Alpine Satellite Development 

Plan for the Proposed Greater 

Mooses Tooth 2 Development 

Project 

Final Supplemental Environmental Impact 

Statement

Volume 1: Chapters 1-6

Prepared by:

U.S. Department of the Interior 

Bureau of Land Management

Anchorage, Alaska

In cooperation with:

Native Village of Nuiqsut

U.S. Army Corps of Engineers

U.S. Environmental Protection Agency

U.S. Fish and Wildlife Service

U.S. Bureau of Ocean Energy Management

State of Alaska

North Slope Borough

Iñupiat Community of the Arctic Slope

August 2018

Total Cost of Producing the EIS: $1.1 million
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Supplemental Environmental Impact Statement

Alpine Satellite Development Plan for the Proposed Greater Mooses Tooth 2 Development Project

i 

Alpine Satellite Development Plan GMT2 

Development Project Final Supplemental 

Environmental Impact Statement

Lead Agency U.S. Department of the Interior (DOI), Bureau of Land Management (BLM)

Proposed Action To provide ConocoPhillips Alaska, Inc. (ConocoPhillips) with authorizations to 

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

facilities to develop and produce petroleum resources on federally managed lands 

within the Greater Mooses Tooth (GMT) Unit of the National Petroleum Reserve in 

Alaska (NPR-A).

Abstract ConocoPhillips is proposing to produce hydrocarbon resources from a surface 

location on federal oil and gas lease AA-081800 in the NPR-A. The proposed GMT2 

Project includes a drill site in the GMT Unit, a pipeline, and a road corridor to 

ConocoPhillips facilities at Greater Mooses Tooth 1 (GMT1).

The BLM has lead responsibility for preparation of this draft supplemental 

environmental impact statement (EIS). The U.S. Army Corps of Engineers, U.S. 

Environmental Protection Agency, U.S. Fish and Wildlife Service, U.S. Bureau of 

Ocean Energy Management, State of Alaska, Native Village of Nuiqsut, Iñupiat 

Community of the Arctic Slope and the North Slope Borough are participating in the 

analysis as cooperating agencies.

This supplemental EIS evaluates relevant new circumstances and information since 

the issuance of the Alpine Satellite Development Plan Final EIS in September 2004. 

Its development also provided opportunities for public participation and to address 

changes to ConocoPhillips’ proposed development plan for GMT2 (referred to as 

Colville Delta 7 [CD7] in the Alpine Satellite Development Plan EIS).

GMT2 is part of the Alpine Satellite Development Plan, for which the BLM prepared 

a final EIS. The record of decision approved issuance of the BLM authorizations 

needed to develop the Alpine Field. The currently proposed GMT2 Development 

Project is very similar to the CD7 development approved for permitting in the 2004 

Alpine Satellite Development Plan Record of Decision, with changes to 

accommodate access to the hydrocarbon reservoir and access to existing 

infrastructure.

The supplemental EIS documents the potential effects to: Physiography; Geology; 

Soils and Permafrost; Sand and Gravel; Paleontological Resources; Water Resources; 

Surface Water Quality; Climate and Meteorology; Air Quality; Acoustical 

Environment; Terrestrial Vegetation and Wetlands; Fish; Birds; Terrestrial Mammals; 

Marine Mammals; Threatened and Endangered Species; Sociocultural Environment; 

State and Local Economy; Subsistence Harvest and Uses; Environmental Justice; 

Public Health; Cultural Resources; Land Use; Recreation; Visual Resources; and, 

Transportation. Also evaluated are the potential effects of spilled crude-oil-produced 

fluids, seawater, and other chemicals.

Further Information Contact Stephanie Rice, BLM Alaska, at 907-271-3202 or visit the supplemental EIS 

website at http://www.blm.gov/alaska. 
Supplemental Environmental Impact Statement

Alpine Satellite Development Plan for the Proposed Greater Mooses Tooth 2 Development Project

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Supplemental Environmental Impact Statement

Alpine Satellite Development Plan for the Proposed Greater Mooses Tooth 2 Development Project

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Executive Summary

What is the BLM proposing to do in this supplemental EIS?

BLM Alaska prepared this supplemental EIS to analyze an application by ConocoPhillips to construct, 

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

petroleum resources at the proposed Greater Mooses Tooth 2 (GMT2) site within the National Petroleum 

Reserve in Alaska (NPR-A). The key issues in this supplemental EIS center on oil and gas production 

decisions, the protection of surface resources, access to subsistence resources, and appropriate mitigation 

measures.

The purpose of this supplemental EIS is to evaluate any relevant new circumstances and information that 

have arisen since the Alpine Satellite Development Plan Final EIS, dated September 2004. Additionally, 

the BLM completed the NPR-A Integrated Activity Plan/Environmental Impact Statement Record of 

Decision in 2013 to determine the appropriate management of BLM-administered lands (public lands) in 

the nearly 23-million-acre NPR-A. This supplemental EIS tiers to both of these previous National 

Environmental Policy Act (NEPA) analyses and incorporates them by reference. 

What are the major issues and focus of controversy? 

The key issues in this supplemental EIS are analysis of impacts to surface resources, particularly 

subsistence resources, and analysis of socioeconomic impacts. Much of the analysis focuses on issues 

raised in scoping, such as subsistence and wildlife protections; impacts of and contributions to global 

climate change; impacts to water quality and air quality; air traffic effects; economic benefits to Alaska 

Natives; and cumulative effects of oil and gas development on the North Slope. The supplemental EIS 

examines a range of alternatives for the GMT2 Project, and considers relevant and reasonable mitigation 

measures, consistent with BLM policy.

Of particular interest is the proximity of the GMT2 site to the Village of Nuiqsut, and potential impacts to 

subsistence. Potential impacts to subsistence may result from hunter avoidance of the area, changes in 

access to subsistence use areas, resource (particularly caribou) availability, community participation in 

subsistence activities, aircraft traffic, spills, and rehabilitation of infrastructure upon abandonment. The 

BLM’s analysis of subsistence impacts under ANILCA Section 810 found that development of the GMT2 

Project may significantly restrict subsistence activities for the village of Nuiqsut, and the cumulative 

effects of GMT2 and other development on the North Slope may significantly restrict subsistence 

activities for the villages of Nuiqsut, Anaktuvuk Pass, Atqasuk and Utqiagvik. 

What measures are being taken to reduce impacts?

All action alternatives incorporate ConocoPhillips’ existing lease stipulations for the GMT Unit, as well 

as best management practices contained in the 2013 NPR-A Integrated Activity Plan/Environmental 

Impact Statement Record of Decision. ConocoPhillips has requested that the BLM grant deviations to two 

stipulations/best management practices (Appendix I). The BLM will determine whether or not to grant 

these deviations in its Record of Decision. 

As the GMT2 applicant and primary oil development company in the Nuiqsut area, ConocoPhillips has 

attempted to mitigate impacts from flights in its exiting Alpine Development Field, and financially 

contributes to subsistence support programs in the community. ConocoPhillips has also incorporated 

project designs, such as subsistence pullouts, to reduce impacts to subsistence and other resources.
Supplemental Environmental Impact Statement

Alpine Satellite Development Plan for the Proposed Greater Mooses Tooth 2 Development Project

iv

The BLM is considering the adoption of new potential mitigation measures as part of its GMT2 

supplemental EIS authorization, which are analyzed for applicable resources throughout Chapter 4 of this

document. The BLM will determine which new mitigation measures to adopt in its Record of Decision.

What alternatives are being considered by the BLM?

The final supplemental EIS contains three action alternatives and a no-action alternative (Alternative D). 

Alternative A, the Proponent’s Proposal, consists of an 8.2-mile gravel road and pipeline connecting the 

GMT2 pad with existing infrastructure at GMT1. Alternative B, the Alternate Road Alignment, consists of 

a 9.4-mile road and pipeline connecting the GMT2 pad to existing infrastructure. The alternate road 

alignment follows the watershed divide between the Fish Creek and Ublutuoch drainages. Alternative C, 

Roadless Development, consists of an 8.6-mile pipeline connecting GMT2 with infrastructure at GMT1, 

and an airstrip and occupied structure pad to support operations at GMT2. 

Alternative A is the BLM’s preferred alternative. The identification of a preferred alternative does not 

constitute a commitment or decision in principle, and there is no requirement to select the preferred 

alternative in the Agency’s record of decision. If warranted, the BLM may select a different alternative 

than the preferred alternative in its record of decision. 

The BLM’s final supplemental EIS analysis reached a preliminary conclusion that Alternative A would be 

the least environmentally damaging alternative that meets the purpose and need for the GMT2 Project. 

Development of GMT2 under all action alternatives may significantly restrict subsistence for the village 

of Nuiqsut; however, Alternatives A and B would likely have the fewest impacts to subsistence. These 

alternatives require less air traffic close to the community compared to Alternative C, and air traffic is the 

most frequently reported caribou hunting impact associated with development. Alternative A requires the 

least amount of gravel fill compared to Alternatives B and C, which is a primary consideration for the 

Corps of Engineers in determining the least environmentally damaging practicable alternative for aquatic 

resources. 

What is next?

After at least 30 days have passed since the issuance of the final supplemental EIS, BLM will issue a 

record of decision that determines whether to issue authorizations associated with ConocoPhillips’ 

application. In doing so, BLM will select an alternative among the range of alternatives evaluated in the 

final supplemental EIS and will determine which, if any, new potential mitigation measures to adopt. 
Supplemental Environmental Impact Statement

Alpine Satellite Development Plan for the Proposed Greater Mooses Tooth 2 Development Project

v 

Contents of Volume 1 

Acronyms ................................................................................................................................................... xiii

Chapter 1. Introduction ................................................................................................................................. 1

1.1 Project Location and Land Status ................................................................................................. 1

1.2 History of Operations in the Area ................................................................................................. 2

1.3 Purpose and Need for the Project .................................................................................................. 3

1.4 Purpose and Need for Federal Action ........................................................................................... 4

1.4.1 Support for Federal Decisions ............................................................................................ 4

1.4.2 Laws, Regulations, and Permits .......................................................................................... 4

1.4.3 Related NEPA Analyses ................................................................................................... 12

1.4.4 Scope of Supplemental EIS .............................................................................................. 15

1.4.5 Changes and New Information ......................................................................................... 15

1.5 Public Involvement ..................................................................................................................... 18

1.5.1 Scoping ............................................................................................................................. 18

1.5.2 Other Stakeholder Opportunities ...................................................................................... 19

Chapter 2. Proposed Project and Alternatives ............................................................................................ 21

2.1 GMT2 Project Changes Over Time ............................................................................................ 21

2.1.1 Project as Proposed in 2004 Alpine Satellite Development Plan Record of Decision ..... 21

2.1.2 Project Evaluated by the BLM in 2012 and 2014 ............................................................. 21

2.1.3 2015 GMT2 Project Proposed by ConocoPhillips ............................................................ 22

2.1.4 Summary of Changes in the GMT2 Project over Time .................................................... 22

2.2 Lease Stipulations and Best Management Practices ................................................................... 25

2.3 Alternatives to the Proposed Project ........................................................................................... 25

2.3.1 Alternatives Selection Process .......................................................................................... 26

2.3.2 Alternatives Considered But Not Carried Forward ........................................................... 27

2.3.3 Alternatives Carried Forward in the Supplemental EIS .................................................... 27

2.4 Features Common to All Alternatives ........................................................................................ 31

2.4.1 Schedule ............................................................................................................................ 31

2.4.2 Location ............................................................................................................................ 32

2.4.3 Drill Pad and Support Facilities ........................................................................................ 32

2.4.4 Pipelines ............................................................................................................................ 33

2.4.5 Ice Roads and Ice Pads ..................................................................................................... 35

2.4.6 Gravel Supply Options ...................................................................................................... 35

2.4.7 Camp Requirements, Locations, and Availability ............................................................ 37

2.4.8 Water Use ......................................................................................................................... 37

2.4.9 Erosion Control Measures................................................................................................. 37

2.4.10 Spill Prevention and Response.......................................................................................... 38

2.4.11 Fuel and Chemical Storage ............................................................................................... 40

2.4.12 Waste Handling and Disposal ........................................................................................... 40

2.4.13 Abandonment and Reclamation ........................................................................................ 41

2.5 Alternative A: ConocoPhillips’s Proposed Project, Preferred Alternative ................................. 42

2.5.1 Project Components .......................................................................................................... 42

2.5.2 Location ............................................................................................................................ 42

2.5.3 Drill Pad and Support Facilities ........................................................................................ 43

2.5.4 Access ............................................................................................................................... 43

2.5.5 Gravel Requirements ........................................................................................................ 45

2.5.6 Camps ............................................................................................................................... 46

2.5.7 Water Use ......................................................................................................................... 46

2.5.8 Spill Prevention and Response.......................................................................................... 47
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2.6 Alternative B: Alternate Alignment of GMT1–GMT2 Access Road ......................................... 47

2.6.1 Project Components .......................................................................................................... 48

2.6.2 Location ............................................................................................................................ 48

2.6.3 Drill Pad and Support Facilities ........................................................................................ 48

2.6.4 Access ............................................................................................................................... 48

2.6.5 Gravel Requirements ........................................................................................................ 51

2.6.6 Camps ............................................................................................................................... 51

2.6.7 Water Use ......................................................................................................................... 52

2.6.8 Spill Prevention and Response.......................................................................................... 52

2.7 Alternative C: Roadless Development ........................................................................................ 53

2.7.1 Project Components .......................................................................................................... 54

2.7.2 Location ............................................................................................................................ 54

2.7.3 Drill Pad and Support Facilities ........................................................................................ 54

2.7.4 Access ............................................................................................................................... 56

2.7.5 Gravel Requirements ........................................................................................................ 58

2.7.6 Camps ............................................................................................................................... 58

2.7.7 Water Use ......................................................................................................................... 59

2.7.8 Spill Prevention and Response.......................................................................................... 59

2.8 Alternative D: No Action ............................................................................................................ 59

2.9 Comparison of Alternatives ........................................................................................................ 60

2.9.1 Access ............................................................................................................................... 64

2.9.2 Spill Prevention and Response.......................................................................................... 65

Chapter 3. Affected Environment ............................................................................................................... 67

3.1 Introduction ................................................................................................................................. 67

3.1.1 Project Study Area ............................................................................................................ 67

3.1.2 Existing and Planned Infrastructure .................................................................................. 67

3.1.3 Hazardous and Solid Waste Sites ..................................................................................... 68

3.2 Physical Characteristics .............................................................................................................. 69

3.2.1 Terrestrial Environment .................................................................................................... 69

3.2.2 Water Resources ............................................................................................................... 75

3.2.3 Atmospheric Environment ................................................................................................ 81

3.2.4 Climate Change ............................................................................................................... 108

3.3 Biological Resources ................................................................................................................ 111

3.3.1 Vegetation and Wetlands ................................................................................................ 111

3.3.2 Fish ................................................................................................................................. 114

3.3.3 Birds ................................................................................................................................ 117

3.3.4 Mammals ........................................................................................................................ 136

3.3.5 Threatened and Endangered Species .............................................................................. 148

3.4 Social Systems .......................................................................................................................... 153

3.4.1 Overview of Nuiqsut ....................................................................................................... 153

3.4.2 Cultural Resources .......................................................................................................... 153

3.4.3 Sociocultural Systems ..................................................................................................... 167

3.4.4 Economy ......................................................................................................................... 169

3.4.5 Land Use ......................................................................................................................... 177

3.4.6 Subsistence...................................................................................................................... 180

3.4.7 Public Health................................................................................................................... 228

3.4.8 Environmental Justice ..................................................................................................... 233

Chapter 4. Environmental Consequences ................................................................................................. 236

4.1 Introduction ............................................................................................................................... 236

4.1.1 Project Study Area and Methodology ............................................................................. 236

4.1.2 Project Alternatives and Major Project Components ...................................................... 237
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Alpine Satellite Development Plan for the Proposed Greater Mooses Tooth 2 Development Project

vii

4.1.3 BLM Protective Measures .............................................................................................. 239

4.1.4 Potential New Mitigation Measures ................................................................................ 239

4.2 Physical Characteristics ............................................................................................................ 239

4.2.1 Terrestrial Environment .................................................................................................. 239

4.2.2 Water Resources ............................................................................................................. 248

4.2.3 Atmospheric Environment .............................................................................................. 264

4.2.4 Project Effects on Global Climate Change ..................................................................... 305

4.3 Biological Environment ............................................................................................................ 314

4.3.1 Vegetation and Wetlands ................................................................................................ 314

4.3.2 Fish ................................................................................................................................. 329

4.3.3 Birds ................................................................................................................................ 335

4.3.4 Mammals ........................................................................................................................ 347

4.3.5 Threatened and Endangered Species .............................................................................. 362

4.4 Social Systems .......................................................................................................................... 372

4.4.1 Cultural Resources .......................................................................................................... 372

4.4.2 Sociocultural Systems ..................................................................................................... 382

4.4.3 Economy ......................................................................................................................... 399

4.4.4 Land Use ......................................................................................................................... 407

4.4.5 Subsistence...................................................................................................................... 416

4.4.6 Public Health................................................................................................................... 462

4.4.7 Environmental Justice ..................................................................................................... 466

4.5 Impacts of Oil, Saltwater and Hazardous Materials Spills ....................................................... 472

4.5.1 Background ..................................................................................................................... 472

4.5.2 Spills History .................................................................................................................. 473

4.5.3 Construction .................................................................................................................... 476

4.5.4 Drilling and Operation .................................................................................................... 476

4.5.5 Waste Disposal ............................................................................................................... 479

4.5.6 Comparison of Alternatives ............................................................................................ 479

4.5.7 Mitigation........................................................................................................................ 480

4.5.8 Conclusions ..................................................................................................................... 483

4.6 Cumulative Impacts .................................................................................................................. 483

4.6.1 Background ..................................................................................................................... 483

4.6.2 Methodology ................................................................................................................... 483

4.6.3 Cumulative Impacts to the Terrestrial Environment ....................................................... 491

4.6.4 Cumulative Impacts to Water Resources ........................................................................ 493

4.6.5 Cumulative Impacts to Air Quality ................................................................................. 497

4.6.6 Cumulative Impacts of Noise.......................................................................................... 500

4.6.7 Cumulative Impacts to Biological Resources ................................................................. 502

4.6.8 Cumulative Impacts to Social Systems ........................................................................... 527

4.6.9 Cumulative Impacts of Oil, Saltwater and Hazardous Materials Spills .......................... 559

4.7 Mitigation Measures and Monitoring ....................................................................................... 559

4.8 Unavoidable Adverse Impacts .................................................................................................. 562

4.9 Relationship Between Local Short-Term Uses and Long-Term Productivity .......................... 562

4.10 Irreversible and Irretrievable Commitments of Resources ....................................................... 563

Chapter 5. Consultation and Coordination ................................................................................................ 564

5.1 Supplemental EIS Consultation and Coordination ................................................................... 564

5.1.1 Coordination and Consultation with Local, State, and Federal Agencies ....................... 564

5.1.2 Tribal Consultation ......................................................................................................... 565

5.1.3 ConocoPhillips Coordination .......................................................................................... 565

5.2 List of Preparers ........................................................................................................................ 565

Chapter 6. References ............................................................................................................................... 568
Supplemental Environmental Impact Statement

Alpine Satellite Development Plan for the Proposed Greater Mooses Tooth 2 Development Project

viii

List of Tables

Table 1. Key permits, approval, and other requirements for GMT2 ........................................................... 10

Table 2. Environmental changes and new information in project study area since 2004 ........................... 16

Table 3. Summary of changes in the GMT2 Project over time .................................................................. 23

Table 4. Alternatives development meeting summary ................................................................................ 26

Table 5. Summary of major project components for each action alternative ............................................. 29

Table 6. Summary of historical ice road opening/closure, 2004–2014 ....................................................... 35

Table 7. Infrastructure for Alternative A, proposed action ......................................................................... 42

Table 8. Gravel use for Alternative A, proposed project a, b ....................................................................... 46

Table 9. Infrastructure for Alternative B, alternate road alignment ............................................................ 48

Table 10. Gravel use for Alternative B, alternate road alignment a, b .......................................................... 51

Table 11. Infrastructure for Alternative C .................................................................................................. 54

Table 12. Gravel use for Alternative C ....................................................................................................... 58

Table 13. Summary of ConocoPhillips current aircraft flights a, b .............................................................. 60

Table 14. Comparison of components, facilities, and access for the action alternatives ............................ 62

Table 15. Summary of total vehicle trips for project alternatives ............................................................... 64

Table 16. Summary of total aircraft flights for project alternatives ............................................................ 65

Table 17. Summary of Alpine Oil Field spills in gallons (October 2013 to March 2017) ......................... 69

Table 18. Geomorphic units in the GMT2 Project area .............................................................................. 70

Table 19. Paleontological sites located in GMT2 Project area ................................................................... 74

Table 20. Summary of drainage basins within the project area a

 ................................................................ 76

Table 21. Monthly temperature, precipitation, and snowfall summary ...................................................... 83

Table 22. Ambient air monitoring stations near the GMT2 Project area .................................................... 85

Table 23. Nuiqsut Monitoring Station background valuesa

 ........................................................................ 86

Table 24. National Ambient Air Quality Standards and Alaska Ambient Air Quality Standards values ... 87

Table 25. National Ambient Air Quality Standards and Alaska Ambient Air Quality Standards .............. 87

Table 26. Nearest interagency monitoring of protected visual environments monitors to project area ...... 88

Table 27. Nearest National Park Service units to project area for nitrogen critical loads .......................... 90

Table 28. Measured and estimated noise levels for noise sources similar to those existing in the GMT2 

Project area a

 ..................................................................................................................................... 101

Table 29. Study site information and characteristics of aircraft noise events recorded during the 2016 

Passive Acoustic Monitoring Projecta

 ............................................................................................... 104

Table 30. Duration of aircraft noise events measured at study sites during the 2016 Passive Acoustic 

Monitoring Project a

 .......................................................................................................................... 106

Table 31. Maximum levels of aircraft noise recorded during the 2016 Passive Acoustic Monitoring 

Project a

 ............................................................................................................................................. 107

Table 32. Summary of vegetation and wetland types in the project area.................................................. 112

Table 33. Fish species found in the GMT2 Project area and vicinity ....................................................... 115

Table 34. Colville Delta Special Area and NPR-A Study Area subareas in relation to the GMT2 Project 

study area .......................................................................................................................................... 118

Table 35. Common, scientific and Inupiaq names and status of avian species found in the Alpine Satellite 

Development Plan Area .................................................................................................................... 120

Table 36. Estimated density contours of glaucous gulls within the project area (2012–2015) ................. 123

Table 37. Estimated density contours of tundra swans within project study area (2012–2015) ............... 126

Table 38. Estimated density contours of brant within project study area (2012–2015) ............................ 128

Table 39. Estimated density contours of king eiders within project study area (2012–2015) .................. 130

Table 40. Estimated density contours of greater white-fronted goose within project study area (2012–

2015) ................................................................................................................................................. 131

Table 41. Estimated density contours of Canada goose within project study area (2012–2015) .............. 131

Table 42. Estimated density contours for yellow-billed loons on the Arctic Coastal Plain (2012–2015) 134
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Alpine Satellite Development Plan for the Proposed Greater Mooses Tooth 2 Development Project

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Table 43. Terrestrial mammal species known or suspected to occur in the project area ..........................138

Table 44. Caribou forage habitats within the GMT2 Project area ............................................................142

Table 45. Marine mammals that are reported to occur along the coast of Harrison Bay, in the Colville 

River Delta, or in the Beaufort Sea offshore north of the GMT2 Project area (not threatened, 

endangered, or candidate species).....................................................................................................147

Table 46 Threatened, endangered, or candidate species documented or potentially occurring in or near the 

GMT2 Project area............................................................................................................................149

Table 47. Estimated density contours of spectacled eider within the project study area (2012–2015) ....151

Table 48. Ancestral cultures of the NPR-A ..............................................................................................158

Table 49. Regional history synopsis.........................................................................................................162

Table 50. Cultural sites located in the GMT2 area of potential effect......................................................165

Table 51. 2015 North Slope Borough resident employment by industry..................................................173

Table 52. 2010 Total employment by employer, Nuiqsut ........................................................................175

Table 53. City of Nuiqsut fiscal year 2018 Projected Revenues...............................................................176

Table 54. Community of Nuiqsut data sources, subsistence and traditional land uses.............................184

Table 55. Nuiqsut annual cycle of subsistence activities..........................................................................190

Table 56. Nuiqsut travel method by subsistence resource ........................................................................192

Table 57. Average resource contribution over all available study years, Nuiqsut....................................194

Table 58. Average percentage of Nuiqsut households attempting harvests, all available study years.....195

Table 59. Average percentage of Nuiqsut households receiving resource, all available study years.......196

Table 60. Combined material and cultural importance.............................................................................198

Table 61. Use areas overlapping project study area by resource category a

..............................................199

Table 62. Sources of Project-Specific Subsistence Use Area Information, Project Area for Construction

..........................................................................................................................................................200

Table 63. Sources of Project-Specific Subsistence Use Area Information, Project Area for Drilling & 

Operations.........................................................................................................................................201

Table 64. Percent of Nuiqsut Harvesters Using Project Area for Construction, Overland Use Areas Only

..........................................................................................................................................................201

Table 65. Percent of Nuiqsut Harvesters Using Project Area for Drilling & Operations, Overland Use 

Areas Only ........................................................................................................................................202

Table 66. Nuiqsut months of use in project study area1

, overland use areas only ....................................217

Table 67. Percent of caribou harvested in the project study area..............................................................222

Table 68. Food security indicators in the North Slope Borough, 2010.....................................................232

Table 69. Ethnic composition of Nuiqsut compared with State of Alaska ...............................................234

Table 70. Major project components of the action alternatives................................................................238

Table 71. Summary of discharge estimates for Alternative A..................................................................253

Table 72. Potential altered inundation area by new infrastructure for Alternative A...............................253

Table 73. Summary of discharge estimates for Alternative B ..................................................................254

Table 74. Potential altered inundation area by new infrastructure for Alternative B ...............................254

Table 75. Potential altered inundation area by new infrastructure for Alternative C ...............................254

Table 76. Summary of major components potentially impacting hydrologya

...........................................259

Table 77. Summary of potential impact to water resources and mitigation measures a

............................261

Table 78. Likelihood of impacts; water resources....................................................................................263

Table 79. Summary of greenhouse gas emissions for GMT2 Project alternatives in carbon dioxide 

equivalents (tons per year)................................................................................................................265

Table 80. Prevention of significant deterioration increments for Class II areas.......................................268

Table 81. Acute, chronic, and cancer risk thresholds for hazardous air pollutants...................................269

Table 82. Class II areas of concern...........................................................................................................270

Table 83. GMT2 Project Alternative A criteria and hazardous air pollutant emissions summary ...........272

Table 84. GMT2 Project Alternative A near-field criteria pollutants impacts summary (μg/m3

) ............273
Supplemental Environmental Impact Statement

Alpine Satellite Development Plan for the Proposed Greater Mooses Tooth 2 Development Project

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Table 85. GMT2 Project Alternative A Near Field Criteria Pollutants Impacts Summary at the Nuiqsut 

Community Receptor (μg/m3

) ........................................................................................................... 273

Table 86. GMT2 Project Alternative A prevention of significant deterioration increments for Class II 

Areas ................................................................................................................................................. 274

Table 87. GMT2 Project Alternative A near-field hazardous air pollutant impacts summary (μg/m3

) .... 274

Table 88. GMT2 Project Alternative A Near Field Hazardous Air Pollutant Impacts Summary at the 

Nuiqsut Community Receptor (μg/m3

) ............................................................................................. 275

Table 89. GMT2 Project Alternative A air quality impacts at the Arctic National Wildlife Refuge ........ 276

Table 90. GMT2 Project Alternative A air quality impacts at Gates of the Arctic National Park and 

Preserve ............................................................................................................................................. 276

Table 91. GMT2 Project Alternative A deposition impacts ..................................................................... 277

Table 92. GMT2 Project Alternative A visibility impacts ........................................................................ 277

Table 93. GMT2 Project Alternative B criteria and hazardous air pollutant emissions summary............ 278

Table 94. GMT2 Project Alternative C criteria and hazardous air pollutant emissions summary............ 281

Table 95. GMT2 Project Alternative C near-field criteria pollutants impacts summary (μg/m3

)............. 282

Table 96. GMT2 Project Alternative C Near Field Criteria Pollutants Impacts Summary at the Nuiqsut 

Community Receptor (μg/m3

) ........................................................................................................... 282

Table 97. GMT2 Project Alternative C prevention of significant deterioration increments for Class II 

Areas ................................................................................................................................................. 283

Table 98. GMT2 Project Alternative C near-field hazardous air pollutant impacts summary (μg/m3

) .... 283

Table 99. GMT2 Project Alternative C Near Field Hazardous Air Pollutant Impacts Summary at the 

Nuiqsut Community Receptor (μg/m3

) ............................................................................................. 284

Table 100. GMT2 Project Alternative C air quality impacts at the Arctic National Wildlife Refuge ...... 285

Table 101. GMT2 Project Alternative C air quality impacts at Gates of the Arctic National Park and 

Preserve ............................................................................................................................................. 285

Table 102. GMT2 Project Alternative C deposition impacts .................................................................... 286

Table 103. GMT2 Project Alternative C visibility impacts ...................................................................... 286

Table 104. Maximum construction emissions for each GMT2 Alternative (Year 2) ............................... 292

Table 105. Maximum developmental drilling emissions for each GMT2 Alternative (Year 3) ............... 292

Table 106. Maximum infill drilling emissions for each GMT2 Alternative (Year 4) .............................. 293

Table 107. Maximum routine operations emissions for Each GMT2 Alternative .................................... 293

Table 108. Relative audibility of project-related noise levels in relation to different ambient sound levels

 .......................................................................................................................................................... 295

Table 109. Estimated project-related noise levels (in dBA, unless otherwise noted) received at Nuiqsut

and at distances 1 to 10 miles from the noise sourcea

 ....................................................................... 297

Table 110. Estimated levels of aircraft noise (dBA) received at the ground surface at distances 0 to 10 

miles from the ground trace of the flight path a

 ................................................................................ 301

Table 111. Summary of major components potentially impacting the acoustical environment and noisesensitive receptors a

 ........................................................................................................................... 304

Table 112. Total greenhouse gas emissions for each action alternative ................................................... 307

Table 113. Energy substitutions for GMT2 Project .................................................................................. 311

Table 114: GMT2 Oil Production As A Percentage of North Slope, Alaska and U.S. Crude Oil Production

 .......................................................................................................................................................... 313

Table 115. Acreage of direct impacts of construction on vegetation and wetlands for action alternatives

 .......................................................................................................................................................... 318

Table 116. Acreage of Indirect impacts of construction on vegetation and wetlands for action alternatives

 .......................................................................................................................................................... 321

Table 118. Comparison of impacts by alternative and project phase........................................................ 332

Table 119. Direct impacts to potential high-value bird habitat types from GMT2 infrastructure within the 

GMT2 Project area ............................................................................................................................ 341
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Table 120. Indirect impacts to potential high-value bird habitats within the project study area (300-foot 

zone of influence) ............................................................................................................................. 342

Table 121. Area of potential high-value bird habitats impacted at the Arctic Slope Regional Corporation 

Mine site for all action alternatives ................................................................................................... 343

Table 122. Estimated direct impacts of action alternatives to potential caribou-use habitats ................... 358

Table 123. Estimated indirect (300-foot zone) impacts of action alternatives to potential caribou-use ... 358

Table 124. Likelihood of impacts, terrestrial mammals ........................................................................... 361

Table 125. Indirect impacts to potential high-value habitats of spectacled eider within the project study 

area (300-foot zone of influence) ...................................................................................................... 363

Table 126. AHRS and TLUI sites within GMT2 Project .......................................................................... 374

Table 127. Code counts for Nuiqsut residents’ testimony on oil development ........................................ 387

Table 128. Top code occurrences for the April 2018 Nuiqsut public meeting on the Draft GMT2 SEIS 399

Table 129. Projected crude oil production; Alpine, total Alaska North Slope, GMT2 ............................. 403

Table 130. Operations manpower requirements for GMT2 production pad ............................................. 404

Table 131. Comparison of estimated capital expenditures, royalties, and taxes (billions, in 2015 dollars) 

by alternative ..................................................................................................................................... 406

Table 132. Land ownership ....................................................................................................................... 409

Table 133. Caribou Hunting Trip Duration, Study Years 1-8 a

 ................................................................ 422

Table 134. Caribou Hunting Number of Trips, Study Years 1-8 a

 ............................................................ 423

Table 135. Changes in Harvest Activities, Years 1-8 a

 ............................................................................. 423

Table 136. Percent of Nuiqsut Harvesters using Construction Area of Potential Effect a ......................... 427

Table 137. Percent of Nuiqsut Harvesters using Drilling and Operation Area of Potential Effecta

 ......... 432

Table 138. Travel Method Used to Access Caribou Use Areas, SRB&A Caribou Subsistence Monitoring 

Reports .............................................................................................................................................. 433

Table 139. Summary of resource/issues time frame and geographic scope.............................................. 485

Table 140. Past, Present and Reasonably Foreseeable Future Developments .......................................... 487

Table 141. Reasonably foreseeable development sources included in GMT1 and GMT2 cumulative 

impacts analysis ................................................................................................................................ 498

Table 142. Tiering analysis calculated ratios ............................................................................................ 498

Table 143. Cumulative air quality impacts at Alaska National Wildlife Refuge ...................................... 499

Table 144. Cumulative air quality impacts at Gates of the Arctic ............................................................ 499

Table 145. Cumulative visibility impacts ................................................................................................. 500

Table 146. Cumulative deposition impacts ............................................................................................... 500

List of Figures

Figure 1. Nuiqsut Monitoring Station, 2011–2015 wind rose .................................................................... 84

Figure 2. Visibility data for Gates of the Arctic National Park (IMPROVE Monitor ID: GAAR1) .......... 89

Figure 3. Visibility data for Denali National Park (IMPROVE Monitor ID: DENA1) .............................. 89

Figure 4. Ammonium ion wet deposition, Poker Creek (NTN AK01), Denali National Park (NTN AK03), 

and Gates of the Arctic National Park (NTN AK06) .......................................................................... 92

Figure 5. Nitrate ion wet deposition, Poker Creek (NTN AK01), Denali National Park (NTN AK03), and 

Gates of the Arctic National Park (NTN AK06) ................................................................................. 93

Figure 6. Sulfate ion wet deposition, Poker Creek (NTN AK01), Denali National Park (NTN AK03), and 

Gates of the Arctic National Park (NTN AK06) ................................................................................. 94

Figure 7. Sulfate ion, nitrate ion, ammonium ion dry deposition, Denali National Park (DEN427) .......... 96

Figure 8. Mercury deposition, Gates of the Arctic National Park (MDN AK06) ....................................... 97

Figure 9. Monitoring data collection sites .................................................................................................. 98

Figure 10. Generalized ranges for the Teshekpuk Caribou Herd and Central Arctic Herd Ranges in 

Relation to the GMT2 Project Area. ................................................................................................. 139
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Figure 11. Location of the Alpine Satellite Development Plan Caribou Monitoring Study Area 

(2001−2017) ...................................................................................................................................... 141

Figure 14. Nuiqsut contemporary subsistence use areas, all resources ..................................................... 186

Figure 15. Nuiqsut caribou subsistence use areas, 2008–2016 ................................................................. 187

Figure 16. Nuiqsut historic and lifetime subsistence use areas, all resources ........................................... 188

Figure 17. Nuiqsut number of subsistence resource categories by month ................................................ 191

Figure 18. Nuiqsut number of subsistence resource categories by travel method .................................... 191

Figure 19. All resources subsistence use areas in the project study area, 1995–2006 .............................. 204

Figure 20. Caribou subsistence use areas in the project study area, 1995–2006 ...................................... 205

Figure 21. Caribou subsistence use areas in the project study area, 2008–2016 ...................................... 206

Figure 22. Wolf and wolverine subsistence use areas in the project study area, 1995–2006 ................... 207

Figure 23. Geese subsistence use areas in the project study area, 1995–2006 ......................................... 208

Figure 24. Eider subsistence use areas in the project study area, 1995–2006 ........................................... 209

Figure 25. Burbot subsistence use areas in the project study area, 1995–2006 ........................................ 210

Figure 26. Arctic cisco subsistence use areas in the project study area, 1995–2006 ................................ 211

Figure 27. Broad whitefish subsistence use areas in the project study area, 1995–2006 .......................... 212

Figure 28. Overland all resources subsistence use areas by month in project study area, 1995–2006 ..... 215

Figure 29. Overland caribou subsistence use areas by month in project study area, 1995–2006 ............. 216

Figure 30. Overland caribou subsistence use areas by month in project study area, 2008–2016 ............. 216

Figure 31. All resources subsistence use areas by method of transportation in project study area .......... 218

Figure 32. Caribou subsistence use areas by method of transportation in project study area ................... 218

Figure 33. Travel method by month in project study area, caribou only .................................................. 219

Figure 34. Nuiqsut travel routes ................................................................................................................ 220

Figure 35. Per capita pounds harvested for key resources, all study years ............................................... 221

Figure 36. Harvesting and attempting to harvest for key resources, all study years ................................. 223

Figure 37 Percent of households using and receiving key resources, all study years ............................... 224

Figure 38. GMT2 Project Location (Black Star), Gates of the Arctic National Park and Preserve 

Receptors, Arctic National Wildlife Refuge Receptors, Meteorological Data Region (4km Weather 

Research and Forecast), Far-Field Air Modeling Region (CALPUFF Domain) .............................. 270

Figure 40. Counts by Code Family ........................................................................................................... 389

Figure 41. Nuiqsut contemporary subsistence use areas, all resources, and GMT2 Construction Project 

Study Area ........................................................................................................................................ 424

Figure 42. ConocoPhillips’ leases in the NPR-A ...................................................................................... 550
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Alpine Satellite Development Plan for the Proposed Greater Mooses Tooth 2 Development Project

xiii

Acronyms

μg/m3 micrograms/cubic meter

°F degrees Fahrenheit

AAC Alaska Administrative Code

AS Alaska Statute

ADEC Alaska Department of Environmental Conservation

ADF&G Alaska Department of Fish and Game

ADNR Alaska Department of Natural Resources

Anadarko Anadarko E&P Onshore, LLC

ANCSA Alaska Native Claims Settlement Act

ANILCA Alaska National Interest Lands Conservation Act

APF Alpine Central Processing Facility

ASDP Alpine Satellite Development Project

ASRC Arctic Slope Regional Corporation

ATV all-terrain vehicle

BLM Bureau of Land Management

BMP best management practice

BOEM Bureau of Ocean Energy Management (DOI) 

CAH Central Arctic Herd (caribou)

CD Colville Delta

CEQ Council on Environmental Quality

CFR Code of Federal Regulations

CO carbon monoxide

CO2 carbon dioxide

ConocoPhillips ConocoPhillips Alaska, Inc.

