

their oilfield facilities and activities on the North Slope, and we assume this practice will 

continue in the future. 
5

Alaska-breeding Steller’s Eiders

Alaska-breeding Steller’s eiders breed almost exclusively on the Arctic Coastal Plain (ACP), and 

nesting is concentrated in tundra wetlands near Utqiaġvik, Alaska (USFWS 2013). Steller’s 

eiders occur at very low densities elsewhere on the ACP (Larned et al. 2012a). Only three 

sightings of Steller’s eiders have occurred near the Action Area recently and only one Steller’s 

eider has been observed within the Action Area during extensive aerial surveys for eiders on the 

North Slope (USFWS Arctic Coastal Plain Aerial Breeding Pair Survey Geodatabase, 1992-

2016). The species has not been found breeding in northeast NPR-A or on the Colville River 

Delta in > 20 years. Therefore, we conclude that the probability of Steller’s eiders occurring in 

the Action Area is so low as to be discountable, and concur with the BLM’s determination in the 

BA (page 28) that this project is not likely to adversely affect Steller's eiders. Thus, further 

consultation for this species under section 7 of the Act is unnecessary. 

Yellow-billed Loons 

The Service was petitioned to list the yellow-billed loon (Gavia adamsii) under the ESA on April 

5, 2004, but on October 1, 2014 we determined the species does not meet the definition of an 

endangered or threatened species under the ESA and listing pursuant to the ESA is not warranted 

(79 FR 59195). Thus, we do not consider this species further in this BO. 

Pacific Walrus 

The Service was petitioned to list the Pacific walrus (Odobenus rosmarus divergens) under the 

ESA on February 8, 2008 but on October 4, 2017 we determined the species does not meet the 

definition of an endangered or threatened species under the ESA and listing pursuant to the ESA 

is not warranted. Thus, we do not consider this species further in this BO. 

DESCRIPTION OF THE ACTION AREA 

Regulations implementing the ESA (50 CFR §402.02) define an “Action Area” as “area[s] to be 

affected directly or indirectly by the Federal action and not merely the immediate area involved 

in the action." Potential impacts of GMT-2 on threatened species would occur at different 

geographic scales (e.g., disturbance from aircraft would occur over a larger area than disturbance 

from ground passenger vehicles). BLM (2018a) depicts the Action Area as the 2.5-mi (4.0 km) 

zone around the proposed GMT-2 drill site and all proposed support infrastructure including 

GMT-1, CD-5, Alpine, the Arctic Slope Regional Corporation (ASRC) mine, and Nuiqsut, 

gravel and ice roads, personnel camps, and material sites. The total area for this action is 

≈ 625 km2(Figure 1). We expect this zone encompasses all potential effects of the Proposed 

Action on threatened species and designated critical habitat, and thus use it as the Action Area. 

DESCRIPTION OF THE PROPOSED ACTION 

Location 

The preferred alternative for the GMT-2 Project is described and analyzed in this document. The 

proposed GMT-2 pad is in Section 32, Township 10N, Range 2E (T10N, R2E) Umiat Meridian 

(UM). The pipeline corridor crosses through Section 3, T10N, R3E UM; and Sections 1, 11, 12, 

14, 22, 23, 27, 32, 33, and 34, T10N, R2E UM. 
6

The Arctic Slope Regional Corporation (ASRC) Mine site is 4.5 miles east of Nuiqsut and east 

of the east channel of the Colville River within T10N, R5E, Sections 10, 11, 14, and 15 UM, at 

latitude 70.225° N and longitude 150.803° W. The Kuukpik 10-acre pad at the junction of the 

CD-5 road and Nuiqsut Spur Road may also serve as a camp during construction. 

Road, Drill Pad and Support Facilities 

The GMT-2 Project is approximately 17 miles southwest of the Alpine Central Facilities. The 

preferred alternative includes an 8.2-mile long, all-season road with about 46 culverts between 

GMT-2 and GMT-1. The gravel footprint of the GMT-2 pad is 0.057 km2 (14 acres), the road is 

0.25 km2

(62.8 acres), and subsistence pullouts (3) for vehicles are 0.002 km2(0.4 acres each), 

for a total of 0.32 km2(78 acres) of gravel surface (Table 1). The pad will include a 210 ft. 

communication tower without guywires. 

The GMT-2 pad would accommodate up to 48 wells; drilling would occur over 7.5 years, and oil 

would be expected to enter the pipeline to Alpine sometime in 2022. Electric power for GMT-2 

operations would be provided by the CD-1/Alpine Central Processing Facility power system. 

Power cables would be suspended from the pipeline horizontal support members via a messenger 

cable. The drilling rig would be 222 ft. tall. The drill rig and drill camp would use a temporary 

power connection, fueled by ultra-low sulfur diesel until the permanent GMT-2 drill site power 

supply system is in place. No processing other than heating of production fluids would occur on 

the pad. A fiber optic cable providing communication support between GMT-1 and GMT-2 

would be suspended from horizontal support members via the same messenger cable as the 

powerlines. The predicted lifespan of GMT-2 is currently 32 years, including 3 years of 

construction, 30 years of oil production, and 1 year with both construction and operation 

occurring. 

Pipelines 

The GMT-2 Project would produce oil, gas, and water that would be carried from the GMT-2 

pad by pipelines going to the Alpine Central Processing Facility at CD-1 for processing. Sales 

quality crude oil processed at the Alpine Central Processing Facility would be transported from 

CD-1 via the existing Alpine Oil Pipeline and Kuparuk Pipeline to the Trans-Alaska Pipeline 

System for shipment to market. 

Miscible injectant and injection water (for enhanced oil recovery) would be delivered by pipeline 

to the GMT-2 pad from CD-1/Alpine Central Processing Facility. Lean gas for artificial lift 

would also be transported from CD-1/Alpine Central Processing Facility. The production crude 

and water injection pipelines would be designed to allow pipeline inspection and maintenance 

(e.g., pigging) between GMT-2 pad and CD-1/Alpine Central Processing Facility. 

Pipelines would be supported on common vertical support members (VSMs) placed 

approximately 55 feet apart. Fiber optic and power cables would also be suspended from the 

VSMs via messenger cable attached to the horizontal support members. Pipelines (including 

suspended cables) would be a minimum of 7 ft. above ground and set within 1000 ft. of the 

gravel road. 

The 8.6-mile long 3-phase GMT-2 to GMT-1 pipeline segment would require approximately 800 

new VSMs, and would connect the new site to current infrastructure (Figure 1). The proposed 
7

GMT-2 to GMT-1 pipeline is located south and east of the proposed access road (Figure 1). No 

valves or vertical loops will be installed between GMT-2 and GMT-1 because there are no major 

stream crossings. No new pipelines would be required from GMT-1 to CD-5, where fluids would 

travel via existing pipelines. The GMT-1 to CD-1/Alpine Central Processing Facility Pipeline 

Segments required as part of the GMT-2 Project would be placed on new or existing VSMs 

within the existing right-of-way from GMT-1 to CD-1/Alpine Central Processing Facility. 

Upgrades to the current infrastructure would include a new 20-inch fluids pipeline placed on 

existing VSMs from CD-5 to CD-4N, from CD-4N to CD-2, and from CD-2 to CD-1. From CD4N to CD-2 and from CD-2 to CD-1, a new 6-inch Miscible Injectant (MI) pipeline would be 

added to existing VSMs. A power cable suspended in a new messenger cable below HSMs 

would be added from GMT-2 to CD-1, where the Alpine Central Processing Facility (ACF) is 

located. 

Table 1. Estimated gravel use for the GMT-2 project. 

Facility Footprint 

km2(acres)

a

Fill Quantity 

(cubic yards)a

Notes/dimensionsa

GMT-2 Drill site Pad 0.057 (14) 152,000

All-season Access Road, 

GMT-1 to GMT-2

0.25 (62.8) 510,000 8.2 miles long; 32 ft. crown 

width & minimum 5 ft. depth

Subsistence Road 

Pullouts

0.005 (1.2) 9,300 3 pullouts, 0.4 acres each

Bridges 0 0 None

Total Gravel for GMT-2 0.32 (78.0) 671,300 Pads and roads

Pipelines 0.0004 (0.1b) 8.6 miles, 3 phase from GMT-2 

to GMT-1 on ~800 new VSMs; 

9.8 miles, crude oil from CD-5 

to CD-1 on existing VSMs; 3.3 

miles miscible injection 

pipeline from CD-4/CD-5

Gravel Source 0.03 (23) 671,300 ASRC Mine

a 

Values are approximate and may change during final design, does not include 0.1 acre from pipeline VSMs between GMT-1 and GMT-2. 

b 

VSM footprint. 

Ice Roads 

Ice roads are likely to be in place and in use from about February 1 through April 20 of each year 

(80 days). Ice roads cross the Tiŋmiaqsiuġvik setback during all three winters (Figure 1). The 

first winter ice road (25.6 miles) would support gravel transfer and road and pad construction; 

the second and third winter ice roads (27 miles and 43.9 miles respectively) would support 

pipeline installation and facility construction. Pipeline construction ice roads would be 80 ft.

wide, gravel haul ice roads would be 50 ft. wide, and the remaining ice roads would be 35 ft.

wide.

Gravel Source 

Gravel excavation (1 season), transport, road and pad construction would utilize ice roads built 

during the first winter (2018/2019). Gravel conditioning and grading are planned during summer 

2019. Winter (2019/2020 and 2020/2021) ice roads would support pipeline installation, tie-in 
8

work, and facility construction. Pipeline construction, power and communication cables, and 

facility installation would be completed during spring and summer of 2021. 

The ASRC commercial gravel mine site would supply gravel for GMT-2 (Figure 1). The ASRC 

mine Phase 3 (POA-1996-869-M4), previously permitted January 30, 2014, is separate from this 

action, and currently identified as POA-1996-869-M11. The mine is approximately 4.5 miles 

northeast of Nuiqsut, and is outside of the NPR-A. The volume of gravel needed for the proposed 

project is 671,300 cubic yards [cy], requiring the excavation of 23 acres at the mine site. 

Vehicle Transport 

Personnel, equipment, and materials would be transported overland on snow trails, ice roads, and 

on the gravel GMT-1 – GMT-2 Access Road, once it is constructed. A summary of estimated 

required vehicle traffic trips is provided in Table 2.5-3 of the BLM’s March 2018 DSEIS (BLM 

2018b). 

Vehicle traffic would be greatest during 2018/2019, 2019/2020, and 2020/2021. Ice road 

construction would occur from mid-November through December. Construction of the gravel 

road, gravel drill pad, and installation of a portion of the pipeline scope would occur from 

February through April. Gravel conditioning would occur in August and September. 

In 2021, traffic would occur on ice roads and the gravel GMT-1 – GMT-2 Access Road. 

Vehicles would support pipeline and facilities construction and drilling. Completion of the 

pipeline installation would occur from February through April via ice road. Facility construction 

will occur February through December. After April 2021, all vehicle traffic would occur on the 

GMT-1 – GMT-2 Access Road. Drilling would begin in May 2021. 

Once drilling begins, vehicle traffic would decline and would be limited to the GMT-1 – GMT-2 

Access Road. Vehicle traffic associated with routine operations would begin after production 

begins in December, 2022 and would continue until decommissioning is complete.

Aerial Transport 

Aerial transport to/from Alpine would occur year round during all phases of the project. 

Construction activities (3 years) would include increases in air traffic predominately for crew 

and material/equipment transport to CD-1/APF. Baseline flights (those that would occur 

regardless of the GMT-2 project; (90 flights/year) currently accommodate drilling and operations 

at Alpine. During the first year of construction at GMT-2, 402 helicopter and 125 fixed-wing 

flights (one-way) would be required above baseline levels. During the second year of 

construction, 409 helicopter and 145 fixed-wing flights beyond baseline levels would be needed. 

During drilling and operations (third year and beyond), helicopter flights would decline to 90 

flights/year beyond baseline levels; fixed-wing flights would remain at 145 flights/year until 

construction concludes during the third year, after which no additional fixed-wing flights would 

be anticipated. All fixed-wing traffic will be supported from Alpine. The greatest number of 

flights (90 – 409 flights/year, ~ 95% of flights above baseline), primarily helicopter support for 

special studies and ice road cleanup, would occur during summer, including the breeding season 

for eiders (May – August) (Figure 2). 
9

Applicant-Requested Mitigation 

Three existing 48-inch diameter culverts, located at the intersection of Fresh Water Road (south 

of Nuiqsut) and an unnamed tributary to Nigliq channel, would be removed and replaced with an 

open cell or free-span structure. Approximately 1,400 cubic yards of gravel would be extracted 

from within 0.10 acre of channel beneath and in the immediate vicinity of the existing road 

crossing. Up to 0.25 acre of open water, roadway shoulder, and abutting wetland could be 

permanently filled as a result of minor road grade raising and re-alignment. 

Interrelated and Interdependent Actions 

For this BO, the Service considered activities that would be interrelated and interdependent to 

the proposed action as well as accidental events that may occur as a result of the proposed action. 

Interrelated actions are those actions that are part of a larger action and depend on the larger 

action for their jurisdiction. Interdependent actions are those actions that have no independent 

utility apart from the action being considered in the BO. Interrelated and interdependent 

activities that may occur in or near the GMT-2 Area in conjunction with the proposed action 

include additional mineral exploration/development on Native lands, additional 

telecommunications infrastructure, increased research activity, offshore oil 

exploration/development, onshore support facilities, additional staging areas, access roads, and 

accidental oil spills originating from barges, tank farms, and supply trucks/vessels. 

Minimization Measures 

1. To the extent possible, permanent facilities would be located in elevated and drier habitats 

to avoid impacts to preferred tundra bird nesting habitats. Over 90% of the gravel footprint 

is in Moist Tussock Tundra and Moist Sedge-Shrub Meadow; 

2. Gravel extraction and major construction would occur during winter to reduce vegetation 

and wildlife impacts; 

3. Power and communication lines would be supported under pipelines to reduce bird 

collision risk, maintaining 7-foot (2.1 m) clearance above tundra; 

4. Lighting would be shielded and directed downward to reduce attraction and disorientation 

to birds (except as required by FAA and OSHA); 

5. The volume of water withdrawn from water source lakes would be restricted (depending on 

depth and fish presence) and recharge and effects on water quality and aquatic species 

would be monitored; 

6. Culverts would maintain fish passage and cross drainage; 

7. Ice roads crossing streams would be slotted at end of the season to maintain connectivity; 

8. A waste management program that controls food availability would reduce attraction of 

predators and scavengers; 

9. Employee training, specifically for proper food disposal and prohibitions on feeding 

wildlife, would minimize wildlife interactions; 

10. The best available technology would be used to reduce nesting, denning, or perching of 

predators and scavengers at facilities. Inspections of drill rigs and infrastructure as 

frequently as is practicable during March through July would ensure that any nesting 

materials placed by ravens are removed; 

11. The Wildlife Avoidance and Interaction Plan would be implemented to reduce attraction of 

and negative interactions with wildlife; 

12. The Polar Bear Avoidance and Interaction Plan would be followed, to reduce and report 

encounters with polar bears; 
10

13. Active spill prevention and response plans would be maintained (Oil Discharge Prevention 

and Contingency Plans and Spill Prevention Control and Countermeasures Plans);

14. All communication towers would be located on production pads and would not have guy 

wires; and 

15. The GMT-2 Project would follow the Alpine Facilities Erosion Control Plan, updated to 

include GMT-2. Temporary erosion protection would be placed before breakup following 

the first construction season to provide protection from a flood event. The temporary 

protection would be replaced with permanent erosion protection once the gravel has been 

allowed to season (settle and drain). The Alpine Storm Water Pollution Prevention Plan 

(SWPPP) would be amended to cover management of pad drainage. The Alpine Erosion 

Control plan also includes snow removal and dust control plans. Snow removal plans 

include the use of snow blowing equipment to minimize gravel spray to the tundra and 

placing cleared snow in designated areas. The dust control plan includes watering gravel 

roads to minimize dust impacts on the tundra and maintain the integrity of the roads. 

Crude and Refined Oil Spills 

While spills of crude and refined oil products are not part of the Proposed Action, they may 

occur as a result of activities authorized and described in the Proposed Action. Therefore, we 

provide a brief review of the potential types of spills that could occur. Spills could occur from 

pipelines, storage tanks, production facilities and infrastructure, drilling rigs, and heavy 

equipment or vehicles. Impacts from spills could vary based on the material spilled, the size of 

the spill, and what time of year the spill occurred. The GMT-2 EIS (BLM 2018b) categorizes 

materials that could be spilled as process water, crude oil, non-crude oil, and other hazardous 

substances. 

Process water is produced water mixed with crude oil and saltwater or brine. Salt 

in the seawater and brine can negatively affect plant growth and survival at 

relatively low concentrations when spilled on tundra. These effects can be 

persistent, because salts are not broken down by chemical or biological processes 

in the soil. Spills of process water can change the salinity in freshwater bodies, 

which may be toxic to sensitive species. 

Crude oil is oil separated from the produced water. Crude oil spilled on the 

tundra can cause damage to plants by coating the surface of leaves or causing 

hydrophobic soil conditions, reducing the supply of water to plant roots. Noncrude oil includes diesel, gasoline, hydraulic fluid, transmission oil, waste oil, 

and other refined petroleum products. Refined petroleum products, particularly 

diesel and gasoline, are generally more toxic to plants, microbes, and animals 

(including humans) than crude oil.

Other hazardous substances that may be onsite include methanol, glycols, corrosion 

inhibitor, scale inhibitor, drag reducing agents, biocides, and drilling muds. Methanol 

and glycols are toxic to animals, and are completely soluble in water. Other hazardous 

substances have different toxicities and behave differently when spilled. Drilling muds 

are complex mixtures that may contain bentonite clay, saline substances, or mineral oil. 

Drilling muds and fluids can affect tundra by changing soil salinity and alkalinity, as 

well as smothering plants due to burial (Alaska Department of Environmental 
11

Conservation Tundra Treatment Guidelines 2010). Other hazardous substances have 

different toxicities and behave differently when spilled (BLM 2018b). 

The total number of spills reported within the Alpine Oil Field for the entire operating period, 

from 1998 through March 2017 is 252 spills, with a total volume of ~15,975 gallons, of which 48 

percent was non-crude oil and 35 percent was process water (BLM 2018b). The BA (BLM 

2018b) states: 

Spills related to construction activities are anticipated to be relatively small in 

volume, primarily related to vehicle and construction equipment fueling and 

maintenance. A tanker truck accident or fuel storage tank failure are the most 

likely source of a large construction spill. Construction related spills are 

anticipated to be non-crude oil products. Spills that could occur during drill and 

operation could result in larger volume spills than construction activities. Spills 

from pipelines, bulk storage tanks, production facilities and infrastructure, 

blowouts, and heavy equipment and vehicles could occur. Pipelines include a 20-

inch produced fluids pipeline (crude oil, gas, and water), a 14-inch injection 

water pipeline (seawater or produced water), a 6-inch gas pipeline, and a 6-inch 

miscible injectant pipeline. Bulk storage tanks for diesel and wastewater may be 

used during drilling and operations, and other hazardous substances may be 

present and stored onsite.....A review of the spill history at Alpine shows the 

majority of the spills are less than 10 gallons, and occur in February and March. 

Most of the spills have occurred on a pad area, or containment and resulted in 

minor impacts with low intensity, short duration, and limited extent (GMT-1 SIES, 

BLM, 2014).
12

Figure 1. GMT-2 Preferred Alternative Action Area (2.5 mi zone around the facilities, ice roads, and material source). From BLM 

(2018a).
13

Figure 2. Locations of helicopter takeoffs/landings within the GMT-2 Action Area. Provided by BLM (2018). 
14

STATUS OF THE SPECIES AND CRITICAL HABITAT 

This section presents biological and ecological information relevant to the status of listed species 

and designated critical habitat, including information on species’ life history, abundance, 

distribution, habitat associations, and other factors relevant to survival and recovery. 

Spectacled Eiders 

Status and Distribution 

The spectacled eider was listed throughout its range as threatened on May 10, 1993 (58 FR 

27474) based on indications of steep declines in the two Alaska-breeding populations. 

Historically, spectacled eiders nested in Alaska discontinuously from the Nushagak Peninsula 

north to Utqiaġvik, and east nearly to Canada’s Yukon Territory (Phillips 1922-1926, Bent 1925, 

Bailey 1948, Dau and Kistchinski 1977, Derksen et al. 1981, Garner and Reynolds 1986, 

Johnson and Herter 1989). Currently, this species comprises three primary breeding populations, 

which nest on Alaska’s North Slope (or Arctic Coastal Plain), the Yukon-Kuskokwim Delta (YK Delta), and in northern Russia (Figure 3). The Y-K Delta population declined 96% between 

the 1970s and early 1990s (Stehn et al. 1993, Ely et al. 1994), which was the primary impetus for 

listing the species. 

After breeding, spectacled eiders migrate to several discrete molting areas (Figure 3), with birds 

from the different populations and genders favoring different molting areas (Petersen et al. 

1999). All three spectacled eider populations overwinter in openings in pack ice of the central 

Bering Sea, south of St. Lawrence Island (Petersen et al. 1999; Figure 3), where they remain 

until March or April (Lovvorn et al. 2003). 

Breeding- North Slope Population 

Spectacled eiders arrive on the ACP breeding grounds in late May to early June. Breeding 

density varies across the North Slope. Numbers of breeding pairs peak in mid-June and decline 

4 – 5 days later when males begin to depart from the breeding grounds (Smith et al. 1994, 

Anderson and Cooper 1994, Anderson et al. 1995, Bart and Earnst 2005). In general, on the 

Arctic Coastal Plain spectacled eiders breed near large shallow productive thaw lakes, often with 

convoluted shorelines and/or small islands (Larned and Balogh 1997, Anderson et al. 1999). Nest 

sites are often located within 3 feet of a lakeshore (Johnson et al. 1996). Mean clutch size 

reported from studies on the Colville River Delta was 4.3 (Bart and Earnst 2005). Spectacled 

eider clutch size near Utqiaġvik has averaged 4.1 to 4.7 (Safine 2011, Safine 2012). Incubation 

lasts 20 – 25 days (Kondratev and Zadorina 1992, Harwood and Moran 1993, Moran and 

Harwood 1994, Moran 1995), and hatching occurs from mid- to late July (Warnock and Troy 

1992). On the nesting grounds, spectacled eiders feed on mollusks, insect larvae, small 

freshwater crustaceans, and plants and seeds (Kondratev and Zadorina 1992) in shallow 

freshwater or brackish ponds, or on flooded tundra. Young fledge approximately 50 to 55 days 

after hatching, and females with broods move from freshwater to marine habitats just prior to or 

after fledging (Safine 2011). 

Nest success is highly variable and greatly influenced by predators. In arctic Russia, apparent 

nest success was estimated as <2% in 1994 and 27% in 1995; predation was believed to be the 

cause of high failure rates, with foxes, gulls and jaegers the suspected predators (Pearce et al. 

1998). Apparent nest success in 1991 and 1993 – 1995 in the Kuparuk and Prudhoe Bay oil 
15

fields on the ACP varied from 25 – 40% (Warnock and Troy 1992, Anderson et al. 1998). Nest 

survival probability for spectacled eiders in an area near Utqiaġvik, where arctic fox control was 

conducted, was 72% in 2011 (95% CI, 27 – 92%; Safine 2012). 

Post-breeding- North Slope 

Males generally depart breeding areas when females begin incubation in late June (Anderson and 

Cooper 1994, Bart and Earnst 2005). Use of the Beaufort Sea by departing males is variable. 

Some appear to move directly to the Chukchi Sea over land, while the majority moved rapidly 

(average travel of 1.75 days) over nearshore waters of the Beaufort Sea from the breeding 

grounds to the Chukchi Sea (TERA 2002). Males seem to prefer large river deltas such as the 

Colville River containing open water in early summer when much of the Beaufort Sea is still 

frozen. About half of adult males tracked in northern and western Alaska using satellite 

telemetry migrated to northern Russia to molt (Matt Sexson, USGS, unpublished data). 

This study also suggested that male eiders follow coast lines before migrating across the northern 

Bering and Chukchi seas en route to northern Russia (Matt Sexson, USGS unpublished data). 

Females generally depart the breeding grounds after males; more of the Beaufort Sea is ice-free 

at this time, allowing more extensive and prolonged use of marine waters (Peterson et al. 1999, 

TERA 2002). Females spent an average of two weeks in the Beaufort Sea (range 6 – 30 days) 

mostly in its western portion (TERA 2002). Females also appeared to migrate through the 

Beaufort Sea an average of 10 km further offshore than males (Peterson et al. 1999). Telemetry 

data indicate that molt migration of failed/non-breeding females from the Colville River Delta 

through the Beaufort Sea is relatively rapid (two weeks) compared to two to three months spent 

by failed/non-breeding females in the Chukchi Sea (Matt Sexson, USGS unpublished data). 

Molt 

Avian molt is energetically demanding, especially for species such as spectacled eiders that 

complete molt in a few weeks. Spectacled eiders use four molting areas from July to late October 

(Figure 3; Larned et al. 1995, Peterson et al. 1999). Females generally use molting areas nearest 

their breeding grounds. Males do not show strong molting site fidelity; males from all three 

breeding areas molt in Ledyard Bay, Mechigmenskiy Bay, and the Indigirka/Kolyma River 

Delta. Males reach molting areas first, beginning in late June, and remain through mid-October. 

Failed/non-breeding females arrive at molting areas in late July, while successfully-breeding 

females and young of the year reach molting areas in late August or September and remain 

through October. 

Winter 

After molting, spectacled eiders migrate offshore in the Chukchi and Bering Seas to a single 

wintering area in openings in pack ice of the central Bering Sea south/southwest of St. Lawrence 

Island (Figure 3). Hundreds of thousands of spectacled eiders (Petersen et al. 1999) rest and feed 

by diving up to 70 m to eat benthic bivalves, mollusks, and crustaceans (Lovvorn et al 2003, 

Cottam 1939, Petersen et al. 1998, Petersen and Douglas 2004). Sampling over several decades 

suggests that the benthic community in the overwintering area has shifted from larger to smaller 

species of clams (Lovvorn et al. 2003, Richman and Lovvorn 2003). 
16

Figure 3. Distribution of spectacled eiders. Molting areas (green) are used July through October. 

Wintering area (yellow) are used October through April. The full extent of molting and wintering 

areas is not yet known and may extend beyond the boundaries shown. 

Late Winter/Spring 

Spectacled and other eiders likely make extensive use of the eastern Chukchi spring lead system 

between departure from the wintering area in March and April and arrival on the North Slope in 

mid-May or early June. Limited spring aerial observations in the eastern Chukchi have 

documented dozens to several hundred common eiders (Somateria mollissima) and spectacled 

eiders in spring leads and several miles offshore in relatively small openings in rotting sea ice 

(W. Larned, USFWS; J. Lovvorn, University of Wyoming, pers. comm.). Woodby and Divoky 

(1982) documented large numbers of king eiders (S. spectabilis) and common eiders using the 

eastern Chukchi lead system, advancing in pulses during days of favorable following winds, and 

concluded that an open lead is probably requisite for spring eider passage in this region. 

Preliminary results from an ongoing satellite telemetry study conducted by the USGS Alaska 

Science Center suggest that spectacled eiders also use this lead system during spring migration 

(USGS unpublished data). 

Adequate foraging opportunities and nutrition during spring migration are critical to spectacled 

eider productivity. Like most sea ducks, female spectacled eiders do not feed substantially on the 
17

breeding grounds, but produce and incubate their eggs while living primarily off body reserves 

(Korschgen 1977, Drent and Daan 1980, Parker and Holm 1990). Clutch size, a measure of 

reproductive potential, was positively correlated with body condition and reserves obtained prior 

to arrival at breeding areas (Coulson 1984, Raveling 1979, Parker and Holm 1990). Body 

reserves must be maintained from winter or acquired during the 4-8 weeks (Lovvorn et al. 2003) 

of spring staging, and Petersen and Flint (2002) suggest common eider productivity on the 

western Beaufort Sea coast is influenced by conditions encountered in May to early June during 

spring migration through the Chukchi Sea (including Ledyard Bay). Common eider female body 

mass has been found to increase 20% during the 4-6 weeks prior to egg laying (Gorman and 

Milne 1971, Milne 1976, Korschgen 1977, Parker and Holm 1990). For spectacled eiders, 

average female body weight in late March in the Bering Sea was 1,550 ± 35 g (n = 12), and 

slightly (but not significantly) greater upon arrival at breeding sites (1,623 ± 46 g, n = 11; 

Lovvorn et al. 2003), indicating that spectacled eiders maintain or enhance their physiological 

condition during spring staging. 

Abundance and Trends 

The first range-wide estimate of spectacled eiders was 363,000 birds (333,526 – 392,532 95% 

CI), obtained by aerial surveys of the wintering area in the Bering Sea in late winter 1996 – 1997 

(Petersen et al. 1999). Winter/spring surveys using aerial photo census techniques were repeated 

in 2009 and 2010. The minimum global population estimate from these surveys was 369,122 

(90% CI, ± 4,932; Larned et al. 2012b), suggesting range-wide population stability over the 

interval. 

Population indices for North Slope-breeding spectacled eiders are unavailable prior to 1992. 

However, Warnock and Troy (1992) documented an 80% decline in spectacled eider abundance 

from 1981 to 1991 in the Prudhoe Bay area. Since 1992, the Service has conducted annual aerial 

surveys for breeding spectacled eiders on the ACP. The average annual population estimate 

(adjusted for detection) for 2007–2016 is 4,236 (95% CI = 3,178 – 5,294) breeding pairs, with a 

ten-year average growth rate of 0.997 (95% CI = 0.954 – 1.043; Wilson et al. 2017). 

Prior to 1972, an estimated 47,700 – 70,000 pairs of spectacled eiders nested on the Y-K Delta in 

average to good years (Dau and Kistchinski 1977). From the early 1970s to the early 1990s, the 

population declined steeply from 48,000 to 2,000 (Stehn et al. 1993). Ely et al. (1994) 

documented a 79% decline in eider nests between 1969 and 1992 for areas near the Kashunuk 

River. Furthermore, aerial and ground survey data indicated that spectacled eider numbers 

declined 9 – 14% per year from 1985 – 1992 (Stehn et al. 1993). Fischer and Stehn (2013) used 

combined annual ground-based and aerial survey data to estimate the number of nests and eggs 

of spectacled eiders on the coastal area of the YK-Delta in 2012 and evaluate long-term trends in 

the YK-Delta breeding population from 1985 to 2012. In a given year, the estimated number of 

nests reflects the minimum number of breeding pairs in the population and does not include nonnesting individuals or nests that were destroyed or abandoned (Fischer and Stehn 2013). The 

total number of spectacled eider nests on the YK-Delta in 2012 was estimated at 8,062 (SE 

1110). The average population growth rate based on these surveys was 1.058 (90% CI = 1.005 –

1.113) in 2003 – 2012 and 0.999 (90% CI = 0.986 – 1.012) in 1985 – 2012 (Fischer and Stehn 

2013). Log-linear regression based solely on the longterm YK-Delta aerial survey data indicate 
18

positive population growth rates of 1.073 (90% CI =1.046 – 1.100) in 2001 – 2010 and 1.070 

(90% CI = 1.058 – 1.081) in 1988 – 2010 (Platte and Stehn 2011). 

Critical habitat 

There is no designated critical habitat for spectacled eiders on lands administered by BLM in the 

NPR-A or elsewhere on Alaska’s North Slope. 

Spectacled Eider Recovery Criteria 

The Spectacled Eider Recovery Plan (USFWS 1996) presents research and management 

priorities with the objective of recovery and delisting so that protection under the ESA is no 

longer required. Although the cause or causes of the spectacled eider population decline is not 

known, factors that affect adult survival are likely to be the most influential on population 

growth rate. These include lead poisoning from ingested spent shotgun pellets, which may have 

contributed to the rapid decline observed in the Y-K Delta (Franson et al. 1995, Grand et al. 

1998), and other factors such as habitat loss, increased nest predation, overharvest, and 

disturbance and collisions with human built structures (factors discussed in the Environmental 

Baseline). Exposure to other contaminants, including petroleum-related compounds, 

organochlorine compounds, and elements, may also have contributed to population declines or 

constrained recovery. Under the Recovery Plan, the species will be considered recovered when 

each of the three recognized populations (Y-K Delta, North Slope of Alaska, and Arctic Russia): 

1) is stable or increasing over 10 or more years and the minimum estimated population size is at 

least 6,000 breeding pairs; or 2) number at least 10,000 breeding pairs over 3 or more years, or 3) 

number at least 25,000 breeding pairs in one year. 

Polar bear 

Status and distribution 

Due to threats to sea ice habitat, on May 15, 2008 the Service listed the polar bear as threatened 

under the ESA (73 FR 28212) throughout its range. In the U.S., the polar bear is also protected 

under the Marine Mammal Protection Act (MMPA) and the Convention on International Trade 

in Endangered Species of Wildlife Fauna and Flora (CITES) of 1973. 

Polar bears are widely distributed throughout the Arctic where the sea is ice-covered for large 

portions of the year. Polar bears throughout their range are subdivided into 19 recognized 

populations or stocks (Figure 4). The U.S. contains portions of two subpopulations: the Chukchi 

Sea (CS) (also called the Alaska-Chukotka subpopulation in the U.S.–Russia Bilateral 

Agreement) and the Southern Beaufort Sea (SB) subpopulation. 

Population size estimates and trends 

The most current population estimate for polar bears is approximately 26,000 individuals (95 % 

CI = 22,000-31,000; Wiig et al. 2015). Regarding population trends, the International Union for 

Conservation of Nature and Natural Resources, Species Survival Commission (IUCN/SSC) Polar 

Bear Specialist Group (PBSG) ranked three of the 19 subpopulations as “declining” and nine as 

“data deficient.” They ranked six as “stable” and just one as “increasing” (PBSG 2015, USFWS 

2017). 
19

Species biology and life history

Polar bears are the largest living bear species (DeMaster and Stirling 1981) with a longer neck 

and proportionally smaller head than other ursids. They are sexually dimorphic; females weigh 

400 to 700 pounds (lbs) and males up to 1,440 lbs (USFWS 2017). 

Figure 4. Global distribution of polar bear subpopulations as defined by the Polar Bear 

Specialist Group (Obbard et al. 2010; http://pbsg.npolar.no/en/status/population-map.html). 

Subpopulations include the Southern Beaufort Sea (SB), Chukchi Sea, Laptev Sea, Kara Sea, 

Barents Sea, East Greenland, Northern Beaufort (NB), Kane Basin (KB), Norwegian Bay (NW), 

Lancaster Sound (LS), Gulf of Boothia (GB), McClintock Channel (MC), Viscount Melville 

(VM), Baffin Bay, Davis Strait, Foxe Basin, Western Hudson Bay (WH), and Southern Hudson 

Bay. 

Breeding and reproduction- Polar bears are a K-selected species, characterized by late sexual 

maturity, small litter sizes, and extended maternal investment in raising young. All of these 

factors contribute to the species’ low reproductive rate (Amstrup 2003). Females generally 
20

mature and breed for the first time at 4 or 5 years and give birth at 5 or 6 years of age. Litters of 

two cubs are most common, but 3-cub litters are seen on occasion across the Arctic (Amstrup 

2003). The minimum reproductive interval for adult females is three years. Cubs stay with their 

mothers until weaning, which occurs most commonly in early spring when cubs are 2 1/2 years 

old. Female bears are available to breed again after their cubs are weaned (USFWS 2017).

Survival- Polar bears are long-lived and are not generally susceptible to disease or 

parasites. Due to extended maternal care of young and low reproductive rates, polar bears 

require high adult survival rates, particularly females, to maintain population levels (Eberhardt 

1985; Amstrup and Durner 1995). Survival rates are generally age dependent, with cubs-of-theyear having the lowest rates and prime-age adults (prime reproductive years are between 

approximately 5 and 20 years of age) having survival rates that can exceed 90 percent (Regehr et 

al. 2007a). Survival rates exceeding 90 percent for adult females are essential to sustain polar 

bear populations (Amstrup and Durner 1995).

Changes in body condition have been shown to affect bear survival and reproduction, which 

could, in turn, have population-level effects (Regehr et al. 2010; Rode et al. 2010). Survival of 

polar bear cubs-of-the-year has been directly linked to their weight and the weight of their 

mothers, with lower weights resulting in reduced survival (Derocher and Stirling 1996; Stirling 

et al. 1999). Changes in body condition indices were documented in the Western Hudson Bay 

subpopulation before a statistically significant decline in that subpopulation was documented

(Regehr et al. 2007b). Thus, changes in these indices may signal that reductions in survival and 

abundance are imminent (USFWS 2017).

Feeding- Polar bears are top predators in the Arctic marine ecosystem. They prey 

heavily on ice-seals, principally ringed seals (Phoca hispida), and to a lesser extent, bearded 

seals (Erignathus barbatus). Areas near ice edges, leads, or polynyas where ocean depth is 

minimal are the most productive hunting grounds (Durner et al. 2004). Bears occasionally take 

larger animals, such as walruses (Odobenus rosmarus) and belugas (Delphinapterus leucas) 

(Kiliaan and Stirling 1978). 

Bowhead whale carcasses, leftover after subsistence harvest, have been available to polar bears 

as a food source on the North Slope since the early 1970s (Koski et al. 2005). The use of whale 

carcasses as a food source likely varies among individuals and years. Stable isotope analysis of 

polar bears in 2003 and 2004 suggested that bowhead whale carcasses comprised 11%-26% 

(95% CI) of the diets of sampled polar bears in 2003, and 0%-14% (95% CI) in 2004 (Bentzen et 

al. 2007). 

Threats to the polar bear

Because the polar bear depends on sea ice for its survival, loss of sea ice due to climate change is 

its largest threat worldwide, although polar bear subpopulations face different combinations of 

human-induced threats (73 FR 28212, Obbard et al. 2010). The largest direct human-caused loss 

of polar bears is from subsistence hunting, but for most subpopulations where subsistence 

hunting of polar bears occurs, it is a regulated and/or monitored activity (Obbard et al. 2010). A 

thorough account of subsistence hunting, sport harvest, poaching, defense-of-life removals, and 

the management systems controlling these direct removal activities can be found in USFWS 
21

(2017). Other threats include accumulation of persistent organic pollutants in polar bear tissue, 

tourism, human-bear conflict, and increased development in the Arctic (Obbard et al. 2010). 

Climate change- As stated in the Polar Bear Conservation Management Plan (PBCMP) 

(USFWS 2016), polar bears evolved over thousands of years to life in a sea ice-dominated 

ecosystem and depend on sea ice for essential life functions. Climate-induced habitat 

degradation and loss are negatively affecting some polar bear stocks, and unabated global 

warming is expected to reduce the worldwide polar bear population (Obbard et al. 2010). 

Patterns of increased temperatures, earlier spring thaw, later fall freeze-up, increased rain-onsnow events (which may cause dens to collapse), and potential reductions in snowfall are also 

occurring. Loss of sea ice habitat due to climate change is identified as the primary threat to 

polar bears (Schliebe et al. 2006, 73 FR 28212, Obbard et al. 2010). 

The sea ice ecosystem supports ringed seals and other marine mammals that comprise the polar 

bear’s prey base (Stirling and Archibald 1977; Smith 1980; Smith 1985; Iverson et al. 2006). 

Sea ice cover is shown to be strongly, negatively correlated with surface temperature, which is 

increasing at about 3 times the global average in the Arctic (Comiso 2012). Declines in sea ice 

area more pronounced in summer than winter (NSIDC, 2011a, b). The mean linear rate of 

decline for August sea ice extent is 29,000 square miles per year, or 10.4 percent per decade 

since 1979 relative to the 1981 to 2010 average (NSIDC 2018). Thus, average Arctic sea ice 

extent in August is approximately 40% less now than 40 years ago. Positive feedback systems 

(i.e., sea-ice albedo) and naturally occurring events, such as warm water intrusion into the Arctic 

and changing atmospheric wind patterns, can cause fragmentation of sea ice, reduction in the 

extent and area of sea ice in all seasons, retraction of sea ice away from productive continental 

shelf areas throughout the polar basin, reduction of the amount of heavier and more stable multiyear ice, and declining thickness and quality of shore-fast ice (Parkinson et al. 1999, Rothrock et 

al. 1999, Comiso 2003, Fowler et al. 2004, Lindsay and Zhang 2005, Holland et al. 2006, 

Comiso 2006, Serreze et al. 2007, Stroeve et al. 2008). 

Loss of access to prey- The decline of sea ice habitat due to changing climate is 

affecting the ability of polar bears to forage in several ways. Sea ice provides a platform for 

hunting and feeding, seeking mates and breeding, denning, resting, and for long-distance 

movement. Polar bears depend on sea ice to hunt seals, and temporal and spatial availability of 

sea ice is predicted to decline. Once sea ice concentration drops below 50 percent, polar bears 

have been documented to abandon sea ice for land, where access to their primary prey is almost 

entirely absent, or they may retreat northward with more consolidated pack ice over the polar 

basin, which is likely less productive foraging habitat (Whiteman et al. 2015). In either case, 

polar bears are likely to have reduced access to prey resources (Whiteman et al. 2015). Ware et 

al. (2017) found that polar bears are increasingly occurring on ice over less-productive waters in 

summer. Although polar bears occasionally capture ringed seals in open water (Furnell and 

Oolooyuk 1980), typically ice seals in open water are inaccessible to polar bears (Harwood and 

Stirling 1992). Thus, species experts do not believe that polar bears will readily adapt to the loss 

of sea ice by adopting other hunting methods, such as hunting seals in ice-free water (Stirling 

and Derocher 1993; Derocher et al. 2004). 
22

 Effects of climate change on polar bear prey species- Ice seals, principally ringed 

seals, and to a lesser extent bearded seals, are the primary prey of polar bears, although other 

food sources are occasionally exploited (USFWS 2017). Climate change and the loss of Arctic 

sea ice are expected to affect ice seal populations significantly, and in response in 2012 the 

National Marine Fisheries Service (NMFS) listed the Arctic subspecies of ringed seal (Phoca 

hispida hispida) and the Beringia distinct population segment (DPS) of the bearded seal 

(Erignathus barbatus nauticus) as threatened species under the Act (77 FR 76706; 77 FR 

76740). 

Ice seal population dynamics reflect a complex mix of biotic and abiotic factors (Pilfold et al. 