Corps U.S. Army Corps of Engineers (DoD)

cy cubic yards

DNA Determination of NEPA Adequacy; can also mean deoxyribonucleic acid as a

carrier of genetic information

DOI Department of the Interior, U.S. Department of the Interior

EA environmental assessment

EIS environmental impact statement

EO Executive order

EPA U.S. Environmental Protection Agency 

FAA Federal Aviation Administration

FLPMA Federal Land Policy and Management Act

FLIR forward looking infrared

GHG greenhouse gases (e.g., carbon dioxide [CO2], methane, nitrous oxide)

GIS Geographic Information System 

GMT Greater Mooses Tooth

GMT1 Greater Mooses Tooth 1

GMT2 Greater Mooses Tooth 2

GPS global positioning system

IAP integrated activity plan

ICAS Iñupiat Community of the Arctic Slope 

IM Instructional Memorandum

MG million gallons

MMS Minerals Management Service

MPH miles per hour

MW megawatt

MWe megawatt electrical

NEPA National Environmental Policy Act

NMFS National Marine Fisheries Service
Supplemental Environmental Impact Statement

Alpine Satellite Development Plan for the Proposed Greater Mooses Tooth 2 Development Project

xiv

NO2 nitrogen dioxide

NOA Notice of Availability (Federal Register)

NOAA National Oceanic and Atmospheric Administration

NOI Notice of Intent (Federal Register)

NPR-A National Petroleum Reserve in Alaska

NPRPA Naval Petroleum Reserves Production Act

NPS National Park Service

NSB North Slope Borough 

NVN Native Village of Nuiqsut

OHV off-highway vehicle

Pb lead

PCB polychlorinated biphenyl

Pet-4 Naval Petroleum Reserve #4

PM10 particulate matter <10 microns

PM2.5 particulate matter <2.5 microns

ppb parts per billion

ppm parts per million

RMP resource management plan

ROD record of decision

SO2 sulfur dioxide

SRB&A Stephen R. Braund & Associates

TCH Teshekpuk Caribou Herd

UM Umiat Meridian

USC United Sates Code

USEPA U.S. Environmental Protection Agency (for reference as author)

USFWS U.S. Fish and Wildlife Service

USGS U.S. Geological Survey

VOC volatile organic compounds

VRM Visual Resource Management

WAH Western Arctic Herd (caribou)
Supplemental Environmental Impact Statement

Alpine Satellite Development Plan for the Proposed Greater Mooses Tooth 2 Development Project

1 

Chapter 1. Introduction

In August 2015, ConocoPhillips Alaska, Inc. (ConocoPhillips), as operator and working interest owner in 

the Greater Mooses Tooth Unit (GMT Unit), filed an application with the Bureau of Land Management 

(BLM) for a permit to drill to develop hydrocarbon resources of the GMT Unit from a surface location on 

a federal oil and gas lease in the National Petroleum Reserve in Alaska (NPR-A). The proposed Greater 

Mooses Tooth 2 Development Project (GMT2 Project) includes a drill site on federally managed land in 

the GMT Unit, access road and pipelines on federal and private land in the NPR-A, and a pipeline and 

pipe rack on private and state lands outside the NPR- The GMT2 drill site, formerly known as Colville 

Delta 7 (CD7) development production pad, is one of the five drill sites composing the Alpine Satellite 

Development Plan for which the BLM, U.S. Department of the Interior (DOI), prepared a final 

environmental impact statement (EIS). The 2004 Alpine Satellite Development Plan Record of Decision 

approved issuance of the BLM authorizations needed for development of the satellites(online at: 

https://www.blm.gov/programs/planning-and-nepa/plans-in-development/alaska).

The currently proposed GMT2 Project is similar to that approved for permitting in the 2004 Alpine 

Satellite Development Plan Record of Decision, and evaluated in the 2012 NPR-A Integrated Activity 

Plan EIS and Greater Mooses Tooth 1 (GMT1) Supplemental EIS (online at: 

https://www.blm.gov/programs/planning-and-nepa/plans-in-development/alaska), with changes that 

reduce the overall impact. These changes include removing the drill site location from the Colville River 

Special Area, and reducing the road and pipeline length, thereby reducing the amount of fill and 

associated impacts to wetlands. 

This supplemental EIS will assist the BLM and other federal, state, and North Slope Borough agencies in 

evaluating ConocoPhillips’s permit applications for this project. This supplemental EIS considers new 

information or circumstances, including changes to the proposed GMT2 project arising since its impacts 

were analyzed in the BLM 2004 Alpine Satellite Development Plan Final EIS and the BLM 2012 NPR-A 

Integrated Activity Plan (IAP/EIS). The supplemental EIS re-analyzes the proposed project in light of the 

new information and circumstances in accordance with the requirements of NEPA (42 United States Code 

[USC] 4321, et seq.) as implemented by Council on Environmental Quality regulations (40 Code of 

Federal Regulations [CFR] 1500-1508). 

1.1 Project Location and Land Status 

The proposed GMT2 Project is located on the “North Slope” of Alaska’s Brooks Range within the NPRA, west of the Colville River Delta. The proposed GMT2 pad is wholly on federally managed lands 

within the northeastern portion of the NPR-A. The proposed road and pipeline corridors cross both 

federally managed lands and private lands held by the Kuukpik Corporation (Nuiqsut Village 

Corporation) within the NPR-A (Map 1.1-1). The northern portion of the pipeline corridor between CD1 

and CD4 North (an area of intersecting pipeline segments north of CD4 known as CD4N) is on State of 

Alaska, 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. Gravel for the project 

will be obtained from the Native-owned Arctic Slope Regional Corporation mine site. None of the 

proposed project facilities are located on or near Native allotments. However, there is one Native 

allotment within the planning area outside of the NPR-A (see Section 4.4.5). 

The 2008 Greater Mooses Tooth Unit Agreement (BLM 2008b, No. AA-087852) was entered into by 

ConocoPhillips, Anadarko, and Arctic Slope Regional Corporation, and approved by the BLM. The Arctic 

Slope Regional Corporation has applied for subsurface estate within the GMT Unit for lands selected by 

Kuukpik Corporation under the Alaska Native Claims Settlement Act, 43 USC 1601 et seq., and Section 
Supplemental Environmental Impact Statement

Alpine Satellite Development Plan for the Proposed Greater Mooses Tooth 2 Development Project

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1431(o) of the Alaska National Interest Lands Conservation Act. The GMT Unit was expanded in 

September 2009 to include leases east of the original unit area.

The GMT Unit agreement identifies notional “participating area” boundaries (Map 1.1-1). These 

boundaries delineate the leases or areas of leases (tracts) that are expected to contribute a portion of the 

production from each reservoir to the agreement. For the GMT2 Project, where only exploration drilling 

has occurred at this point, these boundaries represent a theoretical interpretation of the reservoir locations.

As geophysical data are evaluated, exploration and production wells are drilled, and the physical extents 

of each reservoir are discovered, enough information is collected to reasonably determine which leases 

should be included in a participating area. The BLM uses these boundaries to allocate production for 

royalties to each committed tract within the participating area. Royalties are calculated using the 

allocation method agreed to in the unit agreement (see 43 CFR Section 3131.81). 

The Arctic Slope Regional Corporation has assumed administration of some leases on Kuukpik land in 

the NPR-A pursuant to 43 CFR 3135.1-8(b). In accordance with 43 CFR 3135.1-8(c), the lease terms and 

conditions continue to apply to the lessee. However, only Arctic Slope Regional Corporation (as the new 

lessor) may enforce the lease stipulations on the conveyed lands—the BLM no longer has jurisdiction to 

do so. The BLM remains the land manager and lessor on lands that have been selected but not conveyed, 

and thus the BLM continues to enforce the lease stipulations and best management practices on such 

lands. While the BLM best management practices only apply on BLM-managed lands (including selected 

lands), the new landowner of conveyed lands (Arctic Slope Regional Corporation or Kuukpik 

Corporation) may adopt best management practices similar to or the same as those required by the BLM 

on lands that the BLM manages.

1.2 History of Operations in the Area 

In 1923, Executive Order 3797 created the 23-million-acre Naval Petroleum Reserve Number 4 to protect 

a future oil supply for the Navy. In 1976, the Naval Petroleum Reserves Production Act transferred 

management of the area to the Secretary of the Interior and renamed Pet-4 as the NPR-A. In 1980, 

Congress authorized petroleum production in the NPR-A, and directed the Department of the Interior to 

undertake “an expeditious program of competitive leasing of oil and gas” in the Reserve (P.L. 96-514). 

Several lease sales were held in the early 1980s, and one exploration well was drilled. 

Interest in leasing within the NPR-A lagged until the mid-1990s, when development on adjacent state 

lands made exploration in the NPR-A an economically feasible option. To pursue this renewed interest, 

the BLM developed an integrated activity plan and associated environmental impact statement, assessing 

potential use of the Northeast NPR-A for oil development. The integrated activity plan/ environmental 

impact statement was completed in August 1998, with a record of decision signed in October 1998, 

making approximately 87 percent (4 million acres) of the Northeast planning area available for oil and gas 

leasing. Lease AA-081800 was issued under the 1998 record of decision and included numerous 

stipulations to protect habitat, subsistence use areas, and other resources in the planning area. 

ConocoPhillips’s first exploration program under leases obtained from the 1998 lease sale included the 

Lookout Prospect. The BLM authorized exploration based on a program-specific environmental 

assessment (EA) (BLM 2000) tiered to the 1998 integrated activity plan/EIS. Results of exploration 

indicated that developable reserves exist at Lookout. Lookout was subsequently planned for development 

as a satellite of ConocoPhillips’s Alpine Development Project (Alpine Development Plan) in the Colville 

River Unit and the associated drill site was named CD6. The Alpine Development Plan began with 

construction of the Alpine CD1 and CD2 drilling sites and associated facilities. Oil production from CD1 

commenced in November 2000 and from CD2 in November 2001. 
Supplemental Environmental Impact Statement

Alpine Satellite Development Plan for the Proposed Greater Mooses Tooth 2 Development Project

3 

In total, the Alpine Satellite Development Plan included five satellite developments (CD3 through CD7) 

as potential extensions of the Alpine Development Plan. These satellites were planned to bring 3-phase 

(oil, water, and gas) hydrocarbon production to the Alpine Central Processing Facility at CD1 for 

processing and transport via the existing Alpine Central Processing Facility and Kuparuk common carrier 

oil pipelines to the Trans-Alaska Pipeline System.

In January 2003, the BLM and cooperating agencies (U.S. Army Corps of Engineers, the U.S. 

Environmental Protection Agency [EPA], the U.S. Coast Guard, the State of Alaska, and the North Slope 

Borough) initiated the Alpine Satellite Development Plan EIS for the five proposed drill sites. The final 

EIS was issued in September 2004. In November 2004, the Secretary of the Interior issued a record of 

decision that approved the two satellites on federally managed lands (CD6 and CD7). The CD3 site was 

subsequently constructed on State of Alaska lands and CD4 was constructed on Kuukpik Corporation 

land. Production began at those sites in 2006. After a lengthy permit review, including relocation of the 

Nigliq Channel Bridge and adjustment of the road and pad to conform to the new bridge location, the U.S. 

Army Corps of Engineers issued a permit for CD5 development on Kuukpik Corporation land, which 

began operation in 2015. The BLM issued a February 2015 record of decision for the GMT1 Project, and 

laid the first gravel for the construction of GMT1 in February 2017. The GMT2 Project is contingent on 

the construction of GMT1. 

While the CD5 approval was in process, it was established that the two satellites on federally managed 

land (CD6 and CD7) were not located in the same reservoir as CD1, CD2, CD3, CD4, and CD5. As a 

result, ConocoPhillips asked the BLM to designate and approve the proposed unit area so ConocoPhillips 

could perform exploration and development operations in an efficient and logical manner under a unit 

plan of development. The CD6 satellite was renamed “GMT1” and CD7 was renamed “GMT2” after it 

was determined that these sites would not be part of the Colville River Unit and would be in the newly 

established GMT Unit. 

1.3 Purpose and Need for the Project 

The purpose of the proposed GMT2 Project is to construct a drill site, access road, pipelines, and ancillary 

facilities to support development and transportation of petroleum reserves from the GMT2 production 

pad, while protecting important surface resources. The project will produce 3-phase hydrocarbons (oil, 

gas, and water) that will be carried by pipeline to the Alpine Central Processing Facility at CD1(Alpine 

Central Processing Facility/CD1). Sales quality crude oil produced at Alpine Central Processing 

Facility/CD1 will be transported from CD1 via the existing Alpine Sales Oil Pipeline and Kuparuk 

Pipeline to the Trans-Alaska Pipeline for shipment to market. 

Under the Naval Petroleum Reserves Production Act, the Secretary is required to conduct oil and gas 

leasing and development in the NPR-A (42 USC Section 6506a). The Department of the Interior and 

Related Agencies’ Fiscal Year 1981 Appropriations Act specifically directs the Secretary to undertake “an 

expeditious program of competitive leasing of oil and gas” in the Petroleum Reserve. The GMT2 Project 

helps satisfy the purpose to develop oil and gas resources in the NPR-A. Specifically, the Naval 

Petroleum Reserves Production Act, as amended, encourages oil and gas leasing in the NPR-A while 

requiring protection of important surface resources and uses. EO 13212 (May 2001) directs federal 

agencies to give priority to energy-related projects:

For energy-related projects, agencies shall expedite their review of permits or take other actions as 

necessary to accelerate the completion of such projects, while maintaining safety, public health, 

and environmental protections.

The Naval Petroleum Reserves Production Act provides that the Secretary “shall assume all 

responsibilities” for “any activities related to the protection of environmental, fish and wildlife, and 
Supplemental Environmental Impact Statement

Alpine Satellite Development Plan for the Proposed Greater Mooses Tooth 2 Development Project

4 

historical or scenic values” [42 USC Section 6503(b)] and authorizes the Secretary to “promulgate such 

rules and regulations as he deems necessary and appropriate for the protection of such values within the 

reserve.”

Development and production of hydrocarbons from GMT2 will help offset declines in production from 

Alaska’s North Slope. Development will also provide benefits to local, state, and national economies 

through local hire for jobs created during construction and operations, tax revenues, revenue sharing, 

royalties, and new resources to help meet U.S. domestic energy demand.

1.4 Purpose and Need for Federal Action 

The Council on Environmental Quality regulations direct that an EIS “shall briefly specify the underlying 

purpose and need to which the agency is responding ...” (40 CFR 1502.13). The agency purpose and need 

for action triggers the NEPA analysis, and dictates the range of alternatives. It further provides the 

rationale for eventual selection of an alternative and a decision (BLM 2008c). This document brings 

together the evaluation needs of the BLM, U.S. Army Corps of Engineers, and other federal agencies. 

The need for the action is established by the federal agencies’ responsibilities under various federal 

statutes, including the Naval Petroleum Reserves Production Act and the Clean Water Act; and to respond 

to ConocoPhillips’s requests for drilling permits, a fill material discharge permit, and other related 

authorizations to develop and produce petroleum in the GMT Unit. 

This document analyzes the No Action Alternative (Alternative D in Chapter 2, Proposed Project and 

Alternatives), but the Naval Petroleum Reserves Production Act requires the BLM to issue a permit and

this alternative would not be selected. However, the No Action Alternative provides a baseline for the 

affected environment and for action alternative analysis. CEQ regulations also direct that the BLM must 

include a description of the No Action Alternative (40 CFR 1502.14(d)). Thus, while the No Action 

Alternative will not be selected, CFR regulations state that it must still be analyzed in the EIS. 

Under the No-Action Alternative, the current conditions and expected future condition in the absence of 

the project are evaluated. ConocoPhillips’s application for permit to drill, application for discharge into 

waters of the U.S., and related authorizations would not be approved. The No-Action Alternative does 

assume continuing exploration work as required under the GMT Unit Agreement; the alternative also 

assumes permitted studies in the NPR-A would continue, with continued use of aircraft in the project 

vicinity. The No-Action alternative further assumes that the GMT1 Project would be constructed and 

operated, since that authorization is independent of the proposed project. 

Further information on the No-Action Alternative is provided in Chapter 2 under Section 2.8. 

1.4.1 Support for Federal Decisions

In proposing to undertake an action (e.g., issue a permit), federal agencies are required under NEPA to 

analyze the reasonably foreseeable probable environmental impacts from a proposed project and a 

reasonable range of alternatives, including a decision to take no action. If more than one federal agency is 

involved in a related action, a single NEPA document may be developed to meet the requirements of all 

federal agencies. Typically, as with this project, one agency is designated as the lead agency, with other 

agencies serving as cooperating agencies. 

1.4.2 Laws, Regulations, and Permits

Requirements of federal, state, and local laws and regulations associated with development activities in 

the NPR-A were discussed in detail in the Alpine Satellite Development Plan Final EIS (2004, Section 
Supplemental Environmental Impact Statement

Alpine Satellite Development Plan for the Proposed Greater Mooses Tooth 2 Development Project

5 

1.1.3–1.1.4) and the NPR-A Integrated Activity Plan/EIS (2012, Section 1.8–1.9), which are incorporated 

by reference. A summary is provided below. 

Comprehensive planning and management of oil and gas leasing, exploration, and future development in 

the NPR-A have been addressed in a series of documents. These include the NPR-A Final Environmental 

Assessment Federal Oil and Gas Lease Sale (BLM 1981); Final EIS for Oil and Gas Leasing and 

Development in the NPR-A (BLM 1983); Northeast National Petroleum Reserve Alaska Integrated 

Activity Plan/EIS (BLM 1998b); Northeast NPR-A Final Amended Integrated Activity Plan/EIS (BLM 

2005); Northeast National Petroleum Reserve-Alaska Final Supplemental Integrated Activity Plan/EIS 

(BLM 2008); and NPR-A Final Integrated Activity Plan/EIS (BLM 2012). 

1.4.2.1 Lead and Cooperating Agency Authorities 

The BLM. As the federal land manager of the NPR-A, the BLM is responsible for land-use 

authorizations on federal lands in the NPR-A. Upon completion of the supplemental EIS process, the 

BLM will make decisions regarding ConocoPhillips’s proposal. The authority for management of the land 

and resource development options in the supplemental EIS comes from several statutes including NEPA; 

the Federal Land Policy and Management Act; the Federal Oil and Gas Royalty Management Act of 1982; 

the Naval Petroleum Reserves Production Act of 1976, as amended; Department of the Interior 

Appropriations Act Fiscal Year 1981 (P.L. 96-514), amending the Naval Petroleum Reserves Production 

Act; and Title VIII of the Alaska National Interest Lands Conservation Act. These BLM authorities are 

further described below.

• NEPA sets out policy and provides the means by which the federal government, including the BLM 

and the federal cooperating agencies, examines major federal actions that may have significant 

impacts on the environment, such as the authorization of oil and gas development contemplated in 

this supplemental EIS (42 USC Section 4231 et seq.). 

• Under the Federal Land Policy and Management Act, 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 USC Section 1732). In 

accordance with the Federal Land Policy and Management Act, the BLM manages its lands and their 

uses to ensure healthy and productive ecosystems.

• The proposed action helps satisfy the purpose of the Naval Petroleum Reserves Production Act to 

explore and develop oil and gas resources in the NPR-A. Specifically, the Naval Petroleum Reserves 

Production Act, as amended, requires oil and gas leasing in the NPR-A while also requiring protection 

of important surface resources and uses.

• The Naval Petroleum Reserves Production Act provides the Secretary of the Interior with the 

authority to: protect “environmental, fish and wildlife, and historical or scenic values” in the Reserve 

[42 USC Section 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 USC Section 6506a(b)].

• Title VIII of Alaska National Interest Lands Conservation Act establishes procedures for federal land 

management agencies to evaluate impacts on subsistence uses and needs and means to reduce or 

eliminate such impacts on federally managed lands (16 USC Section 3120). 

Department of the Interior Secretarial Orders 

The Secretary of the Interior issued four Secretarial Orders during the development of GMT2 that 

potentially impacted the Environmental Effects section in Chapter 4 of this supplemental EIS. These 

Secretarial Orders were issued from March to December 2017, and required revisiting the analysis in 
Supplemental Environmental Impact Statement

Alpine Satellite Development Plan for the Proposed Greater Mooses Tooth 2 Development Project

6 

regards to mitigation, climate change, and greenhouse gases. The Secretarial Orders, in chronological 

order of issuance, are presented below. Each was given consideration as to its potential effect on the 

analysis in the EIS. These Secretarial Orders can be viewed in their entirety online in the DOI Library at 

https://www.doi.gov/elips/browse. 

Secretarial Order 3349

Secretarial Order 3349, issued on March 29, 2017, directed the DOI to, under Executive Order 13783 k- 

“Promoting Energy Independence and Economic Growth,” (March 28, 2017) “review all existing 

regulations, orders, guidance documents, policies, and any other similar actions that potentially burden 

the development or utilization of domestically produced energy resources.” The Sec. Order revoked Sec. 

Order 3330, “Improving Mitigation Policies and Practices of the Department of the Interior,” and 

instructed that any action under Sec. Order 3330 must be reviewed for reconsideration, modification, or 

rescission. Among other presidential actions that Executive Order 13783 revoked:

• Executive Order 13653, “Preparing the United States for the Impacts of Climate Change”; 

• Presidential Memorandum of June 25, 2013, “Power Sector Carbon Pollution Standards”; and 

• Presidential Memorandum of November 3, 2015, “Mitigating Impacts on Natural Resources from 

Development and Encouraging Related Private Investment.” 

Secretarial Order 3352

Secretarial Order 3352, issued on May 31, 2017, directed the Assistant Secretary of Land and Minerals 

Management to “initiate a review and development of a revised IAP for the NPR-A, promoting an 

appropriate statutory balance of promoting development while protecting surface resources, and to issue 

an evaluation under the existing IAP to efficiently and effectively maximize tracts offered for sale during 

the next NPR-A lease sale.” 

The Secretarial Order in its entirety can be viewed at 'Secretarial Order 3352, in the DOI online Library'

Secretarial Order 3355

• Secretarial Order 3355 (August 31, 2017) was issued to implement Executive Order 13807 

“Establishing Discipline and Accountability in the Environmental Review and Permitting Process for 

Infrastructure Projects” (August 15, 2017). It set new page and timing limitation of no more than 150 

pages and no more than 12 months forthe development of EIS documents. After review by the 

Washington Office, it was determined that, due to having a Notice of Intent (NOI) published before 

Sec. Order 3355 was issued, this supplemental EIS is not subject to the new limitations on page and 

time lengths.

The Secretarial Order in its entirety can be viewed at 'Secretarial Order 3355, in the DOI online Library'. 

Secretarial Order 3360

• Secretarial Order 3360, issued on December 22, 2017, rescinded the following policies found to be 

inconsistent with Secretarial Order 3349, “American Energy Independence.” Departmental Manual 

Part 523, Chapter 1: Climate Change Policy, dated, December 20, 2012; 

• Departmental Manual Part 600, Chapter 6: Landscape-Scale Mitigation Policy, dated, October 23, 

2015; 

• Bureau of Land Management, Manual Section 1794 - Mitigation, dated, December 22, 2016; and, 

• Bureau of Land Management, Mitigation Handbook H-1794-1, dated, December 22, 2016. 
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The Secretarial Order further directed that the BLM Draft Regional Mitigation Strategy (RMS) for NPRA be revised consistent with EO 13783 and Secretarial Order 3349; and it directed the BLM to revise the 

IM No. 2008-204, which outlines policy for the use of offsite mitigation for BLM authorizations.

The Secretarial Order in its entirety can be viewed at 'Secretarial Order 3360, in the DOI online Library'. 

The U.S. Army Corps of Engineers. The U.S. Army Corps of Engineers has the authority to issue or 

deny permits for placement of dredge or fill material in the waters of the U.S., including wetlands (which 

incorporate the vast majority of the project study area) and for work and/or structures in, on, over, or 

under navigable waters of the U.S. Consequently, U.S. Army Corps of Engineers authority extends to 

ConocoPhillips’s entire proposal, regardless of who owns the land. These U.S. Army Corps of Engineers 

authorities are set forth as follows: 

• Under Section 404 of the Clean Water Act (33 USC Section 1251 et seq.), the U.S. Army Corps of 

Engineers regulates placement of dredge and fill material in waters of the U.S., including wetlands. 

The proposed project is located in an area that is entirely composed of wetlands that are within the 

U.S. Army Corps of Engineers’ jurisdiction. 

• In accordance with 33 CFR 332.1(c)(3), “compensatory mitigation for unavoidable impacts may be 

required to ensure that an activity requiring a section 404 permit complies with the Section 404(b)(1) 

Guidelines.” Pursuant to this authority, the U.S. Army Corps of Engineers can require compensatory 

mitigation calculated on the entire functional value of each acre of the direct project footprint, plus an 

additional multiple of lost functional value associated with impacts to the aquatic ecosystem 

surrounding the project footprint. 

• Under Section 10 of the Rivers and Harbors Act (33 USC Section 401), the U.S. Army Corps of 

Engineers has regulatory authority for work and structures performed in, on, over, or under navigable 

waters of the U.S. 

The EPA. The EPA authority to regulate oil and gas development is contained in the Clean Water Act (33 

USC Section 1251 et seq.), Clean Air Act (42 USC Section 7401 et seq.), and the Safe Drinking Water Act 

(42 USC Section 300f et seq.). Similar to the authority of the U.S. Army Corps of Engineers, the EPA’s 

authority extends to ConocoPhillips’s entire proposal, regardless of who owns the land. These authorities 

follow. 

• Under Section 402 of the Clean Water Act (33 USC Section 1251 et seq.), the EPA has delegated 

authority to the State of Alaska to issue permits for facilities operating within state jurisdiction of 

permits issued for the discharge of pollutants from a point source into waters of the U.S. for facilities, 

including oil and gas. Point-source discharges that require an Alaska Pollutant Discharge Elimination 

System permit include, but are not limited to, sanitary and domestic wastewater, gravel pit and 

construction dewatering, and hydrostatic test water, storm water discharges, etc. (40 CFR 122). 

• In accordance with Section 404 of the Clean Water Act (33 USC Section 1251 et seq.), the EPA 

reviews and comments on U.S. Army Corps of Engineers Section 404 permit applications for 

compliance with the Section 404(b)(1) guidelines and other statutes and authorities within its 

jurisdiction (40 CFR 230). 

• The Division of Water also issues Clean Water Act 401 certifications for Corps wetland permits under 

the Act’s Section 404. 

• Under the Safe Drinking Water Act (42 USC Section 300f et seq.), the EPA's responsibilities include 

the management of the Underground Injection Control program and the direct implementation of 

Class I and Class V injection wells in Alaska. These wells cover injection of non-hazardous and 

hazardous waste through a permitting process for fluids that are recovered from down hole, as well as 
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municipal waste, stormwater, and other fluids that did not come up from down hole (40 CFR 124A, 

40 CFR 144, 40 CFR 146). The EPA oversees the Class II program delegated to the State of Alaska 

that is managed by the Alaska Oil and Gas Conservation Commission, which includes Class II 

enhanced oil recovery, storage, and disposal wells that may receive non-hazardous produced fluids 

originating from down hole, including muds and cuttings (40 CFR 147). 

• Under Sections 165 and 502 of the Clean Air Act (42 USC Section 7401 et seq.), the State of Alaska 

is delegated authority to issue air quality permits for facilities operating within state jurisdiction for 

the Title V operating permit (40 CFR 70) and the “prevention of significant deterioration” permit (40 

CFR 52.21) to address air pollution emissions. The EPA maintains oversight authority of the State’s 

program. 

• Under Section 311 of the Federal Water Pollution Control Act of 1972, as amended (Clean Water Act, 

33 USC Section 1321, 40 CFR Part 112), the EPA requires a “spill prevention, control, and 

countermeasure plan” for oil storage containers with capacity 55 gallons or greater for facilities with 

over 1,320 gallons in aggregate oil storage container capacity. 

• Under the Clean Water Act as amended (Oil Pollution Act; 33 USC Chapter 40; FRP Rule; 40 CFR 

Part 112, Subpart D, Section 112.20–112.21) the EPA requires a “facility response plan” to identify 

and ensure the availability of sufficient response resources for the worst case discharge of oil to the 

maximum extent practicable, “...generally for facilities that transfer over water to or from vessels, 

and maintaining a capacity greater than 42,000 gallons, or any facility with a capacity of over one 

million gallons.” 

• 40 CFR parts 1500–1508 and Section 309 of the CAA (42 USC Section 7609): requires a review and 

evaluation of the draft and final EIS for compliance with Council on Environmental Quality 

guidelines. 

The U.S. Fish and Wildlife Service (USFWS). The USFWS statutory responsibilities include 

enforcement of the Endangered Species Act (as applied to certain marine mammal and bird species 

subject to the Act). Specifically, the USFWS provides consultation (recommendation) as required under 

Section 7 of the Act. The USFWS also provides consultation regarding impacts to fish and wildlife 

resources under the Fish and Wildlife Coordination Act.

The Bureau of Ocean Energy Management. The Bureau of Ocean Energy Management’s Office of 

Environmental Programs conducts NEPA analyses and gathers compliance documents for each major 

stage of energy development planning related to offshore oil and gas development. Bureau of Ocean 

Energy Management will not issue permits associated with this project; however, the Bureau provided 

subject matter expertise in the drafting and review of this EIS. The Interagency Working Group on 

Coordination of Domestic Energy Development and Permitting in Alaska, established under EO 13580, 

adopted the concept of “integrated arctic management” to ensure that decisions on development and 

conservation made in the Arctic are driven by science, stakeholder engagement, and government 

coordination. Bureau of Ocean Energy Management’s participation as a cooperating agency furthers these 

goals by enabling coordinated government efforts on natural resource development planning in the Artic. 

In addition to the statutory authorities described above, a number of Executive orders apply to all federal 

agencies. These include EOs 11988 (Floodplain Management), 11990 (Protection of Wetlands), 12898 

(Environmental Justice), 13075 (Tribal Consultation), and 13112 (Invasive Species Control). 

The State and the North Slope Borough require permits for certain activities within the NPR-A. The 

North Slope Borough, as a Home Rule Borough, issues development permits and other authorizations for 

oil and gas activities under the terms of its ordinances (North Slope Borough Municipal Code Title 19). 
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The State has responsibility for issuance of several permits. Alaska's Department of Natural Resources 

issues temporary water use and water rights permits, permits for cultural resource surveys, cultural 

resource concurrences, and other authorizations for activities associated with oil and gas development. 

The Alaska Department of Fish and Game issues fish habitat permits. Under the state implementation 

plan, the Alaska Department of Environmental Conservation issues prevention of significant deterioration 

and other air quality permits. The Alaska Department of Environmental Conservation is responsible for 

issuing several permits and plan approvals for oil and gas exploration and development activities, 

including the storage and transport of oil and cleanup of oil spills. The Alaska Oil and Gas Conservation 

Commission is responsible for issuing drilling permits and for production, injection, and disposal plan 

approvals for exploration and development activities in the State of Alaska (BLM 2012, page 13). 

Additional state authorities are presented below. 

Alaska Department of Natural Resources

• Issues rights-of-way and land use permits for use of state land, ice road construction on state land, and 

state freshwater waterbodies under AS 38.05.850. 

• Issues a “temporary water use and water rights” permit under AS 46.15 for water use necessary for 

construction and operations. 

• Issues “Alaska cultural resource permits” for cultural resource surveys under the Alaska Historic 

Preservation Act (AS 41.35.080). 

• Issues “cultural resources concurrences” for development on state land (but not federally managed 

land) that may affect historic or archaeological sites under the National Historic Preservation Act of 

1966, as amended (16 USC Section 470 et seq.), and the Alaska Historic Preservation Act (AS 

41.35.010 through .240).

• Authorizes transportation of hydrocarbons from a federal unit to a state unit. 

Alaska Department of Environmental Conservation

• Issues an Alaska Pollutant Discharge Elimination System “wastewater discharge permit” and “mixing 

zone approval” for wastewater disposal into all state waters under a transfer of authority from the EPA 

National Pollutant Discharge Elimination System Program under Section 402, Federal Water 

Pollution Control Act of 1972, as amended (Clean Water Act, 33 USC Section 1342); AS 46.03.020, 

.100, .110, .120, and .710; 18 AAC chapters 15, and 70, and; Section 72.500. 

• Issues a certificate of reasonable assurance/National Pollutant Discharge Elimination System Program 

and mixing zone approval for wastewater disposal into all state waters under Section 402, Federal 

Water Pollution Control Act of 1972, as amended (Clean Water Act; 33 USC Section 1342); AS 

46.03.020, .100, .110, .120, and .710; 18 AAC chapters, 10, 15, and 70, and; Section 72.500. 

• Issues a Class I well wastewater disposal permit for underground injection of non-domestic 

wastewater under AS 46.03.020, .050, and .100. 

• Reviews and approves all public water systems including plan review, monitoring program, and 

operator certification under AS 46.03.020, .050, .710, and .720, 18 AAC Chapter 80. 

• Approves domestic wastewater collection, treatment, and disposal plans for domestic wastewaters (18 

AAC Chapter 72). 

• Approves financial responsibility for cleanup of oil spills (18 AAC Chapter 75). 

• Reviews and approves the “oil discharge prevention and contingency plan” under the Oil Pollution 

Act of 1990 (OPA 90) and the “certificate of financial responsibility” for storage or transport of oil 

under AS 46.04.030 and 18 AAC Chapter 75. The State review applies to oil exploration and 
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production facilities, crude oil pipelines, oil terminals, tank vessels and barges, and certain non-tank 

vessels. 

• Issues a Title V operating permit and a prevention of significant deterioration permit under Clean Air 

Act Amendments (Title V) for air pollutant emissions from construction and operation activities (18 

AAC Chapter 50). 

• Issues solid waste disposal permit for state lands and reviews and approves solid waste processing 

and temporary storage facilities plan for handling and temporary storage of solid waste on federal and 

state lands under AS 46.03.010, 020, 100, and 110; AS 46.06.080; 18 AAC Chapter 60. 

• Approves the siting of hazardous waste management facilities (18 AAC Chapter 63).

• Reviews and approves food service facilities or camps serving 25 persons or more.

Alaska Department of Fish and Game

• Issues “fish habitat permits” under AS 16.05.871 and AS 16.05.841 for activities within streams used 

by fish that the agency determines could represent impediments to fish passage, or for travel in, 

excavation of, or culverting of anadromous fish streams. 

• AS16.05.841–Fishway Act deals exclusively with fish passage; applies to streams with documented 

resident fish use and without documented use by anadromous fish. 

• AS16.05.871–Anadromous Fish Act applies to streams specified in the Anadromous Waters Catalog 

as important for the spawning, rearing or migration of anadromous fishes; much broader authority and 

extends to anadromous fish habitat. 

• Evaluates potential impacts to fish, wildlife and fish and wildlife users, and presenting any related 

recommendations to state land managers (Alaska Department of Natural Resource) or, via the Fish 

and Wildlife Coordination Act, to federal permitting agencies.

Alaska Oil and Gas Conservation Commission 

• Issues a “permit to drill” under 20 AAC Section 25.05. 

• Issues approval for annular disposal of drilling waste (20 AAC Section 25.080). 

• Authorizes “plugging, abandonment, and location clearance” (20 AAC Section 25.105 through 

25.172). 

• Authorizes “production practices” (20 AAC Section 25.200–25.245). 

• Authorizes “Class II waste disposal and storage” (20 AAC Section 25.252). 

• Approves “workover operations” (20 AAC Section 25.280). 

• Reports (20 AAC Section 25.300–25.320). 

• Authorizes “enhanced recovery operations” under 20 AAC Section 25.402–460. 

1.4.2.2 GMT2 Permit Requirements 

Table 1 summarizes key permits, approvals, and requirements associated with GMT2 Project.

Table 1. Key permits, approval, and other requirements for GMT2

Agency Jurisdiction Permit, Approval or Other Requirement

All Cooperating Agencies Variable  NEPA Review
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Agency Jurisdiction Permit, Approval or Other Requirement

Bureau of Land 

Management

Federal  Application for permit to drill

 Temporary use permit

 Material sale

 Threatened and endangered species formal consultation biological 

assessment; Endangered Species Act determination for National 

Marine Fisheries Service-managed species

 Essential fish habitat assessment

 Alaska National Interest Lands Conservation Act 810 evaluation 

and findings

 Compliance with Section 106 of the National Historic Preservation 

Act 

 Production commingling and allocation approval

 EO 13175 Tribal consultation

 DOI Policy on Consultation with Alaska Native Claims Settlement 

Act Corporations (2011)

U.S. Army Corps of 

Engineers

Federal  Clean Water Act Section 404 permit

Environmental Protection 

Agency

Federal  Facility response plan

 Spill prevention, control and countermeasures plan

U.S. Fish and Wildlife 

Service 

Federal  Letter of authorization for incidental take of polar bears

 Consultation under Section 7 of the Endangered Species 

Act/biological opinion for listed species

National Marine 

Fisheries Service 

Federal  Consultation under Section 7 of the Endangered Species 

Act/biological opinion for listed species

Alaska Department of 

Natural Resources

State  Land use (ice roads and pads on state land)

 Temporary water use permit

 Cultural resources coordination/consultation with State Historic 

Preservation Office

Alaska Department of 

Fish and Game

State  Title 16 fish habitat permits for all activities occurring below ordinary 

high water of anadromous waters and often-resident fish streams, 

including vehicle crossings (summer and winter), bridges, culverts, 

water withdrawals, pipeline vertical support member installation, 

etc.

 Public safety permit for non-lethal hazing of wild animals that are 

creating a nuisance or a threat to public safety
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Agency Jurisdiction Permit, Approval or Other Requirement

Alaska Department of 

Environmental 

Conservation

State  Air quality permit 

 Alaska Pollutant Discharge Elimination System permit 

(wastewater/stormwater/hydrotest discharge)

 Oil discharge prevention and contingency plan 

 Section 401 water quality certification 

 Certificate of financial responsibility

 Plan approvals for Drinking Water and Wastewater Treatment 

systems.

 Issues permit AKG332000 Facilities Related to Oil and Gas 

exploration, Development, and Production in the North Slope 

Borough (addresses graywater for mobile camps, gravel pit 

dewatering, excavation dewatering, hydrostatic test water disposal, 

mobile spill response, secondary containment, and operational 

storm water); AR100000 Construction Storm Water; AKG320000 

Statewide Oil and Gas Pipelines (horizontal directional drilling for 

pipeline construction); AKG572000 Small POTW and other Small 

Treatment Word (domestic water); and AKG380000 Waste 

discharges from Drinking Water Treatment Facilities.

Alaska Oil and Gas 

Conservation 

Commission

State  Permit to drill

 Approval for annular disposal of drilling wastes

 Area injection order

Office of Public Safety State  Fire marshal approval

North Slope Borough Local  Rezoning to resource development district–master plan 

 Title 19 development permit/administrative approval

 Iñupiat History, Language, and Culture Division–traditional land use

inventory clearance

Kuukpik Corporation Local  Land use authorization for facilities constructed on Kuukpik land

Native Village of Nuiqsut Local  EO 13175 Tribal consultation

1.4.3 Related NEPA Analyses

The Council on Environmental Quality regulations for the implementation of NEPA direct agencies to 

reduce excessive paperwork and eliminate repetitive discussion of issues by tiering to existing NEPA 

documents to focus on actual issues ripe for decision (40 CFR 1502.20 and 40 CFR 1502.21). This 

supplemental EIS adheres to the Council on Environmental Quality recommendation by summarizing the 

issues discussed in broader/existing NEPA documents and adopting these discussions by reference. This 

supplemental EIS tiers to the following NEPA documents: 

• 2004 Alpine Satellite Development Plan Final EIS

• 2004 Alpine Satellite Development Plan Record of Decision 

• 2008 Northeast NPR-A Final Supplemental Integrated Activity Plan/EIS 

• 2012 NPR-A Final Integrated Activity Plan/EIS

• 2013 NPR-A Integrated Activity Plan Record of Decision

• 2014 GMT1 Final Supplemental EIS 

• 2015 GMT1 Record of Decision 

The BLM issued the 2004 Alpine Satellite Development Plan Final EIS (BLM 2004) to evaluate a 

proposal by ConocoPhillips for the phased development of five satellite oil discoveries—two in the 

Colville River Delta (CD3 and CD4) and three in the NPR-A (CD5, GMT1 [formerly CD6], and GMT2 

[formerly CD7]). CD5 is on land conveyed to Kuukpik Corporation within the NPR-A boundary while 

the GMT1 and GMT2 pads are on federally managed lands administered by the BLM. Both the potential 
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impacts of proposed development activities and a range of alternatives were evaluated. No additional 

NEPA analysis was envisioned as necessary to support the proposed development.

The 2004 Alpine Satellite Development Plan Record of Decision (BLM 2004a) states: 

This Record of Decision documents the Department of the Interior’s decision to approve rights-ofway and permits to drill on public lands in response to an application by ConocoPhillips Alaska, 

Inc. (ConocoPhillips). BLM (2004) fulfills the obligation of BLM and its federal cooperating 

agencies under the National Environmental Policy Act (NEPA), 42 USC Section 4321, to analyze 

the environmental impacts of federal authorizations necessary for ConocoPhillips to undertake its 

proposed development.

The 2008 Northeast NPR-A Final Supplemental Integrated Activity Plan/EIS (BLM 2008) addressed the 

Nation’s need for production of more oil and gas through leasing lands in the northeast NPR-A. It

provides local environmental resource information and includes GMT2 Project as a basic assumption in 

the analyses. In addition, its alternatives evaluated both prescriptive and performance-based lease 

stipulations and other protective measures intended to mitigate impacts. 