2015), making it difficult to accurately assess the effects of changes in sea ice. However, several 

mechanisms by which a warming environment have affected ice seals, or plausibly should be 

expected to, have been identified. An adequate snow layer providing insulation around birth 

lairs is crucial for thermoregulation and survival of young pups (Stirling and Smith 2004). Pups 

in lairs with thin snow roofs are also more vulnerable to predation than pups in lairs with thick 

roofs (Hammill and Smith 1991; Ferguson et al. 2005), and when lack of snow cover has forced 

birthing to occur in the open, nearly 100% of pups died from predation (Smith and Lydersen 

1991; Smith et al. 1991). Rain-on-snow events during the late winter are increasing in frequency 

and can damage or eliminate snow-covered pupping lairs (ACIA 2005). Exposed pups are then 

vulnerable to hypothermia and predation by polar bears and arctic foxes (Alopex lagopus) 

(Stirling and Smith 2004). Pupping habitat on landfast ice (McLaren 1958; Burns 1970) and 

drifting pack ice (Wiig et al. 1999; Lydersen et al. 2004) can also be affected by earlier warming 

and break-up in the spring, which shortens the length of time pups have to grow and mature 

(Kelly 2001; Smith and Harwood 2001). 

Although the rate and extent of population-level response of ice seals to changes in sea ice 

conditions remain unclear, effects to ice seal populations will certainly affect polar bear 

populations. Polar bear populations fluctuate with prey abundance (Stirling and Lunn 1997), and 

regional declines in ringed and bearded seal numbers and productivity have been linked to 

marked declines in the associated polar bear subpopulations (Stirling and Øritsland 1995; Stirling 

2002). 

 Redistribution of polar bears in response to changes in sea ice- Several studies 

have shown that changes in sea ice, including the timing of melt in spring and freeze-up in fall, 

correlate with changes in the distribution of polar bears and their body condition or other indices 

of fitness. In Western Hudson Bay, sea ice break-up now occurs approximately 2.5 weeks earlier 

than it did 30 years ago because of increasing spring temperatures (Stirling et al. 1999; Stirling 

and Parkinson 2006), which is also correlated with when female bears come ashore and when 

they are able to return to the ice (Cherry et al. 2013). Similarly, changes in summer sea ice 

conditions have resulted in an increase in the time spent on shore during summer and the 

proportion of the population on shore in the Southern Beaufort Sea and Chukchi Sea 

subpopulations (Rode et al. 2015; Atwood et al. 2016). Rode et al. (2015) also found that 

changes in sea ice likely explain shifts in summer distribution of the Chukchi Sea subpopulation, 

from use of both Alaskan and Russian coastal areas before reductions in sea ice, to almost 

exclusive use of coastal areas in Russia after reductions in sea ice. 
23

Changes in the distribution of polar bears in response to changes in sea ice may increase 

exposure to some threats. If bears spend more time on land during the open water period, there 

is potential for increased disease transmission (Kirk et al. 2010; Prop et al. 2015; Wiig et al. 

2015), particularly where bears concentrate at dwindling food resources (e.g., remains of 

subsistence-harvested whales at Barter Island, Cross Island, and Point Barrow). Aggregations 

could also increase the number of individuals exposed in the event of oil spills (BOEM 2014). 

Increased use of onshore habitat by polar bears has also led to an increase in the number of 

human-polar bear conflicts (Dyck 2006; Towns et al. 2009). In two studies from northern 

Canada, researchers found that the majority of polar bears killed in defense of human life 

occurred during the open water season (Stenhouse et al. 1988; Dyck 2006). Thus, as more bears 

come on shore during summer, remain on shore longer, and become increasingly food-stressed, 

the risk of human conflict increases along with a probable increase in defense-of-life kills. 

 Demographic response- Reduced access to preferred prey (i.e., ice seals; 

Thiemann et al. 2008) is likely to have demographic effects on polar bears. For example, in the 

Southern Beaufort Sea subpopulation, the period when sea ice is over the continental shelf has 

decreased significantly over the past decade, resulting in reduced body mass and productivity 

(Rode et al. 2010; Rode et al. 2014) and likely reduced population size (Bromaghin et al. 2015). 

Changes in movements and seasonal distributions caused by climate change have been shown to 

affect polar bear nutrition and body condition (Stirling and Derocher 2012). Declining 

reproductive rates, subadult survival, and body mass have occurred because of longer fasting 

periods on land resulting from progressively earlier ice break-ups (Stirling et al. 1999; Derocher 

et al. 2004). Rode et al. (2010) suggested that declining sea ice has resulted in reduced body size 

and reproductive rates in the Southern Beaufort Sea subpopulation, and Regehr et al. (2007b) 

found that reduced sea ice habitat correlated with a reduction in the number of yearlings 

produced per female. In the Western Hudson Bay subpopulation, sea ice related declines in vital 

rates led to reduced abundance and declining population trends (Regehr et al. 2007b). 

To date, however, researchers have documented demographic effects of sea ice loss in only a few 

of the 19 polar bear subpopulations (Regehr et al. 2007a; Rode et al. 2012). Rode et al. (2014) 

found that even though sea ice loss during summer had been substantial in the Chukchi Sea, 

polar bears in that subpopulation had not yet exhibited concomitant declines in body mass or 

productivity. 

 Reduced denning success- Climate change could negatively influence polar bear 

denning (Derocher et al. 2004). Insufficient snow would prevent den construction or result in use 

of poor sites where the roof could collapse (Derocher et al. 2004). Changes in the amount and 

timing of snowfall could also impact the thermal properties of dens, and because cubs are born 

helpless and remain in the den for three months before emergence, major changes in the thermal 

properties of dens could negatively impact cub survival (Derocher et al. 2004). Unusual rain 

events are projected to increase throughout the Arctic in winter (Liston and Hiemstra 2011), and 

increased rain in late winter and early spring could cause den collapse (Stirling and Smith 2004). 

The proportion of bears denning on ice has decreased for some subpopulations (Atwood et al. 

2016) and not others, but the consequences of these shifts to cub survival are unknown. 
24

While polar bears can successfully den on sea ice (Amstrup and Gardner 1994; Fishbach et al. 

2007), for most subpopulations, maternity dens are located on land (Derocher et al. 2004). 

Female polar bears can repeatedly return to specific denning areas on land (Harington 1968; 

Ramsay and Stirling 1990; Amstrup and Gardner 1994). For bears to access preferred denning 

areas on land, pack ice must drift close enough or must freeze sufficiently early to allow 

pregnant females to walk or swim to the area by late October or early November (Derocher et al. 

2004). As distance increases between the pack ice edge and coastal denning areas, it will 

become increasingly difficult for females to access terrestrial denning locations unless they are 

already on or near land. Distance between the ice edge and shore is one factor thought to limit 

denning in western Alaska in the Chukchi Sea subpopulation (Rode et al. 2015). Increased travel 

distances could negatively affect denning success and ultimately population size of polar bears 

(Aars et al. 2006). 

Under most climate-change scenarios, the distance between the edge of the pack ice and land 

will increase during summer. Derocher et al. (2004) predicted that under future climate change 

scenarios, pregnant female polar bears will be unable to access many of the most important 

denning areas in the north coast of the central Beaufort Sea. Bergen et al. (2007) found that 

between 1979 and 2006, the minimum distance polar bears traveled to denning habitats in 

northeast Alaska increased by an average rate of 3.7-5.0 miles (6-8 km) per year, have nearly 

doubled since 1992, and would likely increase threefold by 2060. 

 Shipping and transportation- A decline in Arctic sea ice has increased the 

navigability of Arctic waters, with previously ice-covered sea routes now opening in summer, 

allowing access for commercial shipping, natural resource development, and tourism. Potential 

effects include fracturing of sea ice, disturbance of polar bears and their prey, increased humanpolar bear encounters, introduction of waste/ litter and toxic pollutants into the environment, and 

increased risk of oil spills (PBRS 2015; USFWS 2017). Although shipping is expected to 

increase in Arctic waters in response to declining sea ice, the PBCMP concluded that transArctic shipping poses minimal risk to polar bears in the long-term (USFWS 2017). Arctic 

nations are increasingly working cooperatively to track changes in shipping and manage possible 

increases in environmental impacts (USFWS 2017). 

 Oil and gas development- Polar bears overlap with both active and planned oil and gas 

operations throughout their range. Impacts on polar bears from industrial activities, such as oil 

and gas development, may include: disturbance from increasing human-bear interactions, 

resulting in direct displacement of polar bears, preclusion of polar bear use of preferred habitat 

(most notably, denning habitat); and/or displacement of primary prey. At the time of listing, the 

greatest level of oil and gas activity occurring within polar bear habitat was in the United States 

(Alaska). The Service determined that direct impacts on polar bears from oil and gas 

exploration, development, and production activities had been minimal and did not threaten the 

species overall. This conclusion was based primarily on: 1) the relatively limited and localized 

nature of the development activities; 2) existing mitigation measures that were in place; and 3) 

the availability of suitable alternative habitat for polar bears (USFWS 2017). 

Although oil and gas exploration, development and production throughout the Arctic has 

declined since the time of the listing, offshore oil and gas activities may increase due a decline in 
25

summer sea ice (USFWS 2016. 2017). Plans are also underway for new oil and gas development 

and infrastructure in polar bear habitat (e.g., natural gas pipeline from Mackenzie Delta to 

southern Canada and exploration offshore from Greenland, Russia, and Alaska (Beaufort Sea). 

In the United States, potential effects on polar bears are mitigated through: 1) development of 

activity-specific human-bear interaction plans (to avoid disturbance), 2) safety and deterrence 

training for industry staff, 3) bear monitoring and reporting requirements, and 4) implementation 

of project-specific protection measures (e.g., 1 mile buffers around den sites). In 2015, the 

Department of the Interior released additional proposed regulations for future, offshore 

exploratory drilling activities in the U.S. Arctic (USDOI 2015). These regulations are intended 

to improve operational standards from mobilization to transport, drilling, and emergency 

response in a manner that the entire exploration operation can be conducted in a safe manner 

(USFWS 2017). 

 Contaminants- In the final rule listing the polar bear as a threatened species, the Service 

identified three categories of contaminants in the Arctic that present the greatest potential threats 

to polar bears and other marine mammals: persistent organic pollutants (POPs), heavy metals, 

and petroleum hydrocarbons (73 FR 28288-28291). In the PBCMP (USFWS 2017, p. 74), the 

Service concluded that contaminant concentrations were not thought to have population level 

effects on most polar bear populations, but noted that contaminants may become a threat in the 

future, especially in subpopulations experiencing declines related to nutritional stress brought on 

by sea ice loss and environmental changes. 

 Petroleum hydrocarbons/oil spills- Oil spills could potentially affect polar bears 

through: 1) affecting their ability to thermoregulate if their fur is oiled, 2) lethal or sublethal 

effects of ingestion of oil from grooming or eating contaminated prey, 3) habitat loss or 

decreased availability of preferred habitat; and 4) impacts to the abundance or health of prey. At 

the time of listing, no major oil spills had occurred in the marine environment within the range of 

polar bears and the Service had determined that the probability of a large oil spill occurring in 

polar bear habitat was low. We also noted that, in Alaska: 1) previous operations in the Beaufort 

and Chukchi seas have been conducted safely, and effects on wildlife and the environment have 

been minimized; 2) regulations exist to require pollution prevention and control; and 3) plans are 

reviewed by both leasing and wildlife agencies to ensure appropriate species-specific protective 

measures for polar bears are included. However, we also noted that increased oil and gas 

development coupled with increased shipping elevated the potential for spills, and if a large spill 

were to occur, it could have significant impacts to polar bears and their prey, depending on the 

size, location, and timing of the spill. 

 Persistent Organic Pollutants (POPs)- Persistent organic pollutants are organic 

chemicals resistant to biodegradation, and can affect apex predators such as polar bears that have 

low reproductive rates and high lipid levels because POPs tend to bioaccumulate and biomagnify 

in fatty tissues. While the levels of some contaminants, such as PCBs, generally seem to be 

decreasing in polar bears, others, such as hexachlorocyclohexanes, were relatively high, and 

newer compounds, such as polybrominated diphenyl ethers and perflouro-octane sulfonates, 

posed a potential future risk to polar bears. The effects of these contaminants at the population 

level are relatively unknown (USFWS 2017). 
26

 Metals- The most toxic or abundant elements in marine mammals are mercury, 

cadmium, selenium, and lead. Of these, mercury is of greatest concern because of its potential 

toxicity at relatively low concentrations and its tendency to bioaccumulate and biomagnify in the 

food web (73 FR 28291). In the final rule to list the polar bear (73 RF 28212) the Service noted 

that although mercury found in marine mammals often exceed levels that have caused effects in 

terrestrial mammals, most marine mammals appear to have evolved mechanisms that allow 

tolerance of higher concentrations of mercury (AMAP 2005). Although population-level effects 

are still widely un-documented for most polar bear subpopulations, increasing exposure to 

contaminants may become a more significant threat in the future, especially for declining polar 

bear subpopulations and/or bears experiencing nutritional stress (USFWS 2017). 

 Ecotourism- Polar bear viewing and photography are popular forms of tourism that occur 

primarily in Churchill, Canada; Svalbard, Norway; and the north coast of Alaska (the 

communities of Kaktovik and Barrow). In the final listing rule for the polar bear, the Service 

noted that, while it is unlikely that properly regulated tourism will have a negative effect on polar 

bear subpopulations, increasing levels of public viewing and photography in polar bear habitat 

might lead to increased human-polar bear interactions. Tourism can also result in inadvertent 

displacement of polar bears from preferred habitats or alter natural behaviors (Lentfer 1990; 

Dyck and Baydack 2004, Eckhardt 2005). Conversely, tourism can have the positive effect of 

increasing the worldwide constituency of people with an interest in polar bears and their 

conservation (USFWS 2017). 

Polar bear critical habitat 

The polar bear was listed as a threatened species throughout its range, but the regulatory 

authority to designate critical habitat (50 CFR 424.12(h)) is limited to areas of U.S. jurisdiction, 

which in the case of the polar bear includes Alaska and adjacent territorial and U.S. waters. The 

Service designated 484,734 square kilometers of critical habitat for the polar bear in 2010 (75 FR 

76086). 

Description of Polar Bear Critical Habitat- Designation of critical habitat requires, within the 

geographical area occupied by the polar bear, identification of the physical or biological features 

(PBFs) essential to the conservation of the species that may require special management or 

protection. We identified the following three PBFs essential to the conservation of the polar 

bear: 

1) Sea-ice habitat used for feeding, breeding, denning, and movement, which is further defined 

as sea-ice over waters 300 m or less in depth that occurs over the continental shelf with 

adequate prey resources (primarily ringed and bearded seals) to support polar bears. 

2) Terrestrial denning habitat, which includes topographic features, such as coastal bluffs and 

river banks, with suitable macrohabitat characteristics. Suitable macrohabitat characteristics 

are: 

a) Steep, stable slopes (range 15.5–50.0°), with heights ranging from 1.3 to 34 m, and with 

water or relatively level ground below the slope and relatively flat terrain above the 

slope; 

b) Unobstructed, undisturbed access between den sites and the coast; 
27

c) Sea-ice in proximity to terrestrial denning habitat prior to the onset of denning during the 

fall to provide access to terrestrial den sites; and 

d) The absence of disturbance from humans and human activities that might attract other 

polar bears. 

3) Barrier island habitat used for denning, refuge from human disturbance, and movements 

along the coast to access maternal den and optimal feeding habitat, including all barrier 

islands along the Alaska coast and their associated spits, within the range of the polar bear in 

the United States, and the water, ice, and terrestrial habitat within 1.6 km of these islands. 

Considering the three PBFs, and the quantity and spatial arrangement of them necessary to 

support conservation of the polar bear, we designated the following three critical habitat units, 

each of which contains at least one of the PBFs: 

Unit 1, Sea Ice Habitat- Sea ice habitat covers approximately 464,924 km2

of primarily marine 

habitat extending from the mean high tide line of the Alaska coast seaward to the 300 m depth 

contour, and spans west to the international date line, north to the Exclusive Economic Zone, east 

to the US–Canada border, and south to the southern limit of the known distribution of the 

Chukchi Sea polar bear subpopulation. Sea ice is used by polar bears for the majority of their 

life cycle for activities such as hunting seals, breeding, denning, and traveling. 

Unit 2, Terrestrial Denning Habitat- Terrestrial denning habitat occurs within approximately 

14,652 km2

of land along the northern coast of Alaska from the Canadian border west to near 

Point Barrow. It encompasses approximately 95% of the known historical terrestrial den sites 

from the Southern Beaufort Sea subpopulation (Durner et al. 2009). The inland extent of 

denning distinctly varies between two longitudinal zones, with 95% of known dens between the 

Alaska/Canada border and Kavik River occurring within 32 km of the mainland coast, and 95% 

of dens between the Kavik River and Utqiaġvik occurring within 8 km of the mainland coast. 

The inland boundary of the Terrestrial Denning Unit reflects this difference in the distribution of 

known den sites, with the boundary drawn at 32 km inland between the Alaska/Canada border 

and the Kavik River and 8 km inland between the Kavik River and Utqiaġvik.

Unit 3, Barrier Island Habitat- Barrier island habitat covers approximately 10,575 km2

of barrier 

islands and the associated complex of spits, water, ice, and terrestrial habitats within 1.6 km of 

barrier islands. There is significant overlap between this unit and the Terrestrial Denning and 

Sea Ice units. Similar to the Sea Ice Unit, the Barrier Island Unit extends from near the 

Alaska/Canada Border to near Hooper Bay in southwestern Alaska but only occurs where barrier 

islands exist. 

Exclusions within Designated Polar Bear Critical Habitat- Within the Terrestrial Denning and 

Barrier Island units, critical habitat does not include manmade structures (e.g., houses, gravel 

roads, airport runways and facilities, pipelines, well heads, generator plants, construction camps, 

sewage treatment plants, hotels, docks, seawalls, and the land on which they were constructed) 

that existed on the effective date of the rule. The two communities of Barrow and Kaktovik were 

also excluded. 
28

ENVIRONMENTAL BASELINE 

Regulations implementing the ESA (50 CFR §402.02) define the environmental baseline to 

include the past and present impacts of all Federal, State, or private actions and other human 

actions in the Action Area. Also included are anticipated impacts of all proposed Federal projects 

in the Action Area that have undergone section 7 consultation and the impacts of State and 

private actions concurrent with the consultation in progress. 

Spectacled Eiders 

Spectacled eiders use portions of the Action Area during spring and summer to breed, nest, and 

raise broods. This BO utilized multiple datasets to assess eider density and trend in the GMT-2 

Action Area. Available datasets include both smaller-scale regional studies funded or conducted 

by industry to inform management of proposed projects (Seiser and Johnson 2018a, Seiser and 

Johnson 2018b, Johnson et al. 2018) and larger-scale aerial surveys of the ACP conducted by the 

Service to monitor populations (Wilson et al. 2017). 

Long-term studies have been conducted by ABR Inc. on behalf of CPAI and the BLM in the 

Colville Study Area (CSA), the Kuparuk Study Area (KSA), and NPR-A Study Area (NPRASA), and portions of these study areas overlap with the Action Area (Figure 6). Aerial surveys 

were conducted in the CSA for 25 years (1993 − 1998, 2000 − 2017) and in the NPR-ASA for 14 

years (1999 − 2006 and 2008 − 2014). Ground-based eider nest searches were conducted in the 

CSA (Alpine, CD-2, CD-3, CD-4, CD-5, and Alaska Clean Seas spill-response sites) in 1993 –

2007 and 2009 − 2017 and in the NPR-ASA in 1999 − 2004, 2009, and 2013 − 2014 (Seiser and 

Johnson 2018a, Seiser and Johnson 2018b, Johnson et al. 2015; Johnson pers. comm. 2018). 

These studies provide recent site-specific density and trend data in the GMT-2 Action Area. We 

summarize this information below.

The average indicated density for pre-nesting spectacled eiders over a 25-year study period is 

0.11 individuals/km2(Johnson et al. 2018). The CSA is further partitioned into CD North and 

CD South, with greater densities in CD North (Figure 7). 

All observations of pre-nesting Spectacled Eiders in the [CSA] in 2017 were of 

small groups of 1–3 birds. The CD North subarea contained 85% of the 

Spectacled Eiders observed, whereas the CD South subarea contained 9%. The 

density of pre-nesting Spectacled Eiders in the CD North subarea during 2017 

(0.27 indicated birds/km2) was twice the density recorded on the much larger 

Colville Delta study area (0.13 indicated birds/km2). The distribution of prenesting Spectacled Eiders in 2017 was typical of previous years, when densities 

were highest north of Alpine and low south and northeast of Alpine (Johnson et al. 

2018).

Compared with 14 previous years of pre-nesting surveys, the density of spectacled eiders in the 

NPR-ASA was near average in 2014 with the density being only 21 percent of the density on the 

CSA (Johnson et al. 2015). Over the entire NPR-ASA spectacled eider densities were 0.02 

observed eiders/km2and 0.03 indicated eiders/km2in 2014 (Johnson et al. 2015). Spectacled 

eiders were observed only in two subareas (Alpine West and Fish Creek Delta, Figure 6) in the 

NPR-ASA in 2014, with the highest density in Alpine West (0.14 indicated birds/km2) (Johnson 
29

et al. 2015). The mean density distribution also shows high densities have occurred in Alpine 

West near the Colville River, as well as near the coast and Fish and Judy creeks in the western 

portions of the NPR-ASA (Johnson et al. 2015). 

In 2017, ground-based nest searches for eiders were conducted in select areas of the CSA and 

NPR-ASA (Seiser and Johnson 2018a). These ground-based nest searches have been conducted 

for the past 9 years in preparation for planned tundra activity during the nesting season (Seiser 

and Johnson 2018a). In 2017, only 9 qualifying Alaska Clean Seas sites and 3 water-source lakes 

were searched for eider nests; nest searches along the CD-3 – CD-2 ice road, and CD-3 drill pad 

and airstrip were not conducted (Seiser and Johnson 2018a). The majority of the area where the 

ground-based nest searches took place in 2017 is more than 5 miles from the proposed GMT-2 

pad and road. During the 2017 nest survey, no spectacled eider nests were found within the select 

areas of the CSA and NPR-ASA (Seiser and Johnson 2018a). 

In 2017, ground-based nest searches for eiders were also conducted in potential nesting habitat 

within 200 m of each side of the GMT-1 ice road, ice pads, water-source access points, and 

hydrotest locations between the CD-4 road and the GMT-1 pad (Figures 1 and 2 in Seizer and 

Johnson 2018b). No spectacled eider nests were found during these 2017 nest surveys (Seiser 

and Johnson 2018b). 

Finally, in 2017, ground-based searches for eiders were conducted near DS-1E, DS-2C, DS-2F, 

DS-2T northern basin complex (2T [N]), DS-2T southern basin complex (2T [S]), and Mine Site 

E (Figure 1 in Morgan and Attanas 2018) of the KSA. These areas were searched because 

nesting spectacled Eiders have been observed frequently and repeatedly since ground-based nest 

searches began in 1993 in the area (Morgan and Attanas 2018). Eight spectacled Eider nests were 

located in 2017 (Morgan and Attanas 2018); all were more than five miles from the Action Area. 

Population growth rates in both the CSA and NPR-ASA were slightly positive but not 

statistically significant (Johnson et al. 2018 and Johnson et al. 2015, respectively). 

Pre-nesting spectacled eiders used 18 of 24 available habitats during 24 years of aerial surveys 

on the CSA. Seven habitats were preferred (i.e., use was significantly greater than availability, P 

≤ 0.05) by pre-nesting spectacled eiders: three primarily coastal salt-affected habitats (Brackish 

Water, Salt Marsh, and Salt-killed Tundra), three aquatic habitats (Deep Open Water with 

Islands or Polygonized Margins, Shallow Open Water with Islands or Polygonized Margins, and 

Grass Marsh), and one terrestrial habitat (Deep Polygon Complex) (Johnson et al. 2018). Deep 

Polygon Complex, which consists of a mosaic of small, deep, polygon ponds with relatively 

narrow vegetated rims and sometimes with islets, is notable because of its disproportionate use; 

it was used by 28 percent of the spectacled eider groups yet comprised only 2.7 percent of the 

CSA (Johnson et al. 2018). Six habitats were avoided (i.e., use significantly less than 

availability), including Open Nearshore Water, Tidal Flat Barrens, River or Stream, Moist 

Sedge-Shrub Meadow, Tall, Low, or Dwarf Shrub, and Barrens. All other habitats were used in 

proportion to their availability (Johnson et al. 2018), indicating no preference for or avoidance of 

these habitats. 

Pre-nesting spectacled eiders used 13 of 26 available habitats in the NPR-ASA during 14 years 

of aerial surveys (Johnson et al. 2015), preferring five habitats, four of which also were preferred 
30

in the CSA: Brackish Water, Salt Marsh, Shallow Open Water with Islands or Polygonized 

Margins, and Grass Marsh (Johnson et al. 2015). Two terrestrial habitats (Moist Sedge-Shrub 

Meadow and Moist Tussock Tundra) were significantly avoided, which is notable because these

comprise the majority of area within the NPR-ASA (Johnson et al. 2015). The habitat selection 

information for both the CSA and NPR-ASA is relevant because the permanent gravel footprint 

of GMT-2 would occur in habitat types that were either avoided or were not selected for by 

spectacled eiders (depending on study area and habitat type) in the pre-nesting period. 

Annual aerial surveys to monitor the distribution, abundance, and growth rate of 29 waterbird 

species breeding on the ACP have been conducted by the Service since 1986 (Wilson et al. 

2017). In addition to the ABR Inc. surveys summarized in previous paragraphs, these aerial 

surveys provide larger-scale regional context for local distribution and density estimates and are 

more robust in evaluating population trend. Prior to 2007, two historical surveys with slightly 

different timing and coverage (i.e., the original Arctic Coastal Plain [Original ACP] Survey 

[1986-2006; Brackney and King 1993, Mallek et al. 2006], and the North Slope Eider [NSE] 

survey [1992-2006; Larned et al. 2006]) were conducted. In 2007, the Original ACP and NSE 

surveys were merged (Stehn et al. 2013), and the re-designed survey (hereafter, “ACP Survey;” 

Larned et al. 2007, Larned et al. 2012, Stehn et al. 2013, Stehn 2014) has been flown annually 

since 2007. 

The most recently synthesized aerial survey results (USFWS 2015b, covering survey years 2012 

– 2015) provide a means to evaluate the relative density of spectacled eiders across the ACP and 

provide an additional means to assess density within the Action Area. Using GIS, the range in 

observed density across the ACP was subdivided into five categories or contours, each of which 

contains a range in density and was defined by the lower and upper limits and median of the 

range within that contour. The GMT-2 Action Area occurs within the two lowest density 

contours: 0 – 0.034 eiders/km2(407 km2 [65%] of the Action Area) and 0.035 – 0.101 eiders/km2

(218 km2 [35%] of the Action Area). Thus, consistent with ABR’s surveys, our aerial surveys 

show that spectacled eiders occur at very low density (up to ~1 spectacled eider per 30 km2) or 

low density (up to ~1 spectacled eider per 10 km2) within the GMT-2 Action Area. The ACP 

survey data also allow assessment of trend, which was essentially stable over the interval 2007-

2016 (growth rate 0.997; 95% CI 0.954-1.043; Wilson et al. 2017). 
31

Figure 4. Avian studies in proximity to the GMT-2 Action Area. 
32

Figure 6. Spectacled eider densities in relation to GMT-2 Preferred Alternative Action Area. Source data USFWS 2016 unpublished.
33

Figure 7. Locations of spectacled eiders from pre-nesting aerial surveys and ground-based nest surveys conducted in the area of GMT2. From BLM (2018a). 
34

Possible Threats in the Action Area 

Factors which may have contributed to the current status of spectacled eiders in the action area 

include but are not limited to, long-term habitat loss through development and disturbance, 

environmental contaminants, increased predator populations, collisions with structures, research, 

climate change, and subsistence harvest. These impacts are occurring throughout much of the 

species’ range, including within the action area.

Habitat loss through development and disturbance- Nesting habitat loss on the North 

Slope has been limited, and is not believed to have caused population declines or constrained 

population recovery. However, loss of nesting habitat likely has affected spectacled eiders at the 

individual level and local scale in some areas. 

Development within the Action Area includes the Alpine airstrip, drill pads, roads, pipelines and 

associated infrastructure; GMT-1 pad, road, pipeline; the ASRC mine site; and the community of 

Nuiqsut, the dumpsite, spur road and airstrip. 

Environmental contaminants- Deposition of lead shot in tundra wetlands and shallow 

marine habitat where eiders forage poses a threat to listed eiders. The toxic effects of ingestion of 

lead poisoning may vary among individuals, but include lethal and sublethal effects (Hoffman 

1990). Ingestion of spent lead shot reduced survival rates of spectacled eiders on the Y-K Delta 

(Franson et al. 1995, Flint et al. 1997, Flint and Grand 1997, Grand et al. 1998, Flint and Herzog 

1999). Ingestion of lead shot by listed eiders could occur during the breeding season, particularly 

for breeding hens and young birds foraging in shallow tundra ponds. Exposure may decline 

during incubation, when hens largely forgo foraging, but the need to forage resumes after 

hatching, and both hens and ducklings may encounter and ingest lead shot. Waterfowl hunting 

with lead shot is prohibited throughout Alaska, and for hunting all birds on the North Slope. 

However, its sale and use continues in villages, and lead deposited in wetlands previously will 

presumably be present in the environment and ingested by waterfowl for some unknown period 

into the future.

Other contaminants, including petroleum hydrocarbons from local sources or globally distributed 

heavy metals, may also affect listed eiders. For example, spectacled eiders wintering near St. 

Lawrence Island exhibited high concentrations of metals as well as subtle biochemical changes 

(Trust et al. 2000). Additionally, spectacled eiders breeding and staging on the Colville River 

Delta may have been exposed to petroleum hydrocarbons, heavy metals, and other contaminants 

from nearby industrial development. However, risk of contaminant exposure and potential 

affects to listed eiders in the Action Area are unknown. 

Increased Predator Populations- Predator and scavenger populations have likely 

increased near villages and industrial infrastructure on the ACP in recent decades (Eberhardt et 

al. 1983, Day 1998, Powell and Backensto 2009). Reduced fox trapping, anthropogenic food 

sources in villages, and an increase in availability of nesting/denning sites at human-built 

structures may have resulted in increased numbers of arctic foxes (Alopex lagopus), common 

ravens (Corvus corax), and glaucous gulls (Larus hyperboreus) in developed areas of the ACP 

(Day 1998). For example, ravens are highly efficient egg predators (Day 1998), and have been 

observed depredating Steller’s eider nests near Utqiaġvik (Quakenbush et al. 2004). Ravens also 

appear to have expanded their breeding range on the ACP by using manmade structures for nest 
35

sites (Day 1998). Therefore, as the scale of development increases, the number of artificial nest 

sites and sources of anthropogenic food will also increase, and the reproductive success of 

spectacled eiders could decrease. 

Collisions with structures- Migratory birds suffer considerable mortality from collisions 

with man-made structures (Manville 2004) including light poles, buildings, drill rigs, guyed 

towers or poles, and overhead powerlines. Birds are particularly at risk of collision when 

visibility is impaired by darkness or inclement weather (Weir 1976). There is also evidence that 

lights on structures increase collision risk (Reed et al. 1985, Russell 2005, numerous authors 

cited by Manville 2000). Anderson and Murphy (1988) monitored bird behavior and strikes to a 

12.5 km power line in the Lisburn area (the southern portion of the Prudhoe Bay oil fields) 

during 1986 and 1987. They documented lethal wire collisions in 18 species of birds, including 

at least one eider. Results indicated that strike rate was related to flight behavior, in particular 

the height of flight above ground (or water) level. Johnson and Richardson (1982) in their study 

of migratory bird behavior along the Beaufort Sea coast reported that 88% of eiders flew below 

an estimated altitude of 10 m (32 ft) and well over half flew below 5 m (16 ft). Thus, structures 

as low as < 10 m in height pose a collision risk to migrating eiders. 

Although several factors confound accurate collision estimates for listed eiders, including: 1) 

temporal changes in eider density and distribution, 2) lack of understanding how feature 

configurations contribute to avian collisions, and 3) how variations in weather and lighting 

conditions effect probability of collisions; an unknown level of collision risk remains over the 

life of man-made structures. However, some design considerations may reduce or eliminate 

collision risk for listed eiders, including shielded lighting to limit outward-radiating light and 

minimize potential attraction and/or disorienting effects to eiders, and avoidance of the use of 

guyed towers or overhead lines). 

Research- Field-based scientific research has increased on the ACP in response to interest 

in climate change and its effects on Arctic ecosystems. While some activities have no impact on 

spectacled eiders (e.g., remote sensing tools are used or field work occurs outside the nesting 

season), aerial surveys, on-tundra activities, or remote aircraft landings may disturb listed eiders. 

Many of these activities are considered in intra-Service consultations, or under a programmatic 

consultation with the BLM for summer activities in the NPR-A. We are aware of no current or 

planned research activities within the action area that would affect listed eiders, however. 

Climate Change- The environmental baseline includes consideration of ongoing and 

projected changes in climate. This BO includes consideration of ongoing and projected changes 

in climate using terms as defined by the Intergovernmental Panel on Climate Change (IPCC). 

“Climate” refers to the mean and variability of different types of weather conditions over time, 

with 30 years being a typical period for such measurements, although shorter or longer periods 

also may be used (IPCC 2014, pp. 119 – 120). The term “climate change” thus refers to a change 

in the mean or variability of one or more measures of climate (e.g., temperature or precipitation) 

that persists for an extended period, typically decades or longer, whether the change is due to 

natural variability, human activity, or both (IPCC 2014, p. 120). Various types of changes in 

climate can have direct or indirect effects on species. These effects may be positive, neutral, or 

negative and they may change over time, depending on the species and other relevant 
36

considerations, such as the effects of interactions of climate with other variables (e.g., habitat 

fragmentation) (IPCC 2014, pp. 49 – 52). 

High latitude regions, such as Alaska’s North Slope, are thought to be especially sensitive to 

effects of climate change (Quinlan et al. 2005, Schindler and Smol 2006, Smol et al. 2005). 

While climate change will likely affect individual organisms and communities, it is difficult to 

predict with certainty how these effects will manifest. Biological, climatological, and hydrologic 

components of the ecosystem are interlinked and operate on varied spatial, temporal, and 

organizational scales with feedback between components (Hinzman et al. 2005). 

There are a wide variety of changes occurring across the circumpolar Arctic. Arctic landscapes 

are dominated by freshwater wetlands (Quinlan et al. 2005), which listed eiders depend on for 

forage and brood rearing. As permafrost thaws, some water bodies are draining (Smith et al. 

2005, Oechel et al. 1995), or drying due to increased evaporation and evapotranspiration during 

prolonged ice-free periods (Schindler and Smol 2006, and Smol and Douglas 2007). In addition, 

productivity of some lakes and ponds is increasing in correlation with elevated nutrient inputs 

from thawing soil (Quinlan et al. 2005, Smol et al. 2005, Hinzman et al. 2005, and Chapin et al. 

1995) and other changes in water chemistry or temperature are altering algal and invertebrate 

communities, which form the basis of the Arctic food web (Smol et al. 2005, Quinlan et al. 

2005).

With reduced summer sea ice coverage, the frequency and magnitude of coastal storm surges has 

increased. During these events, coastal lakes and low lying wetlands are often breached, altering 

soil/water chemistry as well as floral and faunal communities (USGS 2006). When coupled with 

softer, semi-thawed permafrost, reductions in sea ice have significantly increased coastal erosion 

rates (USGS 2006), which may reduce available coastal tundra habitat over time. 

Changes in precipitation patterns, air and soil temperatures, and water chemistry are also 

affecting terrestrial communities (Hinzman et al. 2005, Prowse et al. 2006, Chapin et al. 1995), 

and the range of some boreal vegetation species is expanding northward (Callaghan et al. 2004).

Climate-induced shifts in distributions of predators, parasites, and disease vectors may also have 

significant effects on listed and un-listed species. Climate change may also cause mismatched 

phenology among listed eider migration, development of tundra wetland invertebrate stocks, 

fluctuation of small mammal populations, and corresponding abundance of predators (Callaghan 

et al. 2004). 

While the impacts of climate change are on-going and the ultimate effects on spectacled eiders 

within the action area are unclear, species with small populations are more vulnerable to the 

impacts of environmental change (Crick 2004). Some species may adapt and thrive under 

changing environmental conditions, while others decline or suffer reduced biological fitness. 

Subsistence harvest- Prior to the listing of spectacled eiders under the ESA, some level of 

subsistence harvest of this species occurred across the North Slope (Braund et al. 1993). Hunting 

for spectacled eiders was closed in 1991 by Alaska State regulations and Service policy, and 

outreach efforts have been conducted by the North Slope Borough, BLM, and Service to 

encourage compliance. Harvest surveys and other information indicate that spectacled eiders 
37

continue to be taken during subsistence hunting on the North Slope, although estimates of the 

number taken are imprecise, and numerous unquantifiable biases compromise the reliability of 

estimates. Continued efforts to eliminate shooting are being implemented in North Slope 

villages. Intra-service consultation on the promulgation of the Migratory Bird Subsistence 

Hunting Regulations is conducted annually. 

Polar Bears 

Typically, most polar bears occur in the active ice zone, far offshore, hunting throughout the 

year. Bears also spend a limited time on land to feed or move to other areas, although melting sea 

ice may result in increased numbers of polar bears moving from the offshore ice onto land. 

During fall and winter months, polar bears use the terrestrial environment to establish maternal 

den sites (pregnant females), and/or exploit food resources (e.g., whale carcasses). Polar bears 

may also abandon melting sea ice and/or use the terrestrial environment to transit to other areas. 

The available information indicates that polar bears occur near the Action Area with some 

regularity, although most sightings occurred north of the Action Area, closer to the Beaufort Sea 

coast, and most likely correspond to transient individuals (males and non-denning females) and 

are not indicative of use of the area for denning (Figure 8). 

Female polar bears in the Southern Beaufort Sea subpopulation establish maternal dens on pack 

ice or onshore, although the distribution of dens appears to be changing over time. Fishbach et al. 

(2007) found that the proportion denning on pack ice (as opposed to onshore) decreased from 

62% from 1985–1994 to 37% in 1998–2004, and those denning on sea ice shifted from west to 

east. They attributed both trends to deteriorating sea ice conditions in the western Beaufort Sea 

(Fishbach et al. 2007). 

Potential polar bear denning habitat is generally definable by the physical features that facilitate 

the capture of sufficient snow to allow den excavation (Durner et al. 2003). In terrestrial habitats, 

these conditions are typically found along the shores of rivers, lakes and the coast. Orientation of 

these landforms, wind speed and direction, and snow amount and timing also influence the 

suitability of denning habitat (Liston 2012). The two dominant wind directions associated with 

storm events that deposit the most snow (storms with wind speeds above approximately 5 m/s, 

assuming snow is available to be transported) on the North Slope of the Arctic coast are 

northeast to east (45.0 to 90.0 degrees) and west southwest to southwest (247.5 to 270.0 degrees; 

Liston 2012). Suitable denning habitat within the Action Area primarily occurs along the 

Ublutuoch River (Tiŋmiaqsiuġvik) and Niġliq and Niġliagvik channels of the Colville River 

(Figures 8 and 9). 

Only two dens have been found near the Action Area, one within the Action Area in 1917 and 

one ~ 1.8 km outside the Action Area in 2007 (Figure 8), possibly because most dens in this 

region occur closer to the coast (> 95% of records of polar bear dens [n=19] between the Kavik 

River and Utqiaġvik were within 4.5 km of the coast [Durner et al. 2009]). Additionally, suitable 

denning habitat within the Action Area is sparse, and polar bears generally den at a low density 

across the landscape (Harington 1968, Lentfer and Hensel 1980, Amstrup and Gardner 1994).

We also expect transient (non-denning) polar bears to pass through the Action Area only 

infrequently, as they generally remain close to the coast. While no systematic polar bear surveys 

have been conducted in the Alpine Satellites Development project area, the majority of 
38

opportunistic sightings (since 1917) occured north and northeast of the GMT-2 Action Area and 

much closer to the coast (Figure 9). 

Southern Beaufort Sea Subpopulation 

Polar bears in the Action Area are considered to belong to Southern Beaufort Sea (SBS) 

subpopulation (Figure 5). Radio-telemetry data and other marking data suggest that the SBS 

subpopulation ranges between Icy Cape, Alaska and Pearce Point, Northwest Territories, 

Canada. The SBS subpopulation had an estimated population size of approximately 900 bears in 

2010 (Bromaghin et al. 2015), which is a significant reduction from previous estimates of 

approximately 1,800 in 1986 (Amstrup et al. 1986) and 1,526 in 2006 (Regehr et al. 2006). In 

addition, analyses of over 20 years of data on size and body condition of bears in this 

subpopulation demonstrated declines for most sex and age classes and significant negative 

relationships between annual sea ice availability and body condition (Rode et al. 2010). This 

suggests the SBS subpopulation is currently declining due to sea ice loss (USFWS 2016a).

Threats and Possible Stressors in the Action Area 

As stated in the section, Threats to the Polar Bear, the primary threat to polar bears throughout 

their range is the projected future loss of sea ice resulting from climate change. Although 

significant changes in summer sea ice have already occurred in the past few years, the prognosis 

for continued change and how those changes will affect polar bear populations is not yet known. 

Other factors that may affect polar bears in the Action Area are also discussed. 

Subsistence Harvest- The Inuvialuit-Inupiat Polar Bear Management Agreement, a 

Native-to-Native agreement, between the Inupiat from Alaska and the Inuvialuit in Canada was 

created for the SBS subpopulation of polar bears in 1988. Polar bears harvested from the 

communities of Utqiaġvik, Nuiqsut, Kaktovik, Wainwright, and Atqasuk are currently 

considered part of the SBS subpopulation and thus are subject to the terms of the InuvialuitInupiat Polar Bear Management Agreement. The agreement establishes quotas and 

recommendations concerning protection of denning females, family groups, and methods of 

harvest. In 1988, the Inuvialuit-Inupiat Council (Council) established a sustainable harvest quota 

of 80 bears for the SBS subpopulation. Since 1980, Native subsistence harvest of polar bears 

from the SBS has remained relatively consistent at an average of 36 per year.