The BLM completed the 2012 NPR-A Final Integrated Activity Plan/EIS (BLM 2012) to fulfill the NEPA 

requirements for oil and gas lease sales (authorized by the 2013 record of decision) and for potential 

renegotiations of the stipulations of previously leased tracts in the entire NPR-A. Several alternative 

development scenarios were evaluated, with the assessment of related environmental consequences based 

on a number of assumptions, including potential development of the GMT Unit (BLM 2012, Section 4.1–

4.2). The proposed GMT2 Project is consistent with development scenarios considered in all action 

alternatives (BLM 2012, Section 4.2.1.2, volume 2, page 51). 

The 2012 Point Thomson Project Final EIS, which analyzed development of natural gas resources east of 

Prudhoe Bay in an undeveloped region of the North Slope, is also referenced in this supplemental EIS. 

This supplemental EIS references its recent cumulative impacts analysis.

The GMT1 Supplemental EIS was the first supplement to the 2004 Alpine Satellite Development Plan. 

The GMT1 Record of Decision directed the BLM to prepare a Regional Mitigation Strategy (RMS) that 

would “serve as a roadmap for mitigating impacts from GMT1 and future projects enabled or assisted by 

the existence of GMT1.” The RMS will help the BLM manage the NPR-A in a manner consistent with 

public law, and to fulfill the requirements of NEPA. The overall goal of the NPR-A RMS is to facilitate 

the expeditious development of oil and gas resources, while mitigating reasonably foreseeable and 

significantly adverse effects on the surface resources of the NPR-A. The RMS describes current and 

potential future mitigation actions or opportunities that should be considered when approving an 

application for development. The GMT2 Record of Decision will identify mitigation measures that 

incorporate recommendations made in the RMS.

Additional NEPA analysis is required prior to BLM approval of proposed construction of infrastructure 

for development of a petroleum discovery based on specific and detailed information about where and 

what kind of activity is proposed (BLM 2012, page 9). The GMT2 Project was subject to a detailed NEPA 

analysis in BLM (2004), and was reconsidered in BLM (2012). This supplemental EIS focuses on 

changes and additional information that could affect federal decisions on permit applications associated 

with GMT2. 
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1.4.3.1 Previous ANILCA 810 Findings

2004 Alpine Satellite Development Plan

The ANILCA Section 810 evaluation of the 2004 Alpine Satellite Development Plan Final EIS found that 

the effects of the Preferred Alternative would fall above the level of significantly restricting subsistence 

use for the community of Nuiqsut. The finding of potential impacts to subsistence resources by 

displacement and impacts to current subsistence patterns of use was based on the following: 

1) Displacement of caribou, wolf and wolverine from the Fish Creek traditional hunting area during 

the winter construction phase lasting for two years; and, 

2) The presence of oil and gas infrastructure in the Fish Creek traditional hunting area. Subsistence 

users in Nuiqsut have historically altered their traditional hunting patterns to avoid oil and gas 

development. The Fish Creek area is proportionately the area with the highest use for Nuiqsut’s 

winter harvest of caribou, and 25 percent of Nuiqsut’s caribou harvest for 1993, 1994–1995, 

2001, and 2002. Fish Creek is also an important Nuiqsut harvest area for geese (more than 45 

percent) and more than half of wolves harvested by Nuiqsut hunters come from the Fish and Judy 

Creek areas. 

Infrastructure, traffic, and industrial effects such as noise and emissions in this area have the potential to 

reduce the abundance of harvestable resources, alter the distribution of these resources, and result in the 

non-use of traditional harvest areas. Depending on the resulting migration patterns for the Teshekpuk 

Lake Herd, and the areas of relocation for other subsistence species, the communities of Barrow, Atqasuk, 

and Anaktuvuk Pass may also be affected. However, existing data summarized in the 2004 FEIS did not 

warrant a positive finding under ANILCA § 810 for these three communities. 

2014 GMT1

The ANILCA Section 810 evaluation for GMT1 (2014) (supplemental EIS tiered from the 2004 ASDP 

ANILCA §810 analysis) found that the effects of Alternative A would fall above the level of significantly 

restricting subsistence use for the community of Nuiqsut. It found that access to subsistence areas near 

Fish Creek may be facilitated for hunters and fishers who chose to use the GMT1 road, but the potential 

impacts to subsistence resources, user access, and patterns of use may exceed the non-significant level. 

Noise, traffic, and infrastructure, particularly during the construction phase but continuing throughout the 

life of the project, could affect the availability of key resources (caribou, wolves, and wolverine). The 

construction impacts would last for two years. 

A high number of overlapping caribou use areas were documented throughout the GMT1 project study 

area and recent documentation showed the highest number of overlapped areas along the Nigliq Channel, 

Fish Creek, and in overland areas west of the community toward the Tiŋmiaqsiġvik (Ublutuoch) River. 

During the 30-year production phase, the road itself and traffic on the road were anticipated to cause local 

diversion of caribou during peak caribou hunting season (July and August). Alternative A would result in 

increases in helicopter and fixed-wing aircraft traffic from existing conditions. Impacts were anticipated 

to result in increased risk, increased investments in time, money, fuel, and equipment, and potentially 

changed hunting success. Such effects would have a greater negative impact on poor residents who are 

less able to afford the means to travel further away from town and residents for whom the project area 

overlaps or is near their family’s traditional hunting and fishing areas. 
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NPR-A Integrated Activity Plan/Environmental Impact Statement

The ANILCA 810 evaluation for the 2012 NPR-A IAP/EIS followed previous findings in the 2005 and 

2008 Supplements to the Northeast NPR-A IAP and found that the leasing plan would not significantly 

restrict subsistence use by communities in or near the NPR-A (Anaktuvuk Pass, Atqasuk, Barrow, 

Nuiqsut, Point Lay, and Wainwright). The finding stated that adequate stipulations and best management 

practices had been incorporated—including specific procedures for subsistence consultation with directly 

affected subsistence communities, requirements for extensive studies of caribou movement, and increased 

setbacks or other protective measures specific to birds—to ensure that significant restrictions to 

subsistence uses and needs would not occur. The 2012 IAP ANILCA 810 evaluation found that the 

cumulative case may significantly restrict subsistence uses.

The ANILCA Section 810 evaluation for the 2012 NPR-A IAP/EIS leasing plan did not analyze the direct 

and indirect impacts of the GMT1 and GMT2 projects; those projects had already been analyzed by the 

2004 ASDP and were expected to be analyzed in subsequent supplemental EISs. 

1.4.4 Scope of Supplemental EIS

This supplemental EIS supplements BLM (2004), specifically addressing changes in the project, and new 

information and circumstances that might affect the determinations and decisions associated with BLM 

(2004) and BLM (2004a). This effort is greatly facilitated by tiering from and incorporating by reference 

BLM (2004) and BLM (2004a), as well as sections of BLM (2012), BLM (2013) and BLM (2014) where 

applicable. 

The scope of this supplemental EIS includes analysis of potential impacts of the proposed GMT2 Project, 

based on the analyses performed in existing NEPA documents, with a focus on updated or more sitespecific information. Resources that have been addressed thoroughly in existing NEPA documents and for 

which there are no changes in regulation or resource status are briefly summarized in Chapters 3 and 4 

(Affected Environment and Environmental Consequences, respectively). Information for those resources 

where additional data, particularly site-specific and updated information has been identified, or where 

there has been a change in status, is presented in Chapter 3 and incorporated into the analysis of Chapter 

4. See Section 4.1.3 for a discussion on how expected levels of impact are determined. 

1.4.5 Changes and New Information

The primary objective of this supplemental EIS is to identify changes to the project design since it was 

described in BLM (2004), and to evaluate the impact of those changes. A secondary objective is to review 

the description of the affected environment and to consider whether new information or circumstances 

exist, and if so, to evaluate the potential environmental impacts of the project against the updated 

description of the affected environment. Chapter 2, Table 3 summarizes the changes in GMT2 Project 

design. 

A review of new data and information contained in BLM (2012) and BLM (2014) shows there are no 

appreciable changes in the physical, biological, or social resources associated with the project study area 

since BLM (2004). New data includes multi-year studies on hydrology, birds, and caribou. Recent climate 

data may change some projected outcomes. Since 2004, there have been many advances in the study of 

climate change on the North Slope. In addition, ConocoPhillips’s proposed project was modified to 

reduce impacts, and more information on the material site (potential gravel source) has been collected. 

The regulatory framework remains essentially the same, except for several new Endangered Species Act 

listings and air quality regulations. Additionally, the project will be subject to various lease stipulations 

and the new best management practices adopted in BLM (2013). Table 2 summarizes changes and 

additional information by resource. 
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Table 2. Environmental changes and new information in project study area since 2004

Resource Changes in Nature of Resource New Project Information or Regulatory Controls

Physical 

Terrestrial 

Environment

No appreciable change since 

BLM (2004)

Site-specific information on some paleontological 

resources in the area based on archaeological surveys.

Physical Aquatic 

Environment

No appreciable change since 

BLM (2004)

Site-specific information on waterbodies, hydrology, and 

interactions during high-water events (e.g., breakup) 

based on field surveys.

Physical 

Atmospheric 

Environment

No appreciable change since 

BLM (2004)

Detailed information on air pollutant concentrations in 

Nuiqsut based on ambient air quality monitoring.

New air quality regulations and agency guidelines. 

Climate Change Continuing trend of effects Current reports addressing climate change in Alaska.

Vegetation and 

Wetlands

No appreciable change since 

BLM (2004)

Site-specific information on vegetation, wetlands, and 

habitat types for the realigned project, based on surveys 

initially performed for the 2004 EIS.

Fish No appreciable change since 

BLM (2004)

Site-specific information regarding fish-bearing lakes 

from lake studies and anadromous waterways from the 

Alaska Department of Fish and Game Catalog of Waters 

Important for the Spawning, Rearing or Migration of 

Anadromous Fishes.

Birds No appreciable change since 

BLM (2004)

Site-specific information regarding observances of 

selected bird species based on multi-year surveys 

performed for ConocoPhillips.

Terrestrial 

Mammals

No appreciable change since 

BLM (2004)

Site-specific information regarding caribou migration 

patterns and use of the project study area based on 

multi-year surveys performed for ConocoPhillips. 

Additional information on migration patterns since 2004 

has been collected by North Slope Borough, Alaska 

Department of Fish and Game and the BLM.

Threatened and 

Endangered 

Species

Changing habitat of marine 

mammals (USFWS 2009a; 

National Marine Fisheries Service 

2012)

Concern about the vulnerability of 

yellow-billed loon population due 

to low starting population, low 

reproductive rate, and specific 

breeding habitat requirements 

(USFWS 2009b)

The polar bear and two species of ice seal were listed, 

and the yellow-billed loon was designated as a 

candidate species under the Endangered Species Act. 

On October 1, 2014, the USFWS determined that listing 

the yellow-billed loon under the Endangered Species Act 

was not warranted. The loon no longer has status under 

the Endangered Species Act, but the BLM still 

recognizes the species as a special status species and 

as a species of conservation concern by the USFWS.

New site-specific information regarding observations of 

spectacled eiders based on surveys performed for 

ConocoPhillips. 

Site-specific information on polar bear sightings and den 

locations provided by ConocoPhillips and the U.S. 

Geological Survey, respectively. Information on potential 

denning habitat provided by U.S. Geological Survey.

Sociocultural No appreciable change since 

BLM (2004) 

Updated population data based on 2010 U.S. Census 

results. 

Updated economic data.

Community health and welfare information based on a 

Health Baseline Report produced by the State of Alaska 

Department of Health and Human Services (DHSS 

2016).
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Resource Changes in Nature of Resource New Project Information or Regulatory Controls

Subsistence No appreciable change since 

BLM (2004); however, continuing 

development in the vicinity of 

Nuiqsut puts additional pressure 

on subsistence access and 

resources

Updated information regarding subsistence activities 

published in 2016 by Stephen R. Braund & Associates.

Cultural 

Resources

No appreciable change since 

BLM (2004)

Site-specific information on cultural resources in the 

area based on several archaeological surveys and State 

Historic Preservation Office consultation.

Land Use Two new land use plans in the 

NPR-A: 2008 Northeast NPR-A 

Integrated Activity Plan Record of 

Decision and 2013 NPR-A 

Integrated Activity Plan Record of 

Decision 

Both new land use plans 

designate a 0.5-mile setback from 

Tiŋmiaqsiġvik (Ublutuoch) River 

and include restrictions for 

permanent facilities

Both 2008 and 2013 records of 

decision authorize new lease 

sales in the project study area

Selected land in project study 

area transferred to Kuukpik 

Corporation (2010 conveyance), 

and subsurface transferred to 

Arctic Slope Regional 

Corporation.

Administration of some oil and 

gas leases transferred to Arctic 

Slope Regional Corporation 

(Kuukpik land)

New leases, exploration, and 

development on state land and 

water

New OCS leases and planned 

exploration

CD3, CD4, and CD5 constructed 

and operating 

GMT1 began construction in 

February 2017

Nuiqsut Spur Road constructed 

and in use

Inter- and intra-state natural gas 

pipeline(s) permitting underway

For purposes of the analysis, Tiŋmiaqsiġvik (Ublutuoch) 

River and Fish Creek setbacks are considered to be in 

effect on Kuukpik land as well as federally managed 

land. A permit from the land owner (Kuukpik) will be 

required for road and pipelines on private land.

The cumulative impacts analysis of BLM (2014) and the 

Nanushuk Project Draft Environmental Impact Statement 

(U.S. Army Corps of Engineers 2017) address relevant 

new and reasonably foreseeable projects as used in the 

analysis.
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1.5 Public Involvement 

Public involvement is an important part of the NEPA process. The Council on Environmental Quality 

regulations require agencies to make diligent effort to involve the public in preparing and implementing 

their NEPA procedures [40 CFR 1506.6(a)]. Typically, public involvement begins with scoping and 

continues throughout preparation of the analysis and the decision (BLM 2008c, Section 6.9). 

1.5.1 Scoping 

Additional scoping for a supplemental EIS is not required [40 CFR 1501.9(c)(4)]; however, scoping is an 

effective process by which the BLM can acquire internal and external input on the issues, impacts, and 

potential alternatives to be addressed, as well as determine the extent to which those issues and impacts 

will be analyzed. The intent of scoping is to focus the analysis on significant issues and reasonable 

alternatives to eliminate extraneous discussion, and reduce the length of the EIS (BLM 2008c, Section 

9.1.3). 

The BLM solicited public scoping comments on the GMT2 Project in the Notice of Intent to Prepare a 

Supplemental EIS, published in the Federal Register on July 29, 2016. Scoping comments were formally 

accepted through September 30, 2016, but scoping comments received after that date have also been 

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

supplemental EIS. 

In all, the BLM received 27 sets of comments from private citizens, environmental organizations, and 

government agencies, including the North Slope Borough, Kuukpik Corporation, and the Native Village 

of Nuiqsut. The BLM tabulated the comments and identified a number of themes. These themes include:

• Potential impacts of past and proposed development on community health; 

• Potential impacts on the availability of key subsistence resources, particularly caribou and fish, and 

access to those resources;

• Potential impacts of increased development and activity on the local lifestyle, on wildlife, and 

associated cumulative impacts;

• Potential impacts on fish and wildlife and their habitats;

• Existing impacts of noise and disturbance created by aircraft and concern over additional and 

cumulative impacts;

• Potential impacts of existing and proposed development on local water quality and associated effects 

on people and wildlife; 

• Potential impacts of existing development and proposed development on air quality, including the 

need for a comprehensive assessment and modeling of pollutants to determine near-field and far-field 

impacts, cumulative impacts, and impacts on Nuiqsut (e.g., particulates, NO2);

• Effects of greenhouse gas emissions and climate change;

• Need to consider a range of alternatives to the proposed project, including a roadless alternative, 

alternative source of support services (e.g., Nuiqsut), and the environmentally preferable or least 

environmentally damaging alternative;

• Effectiveness of mitigation and permit requirements; spill mitigation; and

• Ensure meaningful public involvement, specifically for Nuiqsut. 

A number of local, state, and federal agencies have been involved in identifying issues for the 

supplemental EIS. Key agency issues to date have focused on:
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• Impacts of road development on hydrology and sheet flow;

• Impacts on air quality;

• Impacts on aquatic resources; and

• Impacts on and of oil and gas development.

1.5.2 Other Stakeholder Opportunities 

 The BLM provides NEPA documents and public notices on their website and takes input from the public 

throughout the NEPA process. On March 29, 2018, the BLM published a Notice of Intent in the Federal 

Register to request comments for the draft SEIS. This Notice opened a 45-day public scoping period, 

which was extended for an additional ten days and officially closed on May17, 2018. During this time 

period the document was available over the internet and hard copies were provided for public review in 

Utqiagvik, Nuiqsut, Atqasuk, Anaktuvuk Pass, Fairbanks, and Anchorage. Public meetings were also held in 

these same communities during the public comment period to ensure better understanding of the project, the 

alternatives, and impacts as well as to obtain in-person public comments. 

The BLM received a robust amount of input during the draft SEIS comment period, including 91 detailed 

letters from a wide representation of stakeholders: individuals; business and industry groups; local 

government; state agencies; congressional representatives; environmental organizations; and Alaska Native 

organizations. In all, over 800 substantive comments were received that warranted a response (see GMT2 SEIS 

Volume 2). These comments included suggestions for new potential mitigation measures, the identification of 

erroneous or unclear text; and specific suggestions regarding the environmental consequences of the proposed 

action on, but not limited to, subsistence, sociocultural systems, terrestrial mammals, birds, fish, air quality, 

and human health. 

During the development of BLM (1998b), BLM (2004), BLM (2008), and BLM (2012), extensive input from 

other federal agencies, the State, the NSB, thousands of individuals, and many institutions was received by the 

BLM. BLM consults with federally-recognized tribes and holds meetings in local communities to discuss oil 

and gas activities in the NPR-A as part of its NEPA processes. Additionally, since 1998, the BLM has required 

Applicants to engage in community consultation before conducting activities in the NPR-A and to submit 

documentation of that consultation to BLM. 

The NVN is participating in the SEIS process as a cooperating agency in addition to participating through the 

Government-to Government (G2G) consultation process. EO 13175 (November 2000), Consultation and 

Coordination With Indian Tribal Governments, was signed 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 United States government-to-government relationships with Native Americans and Alaska 

Natives. BLM has also engaged in consultation with Kuukpik Corporation and the ASRC pursuant to the 

Department of the Interior Policy on Consultation with Alaska Native Claims Settlement Act (ANCSA) 

Corporations dated August 10, 2012. 
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Chapter 2. Proposed Project and Alternatives

The Greater Mooses Tooth 2 Project (GMT2 Project) is the second satellite to be developed in the Greater 

Mooses Tooth Unit (GMT Unit), which is located in the northeast area of the National Petroleum Reserve 

in Alaska (NPR-A) on Alaska’s North Slope near the Beaufort Sea. The project was originally analyzed in 

the Alpine Satellite Development Plan EIS (BLM 2004, Section 2.3–2.4). The first development in the 

GMT Unit was Greater Mooses Tooth 1 (GMT1), which is described in detail in BLM (2015, Section 

2.4–2.5). ConocoPhillips began construction of GMT1 in February 2017 and expects production to begin 

during winter 2018-2019. 

2.1 GMT2 Project Changes Over Time 

The GMT2 Project has undergone several changes since it was originally proposed in BLM (2004). These 

changes are described below. 

2.1.1 Project as Proposed in 2004 Alpine Satellite Development Plan 

Record of Decision

The preferred alternative described in BLM (2004) specified construction of a 9.1-acre drill pad on 

federally managed lands (now interim conveyed to an Alaska Native Claims Settlement Act corporation). 

Transport of produced fluids would be by pipeline to the Alpine Central Processing Facility. An 

approximately 6.3-mile gravel access road would parallel the pipeline from GMT2 to the GMT1 junction. 

Gravel would be extracted from the Clover potential gravel source. Upon completion of construction and 

drilling activities, crews based at Colville Delta 1/Alpine Central Processing Facility would service and 

maintain the GMT2 pad. 

The BLM record of decision adopted the preferred alternative to relocate a substantial portion of the road 

and pipeline between GMT2 and GMT1 to reduce permanent oilfield infrastructure in the Fish Creek 

Setback (Alpine Satellite Development Plan Record of Decision [BLM 2004a, page 17]). The BLM 

(2004a) adopted the Alpine Satellite Development Plan EIS preferred alternative with the following 

modifications: 

• A road and pipeline bridge across the Tiŋmiaqsiġvik (Ublutuoch River) would extend from bank 

to bank, defined as the active flow-way and the frequently active floodplain between 

topographical rises;

• The road/pipeline bridge would be approximately 350-feet long; 

• Adoption of mitigation measures described in the record of decision (BLM 2004a); and, 

• Adoption of a conservation recommendation included by the USFWS in the Endangered Species 

Act biological opinion. 

The project the BLM adopted (BLM 2004a), serves as the basis of ConocoPhillips’s proposed action in 

the application for a permit to drill.

2.1.2 Project Evaluated by the BLM in 2012 and 2014

Following the issuance of the Alpine Satellite Development Plan EIS and Record of Decision (BLM 

2004a and 2004b), the proposed location of the GMT2 pad was revised. In both BLM (2012) and BLM 

(2014), the location of the GMT2 drill pad (BLM 2014, Map 4.6.2; Section 5 U009N002E) is south of the 

location adopted in 2004 (Figure 1.1.1-2; Section 20 U010N002E) within the Colville River Special Area. 
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Map 2.1-1 shows previously evaluated drill pad locations. The 2012/2014 GMT2 drill pad (BLM 2012 

and 2014) was relocated for optimum access to the reservoir, as described below.

After data collection conducted during the drilling and testing of a series of Spark and Rendezvous 

exploration wells, the extent of the subsurface petroleum resource has been under continuing study. In 

both the NPR-A Integrated Activity Plan/EIS (BLM 2012) and the GMT1 Supplemental Environmental 

Impact Statement (supplemental EIS) (BLM 2014), the proposed location of GMT2 is south of the 2004 

location to optimize production potential. 

The Spark-Rendezvous accumulation, which will be accessed by GMT2, is a reservoir system that 

includes gas plus condensate at shallower depths in the northern part and oil at greater depths in the 

southern part.

Of the five oil discoveries in the Alpine sandstone in Northeast NPR-A, the Spark-Rendezvous 

accumulation is the largest reservoir system. Alpine West, Lookout, and Pioneer are oil accumulations 

with little or no free gas. A fourth discovery, Mitre, appears to be predominantly a gas accumulation with 

an oil leg in the south. The U.S. Geological Survey estimates that 120 to 200 million barrels of oil 

(including oil and condensate) and 1.9 to 3.0 trillion cubic feet of gas may be technically recoverable 

from these accumulations (Houseknecht et al. 2010). 

Based on this updated information, the GMT2 pad location was moved approximately 3.2 miles south to 

better access the oil reservoir. The NPR-A Integrated Activity Plan (IAP/EIS)(BLM 2012, page 51) 

describes and evaluates the GMT2 pad location and the GMT1 Supplemental EIS (BLM 2014, page 498). 

While better for production than the original locations, there are environmental considerations for this 

site. This relocated GMT2 drill pad location was in the Colville River Special Area.

In 1977, the Colville River Special Area Management Plan (BLM 2008d) designated the Colville River 

Special Area. When making this designation, the Secretary of the Interior stated that the “central Colville 

River and some of its tributaries provide critical nesting habitat for the Arctic peregrine falcon, an 

endangered species. The bluffs and cliffs along the Colville River provide nesting sites with the adjacent 

areas being utilized as food hunting areas.” (BLM 2004a, page 27). The Colville River Special Area is 

approximately 2.44 million acres and includes lands along the Colville River.

2.1.3 2015 GMT2 Project Proposed by ConocoPhillips

In developing the project as currently proposed, ConocoPhillips again moved the location of the GMT2 

pad, this time moving the location outside the Colville River Special Area to minimize the potential for 

impacts to peregrine falcons. This location is acceptable with respect to oil production, and mitigates the 

potential for impacts on 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. Map 2.1-1 shows the three 

proposed locations of the GMT2 drill pad (i.e., adopted in the 2004 Alpine Satellite Development Plan 

Record of Decision, evaluated in BLM 2012 and BLM 2014, and proposed in the 2015 Application for 

Permit to Drill).

2.1.4 Summary of Changes in the GMT2 Project over Time

The currently proposed GMT2 Project (considered as Alternative A), is similar to the project approved for 

permitting in BLM (2004a) and that evaluated in BLM (2012) and BLM (2014). Some changes in the 

GMT2 Project are based on changes in the GMT1 Project approved for federal permitting (BLM 2015; 

U.S. Army Corps of Engineers 2015), which is approximately 1.9 miles southeast of the originally 

adopted location by the BLM (2004a). Table 3 provides notable changes, including the reason for the 

change.
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Table 3. Summary of changes in the GMT2 Project over time

Component

2004 Alpine 

Satellite 

Development Plan 

Adopted 

Alternative a 

2012/2014 Project b 2015 GMT2 Project Proposed 

by ConocoPhillips c Change in Impacts

Drill Pad 9.1 acres 13.0 acres

The drill pad footprint increased by 3.9 

acres to expand the drilling potential 

(from 20 to 33 wells) and to 

accommodate current drilling, 

operational, and safety practices

14.0 acres 

The drill pad footprint increased 

by approximately 1 acre to 

expand the drilling potential (up to 

48 wells)

Increased impacts due to 

larger pad size 

Number of Wells 20 Approximately 33 Up to 48 Increased production due to 

doubling of number of wells

Access Road 6.3 miles 8.7 miles

Road lengthened 2.4 miles as a result of 

the relocation of the Nigliq Channel 

bridge to the south (CD5 project) and 

route changes to the road caused by the 

changed drill pad location

8.2 miles

Road shorted 0.6 mile due to 

change in drill pad location 

Three 0.4-acre subsistence 

pullouts were added to the access 

road to allow better access and 

use of area to be developed for 

subsistence hunters

Increased impacts from the 

2004 project due to increase 

in road length. Decrease from 

2012/2014 project due to 

shorter road

Pipeline System 6.4 miles 9.1 miles

Pipeline length increased due to change 

in pad location

8.6 miles

Pipeline length decreased due to 

change in pad location

Increased impacts from the 

2004 project due to increase 

in pipeline length; decrease 

from 2012/2014 project due to 

shorter pipeline length

Bridges None None None No change

Facilities in Setbacks 

or Special Areas

Facilities in Fish 

Creek Setback d 

Most of the road 

and pipeline 

between GMT1 

(CD6) and GMT2 

(CD7) would be 

within the 3-mile 

Fish Creek Setback

Drill pad in Colville River Special Area 

Drill pad was relocated south of the 

original location into the Colville River 

Special Area because newer subsurface 

data refined the reservoir target locations

No facilities in sensitive areas

The drill pad was moved north out 

of the Colville River Special Area 

and avoids the Fish Creek 

Setback area that was of concern 

in 2004 (about 2.3 miles south of 

the 2004 drill site location) (see 

Map 2.1-2)

Decrease in impacts to 

sensitive areas due to no 

facilities being located in 

sensitive areas
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Component

2004 Alpine 

Satellite 

Development Plan 

Adopted 

Alternative a 

2012/2014 Project b 2015 GMT2 Project Proposed 

by ConocoPhillips c Change in Impacts

Total Gravel Footprint 50.6 acres 86.6 acres

Increase in gravel footprint (36 acres) is 

a result of the increased drill pad size 

and re-routing of road due to change in 

the location of the drill pad

78.0 acres 

Decrease in gravel footprint (8.6 

acres) is a result of the re-routing 

of road due to change in the 

location of the drill pad

Increased impacts from the 

2004 project due to increase 

in pad size and road length; 

decrease from 2012/2014 

project due to shorter road

Total Gravel

Requirement

339,000 cubic 

yards

625,500 cubic yards e

Increase in required gravel (286,500 

cubic yards) is a result of the increased 

size of drill pad and re-routing of road 

due to change in the location of the drill 

pad

671,300 cubic yards e Increased impacts from the 

2004 project due to increase 

in pad size and road length 

Gravel Source Proposed Clover 

mine site

Arctic Slope Regional Corporation Mine 

site

Existing gravel mine is sufficient to 

provide resources; not necessary to 

develop new gravel site

Arctic Slope Regional Corporation 

Mine site

Geographic location of 

impacts would be confined to 

previously disturbed areas

a Project components for the 2004 GMT2 Project were described in the Alpine Satellite Development Plan Record of Decision (BLM 2004b). 

b Project components for the 2012/2014 GMT2 Project were described in the 2014 GMT1 Supplemental EIS (BLM 2014). All miles, acres, and cubic yards of fill were estimates from 

those documents developed for comparison purposes only. 

c Project components for the current GMT2 Development Project were obtained from detailed permit drawings included as Appendix A of this supplemental EIS. 

d The 2004 drill site was interim conveyed to Kuukpik Corporation in 2010 (BLM 2015f). 

e Differences between total gravel requirements included in BLM (2014) and the current GMT2 Development Project gravel requirement are due to more detailed engineering and 

design information. The differences do not reflect additional gravel requirements.
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2.2 Lease Stipulations and Best Management Practices 

ConocoPhillips is subject to the best management practices in the 2013 NPR-A Integrated Activity 

Plan/EIS Record of Decision (BLM 2013), and lease stipulations in the 2008 Northeast NPR-A EIS 

Record of Decision, which were in place when ConocoPhillips renewed its lease in 2008. While it appears 

that these stipulations and best management practices are not inconsistent with each other, to the extent 

any are found to be inconsistent, the 2008 lease stipulations are expected to control management decisions 

(BLM 2014, page 20). 

ConocoPhillips may request a deviation from these applicable stipulations and best management 

practices, based on procedures described in BLM (2013 and 2014, page 20) that consider whether BLM 

objectives will be met. In adopting the Alpine Satellite Development Plan preferred alternative, the BLM 

(2004a) approved deviations to three lease stipulations controlling activities in the NPR-A at that time 

(i.e., BLM [1998a]). The BLM also approved deviations from three lease stipulations for the GMT1 

Project (BLM 2015). In both cases, deviation from one of the three stipulations (E-2) is also applicable to 

GMT2. 

For the proposed GMT2 Project, ConocoPhillips is requesting a deviation from Stipulation E-2, and BMP 

E-7(c) as discussed below:

• Stipulation E-2 is based on BLM 1998 Lease Stipulation 41, which prohibited oil infrastructure 

within 500 feet of waterbodies. The original Stipulation 41 was re-designated as Lease Stipulation E2 in BLM (2008a) and carried forward in BLM (2013a). E-2 restricts the most recent 500-foot setback 

to fish-bearing waterbodies. In 2004 and again in 2015, the BLM approved deviations to the E-2 lease 

stipulations because of the technical infeasibility of total compliance due to the hydrology, number of 

waterbodies in the area, and the implementation of other measures that would protect waterbodies

(such as use of secondary containment) (BLM 2004a, pages 3, 4, and 16–20; and, 2015a, pages 6, 7, 

and 19). Maps 2.5-2 and 2.6-2 show the deviations that would be required under each project 

alternative.

• BMP E-7(c) requires maintaining a minimum separation distance of 500 feet between pipelines and 

roads. The purpose of this 500-foot minimum distance requirement between roads and pipelines is to 

minimize disruption of caribou movement and subsistence use. Separating roads from pipelines may 

not be feasible within narrow land corridors between lakes or where pipelines and roads converge on 

a drill pad. Where it is not feasible to separate pipelines and roads, the authorized officer (Arctic 

District Office Manager) will consider alternative pipeline routes, designs, and possible burial within 

the roads. For the proposed GMT2 Project, four stretches of road would not meet this requirement, as 

described in Section 2.7.4., the BLM approved deviation from BMP E-7(c) for GMT1 (BLM 2015, 

pages 7 and 20). The BLM based its approval of the GMT1 deviation from BMP E-7(c) on 

topography, as well as supplemental mitigation measures such as speed limits and other design and 

operation measures that reduce impacts to subsistence resources (BLM 2015, page 20). Maps 2.5-2 

and 2.6-2 show the deviations that would be required under each project alternative.

2.3 Alternatives to the Proposed Project 

The National Environmental Policy Act of 1969 (NEPA) directs the BLM to “study, develop, and describe 

appropriate alternatives to recommend courses of action in any proposal that involves unresolved 

conflicts concerning alternative uses of available resources...” [NEPA, Section 102(2)(E)]. In determining 

the alternatives to be considered in satisfying the purpose and need, the emphasis is on what is reasonable 

rather than on whether the ConocoPhillips likes or is itself capable of implementing an alternative (40 

CFR 1502.14; BLM NEPA Handbook.p.49). “Reasonable alternatives include those that are practical or 

feasible from the technical and economic standpoint and using common sense, rather than simply 
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desirable from the standpoint of the applicant.” (Council on Environmental Quality, 1981 as amended–

Question 2a, CEQ, Forty Most Asked Questions Concerning CEQs NEPA Regulations.) 

Guidelines developed under Section 404(b)(1) of the Clean Water Act direct the U.S. Army Corps of 

Engineers to use the overall project purpose (based on the ConocoPhillips’s purpose and need) to define 

alternatives and determine which alternative is the least environmentally damaging practicable alternative. 

Where an activity is not “water dependent,” practicable alternatives that do not involve special aquatic 

sites are presumed to be available, and presumed to have less adverse impact to the aquatic ecosystem, 

unless it is clearly demonstrated otherwise [40 CFR Section 230.10(a)(3)]. The term “practicable” means 

available and capable of being done after taking into consideration cost, existing technology, and logistics 

in light of overall project purpose [40 CFR Section 230.3(q)]. 

2.3.1 Alternatives Selection Process

In supplementing BLM (2004), this supplemental EIS began the process of developing alternatives with 

an appraisal of the full range of applicable alternatives the BLM and cooperating agencies considered in 

BLM (2004) and BLM (2014). 

2.3.1.1 Development and Screening of Alternatives

The BLM and cooperating agencies held a series of meetings to develop, screen, and select alternatives 

for full analysis in the supplemental EIS, as summarized in Table 4. The BLM used the following criteria 

to evaluate the reasonableness of proposed alternatives:

• Is the alternative illegal?

• Does the alternative meet the purpose and need for the project?

• Is the alternative technologically feasible?

• Is the alternative economically feasible?

• Does the alternative duplicate other considered alternatives?

• Does the alternative cause unreasonable social or environmental harm?

Table 4. Alternatives development meeting summary

Meeting 

Date Meeting Participants Meeting Objective and Summary

09/14/2016 BLM, Bureau of Ocean Energy 

Management, EPA, USFWS, Iñupiat 

Community of the Arctic Slope, North 

Slope Borough, Native Village of 

Nuiqsut, State of Alaska, U.S. Army 

Corps of Engineers

GMT2 Cooperating Agency Meeting: Discussion of 

preliminary alternatives. Requested feedback from 

cooperating agencies on how to change preliminary 

alternatives. Discussion of an alternate alignment for the 

GMT1–GMT2 Access Road (Alternative B). Discussion of 

roadless alternatives.

10/13/2016 BLM, Bureau of Ocean Energy 

Management, EPA, USFWS, North 

Slope Borough, Native Village of 

Nuiqsut, State of Alaska, U.S. Army 

Corps of Engineers

Discussion of screening criteria, discussion of screening 

out the roadless alternative with seasonal drilling based on 

economic feasibility. Discussion of how to adjust 

alternatives to minimize impacts. 

10/13/2016 Native Village of Nuiqsut, BLM Government to Government with Nuiqsut: Discussion of 

project alternatives and subsistence access. 

12/14/2016 BLM, Bureau of Ocean Energy 

Management, EPA, USFWS, North 

Slope Borough, State of Alaska, U.S. 

Army Corps of Engineers

Final call for input on alternatives.

01/10/2017 BLM, EPA, USFWS, North Slope 

Borough, State of Alaska, U.S. Army 

Corps of Engineers, Native Village of 

Nuiqsut

Decision made to drop roadless alternative with seasonal 

drilling based on economic analysis. 
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2.3.2 Alternatives Considered But Not Carried Forward

BLM (2004) evaluated a range of alternatives. At that time, alternatives that were considered, but not 

carried forward for further detailed analysis, included: buried pipelines; pipelines elevated more than 

7 feet; pile-supported production pads; drill pad(s) at substantially different locations; supporting 

development from a Nuiqsut Operations Center; and development with access other than gravel road or 

air. The rationale that eliminated these alternatives from further consideration is provided in BLM (2004, 

Section 2.7). Drilling into the GMT2 subsurface reservoir using extended-reach drilling originating from 

pads at substantially different locations or using an existing pad, such as GMT1 or CD5, remains 

technically infeasible due to distance and variations in subsurface geology (BLM 2004). 

BLM (2014) considered 5 action alternatives for the GMT1 Project, and again examined these 5 

alternatives as potential alternatives for the GMT2 Project. Two alternatives analyzed in the GMT1 

Supplemental EIS were not carried forward into the GMT2 Supplemental EIS. An alternative based on 

coordinating development from a Nuiqsut Operations Center was eliminated because it was dependent on 

use of the Nuiqsut Spur Road, a private road owned by the Kuukpik Corporation. Kuukpik Corporation 

reiterated their intent to maintain this road as a private road for the residents of Nuiqsut, and not allow 

commercial uses by outside entities. Without access to the Nuiqsut Spur Road, the alternative that used 

Nuiqsut as a hub was not feasible, and the GMT2 Supplemental EIS did not consider this alternative. 

The BLM also considered a roadless alternative with seasonal drilling in the GMT1 Supplemental EIS, 

but eliminated use of that alternative in the GMT2 Supplemental EIS. Part of the BLM’s criteria for 

reasonableness includes the economic viability of each project alternative. The proponent’s proposed 

project (Alternative A), a roadless alternative with year-round drilling (Alternative C) and a roadless 

alternative with seasonal drilling were all analyzed for economic viability as part of the screening process. 

The roadless alternative with seasonal drilling was the only alternative that was ruled out based on 

economical viability. The initial economic analysis was done in November 2016, and a version with 

confidential information removed was provided in February 2017 to interested stakeholders. As part of 

producing the Final SEIS, ConocoPhillips provided updated production estimates for GMT2. The 

economic analysis was re-run using the same methodology, and showed a roadless alternative with 

seasonal drilling was still economically infeasible. The BLM has included the economic analyses used to 

screen out a roadless alternative with seasonal drilling as Appendix O.

2.3.3 Alternatives Carried Forward in the Supplemental EIS

As noted above in Section 2.3.2, the BLM and other cooperating agencies reconsidered the action 

alternatives analyzed in BLM (2004) and BLM (2014), and brought forward certain components of those 

alternatives in order to create conceptually similar, updated versions of these alternatives for the GMT2 

Project Supplemental EIS. In this supplemental EIS, Alternative A is the GMT2 Project as proposed by 

ConocoPhillips, which is based on the preferred alternative of BLM (2004). Alternative B is an alternate 

alignment of the GMT1–GMT2 Access Road, which follows the watershed boundary between the Fish 

Creek and the Tinmiaqsiugvik River drainage basins. Alternative C is based on the roadless alternative 

with year-round drilling proposed in BLM (2014). The no-action alternative must also be evaluated in the 

supplemental EIS [40 CFR 1502.14(d)]. 

Table 5 summarizes the major components of the action alternatives. The project component values, such 

as road lengths and pad acreage, are approximations based on best available data. Due to differences in 

data processing systems (e.g., GIS) and methodologies (e.g., number rounding), the values presented in 

the final supplemental EIS may differ slightly from values presented in other project-related documents 

(such as permit drawings). The BLM has reviewed these differences and determined them to be 

insignificant to the analysis, as well as to the overall permitting process.
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The BLM has identified Alternative A, the Proponent’s Proposal, as the Agency’s preferred alternative in 

this final supplemental EIS, as it also had done in the draft supplemental EIS. The identification of a 

preferred alternative does not constitute a commitment or decision in principle, and there is no 

requirement to select the preferred alternative in the Agency’s record of decision. If warranted, the BLM 

may select a different alternative than the preferred alternative in its record of decision.
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Table 5. Summary of major project components for each action alternative

Component

Alternative A (Proposed Action, 

Preferred Alternative)

Alternative B (Different Road 

Alignment)

Alternative C (Limited Access, Yearround Drilling)

Drill Pad 14.0 acres 14.0 acres 19.1 acres

Major On-site Facilities: Drill 

Pad 

 Emergency shutdown module

 Fuel gas module

 Test separator module

 Remote electrical and 

instrumentation module

 Pig launching and receiving module

 Chemical injection module 

(including indoor chemical totes)

 Production heater skid

 Metering module

 Communication tower

 High mast lights

 Switchgear-module

 Chemical storage with containment 

and truck loading at GMT1 and 

GMT2

 Well houses

 Transformer platforms (two, oilinsulated)

 Low pressure and high pressure 

pipe rack

 Safe handling module

 Emergency shutdown module

 Fuel gas module

 Test separator module

 Remote electrical and instrumentation 

module

 Pig launching and receiving module

 Chemical injection module (including 

indoor chemical totes)

 Production heater skid

 Metering module

 Communication tower

 High mast lights

 Switchgear-module

 Chemical storage with containment 

and truck loading at GMT1 and GMT2

 Well houses

 Transformer platforms (two, oilinsulated)

 Low pressure and high pressure pipe 

rack 

 Sand handling module

Limited access requires that certain 

services, equipment, and supplies 

otherwise provided at the CD1/Alpine 

Central Processing Facility would need to 

be duplicated at the site. These 

components will be required in addition to 

what is needed for Alternative A. Details 

are presented in Section 2.6. 

Occupied Structure Pad None None 18.4 acres

Air Access Facilities None None Airstrip and apron, 47.3 acres

Access Road 8.2 miles, 62.8 acres (GMT1–GMT2 

Access Road)

9.3 miles, 72 acres (GMT1–GMT2 

Access Road)

0.9 mile, 7.2 acres

(Airstrip Access Road)

Subsistence Tundra Access 

Road Pullouts a 

3 pullouts, 1.2 acres 3 pullouts, 1.2 acres None

Pipeline System 8.6 miles 9.4 miles 8.6 miles

Pipeline Vertical Support 

Members b 

Vertical support members: 0.1 acre Vertical support members: 0.1 acre Vertical support members: 0.1 acre

Ancillary Pipelines None None Diesel & mineral oil supply (through same 

pipeline), 2-inch

Water supply, 2-inch
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Component

Alternative A (Proposed Action, 

Preferred Alternative)

Alternative B (Different Road 

Alignment)

Alternative C (Limited Access, Yearround Drilling)

Bridges None None None

Culverts c 46 50 5

Ice Roads Year 1–2: 52.6 miles

Year 2–3: 43.9 miles

Post-construction: None

Year 1–2: 51.9 miles

Year 2–3: 43.3 miles

Post-construction: None

Year 1–2: 51.6 miles

Year 2–3: 51.2 miles

Post-construction: 7.0 miles annually 

Total Gravel Footprint d 78.0 acres 87.2 acres 92.0 acres

Total Gravel Requirement 671,300 cubic yards 747,300 cubic yards 930,000 cubic yards

Total Water Use 395 million gallons 398 million gallons 691 million gallons

Note: The project component values, such as road lengths and pad acreage, are approximations based on best available data. 

a Three planned subsistence tundra access pullouts with ramps on Alternative A GMT1–GMT2 Access Road, 0.4 acre each = 1.2 acres total. 

b Depending on final road alignment, 800 to 1,000 vertical support members will be required between GMT1 and GMT2, based upon a 55-foot average spacing. Each vertical support 

member has a 24-inch diameter, resulting in a total ground disturbance of 0.1 acre.

c Culverts are spaced at approximately every 1,000 feet across access roads (i.e., the GMT1–GMT2 Access Road and the Airstrip Access Road). Culverts will not be placed across 

pads and the airstrip. The exact location, spacing, size, and quantity of culverts will be determined during a summer field survey prior to construction. Culverts will be placed to ensure 

that natural drainage is maintained in accordance with U.S. Army Corps of Engineers permit special conditions. 

d Total gravel footprint acreage does not include 0.1 acre from the installation of new pipeline vertical support members between GMT2 and GMT1.
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2.4 Features Common to All Alternatives

The following section provides descriptions of features that are common to several of the action 

alternatives. Descriptions of each specific alternative are in Sections 2.5 through 2.8, and specific 

descriptions of components that vary from the general descriptions are presented in this section. 

2.4.1 Schedule

The construction and operation of all action alternatives would follow one of two schedules. The 

difference in these schedules deals with the construction of the GMT2 Project; drilling and operations are 

the same under each schedule. Under the first construction schedule, ConocoPhillips proposes to 

construct the GMT2 facilities over the course of two ice road seasons (winter through spring) spanning 3 

calendar years. Under the second construction schedule, ConocoPhillips proposes to construct the GMT2 

facilities over the course of three ice road seasons spanning 4 calendar years. As detailed design 

progresses, the schedule may be modified. However, the identified work would generally occur in the 

indicated seasons and sequence. 

2.4.1.1 Construction Schedule 1

• 1Q–3Q of Year 0: Record of decision signed by the BLM, final investment decision by 

ConocoPhillips 

• 4Q of Year 0: Order long-lead materials for the GMT2 Project (e.g., pipeline steel)

• 4Q of Year 1: Begin first season ice road construction in support of GMT2 

• 1Q of Year 2: Gravel mining, construction of gravel roads, pads, and airstrips (if relevant), begin 

pipeline construction (e.g., vertical support members) 

• 2Q–3Q of Year 2: Work gravel, perform GMT1 and Alpine Central Processing Facility/CD1 tie-in 

work

• 4Q of Year 2: Begin second season ice road construction in support of GMT2 construction 

• 1Q of Year 3: Install vertical support members, pipelines, power and telecom cables, and facilities

• 2Q–3Q of Year 3: Install GMT2 modules, GMT2 pad pipe racks, and GMT2 pad tie-ins 

• 4Q of Year 3: Complete construction and hydrotest 

• 2Q of Year 3–Year 10: Drill up to 48 wells, first oil anticipated in 4Q of Year 3. 

• Year 11–Year 32: Project in routine operations phase

2.4.1.2 Construction Schedule 2

• 1Q–3Q of Year 0: Record of decision signed by the BLM, final investment decision by 

ConocoPhillips 

• 4Q of Year 0: Order long-lead materials for the GMT2 Project (e.g., pipeline steel). Begin first season 

ice road construction in support of GMT2. 

• 1Q of Year 1: Gravel mining, construction of gravel roads, pads and airstrips (if relevant) 

• 2Q–3Q of Year 1: Work gravel

• 4Q of Year 1: Begin second season ice road construction in support of GMT2 construction 

• 1Q of Year 2: Begin pipeline construction, install vertical support members 

• 2Q–3Q of Year 2: Perform GMT1 and Alpine Central Processing Facility/CD1 tie-in work 

• 4Q of Year 2: Begin third season ice road construction in support of GMT2 construction 

• 1Q of Year 3: Finish pipeline construction, install power and telecom cables, build facilities 

• 2Q–3Q of Year 3: Install GMT2 modules, GMT2 pad pipe racks, and GMT2 pad tie-ins 

• 4Q of Year 3: Complete construction and hydrotest 

• 2Q of Year 3–Year 10: Drill up to 48 wells, first oil anticipated in 4Q of Year 3. 

• Year 11–Year 32: Project in routine operations phase 
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The BLM expects that drilling would continue until all planned wells are completed, and that the drilling 

of wells will be consecutively for the purposes of this document. However, ConocoPhillips will determine 

the timing of drilling based upon economics and rig availability. Drilling is expected to progress at a rate 

of 54 days needed per well, or a total of 2,592 days needed (54 days per well [times] 48 wells). 

2.4.2 Location 

All action alternatives have project components in the same general location. The location of the proposed 

GMT2 drill pad, pipelines, and the existing Arctic Slope Regional Corporation Mine site do not vary 

among the alternatives. The proposed GMT2 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. 

The Arctic Slope Regional Corporation 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 Arctic Slope Regional Corporation Mine site is a commercial gravel material 

source owned and operated by Arctic Slope Regional Corporation. Gravel extraction from the Arctic 

Slope Regional Corporation Mine site is permitted separately as described in Section 2.4.6.

2.4.3 Drill Pad and Support Facilities

The proposed GMT2 pad would be constructed with gravel and be a minimum of 5-feet thick with side 

slopes of 2-feet wide to 1-foot high (2:1) (Appendix A, Sheet 31 of 33). Additional pad thickness would 

be provided if needed for thermal protection of permafrost. The pad surface designs and locations vary 

among alternatives and are discussed in their respective sections.

The drill pad is sized and designed to allow for all drilling and operation of site facilities, wellhead 

shelters, drill rig movement, drilling material storage, and well work equipment. Plans include up to 48 

wells (approximately half production wells, half injection wells) at 20-foot wellhead spacing (Appendix 

A, Sheet 21 of 33). Insulated conductors and thermosyphons would be used to reduce subsidence and 

protect structural components from freeze-thaw damage.

Hydraulic fracture stimulation of some wells during winter when an ice road connects CD1/Alpine 

Central Processing Facility to Kuparuk for access to equipment and supplies. Hydraulic fracturing will 

only occur in the initial stage of drilling to stimulate flow at the production wells, and is not needed for 

continued production during the life of the well. All hydraulic fracturing activities will comply with 

Alaska Oil and Gas Conservation Commission (AOGCC) regulation found in 20 AAC 25.283. Seawater 

will be hard-piped to the GMT2 site for use in the hydraulic fracturing. There are no plans to use 

freshwater or to truck the seawater to GMT2. Acidizing will not occur at GMT2 wells because the source 

rock does not lack permeability that can be enhanced by acidizing. Disposal of fluids generated by 

fracking operations at GMT2 will be trucked to CD1/Alpine for disposal. Generally, no more than 30 

truck trips will be required per well to dispose of hydraulic fracturing fluids.

The GMT2 drill pad under all action alternatives would include the following on-pad facilities: 

• Emergency shutdown module 

• Fuel gas module 

• Test separator module

• Remote electrical and instrumentation module 

• Pig launching/receiving module

• Chemical injection module (including tanks within module, containment, and exterior tank fill 

connection) 

• Production heater skid 
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• Metering module 

• Communication tower

• High mast lights

• Switchgear-module 

• Well houses

• Two oil-insulated transformer platforms 

• Low pressure and high pressure pipe rack 

• Sand handling module 

All action alternatives will also include chemical storage with containment and truck loading at the 

GMT1 and GMT2 pads for bulk loading and unloading. Alternative C, Section 2.7, describes additional 

facilities needed. 

There are no plans for processing of production fluids beyond royalty determinations and process fluid 

heating at the drill site. The pad would be oriented roughly northeast to southwest in line with wind rose 

data from Nuiqsut to minimize snow accumulation on the site. 

The CD1/Alpine Central Processing Facility power system would provide electric power for GMT2 

operations. Power cables would be suspended from the pipeline horizontal support members via a 

messenger cable, as shown in Appendix A, Sheets 23 through 27 of 33. The drill rig and drill camp would 

use a temporary power connection, fueled by ultra-low sulfur diesel until the permanent GMT2 drill site 

power supply system is commissioned. Alternative fuel usage will be evaluated as technology becomes 

available in accordance with Supplemental BMP 1: Air Quality of the GMT1 Record of Decision (BLM 

2015). Natural gas, gasoline, and other fuel mixtures producing less carbon dioxide (CO2), sulfur dioxide 

(SO2) and particulate matter will be incorporated if and when practicable. A fiber optic cable providing 

communication support between GMT1 and GMT2 would be suspended from horizontal support 

members via the same messenger cable as the powerlines, as shown in Appendix A, Sheet 23 of 33.

2.4.4 Pipelines

The GMT2 Project would produce oil, gas, and water that would be carried by pipelines from the GMT2 

pad to the Alpine Central Processing Facility at CD1 for processing. Sales quality crude oil processed at 

the Alpine Central Processing Facility would be shipped to market from CD1 via the existing Alpine Oil 

Pipeline and Kuparuk Pipeline to the Trans-Alaska Pipeline System.

Miscible injectant and injection water (for enhanced oil recovery) would be delivered by pipeline to the 

GMT2 pad from CD1/Alpine Central Processing Facility. Lean gas for artificial lift would also be 

transported from CD1/Alpine Central Processing Facility. The production crude and water injection 

pipelines would be designed to allow pipeline inspection and maintenance (e.g., pigging) between the 

GMT2 pad and CD1/Alpine Central Processing Facility. Pipeline design would comply with the American 

Society of Mechanical Engineers Codes B31.4 and B31.8, applicable federal and state standards, and 

ConocoPhillips internal standards. All pipelines would be hydrotested prior to startup as required by the 

code of construction (e.g., B31.4 and B31.8). 

Common vertical support members would support the pipelines, placed approximately 55 feet apart. Fiber 

optic cable and power cables would be suspended from the same vertical support members via messenger 

cable attached to the horizontal support members. The decision to use messenger cables rather than cable 

trays (as authorized by BLM [2004a]) was based on ConocoPhillips’s experience showing that over time 

cable trays do not have sufficient structural integrity to span the distance between vertical support 

members; messenger cables are the current industry standard. 
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Pipelines (including suspended cables) would be a minimum of 7 feet above ground. This also decreases 

the risk of reduced clearance between the snow surface and the bottom of pipelines, especially during 

harsh winters (Lawhead et al. 2006b).

The proposed GMT2 Project includes two major pipeline segments as addressed below. 

2.4.4.1 GMT2 to GMT1 Pipeline Segment

The GMT2 to GMT1 pipeline segment would require 800 to 1,000 new vertical support members, and 

depending on final road alignment, would be placed approximately 55-feet apart. Appendix A, Sheets 7 

through 12, show the GMT2 to GMT1 pipeline route. Appendix A, Sheet 23 includes details of the GMT2 

to GMT1 pipeline segment as follows: 

• 20-inch produced fluids pipeline: crude oil, gas, and water transported from GMT2 to GMT1 

• 14-inch injection water pipeline: seawater or produced water transported to GMT2 from GMT1; at 

GMT1 it will connect to a 14-inch waterline from Alpine Central Processing Facility

• 6-inch gas pipeline: lean gas transported to GMT2 from GMT1 for gas injection/artificial lift; at 

GMT1 it will connect to a 6-inch gasline from Alpine Central Processing Facility

• 8-inch miscible injectant pipeline: miscible injectant transported to GMT2 from GMT1 for injection 

to support enhanced oil recovery; at GMT1 it will connect to an 8-inch gasline from Alpine Central 

Processing Facility

• Power and fiber optic communication cables suspended from horizontal support members via 

messenger cable

• Space for a future 24-inch pipeline

2.4.4.2 GMT1 to CD1/Alpine Central Processing Facility Pipeline Segments

Pipelines required as part of the GMT2 Project would be placed on permitted or existing vertical support 

members within the existing right-of-way from GMT1 to CD1/Alpine Central Processing Facility. 

Appendix A, Sheets 12 through 20, shows the GMT1 to CD1/Alpine Central Processing Facility pipeline 

route. Details of the GMT1 to CD1/Alpine Central Processing Facility pipeline segments are in Appendix 

A, Sheets 24 through 27, and include: 

• GMT1 to CD5: A power cable suspended from permitted horizontal support members via a new 

messenger cable; 

• CD5 to CD4N: A 20-inch produced fluids pipeline placed on existing racks and a power cable 

suspended from existing horizontal support members via a new messenger cable; 

• CD4N to CD2 Junction: A 20-inch produced fluids pipeline placed on permitted racks, an 8-inch 

miscible injectant pipeline placed on permitted racks, and a power cable suspended from permitted 

horizontal support members via a new messenger cable; and,

• CD2 Junction to CD1/Alpine Central Processing Facility: A 20-inch produced fluids pipeline placed 

on permitted racks, an 8-inch miscible injectant pipeline placed on permitted racks, and a power cable 

suspended horizontal support members from permitted via a new messenger cable. 

2.4.4.3 Valves and Vertical Loops

No manual valves or automatic valves, or vertical loops will be installed as part of the GMT2 to GMT1 

pipeline segment because it does not include any major water crossings. Manual valves will be installed 

over water crossings along other segments (e.g., east of GMT1) as required by the Alpine Satellite 

Development Plan Record of Decision (BLM 2004a). This is consistent with industry standards. 
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2.4.5 Ice Roads and Ice Pads

Ice roads are used to support every year of construction activities, whether 2 or 3 years, as well as general 

vehicle access to Alpine facilities in all alternatives. Typically, ice road construction is dependent upon 

ground temperature and precipitation (i.e., snow for pre-packing of routes) and begins in November–

December. Vehicle access via ice road depends on dates of opening and closing of the ice road and the 

distance from the main Alpine operations. The useable ice road season for travel to GMT2 is shorter than 

that of other projects such as CD3 by the logistical challenges of constructing and completing a more 

remote ice road.

The earliest opening dates and latest closure dates for ice roads between drill site 2L (in Kuparuk Field) to 

CD1/Alpine Central Processing Facility and between drill sites CD2 and CD3 for the 11-year period 2004 

through 2014 are provided in Table 6. Based on these data, for the GMT2 Project, the ice road season (ice 

road construction is complete and open for vehicle use) is defined as February 1 through April 20 of each 

year.

Table 6. Summary of historical ice road opening/closure, 2004–2014

Open/Close Dates

Ice Road from Drill Site 2L to Alpine 

Central Processing Facility Ice Road from CD2 to CD3

Earliest Date Open January 16 January 4

Latest Date Open February 2 January 26

Earliest Date Closed April 27 April 27

Latest Date Closed May 7 May 7

Range of Days Open 91 to 107 104 to 121

The annual ice road season for GMT2 is expected to be 80 days and will last from February 1 through 

April 20. The shorter ice road season is assumed based on the distance of GMT2 from Alpine (i.e., it will 

most likely be completed last and closed to vehicle use first) and correlates well with the 80-day ice road 

season documented for exploration projects which have occurred in NPR-A over the last decade.

2.4.6 Gravel Supply Options

The Arctic Slope Regional Corporation Mine site is the proposed gravel source for all alternatives. The 

Arctic Slope Regional Corporation Mine site is an existing commercial gravel source on the East Channel 

of the Colville River, approximately 6 miles southeast of CD4, 21.0 miles east of GMT2, and 4.5 miles 

east-northeast of Nuiqsut. The Arctic Slope Regional Corporation Mine site is on Alaska Native Claims 

Settlement Act Native corporation land: the Kuukpik Corporation owns the surface estate, and the Arctic 

Slope Regional Corporation owns the subsurface estate including sand and gravel resources.

BLM (2004a, page 3) approved Clover potential gravel source as the gravel source. The Clover mine site 

is a 65-acre potential undeveloped gravel source within the NPR-A. The BLM approved issuance of BLM 

permits for the extraction and sale of gravel in 2004. BLM (2004a) included mitigation requiring that the 

mine (Clover site) be rehabilitated, based on the rehabilitation plan included as Appendix O of BLM 

(2004a), including interim reclamation (BLM 2004a, page 23). The Clover site would require further 

NEPA analysis should ConocoPhillips or another group propose to develop it in the future. 

In 1997, the Arctic Slope Regional Corporation Mine site received permit authorization from the U.S. 

Army Corps of Engineers for the 10-year, phased development of the 150-acre site including the 

excavation of up to 5 million cubic yards of sand and gravel material. Extraction of material from within 

the 67-acre Phase 1 operating area produced 1.03 million cubic yards of gravel (U.S. Army Corps of 

Engineers 2012c). Subsequent reclamation of Phase 1 has foreclosed the area to future mining, although 
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overburden material may still be disposed of onsite to facilitate creation of bird nesting islands and 

shallow water habitat.

In 2004, Arctic Slope Regional Corporation obtained permits from the U.S. Army Corps of Engineers to 

continue extraction of gravel material from the 83-acre Phase 2 area of the mine site. Two cells have been 

mined within the Phase 2 operating area: approximately 20 acres in 2005 and 5 acres in 2007 (U.S. Army 

Corps of Engineers 2012c). Up to 2 million cubic yards of additional gravel extraction from two cells 

within Phase 2 was authorized under permit POA-1996-869-M4: Cell #1 in the eastern portion and Cell 

#2 in the western portion (U.S. Army Corps of Engineers 2013). 

Two recent projects used a total of 1.1 million cubic yards of gravel: approximately 595,700 cubic yards 

for CD5 (U.S. Army Corps of Engineers 2011) and approximately 455,000 cubic yards for the Nuiqsut 

Spur Road project (U.S. Army Corps of Engineers 2014a). Another 628,000 cubic yards of gravel is 

expected to be used for the GMT1 Project, which began construction in January 2017. The gravel for 

CD5 and the Nuiqsut Spur Road was taken from Arctic Slope Regional Corporation Mine site Phase 2. 

Gravel for the GMT1 Project came from a 25-acre parcel in Phase 3 of the Arctic Slope Regional 

Corporation Mine site, authorized under permit POA-1996-869-M10. 

The Arctic Slope Regional Corporation Mine site includes a total of 580 acres: 150 that have been 

permitted (Phase 1 and 2) and 430 new acres (Phase 3) that are underlain with known sand and gravel 

deposits (U.S. Army Corps of Engineers 2012c). Phase 3 is located immediately south of the Phase 2. 

Assuming that gravel within Phase 3 is similar to quantities of gravel per acre as identified within Phase 2 

(BLM 2014), gravel from the Arctic Slope Regional Corporation Mine site is potentially available for use 

in the GMT2 Project. 

Phase 3 is only partially permitted; authorization would need to be obtained from the U.S. Army Corps of 

Engineers prior to gravel extraction for the construction of GMT2. Upon permitting, the material in this 

area will be available for public and private project use in the Colville River Delta area and adjacent 

areas. Winter geotechnical work would occur as needed to delineate and assess sand and gravel resources. 

All gravel mining work would be performed during the winter season (U.S. Army Corps of Engineers 

2012c). 

A general relationship of 1 acre disturbed for a gravel mine to meet the gravel needs for 5 acres of gravel 

pad, road, airstrip, or other development is identified in BLM (2012, Section 4.2.2, page 26). However, 

since the Arctic Slope Regional Corporation Mine site was recently used for CD5 and the Nuiqsut Spur 

Road, there is more specific information available about the site. Based upon this information, it is 

expected that 23 acres of the Arctic Slope Regional Corporation Mine site footprint will be disturbed to 

provide gravel for the GMT2 Project. Mined gravel would be transported from the Arctic Slope Regional 

Corporation Mine site to the GMT2 gravel use areas (e.g., gravel pads, airstrip, road locations) over ice 

roads during Year 1. 

Because the Arctic Slope Regional Corporation Mine site is an existing commercial mine, some impacts 

such as disturbance of vegetation and habitat associated with removal of overburden, and creation of 

ramps are potentially less than for developing a new mine in an undisturbed location. The U.S. Army 

Corps of Engineers considered these impacts when issuing permits for the mine (U.S. Army Corps of 

Engineers 2016). Mining impacts are addressed for each affected resources in Sections 4.2, 4.3, and 4.4 of 

this supplemental EIS (as applicable), that could be caused by or result from mining at the Arctic Slope 

Regional Corporation Mine site. 

The gravel mining site will be rehabilitated as required under the approved Arctic Slope Regional 

Corporation Gravel Mine Reclamation Plan (U.S. Army Corps of Engineers 2016). BLM (2014) noted 

that a reclamation plan was developed for the Arctic Slope Regional Corporation Mine site as part of the 
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original permitting process, and that the U.S. Army Corps of Engineers approved a revised reclamation 

plan in 2004 for Phase 1 and 2 areas. The reclamation and mitigation goal is for waterfowl habitat with a 

matrix of undisturbed tundra, deep water, shallow and very shallow littoral, and waterfowl nesting 

islands. All reclamation work will occur as part of an overall gravel mining operation because both the 

overburden material and heavy equipment necessary for the activities would be available (BLM 2014).

2.4.7 Camp Requirements, Locations, and Availability

The following camps may be used to support GMT2 construction and operations: 

• Existing facilities at CD1/Alpine Central Processing Facility.

• One or more facilities in Nuiqsut, including the Arctic wolf camp or the Nuiqsut Hotel. During the 

winter, workers would be based only in Nuiqsut and would access GMT2 via ice road. 

• GMT2 Temporary Construction Camp located at the Kuukpik 10-acre pad at the junction of the CD5 

road and Nuiqsut Spur Road may be used year-round during construction. 

• A temporary construction camp on an ice pad, located near a drill site that can utilize power from the 

Alpine Central Processing Facility power grid. 

• GMT2 Camp(s): camps located at the GMT2 drill pad or occupied structure pad.

2.4.8 Water Use

Fresh water would be required for domestic use at remote construction camps and for construction and 

maintenance of ice roads and ice pads. Potable water requirements are based on a demand of 100 gallons 

per day per person. Freshwater may be used for hydrostatic testing. Approximately 1.5 million gallons of 

water per mile are used for typical 35- to 50-foot wide ice road construction; the pipeline construction ice 

road is wider, and requires more water. Ice roads would typically be available for use for 80 days each 

winter season. 

Water for construction and maintenance of ice roads and pads would be withdrawn from lakes in the 

vicinity of the GMT2 construction activities as allowed by State of Alaska temporary water use 

authorizations and fish habitat permits where necessary. Water use is also presented in the discussion of 

each alternative. 

Drilling water requirements are estimated to be 2 million gallons per well. A 10-acre ice pad, requiring 

2.5 million gallons of water would be required to support drilling activities under all alternatives. A 

10-acre ice pad has been used historically at CD3, CD5, and GMT1 for additional drilling/well support 

activities such as hydraulic fracturing and placement of the rig camp, and will be used in the same manner 

for GMT2. The use of the temporary ice pad for 80-90 days during winter reduces the permanent gravel 

footprint of the drill site that would be required to conduct the same effort. The ice pad will move each 

year and be located on the north or south side of the drill site nearest the active well drilling. 

Water for drilling may be withdrawn from lakes in the vicinity of the project as allowed by temporary 

water use authorizations and fish habitat permits where necessary. See Table 5 for water use for each 

project alternatives.

2.4.9 Erosion Control Measures

The GMT2 Project would follow the Alpine Facilities Erosion Control Plan, which will be updated to 

include the GMT2 Project. The Alpine Facilities Erosion Control Plan outlines procedures for operation, 

monitoring, and maintenance of various erosion control methods. Erosion control at CD1/Alpine Central 

Processing Facility is accomplished using a combination of biotechnical and engineering control (physical 

armor) methods. 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 
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with permanent erosion protection once the gravel had been allowed to season (settle and drain). Alpine’s 

Storm Water Pollution Prevention Plan will be amended to cover management of GMT2 and drainage for 

other pads. 

The Alpine Facility Erosion Control Plan also contains snow removal and dust control measures. Snow 

removal plans include the use of snow-blowing equipment to minimize gravel carryover to the tundra and 

placing cleared snow in designated areas. The Alpine Facility Erosion Control Plan discusses snow 

removal and gravel deposition removal. ConocoPhillips selects snow push areas annually, based on 

avoiding areas of thermokarsting, proximity to waterbodies, and evaluating how the area looks based on 

previous years’ activities. Snow clearing typically results in small amounts of gravel being pushed onto 

the tundra. As noted in the Alpine Erosion Control Plan, gravel removal from tundra will typically be 

performed by personnel using hand tools, but may require the use of heavy equipment for large 

depositions. Gravel deposition due to snow removal will be minimized to the maximum extent possible 

and gravel removal will be conducted in accordance with all U.S. Army Corps of Engineers regulations 

and permit stipulations. The dust control plan includes watering gravel roads to minimize dust impacts on 

the tundra and maintain the integrity of the roads.

2.4.10 Spill Prevention and Response

GMT2 Project facilities have been designed to minimize the possibility of spills. Section 4.5 provides a 

detailed discussion of the impacts associated with potential spills. In addition, ConocoPhillips will 

implement a pipeline maintenance and inspection program and an employee spill prevention training 

program to further reduce the likelihood of spills occurring. 

ConocoPhillips designs and constructs pipelines to comply with applicable state, federal, and local 

regulations. In addition, ConocoPhillips will go beyond those minimum requirements, as described below. 

The pipelines would be constructed of high-strength steel and would have wall thicknesses equal to or in 

excess of regulatory requirements. Welds would be validated using non-destructive examination (i.e., 

radiography and ultrasonic) during pipeline construction to ensure their integrity, and the pipelines would 

be tested hydrostatically prior to operation. The production crude and water injection pipelines will be 

fully capable of using pigs1

 for cleaning and corrosion inspection operations. 

If a spill occurs on a pad, the fluid is expected to remain on the pad, unless the spill is near the pad edge 

or exceeds the retention capacity of the pad. The retention capacity of the gravel pad is estimated at 0.125 

barrels per cubic yard of gravel for the purpose of planning spill response (Alaska Clean Seas 2015). In 

the event of a release, all contaminated gravel will be picked up as soon as possible to comply with permit 

stipulations and determine the extent of the spill. Fuel transfers near pad edges will be limited as much as 

possible in order to mitigate the risk of a spill leaving the pad. 

ConocoPhillips’s design of production facilities includes provisions for secondary containment for 

hydrocarbon-based and hazardous materials, as required by state and federal regulatory requirements. 

In addition to regulations governing spill prevention and response, the GMT2 Project would also be 

managed under the 2013 BLM BMPs A-1 through A-7, and E4. ConocoPhillips will also adhere to the 

supplemental best management practices for spill prevention and response included in the GMT1 Record 

of Decision (BLM 2015): Supplemental BMP Practice 1, which updates BMP A-4, Supplemental BMP 

Practice 2, which updates BMP A-3, Supplemental BMP Practice 3, which updates BMP A-3, 

 

1 “Pig” refers to pipeline inspection and maintenance tools. A pig is a cylindrical metal tool that is carried along with the flow of 

oil in the pipeline. Different types of pigs perform different functions, from scrubbing and removing buildup from the inside of 

the pipeline to inspecting the structural integrity of the pipeline.
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Supplemental BMP Practice 4, which provides additional clarification for BMP A-3, and Supplemental 

BMP Practice 5, which updates BMP E-4. 

2.4.10.1 Spill Prevention

Spill prevention and response measures that would be used during construction and operation at the 

GMT2 pad are outlined in the Alpine Field and Satellites and Alpine Pipeline System Oil Discharge 

Prevention and Contingency Plan approved by the ADEC in February 2018. (Appendix P). The intent of 

these plans is to demonstrate ConocoPhillips’s capability to prevent oil spills from entering the water and 

land and to ensure rapid response if a spill event occurs. The Alpine Oil Discharge Prevention and 

Contingency Plan complies with State of Alaska requirements in AS 46.04.030(b), 18 AAC 75 for spill 

prevention, and federal EPA regulations in 40 CFR Part 112, Subpart D (Facility Response Plans). The 

Spill Prevention, Control, and Countermeasures Plan complies with the federal EPA regulations in 40 

CFR 112.

ConocoPhillips would implement these plans to minimize accidental oil spill impacts. The current Alaska 

Department of Environmental Conservation approved Alpine Oil Discharge Prevention and Contingency 

Plan would be amended to include the GMT2 pad. Through the amended Alpine Oil Discharge Prevention 

and Contingency Plan, ConocoPhillips will demonstrate that readily accessible inventories of appropriate 

oil spill response equipment and personnel at Alpine will be available for use at the drill site. In addition, 

the spill response cooperative, Alaska Clean Seas, is ConocoPhillips’s primary response action contractor. 

Alaska Clean Seas provides trained personnel to manage all stages of a spill response, from containment 

and recovery to cleanup. 

There is potential for pipeline spills where the pipeline crosses under the road, due to corrosion of the 

buried portion of the pipe (i.e., GMT1 to CD1/Alpine Central Processing Facility pipeline segments). The 

likelihood of corrosion occurring is reduced through pipeline design and monitoring. The pipeline is 

coated and carried in casing beneath the raised road surface, but above the tundra/soil. This design 

significantly reduces risk of external corrosion that is common with buried steel piping that is in contact 

with soil. In addition, ConocoPhillips maintains a corrosion control program and an inspection program 

that includes ultrasonic inspection, radiographic inspection, coupon monitoring, metal loss detection pigs 

and geometry pigs, and forward-looking-infrared technology. The inspection programs are American 

Petroleum Institute Standard 570-based programs that focus inspection efforts on areas of greatest 

potential. These programs are described in the Alpine Oil Discharge Prevention and Contingency Plan. 

The Alpine Spill Prevention, Control, and Countermeasures Plan is implemented to prevent oil discharge 

to waters of the U.S. It describes ConocoPhillips’s spill prevention programs in place that minimizes the 

potential for oil discharges to water at Alpine facilities. The Alpine Spill Prevention, Control, and 

Countermeasures Plan would be amended to include GMT2. 

2.4.10.2 Spill Response

The threat to rivers and streams from a possible pipeline spill between the GMT2 drill pad and 

CD1/Alpine Central Processing Facility would be minimized by quickly intercepting, containing, and 

recovering spilled oil near the waterway-pipeline crossing points. The response strategy for GMT2 

Project involves two approaches: a design component approach, and an equipment pre-staging approach, 

as described below:

• Design Component: The pipelines would generally be north (downstream) of the road from CD4N 

westward until just east of GMT1 pad. Placing the pipelines on the downstream side (i.e., north) side 

of the road would prevent ice impacts to the pipelines during breakup because the road would act as a 

barrier to ice. Road stream crossings would be used as primary control points to contain potential 

spilled oil. The road could be used for access and staging for spill response. 
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• Equipment Pre-Staging: Spill response equipment would be placed at the GMT2 drill pad for an 

initial response. This strategy would facilitate the rapid deployment of equipment by personnel. The 

effective response time would be considerably reduced by this pre-staging concept and this would 

expedite equipment deployment to contain and recover spilled oil to minimize the affected area. 

During summer, pre-staged containment boom placed at strategic locations near selected river 

channels would facilitate a rapid response. Pre-deployed boom may also be placed within selected 

river channels to mitigate a spill.

2.4.10.3 Spill Training and Inspections

ConocoPhillips provides regular training for its employees on the importance of preventing oil or 

hazardous materials spills. ConocoPhillips provides new-employee orientation, annual environmental 

training seminars, and appropriate certification classes for specific issues, covering spill prevention. 

ConocoPhillips employees participate in frequent safety meetings, which address spill prevention issues, 

as appropriate. The ConocoPhillips Incident Management Team participates in regularly scheduled 

training programs and conducts spill response drills in coordination with federal and state agencies. 

Employees are encouraged to participate in the North Slope Spill Response Team. Alaska Clean Seas 

provides weekly spill response training to the North Slope Spill Response Team members in order to 

ensure continuous availability of skilled spill responders on the North Slope. 

ConocoPhillips is required to conduct visual examinations of pipelines and facility piping at least monthly 

during operations. ConocoPhillips is capable of providing aerial overflights as necessary to allow 

inspection both visually and with the aid of forward looking infrared (FLIR) technology. FLIR technology 

allows identification of spills based on the temperature “signature” resulting when warm fluid (oil) leaks. 

This technology is capable of detecting warm spots in low-light conditions, or when other circumstances 

such as light fog or drifted snow limit visibility. FLIR technology also has the ability to identify trouble 

spots along the pipeline, such as damaged insulation, before a problem occurs. ConocoPhillips would also 

conduct regular visual inspections of facilities and pipelines from gravel roads under Alternative A. 

Inspections would be conducted via ice road and aircraft under Alternative C. 

2.4.11 Fuel and Chemical Storage

Diesel will be stored in temporary tanks onsite during construction under all alternatives. During the 

drilling and operations phase (after first oil) fluids that may be stored in permanent tankage include diesel, 

corrosion inhibitor, scale inhibitor, methanol, emulsion breaker, weathered crude, and foam inhibitor. No 

other fuels or chemicals will be stored onsite at the GMT2 pad. 

Fuel storage would comply with state and federal oil pollution prevention requirements, according to the 

Alpine Field and Satellite and Alpine Pipeline System Oil Discharge Prevention and Contingency Plan 

and Alpine Spill Prevention, Control, and Countermeasure Plan (Appendix P). Secondary containment for 

fuel storage tanks would be sized as appropriate to container type and according to governing regulatory 

requirements in 18 AAC 75 and 40 CFR 112. Fuel and chemical storage associated with the GMT2 

Project would also be managed under BLM stipulations (BLM 2008a) and BMPs A-3, A-4, and A-5 

(BLM 2013a). In addition ConocoPhillips will adhere to the supplemental best management practices for 

fuel and chemical storage included in the GMT1 Record of Decision (BLM 2015) (see Section 2.4.10). 

2.4.12 Waste Handling and Disposal

Sanitary wastes that may be generated from the various camps would be hauled to an approved disposal 

site or treated and discharged under the Alaska Pollutant Discharge Elimination System General Permit 

AKG573000. AKG573000 is a small domestic general permit that allows discharge of domestic 

wastewater associated with camps during construction. It can cover discharges up to 1 million gallons per 

day. Food waste would be incinerated either at GMT2 or at Alpine Central Processing Facility and non-
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burnable waste would be recycled or transported to the North Slope Borough landfill at Deadhorse. Other 

hazardous and solid waste associated with the GMT2 Project would be managed under Alaska 

Department of Environmental Conservation and EPA regulations as well as BLM stipulations (BLM 

2008a) and BMPs A-1, A-2, A-6, and A-7 (BLM 2013a). Drilling wastes (i.e., muds and cuttings) would 

be disposed of through annular disposal onsite and/or transported to an approved disposal well such as the 

Alpine Central Processing Facility disposal well at CD1. Annular disposal is pumping down the well 

through the space between two casing strings, known as the annulus with the mud and cuttings entering 

an approved horizon below the outer casing string’s shoe. Drill cuttings may be washed and reused. 

Reserve pits are not required and will not be constructed. A temporary storage cell may be constructed for 

staging of muds and cuttings prior to disposal. Any temporary storage would comply with the Alaska 

Department of Environmental Conservation solid waste permit and would not result in any additional 

impacts to the waters of the U.S. Produced water would be processed at Alpine Central Processing 

Facility and re-injected to the subsurface as part of pressure maintenance/waterflood for secondary 

recovery. Well-work waste materials would be managed according to the Alaska Waste Disposal and 

Reuse Guide. No Class I disposal well and injection facility would be located on the GMT2 pad due to 

lack of an acceptable disposal horizon at this location. The Ivishak is the preferred disposal horizon for 

the Class I wells. Well data indicate that the Ivishak degrades in quality from Alpine toward the GMT2 

Project location. A review of seismic and well data conducted by the project proponent in 2016 revealed 

no indication of reservoir quality suitable for injection at the GMT2 pad and confirmed what the 

surrounding wells show. Class I wastes generated by the GMT2 Project would be transported offsite for 

disposal at CD1/Alpine Central Processing Facility, Prudhoe Bay drill site 4 grind and inject, or another 

appropriate facility. Vehicle trips to transport hazardous waste for disposal are estimated to be between 1 

and 4 trips per day. 

In addition to regulations governing waste handling and disposal, the GMT2 Project would also be 

managed under the 2013 BLM BMPs A-1 through A-7, and E4. ConocoPhillips will also adhere to the 

supplemental best management practices for waste handling included in the GMT1 Record of Decision 

(BLM 2015) (see Section 2.4.10). 

2.4.13 Abandonment and Reclamation

The abandonment and reclamation of GMT2 Project facilities will be determined at or before the time of 

abandonment. The plan for GMT2 abandonment and reclamation is subject to a number of federal, state, 

and local authorities as well as private landowners. Other stakeholders would also provide comment on 

the abandonment and reclamation plan. Controlling factors may include: 

• BLM leases, applications for permit to drill and rights of way 

• U.S. Army Corps of Engineers Section 404 Permit

• State of Alaska easement

• Alaska Oil and Gas Conservation Commission requirements for plugging and abandonment of wells 

• North Slope Borough Title 19 

• Kuukpik Surface Access Agreement

The abandonment and reclamation of project facilities may involve removing gravel pads and roads or 

alternatively leaving these in place indefinitely. Revegetation of abandoned facilities could be 

accomplished by seeding with native vegetation or by allowing natural colonization. Depending on the 

types of abandonment and reclamation that occurs, summer road and air traffic could cause similar 

impacts to those experienced during construction and operations activities, but at potentially lower 

intensity levels and for shorter durations. 

If the gravel is removed as part of the reclamation process, it could be used for other development 

projects. To assist with abandonment and reclamation, the BLM holds a bond from companies conducting 
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42

development activities within the NPR-A as discussed in Section 4.8. This bond ensures that the company 

will cover the full cost of reclamation. Reclamation standards are determined by the BLM authorized 

officer at the time of reclamation.