Polar Bear Research- Currently, several ongoing polar bear research programs take place 

along the ACP. The goal of these programs is to gain information on the ecology and population 

dynamics of polar bears to help inform management decisions, especially in light of climate 

change. These activities may cause short-term adverse effects to individual polar bears targeted 

in survey and capture efforts and may incidentally disturb those nearby. In rare cases, research 

efforts may lead to injury or death of individual polar bears. Polar bear research is authorized 

through permits issued under the MMPA. These permits include estimates of the maximum 

number of bears likely to be harassed, subjected to biopsy darting, captured, etc., and include a 

condition that halts a study if a specified number of deaths, usually four to five, occurs during the 

life of the permit, which typically lasts five years. 

Incidental Take Regulations- Incidental Take Regulations (ITRs) for the Beaufort and 

Chukchi seas have been issued under the MMPA for oil and gas activities in and adjacent to the 

Beaufort and Chukchi seas since the early 1990s. Oil and gas companies can obtain LOAs under 
39

the ITRs, and these LOAs include reporting requirements. Under the Beaufort Sea ITRs, the oil 

and gas industry observed an average 306 polar bears annually (range 170 – 420 in 2006 – 2009). 

About 81% of observed bears showed no change in behavior, 4% fled from the source of 

disturbance, and the remaining 15% were subject to intentional hazing or other deterrence 

actions (described below). Because few oil and gas activities have occurred in the Chukchi Sea 

and adjacent area, few polar bear sightings have been reported by industry. The current Chukchi 

Sea ITRs expire in 2018, and the Service will likely re-issue these regulations. 

Deterrence Activities and Intentional Take Authorization- Polar bear deterrence activities 

associated with Industry and non-Industry activities take place in the Action Area. The Service 

previously consulted on a Final Rule regarding passive and preventative deterrence measures any 

person can use when working in polar bear habitat (75 FR 61631). These passive deterrence 

measures are expected to cause only short-term changes in behavior, such as bears departing the 

area. However, intentional take LOAs also allow trained individuals to use other mechanisms 

(e.g., non-lethal projectiles) to deter polar bears from human structures and activities. Industryrelated intentional take authorizations are described further in Section 6 (Effects of the Action) of 

this document. 

Climate Change- For a more complete discussion of effects of climate change in the 

arctic, see the section, Climate Change for spectacled eiders. In addition to the loss of sea ice, 

climate change may affect polar bears and their habitat in a variety of other ways. For example, 

increasing temperatures in the arctic are likely to result in increased frequency of rain-on-snow 

events, which will affect the insulation and structure of dens, potentially reducing the production 

of cubs (and ice seals, which are the primary prey of polar bears). However, uncertainty 

regarding the frequency of these events and their effects on productivity makes predicting their 

impact impossible. 

Summary 

The primary factor affecting the status of polar bears in the Action Area is the loss of sea ice. In 

addition, polar bears are taken by subsistence hunters annually, but this harvest is managed 

through international agreements to ensure sustainability. Other stressors are not thought to 

significantly affect polar bear populations; however, all stressors could become more significant 

in combination with expected loss of sea ice. While polar bears may be present in the Action 

Area, we expect them to occur infrequently, with the greatest likelihood of occurrence in the 

northern portions of Action Area, which is nearest to the coast. 

Polar Bear Critical Habitat 

In this section, we discuss the condition of the critical habitat in the Action Area and the factors 

responsible for that condition, and the value of the critical habitat in the Action Area for the 

conservation/recovery of the listed species. We consider the Action Area as the 4.0-km zone 

around the proposed GMT-2 drill site and all associated support facilities, and we continue to 

consider this zone to encompass all potential effects of the Proposed Action on threatened 

species and designated critical habitat. Only ~ 16% (~ 103 km2) of the Action Area is within the 

Terrestrial Denning Unit of polar bear critical habitat (Figure 8), and therefore we focus on the 

area of overlap between critical habitat and the Action Area and only mention the surrounding 

environment when it is relevant or provides useful context. Within critical habitat, the primary 

factors affecting the condition of critical habitat are climate change, which is affecting polar bear 
40

habitat broadly throughout the Arctic, and oil and gas development and the associated 

infrastructure and human activities, which is relevant to conditions within critical habitat at the 

local scale. 

The primary factor affecting the condition of polar bear habitat is the decline of sea ice due to 

changing climate, caused by increasing concentrations of greenhouse gasses. This generalization 

applies to the species’ habitat as a whole as well as to designated critical habitat, which occurs 

exclusively within Alaska. Most of the identified mechanisms by which climate change will 

affect polar bear habitat pertain to marine habitats, including sea ice and barrier islands, although 

the PBCMP (USFWS 2016) summarizes mechanisms by which denning (including in the 

terrestrial environment) could be affected by climate change. These include insufficient snowfall 

and/or increased warming or rainfall in winter, all of which could impact the fitness or survival 

of cubs by weakening the structural stability of dens or decreasing their insulation qualities (see 

Derocher et al. 2004). At this time, however, we have no reason to believe that climate change 

has affected the limited extent of suitable denning habitat within the Action Area. 

In addition to climate change, the condition of critical habitat within the Action Area has been 

affected by the presence of industrial oil development and the associated human activities. 

Within critical habitat in the Action Area, permanent human-built structures include Alpine, CD2, CD-5, and the permanent gravel road that connects GMT-1 with the Alpine oil development 

complex to the east and the village of Nuiqsut to the south (Figure 8).

When evaluating the baseline condition of PCEs in the Action Area, we considered actions that 

are ongoing or were consulted on previously. They include research on polar bears by USGS and 

the Service, summer activities and research in NPR-A, contaminated site remediation and 

restoration, and development projects in and adjacent to Nuiqsut. We have previously evaluated 

the effects of some oil and gas activities in the Action Area in consultations on other actions, 

such as the LOAs issued pursuant to these ITRs. All of these previously consulted upon activities 

had only short-term, localized effects to critical habitat, and none approach the level of adverse 

modification. 

Although previous actions within critical habitat in the Action Area have not physically altered 

the physical and biological features (PBFs) of terrestrial denning habitat, human activities related 

to the proposed action may conceivably disturb polar bears and thereby dissuade use of critical 

habitat. However, potential impacts of human activities to denning are limited by the following 

factors: 

ITRs that authorize (under the Marine Mammal Protection Act) the nonlethal, 

incidental, unintentional take of small numbers of polar bears during oil and gas 

industry activities in the Beaufort Sea and adjacent northern coast of Alaska include 

several requirements that serve to reduce potential disturbance of denning polar 

bears. LOAs, which are the applicant- and project-specific mechanism of 

authorizing incidental take under provisions of the ITRs, require: 

 Efforts to locate occupied polar bear dens within and near areas of 

operation, utilizing appropriate tools, such as forward-looking infrared 

(FLIR) imagery and/or polar bear scent-trained dogs. All observed or 
41

suspected polar bear dens must be reported to the Service prior to the 

initiation of activities. 

 Operators must observe a 1.6 km operational exclusion zone around all 

known polar bears during the denning season (November–April, or 

until the female and cubs leave the area). Should previously unknown 

occupied dens be discovered within 1.6 km of activities, work must 

cease and the Service contacted for guidance. The Service will 

evaluate these instances on a case-by-case basis to determine the 

appropriate action. Potential actions may range from cessation or 

modification of work to conducting additional monitoring, and the 

holder of the authorization must comply with any additional measures 

specified. 

Human activities at developed sites within the Action Area take place nearly continuously and 

throughout the year. Therefore, parturient female polar bears prospecting for potential denning 

sites in or near the Action Area, and that are sensitive to human presence and disturbance, would 

presumably be able to identify and avoid areas of disturbance. Nearby, particularly north of the 

Action Area, is extensive denning habitat that lacks industrial or village development and 

remains available for denning. 

Assessing the value of critical habitat within the Action Area to the conservation of polar bears is 

inherently subjective, but history of use of the area provides a reasonable index of value. 

Information on the history of denning nearby is available from several sources, including radio 

telemetry data, results from den searches, and observations reported by employees of the oil 

industry in the Alpine oil development complex in the Colville Delta and at CD-5 and GMT-1. 

The available information indicates that polar bears occur near the Action Area with some 

regularity (Figure 9). However, most recent sightings occurred north of the Action Area, closer 

to the Beaufort Sea coast, and most consist of sightings of polar bears, the majority of which 

likely correspond to transient individuals (males and non-denning females) and are not indicative 

of use of the area for denning. We are aware of no records of denning within critical habitat in 

the Action Area, although four dens have been found nearby, one within the Action Area in 

1917, another ~ 4 km outside the Action Area in 1949, a third ~ 2.8 km outside the Action Area 

in 1997, and the fourth ~ 2.1 km outside the Action Area in 2007 (Figure 9). A small portion of 

critical habitat within the Action Area contains the macrohabitat features suitable for denning, 

primarily ~ 3.0 km to the southwest of CD-5, along banks of the Ublutuoch River 

(Tinmiaqsiuġvik), and ~ 3.0 km to the east of CD-5, along banks of the Nigliaġvik Channel 

(Figure 8).

The value of critical habitat within the Action Area may change over time in response to climate 

change. Fischbach et al. (2007), examining distribution of maternal dens in the Beaufort Sea 

region, found that the proportion denning on pack ice (as opposed to onshore) decreased from 

62% from 1985 – 1994 to 37% in 1998 – 2004, and those denning on sea ice shifted from west to 

east. They attributed both trends to deteriorating sea ice conditions in the western Beaufort Sea 

(Fischbach et al. 2007). Derocher et al. (2004) reported that the number of dens on the 

southernmost islands in Svalbard strongly correlated with the date that sea ice arrived in autumn, 

and proposed that continued deterioration of sea ice may prevent pregnant females from 

accessing important denning habitat on islands or coasts, including on the North Slope of Alaska. 
42

Thus, the value (or use) of critical habitat inside the Action Area may increase as conditions 

elsewhere deteriorate, or the value may decrease as sea ice in the polar basin in early winter 

retreats northward, preventing pregnant females from accessing the Beaufort Sea coast in Alaska 

(Derocher et al. 2004). 

In summary, the value of polar bear critical habitat within the GMT-2 Action Area is limited by 

several factors, including the minimal degree of overlap between critical habitat and the Action 

Area (16% of the Action Area); the small proportion of the landscape within the area of overlap 

that contains the macrohabitat features of denning habitat; and information suggesting that use of 

the Action Area by polar bears, particularly for denning, is very minimal. Further, although there 

is significant human presence within critical habitat in the Action Area, the degree to which 

infrastructure and human activities intersect with potential denning habitat is minimal, and 

human activities there are highly managed to reduce disturbance of polar bears and protect an 

occupied den, should one occur there. We conclude that the value of critical habitat within the 

Action Area is minimal, and that human presence and activities within the area of overlap have 

affected, although not substantially, the overall condition of critical habitat within the Action 

Area. 

EFFECTS OF THE ACTION 

Regulations implementing the ESA (50 CFR §402.02) define the “Effects of the Action” as the 

direct and indirect effects of an action on the species or critical habitat, together with the effects 

of other activities that are interrelated or interdependent with that action. This section of the BO 

analyzes direct effects, indirect effects, and interdependent and interrelated effects of the 

proposed Action on listed species and critical habitat. 

Spectacled Eiders 

This section includes an analysis of the direct and indirect effects of the proposed action on 

spectacled eiders and/or habitat and its interrelated and interdependent activities. We evaluated 

the following possible mechanisms by which GMT-2 could potentially affect spectacled eiders: 

 Habitat loss with associated disturbance 

 Collisions with structures 

 Increased predator populations 

 Exposure to spills and contaminants 

 Increased subsistence activities 
43

Figure 9. Potential terrestrial polar bear denning microhabitat features (redlined) within designated critical habitat (shaded area) 

contained by the GMT-2 Action Area. From BLM (2018a). 
44

Figure 10. Polar bear den locations, and sightings within and near the GMT-2 Action Area. From BLM (2018a).
45

Habitat loss with associated disturbance 

The construction and operation of oil and gas facilities at GMT-2 could affect the reproduction 

of spectacled eiders directly through the alteration of habitat, which could render it unsuitable for 

nesting or brood rearing, and indirectly if disturbance from human presence and activities at 

facilities prevents nesting or affects breeding success in nearby habitat. We evaluate the 

potential for alteration of habitat and disturbance to affect spectacled eiders, below. 

Gravel extraction and fill - The BLM estimated that permanent gravel pads and roads 

would occupy 0.32 km2of area in the Action Area, and we conclude the placement of gravel fill 

will permanently render this habitat unsuitable for nesting and brood rearing by spectacled 

eiders. We estimate the magnitude of this effect below. 

Ice roads and pads- We would not anticipate significant long-term habitat loss from ice 

road or snow trail operations associated with winter gravel extraction and transport. Research 

indicates damage from ice roads occurs on higher, drier sites with little or no damage in wet or 

moist tundra areas (Pullman et al. 2003) when ice roads are used. Jorgenson (1999) found 

impacts were limited to isolated patches of scuffed high microsites and crushed tussocks. 

Similarly, Yokel and VerHoef (2014), found disturbance from seismic and ice road activity was 

greatest in drier, shrubby habitat than in moist habitat. McKendrick (2003) studied several 

riparian willow areas and found although some branches were damaged, the affected plants 

survived. Because spectacled eiders prefer to nest in low moist tundra areas (Anderson and 

Cooper 1994, Anderson et al. 2009), we conclude the limited damage in higher drier tundra 

habitat from ice roads would not adversely affect spectacled eiders. 

Disturbance- We anticipate that disturbance of spectacled eiders would occur within a 

“zone of influence” surrounding new development from on-pad activities and traffic on roads. 

Three mechanisms through which disturbance could affect breeding potential or success are: 

1. Flushing hens from nests, exposing eggs or small young to inclement weather and 

predators, or causing nest abandonment; 

2. Disturbing hens with ducklings, potentially causing broods to fragment and 

decreasing survival of ducklings; and 

3. Displacing adults and/or broods from preferred habitats during pre-nesting, nesting, 

brood rearing, and migration. 

Empirical support documenting the indirect effects of disturbance on spectacled eider breeding 

performance is limited, but some information exists. In the Alpine development complex, the 

locations of pre-nesting spectacled eiders within oil fields did not differ before and after 

construction (Johnson et al. 2006), and pre-nesting spectacled eiders (observed in groups or 

pairs) averaged 239 m from structures whereas nests averaged 442 m from structures (Anderson 

et al. 2007). This suggests that pre-nesting pairs were not particularly sensitive to nearby 

infrastructure, whereas hens appeared to avoid nearby infrastructure when identifying nest sites 

and laying eggs. Therefore, habitat near facilities may have lower nesting value than habitat 

farther from sources of disturbance. Female waterfowl may also damage eggs when they are 
46

flushed from nests (Major 1989), and may abandon nests entirely, particularly if disturbance 

occurs early in the incubation period (Livezy 1980, Götmark and Ählund 1984). However, the 

effects of disturbance and displacement would likely vary with the number, duration, frequency, 

intensity and timing of activities, and these factors would vary among facilities and the activities 

associated with them. Additionally, individual eiders would likely respond to disturbance 

differently, depending on individual tolerance and previous experience. Based on this extremely 

cursory review of species- and location-specific information, and observations from other 

waterfowl species, we can identify processes by which the distribution or success of nests could 

be affected by industrial activities. However, estimating impacts is complicated by uncertainty 

regarding the actual magnitude of impact, the potential for habituation over time, and whether 

spectacled eiders displaced from nesting habitat by disturbance would forego nesting, nest 

elsewhere with lower success, or merely move elsewhere with no change in breeding 

performance.

Based on the concepts and mechanisms described above, disturbance from aircraft could 

potentially adversely impact spectacled eiders. The project description predicts that 125 to 145 

fixed-wing aircraft flights (above current baseline levels) to and from the Alpine airstrip would 

be needed during construction of GMT-2, and we assume additional fixed-wing aircraft traffic 

will be needed to support production and maintenance into the future. Potential impacts of 

aircraft disturbance to nesting spectacled eiders are poorly understood but observations in the 

Kuparuk Oilfield indicate that spectacled eiders generally respond similarly to other waterfowl 

(ABR, unpublished), and spectacled eiders occasionally nest near the Deadhorse and Utqiaġvik 

airports, indicating at least some individuals tolerate or become habituated to aircraft traffic at 

established airstrips. As with other forms of disturbance, tolerance likely varies among 

individuals, and some individuals could be disturbed or displaced with unknown physiological 

and reproductive consequences. However, we expect impacts to be minimal, as the ongoing 

regular air traffic at Alpine has presumably allowed less-sensitive individuals to habituate and 

more-sensitive individuals to nest farther from the airstrip to create separation from disturbance. 

Therefore, we conclude increased air traffic at Alpine needed to support GMT-2 will have 

insignificant effects to spectacled eiders. 

Helicopters would also be used in support of GMT-2, and the project description includes an 

estimated ~400 takeoffs/landings per year during construction, declining to ~90 flights/year after 

construction ends. Unlike fixed-wing aircraft, Industry helicopter operations often occur off 

established infrastructure on undeveloped tundra. 

Helicopter traffic in NPR-A is substantial and increasing each year, with >10,000 

takeoff/landings in 2018. Given 1) the volume of air traffic, 2) the potential for impacts to listed 

species, 3) the difficulty in ascribing flights to specific projects (e.g., GMT-2), and 4) the 

difficulty of accurately predicting aircraft activity years in advance; we now separately conduct 

section 7 consultation on helicopter traffic in NPR-A each year with the BLM. The flights 

associated with GMT-2 are not additive to, but are a subset of, the flights being considered in 

this “annual summer programmatic” consultation. This approach allows annual estimation of 

helicopter traffic, which has increased substantially in recent years, and has resulted in 

improvements in categorizing activities and estimating impacts. Therefore, we will address 

helicopter traffic associated with individual oil and gas development projects, including GMT-2, 
47

in the summer programmatic consultation, and these effects are not considered further in this 

consultation. 

The greatest potential for human presence and activities to disturb spectacled eiders is within the 

zone of influence immediately adjacent to permanent facilities in nesting and brood-rearing 

habitat. For example, construction of gravel pads and roads, production facilities, pipelines, and 

human activities associated with operation and maintenance of this infrastructure are all potential 

sources of disturbance. However, because gravel mining, material hauling, pad, road, and 

pipeline construction, and pipeline maintenance would occur during winter, when spectacled 

eiders are not present, disturbance to nesting eiders from these sources would be discountable. 

Nonetheless, on-going disturbance associated with human activities at GMT-2 infrastructure 

would occur year-round, including during breeding, nesting, and brood-rearing periods for 

spectacled eiders. 

Estimate of effects- To estimate the number of spectacled eider nests that could be 

affected by habitat loss and disturbance, we multiplied the area over which impacts could occur 

by the estimated density of spectacled eiders within that area. We considered the affected area to 

include permanent gravel fill (0.32 km2; BLM 2018b) plus an adjacent zone of influence in 

which human activities at nearby facilities could plausibly prevent nesting or reduce breeding 

success. We assumed that disturbance could affect the likelihood of nesting or nesting success 

within 200 m (~650 ft) of facilities (pads and roads) where human activities will take place 

during the nesting season (8.03 km2; BLM 2018b). Thus, we estimated the total affected area to 

be 8.35 km2.

We used observations from a systematic aerial survey of Alaska’s Arctic Coastal Plain (USFWS 

2015b) to characterize spectacled eider density within the affected area. Because these aerial 

surveys provide an index of the population, we made adjustments to convert the index to a 

density estimate. First, because the index of density varies within the affected area, we 

approximated mean density by weighting the values proportionately, deriving an average 

estimate for the affected area of 0.04 “indicated” spectacled eiders1

/km2. Then, we adjusted for 

imperfect detection by assuming ~75% of spectacled eiders are seen during aerial surveys2, 

which converted the population index to an estimate of density of 0.53 spectacled eiders/ km2. 

Last, assuming one potential nest for every two adults, we divided the estimate of spectacled 

eider density by two to convert the estimate to the number of pairs or nests/ km2. Applying this 

process, we estimate an average of 0.027 pairs or nests/km2per year in the affected area. 

Multiplying the affected area (8.35 km2) by the estimated density of pairs or nests (0.027/km2), 

we estimate the proposed action could result in a potential loss of production of 0.23 nests/year, 

totaling ~7.2 nests (rounded to 7) across the 32-year life of the project. Admittedly, this estimate 

is extremely imprecise, is predicated upon several untested assumptions, and is subject to several 

 

1

In these aerial survey indices, “Indicated birds” represents the number of singles*2 + the number of pairs*2 + the 

number of flocked individuals (Stehn et al 2013) and detection is assumed to be 1.0. 

2

 A detection rate of 75% is an approximate average of three independent rates for single, paired, and flocked 

spectacled eiders, which were 0.71, 0.78 for pairs, and 0.81 for small flocks (Wilson et al. 2017; J. Fischer, pers. 

comm.). 
48

unquantifiable biases3. Nonetheless, we believe it is consistent with the (low) density of 

spectacled eiders in the Action Area and reasonably approximates potential loss of production 

from habitat loss and disturbance during nesting. 

Summary- We conclude that habitat loss would result from permanent gravel fill for the 

construction of pads and roads, and indirect effects caused by disturbance and displacement 

could result when human activities occur during the breeding season. Impacts of ice pad and ice 

road construction, and the incremental increase to fixed-wing aircraft traffic at the Alpine airstrip 

to support GMT-2, would have insignificant impacts to spectacled eider reproduction. While 

recognizing potential impacts of helicopter traffic associated with GMT-2, those impacts are 

addressed elsewhere in annual consultation with BLM. Using the process described above, we 

roughly estimate that the Proposed Action will result in the loss of production of ~7 spectacled 

eider nests across the 32-year life of the project. Because the most recent population estimate for 

North Slope-breeding spectacled eiders is 14,814 (13,501–16,128, 90% CI; Stehn et al. 2013), 

we would not anticipate population level effects from the loss of ~7 nests over the next 32 years. 

Collisions with structures 

Migratory birds are killed in significant numbers by collisions with human-built structures, 

including communication towers, buildings (particularly those with windows or glass exteriors), 

power lines, marine vessels, vehicles, wind turbines, and others (APLIC 2012, Manville 2009, 

Loss 2014). Structures associated with the oil and gas industry on Alaska’s North Slope that 

pose a collision risk for birds include offshore and onshore buildings, drill rigs, flare stacks, 

power lines, communication towers, marine vessels transporting materials, and possibly pipe 

racks. Lethal collisions involving spectacled eiders or other closely-related species (which 

presumably, by virtue of their greater numbers, serve as indicators of risk to less-numerous 

species such as spectacled and Steller’s eiders) have occurred on the North Slope at buildings, 

power lines, and possibly other structures, although several biases (e.g., scavengers removing 

carcasses before they are found) likely cause underestimation of the frequency of collisions and 

the types of structures at which they occur. 

Spectacled eiders are potentially at risk of encountering and colliding with human-built 

structures on the North Slope: 1) during spring migration, as they move west to east, and disperse 

to prospect for and colonize suitable breeding habitat; 2) during the breeding season, as they 

move locally within nesting and brood-rearing habitat; and 3) after breeding, as a succession of 

males, unsuccessful hens, and successful hens with broods, leave the coastal plain, returning to 

the marine environment for the non-breeding season. Darkness at night appears to increase 

collision risk for species that fly or migrate at night (Weir 1976), presumably by making unlit 

objects such as power lines less visible, and by creating a need for artificial lighting of some 

structures, which compounds susceptibility by attracting or disorienting flying birds (Reed et al. 

1985, Russell 2005, Manville 2009). For spectacled eiders, spring migration in May and June, 

and local movements during the June-July breeding season, take place during the arctic summer 

with continuous daylight. In late summer and fall, however, when successfully-nesting hens and 

 

3

 Several assumptions are inherent in this process, each of which we believe make this a conservative, or moreprotective, estimate. These are that all pairs within the zone of influence will fail to produce young (i.e., no pairs 

within the zone of influence will nest successfully, and none will move elsewhere to avoid disturbance and then nest 

successfully) and that all failures can be ascribed to the effects of the action. 
49

broods migrate from the coastal plain, collision risk escalates with returning twilight and 

darkness and the accompanying increase in artificially-lit structures. 

When considering collision risk to spectacled eiders migrating on the North Slope, two relevant 

factors warrant mention. First, although some migration may take place overland on the coastal 

plain, available information suggests that most migrants move along the Beaufort Sea coast or 

over offshore waters. In spring, as eiders, including spectacled eiders, move east into the region, 

they are thought to follow open water leads in pack ice (Woodby and Divoky 1982, Johnson and 

Richardson 1982, Oppel et al. 2009, M. Sexson, USGS, pers. comm.). During post-breeding 

migration in summer and fall, satellite telemetry studies on the eastern ACP indicated male 

spectacled eiders departed early in summer and generally remained close to shore, sometimes 

crossing overland, whereas most females, which departed later, moved north into the Beaufort 

Sea before moving westward (Petersen et al 1999; TERA 2002). Thus, it is reasonable to 

conclude that most spectacled eider migration occurs along the coast and offshore, taking place 

several miles north of the structures at GMT-2. Second, during spring spectacled eiders migrate 

to their breeding areas on the North Slope from the west, progressing eastward from the Bering, 

Chukchi, and western Beaufort seas, and in fall, they return to the west. Telemetry data, 

although limited, do not show individuals moving farther east after nesting, and prior to returning 

to the west where they molt and winter (Petersen et al 1999; TERA 2002; Sexson 2015). 

Therefore, presumably the only spectacled eiders that move as far east as GMT-2 are those that 

nest near or to the east of GMT-2, which aerial surveys show includes only ~13% of the 

population that nests on the North Slope (USFWS unpubl. data). 

Therefore, to evaluate collision risk to spectacled eiders posed by GMT-2 structures, we 

considered the generalizations drawn above, documented instances of collisions of spectacled 

eiders and other sea ducks on the North Slope, the project description, and the BMPs that serve 

to reduce risk. In addition to the drilling rig and communication tower, up to 48 permanent well 

houses on the GMT-2 pad would also pose collision risk. Several factors will serve to ameliorate 

collision risk, however. As noted above, all structures at GMT-2 would be well inland (> 27 km) 

from the migratory routes used by most spectacled eiders. Also, only ~13% of spectacled eiders 

nesting on the North Slope are likely to range as far east as the Action Area, significantly 

reducing exposure. The drilling rig would be present for 7.5 years (2022-2029) but would then 

be removed. Furthermore, the communication tower would not be supported by guy wires, 

substantially reducing the profile and associated collision risk. BMP E10 requires that lights on 

tall structures to be shielded and directed downward, reducing potential attraction and 

disorientation resulting in collision from outward radiating light. Very importantly, no overhead 

power lines are proposed, completely alleviating one considerable form of risk. Finally, because 

spectacled eiders occur at low density in the Action Area, the risk of locally-nesting or -fledging 

individuals encountering structures at GMT-2 is very minimal. Collectively, we believe these 

factors significantly reduce collision risk at GMT-2. Although we have no means to objectively 

estimate the number of spectacled eiders that would collide with structures at GMT-2, based on 

our subjective assessment we conclude that between 0 and 5 spectacled eiders would be injured 

or killed over the 32-year life of the project. 
50

Increased predator populations 

As discussed in the Environmental Baseline for spectacled eiders, abundance of predators and 

scavengers has increased near industrial infrastructure on the ACP. In particular, ravens have 

expanded their breeding range northward onto the ACP by using human-built structures for 

nesting and perching. Therefore, as the number of structures and anthropogenic attractants 

associated with development increase, the distribution and survival of predators may change, 

with potential individual- or population-level impacts to nesting spectacled eiders. 

We expect structures associated with GMT-2 would increase the number of potential nesting and 

perching sites for ravens, and possible access to anthropogenic food sources may also attract 

predators to the action area. However, BMP E-9 prohibits feeding of wildlife and requires CPAI 

to utilize the best available technology to prevent facilities from providing nesting, denning, or 

shelter sites for ravens, raptors, or foxes. Further, BMP E-9 requires monitoring and annual 

reporting, which will allow managers to assess whether ravens and foxes nest or den in 

association with GMT-2 infrastructure. Therefore, based on results of monitoring efforts, 

management actions specific to GMT-2 or the GMT/Alpine industrial complex as a whole can be 

implemented as needed. 

Based upon the low density of spectacled eiders in the Action Area, and the requirements of 

BMP E-9 and our ability to track and address predator response to GMT-2 as needed, we 

anticipate that impacts to predator populations caused by GMT2 will not adversely affect 

spectacled eiders. 

Exposure to spills and contaminants 

We evaluated the effects of oil and other toxic substance spills on spectacled eiders in the IAP 

BO (USFWS 2013, pp. 77, 98) and concluded that adverse effects to spectacled eiders are 

unlikely to occur due to the low probability of large spills occurring and because spectacled 

eiders are unlikely to contact small spills. BMPs, lease stipulations, and development setbacks 

from the coast reduce the likelihood of a significant quantity of oil spilled in NPR-A reaching 

concentrations of spectacled eiders in marine waters. Because the deviations the BLM may grant 

could affect potential effects of spills to aquatic habitats, we discuss their potential impacts in 

section titled: 6.1.3 Effects of Best Management Practices and Lease Stipulations. 

Increased subsistence activities 

The harvest of spectacled eiders for subsistence or sport purposes is prohibited, although harvest 

survey date indicate that some harvest likely continues to occur. As a result, the potential 

impacts of subsistence harvest is consulted upon annually in the Intra-Service Biological Opinion 

for Hunting Regulations for the Spring/Summer Harvest, and allows the representation and 

participation of subsistence users and for integration of local, regional, and statewide 

perspectives on practices and impacts. We acknowledge that allowing use of the continuallyexpanding infrastructure associated with the Alpine and GMT industrial complex to access 

subsistence areas could conceivably result in an increase in impacts to spectacled eiders. 

Nonetheless, we believe this possibility is disountable, particularly considering the low density 

of spectacled eiders in the Action Area. Furthermore, we believe evaluating and addressing 

potential effects of subsistence practices are better accomplished in consultation on the 

regulations for subsistence harvest. Therefore, the small potential for impacts is not further 

addressed in this BO. 
51

Effects of Best Management Practices and Lease Stipulations 

GMT-2 is subject to the lease stipulations set forth in the 2008 IAP ROD, and subject to BMPs 

set forth in the 2013 IAP ROD. As discussed in the IAP BO (USFWS 2013), the BLM would 

require adherence to almost all lease stipulations and BMPs, several of which benefit spectacled 

eiders. However, in order for the Proposed Action to be developed, the BLM would have to grant 

deviations to stipulation E-2 and BMP E-7(c). BMP E-7(c) pertains to spatial separation between 

roads and pipelines, and the requested deviation would not impact spectacled eiders. Stipulation 

E-2 pertains to the spatial separation between permanent oil and gas facilities (including 

pipelines) and fish-bearing water bodies and aquatic habitats. A deviation to stipulation E-2 

could slightly increase the risk of oil reaching the marine environment, should a large spill occur. 

In spring and autumn, spectacled eiders congregate in ice-free marine waters such as those 

offshore of river deltas, and an increased risk of oil reaching the marine environment could 

increase risk to spectacled eiders. 

Based on the large spill scenario analysis in the IAP/EIS (BLM 2012), large oil spills are 

unlikely to occur for GMT-2. Oil spills from pipelines are not likely to be large or spread widely 

given spill prevention measures in the Oil Discharge Prevention and Contingency Plans and Spill 

Prevention Control and Countermeasures Plans. Prevention measures include hydrostatic testing 

prior to operation, shut-off valves, pressure monitoring, regular inspection and maintenance with 

in-line pigs, FLIR monitoring, and emergency response procedures (including booms to protect 

streams and drainages). Because of the myriad prevention measures used, large spills occur so 

infrequently (once in 39 years of North Slope operations) that they are not reasonably certain to 

occur. Thus, the low probability of a large oil spill occurring from a pipeline makes it highly 

unlikely spectacled eiders would be affected by granting of the deviation to stipulation E-2.

Polar Bears 

Based on the GMT-2 Project, we determined that the following factors might cause adverse 

effects to polar bears: 

 Oil spills 

 Disturbance 

 Human-polar bear interactions 

In the sections below, we describe how these factors could affect polar bears and estimate the 

number of polar bears potentially affected by them.

Oil Spills 

In the IAP BO (USFWS 2013, p. 99), we concluded that given the low probability of a large oil 

spill combined with the infrequent occurrences of polar bears in NPR-A, it is highly unlikely that 

polar bears would be affected by oil spills in NPR-A should spills occur. Likewise, we do not 

expect polar bears would be affected by spills within the GMT-2 Action Area should spills 

occur. We continue the discussion of the impacts of oil spills as it pertains to the proposed 

deviations to BMPs in section 6.3.4 Effects of Best Management Practices and Lease 

Stipulations. 

Disturbance 

Several activities that would occur at GMT-2 could disturb polar bears. Possible sources of 

disturbance could include aircraft, drilling activities, activity at facilities, pipeline construction 
52

and maintenance, and gravel and ice road construction and associated vehicle traffic. These 

disturbances could affect denning and non-denning polar bears.

Denning Bears- Few if any polar bear dens are likely to be affected by GMT-2 

construction and operation activities because the Action Area is inland from the coast where 

polar bears occur infrequently, and because gravel and ice roads cross relatively small areas of 

suitable habitat for denning. Based on historical denning information in the Action Area and 

along the ACP, polar bears are unlikely to den in the GMT-2 Action Area. Durner et al. (2009, p. 

5) determined 95 percent of all historical confirmed and probable dens have occurred within 4.5 

km (2.8 mi) of the Beaufort Sea coast in the region of the Action Area. Necessary topographic, 

macrohabitat, and microhabitat features that are essential for polar bear denning include steep, 

stable slopes (range 15.5–50.0°), with heights ranging from 1.3 to 34 m (4.3 to 111.6 ft.), and 

with water or relatively level ground below the slope and relatively flat terrain above the slope. 

The remaining 5 percent of polar bear dens may be located farther from the coast where 

topographic, macrohabitat, and microhabitat features exist, but the probability of a den decreases 

with distance from the coast. The GMT-2 Action Area is largely outside 4.5 km (2.8 mi), and all 

new road and pad constructions are > 14 km (9 mi) from the coast. 

The highest potential for disturbance to denning polar bears in the GMT-2 Action Area would be 

during winter construction seasons 2018/2019, 2019/2020 and 2020/2021 when noise and 

activity levels would be greatest. During operations, co-occurrence of infrastructure and suitable 

denning habitat within critical habitat (16% of GMT-2, which has higher probability of den sites) 

has been assessed at 3.5 ha for GMT-1(ABR 2014), and is essentially the same for GMT-2.

While no new co-occurrence of infrastructure will occur, GMT-2 construction and operations 

will add to traffic along this route and extend the period of high activity and disturbance until the 

operation phase. A maternal polar bear searching for a den location near the road will be subject 

to continuous traffic along her route, and will either tolerate the noise, or move to a quieter 

location prior to denning. The Service finds it unlikely that disturbance from the GMT-2 Action 

Area would impact denning polar bear because: based on historical denning information in the 

Action Area and along the ACP; polar bears are unlikely to den in the GMT-2 Action Area; and 

maternal polar bears would have to tolerate the construction and operation activities of the GMT2 Action Area while passing through to den in suitable habitat. As a safeguard, the BLM and 

Service will require CPAI to adhere to minimization measures as described in the IAP BO 

(USFWS 2013, Appendix A) and explained in sections captioned 6.3.4 Effects of Best 

Management Practices and Lease Stipulations and 6.3.5 Minimization measures pursuant to the 

Marine Mammal Protection Act below. 

Aircraft overflights have the potential to disturb denning polar bears, but typically these events 

are occasional and short in duration. Amstrup (1993) studied the response of denning bears to 

research aircraft flying 50 to 500 m above the ground and recorded 40 cases of potential 

disruption of denning by research aircraft (44 dens were located in this study). Two bears left 

their dens temporarily, but disturbance did not appear to affect cub survival (Amstrup 1993). 

Thus, flights over dens are not expected to cause disturbance to the degree that reproductive 

performance is likely to be affected. Additionally, the chance of aircraft flying directly over a 

polar bear den is low because dens occur at very low density across the landscape. Further, 

aircraft associated with GMT-2 will likely fly at elevations higher than those evaluated in the 

Amstrup (1993) study, as minimum flight elevations over polar bears or areas of concern and 
53

flight restrictions around known polar bear dens will be required in LOAs/minimization 

measures (e.g., BMP F), as appropriate, to reduce the likelihood that bears are disturbed by 

aircraft. Aircraft overflights during the denning season are rare, and the chance of encountering 

denning bears is extremely low, but if this does occur we expect the effect of aerial disturbance 

on denning bears to be minimal. 

Table 2. Winter helicopter Flights in the Action Area (5% of all helicopter flights). 

Project Phase Winter Helicopter Flights within GMT-2 Action 

Area

Construction (First Year) 20

Construction (Second Year) 20

Drilling and Operations (annual no. of flights) 5

Drilling and Operations (total flights for the 30 year phase) 150

Project Life Total Flights (32 years) 195

Non-denning Bears- Transient (non-denning) polar bears tend to move along the coast 

during the late summer–fall open water season and congregate on barrier islands where whale 

carcasses or other food is available (Miller et al. 2006, Schliebe et al. 2008). It is unlikely that 

polar bears would be encountered within the GMT-2 Action Area with any frequency given its 

inland location. To illustrate, seven polar bear sightings have been recorded around Alpine CD-1 

and CD-2 (approximately one third the distance from the coast of GMT-2) between 2005 and 

2016, 7 sightings were recorded near CD-3, and 3 sightings have been recorded at CD-5 (BLM 

2018a). Thus, we expect very few polar bears would enter the GMT-2 Action Area given the 

distance from the coast. However, if polar bears pass through the Action Area, human-polar bear 

interactions possibly leading to deterrence actions may occur. We expect the likelihood of 

interactions to increase with decreasing distance from the coast. In the IAP BO (USFWS 2013, 

pp. 82-89) we estimated that about 15% of polar bear interactions in NPR-A would result in 

deterrence actions and that in most cases, the actions would cause only minor, temporary 

behavioral changes (e.g., causing the bear to flee). We describe these potential deterrence actions 

below. 

Human-Polar Bear Interactions 

Information regarding human-polar bear interactions occurring at oil and gas developments 

across the North Slope indicates that the Proposed Action could result in deterrence actions. 

CPAI maintains records of polar bear observations throughout its North Slope operations. Most 

records (100 of 127, or 79%) are from Kuparuk. Small numbers are from the Colville River delta 

(19 records, 15%) and NE NPR-A (3 records, 2%) between 1995 and 2016 (Appendix D: BLM 

2018a) and most of these are within 8 km (5 miles) of the coast. The 22 records from the Colville 

and NE NPR-A comprise 28 individuals (excluding identifiable multiple observations of the 

same individuals); records of polar bear sightings by CPAI and others in the GMT-2 area are 

shown in Figure 5 of BLM 2018a. Of these 22 encounters, 4 (18%) involved hazing, deliberate 

efforts to persuade bears to move away from people or facilities. In each case a single bear was 

involved, for a total of 4 polar bears hazed. In most cases, hazing involved more than 1 type of 

deterrent, therefore the sum of all deterrent types exceeded the total number of hazings: 4 

hazings involved vehicles, 3 involved noise (horns, sirens, etc.), 3 involved spotlights, and 3 

involved firearms (all with non-lethal rounds, typically cracker shells or similar noise-making 
54

rounds). None of the deterrence actions for CPAI resulted in a severe injury or death of a polar 

bear. 

Thus, we expect that most deterrence actions would not involve the use of projectiles and 

therefore are likely to cause only minor, temporary behavioral changes (e.g., forcing a bear to 

leave the area). Potential effects of deterrence actions to individual bears likely vary with a 

bear’s physiological and reproductive condition, and the number, type, and duration of 

deterrence actions used. In the unlikely event that bears are deterred using more aggressive 

methods (e.g., projectiles such as bean bags and rubber bullets), those bears may be injured (e.g., 

sustain pain and bruising). 

Very rarely, these deterrence actions may be fatal if the projectiles are used incorrectly4. In the 

IAP BO (USFWS 2013, p. 89), we estimated that up to five deterrence actions using projectiles 

may occur annually as a result of the Proposed Action, with no more than five fatalities to polar 

bears occurring during the 50-year life of the full development scenario. However, predicting the 

number of deterrence actions for individual projects such as GMT-2 is difficult. Regardless, 

given the distance from the coast, we expect the use of projectiles would occur fewer than once 

annually, with up to two injuries and no fatalities over the life of the project. 

Effects of Best Management Practices and Stipulations 

GMT-2 is subject to the lease stipulations set forth in the 2008 IAP ROD, and subject to BMPs 

set forth in the 2013 IAP ROD. As discussed in the IAP BO (USFWS 2013), the BLM would 

require adherence to almost all of the IAP ROD’s (BLM 2013) BMPs and lease stipulations. In 

order for the project to be implemented, the BLM would have to grant deviations to stipulation 

E-2 and BMP E-7(c). While granting a deviation to E-7(c) would not impact polar bears, 

deviation to E-2 could slightly increase the risk of oil reaching the marine environment, should a 

large spill occur. Polar bears contacting spilled oil could suffer injuries or die. 

Based on the large spill scenario analysis in the IAP/EIS (BLM 2012), large oil spills are 

unlikely to occur for GMT-2. Oil spills from pipelines are not likely to be large or spread widely 

given spill prevention measures in the Oil Discharge Prevention and Contingency Plans and Spill 

Prevention Control and Countermeasures Plans. Prevention measures include hydrostatic testing 

prior to operation, shut-off valves, pressure monitoring, regular inspection and maintenance with 

in-line pigs, FLIR monitoring, and emergency response procedures (including booms to protect 

streams and drainages). Large spills occur so infrequently (once in 39 years of North Slope 

operations) that they are not reasonably certain to occur. Thus, the low probability of a large oil 

spill occurring from a pipeline makes it highly unlikely polar bears would be affected by the 

deviations. 

Minimization measures pursuant to the Marine Mammal Protection Act 

The Service has issued ITRs for the Beaufort Sea and adjacent areas under the MMPA for oil 

and gas activities since the early 1990s. Oil and gas companies can obtain LOAs under the ITRs, 

and these LOAs require adherence to an approved polar bear interaction plan. CPAI has obtained 

an LOA pursuant to the Beaufort Sea ITRs that authorizes incidental take of polar bears for its 

 

4 One deterrence action in 2011 associated with BP Exploration, Alaska resulted in an unintended 

fatality of a polar bear.
55

oilfields and activities on the North Slope. The Service also issues LOAs for intentional take of 

polar bears that authorize specific methods of deterring polar bears, and like LOAs for incidental 

take, intentional take LOAs require adherence to an approved interaction plan. CPAI has 

obtained LOAs for their various oilfield projects to date. These LOAs will expire before the end 

of the development lifespan of this project, but we assume that CPAI will obtain new LOAs in 

the future. Based on the record of the oil and gas industry as a whole and CPAI in particular, we 

expect that potential impacts of GMT-2 on polar bears will be minimized through adherence to 

their approved interaction plan.