2.5 Alternative A: ConocoPhillips’s Proposed Project, Preferred 

Alternative 

ConocoPhillips’s proposed GMT2 Project (Alternative A) includes a drill pad, a gravel access road 

(GMT1–GMT2 Access Road), and pipelines, as described below. Alternative A is depicted in Map 2.5-1. 

More detailed design drawings for the GMT2 Project are included in Appendix A. 

Construction will take either 2 or 3 years, as described in Section 2.4.1. Drilling is expected to begin in 

May of Year 3, with first oil expected at the end of Year 3. To complete all 48 wells, drilling would 

continue year-round for approximately 7 years. Operations would continue as needed to achieve 

economic and production goals, which is currently estimated to be 30 years, post construction. 

2.5.1 Project Components

Table 7 summarizes the major infrastructure components of Alternative A, the proposed action. 

Table 7. Infrastructure for Alternative A, proposed action

Component Alternative A, Proposed Action

Gravel Drill Pad 14.0 acres

Wells Up to 48

Access Road 8.2 miles, 62.8 acres

Tundra Access Road Pullouts 3 pullouts, 1.2 acres (0.4 acre each)

Elevated Pipelines on Vertical 

Support Members 

8.6 miles from GMT2 to GMT1; 0.1 acres 

9.8 miles of crude oil pipeline from CD5 to CD1/Alpine Central Processing 

Facility (on existing vertical support members); 3.3 miles of miscible 

injectant pipeline from CD4/CD5 intersection to CD1/Alpine Central 

Processing Facility (on existing vertical support members) 

Bridges None

Gravel Supply Arctic Slope Regional Corporation Mine site

Total Gravel Footprint a 78.0 acres

Total Gravel Requirement 671,300 cubic yards

Ice Roads Year 1–2: 52.6 miles

Year 2–3: 43.9 miles

a Total gravel footprint acreage does not include 0.1 acre from the installation of new pipeline vertical support members between 

GMT2 and GMT1.

2.5.2 Location 

The proposed Alternative A GMT2 pad location and pipeline route are described in Section 2.4.2. The 

road corridor for Alternative A crosses through Section 31, T11N, R3E UM; Section 6, T10N, R3E UM; 

and Sections 1, 11, 12, 14, 22, 23, 27, 32, 33, and 34, T10N, R2E UM. 

In siting the GMT2 pad, the gravel GMT1–GMT2 Access Road, and the pipeline, eight criteria were 

considered: (1) keeping infrastructure out of the Colville River Special Area, (2) wetland habitat, (3) 

archaeological resources, (4) hydrology and drainage, (5) topography, (6) minimizing gravel footprint, (7) 

load weight requirements (road), and (8) local community interests. 
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2.5.3 Drill Pad and Support Facilities

The proposed Alternative A GMT2 drill pad and facilities are described in Section 2.4.3. 

Total operational power required for the proposed Alternative A, including emergency shutdown module, 

fuel gas module, test separator module, remote electrical and instrumentation module, pig launching and 

receiving module, chemical injection module, production heater skid, pad lighting, heat trace and other 

drill site power requirements (shown in Appendix A on Sheet 21 of 33) is expected to be between 1.0 to 

2.0 megawatts electrical, depending on season (summer versus winter). Additional power for the rig 

during drilling is approximately 2.0 megawatts.

2.5.4 Access

Alternative A includes access via gravel road from GMT1 (GMT1–GMT2 Access Road) and seasonal ice 

roads to support construction, drilling, and operations. Alternative A does not include an airstrip or 

associated facilities and pads, although helicopters can directly access the site. Planned use of fixed-wing 

aircraft associated with Alternative A is for transport of personnel, equipment, and supplies to the existing 

airstrip at the Alpine CD1/Alpine Central Processing Facility. Use of helicopters will be limited to 

emergency response to the GMT2 pad, ice road clean-up during construction years, and required 

monitoring studies. Helicopters will depart from Alpine CD1/Alpine Central Processing Facility and land 

directly on the tundra. 

2.5.4.1 Roads

Alternative A will include a gravel road with culverts and ice roads during the construction phase. 

GMT1 to GMT2 Road

An 8.2-mile long gravel road (GMT1–GMT2 Access Road) will connect GMT2 to GMT1 and the 

existing Alpine Field road system. The road will include three subsistence tundra access road pullouts to 

allow local residents to access the area for subsistence use. The GMT1–GMT2 Access Road would be a 

minimum of 5-feet high with side slopes of 2:1 (Appendix A, Sheet 31 of 33) and designed to maintain 

the existing thermal regime. The road would be 32-feet wide (crown width), which is wide enough to 

allow drill rig travel. 

Where possible, the road would be constructed at least 500 feet from pipelines to minimize caribou 

disturbance (Lawhead et al. 2006a), as recommended by Cronin et al. (1994) to support greater crossing 

success. This also prevents excessive snow accumulation from snow drifts. Four stretches of the GMT1–

GMT2 Access Road would not meet this requirement: a 0.7-mile long portion located west of lake 

M9925; a 0.7-mile long portion northeast of lake M9922; a 0.9-mile long portion east of lake Z06006; 

and a 0.4-mile long portion north of lake R0062 (Map 2.5-2). Pipelines are typically constructed within 

1,000 feet of roads to allow for visual inspection for leak detection from the road; the GMT2 to GMT1 

pipeline segment is within 1,000 feet of the road or pad for its entire length. With more sophisticated leak 

detection methods now available, such as monitoring from aircraft equipped with thermal imaging 

equipment, some newer pipelines have been constructed without using this 1,000-foot constraint. 

The Alternative A pipeline and road routing between GMT2 and GMT1 would require deviations from 

two BLM requirements, as described in Section 2.2: Lease stipulation E-2, which requires a 500-foot 

setback from waterbodies and BMP E-7(c) which requires a minimum separation distance of 500 feet 

between pipelines and roads. 

The location of the GMT1–GMT2 Access Road as proposed west and northwest (downgradient) of the 

pipeline route would allow the road to act as a barrier to protect waters in Fish Creek drainage in the event 

of a potential pipeline spill. 
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Bridges and Culverts

No new major stream or river crossings are proposed for the GMT2 Project; therefore, no bridges will be 

required. The route includes a culvert crossing over the small unnamed beaded stream pool outlet draining 

from Lake M9925. 

Culverts will be placed to ensure that natural drainage is maintained in accordance with U.S. Army Corps 

of Engineers permit special conditions. The typical design of culverts is shown in Appendix A, Sheets 33 

of 33. Preliminary culvert locations for cross-flow will be selected based on aerial photography. 

ConocoPhillips (or its contractor) will then walk the road alignment to optimize final culvert locations, 

noting low areas where culverts are needed, and review the data with the Alaska Department of Fish and 

Game (regulatory agency for potential effects on fish) for concurrence. Thus, the final design for the size, 

number, and location of the culverts will be complete after the field survey is completed. The estimated 

spacing of culverts is every 1,000 feet; however, some culverts may be closer than the 1,000-feet spacing 

as is common on roads associated with oil and gas development on the North Slope. The culverts would 

be installed per the final design prior to breakup of the first construction season, but additional culverts 

may be placed after breakup as site-specific needs are further assessed with the Alaska Department of 

Fish and Game and the U.S. Army Corps of Engineers. 

Ice Roads and Pads

Ice roads would be constructed to access the gravel source and construction areas (e.g., road, drill pad, 

and pipelines). Proposed ice road routes for Alternative A (proposed project) are depicted on Map 2.5-3. 

Due to heavy equipment size and frequency of construction traffic, safety considerations dictate use of 

separate ice roads for pipeline construction, gravel placement, lake access, and general traffic. 

During Year 1–2 of construction, ice pads would be built at the gravel source and along the gravel haul 

route. During Year 2–3 of construction, ice pads would be built at both ends of the pipeline route, plus an 

additional pad for construction laydown. All action alternatives would include a 10-acre ice pad for each 

year of drilling, and a 2-acre ice pad each year post drilling, for operations and maintenance. A summary 

of ice roads and pads that would be constructed under Alternative A appears in Appendix B. 

2.5.4.2 Vehicle Traffic

Under Alternative A, personnel, equipment, and materials would be transported overland on snow trails, 

ice roads, and on the gravel GMT1–GMT2 Access Road, once it is constructed. Appendix B provides the 

details about estimated vehicle traffic trips that would be required for Alternative A. 

In Year 1, traffic would be primarily associated with pre-construction activities from mid-November 

through December. Activities would consist of pre-packing snow and constructing ice roads in preparation 

for the following construction season in Year 2. 

Alternative A vehicle traffic levels would be the highest during the first construction season (Year 1 to 

Year 2). Construction of the ice roads would be completed in January and construction of the gravel road, 

gravel drill pad, and installation of a portion of the pipeline scope would occur February through April. 

Gravel conditioning work would occur in August and September. Ice road pre-packing and construction 

for the second construction season (Year 2 to Year 3) would occur mid-November through December of 

Year 2. 

In Year 3, traffic would occur on the ice roads and the gravel GMT1–GMT2 Access Road. Vehicles would 

support pipeline and facilities construction and the beginning of drilling. Completion of the pipeline 

installation would occur February through April via ice road. Facility construction will occur February 
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through December. After April, all vehicle traffic would be on the GMT1–GMT2 Access Road. Drilling 

would begin in May. 

In Year 4, drilling would be ongoing and vehicle traffic would be at levels greatly reduced from previous 

years and would be along the GMT1–GMT2 Access Road. Vehicle traffic associated with routine 

operations would begin after first oil in December of Year 3 and would continue for the life of the drill 

site to support the facility.

2.5.4.3 Air Transport

Aircraft traffic would support transportation of work crews, materials, and equipment from Fairbanks, 

Anchorage, or Deadhorse. Under Alternative A, aircraft would typically utilize the existing CD1/Alpine 

Central Processing Facility airstrip. Flights would primarily support personnel and equipment transport 

required for construction and the start of drilling. Estimated air traffic associated with Alternative A is 

described below. 

2.5.4.4 Aircraft Traffic

Under Alternative A, personnel, equipment, and materials would be transported overland on snow trails, 

ice roads, and on the gravel GMT1–GMT2 Access Road, once it is constructed. All fixed-wing flights 

listed will land in CD1/Alpine Central Processing Facility and helicopters will base out of CD1/Alpine 

Central Processing Facility. Aircraft would maintain altitude of 1,000 feet or more except during takeoff 

and landing (within 3.6 miles of the airstrip). Flight paths would depend on prevailing winds, but would 

generally align with the airstrip orientation. Appendix B provides details about estimated aircraft trips that 

would be required for Alternative A.

During construction, fixed-wing aircraft trips are limited to between 5 and 15 flights per month for crew 

changes. Helicopter landings to support environmental studies and ice road cleanup will occur from May 

through September. 

Once construction of the GMT2 pad and GMT1–GMT2 Access Road are complete there will be no need 

for routine additional fixed-wing flights as post-construction drilling needs will be handled by flights into 

CD1/Alpine Central Processing Facility that are already part of the ongoing operations. Operation and 

maintenance will be handled by staff at the CD1/Alpine Central Processing Facility who will travel by the 

GMT1–GMT2 Access Road. Helicopter landings to support environmental studies will occur from May 

through September until the end of operations. 

2.5.5 Gravel Requirements

Under Alternative A, a total of approximately 671,300 cubic yards of material required for this project 

would be used to fill approximately 78.1 acres. Table 8 lists the amount of material that would be used for 

project components. See Appendix A, Sheet 5 for a description of project infrastructure.
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Table 8. Gravel use for Alternative A, proposed project a, b

Facility

Footprint 

(Acres)

Fill Quantity 

(Cubic Yards) Notes/Dimensions

GMT2 Pad 14.0 152,000 See Appendix A, Sheet 5 and Sheet 21 

for description of dimensions

GMT1–GMT2 Access Road 62.8 510,000 Length: 8.2 miles; crown width: 32 feet; 

minimum thickness: 5 ft

Road Pullouts for Subsistence 

Tundra Access

1.2 9,300 3 pullouts, 0.4 acres each

Total Gravel Requirement 78.0 671,300 None

a Values are approximate and may change during final design.

b Total gravel footprint acreage does not include 0.1 acre from the installation of new pipeline vertical support members between 

GMT2 and GMT1. Depending on final road placement, 800 to 1,000 vertical support members with 55-foot average spacing will be 

required.

2.5.6 Camps

The following camps are proposed to support construction and operation of the proposed GMT2 Project. 

All camps except the GMT2 Camp currently exist to support other development projects:

• Alpine Camp: 150 beds would be reserved for construction use at the main camp located at 

CD1/Alpine Central Processing Facility on the gravel pad, which is connected to the existing 

CD1/Alpine Central Processing Facility electric grid. Workers would access the GMT2 pad via ice 

road and the GMT1–GMT2 Access Road.

• Nuiqsut Hotel and Arctic Wolf Camp: The project will utilize existing beds at these two facilities 

located in Nuiqsut to support the project. 

• GMT2 Temporary Construction Camp: Located on the Kuukpik Pad at the intersection of the Spur 

Road and the CD5 Road, this camp would supply 370-456 beds for 120 days to support winter 

construction work (Year 1 to Year 3) and 175 for 245 days to support summer activities in Year 1 to 

Year 3. 

• GMT2 Camp: a 75-person rig camp located at the GMT2 drill pad and connected to the existing 

Alpine electric grid via power cable from CD1/Alpine Central Processing Facility once a connection 

is established. Prior to electric power being available, the camp will be powered via diesel generators.

During construction (Years 1 to 3), offsite camp facilities including Arctic Wolf Camp, Nuiqsut Hotel, and 

the GMT2 Temporary Construction Camp will be used. Drilling would be supported by a crew (workers 

to support drilling and well tie-in) based in a 75-person rig camp on the drill pad. This camp would be 

placed on the GMT2 Drill Pad as early as May of Year 3. After drilling, operations and maintenance 

personnel would typically commute from CD1/Alpine Central Processing Facility or Kuparuk and no 

additional camp facilities would be required.

2.5.7 Water Use

Fresh water would be required for domestic use at remote construction camps and for construction and 

maintenance of ice roads and ice pads. Potable water requirements are based on a demand of 100 gallons 

per day per person. Freshwater may be used for hydrostatic testing. Approximately 1.0 million gallons of 

water per mile are used for 35-foot wide ice road construction; ice roads for pipeline construction are 

wider than typical ice roads and may require two to four times that volume depending on the width. The 

ice road used to haul gravel from the Arctic Slope Regional Corporation Mine site will be a 35-foot ice 

road, and the ice road along the GMT2 Access Road and pipeline route will be wider to allow for pipeline 

construction. Ice roads would typically be available for use approximately 80 days each winter season, 

depending on local conditions. 
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Details about estimated water use for Alternative A are provided in Appendix B. Water for construction 

and maintenance of ice roads and pads would be withdrawn from lakes in the vicinity of the GMT2 

Project as approved by State of Alaska temporary water use authorizations and fish habitat permits where 

necessary.

2.5.8 Spill Prevention and Response

ConocoPhillips’ proposed GMT2 Project includes the GMT1–GMT2 Access Road, a gravel road 

connecting the GMT2 drill site to GMT1, which will provide year-round vehicle access to CD1/Alpine 

Central Processing Facility through existing and permitted roads. Alpine Central Processing Facility is a 

centralized facility that provides support to satellite drill sites in a variety of ways, including the 

equipment, personnel, and other support necessary to be able to respond to potential emergencies. The 

road connection to the resources at Alpine Central Processing Facility is an important part of the project 

design. In addition, ConocoPhillips would conduct regular ground-based visual inspections of facilities 

and pipelines from gravel roads under this alternative. 

The spill response strategy for GMT2 under Alternative A involves two approaches: a design component 

approach, and an equipment pre-staging approach, as described below:

• Design Component Approach: Placement of the pipeline south of the road allows the road to act as 

a barrier to prevent oil from migrating into valuable streams and wetlands where the road is 

downgradient of the pipeline (eastern half of the GMT1–GMT2 Access Road; see Section 4.2.2). 

Additionally, there are several culverts planned for the GMT2 Access Road stream crossings and 

wetlands protection. The culvert crossings would be used as the primary control points to contain 

potential spilled oil from reaching streams and wetlands in the project area. The road could be used 

for access and staging for spill response.

• Equipment Pre-Staging Approach: Spill response equipment would be placed at the drill site for an 

initial response. This strategy would facilitate the rapid deployment of equipment by personnel. The 

effective response time would be reduced considerably by this pre-staging concept and this would 

expedite equipment deployment to contain and recover spilled oil and to minimize the affected area. 

During summer, pre-staged containment booms placed at strategic locations near selected river 

channels would facilitate a rapid response. Pre-deployed booms may also be placed within selected 

river channels to mitigate a spill.

ConocoPhillips would conduct regular ground-based visual inspections of facilities and pipelines, 

including the pipeline from GMT1 to GMT2 from gravel roads under Alternative A. 

2.6 Alternative B: Alternate Alignment of GMT1–GMT2 Access 

Road 

Alternative B includes a drill pad, a gravel access road (GMT1–GMT2 Access Road), and pipelines, as 

described below. Alternative B was developed to have the GMT1–GMT2 Access Road follow the 

watershed boundary between Fish Creek and the Tinmiaqsiugvik River drainage basins. This could 

potentially move the road to higher ground and prevent contamination of two watersheds in the event of a 

spill. Alternative B is depicted in Map 2.6-1. More detailed design drawings for the GMT2 Project are 

included in Sheets 2, 7, 8, and 13-33 of Appendix A. 

Construction will take either 2 or 3 years, as described in Section 2.4.1. Drilling is expected to begin in 

May of Year 3, with first oil expected at the end of Year 3. To complete all 48 wells, drilling would 

continue year-round for approximately 7 years. Operations would continue as needed to achieve 

economic and production goals, which is currently estimated to be 30 years, post construction. 
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2.6.1 Project Components

Table 9 summarizes the major infrastructure components of Alternative B, alternate road alignment. 

Table 9. Infrastructure for Alternative B, alternate road alignment

Component Alternative B, Alternate Road Alignment

Gravel Drill Pad 14.0 acres

Wells Up to 48

Access Road 9.3 miles, 72 acres

Tundra Access Road Pullouts 3 pullouts, 1.2 acres (0.4 acre each)

Elevated Pipelines on Vertical 

Support Members

9.4 miles from GMT2 to GMT1; 0.1 acres 

9.8 miles, crude oil pipeline from CD5 to CD1/Alpine Central Processing 

Facility (on existing vertical support members); 3.3 miles, miscible injectant 

pipeline from CD4/CD5 intersection to CD1/Alpine Central Processing 

Facility (on existing vertical support members) 

Bridges None

Gravel Supply Arctic Slope Regional Corporation Mine site

Total Gravel Footprint a 87.2 acres

Total Gravel Requirement 747,300 cubic yards

Ice Roads Year 1–2: 51.9 miles

Year 2–3: 43.3 miles

a Total gravel footprint acreage does not include 0.1 acre from the installation of new pipeline vertical support members between 

GMT2 and GMT1.

2.6.2 Location 

The proposed Alternative B GMT2 pad location and pipeline route are described in Section 2.4.2. The 

road corridor for Alternative B crosses through Section 31, T11N, R3E UM; Section 6, 7 and 18, T10N, 

R3E UM; and Sections 13, 14, 22, 23, 27, 32, 33, and 34, T10N, R2E UM. 

Eight criteria considered in siting the GMT2 pad, the gravel GMT1–GMT2 Access Road, and the 

pipeline, were: (1) keeping infrastructure out of the Colville River Special Area and Fish Creek Setback, 

(2) wetland habitat, (3) archaeological resources, (4) hydrology and drainage, (5) topography, (6) 

minimizing gravel footprint, (7) load weight requirements (road), and (8) local community interests. 

2.6.3 Drill Pad and Support Facilities

The proposed Alternative B GMT2 drill pad and facilities are described in Section 2.4.3. 

Total operational power required for the proposed Alternative B, including emergency shutdown module, 

fuel gas module, test separator module, remote electrical and instrumentation module, pig launching and 

receiving module, chemical injection module, production heater skid, pad lighting, heat trace and other 

drill site power requirements (shown in Appendix A on Sheet 21 of 33) is expected to be between 1.0–2.0 

megawatts electrical, depending on season (summer versus winter). Additional power for the rig during 

drilling is approximately 2.0 megawatts.

2.6.4 Access

Alternative B includes access via gravel road from GMT1 (GMT1–GMT2 Access Road) and seasonal ice 

roads to support construction, drilling, and operations. Alternative B does not include an airstrip or 

associated facilities and pads, although helicopters can directly access the site. Planned use of fixed-wing 

aircraft associated with Alternative B is for transport of personnel, equipment, and supplies to the existing 
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airstrip at the Alpine CD1/Alpine Central Processing Facility. Use of helicopters will be limited to 

emergency response to the GMT2 pad, ice road clean-up during construction years, and required 

monitoring studies. Helicopters will depart from Alpine CD1/Alpine Central Processing Facility and land 

directly on the tundra. 

2.6.4.1 Roads

Alternative B will include a gravel road with culverts and ice roads during the construction phase. 

GMT1 to GMT2 Road 

A 9.3-mile long gravel road (GMT1–GMT2 Access Road) will connect GMT2 to GMT1 and the existing 

Alpine Field road system. The road will include three subsistence tundra access road pullouts to allow 

local residents to access the area for subsistence use. The GMT1–GMT2 Access Road would be a 

minimum of 5-feet high with side slopes of 2:1 (Appendix A, Sheet 31 of 33) and designed to maintain 

the existing thermal regime. The road would be 32-feet wide (crown width), which is wide enough to 

allow drill rig travel. 

Where possible, the road would be constructed at least 500 feet from pipelines to minimize caribou 

disturbance (Lawhead et al. 2006a), as recommended by Cronin et al. (1994) to support greater crossing 

success. This also prevents excessive snow accumulation from snow drifts. Two stretches of the GMT1–

GMT2 Access Road would not meet this requirement: a 0.6-mile long portion located east of lake 

MB0401 and a 0.1-mile long portion north of lake R0062 (Map 2.6-2). Pipelines are typically constructed 

within 1,000 feet of roads to allow for visual inspection for leak detection from the road; the GMT2 to 

GMT1 pipeline segment is within 1,000 feet of the road or pad for its entire length. With more 

sophisticated leak detection methods now available, such as monitoring from aircraft equipped with 

thermal imaging equipment, some newer pipelines have been constructed without using this 1,000-foot 

constraint. 

The Alternative B pipeline and road routing between GMT2 and GMT1 would require deviations from 

two BLM requirements, as described in Section 2.2: Lease Stipulation E-2, which requires a 500-foot 

setback from waterbodies, and BMP E-7(c) which requires a minimum separation distance of 500 feet 

between pipelines and roads. A total of 0.9 mile of the road around the north and eastern side of Lake 

M9925 would be within 500 feet of the waterbody and two sections of the road would be less than 

500 feet apart as described above. 

For the portion of the road located in the Fish Creek drainage, the location of the GMT1–GMT2 Access 

Road as proposed west and northwest (downgradient) of the pipeline route would allow the road to act as 

a barrier to protect waters in Fish Creek drainage in the event of a potential pipeline spill. 

Bridges and Culverts

No new major stream or river crossings are proposed for the GMT2 Project, therefore no bridges will be 

required. 

Culverts will be placed to ensure that natural drainage is maintained in accordance with U.S. Army Corps 

of Engineers permit special conditions. The typical design of culverts is shown in Appendix A, Sheets 33 

of 33. Preliminary culvert locations for cross-flow will be selected based on aerial photography. 

ConocoPhillips (or its contractor) will then walk the road alignment to optimize final culvert locations, 

noting low areas where culverts are needed, and review the data with the Alaska Department of Fish and 

Game (regulatory agency for potential effects on fish) for concurrence. Thus, the final design for the size, 

number, and location of the culverts will be complete after the field survey is completed. The estimated 

spacing of culverts is every 1,000 feet; however, some culverts may be closer than the 1,000 feet spacing 
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as is common on roads associated with oil and gas development on the North Slope. The culverts would 

be installed per the final design prior to breakup of the first construction season, but additional culverts 

may be placed after breakup as site-specific needs are further assessed with the Alaska Department of 

Fish and Game and the U.S. Army Corps of Engineers. 

Ice Roads and Pads

Ice roads would be constructed to access the gravel source and construction areas (e.g., road, drill pad, 

and pipelines). Proposed ice road routes for Alternative B are depicted on Map 2.5-3. Due to heavy 

equipment size and frequency of construction traffic, safety considerations dictate use of separate ice 

roads for pipeline construction, gravel placement, lake access, and general traffic. 

During Year 1–2 of construction, ice pads would be built at the gravel source and along the gravel haul 

route. During Year 2–3 of construction, ice pads would be built at both ends of the pipeline route, plus an 

additional pad for construction laydown. All action alternatives would include a 10-acre ice pad for each 

year of drilling, and a 2-acre ice pad each year post drilling, for operations and maintenance. Details about

ice roads and pads that would be constructed under Alternative B are presented in Appendix B. 

2.6.4.2 Vehicle Traffic

Under Alternative B, personnel, equipment, and materials would be transported overland on snow trails, 

ice roads, and on the gravel GMT1–GMT2 Access Road, once it is constructed. Appendix B provides 

details about estimated vehicle traffic trips that would be required for Alternative B. 

In Year 1, traffic would be primarily associated with pre-construction activities from mid-November 

through December. Activities would consist of pre-packing snow and constructing ice roads in preparation 

for the following construction season in Year 2. 

Alternative B vehicle traffic levels would be the highest during the first construction season (Year 1 to 

Year 2). Construction of the ice roads would be completed in January and construction of the gravel road, 

gravel drill pad, and installation of a portion of the pipeline scope would occur February through April. 

Gravel conditioning work would occur in August and September. Ice road pre-packing and construction 

for the second construction season (Year 2 to Year 3) would occur mid-November through December of 

Year 2. 

In Year 3, traffic would occur on the ice roads and the gravel GMT1–GMT2 Access Road. Vehicles would 

support pipeline and facilities construction and the beginning of drilling. Completion of the pipeline 

installation would occur February through April via ice road. Facility construction will occur February 

through December. After April, all vehicle traffic would be on the GMT1–GMT2 Access Road. Drilling 

would begin in May of Year 3. 

In Year 4, drilling would be ongoing and vehicle traffic would be at levels greatly reduced from previous 

years and would be along the GMT1–GMT2 Access Road. Vehicle traffic associated with routine 

operations would begin after first oil in December of Year 3 and would continue for the life of the drill 

site to support the facility.

2.6.4.3 Air Transport

Aircraft traffic would support transportation of work crews, materials, and equipment from Fairbanks, 

Anchorage, or Deadhorse. Under Alternative B, aircraft would typically utilize the existing CD1/Alpine 

Central Processing Facility airstrip. Flights would primarily support personnel and equipment transport 

required for construction and the start of drilling. Estimated air traffic associated with Alternative B is 

described below.
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2.6.4.4 Aircraft Traffic

Under Alternative B, personnel, equipment, and materials would be transported overland on snow trails, 

ice roads, and on the gravel GMT1–GMT2 Access Road, once it is constructed. All fixed-wing flights 

listed will land in CD1/Alpine Central Processing Facility and helicopters will base out of CD1/Alpine 

Central Processing Facility. Aircraft would maintain altitude of 1,000 feet or more except during takeoff 

and landing (within 3.6 miles of the airstrip). Flight paths would depend on prevailing winds, but would 

generally align with the airstrip orientation. Appendix B provides details about estimated aircraft trips that 

would be required for Alternative B. 

During construction, fixed-wing aircraft trips are limited to between 5 and 15 flights per month for crew 

changes. Helicopter landings to support environmental studies and ice road cleanup will occur from May 

through September. 

Once construction of the GMT2 pad and GMT1–GMT2 Access Road are complete there will be no need 

for routine additional fixed-wing flights as post-construction drilling needs will be handled by flights into 

CD1/Alpine Central Processing Facility that are already part of the ongoing operations. Operation and 

maintenance will be handled by staff at the CD1/Alpine Central Processing Facility, who will travel by 

the GMT1–GMT2 Access Road. Helicopter landings to support environmental studies will occur from 

May through September until the end of operations. 

. 

2.6.5 Gravel Requirements

Under Alternative B, a total of approximately 747,300 cubic yards of material required for this project 

would be used to fill approximately 87.2 acres. Table 10 lists the amount of material that would be used 

for project components. See Appendix A, Sheet 5, for a description of project infrastructure. 

Table 10. Gravel use for Alternative B, alternate road alignment a, b

Facility

Footprint 

(Acres)

Fill Quantity 

(Cubic Yards) Notes/Dimensions

GMT2 Pad 14.0 152,000 See Appendix A, Sheet 21 of 33 for

description of dimensions

GMT1–GMT2 Access Road 72 586,000 Length: 9.3 miles; crown width: 32 feet; 

minimum thickness: 5 feet

Road Pullouts for 

Subsistence Tundra Access

1.2 9,300 3 pullouts, 0.4 acres each

Total Gravel Requirement 87.2 747,300 None

a Values are approximate and may change during final design.

b Total gravel footprint acreage does not include 0.1 acre from the installation of new pipeline vertical support members between 

GMT2 and GMT1. 800 to 1,000 vertical support members, depending on final road placement, with 55-foot average spacing will be 

required.

2.6.6 Camps

The following camps are proposed to support construction and operation of the proposed GMT2 Project. 

All camps except the GMT2 Camp currently exist to support other development projects:

• Alpine Camp: 150 beds would be reserved for construction use at the man camp located at 

CD1/Alpine Central Processing Facility on the gravel pad, which is connected to the existing 

CD1/Alpine Central Processing Facility electric grid. Workers would access the GMT2 pad via ice 

road and the GMT1–GMT2 Access Road.
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• Nuiqsut Hotel and Arctic Wolf Camp: The project will utilize existing beds at these two facilities 

located in Nuiqsut, during the winter construction season to support the project.

• GMT2 Temporary Construction Camp: Located on the Kuukpik Pad at the intersection of the Spur 

Road and the CD5 Road, this camp would supply 370-456 beds for 120 days to support winter 

construction work (Year 1 to Year 3) and 175 for 245 days to support summer activities in Year 1 to 

Year 3.

• . 

• GMT2 Camp: a 75-person rig camp located at the GMT2 drill pad and connected to the existing 

Alpine electric grid via power cable from CD1/Alpine Central Processing Facility once a connection 

is established. Prior to electric power being available, the camp will be powered via diesel generators.

During construction (Years 1 to 3), offsite camp facilities including Alpine Camp, Nuiqsut Hotel, and 

Kuukpik Camp will be used. Drilling would be supported by a crew (workers to support drilling and well 

tie-in) based in a 75-person rig camp on the drill pad. This camp would be placed on the GMT2 Drill Pad 

as early as May of Year 3. After drilling, operations and maintenance personnel would typically commute 

from CD1/Alpine Central Processing Facility or Kuparuk and no additional camp facilities would be 

required. 

2.6.7 Water Use

Fresh water would be required for domestic use at remote construction camps and for construction and 

maintenance of ice roads and ice pads. Potable water requirements are based on a demand of 100 gallons 

per day per person. Freshwater may be used for hydrostatic testing. Approximately 1.0 million gallons of 

water per mile are used for 35-foot wide ice road construction; ice roads for pipeline construction are 

wider than typical ice roads and may require two to four times that volume depending on the width. The 

ice road used to haul gravel from the Arctic Slope Regional Corporation Mine site will be a 35-foot ice 

road, and the ice road along the GMT2 Access Road and pipeline route will be wider to allow for pipeline 

construction. Ice roads would typically be available for use approximately 80 days each winter season, 

depending on local conditions. 

Details of estimated water use for Alternative B are provided in Appendix B. Water for construction and 

maintenance of ice roads and pads would be withdrawn from lakes in the vicinity of the GMT2 Project as 

approved by State of Alaska temporary water use authorizations and fish habitat permits where necessary.

2.6.8 Spill Prevention and Response 

Alternative B includes the GMT1–GMT2 Access Road, a gravel road connecting the GMT2 drill site to 

GMT1, which will provide year-round vehicle access to CD1/Alpine Central Processing Facility through 

existing and permitted roads. Alpine Central Processing Facility is a centralized facility that provides 

support to satellite drill sites in a variety of ways, including the equipment, personnel, and other support 

that are necessary to be able to respond to potential emergencies. The road connection to the resources at 

Alpine Central Processing Facility is an important part of the project design. In addition, ConocoPhillips 

would conduct regular ground-based visual inspections of facilities and pipelines from gravel roads under 

this alternative. 

The spill response strategy for GMT2 under Alternative B involves two approaches: a design component 

approach, and an equipment pre-staging approach, as described below:

• Design Component Approach: Placement of the pipeline south of the road allows the road to act as 

a barrier to prevent oil from migrating into valuable streams and wetlands where the road is 

downgradient of the pipeline (eastern half of the GMT1–GMT2 Access Road; see Section 4.2.2). 
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Additionally, there are several culverts planned for the GMT2 Access Road stream crossings and 

wetlands protection. The culvert crossings would be used as the primary control points to contain 

potential spilled oil from reaching streams and wetlands in the project area. The road could be used 

for access and staging for spill response.

• Equipment Pre-Staging Approach: Spill response equipment would be placed at the drill site for an 

initial response. This strategy would facilitate the rapid deployment of equipment by personnel. The 

effective response time would be considerably reduced by this pre-staging concept and this would 

expedite equipment deployment to contain and recover spilled oil and to minimize the affected area. 

During summer, pre-staged containment booms placed at strategic locations near selected river 

channels would facilitate a rapid response. Pre-deployed booms may also be placed within selected 

river channels to mitigate a spill.

ConocoPhillips would conduct regular ground-based visual inspections of facilities and pipelines, 

including the pipeline from GMT1 to GMT2 from gravel roads under Alternative B. 

2.7 Alternative C: Roadless Development 

Alternative C is similar to Alternative A, but there is no gravel access road from GMT1 to GMT2 and the 

rest of the Alpine Field development area. Access would be by aircraft and ice road (winter only). 

Alternative C includes a drill pad, an occupied pad, an airstrip and associated facilities, a local access 

road, and pipelines. The airstrip provides year-round access to GMT2 in lieu of a gravel road. A local 

gravel access road would connect the drill pad, occupied pad, and air access facilities (airstrip and apron). 

During winter, ice roads would be constructed to access the site. Movement of the drill rig to and from 

other drill sites would be limited to the ice-road season restricting the ability to mobilize/demobilize the 

rig for work at other drill sites when it cannot work at GMT2. Alternative C is depicted in Map 2.7-1 and 

2.7-2. 

As for other action alternatives, construction will take either 2 or 3 years, as described in Section 2.4.1. 

Drilling is expected to begin in May of Year 3, with first oil expected the end of Year 3. To drill up to 48 

wells, drilling would continue year-round until Year 9 (7.1 years total). Operations would continue as 

needed to achieve economic and production goals, which is currently estimated to be 30 years, post 

construction. 
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2.7.1 Project Components

Table 11 provides the major components required for Alternative C. 

Table 11. Infrastructure for Alternative C

Component Alternative C

Gravel Drill Pad 19.1 acres

Wells Up to 48

Occupied Structure Pad 18.4 acres

Air Access Facilities 47.3 acres (airstrip and apron)

Airstrip Access Road 0.9 mile, 7.2 acres

Elevated Pipelines on 

Vertical Support 

Members

8.6 miles from GMT2 to GMT1; 0.1 acres 

9.8 miles, crude oil pipeline from CD5 to CD1/Alpine Central Processing Facility (on 

existing vertical support members); 3.3 miles, MI pipeline from CD4/CD5 intersection to 

CD1/Alpine Central Processing Facility (on existing vertical support members)

Gravel Supply Arctic Slope Regional Corporation Mine site

Total Gravel Footprint 92.0 acres

Ice Roads 51.6 miles (Year 1) 

51.2 miles (Year 2) 

7.0 miles (from GMT2 to GMT1 for every year post construction period)

a Total gravel footprint acreage does not include 0.1 acre from the installation of new pipeline vertical support members between 

GMT1 and GMT2.

2.7.2 Location 

The proposed Alternative C GMT2 drill pad location and pipeline route are described in Section 2.4.2. 

The occupied structure pad, air access facilities (airstrip and apron), and the Airstrip Access Road are 

located in Section 33, T10N, R2E UM (occupied structure pad); Sections 27, 28, and 33, T10N, R2E UM; 

and Section 31, T11N, R3E UM (air access facilities); and Sections 32 and 33, T10N, R2E UM (Airstrip 

Access Road). The Alternative C occupied structure pad, air access facilities, and Airport Access Road 

would be roughly northeast of the GMT2 drill pad as shown in Maps 2.7-1 and 2.7-2. 

In siting these facilities, the same criteria were used as used for siting of Alternative A: keeping 

infrastructure out of the Colville River Special Area, wetland habitats, archaeological resources, 

hydrology and drainage, topography, minimizing gravel footprint, load weight requirements (road), and 

local community interests. 

2.7.3 Drill Pad and Support Facilities

Table 11 summarizes major project components. Major facilities and features include those described in 

Section 2.4.3. In addition, Alternative C would require that certain facilities, services, equipment, and 

supplies (otherwise provided at CD1/Alpine Central Processing Facility) would need to be duplicated at 

or near the drill pad as described below. 

Air access facilities would consist of a 5,000-foot gravel airstrip and parking aprons. The airstrip would 

be capable of supporting a Hercules C-130 aircraft to transport a relief well drill rig in the event of a 

blowout or other emergency. 

An occupied structure pad would be connected to the airport apron and would provide space for personnel 

housing and material storage. A new mud plant and bulk cement facility would be required for year-round 

drilling because the existing plant at CD1/Alpine Central Processing Facility must remain in place to 
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service drilling operations at the other satellites. On-site wastewater and solid waste treatment or 

management would be required (see Section 2.4.12). In addition to housing, the following facilities will 

be located on this pad. 

• Mud plant and bulk cement facility

• Cement and mud storage silos 

• Water storage (muds make-up) 

• Mineral oil, diesel and brine tankage (muds make-up) 

• Muds make-up pump module 

• Wastewater tankage (three tanks)

• Water tankage and supply pump (potable) 

• Waste staging area

• Waste incinerator 

• Emergency generator

• On-site waste processing

• Redundant equipment storage/parking 

• Bull rail for vehicle block heaters

• Warm and cold storage facilities

• Equipment/fleet maintenance shop

• Emergency response facility

The GMT2 drill pad would be accessed via the 0.9-mile long Airport Access Road from the occupied 

pad/air access facilities. A tank farm would be needed to provide appropriate storage volumes for all 

operating fluids such as methanol and anti-corrosion chemicals. Diesel fuel for powering drilling support 

equipment, well work operations, fueling vehicle and equipment fleet, and freeze protect of wells would 

be transported via a new 2-inch diesel pipeline from CD1/Alpine Central Processing Facility. The 2-inch 

diesel pipeline would also be used for periodic shipments of mineral oil to the mud plant during the nonice road season. Water would be supplied via a 2-inch heat traced water pipeline from CD1/Alpine 

Central Processing Facility. Drilling wastes (i.e., muds and cutting) that cannot be managed using annular 

disposal onsite, would be stored in tanks and transported for disposal at CD1/Alpine Central Processing 

Facility during winter ice road season. Camp waste during the post-construction drilling and operating 

period would be incinerated on-site. In addition to the infrastructure described in Section 2.4.3, the 

following facilities would be required. 

• Fuel storage with supply pump

• Fueling station

• Bulk loading station/ops and drilling fluid tankage 

• Drilling tubulars and tools storage

• Vehicle storage (with bull rail)

• Redundant emergency response equipment storage

Alternative C would require approximately 3.5 to 4.5 megawatts electrical (depending on season, i.e., 

summer versus winter). Higher power requirements over Alternative A are due to the necessary additional 

project components and facilities. Additional power for rig during drilling is approximately 2.0 

megawatts. 

Alternative C facilities would be re-supplied during the ice road season to support the required long-term 

storage of drilling and operating fluid and supplies. 
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2.7.4 Access

Alternative C includes year-round access via aircraft and seasonal access by ice roads to support 

construction, drilling, and operations. Alternative C does not include a gravel road to access GMT1 and 

the Alpine Field road system. A local gravel road will be constructed to provide access to the drill site 

from the occupied structure pad/air access facilities. 