Polar Bear Critical Habitat 

We identify the following factors that could potentially cause adverse effects to polar bear 

critical habitat: 

Alteration of the physical and biological features (BPFs) of critical habitat, resulting from the 

construction of permanent facilities and gravel roads; 

 Oil spills; 

 Disturbance; and 

 Human-polar bear interactions. 

We identify no interrelated or interdependent actions that require additional consideration. 

Alteration of the Physical or Biological Features of Critical Habitat 

Permanent alteration of the landscape, which could potentially affect the BPFs of critical habitat, 

has been assessed for the GMT-1 drill site and the associated permanent gravel road. The GMT-2 

drill site is not within designated critical habitat or habitat containing the macrohabitat features 

associated with denning habitat, and therefore will not alter the PBFs. Infrastructure associated 

with GMT-2 intersects with suitable denning habitat where the gravel road connecting GMT-1 to 

CD-5 (and the larger Alpine development complex) crosses the Ublutuoch River just inside the 

boundary of designated critical habitat. However, the road crosses the Ublutuoch River on a 

raised bridge, and the macrohabitat features that define potential denning habitat remain 

unchanged. Considering these factors, we conclude that GMT-2 and the associated infrastructure 

will not affect the PBFs of polar bear critical habitat. 

Oil Spills 

The BLM, in managing the NPR-A as a whole, periodically revises their Integrated Activity 

Plans (IAPs) to reflect evolving management priorities, changes in industry interest and resource 

assessments, advances in technology, and other factors. The IAPs contain reasonable 

development scenarios for the reserve as a whole, and entail large scale impact evaluations that 

include assessment of the likelihood of spills of varying sizes occurring, and the likelihood that 

spills, if they occur, reach lakes, rivers, or the marine environment. We consult with the BLM on 

their IAPs, allowing periodic impact evaluations that reflect updated development scenarios and 

the corresponding lease stipulations and Best Management Practices, which are designed to 

minimize impacts. In 2013, we consulted with the BLM on their then-current IAP (USFWS 

2013, p. 99) and concluded that given the low probability of a large oil spill combined with the 

infrequent occurrences of polar bears in NPR-A, it is highly unlikely that polar bears would be 

affected by oil spills in NPR-A should spills occur. Further, we concluded that spills of oil or 
56

other contaminants could cause minor and temporary effects to polar bear critical habitat, but 

effects would be limited to localized areas and would not prevent polar bears from deriving the 

intended conservation benefit from designated critical habitat as a whole (USFWS 2013, p. 100). 

We believe this conclusion remains valid. 

More specifically to GMT-2, based on the estimates of likelihood of large spills provided in the 

DSEIS (BLM 2018b), spills large enough to affect the BPFs of critical habitat are unlikely to 

result from GMT-2. Further, the limited spatial overlap between suitable denning habitat within 

critical habitat in the Action Area, and infrastructure from which oil could conceivably be 

spilled, makes it even more unlikely that oil sufficient to affect the BPFs of critical habitat would 

be spilled. Considering the low likelihood of large spills occurring within the Action Area, and 

the likelihood that suitable denning habitat would be affected if a large spill were to occur, we 

conclude that oil spills from GMT-2 are extremely unlikely to affect the value of terrestrial 

denning habitat to polar bears. 

Disturbance 

Several activities that would occur at GMT-2 could disturb polar bears, and disturbance is 

relevant if it prevents polar bears from accessing or using critical habitat. Potential sources of 

disturbance could include drilling activities, activity at facilities, pipeline construction and 

maintenance, gravel and ice road construction and associated vehicle traffic, and air traffic. 

Disturbance could conceivably affect the fecundity of females that are disturbed while searching 

for a den site or could potentially affect the outcome of a den established near a source of 

disturbance. 

The effect of disturbance at established dens diminishes with distance and is thought to be 

negligible beyond 1.6 km (76 FR 47010). Therefore, we assume the potential for disturbance at 

dens is limited to locations where infrastructure and human activity would occur within 1.6 km 

of suitable denning habitat. The GMT-2 drill site is not within designated critical habitat or near 

suitable denning habitat, so the potential for disturbance at dens is limited to areas where ice 

roads, gravel roads, and pipelines will occur within 1.6 km of suitable denning habitat. During 

construction, the ice road passing through critical habitat is aligned closely to the permanent 

road; therefore, any added disturbance from the ice road is negligible above the estimated 3.5 ha 

for the permanent road. Review of historical information suggests an absence of denning in the 

area of overlap between designated critical habitat and the Action Area. Furthermore, the Action 

Area is further inland than most polar bears dens occur (> 95% of records of polar bear dens 

[n=19] between the Kavik River and Utqiaġvik were within 4.5 km of the coast [Durner et al. 

2009]). Therefore, it is very unlikely that polar bears will attempt to establish dens near 

infrastructure from GMT-2. 

Other factors likely further reduce the likelihood that disturbance from GMT-2 will affect 

denning polar bears. Female polar bears prospecting for den sites near the road connecting GMT1 with CD5 would likely encounter traffic and disturbance while prospecting for den sites. 

Projected traffic rates along the all-season road include > 70,000 vehicle trips per winter during 

construction (through April 2020), > 6000 vehicle trips during the final ice road year (through 

April 2021), and ~ 700 vehicle trips per year thereafter. Thus, prospecting females are likely to 

be exposed to disturbance, allowing less-tolerant individuals to move away from the road prior to 

establishing dens and giving birth to cubs. Additionally, considerable suitable denning habitat 
57

containing no oil and gas infrastructure or regular sources of human disturbance occurs near the 

Action Area, especially to the north where denning occurs more frequently (Durner et al. 2009). 

The potential that disturbance will indirectly reduce the value of polar bear critical habitat would 

be significantly reduced by other existing regulatory programs that directly address the 

disturbance of polar bears. The Marine Mammal Protection Act (MMPA) allows for incidental, 

non-intentional take from harassment of small numbers of marine mammals during specific 

activities. Section 101(a)(5) of the MMPA gives the Service authority to administer an incidental 

take program that allows polar bear managers to work cooperatively with parties requesting 

authorization for take. Using the issuance of Incidental Harassment Authorizations (if take is 

limited to nonlethal harassment) or promulgation of Incidental Take Regulations (ITRs), the 

Service can provide authorization for take under specific conditions. Conditions associated with 

this authority that serve to limit impacts to polar bears include: 

 No more than small numbers of polar bears can be taken; 

 No greater than a negligible impact on the species can result; 

 An unmitigatable adverse impact on the availability of the species for subsistence use by 

Alaska Natives must not result; 

 Means of effecting the least practicable adverse impact upon the species, its habitat, and 

its availability for subsistence harvest must be employed; and 

 Monitoring and reporting of impacts are required. 

Since 1991, affiliates of the oil and gas industry have requested, and we have issued regulations 

for, incidental take authorization for onshore and offshore oil and gas exploration, development, 

and production activities in Alaska in polar bear habitat. Regulations have been issued 

separately, on staggered 5-year schedules, for the Chukchi and Beaufort sea regions. This 

geographic separation of the regulations corresponds to the two subpopulations that occur in 

Alaska. As a result, we periodically re-evaluate for the Chukchi and Beaufort sea regions 

whether or not the thresholds of small numbers, negligible effects, and adverse impacts to 

subsistence harvest are exceeded. Mitigation measures applied to ensure least practicable impacts 

include requirement of site-specific plans of operation and site-specific polar bear interaction 

plans. In combination, these plans reduce attraction to bears (e.g., through garbage disposal 

procedures, snow management procedures) and provide training and other measures to eliminate 

the potential for injurious or lethal take of bears in defense of human life in the event that 

encounters occur. Other mitigation measures may be required on a case-by-case basis, such as 

use of infra-red thermal technology or trained dogs to determine presence or absence of dens in 

suitable denning habitat; measures to protect pregnant polar bears during denning activities (den 

selection, birthing, and maturation of cubs); and limiting industrial activities near barrier islands, 

which are used for denning, feeding, resting, and seasonal movements. This incidental-take 

program and the associated mitigation measures have effectively limited human-bear interactions 

and disturbance to bears, ensuring that, at least to date, industry effects have had a negligible 

impact on polar bears. 

In addition to disturbance from ground-level activities at facilities or along the road, air traffic 

associated with GMT-2 could potentially disturb polar bears, affecting the success or likelihood 

of denning in the Action Area. An estimated 5% of all air traffic above baseline would occur 

within the Action Area during the winter months, section 3.6 Aerial Transport. Flights would 
58

maintain altitudes of > 1,000 feet (weather and safe operating conditions permitting), except 

during takeoff and landing. Flights would originate at (and presumably return to) Deadhorse, 

Kuparuk, Nuiqsut, or Alpine, where considerable background air traffic, including takeoffs and 

landings, currently occurs. Incidental take under the USFWS LOA (16-13) requires CPAI to run 

a detection survey each year prior to activities occurring in polar bear denning habitat during the 

denning period (November to mid-April). Therefore, we conclude that additional new flights 

required for GMT-2 will not significantly alter denning conditions for denning in the Action 

Area, and conclude that air traffic associated with GMT-2 will have a negligible effect on polar 

bear denning within critical habitat. 

Additionally, Section 7(a)(2) of the ESA requires Federal agencies, including the Service, to 

ensure that their actions are not likely to jeopardize the continued existence of any species listed 

under the ESA or destroy or adversely modify designated critical habitat. Authorizing take of 

polar bears under Section 101(a)(5) of the MMPA, as described above, qualifies as a Federal 

action requiring consultation. Thus, every five years, on an alternating schedule, we consult on 

the issuance of regulations for oil and gas exploration, development, and production activities in 

Alaska in polar bear habitat in the onshore and offshore environments of the Chukchi and 

Beaufort seas. Although the standards of the MMPA (authorized impacts cannot be reasonably 

likely to adversely affect the species) are more protective than those of the ESA (the action 

agency must ensure their actions are not likely to jeopardize the species or destroy or adversely 

modify critical habitat), the section 7 consultation process provides an additional layer of 

protection for the polar bear and its habitat. Specifically, biological opinions issued through 

section 7 consultation on the incidental take regulations and “letters of authorization” issued to 

individual operators require periodic re-evaluation of impacts to polar bears and their habitat, and 

include a requirement that consultation is re-initiated if required monitoring and reporting 

indicate that impacts to polar bears or their habitat exceed those predicted and evaluated during 

consultation. 

In summary, two separate regulatory programs, authorized under different statutes, evaluate the 

effects of oil and gas activities upon polar bears in the Chukchi and Beaufort sea regions. Oil and 

gas operators are required to document and report human-bear interactions and other impacts, 

and the regulatory programs are re-evaluated every five years in order to ensure impacts are 

adequately managed. Further, consistent with the requirements and protective standards of the 

MMPA, for the incidental take program to continue it must be ensured that no more than 

negligible effects to polar bears and their habitat occur. 

Human-Polar Bear Interactions 

Information regarding human-polar bear interactions occurring at oil and gas industry facilities 

across the North Slope are provided in section 6.3.3 Human-Polar Bear Interactions. In keeping 

with the purpose and benefits of deterrence actions in general, deterrence actions at industrial 

infrastructure in or near denning habitat would presumably dissuade polar bears from 

establishing a den nearby, reducing the potential for disturbance or conflict after a den is 

established. Thus, although deterrence actions in denning habitat may alter behavior or disrupt 

movements in the short term, or in rare cases could result in non-lethal injury (e.g., bruising), we 

believe the net effect of deterrence actions to the denning success of the individuals involved 

would be positive. Overall, human-polar bear interactions, as mitigated by the existing 
59

deterrence program, would contribute positively to maintaining the conservation benefit of polar 

bear critical habitat. 

CUMULATIVE EFFECTS 

Regulations implementing the ESA (50 CFR §402.02) define “cumulative effects” as the effects 

of future State, tribal, local, or private actions that are reasonably certain to occur in the Action 

Area. Within the GMT-2 Action Area, future oil and gas development, scientific research, and 

community growth will likely occur. However, these activities would require Federal permits 

(e.g., from the BLM and USACE) and separate consultation and therefore are not considered 

cumulative impacts under the ESA. 

The new road and ice roads may affect access to areas used by subsistence hunters, which could 

conceivably impact harvest of spectacled eiders. Promulgation of regulations that govern the 

subsistence harvest of migratory birds is a Federal action that requires separate consultation 

under the ESA and therefore is not considered a cumulative impact under the ESA. 

CONCLUSION 

Section 7(a)(2) of the ESA requires Federal agencies to ensure their activities are not likely to: 

(1) jeopardize the continued existence of any listed species, or (2) result in the destruction or 

adverse modification of designated critical habitat. Regulations that implement section 7(a)(2) of 

the ESA define “jeopardize the continued existence of” as “to engage in an action that 

reasonably would be expected, directly or indirectly, to reduce appreciably the likelihood of both 

the survival and recovery of a listed species in the wild by reducing the reproduction, number, or 

distribution of that species” (50 CFR 402.02). 

This BO evaluates the potential impacts of the proposed Action on spectacled eiders, polar bears, 

and polar bear critical habitat in the GMT-2 Action Area. To reach a conclusion, impacts of the 

proposed Action are not considered in isolation, but are placed in the context of the current status 

of the species and critical habitat, the environmental baseline, and cumulative effects (as defined 

by the ESA). After considering these aggregate effects on the species, the Service’s biological 

opinion is that the proposed Action is not likely to jeopardize the continued existence of any of 

these species, nor is it likely to destroy or adversely modify polar bear critical habitat. 

In evaluating the impacts of the Action to listed species, the Service identified a number of 

adverse effects that may occur. These are discussed more fully in the section, Effects of the 

Proposed Action, and are summarized below. Incidental take has been authorized for activities 

that may adversely affect listed eiders. Impacts to polar bears were assessed to ensure the Action 

is in compliance with section 7(a)(2). However, while we estimate the take that may occur, no 

incidental take for polar bears has been authorized in this BO as the take of marine mammals 

may only be authorized under the ESA after it is authorized under the MMPA. 

The analysis set forth in this BO is based on our assessment of the likely effects of the activities 

in the BLM’s description of the Proposed Action. Additional section 7 consultation may be 

required in the future, however, as specific exploration and development projects are proposed. 

Additional consultation would be required in accordance with 50 CFR § 402.16; for example, if 
60

proposed projects so differ from the activities in the Proposed Action that the likely effects of the 

proposed projects to listed species or critical habitat exceed those considered in this BO. Any 

additional consultations would require careful consideration of all information available at that 

time, including up-to-date evaluations of the status of listed species and critical habitat, the 

environmental baseline and project-specific considerations such as the specific location, nature, 

and extent of proposed activities. We wish to provide clear notification that additional 

consultations could result in different conclusions than the ones set forth in this BO, depending 

on these project-specific considerations. 

Summary for Spectacled Eiders 

We identified loss of nesting habitat (with the associated disturbance) and collisions as the 

factors most likely to adversely affect spectacled eiders.

Some habitat could be completely and permanently lost when structures or fill render the habitat 

unusable. Additionally, the capability of immediately adjacent habitat to support eiders may be 

completely or partially compromised by nearby structures and the associated human activity, 

which could disturb nesting eiders or prevent them from nesting or rearing broods nearby. The 

extent of the area affected by disturbance remains unknown, and it is also unknown whether 

eiders are simply displaced from this habitat (possibly with reduced productivity) or continue to 

use it but possibly at reduced fitness. We have determined habitat loss and disturbance within the 

adjacent 200 m zone of influence around GMT-2 facilities may adversely affect listed eiders, 

causing functional loss of 8.35 km2

of nesting habitat. We estimate this would result in the 

production loss of 7 spectacled eider nests over the 32-year life of the project. We also estimate 

that between zero and 5 spectacled eiders would be injured or killed by colliding with structures 

at GMT-2 over the life of the project. 

The Service determined that while some impacts of the Proposed Action will likely cause 

adverse effects on individuals, these effects, when taken together, are not likely to cause 

population-level impact in spectacled or Steller’s eiders. We anticipate that BLM’s IAP/EIS 

stipulations and BMPs would minimize potential effects of exploration and development, 

including predator attraction, disturbance, habitat loss/alteration, exposure to oil spills or other 

contaminants, and collisions. Therefore, the Service concludes that the effects of all the Proposed 

Action, considered together with, cumulative effects and in the context of the status of the 

species, environmental baseline, and cumulative effects, are not reasonably likely to jeopardize 

the continued existence of spectacled eiders by reducing appreciably the likelihood of survival 

and recovery of the species in the wild by reducing their reproduction, numbers, or distribution. 

Summary for Polar Bears 

Polar bears could be adversely affected by the Proposed Action through disturbance, and humanpolar bear interactions. These effects are summarized below. 

We anticipate most polar bears would not experience more than short-term disturbance resulting 

from the Proposed Action. Non-denning (mobile) bears may be affected by human presence and 

activities such that they change their behavior and move away from the source of disturbance, or 

in rare cases may be attracted to the area where activity is occurring. The majority of polar bear 

disturbances would result only in short-term behavior changes that have a minimal effect on 

polar bears. 
61

Small spills of oil and other chemicals are expected to occur. However, it is highly unlikely that 

polar bears will be significantly affected because the vast majority of spills will likely be of a 

very low volume and would occur on development pads. Moreover, the density of polar bears is 

low in the Action Area so it is unlikely that polar bears will encounter spilled substances that 

result from the Proposed Action. Further, human activities associated with spill response would 

likely cause sufficient disturbance to displace polar bears from the spill site before they contact 

the spill. Very rarely an oil or chemical spill may be unattended, and one or more polar bears 

may access these chemicals and suffer injury or death. Even in the unlikely event that one or 

more large spills occur from an uncontrolled well blowout or leak from a pipeline crossing a 

river, the scarcity of polar bears in the Action Area suggests very few polar bears would be 

exposed. Given the low probability of a large oil spill combined with the low density of bears in 

the Action Area, we expect a very small number of polar bears to contact spills. Therefore, at 

most, we expect a small number of individual-level impacts to polar bears, and population-level 

effects are not likely to occur. 

Some human-polar bear interactions may require deterrence actions. Predicting the number of 

deterrence actions for individual projects such as GMT-2 is difficult. However, we anticipate the 

use of projectiles would occur fewer than once annually and up to two times for the 32-year life 

of the GMT-2 development with no deterrence action resulting in deaths. 

We anticipate that stipulations and BMPs set forth in the BLM’s IAP/EIS directly benefit polar 

bears by: 

 reducing access to anthropogenic sources of food (e.g., trash); 

 requiring designs to reduce surprise encounters with bears; 

 requiring workers to be educated on bear avoidance strategies; 

 preventing environmental contamination; and 

 protecting potential denning habitat from impacts and disturbance. 

These BMPs complement protective measures included in LOAs issued under the MMPA by the 

USFWS. 

In summary, we expect few, if any, polar bears would die as a result of disturbance, human-polar 

bear interactions, or small oil spills. The anticipated level of impact is not likely to cause 

population-level declines. All anticipated effects of the Proposed Action would likely impact 

only a limited number of individuals and only a small proportion of the worldwide population. 

Therefore, the Service concludes the effects of the Proposed Action, considered together with 

cumulative effects and in the context of the status of the species, environmental baseline, and 

cumulative effects, are not reasonably likely to jeopardize the continued existence of polar bears 

by reducing appreciably the likelihood of survival and recovery of the species in the wild by 

reducing their reproduction, numbers, or distribution. 

Summary for Polar Bear Critical habitat 

Three units of critical habitat in Alaska exist to support the conservation of polar bears; these 

units are sea ice habitat, terrestrial denning habitat, and barrier island habitat. As summarized 

above in the Status of Critical Habitat, the condition of designated critical habitat is declining 

and is expected to continue to decline in response to Arctic warming (IPCC 2014; Overland and 
62

Wang 2007, 2013). To date, the primary changes in the status of critical habitat have been 

decreases in the extent and quality of sea ice (USFWS 2016a, p. 65). Secondarily, increased 

human activities, including oil and gas exploration, development, and production, have occurred 

both offshore and onshore in critical habitat. However, these activities are tightly regulated and 

impacts to polar bears and their habitat have been negligible to date (75 FR 76118-76119). Thus, 

the ability of critical habitat to support polar bear conservation is declining and is expected to 

continue to decline, but to date the effects are primarily to sea ice and are attributable to globalscale climate change, whereas as impacts onshore, and those caused by local-scale factors, have 

thus far only negligibly affected polar bears and their habitat. 

In the Environmental Baseline section above, we evaluated the value of critical habitat within the 

Action Area, considering how past and ongoing human and natural factors have affected it. We 

conclude the value of polar bear critical habitat within the GMT-2 Action Area is limited by 

several factors, including its small area (only 16% of the Action Area); the limited extent of the 

macrohabitat features of denning habitat within critical habitat in the Action Area; and 

indications that use of the Action Area by polar bears, particularly for denning, is very minimal. 

Additionally, although activities occur within critical habitat in the Action Area, the actual area 

in which infrastructure and human activities overlap is minimal. Further, human activities there 

are highly managed to reduce disturbance of polar bears and protect dens, in the unexpected 

event that a den were to occur there. We conclude that the value of critical habitat within the 

Action Area is minimal, and that climate change and human activities within the area of overlap 

have affected, but not substantially, the condition and value of critical habitat within the Action 

Area. 