2.7.4.1 Road

Local Gravel Access Road

An approximately 0.9-mile gravel road would be constructed to access the GMT2 drill pad from the 

occupied pad/air access facilities. This is the only permanent road in Alternative C.

Ice Roads and Pads

When conditions allow, primary access to the GMT2 site would be by ice road. Ice roads would be 

constructed to access the gravel source and construction areas (e.g., drill pad, occupied pad, airstrip and 

pipelines). Due to the heavy equipment size and trip frequency of construction traffic, safety 

considerations dictate use of separate ice roads for pipeline construction, gravel placement, lake access for 

water supply, and general traffic. Map 2.7-3 shows proposed ice road routes for Alternative C.

During Year 1 to 2 of construction, ice pads would be built at the gravel source and along the gravel haul 

route. During Year 2 to 3 of construction, ice pads would be built at both ends of the pipeline route, plus 

an additional pad for construction laydown. 

Post construction, a 7.0-mile ice road would be constructed each year from the GMT1 drill pad to GMT2 

to access the drill site by vehicle. Alternative C would include a 10-acre ice pad for each year of drilling, 

and a 2-acre ice pad each year for operations and maintenance. Appendix B provides details about ice 

roads and pads that would be constructed under Alternative C. 

2.7.4.2 Vehicle Traffic

The design of components in Alternative C separates the GMT2 drill pad from the occupied structure pad 

(e.g., camp) to comply with aircraft safety regulations. A 0.9-mile gravel Airstrip Access Road would 

connect the GMT2 pad with the occupied structure pad. Appendix B provides details of estimated vehicle 

traffic for Alternative C, including potential traffic on the Airport Access Road. 

Mid-November through December of Year 1, vehicle traffic would be the same as that for Alternative A—

supporting pre-packing and ice road construction. 

In Year 2, construction of the ice roads would be completed in January. Vehicle traffic in Alternative C 

would be the most intense from February through April to support gravel hauling and construction of 

gravel pads, the Airstrip Access Road, and the airstrip, as well as a portion of the pipeline scope. Gravel 

conditioning work would occur in August and September. Ice road pre-packing and construction for the 

Year 2 to Year 3 construction season would occur mid-November through December of Year 2. 

In Year 3, traffic between Alpine facilities would occur during the construction and operation of ice roads 

(January through April; November and December) with local access between the GMT2 drill pad and 

occupied pad/airstrip occurring via the Airstrip Access Road. Pipeline and facilities construction would 

continue and pipeline installation completion would occur February through April via ice road. After 

April, all vehicle traffic would be on the local access road. Drilling would begin in May. 
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In Year 4 of the project life, drilling would be ongoing and vehicle traffic would be at levels greatly 

reduced from previous years and would be along the Airstrip Access Road. 

With year-round drilling and year-round operations, traffic levels are expected to maintain the same levels 

as Year 4 for the remainder of the project, but may decrease somewhat when drilling is completed and 

fewer personnel and support supplies are required. 

2.7.4.3 Air Transport

Air access is supported by a 5,000-foot gravel airstrip with parking aprons. The airstrip would be capable 

of supporting a Hercules C-130 aircraft, but the Otter/CASA class aircraft will be the most commonly 

used aircraft. An approximate 1-mile exclusion zone around the GMT2 drill pad separating the GMT2

drill pad from Air Access Facilities is required in accordance with 14 CFR 77.19(e) to ensure the safety of 

aircraft taking off and landing at the airstrip. Other factors contributing to the exclusion zone include the 

height of the drill rig and the setback distances required by the Federal Aviation Administration for 

approach and takeoff. Helicopters will also be used to support Alternative C. 

Transportation to GMT2 pad from the existing CD1/Alpine Central Processing Facility would be via 

aircraft approximately 9 months of the year (May through January). Although aircraft can access the site 

year-round, access would be primarily via ice road approximately 80 days of the year (February 1 through 

April 20). 

2.7.4.4 Aircraft Traffic

Air access to GMT2 via fixed-wing would begin upon completion of the GMT2 airstrip in the second 

construction season (Year 2–3). Prior to this, all fixed-wing flights listed will land in CD1/Alpine Central 

Processing Facility and air access would be limited to helicopter access. Aircraft would maintain altitude 

of 1,000 feet or more except during takeoff and landing (within 3.6 miles of the airstrip). Flight paths 

would depend on prevailing winds, but would generally align with the airstrip orientation. See Appendix 

B for details about estimated aircraft trips that would be required for Alternative C. 

No airstrip or camp would be available at GMT2 during the first construction season (Year 1–2), since 

this infrastructure will be under construction. Construction crews will stage out of Alpine-area camps as 

discussed in Section 2.7.6, “Camps.” Otter/CASA flights to support construction crews during winter of 

Year 1–2 will land at CD1/Alpine Central Processing Facility. From May to October of Year 2 there will 

be two helicopter flights per day to support gravel-working crews at GMT2. From May to September 

approximately 400 helicopter flights will support special studies and ice road cleanup activities. 

GMT2 air access facilities will become available in April/May of Year 3 and flights supporting drilling 

and operations will begin using the GMT2 airstrip. From May to September, approximately 400 

helicopter flights will support special studies and ice road cleanup activities. 

Beginning in Year 4 and continuing through Year 9, crew changes and cargo transport will be performed 

by aircraft at the GMT2 airstrip: approximately 40 crew change (Otter/CASA) flights per month during 

ice road season and 90 flights per month outside of ice road season; and approximately 5 cargo (CD-6 or 

C-130) flights per month during ice road season and 23 flights per month outside of ice road season. 

Pipeline inspection flights (Otter/CASA) will remain at once a week. In addition, approximately 36 

helicopter landings will occur to support ice road cleanup activities and 107 helicopter landings will occur 

to support special studies. Helicopter flights will generally occur between May and September. Helicopter 

visits to spill response equipment related to the GMT2 Project are included in the estimated helicopter 

landings. 
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Upon completion of drilling activities in Year 10 (i.e., operation only), crew change and cargo transport 

flights will reduce to approximately four crew change (Otter/CASA) flights per month during ice road 

season and 20 flights per month outside of ice road season; and approximately three cargo (CD-6 or C130) flights per month. Pipeline inspection flights (Otter/CASA) will remain at once a week. Helicopter 

landings for ice road cleanup activities and special studies would remain the same. 

k A single “flight” is defined as a landing and subsequent takeoff.

2.7.5 Gravel Requirements

Under Alternative C, a total of approximately 930,000 cubic yards of material required for this project 

would be used to fill approximately 92.0 acres. Table 12 lists the amount of material that would be used 

for project components. 

Table 12. Gravel use for Alternative C

Facility

Footprint 

(Acres)

Fill Quantity 

(Cubic Yards) Notes/Dimensions

GMT2 Drill Pad 19.1 207,000 Roughly 510 feet by 1,363 feet

Occupied Structure Pad 18.4 168,000 Roughly 835 feet by 820 feet

Air Access Facilities 47.3 497,000 5,000-foot-long airstrip

Airstrip Access Road 7.2 58,000 0.9-mile long; 32 feet crown width and 

minimum 5 feet thickness

Total Gravel Requirement a, b 92.0 930,000 None

a Values are approximate and may change during final design.

b Total gravel footprint acreage does not include 0.1 acre from the installation of new pipeline vertical support members between 

GMT2 and GMT1. Depending on final road placement, 800 to 1,000 vertical support members with 55-foot average spacing will be 

required.

2.7.6 Camps

The following camps are proposed to support construction and operation for GMT2 Project Alternative C: 

• Alpine Camp: 150 beds would be reserved for construction use at the man camp located at 

CD1/Alpine Central Processing Facility on the gravel pad which is connected to the existing 

CD1/Alpine Central Processing Facility electric grid. The camp would remain onsite year-round 

through the construction period and is required to support both winter and summer work. 

• Nuiqsut Hotel and Arctic Wolf Camp: The project will utilize existing beds at these two facilities 

located in Nuiqsut, during the winter construction season to support the project. 

• GMT2 Temporary Construction Camp: Located on the Kuukpik Pad at the intersection of the Spur 

Road and the CD5 Road, this camp would supply 370-456 beds for 120 days to support winter 

construction work (Year 1 to Year 3) and 175 for 245 days to support summer activities in Year 1 to 

Year 3.

• Temporary Camp: a 140-person camp located on an ice pad for 120 days to support winter 

construction during Year 2. This camp would be located adjacent to a drill site (such as CD5 or 

GMT1) that can supply power from the Alpine Central Processing Facility electric grid.

• GMT2 Camps: camps located at the GMT2 Occupied Structure Pad and connected to the existing 

Alpine electric grid via power cable from CD1/Alpine Central Processing Facility

As in the other action alternatives, construction is expected to take 2 years as described in Section 2.4.1. 

During construction (Years 1 and 2), offsite camp facilities including Alpine Camp, Nuiqsut Hotel, and 
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Kuukpik Camp will be used. In addition, a temporary camp would be located on an ice pad at GMT2 to 

support Year 2 winter construction activities to complete construction of additional roadless facilities. 

Drilling is expected to begin in May of Year 3 and would be supported by 225 personnel housed on the 

occupied structure pad in the following camps: 120 person drilling support separated into a 75-person rig 

camp plus 45 additional stand-alone rig support; an 80-person well operations/well tie-in camp housing 

welders, instrument technicians, electricians, flowback crew, and wellwork crews). A 25-man, full-service 

operation camp would be on the occupied structure pad. Drilling activities would continue for 7.1 years. 

Operation (i.e., production) would begin after the estimated first oil date (December), and would be 

concurrent with drilling the remainder of the 48 wells. Post-construction operation would continue for 30 

years to 2050. Upon completion of drilling activities, a 25-person camp would be located on the occupied 

structure pad to house personnel to provide full-service operations.

2.7.7 Water Use

Water for use at the site (e.g., personal water use) would be provided via a 2-inch water pipeline from the 

Alpine Central Processing Facility. Water use from local lakes would be required for ice pads, road, and 

bridges. Alternative C would require construction of a 7.0-mile annual resupply ice road every year for 30 

years to support drilling and operations. Details about estimated water use for Alternative C are provided 

in Appendix B.

2.7.8 Spill Prevention and Response

Alternative C would require redundant emergency response facilities and equipment storage at the 

occupied structure pad. Outside the ice road season, any equipment not available locally (at the GMT2 or 

occupied structure pad) would be brought in by aircraft to the GMT2 airstrip. For additional discussion of 

spill response, see Section 4.5. 

Pipeline inspections would be conducted via ice road and aircraft under Alternative C. Pipeline 

inspections and maintenance and emergency response activities (including training and drills) would 

depend upon aircraft logistics and weather restrictions for approximately 9 months per year and would 

occur from ice roads for approximately 80 days per year. Mobilization of emergency response equipment, 

supplies, and personnel housed at the CD1/Alpine Central Processing Facility would require dependency 

on aircraft support and could be challenging, particularly during periods of adverse weather. Response 

time for safety or medical emergencies could also be compromised when aircraft support is restricted by 

adverse weather. Due to adverse weather, air travel has been restricted at CD1/Alpine Central Processing 

Facility 13 to 22 percent each year for years 2009–2013 (ConocoPhillips MNAD 2015). In the event of 

bad weather at Alpine, a response effort could be staged out of Nuiqsut, as often the weather is different in 

both locations. Therefore, the same would be true if the weather was bad in Nuiqsut, a response effort 

could be staged out of Alpine. Alpine would be the primary location to stage a response. 

Under Alternative C, the incremental challenges associated with responding in a timely manner to 

emergency life-saving and spill events would increase safety and environmental risks throughout the life 

of the project. Dedicated response resources are available at CD1/Alpine Central Processing Facility 

including full-service medical, fire, and spill response personnel, facilities, and equipment.

2.8 Alternative D: No Action 

Under Alternative D (no action), the current conditions and expected future condition in the absence of 

the GMT2 project are evaluated. ConocoPhillips’s application for permit to drill, application for discharge 

into waters of the U.S., and related authorizations would not be approved. 

The following regulatory guidance (BLM 2015d) provides framework for the analysis:
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The U.S. Court of Appeals in Sierra Club v Peterson 717 F.2d 1409 (D.C. Cir. 1983) found that 

“on land leased without an NSO [no surface occupancy] stipulation, the U.S. Department of the 

Interior (DOI) cannot deny the permit to drill...once the land is leased the DOI no longer had the 

authority to preclude surface-disturbing activities even if the environmental impact of such activity 

is significant. The Department can only impose mitigation upon a lessee who pursues surfacedisturbing exploration and/or drilling activities.” The court goes on to say “notwithstanding the 

assurance that a later site-specific environmental analysis would be made, in issuing these leases 

the DOI has made an irrevocable commitment to allow some surface-disturbing activities 

including drilling and road building.”

Alternative D assumes continuing exploration work as required under the GMT Unit Agreement. 

Alternative D also assumes permitted studies in the NPR-A would continue, with continued use of aircraft 

in the project vicinity (see Section 3.4.4.1, Local Transportation). The no-action alternative further 

assumes that the GMT1 Project would be constructed and operated, since that authorization is 

independent of the proposed project. 

No water use beyond what is currently required is expected to occur as a result of Alternative D. There 

would be no additional gravel use or footprint for Alternative D. 

Vehicle traffic for Alternative D is expected to be the same as currently expected from current and 

expected future conditions: no vehicle traffic is expected due to the lack of gravel or ice road to support 

the GMT2 Project.

Aircraft traffic for Alternative D is should be the same as currently expected from current activities and 

from future expected activities.Table 13 shows the baseline (current) ConocoPhillips flights without 

GMT2 Project and includes biological and hydrological studies. More detailed information is provided in 

Appendix B. 

Table 13. Summary of ConocoPhillips current aircraft flights a, b

Flight Purpose Aircraft Type

Flights Projected

for 2018

Flights Projected

for 2019 and Beyond

Construction Crew Support c Otter/CASA 2,071 1,981

Construction Cargo d DC-6 360 366

Special Studies/Ice Road Cleanup e Helicopter 1,070 765

Annual Total N/A 3,501 3,112

a A single flight is defined as a landing and subsequent takeoff.

b Helicopter numbers refer to landings within the NPR-A. 

c Aircraft supporting crew changes would take off from Kuparuk or Deadhorse and land at the CD1/Alpine Central Processing 

Facility airstrip.

d Construction cargo flights will land at the CD1/Alpine Central Processing Facility airstrip. Point of origin for these flights will be 

Kuparuk, Deadhorse, Fairbanks or Anchorage depending on the cargo being transported. 

e Special studies and ice road cleanup flights will originate at the CD1/Alpine Central Processing Facility airstrip. Landing/overflight 

area will be determined by the ice road location or study being conducted.

2.9 Comparison of Alternatives 

All action alternatives (Alternatives A, B, and C) require similar types of facilities (gravel pads and 

roads/air access facilities) with a similar gravel footprint. The pipeline route is the same for all action 

alternatives except Alternative B. All action alternatives have the same construction, drilling and 

operation schedule. The amount of gravel required varies between alternatives with Alternative C 

requiring approximately 45 to 50 percent more than Alternative A. 
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Major project components and on-site facilities and schedules are listed and detailed descriptions of each 

alternative are provided in Sections 2.5 through 2.8. Table 14 provides a summary of differences between 

the alternatives. 
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Table 14. Comparison of components, facilities, and access for the action alternatives

Project Component Alternative A

Preferred Alternative Alternative B Alternative C

Drill Pad 14.0 acres 14.0 acres 19.1 acres

Wells Up to 48 Up to 48 Up to 48

Occupied Structure Pad None None 18.4 acres

Air Access Facilities None None 47.3 acres; airstrip and apron

GMT1–GMT2 Access Road 8.2 miles; 62.8 acres of fill 9.4 miles, 72 acres of fill None

Tundra Access Subsistence Pullouts 3 pullouts 3 pullouts None

Airstrip Access Road None None 0.9 mile, 7.2 acres

Ice Roads and Pads Year 1–2: 52.6 mile ice road, 175-acre 

ice pad

Year 2–3: 43.9 mile ice road, 135-acre 

ice pad

Year 3–10: 10-acre ice pad to support 

drilling

Year 1–2: 51.9-mile ice road, 175-acre ice 

pad

Year 2–3: 43.3-mile ice road, 135-acre ice 

pad

Year 3–10: 10-acre ice pad to support 

drilling

Year 1–2: 51.6-mile ice road, 205-acre ice pad

Year 2–3: 51.2-mile ice road, 175-acre ice pad

Years 3–10: 7.0-mile ice road, 10-acre ice pad

Years 11–32: 7.0-mile ice road, 2.0-acre ice pad

Total Water Requirements 395 million gallons 398 million gallons 691 million gallons

GMT1–GMT2 Pipeline System 8.6 miles; 0.1 acre of fill from new 

vertical support members

9.4 miles, 0.1 acre of fill from new vertical 

support members

8.6 miles; 0.1 acre of fill from new vertical support 

members

Ancillary Pipelines None None Diesel and mineral oil supply, 2-inch water supply, 

2-inch

Total Gravel Footprint 78.0 acres 87.2 acres 92.0 acres

Gravel Supply Arctic Slope Regional Corporation 

Mine site

Arctic Slope Regional Corporation Mine 

site

Arctic Slope Regional Corporation Mine site

Total Gravel Requirement 671,300 cubic yards 747,300 cubic yards 930,000 cubic yards

Construction Schedule 4Q Year 1–3Q Year 3 4Q Year 1–3Q Year 3 4Q Year 1–3Q Year 3

Drilling Timeframe 7.1 years, 2Q Year 3–Year 10 7.1 years, 2Q Year 3–Year 10 7.1 years, 2Q Year 3–Year 10

Post-Construction Operation 30 years 30 years 30 years

Lodging Requirements, Construction Year 1–2: 370-456 beds in winter, 175

beds in summer

Year 2–3: 370-456 beds in winter, 175 

beds in summer

Year 1–2: 370-456 beds in winter, 175 

beds in summer

Year 2–3: 370-456 beds in winter, 175 

beds in summer

Year 1–2: 370-456 beds in winter, 175 beds in 

summer

Year 2–3: 370-456 beds in winter, 175 beds in 

summer

Lodging Requirements, Drilling 75-bed drilling camp 75-bed drilling camp 120-bed drilling camp

80-bed operations camp

Lodging Requirements, Operations None None 25-bed operations camp
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Project Component Alternative A

Preferred Alternative Alternative B Alternative C

Access Year-round access via gravel road Year-round access via gravel road Year-round access by aircraft only; seasonal 

access by ice road
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2.9.1 Access

The number of vehicle trips and miles traveled to support construction is relatively similar for all action 

alternatives, but is slightly lower for Alternative A. For drilling and operations the number of trips and 

miles traveled is also relatively similar for all action alternatives. Table 15 provides a summary of vehicle 

trips required for each alternative.

Table 15. Summary of total vehicle trips for project alternatives

Project Phase

Alternative A

Preferred 

Alternative

Alternative B Alternative C

Vehicle Trips: Construction Years 1–2 93,600 98,200 106,700

Vehicle Trips: Construction Years 2–3 72,500 72,600 75,100

Vehicle Trips: First Year of Drilling 6,100 6,100 5,300

Vehicle Trips: Post-Construction Ice Road a None None 5,500 annually

Vehicle Trips: Infill Drilling b 56,970

(9,000 annually)

56,970

(9,000 annually)

142,425

(22,500 annually)

Vehicle Trips: Routine Operations c 161,000

(700 annually)

161,000

(700 annually)

501,400

(21,800 annually)

Total Trips d 390,200 394,900 865,700

Miles Traveled: Construction Years 1–2 931,400 miles 1,023,800 miles 1,356,600 miles

Miles Traveled: Construction Years 2–3 408,300 miles 409,300 miles 335,900 miles

Miles Traveled: First Year of Drilling 153,100 miles 159,210 miles 5,300 miles

Miles Traveled: Annual Ice Road None None None

Miles Traveled: Infill Drilling 1,416,654 miles

(223,800 annually)

1,473,600 miles

(232,800 annually)

1,083,063 miles

(171,100 miles 

annually)

Miles Traveled: Routine Operations 287,500 miles

(12,500 annually)

310,500 miles

(13,500 annually)

1,616,900 miles

(70,300 annually)

Total Miles d 3,197,000 miles 3,376,600 miles 4,604,700 miles

a Annual ice roads will be needed for Alternative C for every year that drilling is taking place. For Alternative C, an ice road will be 

constructed for 6.33 years; vehicle trips and miles traveled for the annual ice road phase were calculated by multiplying the annual 

total by 6.33. 

b Infill drilling is expected to take 6.33 years for Alternatives A, B and C. Vehicle trips and miles traveled for the infill drilling phase 

were calculated by multiplying the annual total by 6.33.

c Total trips and total miles for routine operations assumes a project lifespan of 23 years post-drilling. 

d Totals are rounded to the nearest hundred.

The number of aircraft flights required differs dramatically between alternatives. Alternative C requires 

14 times the number of flights required by Alternative A. These include all types of flights, such as crew 

changes using both Otter/CASA aircraft and helicopter, cargo flights, pipeline inspection flights, and 

helicopter-based special studies and cleanup activities. Table 16 provides a summary of aircraft flights 

required for each alternative. 
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Table 16. Summary of total aircraft flights for project alternatives

Aircraft Type Alternative A

Preferred Alternative Alternative B Alternative C

Otter/CASA 270 270 12,542

DC 6/C-130 None None 2,570

Helicopter a, b 3,642 3,642 5,207

Total c, d 3,912 3,912 20,319

a Helicopter numbers refer to landings within the NPR-A. Helicopter visits to spill response equipment pre-staged as part of the 

GMT2 Project are included in helicopter landing numbers. 

b Helicopter landings for ice road cleanup are estimated at five landings per mile of ice road. Ice road cleanup will only occur from 

May–September of Year 2 and Year 3.

c Total flights are divided across the GMT2 Project’s estimated 30-year lifespan. 

d A single “flight” is defined as a landing and subsequent takeoff.

2.9.2 Spill Prevention and Response

Spill prevention and response would be different depending upon the alternative selected. 

For Alternatives A and B, visual observations of the pipeline and facilities would be conducted from the 

GMT1–GMT2 Access Road. For Alternative C, road access would be limited to the annual ice road; all 

other access would be via aircraft. Conducting visual observations and investigation of pipelines from the 

gravel road would significantly reduce the number and frequency of aircraft over flights needed to 

visually inspect the pipelines. Annual summer deployment of boom and pre-staged equipment along the 

pipeline route and its subsequent removal prior to winter could be effectively managed from a gravel road 

for some strategic locations, which would also reduce the number and frequency of aircraft flights 

required to deploy and then remove the equipment. In addition, the gravel road would support equipment 

staging and provide immediate access points for response vehicles and/or vessels, in the event of a 

pipeline spill; this would increase response effectiveness and reduce the potential for disturbance to 

tundra and wildlife caused by response activities. 

Dedicated oil spill response resources, including full-service medical, fire, and spill response personnel, 

facilities, and equipment are available at CD1/Alpine Central Processing Facility. Under Alternatives A 

and B, these resources would be accessible to GMT2 via the GMT1–GMT2 Access Road. Because no 

road access is available for Alternative C (except for during ice road season), these resources would not 

be available. It is not feasible to duplicate these resources at each drill site. Much of the equipment should 

be kept in warm storage buildings to maintain response readiness. It also requires continuous inspection 

and maintenance to be ready for emergency response. Workers needed to maintain this equipment would 

also require housing. The resources maintained at CD1/Alpine Central Processing Facility will be 

separated by approximately 23 miles of tundra, rivers, and lakes from GMT2 (7.0 miles from GMT1 via 

the approved CD5–GMT1 Road). The GMT1–GMT2 Access Road would allow year-round transport and 

mobilization of these resources and ensure they can be reliably made available for timely incident 

response. 

Hazardous conditions from a worst-case well control discharge at GMT2 facilities could require site 

evacuation and locally staged equipment could become inaccessible or unusable due to oiling or unsafe 

operating conditions. Permanent road access to GMT2 provides assurance that response equipment and 

resources would be rapidly available and deployable.
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Chapter 3. Affected Environment

3.1 Introduction 

The objective of this section of the supplemental EIS is to both summarize the affected environment, as 

described in BLM (2004a) and BLM (2014), and to supplement it with new information that has arisen 

since BLM (2004a). 

3.1.1 Project Study Area

The GMT2 Project facilities are located entirely within the Northeast NPR-A, on the North Slope of 

Alaska, west of the Colville River Delta. Map 3.1-1. The GMT2 project study area encompasses 158,480 

acres and is comprised of all project components necessary for GMT2 to be developed. The project study 

area includes the community of Nuiqsut, the gravel mine located 4.5 miles northeast of Nuiqsut, the 

Alpine Central Processing Facility (CPF), CD2, and CD4 in the Colville Delta north of Nuiqsut, bridges 

over the Nigliq Channel of the Colville River (and 3 smaller bridges between the Nigliq and CDS and 

over the Ublutuoch River), the CDS drill site, the CDS-GMTl access road, the GMTl drill site northwest 

of Nuiqsut, and the proposed GMT1-GMT2 access road and GMT2 drill site west of Nuiqsut shows the 

project study area defined for this supplemental EIS. In general, the discussion of the affected 

environment for each resource will focus on the project study area, as this is where the potential for 

impacts could occur. However, resources have a varied geographic scope, and details regarding the 

affected environment for most resources extends beyond the boundary of the project study area in order to 

provide appropriate context for the environmental consequences presented in Chapter 4. 

3.1.2 Existing and Planned Infrastructure

The proposed GMT2 pad lies approximately 16.5 miles west of Nuiqsut, a community of about 400 

people (see Section 3.4.1 for more information). Nuiqsut is served year-round by an approximately 4,500-

foot airstrip, owned and operated by the North Slope Borough. Seasonal ice roads to Alpine facilities are 

typically extended to Nuiqsut, allowing access to the Prudhoe Bay road system during the winter. 

During the winters of 2014 to 2016, Kuukpik Corporation constructed the 5.8-mile gravel road (Nuiqsut 

Spur Road) from Nuiqsut to the Colville Delta 5 (CD5) access road (Map 3.1-1), including a new gravel 

storage pad (Nuiqsut Laydown Pad) near the juncture. The Nuiqsut Spur Road is intended to increase 

access to subsistence resources; provide access for training and employment of local residents at the 

Alpine oilfield; improve access from Alpine to Nuiqsut to facilitate local business opportunities (e.g., 

camp facilities); and, provide year-round transportation for life/safety/health response, spill response (e.g., 

mutual aid), and medical emergencies, according to the mutual aid agreement between ConocoPhillips 

and the North Slope Borough. 

In early 2015, Conoco Phillips received authorization from the BLM (2015a) and the U.S. Army Corps of 

Engineers (2015) for construction of the GMT1 Project, which consists of a 7.6-mile gravel road, an 

11.8-acre gravel pad, and an 8.3-mile pipeline. The purpose of the GMT1 Project is to support 

development and transportation of petroleum reserves within the Greater Mooses Tooth Unit. 

Construction of GMT1 began in February 2017. 

The main Alpine development complex at the Colville Delta 1(CD1)/Alpine Central Processing Facility is 

approximately 20 miles northeast of the proposed GMT2 pad, as shown in Map 3.1-1. The gravel CD5–

CD4 Access Road and bridges were completed in 2015. The Alpine Central Processing Facility is not 

connected by gravel road to the existing North Slope road system, and is only accessed by seasonal ice 

road and by air. 
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There are several cabins in the area. A number of federal and industry exploration wells are in the project 

area, but no development has occurred at these sites. Several small weather stations are located west of 

the project area. 

3.1.3 Hazardous and Solid Waste Sites

The Alpine Satellite Development Plan EIS (BLM 2004, Section 3.1.2.3), the Northeast NPR-A 

Supplemental Integrated Activity Plan/EIS (BLM 2008, Section 3.2.10), and the NPR-A Integrated 

Activity Plan/EIS (BLM 2012, Section 3.2.11) provide information on hazardous and solid waste sites in 

and around the Alpine Field and within the NPR-A. Hazardous and solid waste sites are associated with 

past activities including oil and gas exploration, winter petroleum seismic exploration operations, 

Department of Defense activities, and current activities including landfills and fuel storage. Other uses, 

including overland transport, research, and recreation and subsistence activities, have resulted in 

incidental fuel spills.

3.1.3.1 Known Hazardous and Solid Waste Sites Within the Project Study Area

To identify known contaminated sites within the project study area, the Alaska Department of 

Environmental Conservation Contaminated Sites Database and EPA Superfund Enterprise Management 

System on-line databases were reviewed. One contaminated site, the North Slope Borough Nuiqsut Power 

Plant (Alaska Department of Environmental Conservation Hazard ID 25937), was identified within the 

project study area on the Alaska Department of Environmental Conservation Contaminated Sites 

Database. Petroleum contaminated soil was encountered at the Nuiqsut Power Plant site in 2012 during 

excavation activities to replace underground fuel piping between the power plant and the washeteria after 

a problem with the piping integrity was identified. No known sites were listed on the EPA Superfund 

Enterprise Management System within the project area.

A review of the Alaska Department of Environmental Conservation Solid Waste Sites web map shows 

two solid waste sites within the project study area, the Nuiqsut Landfill, and the ConocoPhillips Alpine 

Grind and Inject Facility. The Nuiqsut Landfill is an Alaska Department of Environmental Conservation 

Class III permitted landfill (permit number SWGPNSB-21) for domestic and commercial refuse generated 

in the community of Nuiqsut. The landfill does not accept acids, corrosives, solvents, 

contaminated/polluted soils, oily wastes, explosives, hazardous wastes, radioactive waste, unsterilized 

medical wastes, polychlorinated biphenyls, containers holding in excess of 1 gallon of liquid, or regulated 

asbestos-containing materials. 

The ConocoPhillips Alpine Grind and Inject Facility is an Alaska Department of Environmental 

Conservation-permitted facility (permit number SWXA006-19) authorized for the treatment and storage 

of Resource Conservation and Recovery Act exempt exploration and production waste (drilling waste) 

and Resource Conservation and Recovery Act non-exempt non-hazardous waste. Storage facilities 

currently consist of two permanent cells at the CD2 pad and several temporary cells at the CD2 and CD5 

pads.

3.1.3.2 Alpine Hazardous Waste Generation 

The EPA Hazardous Waste Biennial Report collects data on the generation, management, and 

minimization of hazardous waste, and is reported for odd number years. A search of the biennial report 

database shows the Alpine Oil Field (handler ID AKR000003806) generated 47.6 tons of waste during the 

2015 reporting period. The majority of the waste generated, 45.5 tons, was compressed gas, which was 

disposed of on-site using underground injection. The remaining 2.1 tons of waste consisted of paint, paint 

thinner, batteries, compressed gas, contaminated debris, and other liquid and solid wastes. These wastes 

were shipped off-site for disposal.
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3.1.3.3 Alpine Spill History

The Alaska Department of Environmental Conservation Spills Database lists 252 spills reported within 

the Alpine Oil Field for the entire operating period, 1998 through March 2017. For this document, 

materials that could be spilled are categorized as crude oil, non-crude oil, process water, and other 

hazardous substances. The total volume of spills for the operational period is approximately 15, 975 

gallons. Non-crude oil (diesel, hydraulic oil, engine oil, etc.) and process water make up the largest 

volume of substances spilled. From the start of operations in 1998 to March of 2017, approximately 7,700 

gallons of non-crude oil or 48 percent of the total volume, was spilled, and approximately 5,600 gallons 

of process water, or 35 percent of the total volume, was spilled. This is a change from the analysis in the 

GMT1 EIS (BLM 2014, Section 3.1.3), which shows process water making up 45 percent of the total 

volume spilled, and non-crude making up 33 percent of the total volume spilled, based on the spills 

reported from the start of operations in 1998 to October 2013. 

There have been 62 reported spills from October 2013 to March 2017. The largest spill reported in this 

timeframe was 3,000 gallons of diesel as a result of an overfill, which accounts for 73 percent of the 4,102 

gallons spilled. Table 17 shows a breakdown of the substances spilled by cause, and the volume released. 

Spills prior to October 2013 are discussed in detail in the GMT1 EIS (BLM 2014, Section 3.1.3).

Table 17. Summary of Alpine Oil Field spills in gallons (October 2013 to March 2017)

Substance Released

Due to Human Factors

(gallons)

Due to Structural/Mechanical

(gallons)

Total Released

(gallons)

Crude Oil 2.0 7.0 9.0

Non-Crude Oil 3,474.0 283.0 3,757.0

Process Water 210.0 57.0 267.0

Hazardous Substances 0.7 68.0 68.7

Total (gallons) 3,686.7 415.0 4,101.7

3.2 Physical Characteristics

The following description of physical characteristics of the project study area is structured and organized 

to match BLM (2004a) and BLM (2014). 

3.2.1 Terrestrial Environment

The terrestrial environment remains essentially the same as described in BLM (2004); however, there is 

an increased understanding of the role of climate change in the Arctic, which is described in Section 3.2.4, 

Climate Change.

3.2.1.1 Physiography

The North Slope of Alaska encompasses three physiographic provinces: the Arctic Coastal Plain, the 

Arctic Foothills, and the Brooks Range. The project study area is situated entirely within the Arctic 

Coastal Plain Province. The Arctic Coastal Plain is an area characterized by low topographic relief, 

numerous lakes, meandering stream channels, and polygonal-patterned ground. It rises gradually from sea 

level to a maximum elevation of roughly 600 feet, and is comprised of two distinct zones: tundra 

lowlands and coastal area. Map 3.2-1 shows the geomorphic classification of the project study area. Table 

18 lists the areal extent of each geomorphic unit occurring with the project study area.
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Table 18. Geomorphic units in the GMT2 Project area

Geomorphic Unit Acres

Thaw Basin, Ice-rich Margin 26,280

Alluvial-Marine Deposit 24,281

Aquatic Geomorphic Unit, Fresh 22,171

Delta Inactive Overbank Deposit 18,305

Thaw Basin, Ice-rich Center 11,687

Old Alluvial Terrace 7,743

Aquatic Geomorphic Unit, Brackish 6,008

Delta Abandoned Overbank Deposit 5,898

Delta Active Channel Deposit 4,628

Delta Thaw Basin, Ice-poor 3,594

Thaw Basin, Ice-poor Margin 2,537

Delta Active Overbank Deposit 1,871

Eolian Inactive Sand Deposit 1,553

Thaw Basin, Ice-rich Undifferentiated 1,396

Meander Inactive Overbank Deposit 1,373

Lowland Headwater Floodplain 881

Delta Inactive Channel Deposit 877

Delta Thaw Basin, Ice-rich 825

Thaw Basin, Ice-poor Center 740

Thaw Basin, Ice-poor Undifferentiated 529

Human Modified 459

Eolian Active Sand Deposit 459

Thaw Basin Pingo 174

Eolian Inactive Sand Dune 159

Eolian Active Sand Dune 123

Solifluction Deposit 62

Meander Inactive Channel Deposit 62

Meander Abandoned Overbank Deposit 63

Recent Alluvial Terrace 26

Meander Active Overbank Deposit 19

Inactive Tidal Flat 8

Meander Active Channel Deposit 5

Not Mapped 10,636

Project Area Total 155,431

3.2.1.2 Geology and Minerals

The proposed project is in the NPR-A, where the geology has been studied by the U.S. Geological Survey 

for more than 100 years. Information on geology of the project study area is presented by BLM (2004, 

Section 3.2.1.2), BLM (2008, Section 3.2.4) and BLM (2012, Section 3.2.5). 

Supplemental site-specific information relevant to the evaluation of geology and mineral resources within 

the project study area was not identified. 

3.2.1.3 Petroleum Resources

The petroleum geology of the NPR-A, exploration efforts, leasing activity, and oil and gas potential is 

described in BLM (2008, Section 3.2.5) and BLM (2012, Section 3.2.6). 

Geologists assess oil and gas potential of the area by defined geologic plays, each with unique 

characteristics. In 2017, the U.S. Geological Survey assessed the undiscovered technically recoverable oil 

and gas resource in a portion of the NPR-A that includes the project study area, adjacent State and Native 

lands, and State waters at 8.7 billion barrels (BBL) of oil and 25 trillion cubic feet of natural gas (U.S. 

Geological Survey 2017). Based on data from industry exploration, the U.S. Geological Survey estimated 
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that 120 to 200 MMbbl of discovered oil (oil and condensate) may also be technically recoverable in the 

NPR-A (U.S. Geological Survey 2010). Other information on geology is provided in BLM (2004, Section 

3.2.1.2) and BLM (2012, Section 3.2.5).

3.2.1.4 Soils and Permafrost

Soils and permafrost within the Northeast NPR-A within the project study area are described in BLM 

(2004a, Section 3.2.1.3–3.2.1.4), with additional information in BLM (2014, Section 3.2.1.4). Soils and 

permafrost remain essentially the same as described in BLM (2004a) and BLM (2014). 

The soils in the region are shallow and wet, with deep permafrost beneath. In the project study area, 

vegetation covers much of the surface, with an associated layer of ice-rich organic silt, silt, and sandy silt. 

Detailed results of soil samples collected around the general project study area are reported in 

Geomorphology of the Northeast Planning Area, NPR-A, by Jorgenson et al. (2003a). The project study 

area is underlain by continuous permafrost, which on the North Slope, ranges from depths of about 650 

feet to more than 2,000 feet. During the Arctic summer, solar radiation thaws a shallow layer of soil at the 

surface, creating a seasonally unfrozen zone termed the active layer. Beneath the active layer, almost all 

material remains frozen; segregated and massive ice formations are common. A continuing supply of 

available water is required to maintain many of these features and without new water, they may degrade 

rapidly, resulting in a change of vegetation and ecosystems. Permafrost impedes the infiltration of surface 

water, resulting in saturated surface soils. Vegetation insulates the permafrost, and disturbance of surface 

vegetation can increase melting of permafrost and result in subsidence. The potential for subsidence 

varies with ice content of the soils. As noted above, the alluvial-marine deposits in the project study area 

contain fairly high mean ice volumes. These same deposits are typically found out of the active 

floodplain, yielding a lower potential to impound water, which would promote permafrost degradation 

(BLM 2004, Section 3.2.1.3). 

3.2.1.5 Sand and Gravel Resources

Sand and gravel resources in the project study area and the region are discussed in BLM (2004, Section 

3.2.1.5), BLM (2008, Section 3.2.8), and BLM (2012, Section 3.2.9). The sand and gravel material sites 

identified within the project study area include the existing Arctic Slope Regional Corporation Mine site 

located east of the Colville River and the proposed Clover site on the west side of the river described in 

BLM (2004, page 160). The Arctic Slope Regional Corporation Mine site is the gravel source proposed 

for the GMT2 Project. Maps 3.1-1 and 3.2-1 identify the location of this site. 

The area west of the Colville River is characterized by an apparent scarcity of suitable gravel for 

construction (BLM 2012, Section 3.2.9). 

3.2.1.6 Paleontological Resources

Paleontological resources associated within the project study area were described in BLM (2004, Section 

3.2.1.6) and updated in BLM (2012, Section 3.2.7). This section tiers to and incorporates by reference 

relevant information, while placing emphasis on the proposed GMT2 Project location and potential 

socioeconomic impacts on a narrower scale. This section incorporates and expands upon the GMT1 

Supplemental Environmental Impact Statement (BLM 2014, Section 3.2.1.6) and ConocoPhillips 

Alaska’s Final GMT2 Modified NEPA Analysis Document (ConocoPhillips 2016 Section 3.2.1.6).

Study Area

The study area for paleontological resources includes all areas where the project may directly or indirectly 

impact paleontological materials. This analysis is tiered off the Alpine development plan (BLM 2004) and 

includes areas where activities in support of GMT2 may be located, including the GMT1 footprint. The 
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direct impact analysis area represents locations subjected to direct ground-disturbing activities, including 

existing, proposed, and alternative development footprints for GMT1 and GMT2. Paleontological 

resources that are not in the direct path of construction and supporting activities can still be affected by 

project development. For example, development can provide easier access to otherwise remote and 

difficult-to-access paleontological site locations, resulting in increased foot or vehicle traffic. Increased 

traffic can intensify erosion and/or increase the chances that paleontological resources will be altered or 

even pilfered. The indirect impact analysis area is the project study area, including lands outside the 

gravel footprint of the GMT2 Project.