In the Effects of the Action section above, we identified the following factors that could 

potentially cause adverse effects to polar bear critical habitat: 

 Alteration of the physical and biological features (BPFs) of critical habitat, resulting from 

the construction of permanent facilities and gravel roads; 

 Oil spills; 

 Disturbance; and 

 Human-polar bear interactions. 

After evaluating these factors, we conclude that the value of terrestrial denning habitat will not 

be impacted by alteration of the BPFs, and that appreciable impacts from oil spills are extremely 

unlikely to occur. Further, polar bear interactions with humans associated with GMT-2 may alter 

behavior or disrupt movements in the short term, or may require deterrence actions to avoid 

potentially harmful situations. However, we believe the tightly managed deterrence program 

would ensure human-polar bear interactions do not reduce the conservation benefit of polar bear 

critical habitat. 

Finally, although disturbance of polar bear dens or females prospecting for den sites could 

potentially affect denning, we find this potential is minimized by these factors: 

1) The spatial overlap between suitable denning habitat and infrastructure where disturbance 

could occur is very limited in extent. Assuming potential disturbance at dens is limited to 

areas where suitable denning habitat occurs within 1 mi (1.6 km) of infrastructure (76 FR 
63

47010), this will be limited to 0.72 km2during construction. The area of this overlap 

would drop to 0.66km2 when construction is complete and operations begin in 2022. 

2) Polar bears generally avoid denning where oil and gas exploration, development and 

production occur (75 FR 76115). Due to the availability and proximity of terrestrial 

denning habitat that lacks industrial infrastructure and human activity, the potential for 

polar bears to establish dens near sources of disturbance is likely further reduced; and 

3) The existing MMPA incidental take regulatory program has been very successful in 

ensuring that impacts to polar bears of oil and gas exploration, development, and 

production have been negligible. This program entails measures to detect and protect 

pregnant polar bears and dens, monitoring and reporting requirements, and periodic reevaluations to ensure requirements under the MMPA and ESA are met (CPAI currently 

has the following LOAs under the MMPA, which apply at least in part to GMT1: LOA 

16-13; LOA 17-09; LOA 17-10; LOA 17-12). 

We are aware of no cumulative effects within the Action Area that will materially affect the 

value of critical habitat. 

In summary, after reviewing the current status of polar bear critical habitat, the environmental 

baseline for the Action Area, the effects of GMT-2, and cumulative effects, it is the Service’s 

biological opinion that the development and operation of GMT-2 is not likely to destroy or 

adversely modify designated critical habitat. 

ESTIMATED INCIDENTAL TAKE 

Biological opinions often have an accompanying Incidental Take Statement. Section 9 of the 

ESA and Federal regulations pursuant to section 4(d) of the ESA prohibit the take of endangered 

and threatened species without special exemption. Take is defined as to harass, harm, pursue, 

hunt, shoot, wound, kill, trap, capture or collect, or attempt to engage in any such conduct. 

“Harm” is further defined to include significant habitat modification or degradation that results 

in death or injury to listed species by significantly impairing essential behavioral patterns, 

including breeding, feeding, or sheltering. “Harass” is defined by the Service as intentional or 

negligent actions that create the likelihood of injury to listed species to such an extent as to 

significantly disrupt normal behavior patterns which include, but are not limited to, breeding, 

feeding, or sheltering. Incidental take is defined as take that is incidental to, but not for the 

purpose of, carrying out of an otherwise lawful activity. Under the terms of section 7(b)(4) and 

section 7(o)(2), taking that is incidental to and not intended as part of the agency action is not 

considered a prohibited taking provided that such taking is in compliance with the terms and 

conditions of this Incidental Take Statement. 

Estimated Incidental Take for Spectacled Eiders 

Habitat Loss and Disturbance 

Using the methods described in the Effects of the Action section, we estimate the following 

incidental take for the 32-year life of the project: 

 Seven nests. 
64

Collisions 

Using methods described the Effects of the Action section for spectacled eiders, we estimate the 

following incidental take for the 32-year life of the project: 

 Between 0 and 5 spectacled eiders may collide with structures associated with GMT-2 

over the life of the project, resulting in injury or death. 

Estimated Incidental Take for Polar Bears 

Using methods described the Effects of the Action section for polar bears, we estimate the 

following incidental take for the 32-year life of the project: 

 Up to two deterrence actions that cause injury (e.g., pain and bruising), but that do not 

cause severe injury or death, during the 32-year life of development. 

The process for authorizing take (incidental or intentional) for marine mammals such as polar 

bears differs from the process of authorizing incidental take of other threatened and endangered 

species. Although we have enumerated the extent of anticipated incidental take of polar bears, 

the Service is not authorizing incidental take of polar bears under the ESA in this BO. Consistent 

with the ESA and regulations at 50 CFR §402.14(i) Appendix (A), incidental take statements for 

marine mammals are not included in formal consultations until regulations, authorizations, or 

permits under the MMPA are in effect. Because such take must first be authorized under the 

MMPA, incidental take under the ESA that results from actions conducted in compliance with all 

requirements and stipulations set forth in the MMPA authorization will be considered by the 

Service to also be authorized under the ESA. CPAI has obtained authorization under the MMPA 

for take of polar bears for their various oilfield projects on the North Slope to date. These LOAs 

will expire before the end of the development lifespan of this project, but we assume that CPAI 

will continue to receive LOAs in the future. 
65

REASONABLE AND PRUDENT MEASURES AND TERMS AND CONDITIONS 

Reasonable and Prudent Measures (RPMs) and their implementing Terms and Conditions 

(T&Cs) aim to minimize the incidental take anticipated to result from the Proposed Action. As 

described above, activities resulting from GMT-2 may lead to the incidental take of spectacled 

eiders through habitat loss, disturbance, predation, and collisions. The Service expected that 

adherence to the lease stipulations and BMPs included in the IAP ROD (BLM 2013) would 

effectively minimize incidental take of spectacled eiders, and thus did not include RPMs and 

T&Cs in the IAP BO (USFWS 2013). However, the Action Area for GMT-2 includes areas 

outside of NPR-A where these BMPs do not apply. Thus, we are including RPMs and T&Cs for 

spectacled eiders in this amended BO to minimize incidental take within the entire Action Area. 

The RPMs and T&Cs are based on the BMPs applied to management within NPR-A but have 

been adapted to focus on minimizing incidental take of spectacled eiders within the entire Action 

Area. 

Disturbance 

RPM 1. Minimize ground-level activity (by vehicle or on foot) within 200 meters of occupied 

spectacled eider nests. 

Predation 

RPM 2. Minimize the use of GMT-2 facilities as nesting, denning, or shelter sites for avian and 

nest predators. 

Collisions 

RPM 3. Minimize the likelihood that collisions would occur as a result of GMT-2 

infrastructure. 

TERMS AND CONDITIONS 

Disturbance 

RPM 1. Minimize ground-level activity (by vehicle or on foot) within 200 meters of occupied 

spectacled eider nests. 

T&C 1a. Ground-level activity (by vehicle or on foot) within 200 meters of occupied 

spectacled eider nests, from June 1 through July 31, will be restricted to existing 

thoroughfares, such as pads and roads. Construction of permanent facilities, placement of fill, 

alteration of habitat, and introduction of high noise levels within 200 meters of occupied 

spectacled eider nests will be prohibited. 

T&C 1b. In instances where summer (June 1 through July 31) support/construction activity 

must occur off existing thoroughfares, Service-approved nest surveys must be conducted 

during mid-June prior to the approval of the activity. Collected data will be used to evaluate 

whether the action could occur based on employment of a 200-meter buffer around nests or if 

the activity would be delayed until after mid-August once ducklings are mobile and have left 

the nest site. Also, in cases in which oil spill response training is proposed to be conducted 

within 200 meters of shore in riverine, marine, or inter-tidal areas, the BLM and USACE will 
66

work with the Service to schedule the training at a time that is not a sensitive nesting/broodrearing period or require that nest surveys be conducted in the training area prior to the 

rendering a decision on approving the training. The protocol and timing of nest surveys for 

spectacled eiders will be determined in cooperation with the Service, and must be approved 

by the Service. Surveys should be supervised by biologists who have previous experience 

with spectacled eider nest surveys. 

These T&Cs are based on the BLM’s BMP E-18. 

Predation 

RPM 2. Minimize the use of GMT-2 facilities as nesting, denning, or shelter sites for avian and 

nest predators. 

T&C 2a. Areas of operation shall be left clean of all debris. 

This T&C is based on the BLM’s BMP A-1. 

T&C 2b. CPAI shall prepare and implement a comprehensive waste management plan for 

all activities occurring within the GMT-2 Action Area. The plan shall be submitted to the 

authorized officers for approval, in consultation with federal, State, and North Slope Borough 

regulatory and resource agencies, as appropriate (based on agency legal authority and 

jurisdictional responsibility), as part of a plan of operations or other similar permit 

application. Management decisions affecting waste generation shall be addressed in the 

following order of priority: (1) prevention and reduction, (2) recycling, (3) treatment, and (4) 

disposal. The plan shall consider and take into account the following requirements: 

1. Methods to avoid attracting wildlife to food and garbage. The plan shall identify 

precautions that are to be taken to avoid attracting wildlife to food and garbage. 

2. Disposal of putrescible waste. Requirements prohibit the burial of garbage. Lessees and 

permitted users shall have a written procedure to ensure that the handling and disposal of 

putrescible waste will be accomplished in a manner that prevents the attraction of 

wildlife. All putrescible waste shall be incinerated, backhauled, or composted in a 

manner approved by the authorized officer. All solid waste, including incinerator ash, 

shall be disposed of in an approved waste-disposal facility in accordance with 

Environmental Protection Agency and Alaska Department of Environmental 

Conservation regulations and procedures. The burial of human waste is prohibited except 

as authorized by the authorized officer. 

These T&Cs are based on the BLM’s BMPs A-2a and A-2b.

T&C 2c. CPAI shall utilize best available technology to prevent facilities from providing 

nesting, denning, or shelter sites for ravens, raptors, and foxes. The lessee shall provide the 

authorized officer with an annual report on the use of oil and gas facilities by ravens, raptors, 

and foxes as nesting, denning, and shelter sites. Additionally, feeding of wildlife is 

prohibited and will be subject to non-compliance regulations. 

This T&C is based on BLM’s BMP E-9.

Collisions 
67

RPM 3. Minimize the likelihood that collisions would occur as a result of GMT-2 

infrastructure. 

T&C 3a. Illumination of all structures between August 1 and October 31 shall be designed 

to direct artificial exterior lighting inward and downward, rather than upward and outward, 

unless otherwise required by the Federal Aviation Administration. 

This T&C is based on BLM’s BMP E-10. 

T&C 3b. To reduce the possibility of spectacled eiders colliding with above-ground utility 

lines (power and communication), such lines shall either be buried in access roads or 

suspended on vertical support members except in rare cases which are to be few in number 

and limited in extent. Exceptions are limited to the following situations, and must be reported 

to the USFWS when exceptions are authorized: 

1. Overhead power or communication lines may be allowed when located entirely 

within the boundaries of a facility pad; 

2. Overhead power or communication lines may be allowed when engineering 

constraints at the specific and limited location make it infeasible to bury or connect 

the lines to a vertical support member; or 

3. Overhead power or communication lines may be allowed in situations when human 

safety would be compromised by other methods. 

This T&C is based on BLM’s BMP E-11c. 

T&C 3c. To reduce the likelihood of spectacled eiders colliding with communication 

towers, towers should be located, to the extent practicable, on existing pads and as close as 

possible to buildings or other structures, and on the east or west side of buildings or other 

structures if possible. Support wires associated with communication towers, radio antennas, 

and other similar facilities, should be avoided to the extent practicable. If support wires are 

necessary, they should be clearly marked along their entire length to improve visibility to 

low-flying birds. Such markings shall be developed through consultation with the Service. 

This T&C is based on BLM’s BMP E-11d.
68

CONSERVATION RECOMMENDATIONS 

Section 7(a)(1) of the ESA directs Federal agencies to utilize their authorities to further the 

purposes of the ESA by carrying out conservation programs for the benefit of endangered and 

threatened species. Conservation recommendations are discretionary agency activities to 

minimize or avoid adverse effects of a proposed action on listed species or critical habitat, to 

help implement recovery plans, or to develop information. BLM and USACE are encouraged to: 

1. Continue to work with the Service and other Federal and State agencies in implementing 

recovery actions identified in the Steller’s and spectacled eider recovery plans. Research to 

determine important habitats, migration routes, and wintering areas of spectacled and 

Steller’s eiders is an important step toward minimizing conflicts with current and future 

North Slope oil/gas activities. 

2. Continue to monitor threatened eiders and BLM special status species in the Action Area and 

surrounding region in which oil and gas development is likely to occur. Results will allow 

the Service, BLM, and USACE to better evaluate abundance, distribution, and population 

trends of listed eiders and other special status species. These efforts will enhance the 

likelihood that future oil and gas development within NPR-A and the Colville River delta 

will not jeopardize listed eiders or lead to listing additional species. 

3. Develop an outreach program that aims to eliminate use of lead shot and accidental shootings 

of spectacled and Alaska-breeding Steller’s eiders within the Action Area.

The Service requests notification of the implementation of any conservation recommendations 

by the BLM and USACE to keep the Service informed of actions minimizing or avoiding 

adverse effects or benefiting candidate or listed species or their habitats. 

Thank you for your cooperation in the development of this BO. If you have any comments or 

require additional information, please contact Ted Swem, Consultation Branch Chief, at 

ted_swem@fws.gov, (907) 456-0441, or Fairbanks Fish and Wildlife Field Office, 101 12th

Ave., Fairbanks, Alaska, 99701. 
69

RE-INITIATION NOTICE 

This concludes formal consultation on the Action described. As provided in 50 CFR 402.16, reinitiation of formal consultation is required where discretionary BLM or USACE involvement or 

control over the action has been retained (or is authorized by law) and: 

1) If the amount or extent of incidental take is exceeded; 

a. Habitat loss and associated disturbance: 

 Seven spectacled eider nests during the 32-year development lifespan 

b. Collisions: 

 Five spectacled eiders injured or killed in collisions with infrastructure. 

2) If new information reveals the Proposed Action may affect listed species in a manner or 

to an extent not considered in this opinion that includes but is not limited to the 

following: 

a. More than to two deterrence events that lead to injury (e.g., pain and bruising) 

during the 32-year life of development, but that do not cause severe injury or 

death; 

b. Any human-caused incidents that lead to the death of a polar bear; or 

c. Any human-caused incidents that cause the premature abandonment of polar bear 

dens. 

3) If a new species is listed or critical habitat designated that may be affected by the Action. 
70

LITERATURE CITED 

Aars, J., N.J. Lunn, and A.E. Derocher. 2006. Polar Bears: Proceedings of the 14th Working 

Meeting of the IUCN/SSC Polar Bear Specialist Group 20–24 June 2005, Seattle, 

Washington. Seattle, Washington, USA. 

ABR. 2014. Section 7 consultation for the polar bear, pacific walrus, spectacled eider, Steller’s 

eider, and yellow-billed loon in the GMT-1 project area. Prepared for ConocoPhillips 

Alaska, Inc. Anchorage, Alaska by Charles B. Johnson, Robert M. Burgess, and JillMarie Seymour at ABR, Inc.—Environmental Research & Services, Fairbanks, Alaska. 

ACIA. 2005. Arctic Climate Impact Assessment. Cambridge University Press. 

AMAP. 2005. AMAP Assessment 2002: Persistent Organic Pollutants in the Arctic. Arctic 

Monitoring and Assessment Programme, Oslo, Norway. 

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Appendix A: Deviations Requested by CPAI 

(Text provided by BLM 2018b) 

In a letter dated October 30, 2017, CPAI formally requested that BLM grant deviations to two 

stipulations/BMPs (DSEIS Appendix I). 

Deviation Request for Lease Stipulation E-2 (Facilities Within 500 Feet of Water Bodies) 

CPAI first seeks a deviation from Lease Stipulation E-2 (2008), which prohibits permanent oil 

and gas facilities, including roads and pipelines, within 500 feet of fish bearing water bodies and 

aquatic habitats. A map illustrating all rivers, streams, and lakes within 500 feet of the 

Alternative A facilities is included as Attachment 2 for reference. As shown on that map, the 

road route for Alternative A comes within 500 of one named lake (M9925). 

The objective of Lease Stipulation E-2 is to protect fish-bearing waterbodies, water quality, and 

aquatic habitats. In the 2013 IAP, Stipulation E-2 was clarified to apply only to fish-bearing 

waterbodies. The terms of Lease Stipulation E-2 in both the 2008 and 2013 versions expressly 

provide: "Essential pipeline and road crossings will be permitted on a case-by-case basis." 

The GMT2 project area, like much of the North Slope, contains abundant lakes, rivers, streams, 

creeks, and ponds. These water bodies are prevalent because the area is underlain by permafrost, 

which generally prohibits drainage. Additionally, this area is classified as wetlands, attesting to 

presence of numerous water bodies. The 2004 Alpine Satellite Development Plan EIS (Sections 

3.2.1.1 and 3.2.2.1) states: 

 "The tundra covered Arctic Coastal Plain . . . is generally characterized by 

periglacial features associated with flat topography, poor drainage, and underlying 

permafrost. Thaw-lakes and polygonal surface patterns on inter-lake ice wedges 

are the dominant terrain features." 

 "Abundant thaw-lakes and marshy thaw-lake basins, generally only a few feet 

deep, cover 25 to 30 percent of the landscape." 

 "Lakes and ponds are the most prevalent features of the Plan Area. " 

Because of the abundance of water bodies in the area, it is not technically possible, let alone 

technically feasible, to locate all facilities farther than 500 feet from the highest high-water mark 

of all active floodplains. CPAI selected the proposed locations for pads, roads, and pipelines by 

balancing engineering, habitat, economics, hydrology, and other environmental factors, such as 

avoiding bird nest locations, to the extent possible. Maintaining a distance of 500 feet from every 

water body, while also minimizing gravel footprint, is not practicable in this environment. 

Even where facilities need to be placed closer than 500 feet from a water body, the objective of 

Lease Stipulation E-2, protection of water quality, would still be satisfied. Standard practices 

such as pipeline inspections and other spill prevention efforts will protect water bodies from 

potential spills to the extent possible. Secondary containment for tanks, tank inspection 

procedures, and refueling practices minimize the chance of a potential tank spill leaving a pad 

and entering a water body. Spill response equipment will be staged near sensitive areas and 

agency approved spill plans will be in place. 
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BLM granted approval an exception from this requirement in 2004, based on technical 

infeasibility of total compliance due to the hydrology and number of water bodies in the area as 

well as implementation of other measures that would protect water bodies (e.g., use of secondary 

containment).5 BLM reaffirmed this decision, speaking terms of a "deviation" rather than an 

exception, for the GMT1 development at page 7 of the GMT1 ROD, issued in 2015. CPAI now 

requests confirmation that the 2004 exception remains in effect to allow the location of facilities 

closer than 500 feet from water bodies where necessary based on other environmental and 

engineering factors. 

Deviation Request for BMP E-7c (500 Feet Between Pipelines and Roads) 

CPAl's second request is for a deviation from BMP E-7c., which requires a minimum distance of 

500 feet between pipelines and roads. Four stretches of the proposed road and pipeline routes 

locate the pipeline within 500 feet of the gravel road. These are 3,990 feet of road and pipeline 

near lake M9925, 3,909 feet near lake M9923, 4,803 feet near lake Z06005, and 1,195 feet near 

lake R0062. These particular distances and locations may change subject to potential pipeline 

route modifications. 

The objective of BMP E-7c is to minimize disruption of caribou movement and subsistence use. 

The standard is for pipelines and roads to be designed to allow the free movement of caribou and 

the safe, unimpeded passage of the public while participating in subsistence activities. The BMP 

also states: "Separating roads from pipelines may not be feasible within narrow land corridors 

between lakes and where pipelines and roads converge on a drill pad. Where it is not feasible to 

separate pipelines and roads, alternative pipeline routes, designs and possible burial within the 

road will be considered by the authorizing officer. " 

Separating the pipeline from the gravel road by more than 500 feet, while also staying 500 feet 

away from nearby lakes, is not feasible at the four locations. Location 2 is also narrowed by the 

need to keep the road out of the Fish Creek setback. The nearest the road comes to the pipeline at 

location 1 is approximately 359 feet, at location 2,337 feet, at location 3,269 feet, and at location 

4,458 feet. 

Even where pipelines and roads would be placed closer than 500 feet, the objective of BMP E7c, that the pipelines and roads would be designed to allow the free movement of caribou and the 

safe, unimpeded passage of the public while participating in subsistence activities, will still be 

satisfied. The pipeline height will be a minimum of 7 feet allowing unimpeded passage, and road 

pullouts have been proposed to support subsistence activities and provide a safe place for 

subsistence hunters to rendezvous while hunting or traveling to camp and cabin sites. 

For the reasons set forth above, CPAI requests a deviation from ROP E-7c as necessary to allow 

certain stretches of road and pipeline to be less than 500 feet apart. 

 

5

 In the 2004 Alpine Satellite Development Plan ROD, this Lease Stipulation is referred to on page 3 as "Stipulation 

41."