The project area was selected to include all major project components of the proposed GMT2 Project and 

alternatives and where supporting activities may be located. This includes new permanent infrastructure 

such as the road, airstrip, pads, and pipeline; existing infrastructure that will be used as part of the project 

such as Alpine Processing Facility/CD1 (processing of produced fluids, origination of vehicle trips) and 

Nuiqsut (potential housing for construction crews), the Arctic Slope Regional Corporation Mine site 

(gravel source), and ice roads. To ensure that the project area is large enough to account for any changes 

or routing of project components, it generally extends 2.5 miles from existing project facilities, and 5 

miles from new proposed GMT2 Access Road, pipeline, and pad development. The area of potential 

effect for direct, indirect, and cumulative impacts for paleontological resources by alternative will be 

detailed further in the section on environmental consequences for paleontological resources.

Data Sources

Recent paleontological surveys (e.g., Druckenmiller 2015, 2016; Fiorillo 2014; Groves and Mann 2015; 

Mann and Groves 2016) provide the most current site location and condition information in the NPR-A. 

Although no paleontology-specific surveys have been conducted for the GMT2 area, paleontological 

remains are also investigated and documented as they are encountered during cultural resource surveys 

(Potter et al. 2003, 2004; Reanier 2009a, 2009b, 2014a, 2014b; Reanier and Kunz 2010; Stephen R. 

Braund and Associates 2013) or reported to archaeologists. 

The results of these paleontological and archaeological surveys, including locations and descriptions of 

discovered sites, are housed at the Alaska Heritage Resources Survey (Alaska Heritage Resources 

Survey)—a statewide GIS database of archaeological and paleontological sites that provides locational 

information and coordinates, descriptions of site characteristics, features, associated materials, chronology 

and time period, site condition, and other important site information. The Alaska Heritage Resources 

Survey is the primary source of information for paleontological properties in the project area, but there 

are certain limitations to the data. Data reported in the Alaska Heritage Resources Survey comes from a 

variety of sources and can be inconsistent. Many of the sites were recorded before the advent of GPS 

technology, so reported locations and site extents are often imprecise. While ongoing efforts are underway 

to update the database, many of the sites have not been frequently updated and may have been removed or 

destroyed since being reported, may not resemble provided descriptions, or may not be described 

accurately or in detail. Despite these limitations, the geospatial data in the Alaska Heritage Resources 

Survey database represents the best available information for paleontological site locations within the 

project area (BLM 2014, page 172). 

Paleontological Overview

Most rock formations in the NPR-A dating from the late Paleozoic and onward contain some fossils 

traces, the earliest of which is a 380-million-year-old lungfish tooth plate (Lindsey 1986). Much of the 

bedrock underlying the NPR-A has a marine origin, which includes fossil brachiopods, cephalopods, 

gastropods, pelecypods, sponges, bryozoans, corals, and crinoids. The first evidence of terrestrial plant 

fossils are noted in roughly 160 million-year-old Jurassic formations, and the NPR-A produces some of 

the best examples of the flora of that 100 million-year-old mid-Cretaceous period found anywhere in 
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North America (Lindsey 1986). These plant fossils document a change from a warm to a cool climate 

with modern conifers beginning to appear on the North Slope. 

Late Cretaceous vertebrate fossils dating from 70 to 65 million years ago (mya) are also common in the 

NPR-A. Most of the known fossil deposits of this age are found in the extensive bluffs of the Colville 

River downstream from Umiat. Research at the Liscomb Bone Bed along the Colville River has been a 

hotbed of paleontological research over the last several decades. Initial research at Liscomb provided new 

insights regarding dinosaur physiology, in terms of the un-reptile-like ability to survive in a cold, dark 

environment, and the impacts of the associated implications regarding dinosaur extinction theories 

(Brouwers et al. 1987; Clemens and Nelms 1993; Fiorillo and Gangloff 2000; Gangloff 1997; Gangloff 

and Fiorillo 2010; Paul 1988; Richet al. 2002). Recent work in the Liscomb Bone Bed produced evidence 

of several species of dinosaur not previously known to be present in the Arctic and also the possibility of 

several new species that may be endemic to the Arctic (Druckenmiller 2010). Recent work by Gangloff 

and Fiorillo (2010) also appears to support the theory that Arctic Late Cretaceous dinosaurs were 

permanent residents of the region rather than migratory. These new findings are extremely significant and 

further emphasize that the value of this “world class” paleontological resource, which is the largest, most 

species-comprehensive, polar dinosaur locale in the world, cannot be overstated. To date the following 

dinosaurs have been identified from the Liscomb Bone Bed: Hadrosaurus, Pachyrhinossaurs, 

Thescelosaurus, Troodon, Dromaeosaurus, Saurornitholestes, Tryannosaurus, and Ornithomimosaurus 

(Druckenmiller 2010; Fiorillo et al. 2009; Gangloff et al. 2005). 

Dinosaur tracks and skin imprints have been identified on the Awuna, Kuk, Kokolik, and Avingak rivers, 

some of which were of species not previously known to have been present in the NPR-A. An Ichthyosaur 

skeleton from the Upper Triassic (approximately 210 mya) was located and recovered along the North 

Face of the Brooks Range from Cutaway Creek, a tributary of the Kuna River. Other than a single 

hadrosaur bone found on Axel Heiberg Island, the dinosaur remains in the NPR-A not only represent the 

farthest north occurrence of dinosaurs in North America but account for about 99 percent of the known 

polar dinosaur remains worldwide. 

The mammalian fossil remains most commonly found in the NPR-A date from 50,000 to 12,000 years 

ago, the final episode of the Pleistocene, and are abundant in many of the Quaternary deposits across the 

region (Guthrie and Stoker 1990; Hamilton and Ashley 1993; Matheus 1998, 2000; Matheus et al. 2003). 

Like dinosaur remains, most of the Pleistocene fossils are found as the result of stream erosion. The bones 

of horses, mammoths, antelope, bison, bears, lions, muskoxen, caribou, and moose are a resource of 

important data reflecting the climate, environment, and ecosystem that existed when the first humans 

entered the Western Hemisphere from the Old World (Dale Guthrie 2006; Kunz and Mann 1997; Kunz et 

al. 1999; Mann et al. 2008). The genetic information in these fossils also provides valuable information 

regarding the impacts of and responses to episodes of past climate change on populations of Arctic 

megafauna (Groves et al. 2009). Other information on paleontological resources is provided in BLM 

(2004, Section 3.2.1.6) and BLM (2012, Section 3.2.7). 

Fossil-bearing locales of Pleistocene mammals are more numerous than those of dinosaurs because they 

are much younger, Late Pleistocene in age (45,000–12,000 years ago), and in most cases not as deeply 

buried and therefore are more easily exposed. In most cases Pleistocene mammal remains are not 

fossilized (mineralized) and therefore are a good source of bio-molecular material, which can provide 

insights into past environmental conditions, and also can be dated very accurately by the radiocarbon 

method. Pleistocene fossils have been recovered from the Colville River and most of it tributary streams 

and from the Ikpikpuk, Titaluk, and Meade rivers and their tributary streams (Matheus 1998, 2000). 

Pleistocene faunal remains have also been identified in deflated sand dunes of Pleistocene age on the 

coastal plain.
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Pleistocene fossils have been recorded from all the physiographic provinces within the NPR-A, but are 

most common in the northern portion of the Arctic Foothills and the southern portion of the Arctic Coastal 

Plain Provinces. It is probable that dinosaur remains are as ubiquitous across the NPR-A as are 

Pleistocene remains, but are too deeply buried to be exposed except under special circumstances. The 

principal reason that dinosaurs are known primarily from the Colville River is that a river of that 

magnitude is required to down-cut deep enough to expose fossils of Cretaceous or greater age. Most of 

the paleontological resources in the NPR-A are protected from most types of impact by virtue of their 

isolation and remoteness. The bulk of the deposits are deeply buried and frozen under a landscape that is 

covered by snow 9 months of the year. It is through exposure on eroding bluff faces that most 

paleontological remains are discovered, but this also exposes these resources to the threats of erosion and 

unauthorized collection or looting, and therefore the loss of valuable and important scientific and 

educational material. 

Paleontological Resources in the Project Area

As shown in Table 19, there are seven total paleontological sites located in the project area listed in the 

Alaska Heritage Resources Survey database (Alaska Department of Natural Resources OHA 2017). These 

resources are almost exclusively Pleistocene in age, namely sites relating to mammoths, with exceptions 

being one undated site that contains bird and small mammal remains and two other sites containing 

Pleistocene gastropod (snail) species. However, the conditions of these sites vary as recent attempts have 

failed to relocate HAR-00038 and HAR-00039, while no attempt to relocate HAR-00031 has been 

reported; the current conditions of these sites remain unknown. BLM archaeologists collected the exposed 

mammoth femur at HAR-00057 and found nothing further at the site after excavating the surrounding 

area. The mammoth scapula at HAR-00170 was found after having been moved from its original location 

(therefore lacking important contextual information) and was also removed. HAR-00066 and HAR-00067 

are the only intact paleontological site confirmed to be in the study area, thus these are the only sites that 

are considered in the environmental consequences analysis presented in Chapter 4. 

Table 19. Paleontological sites located in GMT2 Project area

Alaska Heritage

Resources Survey Site Description Site Condition (Year)

HAR-00031 Mammoth remains in bluff section of Colville 

River

Unknown (1986)

HAR-00038 Middle Pleistocene gastropods invertebrates Field surveys could not relocate (1986)

HAR-00039 Middle Pleistocene gastropods invertebrates Field surveys could not relocate (1986)

HAR-00057 Mammoth femur sticking vertically from ground Removed and completely excavated 

(2003)

HAR-00066 Fragmentary mammal fossils in eroded, slumped 

sediments

Intact (2004)

HAR-00067 Bird and small mammal remains Intact (2004)

HAR-00170 Out of context mammoth scapula found in gravel 

used at Alpine that came from the Arctic Slope 

Regional Corporation Mine site

Removed and completely excavated 

(2007)

3.2.1.7 Renewable Energy

The existing and potential development areas for renewable energy generation facilities within the project 

study area are essentially the same as described in BLM (2014, Section 3.2.1.7) 

3.2.1.8 Wildland Fire

Wildland fire in the NPR-A is discussed in BLM (2012, Section 3.3.3) and includes both wildfires and 

prescribed fires. Wildfires are unplanned fires that occur in wildlands and are caused by human or natural 
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means (e.g., lightning strikes), whereas prescribed fires are naturally or manually ignited fires that occur 

in areas where burning is planned. Prescribed fires have not been used as a management tool within the 

NPR-A and are not proposed (BLM 2012, page 222). Large wildfires are rare in the tundra on the North 

Slope; most are small and although fires larger than 10,000 acres have occurred, the 256,000-acre 

Anaktuvuk River Fire in 2007 was unprecedented. Palynological (pollen) investigation of two foothills 

lakes shows little evidence of large, extensive fires in the past 5,000 years and analysis of deeper lake 

cores have revealed only a few large fires in the past 9,000 years or so. The number of recorded fires on 

the North Slope has increased over the past 40 years, although this may be attributed to increased 

detection (BLM 2012, page 222). Though wildfire is not historically common in the area of the project, in 

2012 two lightning-caused wildfires occurred within a few miles of the project area. One of the two (the 

2,311-acre Itkillik River Fire) required suppression action while the other (216-acre West Collville River 

Fire) did not.

3.2.2 Water Resources

The aquatic environment, including the project area is described in BLM (2004a, Section 3.2.2.1) and 

BLM (2012, Section 3.2.10.1). 

Water resources in the project area consist mainly of rivers, shallow discontinuous streams, lakes, and 

ponds. Springs are absent, deep groundwater is saline, and shallow groundwater is limited to shallow 

areas below rivers and lakes. Streams in the Arctic Coastal Plain typically freeze relatively early and thaw 

relatively late (September and June, respectively). Wetlands are described in Section 3.3.1, “Vegetation 

and Wetlands.”

Hydrology in the project area is predominantly a function of climate and permafrost, which limits water 

availability. More than half the annual precipitation occurs as snow, and snowmelt contributes the 

majority of annual runoff and helps maintain a saturated layer of surface soils. 

This section summarizes relevant information originally presented in the BLM reports cited above and 

includes supplemental information regarding hydrology in the proposed project area obtained from 

studies conducted in 2009 through 2013 by Michael Baker Jr., Inc. (Michael Baker Jr. Inc. 2009b, 2010, 

2011, and 2013a).

3.2.2.1 Rivers, Streams and Drainage Basins

The following discussion is drawn from BLM (2012, Section 3.2.10.1). While hydrologic data for the 

proposed project area is limited, streams and rivers for which data are available share flow characteristics 

that are unique to the region (Brabets 1996). In the winter, flow is generally nonexistent or so low as to 

not be measurable. River flow begins during break-up in late May or early June as rapid flooding, and 

when combined with ice and snow, can inundate extremely large areas in a matter of days. More than half 

of the annual discharge for a stream can occur during a period of several days to a few weeks (Sloan 

1987). Most streams continue to flow throughout the summer, but at substantially lower discharges. 

Rainstorms can increase stream flow, but they are seldom sufficient to cause flooding within the Arctic 

Coastal Plain. Stream flow rapidly declines in most streams shortly after freeze-up in September and 

ceases in most rivers by December. Streams on the North Slope are generally divided into three types, 

based on the physiographic province of their origin: those that originate: (1) on the Arctic Coastal Plain, 

(2) in the Arctic foothills, or (3) in the Brooks Range. 

The Arctic Coastal Plain is a mosaic of tundra wetlands with extremely low relief. Because the permafrost 

prevents water from entering the ground and the low relief limits runoff, the Arctic Coastal Plain is 

covered with lakes, ponds, and generally slow-moving streams. Streams originating in the Arctic Coastal 

Plain generally have the latest break-up and earliest freeze-up. The Tiŋmiaqsiġvik (Ublutuoch) River and 
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Fish Creek both originate in the Arctic Coastal Plain. There are no streams in the project area that 

originate in the Arctic foothills.

Streams originating in the Arctic foothills have a steeper gradient and consequently more gravel bar and 

cut bank features than those on the Arctic Coastal Plain. These streams tend to break up earlier, freeze-up 

later, and have a slightly higher average unit runoff than streams of the Arctic Coastal Plain.

The Colville River is the largest river on the North Slope originating in the Brooks Range. As the only 

river that includes mountainous and glacial drainage, the Colville River carries the highest sediment load 

and exhibits the greatest range of geomorphic features of any river in the area. Break-up and freeze-up are 

more complex along the Colville River because of the extreme length and range of elevation. Flow 

persists later in the year on the Colville River than on other North Slope rivers in the region. 

Approximately half the project area is located within Tiŋmiaqsiġvik (Ublutuoch) River drainage basin. 

The project area also lies within the Fish Creek drainage basin, Judy Creek drainage basin, the Colville 

River Delta-Frontal Harrison Bay drainage basin, the Antiganu Point-Frontal Harrison Bay drainage 

basin, and the Kachemach River drainage basin (see Table 20). The project area is located primarily 

within the eastern portion of the Fish Creek drainage basin and the northern portion of the Tiŋmiaqsiġvik 

(Ublutuoch) River drainage basin (Michael Baker Jr. Inc. 2009a; BLM 2004a, 2012). 

A summary of general hydrologic data for the major drainages located near the proposed project 

infrastructure is provided in Table 20 and shown on Map 3.2-2. 

Table 20. Summary of drainage basins within the project area a

Drainage Basin Waterbody Headwater Origin Receiving 

Water

Drainage 

Area 

(square 

miles)

Lake 

Coverage 

(%)

Colville River Colville River (Nigliq 

Channel and East Channel)

Brooks Range Harrison Bay 20,920 3

Fish Creek Fish Creek Arctic Foothills and 

Arctic Coastal Plain

Harrison Bay 1,827 22

Judy Creek Judy Creek Arctic Foothills Fish Creek 666 18

Tiŋmiaqsiġvik 

(Ublutuoch) River

Tiŋmiaqsiġvik (Ublutuoch) 

River

Arctic Coastal Plain Fish Creek 248 15

a Adapted from BLM (2004a, Table 3.2.2-2; Section 3.1.1) with additional information from BLM (2012, Table 3-12). The Harrison 

Bay and Kachemach River drainage basins are located within the project area, but are unlikely to be directly affected by the 

proposed project infrastructure or activities.

Colville River and Colville River Delta

The Colville River is the longest river (370 miles) and has the largest drainage basin (20,920 square 

miles) on the North Slope of Alaska, extending from the Brooks Range to the Arctic Ocean (Jorgenson et 

al. 1997). The Colville River Delta is more than 25-miles long and covers approximately 250 square miles 

(Jorgenson et al. 1994). The head of the Colville River Delta is the downstream-most point where the 

river flows in a single channel. Information about the Colville River or Colville River Delta is described 

in BLM (2004a, Section 3.2.2.1) and BLM (2012, Section 3.2.10). 

Fish Creek Basin Streams

The general Fish Creek drainage basin and stream information is described in BLM (2004a, Section 

3.2.2.1) and BLM (2012, Section 3.2.10.1). 

The Fish Creek drainage basin is relatively large (1,827 square miles) with portions of its headwaters in 

the Arctic foothills, as well as the Arctic Coastal Plain. The Fish Creek basin consists of three significant 
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tributary basins: Inigok Creek drainage basin, Judy Creek drainage basin, and Tiŋmiaqsiġvik (Ublutuoch) 

River drainage basin (URS Corporation 2003). Only the Judy Creek drainage basin has a significant 

portion of its headwaters in the Arctic foothills (BLM 1998b). Supplemental information relative to the 

project area and more recent studies are presented below.

The Fish Creek drainage basin has two significant streams within the project area, Fish Creek and its 

tributary, the Tiŋmiaqsiġvik (Ublutuoch) River. Fish Creek flows northeast and enters Harrison Bay just 

west of the Colville River Delta. The Tiŋmiaqsiġvik (Ublutuoch) River (as well as the Nigliq Channel of 

the Colville River) is used by residents of Nuiqsut for access to hunting and fishing areas (BLM 2004a, 

Section 3.4.9.4). Judy Creek, a tributary to Fish Creek, is outside the project area.

The hydrology of the project area, including the Tiŋmiaqsiġvik (Ublutuoch) River sub-drainage has been 

studied from 2001 through 2013. The Tiŋmiaqsiġvik (Ublutuoch) River is a tributary of Fish Creek that 

flows north approximately 7 river miles from the GMT1 road crossing, connecting to Fish Creek 

approximately 10 river miles upstream from Harrison Bay. It is characterized by numerous meander 

bends, often with undercut banks (Michael Baker Jr. Inc. 2009a) which are vegetated with dense brush 

(Dietzmann et al. 2002).

There are two primary drainage basins crossed by the proposed route to GMT2 from GMT1, Fish Creek 

and Tiŋmiaqsiġvik (Ublutuoch) River. Delineation of sub-drainage basins that contribute to the flow at 

various points along the proposed corridor for the GMT1 Project show that water flow along the GMT1 

road corridor is typically from the south to north (BLM 2014, Section 3.2.2.1). Information collected at a 

small drainage along the proposed route from GMT1 to GMT2 showed water flow from south to north, 

and supports a conclusion that the water flow along the proposed GMT2 route is typical to that of the 

GMT1 area (Michael Baker Jr. Inc. 2011). In general, the sub-drainage basins are relatively small (4.1 

square miles or less) (Michael Baker Jr. Inc. 2009a).

There are no large or perennial streams along the GMT2 proposed road and pipeline corridor. The route 

crosses a small, unnamed beaded stream pool outlet draining from Lake M9925 (see Map 3.2-3). There 

are no additional new stream or river crossings proposed for the GMT2 Project, although smaller, 

seasonal flow drainages may be crossed. The small, unnamed beaded stream pool crossed by the GMT2 

proposed access corridor is described as a poorly defined, shallow-beaded stream that drains a ponded 

area into Lake M9925. This drainage was monitored in 2010 and 2011, with visual observations 

continuing in 2013 (Michael Baker Jr. Inc. 2010, 2011, 2013a). The drainage at this location was shallow 

and poorly defined during spring break-up monitoring in 2010 and was well defined during spring breakup monitoring in 2011, although later in the season the flow ceased (Michael Baker Jr. Inc. 2011).

Flooding Regime

Flooding of North Slope rivers is influenced by the type of physiographic region drained, the size of the 

drainage area, and the frequency of the event. Snowmelt flooding occurs annually in all North Slope 

rivers. For rivers in the project area, snowmelt flooding nearly always produces the annual peak 

discharge. On some of the larger rivers, summer precipitation or late summer/fall snowmelt events have 

been observed to produce low magnitude floods. Ice jams during break-up can also influence or result in 

flooding as described in the following sections.

As spring break-up flooding is normally the largest annual flooding event each year on the North Slope, 

monitoring of this event is integral to understanding regional hydrology. The break-up cycle is the result 

of several factors including snow pack, sustained cold or warm temperatures, ice thickness, wind speed 

and direction, precipitation, and solar radiation (Michael Baker Jr. Inc. 2009a).
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Colville River and Colville River Delta

The flooding regime for the Colville River and Colville River Delta remain essentially as described in 

BLM (2004a, Section 3.2.2.1).

Fish Creek Basin

The hydrologic conditions on Fish Creek, Judy Creek, and the Tiŋmiaqsiġvik (Ublutuoch) River were 

investigated during break-up in 2001, 2002, and 2003 (URS Corporation 2001, 2003; Michael Baker Jr. 

Inc. 2003). These studies were presented in BLM (2004a, Section 3.2.2.1) and included monitoring sites 

at six locations along Fish Creek, four locations along Judy Creek, and two locations along the 

Tiŋmiaqsiġvik (Ublutuoch) River. The hydrologic conditions on Fish Creek and Judy Creek were studied 

from 2005–2009 and also on the Tiŋmiaqsiġvik (Ublutuoch) River from 2007–2009 (U.S. Geological 

Survey 2017). The hydrologic conditions within the Fish Creek drainage basin were further studied in 

2009, 2010, 2011, and 2013 to support the proposed GMT1 and GMT2 Projects (Michael Baker Jr. Inc. 

2009a, 2010, 2011, 2013a).

3.2.2.2 Lakes and Ponds

The characterization of lakes and ponds within the project area remains essentially as described in BLM 

(2004a, Section 3.2.2.1) and BLM (2012, Section 3.2.10.1), as summarized in the following sections.

Lakes and ponds are the most common hydrologic feature on the Arctic Coastal Plain, including the 

project area, with most of the lakes and ponds in this region originating from the thawing of ice-rich 

sediments (Sellman et al. 1975). Surface water sources located in close proximity to proposed GMT2 

Project facilities include several drainages, and small creeks near the proposed GMT2 pad. There are also 

several lakes, drainages, and small creeks along the access road to GMT1.

Unlike streams, lakes store water year-round and are the most readily available water source on the North 

Slope (Sloan 1987), with availability of year-round water determined by the depth of the lake. Lakes are 

generally classified by depth, as either shallow (less than 6 feet) or deep (greater than 6 feet).

Recharge of lakes in the project area occurs through three mechanisms: (1) melting of winter snow 

accumulations within the lake’s drainage basin, (2) overbank flooding from nearby streams, and (3) 

precipitation in the form of rainfall (Michael Baker Jr. Inc. 2002). Smaller lakes may also be recharged by 

other lakes within the project area if they are connected by a channel.

Shallow Lakes and Ponds

Seasonally flooded wetlands, ponds, and shallow lakes dominate the Arctic Coastal Plain in the project 

area. The shallow lakes and ponds generally begin to freeze in September, freeze to the bottom by midwinter, and become ice-free between mid-June and early July, about a month earlier than the deeper lakes 

(Walker 1983, Hobbie 1984).

While ponds and shallow lakes generally lack fish because they usually freeze to the bottom, they can 

provide important summer fish-rearing habitat if they are connected to a stream by a channel or 

intermittently flooded by a nearby stream. They also provide important habitat to emergent vegetation, 

invertebrates, and migratory birds due to the earlier availability of ice-free areas.

Deep Lakes

Deep lakes (greater than 6 feet deep) with relatively large areas are present in the southern and western 

areas of the Arctic Coastal Plain. Some deep lakes are present within the project area. Because deep lakes 

do not freeze to the bottom, they provide an overwintering area for fish and aquatic invertebrates and are 
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the most readily available supply of water during the winter. Deep lakes also have a larger thermal mass, 

thus the deeper lakes may remain covered by ice into early July (much later than the shallow lakes) 

(Walker et al. 1978). 

Lake Water Usage

Ongoing and future oilfield activities within the project area would utilize ice roads and pads during the 

winter for access and transportation. Each winter season, millions of gallons of fresh water and ice chips 

are withdrawn from regional lakes for the construction of ice roads and pads. Water withdrawals for 

construction can begin as early as December and continue through April. Ice roads are usually completed 

mid-winter; however, water withdrawals for ice road and pad maintenance continue throughout the 

season. Freshwater lakes are also used as a potable water source and as sources of make-up water for 

exploratory drilling operations (Michael Baker Jr. Inc. 2002). 

Between 1999 and 2006, approximately 513 million gallons of water from 126 lakes were used for 

exploration and construction of ice roads and pads in the NPR-A (BLM 2012, Section 3.2.10.1). 

Generally, water withdrawals during winter occur from lakes 7-feet deep or deeper and are limited to 15 

percent of the estimated free-water volume remaining below the ice.

Lake Studies

The BLM (2004a, Section 3.2.2.1) described several lake studies conducted between 2000 and 2003 

located within the project area. Key findings from these studies are summarized briefly as follows.

• Over a 5-year-study-period, water withdrawals generally did not affect water chemistry, nor did they 

directly affect fish populations (MJM Research 2003e). Pumping did not appear to affect temperature, 

pH, turbidity, sulfate, or nitrate levels (Michael Baker Jr. Inc. 2002).

• Lake water quality parameters (including dissolved oxygen, specific conductance and pH) changed 

little as a result of pumping (for water withdrawal). Water surface elevation changes in pumped lakes 

were within the range of changes seen in reference lakes, and changes in water surface elevations 

were correlated with changes in ice thickness (Oasis 2001).

• Water withdrawal rates were typically well below the maximum allowable. The water level decreases 

caused by pumping did not advance the freezing rate of the study lakes, and water levels depressed by 

pumping returned to pre-pump levels before freeze-up (Michael Baker Jr. Inc. 2002). 

• Water surface elevations in the majority of pumped lakes were lowered more than in reference lakes. 

The dominant mechanism for recharge of the lakes was melting winter snow accumulations. Data 

from 2001 and 2002 studies as well as anecdotal information at seven North Slope communities 

(including Nuiqsut) indicated that the magnitude of spring recharge has always been sufficient to 

compensate for withdrawals (Michael Baker Jr. Inc. 2002).

3.2.2.3 Subsurface Water (Groundwater)

The characterization of groundwater within the project area remains essentially as described in BLM 

(2004a, Section 3.2.2.1) and BLM (2012, Section 3.2.10.1), as summarized in the following sections. 

In general, usable subsurface water in the project area is limited to distinct and unconnected shallow 

zones due to the presence of permafrost, which is almost continuous across the North Slope (BLM 2004a, 

Section 3.2.2.1). The frozen state of the soils combined with their fine-grained characteristics and 

saturated conditions form a confining layer that prevents percolation and recharge from surface water 

sources, and prohibits the movement of groundwater. Because percolation and recharge are restricted, the 

formation of usable subsurface water resources is limited to unfrozen material on top of the permafrost or 

taliks (thawed zones) beneath relatively deep lakes, or zones in thawed sediments below major rivers and 
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streams. In general, while these shallow groundwater zones do exist, they are typically very small and the 

water is likely unsuitable for drinking and potentially harmful to vegetation due to high salinity when 

discharged on the tundra surface (BLM 2004a, Section 3.2.2.1). 

Shallow, supra-permafrost water also occurs seasonally in the region within the active zone above the 

impervious permafrost; the thickness of the active layer is typically 1.5 feet, but ranges from 1 feet to 4 

feet (BLM 2004a, Section 3.2.2.1). 

Groundwater within permafrost or intra-permafrost water occurs in discontinuous confined locations, 

where often the presence of dissolved salts depresses the freezing point of the water. Like shallow 

groundwater, the saline quality of the intra-permafrost groundwater makes it unsuitable for drinking water 

and potentially harmful to vegetation if discharged to the tundra surface. The usability of this type of 

groundwater source is likely to be limited because of the nature of its formation. 

Deep wells drilled through the permafrost have encountered highly mineralized groundwater at depths of 

3,000 feet to more than 5,000 feet in the vicinity of Prudhoe Bay and at depths of 1,600 feet to 2,500 feet 

near Utqiagvik (formerly Barrow), but little data on deep water sources in the project area exist (BLM 

2008a, Section 3.2.9.3; Kharaka and Carothers 1988). Available data suggest that deep groundwater in the 

NPR-A would probably be similar to that found at Utqiagvik (formerly Barrow) and Prudhoe Bay, and 

would be too saline for domestic use (BLM 2008a). 

Recharge

Snowmelt provides the major source of water for recharge to the shallow water-bearing zones that occur 

below large lakes and major streams and to the annual thaw zones that occur beneath ponds and marshy 

areas (BLM 2004a, Section 3.2.2.1). However, deeper groundwater zones beneath the permafrost are not 

as readily recharged. Sub-permafrost water may be recharged from areas to the south in the Arctic 

foothills and the Brooks Range by infiltration of meltwater. It is also possible that the sub-permafrost 

water could represent stagnant and/or isolated water zones that were cut off from recharge and 

groundwater movement as a result of the formation of permafrost during the Pleistocene, or that were 

isolated by orogenic events associated with the formation of the Brooks Range. 

Springs

Landsat imagery analysis was used to locate numerous groundwater springs on the North Slope by 

identifying the large overflow icings (aufeis) created downstream during the winter. However, none of 

these springs were located in the project area (BLM 2004a, Section 3.2.2.1). 

3.2.2.4 Surface Water Quality

A summary of surface water chemistry by analyte in the project area is contained in the Alpine Satellite 

Development Plan Final EIS as cited in BLM (2004a, Section 3.2.2.2) and in BLM (2012, Section 

3.2.10.2). Results for water quality that are relevant to the project area are summarized as follows.

It is important to have knowledge of existing water quality conditions in determining potential impacts of 

proposed actions. Surface water is used by fish and wildlife in the project area and could be a source of 

potable water for humans. The State of Alaska water quality standards are published in 18 AAC 70. The 

State of Alaska drinking water regulations prescribe treatment for potable use. Drinking water regulations 

for the State of Alaska are published in 18 AAC 80. 

Drinking water is obtained from lakes near the Alpine development (lakes L9313 and L9312 seen on Map 

3.2-3) and Nuiqsut (BLM 2014 Section 3.2.2.4). A discussion regarding drinking water for these sources 

is included in Section 3.4.6, “Public Health.” 
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Most freshwaters in the project area are considered pristine as stated in BLM (2012, Section 3.2.10.2); 

however, fecal contamination above State of Alaska water quality standards may occur in areas with 

dense avian, caribou, and lemming populations. Cold water temperatures tend to prolong the viability of 

fecal coliform. Ponds and local streams are highly colored from dissolved organic matter and iron, and 

most freshwater waterbodies in the NPR-A have low turbidity, and dissolved oxygen near saturation. 

According to Alaska Department of Environmental Conservation, no freshwater in the proposed project 

area is impaired by pollutants (BLM 2004b, Section 3.2.2.2, page 184; Alaska Department of 

Environmental Conservation 2017). 

Water quality data specific to the lakes in the vicinity of the proposed GMT2 Access Road corridor and 

pad, GMT1, CD1, and CD4 were collected in 2002, 2004, and 2009–2012 as described in MJM Research 

(2004), Michael Baker Jr. Inc. (2009b), North Slope Science Initiative Alaska (2009), Michael Baker Jr. 

Inc. (2010), and Derry et al. (2012). Surface water features, including named lakes, are included in Map 

3.2-3. 

These data can be used to evaluate the potential impact to water quality from roads and pads associated

with CD1 and CD4 and provide background water quality data for the proposed project area. Turbidity 

measured was variable between lakes and during monitoring years but, in all cases, was well below the 

levels that affect aquatic organisms. Dissolved oxygen measured during the summer was typically near 

100 percent saturation in the lakes sampled as discussed in MJM Research (2006), Michael Baker Jr. Inc. 

(2009b), and Michael Baker Jr. Inc. (2010). Dissolved oxygen concentrations for lakes approximately 10-

feet deep remained high during the March 2011 sampling event but concentrations were lower by 50 

percent for lakes 6 feet deep as discussed in Derry et al. (2012). Winter dissolved oxygen concentrations 

are highly variable between individual lakes (deep and shallow) and stratified within the water column 

under the ice and cannot be regionalized, which makes it extremely difficult to compare lakes across a 

region. 

In 2006 and 2008, water chemistry results from lake samples collected within the proposed project area 

met the water quality standards for dissolved oxygen, pH, and turbidity (North Slope Science Initiative 

Alaska 2009). Of those lakes sampled, lakes M0024, M9914, M9922, and M9923 are located within 0.5 

mile of the proposed GMT2 pipeline route (see Map 3.2-3). 

Information available for alkalinity and pH, with respect to freshwater waterbodies within the proposed 

project area, remain essentially as described in BLM (2004a, Section 3.2.2.2) and in BLM (2012, Section 

3.2.10.2). 

3.2.3 Atmospheric Environment

Regional air quality is influenced by factors including climate, meteorology, magnitude and location of air 

pollution sources, and chemical properties of air pollutants. In the lower atmosphere, regional and local 

air quality is also impacted by topography influencing atmospheric dispersion and pollutant transport. The 

following sections summarize the existing air quality and conditions within the GMT2 Project area, 

National Petroleum Reserve in Alaska (NPR-A), and Alaska North Slope. 

3.2.3.1 Climate and Meteorology

The GMT2 Project area is located in the NPR-A as part of the Alaska North Slope in Section 32, 

Township 10N, Range 2E, Umiat Meridian. The area is considered an Arctic Climate Zone with cold 

winters spanning approximately 8 months of the year and cool summers spanning approximately 4 

months of the year. Based on the data from the Nuiqsut Airport, the annual mean temperature of the 

GMT2 Project area averages −10 degrees Fahrenheit (°F), with temperatures below freezing from October 

through May. The monthly temperature, precipitation, and snowfall data for nearby monitoring locations 

in the GMT2 Project area are detailed in Table 21 below. Utqiagvik (formerly Barrow) Airport and 
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Kuparuk are included in the table as they have data spanning 30 years for a more accurate view of climate 

norms of the area, whereas Nuiqsut is the station closest to the GMT2 Project area and has collected more 

recent years of data.

From data downloaded from the Nuiqsut Airport spanning 2006 through 2016 (National Climatic Data 

Center 2017), the average maximum monthly temperature is 11 °F with the maximum temperature 

occurring in July at approximately 29 °F. During that same time period, the average minimum monthly 

temperature is −29 °F with the minimum temperature occurring in January at −49.4 °F. The mean 

temperature during that 10-year period is −10 °F. In the GMT2 Project area, rainfall is highest during the 

months of July and August, with monthly totals averaging 1 inch and snowfall is the highest during 

October, averaging approximately 8.7 inches. 

Wind speed and direction is monitored at the Nuiqsut Monitoring Station operated by ConocoPhillips. 

The wind rose shown in Figure 1 shows the characteristic east-northeast to west-southwest bimodal 

pattern of the Alaska North Slope and winds speed and direction from 2011 through 2015. The mean 

hourly wind speed average 5 meters per second (11 miles per hour [mph]), and calm winds were 

infrequent occurring less than 1 percent of the 2011–2015 5-year period (SLR International Corporation 

2012, 2015, 2016, 2017). 

Wind speed and direction are important to the dilution and transport of air pollutants. Wind direction 

determines where the air pollutants are transported, and based on the Nuiqsut Monitoring Station wind 

rose, air pollutants are most often transported in a southwest direction within and near the GMT2 Project 

area. Wind speed impacts the concentration of air pollutants since dispersion increases with increasing 

wind speeds, thereby decreasing air pollutant concentrations at individual receptors. 

The degree of stability in the atmosphere is also a key factor in dispersion of emitted pollutants. During 

stable conditions, vertical movement in the atmosphere is limited and the dispersion of pollutants is 

inhibited. Conversely, during unstable conditions, vertical motions in the atmosphere are prevalent, and 

dispersion of pollutants in the atmosphere is enhanced. Temperatures that increase with height, or 

temperature inversions, can result in very stable conditions with virtually no vertical air motion. The 

GMT2 Project area will typically have more severe inversions in the winter rather than in the summer due 

to colder stable air masses settling closer to the ground. Afternoons in the GMT2 Project area typically 

have increasing instability due to warming. 
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Table 21. Monthly temperature, precipitation, and snowfall summary

Location Weather Data Jan Feb Mar Apr May Jun Jul Aug Sept Oct Nov Dec Avg.

Utqiagvik (formerly 

Barrow) Airporta

Daily Max 

Temperature (°F)

-7.3 -8.0 -6.1 8.5 25.8 40.5 46.9 43.9 35.8 21.8 6.2 -1.8 17.2

Utqiagvik Airporta Daily Min 

Temperature (°F)

-19.5 -20.4 -19.2 -4.9 16.5 30.8 34.8 34.1 28.5 12.6 -4.8 -13.8 6.2

Utqiagvik Airporta Daily Avg 

Temperature (°F)

-13.4 -14.2 -12.7 1.8 21.1 35.6 40.9 39.0 32.1 17.2 0.7 -7.8 11.7

Utqiagvik Airporta Avg Total 

Precipitation (in)

0.13 0.14 0.09 0.16 0.18 0.32 0.98 1.05 0.72 0.41 0.21 0.14 4.53

Utqiagvik Airporta Avg Total 

Snowfall (in)

2.6 2.6 2.1 3.2 2.7 0.7 0.2 0.9 4.4 9.1 5.7 3.5 37.7

Kuparuka Daily Max 

Temperature (°F)

-10.0 -10.5 -7.4 9.3 28.6 47.7 56.6 51.0 39.7 21.2 3.8 -4.4 18.8

Kuparuka Daily Min 

Temperature (°F)

-20.8 -21.7 -19.8 -4.3 18.9 35.1 41.0 39.1 31.1 12.3 -7.4 -15.5 7.3

Kuparuka Daily Avg 

Temperature (°F)

-15.4 -16.1 -13.6 2.5 23.7 41.4 48.8 45.1 35.4 16.7 -1.8 -10.0 13.1

Kuparuka Avg Total 

Precipitation (in)

0.12 0.09 0.08 0.16 0.07 0.32 0.89 1.04 0.44 0.30 0.15 0.14 3.80

Kuparuka Avg Total 

Snowfall (in)

2.8 2.6 2.3 2.8 1.8 0.5 0.0 0.3 3.0 8.4 4.9 3.7 33.1

Nuiqsutb Daily Max 

Temperature (°F)

1.1 1.7 -0.6 5.6 12.8 27.2 28.9 24.4 18.3 9.4 1.7 1.7 11.0

Nuiqsutb Daily Min 

Temperature (°F)

-49.4 -49.0 -47.0 -39.4 -29.4 -5.0 -1.0 -2.0 -12.8 -28.3 -40 -46 -29.1

Nuiqsutb Daily Avg 

Temperature (°F)

-26.6 -24.3 -26.7 -15.7 -4.26 4.83 8.85 6.31 1.59 -5.11 -15.9 -22.4 -9.94

a Source: NOAA (2017). Data downloaded from https://www.ncdc.noaa.gov/cdo-web/datatools/normals for Utqiagvik (formerly Barrow) Wiley Post-Will Rogers Airport, Alaska; and 

Kuparuk, Alaska (1981–2010).

b Source: National Climatic Data Center (2017). Data downloaded from NCEI CDO on September 15, 2017, for Nuiqsut, Alaska, from 2006 through 2016.
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Figure 1. Nuiqsut Monitoring Station, 2011–2015 wind rose

3.2.3.2 Air Quality 

Federal and state air quality regulations exist under the Clean Air Act to protect existing air quality. 

Alaska is one of four Pacific Northwest states regulated under Region 10 of the U.S. Environmental 

Protection Agency (EPA). In Alaska, the Alaska Department of Environmental Conservation is the 

regulating authority to enforce the Alaska Air Quality Control Regulations under 18 Alaska 

Administrative Code 50 per the state implementation plan approved by the EPA.

There are a number of federal air quality regulations that are applicable to sources in the oil and gas 

industry segment. These include New Source Performance Standards (40 Code of Federal Regulations 

[CFR] Part 60), National Emission Standards for Hazardous Air Pollutants (40 CFR Part 61), National 

Emission Standards for Hazardous Air Pollutants for Source Categories (40 CFR Part 63), and Mandatory 

Greenhouse Gas Reporting (40 CFR Part 98). Many federal regulations have been adopted by Alaska 

Department of Environmental Conservation and published by reference in the Alaska Air Quality Control 

Regulations. Federal air quality regulations should be evaluated for applicability and must be followed in 

addition to state permitting requirements.

Under Alaska Department of Environmental Conservation authority, there are different types of air quality 

permits for the oil and gas industry that may apply. Sources that have estimated emissions of 250 tons per 
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year or greater are required to file for a construction permit. Otherwise, the facility is required to file a 

minor source specific or Title I permit. Lastly, sources that have the potential to emit 10 tons per year or 

more of a single hazardous air pollutant, 25 tons per year or more of total hazardous air pollutants, and/or 

100 tons per year or more of any criteria pollutant (nitrogen oxides [NOx], carbon monoxide [CO], 

volatile organic compounds [VOC], sulfur dioxide [SO2], or particulate matter [PM]), are required to file 

an operating or Title V permit. A general permit is offered for oil and gas drill rigs that meet specific 

requirements, such as duration of drilling activity, location and proximity to Class I or non-attainment 

areas, and records that must be kept. 

Currently, the NPR-A is an attainment area as discussed further below. This is supported by monitoring 

station data collected in the Alaskan North Slope for pollutant concentrations, in addition to temperature 

and wind speed. The stations closest to the GMT2 Project area are the CD1 Monitoring Station, CD5 

Monitoring Station, and Nuiqsut Monitoring Station. All of these stations are operated by SLR 

International Corporation on behalf of ConocoPhillips and in accordance with EPA prevention of 

significant deterioration guidance. The stations collect data for CO, NOx, nitric oxide (NO), nitrogen 

dioxide (NO2), ozone (O3), SO2, particulate matter less than 2.5 microns in diameter (PM2.5), and 

particulate matter less than 10 microns in diameter (PM10). A list of the monitoring stations, their location 

coordinates, and the years of data collection are included in Table 22. 

Table 22. Ambient air monitoring stations near the GMT2 Project area

Name of Monitoring 

Station 

UTM NAD83 Zone 5 Easting 

(meters)

UTM NAD83 Zone 5 Northing 

(meters)

Current 3 Years 

of Data

Nuiqsut 575,512 7,792,061 2014–2016

CD1 Facility 577,629 7,805,334 2013–2015

CD5 Pad 566,770 7,801,707 October 2015–

December 2016

The Nuiqsut Monitoring Station is located at the north end of the town of Nuiqsut approximately 400 

meters north west of the Nuiqsut Power Plant. The Nuiqsut Monitoring Station also collects wind 

direction, horizontal and vertical speed, temperature, differential temperature, and solar radiation data. At 

the CD1 Facility, the monitoring station was located on the southwest portion of the pad; data collection 

stopped after 2015. The monitoring data were collected primarily to show if emissions from drilling 

activities and rigs exceeded any National Ambient Air Quality Standards to address air quality for 

continued operations. Based on the wind rose from data collected at the CD1 monitoring station, as 

shown in the CD1 monitoring reports, the wind predominately blows from the east north-east and east 

directions (SLR International Corporation 2013, 2014, 2015a, 2016a). At the CD5 Drill Pad, the 

monitoring station is located on the east portion of the pad and data collection began in October 2015. 

The monitoring data are collected primarily for potential future air permitting activities and also to 

comply with a North Slope Borough ordinance to identify air monitoring systems prior to and after site 

construction (SLR International Corporation 2016b, 2017a). 

Based on analysis of these monitoring stations, the data from Nuiqsut Monitoring Station is considered 

the most representative of the GMT2 Project area. The CD1 and CD5 facility data is more representative 

of the onsite operations, rather than the area at large. The measurements in Table 23 are based on data 

collected from 2014 through 2016 at the Nuiqsut Monitoring Station in parts per million (ppm), parts per 

billion (ppb), and micrograms per cubic meter (μg/m3

) (SLR International Corporation 2015, 2016, 2017). 

These values have been updated after the dataset review and revisions by EPA of the Nuiqsut Monitoring 

Station monitoring data for 2014 (EPA 2017b). 
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Table 23. Nuiqsut Monitoring Station background valuesa 

Pollutant Average 

Time 2014 2015 2016

Background 

Design 

Concentration

Form of Standard

Carbon Monoxide 

(CO) 1-hour 1 ppm 1 ppm 1 ppm 1 ppm(1,230 μg/m3)

Not to be exceeded more 

than once per year

Carbon Monoxide 

(CO) 8-hour 1 ppm 1 ppm 1 ppm 1 ppm(1,230 μg/m3) 

Not to be exceeded more 

than once per year

Nitrogen Dioxide (NO2) 1-hour 25 

ppb

24 

ppb

18 

ppb

22.3 ppb

(41.9 μg/m3) 

98th percentile averaged 

over three years

Nitrogen Dioxide (NO2) Annual 2 ppb 2 ppb 1 ppb 2 ppb

(3.8 μg/m3)

Annual mean

Sulfur Dioxide (SO2) 1-hour 1.9 

ppb

1.2 

ppb

3.2 

ppb

2.1 ppb

(5.9 μg/m3) 

99th percentile averaged 

over three years

Sulfur Dioxide (SO2) 3-hour 2.2 

ppb

0.0 

ppb

0.0 

ppb

2.2 ppb

(6.2 μg/m3) 

Not to be exceeded more 

than once per year

Sulfur Dioxide (SO2) 24-hour 1.7 

ppb

0.0 

ppb

0.0 

ppb

1.7 ppb

(4.8 μg/m3) 

Not to be exceeded more 

than once per year

Sulfur Dioxide (SO2) Annual -0.1 

ppb

0.0 

ppb

0.001 

ppb

0.001 ppb

(0.003 μg/m3)

Annual mean

Particulate Matter of 

less than 10 microns 

(PM10) 

24-hour 40 

μg/m3

51.5 

μg/m3

44.0 

μg/m3 45.2 μg/m3

Not to be exceeded more 

than once per year on 

average over three years

Particulate Matter of 

less than 2.5 microns 

(PM2.5)

24-hour 6 

μg/m3

10 

μg/m3

6 

μg/m3 7.3 μg/m3

98th percentile averaged 

over three years

Particulate Matter of 

less than 2.5 microns 

(PM2.5)

Annual 2.1 

μg/m3

2.8 

μg/m3

1.3 

μg/m3 2.1 μg/m3

Annual mean averaged over 

three years

Ozone (O3) 1-hour 56.8 

ppb

49.0 

ppb

45.1 

ppb

50.3 ppb

(101 μg/m3) 

Not to be exceeded more 

than once per year on 

average over three years

Ozone (O3) 8-hour 53.7 

ppb

46.9 

ppb

44.5 

ppb

48.4 ppb

(96.8 μg/m3) 

Annual fourth-highest daily 

maximum averaged over 

three years

a Values are in parts per million (ppm), parts per billion (ppb), and micrograms per cubic meter (μg/m3). 

The NPR-A is an attainment area for current National Ambient Air Quality Standards and Alaska Ambient 

Air Quality Standards. An attainment area indicates the existing background air quality are below the 

national and state of Alaska standards. The current National Ambient Air Quality Standards/Alaska 

Ambient Air Quality Standards are listed in Table 24and the final backgrounds compared to the National 

Ambient Air Quality Standards are listed in Table 25. 
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Table 24. National Ambient Air Quality Standards and Alaska Ambient Air Quality Standards values

Pollutant

Average 

Time NAAQSa AAAQSb Form of Standard

CO 1-hour 40,000 

μg/m3

40,000 

μg/m3 Not to be exceeded more than once per year

CO 8-hour 10,000 

μg/m3

10,000 

μg/m3 Not to be exceeded more than once per year

NO2 1-hour 188 μg/m3 188 μg/m3 98th percentile averaged over three years

NO2 Annual 100 μg/m3 100 μg/m3 Annual mean

SO2 1-hour 196 μg/m3 196 μg/m3 99th percentile averaged over three years

SO2 3-hour 1,300 μg/m3 1,300 μg/m3 Not to be exceeded more than once per year

SO2 24-hour NA 365 μg/m3 Not to be exceeded more than once per year

SO2 Annual NA 80 μg/m3 Annual mean

PM10 24-hour 150 μg/m3 150 μg/m3 Not to be exceeded more than once per year on 

average over three years

PM2.5 24-hour 35 μg/m3 35 μg/m3 98th percentile averaged over three years

PM2.5 Annual 12 μg/m3 12 μg/m3 Annual mean averaged over three years

O3 1-hour NA 235 μg/m3 Not to be exceeded more than once per year on 

average over three years

O3 8-hour 70 ppb NA Annual fourth-highest daily maximum averaged over 

three years

a Referenced from 40 CFR Part 50.

b Referenced from 18 AAC 50.010.

Table 25. National Ambient Air Quality Standards and Alaska Ambient Air Quality Standards

Pollutant

Average 

Time

Nuiqsut Monitoring 

Station Background NAAQS/AAAQS

Background Percentage of 

NAAQS/AAQS

CO 1-hour 1,230 μg/m3 40,000 μg/m3 3

CO 8-hour 1,230 μg/m3 10,000 μg/m3 12

NO2 1-hour 41.9 μg/m3 188 μg/m3 22

NO2 Annual 3.8 μg/m3 100 μg/m3 4

SO2 1-hour 5.9 μg/m3 196 μg/m3 3

SO2 3-hour 6.2 μg/m3 1,300 μg/m3 0.5

SO2 24-hour 4.8 μg/m3 365 μg/m3 1

SO2 Annual 0.003 μg/m3 80 μg/m3 0.004

PM10 24-hour 45.2 μg/m3 150 μg/m3 30

PM2.5 24-hour 7.3 μg/m3 35 μg/m3 21

PM2.5 Annual 2.1 μg/m3 12 μg/m3 18

There are human-made and natural emission sources that affect air quality in the NPR-A. Human-made 

emission sources in the GMT2 Project area include residential heating, snow machines, vehicle 

combustion and traffic, aircraft, open burning, gravel mining, and oil and gas production facilities. 

Natural emission sources in the GMT2 Project area include particulate matter emissions from wind gusts 

and particulate matter and combustion emissions from wildfires. 
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3.2.3.3 Visibility

Atmospheric visibility degradation, or atmospheric haze, is a result of air pollution and is caused by the 

scattering of sunlight by particles suspended in the atmosphere (EPA, 2017c). The result of haze is 

impaired visibility conditions. In 1999, the EPA published the Regional Haze Rule implementing a 

visibility protection program for certain areas, such as national parks and wilderness areas classified as 

Class I areas and other federally managed public lands classified as Class II areas. Class II areas under the 

Regional Haze Rule have less restrictive visibility requirements compared to Class I areas. The visibility 

threshold is 0.5 delta deciviews (Δdv) (approximately 5 percent change in visibility) which is the level for 

which a source is considered to contribute to regional haze. The 0.5 Δdv is not an adverse impact 

threshold, but is intended as a conservative screening criterion to identify potential visibility impacts. The 

Interagency Monitoring of Protected Visual Environments database collects visibility and air pollutant 

concentration data from monitoring sites in and near Class I areas across the country (Interagency 

Monitoring of Protected Visual Environments 2017). Most monitors record the light extinction 

coefficients which quantifies the change in visibility due to changes in air pollutant concentration. The 

nearest current Interagency Monitoring of Protected Visual Environments monitors near the GMT2 

Project area are listed below in Table 26 along with their approximate distance from the GMT2 Project 

area. The Ambler monitor stopped collecting data in 2004, and is therefore not included. 

Table 26. Nearest interagency monitoring of protected visual environments monitors to project area

Nearest Visibility Monitors

Approximate Distance 

from Project Area

Clean Air Act Status

(Class I or Class II)

Gates of the Arctic National Park 165 miles south-southwest Class II

Denali National Park 500 miles south Class I

Visibility is described by two units of measurement: haze index in units of deciviews (dv) and standard 

visual range in units of kilometers (km). Visibility graphs of the Gates of the Arctic and Denali National 

Park are shown in Figure 2and Figure 3 in units of dv. 
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Figure 2. Visibility data for Gates of the Arctic National Park (IMPROVE Monitor ID: GAAR1)

Figure 3. Visibility data for Denali National Park (IMPROVE Monitor ID: DENA1)

ADEC has indicated that Alaska is affected by international long-range transport of pollutants that affect 

visibility conditions: “International transport of pollutants into Alaska has been documented through a 

variety of research studies. In particular, the research has focused on Arctic haze and Asian dust” (ADEC 

2011). Arctic haze is attributed to anthropogenic aerosols from Northern Europe and Russia that reach 

Alaska in the winter and early spring. At both Gates of the Arctic and Denali national parks,, the natural 

condition haze index on the clearest days is just below 2 dv, which equates to a visual range of 

approximately 350 kilometers (218 miles). The natural condition haze index on the haziest days is about 

7.5 dv, which equates to a visual range of just under 200 kilometers (120 miles). Data collected at the 

monitors, as shown in Figure 2 and Figure 3, show haziest days on a downward trend with a recent 

increase in haze index at Denali National Park. However, both monitors have shown on the haziest days, a 

haze index peak is approximately 15 dv which equates to a visual range of approximately 100 kilometers 

(62 miles). The haze index on clear days is only slightly higher than the natural condition and still shows 

an index between 2 and 4 dv, which is just below a visual range of 350 kilometers (218 miles). Per the 

Nuiqsut wind rose of Figure 1, a southwest directional transport of pollutants is expected for the GMT2 
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Project area. Both of the Interagency Monitoring of Protected Visual Environments monitors are southsouth west of the GMT2 Project area as shown in Figure 9 at the end of this section. Therefore, the 

transport of pollutants from the GMT2 Project may affect the visibility of these national parks.

3.2.3.4 Acid Deposition

Deposition occurs when acid-forming particles in the atmosphere such as nitrate ion (NO3-), sulfate ion 

(SO42

-) and ammonium ion (NH4-) fall to the Earth’s land and water. These acid-forming particles are the 

result of NOx and sulfur oxides (SOx) breaking down or chemically reacting with other compounds in the 

atmosphere. Deposition can occur in three forms: wet deposition where the particles fall by rain or snow, 

occult deposition where particles are transferred by clouds or fog, and dry deposition where particles 

either chemically react or physically fall to the Earth’s surface. Sulfur and nitrogen depositions have a 

0.005 kilogram per hectare per year (kg/ha-yr) deposition analysis threshold set forth by the Federal Land 

Managers for Western Areas (Federal Land Managers 2010). The deposition analysis threshold is not an 

adverse impact threshold; rather, it is an approximate value of the naturally occurring deposition where 

values below it are considered negligible. The National Park Service uses critical loads as an adverse 

impact threshold. Depending on the natural resource, minimum and maximum critical loads can vary. 

Table 27 lists the nearest National Park Service Units where nitrogen critical loads have been analyzed 

and recorded. The critical load range represents the lowest and highest critical loads based on 2010 and 

2011 estimates (Linder et al. 2013) of these units nearest the GMT2 Project area. The maximum nitrogen 

deposition is based on recorded values from 1993 through 2016 for Poker Creek, 2008 through 2015 for 

Gates of the Arctic National Park, and 1980 through 2016 for Denali National Park. 

Table 27. Nearest National Park Service units to project area for nitrogen critical loads

Nearest National Park 

Service Units

Approximate Distance 

from Project Area

Nitrogen Critical 

Load Range 

(kg/ha-yr)a

Maximum Nitrogen 

Deposition

(kg/ha-yr)

Poker Creek 370 miles south-southwest 1–3 0.47

Gates of the Arctic National 

Park 

165 miles south-southwest 1–3 0.94

Denali National Park 500 miles south 1–3 0.64

a Kilogram per hectare per year.

The National Atmospheric Deposition Program has monitoring stations across the United States to take 

wet deposition readings (National Atmospheric Deposition Program 2017). The National Atmospheric 

Deposition Program’s National Trends Network collects precipitation at locations near pollution sources 

and analyzes the liquid for concentrations of acid-forming ions. The nearest monitoring stations to the 

GMT2 Project area are University of Alaska-Fairbanks and United States Forest Service Poker Creek 

(NTN Site AK01), National Park Service Gates of the Arctic National Park (NTN Site AK06), and 

National Park Service Denali National Park (Site NTN AK03) (National Atmospheric Deposition 

Program 2017a). The Ambler Monitoring Station (NTN Site AK99) stopped collecting acid deposition 

data in 2005, and is therefore not referenced. Based on data collected from each of the stations, the annual 

average concentrations of ammonium, nitrate, and sulfate ions have decreasing trend lines, however have 

shown slight increases in recent years. Figure 4, Figure 5, and Figure 6 below show the recorded 

concentrations at each monitoring station with the trend lines below for NH4-, NO3- and SO42

- ions, 

respectively. The blue dots are concentrations for years where the weighted mean had valid samples 

where 75 percent of the year had valid concentration data, 90 percent of the annual precipitation had valid 

concentration data, and 75 percent of the precipitation data was accounted for in a year. Red dots are 

concentrations for years where the weighted mean did not meet the valid sample criteria. Trend lines in 

black are also shown on each graph where at least 3 years of valid data were available to create a trend. 
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Trend lines for ammonium, nitrate, and sulfate ions show that for Poker Creek and Gates of the Arctic 

National Park, recorded deposition at these locations are decreasing, whereas at Denali National Park, 

recent recordings of deposition are increasing. The acid deposition monitors are south and south-south 

west of the GMT2 Project area as shown in Figure 9 at the end of this section. Therefore, the transport of 

pollutants from the GMT2 Project may affect the acid deposition of these National Park Service units. 

 
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Figure 4. Ammonium ion wet deposition, Poker Creek (NTN AK01), Denali National Park (NTN AK03), and 

Gates of the Arctic National Park (NTN AK06)
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Figure 5. Nitrate ion wet deposition, Poker Creek (NTN AK01), Denali National Park (NTN AK03), and Gates of 

the Arctic National Park (NTN AK06)
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Figure 6. Sulfate ion wet deposition, Poker Creek (NTN AK01), Denali National Park (NTN AK03), and Gates of 

the Arctic National Park (NTN AK06)
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For dry deposition, the Clear Air Status and Trends Network logs flux data from monitoring stations 

across the country (EPA 2017a). Flux is the rate at which dry particles reach the ground. Flux is described 

in units of kilograms per hectare per hour (kg/ha-hr) for dry deposition. Clean Air Status and Trends 

Network logs fluxes to calculate a weekly average and then an annual average. 

The nearest three monitoring stations to the GMT2 Project area are at Poker Flats (Site ID POF425), 

Denali National Park (Site ID DEN427), and Kobuk Valley National Park (Site ID KVA428) (EPA 

2017a). The Poker Flats site stopped recording dry deposition fluxes in January 2004, and Kobuk Valley 

National Park stopped recording dry deposition fluxes in June 2005. The most robust data are from Denali 

National Park from 1998 through 2016. Sulfate ion dry deposition reached its maximum at 2.5 kg/ha-hr in 

2006. Nitrate ion dry deposition reached its maximum just below 2.0 kg/ha-hr in 2004, and ammonium 

ion dry deposition’s maximum was 1.4 kg/ha-hr in 2004. For all three ion fluxes, a fairly consistent trend 

has been recorded for the annual average throughout the recorded history. 

The Denali National Park monitor is south-south west of the GMT2 Project area as shown in Figure 9 at 

the end of this section. Therefore, the transport of pollutants from the GMT2 Project may affect the dry 

deposition of the Denali National Park dry deposition monitor.
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Figure 7. Sulfate ion, nitrate ion, ammonium ion dry deposition, Denali National Park (DEN427)
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3.2.3.5 Mercury Deposition

Another form of wet deposition is mercury deposition in precipitation. Mercury deposition is recorded as 

part of National Atmospheric Deposition Program in the Mercury Deposition Network. The nearest 

current station to the GMT2 Project area is the Gates of the Arctic National Park (MDN Site AK06). The 

station at Ambler, Alaska (MDN Site AK99), stopped collecting mercury deposition data in 2005. Most of 

the deposition recordings of mercury levels in the precipitation average below 50 nanograms per liter 

(ng/L) with random spikes in 2010, 2013, and 2015. The data recorded at MDN Site AK06 is below in 

Figure 8Figure 8 (National Atmospheric Deposition Program 2017b). The Gates of the Arctic National 

Park monitor is south of the GMT2 Project area as shown in Figure 9 at the end of this section. 

Figure 8. Mercury deposition, Gates of the Arctic National Park (MDN AK06)
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Figure 9. Monitoring data collection sites
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3.2.3.6 Acoustical Environment

This section draws from and updates previous descriptions of noise conditions in the project area in BLM 

(2004a, Section 3.2.3.3) and BLM (2014, Section 3.2.3.3). 

Overview

The acoustical environment is the combination of all sounds within a given area. These include natural 

sounds such as those caused by wildlife, blowing wind, and running water; as well as unwanted humancaused sounds that are considered noise because they have the potential to impact the natural acoustical 

environment and noise-sensitive resources and values. In the context of the proposed action, noisesensitive resources include wildlife, as well as people engaged in subsistence pursuits, recreation, and 

other activities.

The degree to which noise may cause disturbances to wildlife and human receptors is dependent on many 

factors. For example, wildlife responses to noise are known to vary by species; acoustical factors 

including the frequency, intensity (loudness), and duration of noise; as well as non-acoustical factors 

including life-history stage, environmental or behavioral context, and degree of past exposure (Francis 

and Barber 2013). Noise that is abrupt and unpredictable may be perceived as a threat, potentially 

triggering a startle response or antipredator behavior (Frid and Dill 2002; Francis and Barber 2013). 

Chronic noise may impact sensory capabilities via masking of biologically important natural sounds such 

as those used for communication or detection of predators or prey (Francis and Barber 2013). Similarly, 

human responses to noise also are contingent both on acoustical and non-acoustical factors. Among the 

non-acoustical factors are social context and perceived ability to exert control over the noise source 

(Kroesen et al. 2008; Stallen 1999). Impacts on noise-sensitive resources are discussed in Chapter 4 of the 

supplemental EIS. 

The spread (propagation) of sound in outdoor settings also is affected by many variables. These include 

distance from the source; weather (meteorological) conditions such as temperature, wind, and humidity; 

and landscape features and surface characteristics that may interfere with sound through absorption, 

reflection, or diffraction (Attenborough 2014). Among these, distance is the most significant factor. For a 

point source producing a constant sound level, sound levels expressed as decibels (dB) generally decrease 

(attenuate) by approximately 6 dB for each doubling of distance from the source. The same 6 dB 

attenuation with doubling distance holds for the maximum sound level produced by a single moving 

source (e.g., an aircraft in flight) when the source is at its closest point of approach to the receptor 

(Attenborough 2014). For a line of moving sources (e.g., vehicle traffic on a road), sound levels decrease 

by approximately 3 dB with doubling distance. When wind is present, sound attenuation with distance is 

less than expected in the downwind direction (i.e., downwind propagation is enhanced) and greater than 

expected in the upwind direction. Temperature inversions have the effect of reducing attenuation 

(enhancing propagation). In general, meteorological conditions tend to enhance sound levels to a lesser 

degree (e.g., 1 to 5 dB) than they attenuate sound levels (e.g., 5 to 20 dB) (Attenborough 2014). 

Existing noise sources in the project area include:

• Vehicle operations (vehicles, off-road vehicles, and snowmobiles) and community noise (generators 

and other small equipment motors) within the village of Nuiqsut; 

• Vehicles, off-road vehicles, and snowmobiles used for subsistence activities and travel among villages 

and between villages and subsistence camps;

• Firearms used to support subsistence activities;

• Blasting to facilitate mining of gravel deposits at the Arctic Slope Regional Corporation Colville 

River Consolidated Use Gravel Material Site; 
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• Motorized boat operations;

• Aircraft operations at Nuiqsut; 

• Vehicle and equipment operations at CD1, CD2, CD4, and CD5; 

• Aircraft operations into CD1; 

• Incidental aircraft and boat operations into the region by recreationists and scientific researchers; and

• Incidental aircraft operations transiting the project area.

Table 28 lists measured or estimated noise levels for noise sources similar to those existing in the project 

area, including noise estimates reported for a standardized distance of 1,000 feet from the source. Of 

current noise sources in the GMT2 Project area, blasting at the Arctic Slope Regional Corporation gravel 

mine is likely to generate the loudest noise events. Although no noise data for the gravel mine currently 

are available, blast noise attributable to explosive detonations can exceed 140 dB at a distance of 1,000 

feet from the source, depending on the size of charge and method of detonation (Pääkkönen 1991 (Table 

28). If this noise level is generated by blasts at the gravel mine, then associated peak noise levels received 

4.5-miles away in the village of Nuiqsut could be as high as 110 dB, assuming 6 dB attenuation with 

doubling of distance from the source and not accounting for effects of meteorological conditions or the 

presence of noise barriers. Other sources that have the potential to generate high noise levels sufficient for 

long-distance (beyond 5 miles) propagation include firearms used for subsistence hunting, drill rigs, and 

aircraft (Table 28). Noise generated by aircraft and other forms of motor vehicles generally is greatest 

during acceleration, but values reported for aircraft in Table 28 are for steady level flight rather than for 

acceleration phases such as take-off and climb-out. Additional information concerning the extent of 

aircraft noise in the project area is presented below.
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Table 28. Measured and estimated noise levels for noise sources similar to those existing in the GMT2 

Project area a

Noise Source

Noise 

Level 

(dBA)

Measurement 

Distance 

(feet) 

Estimated 

Noise 

Level at 

Standard 

1,000-foot 

Distance 

(dBA) a

Estimated 

Attenuation 

Distance to 

Standard 

Noise Level 

of 35 dBA 

(miles) a Measurement Details

Explosion (analog 

for gravel mine 

blasting) b

150 dB 328 dB 140.3 >25.0 c Mean of three peak noise-level 

measurements for groundsurface detonations of 500-g 

charge of explosive hexogen 

(RDX)

Hunting rifle 

(Remington 30-06) d

159.4 dB 3.3 dB 109.7 >25.0 c Mean of 24 peak noise-level 

measurements, 22-inch barrel 

length

Drill rig e 84.5 984 84.4 >25.0 c Maximum 1-sec noise level 

measured during 44-hour period 

with minimal wind

Drill rig e 52.5 984 52.4 1.4 Median 1-second noise level 

measured during 44-hour period 

with minimal wind

C-130 f 88.7 315 g 76.7 23.0 c, g Maximum 1-second noise level, 

estimated for level flight at 180 

knots

Helicopter (B206)h 66.7 1,000 g 66.7 7.3 c, g Maximum noise level, estimated 

for level flight at 160 knots

Single/twin-engine 

propeller aircraft 

(C207 & DHC6)h

65.2 1,000 g 65.2 6.1 c, g Maximum noise level, estimated 

for level flight at 160 knots

Construction 

equipment, 5 pieces 

operating 

simultaneously i

88.0 j 50 62.0 4.2 Maximum 1-second noise level

Construction 

equipment, 3 pieces 

operating 

simultaneously i

85.8 k 50 59.8 3.3 Maximum 1-second noise level

Construction 

equipment, 1 piece i

81.0 50 55.0 1.9 Maximum 1-second noise level

Two-stroke 

snowmobile l

79.1 50 53.1 1.5 Median of maximum noise level 

measured during 12 snowmobile 

pass-by events during full 

acceleration with average speed 

31.3 mph

4-wheel ORV m 78.5 50 52.5 1.4 Median noise level reported for 

eight models of off-road 

vehicles, with measurements 

conducted during four pass-by 

events per model with vehicles 

at full acceleration

Central 

gathering/processing 

facility with 

generator n

53.5 837 52.0 1.3 Maximum 1-second noise level 

measured during 16-hour period 

with minimal wind
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Noise Source

Noise 

Level 

(dBA)

Measurement 

Distance 

(feet)

Estimated 

Noise 

Level at 

Standard 

1,000-foot 

Distance 

(dBA) a

Estimated 

Attenuation 

Distance to 

Standard 

Noise Level 

of 35 dBA 

(miles) a Measurement Details

Central 

gathering/processing 

facility with 

generator n

37.4 837 35.9 0.2 Median 1-second noise level 

measured during 16-hour period 

with minimal wind

Pickup truck o 75.0 50 49.0 0.9 Maximum 1-second noise level, 

one measurement

Four-stroke 

snowmobile l

72.7 50 46.7 0.7 Median of maximum noise level 

measured during 24 snowmobile 

pass-by events during full 

acceleration with average speed 

27.4 mph

a Noise levels are reported in A-weighted decibels (dBA) unless otherwise noted. The table also includes estimated noise levels at a 

standard distance of 1,000 feet from the source and estimated distances for noise attenuation to a standard noise level of 35 dBA. 

These estimates assume noise attenuation of 6 dBA per doubling of distance from source and do not account for potential effects of 

meteorological conditions, sound barriers, and landscape characteristics. Noise sources are sorted in descending order by the 

estimated maximum noise level received at a standard 1,000-foot distance from the source.

b Pääkkönen (1991).

c Actual noise levels received at large distances can vary considerably due to meteorological conditions.

d Flamme et al. (2011).

e Ambrose and Florian (2014), site PAPA208.

f U.S. Army Corps of Engineers (2004, Appendix H); noise levels at 315 feet and 1,000 feet were estimated using the U.S. Air Force 

OMEGA10R noise model.

g Slant distance, defined as the line-of-sight distance from the noise receptor to the airborne aircraft. 

h Miller et al. (2003), 1,000-ft noise level estimated using the Federal Aviation Administration’s Integrated Noise Model.

i Construction noise estimates are based on the median value (81.0 dBA at 50 ft) reported for noise emissions from 49 generic types 

of construction equipment in USDOT (2006).

j Aggregate noise level resulting from simultaneous operation of 5 pieces of equipment each emitting 81.0 dBA measured at 50 feet.

k Aggregate noise level resulting from simultaneous operation of 3 pieces of equipment each emitting 81.0 dBA measured at 50 feet.

l Menge et al. (2002).

m Martin et al. (2005).

n Ambrose and Florian (2014), site PAPA206.

o USDOT (2006).

Results of Passive Acoustic Monitoring

During summer 2016, researchers from the University of Alaska-Fairbanks (Stinchcomb and Brinkman, 

unpublished data) collected audio recordings and sound-level data at 20 sites located near Nuiqsut and 

along the Fish Creek and Colville River drainages in conjunction with a passive acoustic monitoring 

project. Four of the 20 sites were located within the delineated GMT2 Project area. Objectives of this 

research were to quantify natural ambient sound levels and human-caused noise attributable to aircraft 

activities in the area, and to establish baseline acoustic conditions for purposes of future monitoring. 

Below, we use these data to further describe the existing acoustical environment in the passive acoustic 

monitoring study area. A description of research methods and a map showing study site locations are 

included in Appendix C. 

Natural Acoustical Environment 

Table 29 summarizes information about study sites and results of the 2016 Passive Acoustic Monitoring 

Project. Natural ambient sound levels, characterized as the median sound level (Median Lnat dBA) 

measured during periods without detectable aircraft noise, ranged from 25.3 dBA to 47.3 dBA at 16 sites 
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where human-caused noise was attributable primarily to aircraft activities. The loudest natural ambient 

sound levels were recorded at a windy site (site name U.S. Geological Survey) located in the Colville 

River Delta near the coast. The average for these 16 sites was 35.4 dBA, which is similar to the average 

wind-free natural ambient sound level (32 dBA) measured near the Kuparuk Oil Field during studies 

conducted in 1985 and 1986 (Hampton et al. 1988), but higher than median sound levels measured in 

2010 during baseline acoustical monitoring at a coastal plain location approximately 9 miles inland from 

the coast and 3 miles west of the Canning River where noise from human activities was generally absent 

(U.S. Army Corps of Engineers 2012). This baseline monitoring effort, which was conducted to support 

noise analysis for the Point Thomson Project (U.S. Army Corps of Engineers 2012), recorded hourly 

median sound levels of 23 to 28 dBA during winter conditions (27 April–8 June) and 24–26 dBA during 

summer conditions (12 July–12 August).
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Table 29. Study site information and characteristics of aircraft noise events recorded during the 2016 Passive Acoustic Monitoring Projecta

Site Name

Latitude

(degrees 

N)

Longitude 

(degrees 

W)

Distance 

to 

Nuiqsut 

(miles)

Length of 

Recording 

Period 

(days)

Median 

Lnat

b

(dBA)

Total 

Aircraft 

Noise 

Events

Median 

Aircraft 

Noise 

Events 

per Day

Maximum 

Aircraft 

Noise 

Events 

per Day

Heli 

Eventse

(% of 

total 

events)

Prop 

Eventse

(% of 

total 

events)

Jet 

Eventse

(% of 

total 

events)

Unknown 

Eventse

(% of 

total 

events)

NIGLIQ1 70.242 151.000 1.6 38 35.5 c 565 14 35 3.4 72.9 23.5 0.2

ICERD 70.237 150.826 4.1 84 36.2 c 1,090 11.5 40 13.9 66.2 19.4 0.6

ITKILLIK1 70.152 150.955 4.7 84 40.3 818 8 42 5.7 54.9 39.4 0.0

NIGLIQ2 70.331 151.081 8.0 84 33.8 c 940 11 40 22.3 60.0 17.2 0.4

ITKILLIK2 70.106 150.837 8.5 54 25.3 408 6 37 8.3 37.3 54.4 0.0

FSHCK2 70.273 151.686 8.9 5 40.2 15 3.5 6 13.3 46.7 40.0 0.0

CLVL2 70.074 151.066 10.0 76 36.3 553 6 23 6.5 42.5 48.8 2.2

CD3 70.332 150.715 10.1 83 40.2 985 12 37 10.3 77.5 10.8 1.5

FSHCK1 70.316 151.486 12.0 23 35.0 145 7 36 11.7 53.1 35.2 0.0

FSHCK3 69.714 151.508 13.6 29 32.9 217 8 18 5.5 58.1 36.4 0.0

OCNPT 70.072 151.382 13.7 66 37.8 288 4 13 6.3 40.3 53.1 0.3

FSHCK4 69.637 151.435 17.0 15 33.1 124 7 15 4.8 47.6 47.6 0.0

USGS 70.464 150.756 17.5 80 47.4 574 7 22 7.1 70.2 22.1 0.5

CLVL4 70.000 151.593 20.8 51 31.4 114 3 8 16.7 40.4 43.0 0.0

CLVL5 69.894 151.566 26.2 84 33.9 77 1 13 23.4 62.3 14.3 0.0

UMIRUK 69.796 151.565 32.0 32 28.9 16 1 2 0.0 100.0 0.0 0.0

ROCKY 69.546 151.454 36.7 33 30.8 31 1 3 3.2 96.8 0.0 0.0

SHORTY 69.361 152.123 41.1 21 35.3 18 1 3 11.1 88.9 0.0 0.0

ANKTVK 70.360 151.292 47.3 21 37.7 21 2 6 23.8 71.4 4.8 0.0

UMIAT 70.297 151.288 65.4 41 35.6 c 466 9.5 62 30.7 62.4 4.7 2.1

Average N/A N/A N/A 35.4 d 6.2 23.1 11.4% 62.5% 25.7% 0.4%

a Study sites are sorted by distance to Nuiqsut; sites NIGLIQ1, ICRD, NIGLIQ2, and FSHCK2 are located in the delineated GMT2 Project area and are indicated in bold print. Data are 

from Stinchcomb and Brinkman (unpublished data). 

b Median Lnat is the median sound level that was measured at study sites in the absence of audible aircraft noise, and is assumed to represent the natural ambient sound level. 

c Measured sound level includes ambient noise attributable to human sources other than aircraft.

d Excludes four sites where measured sound levels include ambient noise attributable to human sources other than aircraft.

e Percentages of total aircraft noise events that were attributable to helicopters (Heli), propeller aircraft (Prop), jets (Jet), or unknown (Unk) sources. 
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Aircraft Noise

Aircraft noise is common in and near the GMT2 Project area. Aspects of aircraft noise are characterized 

as follows based on aircraft noise events measured during the 2016 Passive Acoustic Monitoring Project. 

For analysis purposes, an aircraft noise “event” is defined as an aircraft sound signature measured from 

the time it becomes audible in a sound recording to the time when the aircraft sound fades from audibility 

(see Appendix C). A single event does not necessarily equate to an individual aircraft, as multiple events 

may be caused by the same aircraft passing over the same site at different times or by the same aircraft 

passing over different sites. 

In 2016, aircraft-related noise varied widely among study sites, especially in terms of the typical number 

of noise events detected on a daily basis (Table 29). For all sites combined, the median number of daily 

events ranged from 1 to 14, and the maximum number of daily events ranged from 2 to 62, with the 

lowest numbers of daily events generally occurring at sites distant from Nuiqsut (excluding Umiat) and 

the highest number of daily events occurring at sites relatively close to Nuiqsut and the Colville Delta 

area. At all sites, fewer aircraft events were attributable to helicopters (11.4 percent of total events, on 

average) than to propeller aircraft (62.5 percent of total events, on average) over the course of the study. 

Across the 20 study sites, the median duration of discrete aircraft noise events ranged from 1.9 minutes to 

5.5 minutes, and the maximum duration ranged from 5.8 minutes to 30.3 minutes (Table 30).

In addition to the number and duration of discrete events per day, aircraft noise events can be 

characterized on the basis of maximum loudness, or Lmax, defined as the maximum 1-second sound level 

(dBA) measured during the noise event. On the basis of this metric, noise levels measured during 

helicopter events in 2016 tended to be greater than levels measured during propeller aircraft events and jet 

aircraft events. Across study sites, the median Lmax ranged from 44.6 dBA to 72.9 dBA for helicopter 

events, from 40.9 dBA to 58.8 dBA for propeller aircraft events, and from 38.0 dBA to 52.6 dBA for jet 

aircraft events (Table 31). The maximum Lmax measured at study sites ranged from 66.8 dBA to 94.0 

dBA for helicopter events, from 59.4 dBA to 88.9 dBA for propeller aircraft events, and from 40.3 dBA to 

77.3 dBA for jet aircraft events. Although maximum noise levels attributable to helicopters tended to be 

greater than those attributable to propeller aircraft, it is nevertheless reasonable to conclude from data 

currently available that propeller aircraft generated more noise and thus greater impacts on the acoustical 

environment in the project area during summer 2016 because of the greater frequency of propeller aircraft 

noise events relative to helicopter noise events.
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Table 30. Duration of aircraft noise events measured at study sites during the 2016 Passive Acoustic 

Monitoring Project a

Site Name Distance to Nuiqsut 

(miles)

Median Event Duration 

(minutes)

Maximum Event Duration 

(minutes)

NIGLIQ1 1.6 2.5 15.6

ICERD 4.1 2.3 29.5

ITKILLIK1 4.7 2.1 19.7

NIGLIQ2 8.0 2.3 27.4

ITKILLIK2 8.5 2.4 17.8

FSHCK2 8.9 1.9 9.2

CLVL2 10.0 2.5 22.8

CD3 10.1 2.7 23.8

FSHCK1 12.0 2.2 7.7

FSHCK3 13.6 2.4 12.9

OCNPT 13.7 2.4 20.6

FSHCK4 17.0 2.6 25.5

USGS 17.5 2.8 33.0

CLVL4 20.8 2.7 23.1

CLVL5 26.2 3.4 9.2

UMIRUK 32.0 3.9 5.8

ROCKY 36.7 5.5 12.1

SHORTY 41.1 3.6 7.6

ANKTVK 47.3 3.3 10.3

UMIAT 65.4 3.0 30.3

Average N/A 2.8 18.2

a Study sites are sorted by distance to Nuiqsut; sites NIGLIQ1, ICRD, NIGLIQ2, and FSHCK2 are located in the delineated GMT2 

Project area and are indicated in bold print. Data are from Stinchcomb and Brinkman (unpublished data).
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Table 31. Maximum levels of aircraft noise recorded during the 2016 Passive Acoustic Monitoring Project a

Site Name

Distance to 

Nuiqsut 

(miles)

Heli Median 

Lmax (dBA)

Prop Median 

Lmax (dBA)

Jet Median 

Lmax (dBA)

Unk Median 

Lmax (dBA)

Heli 

Maximum 

Lmax (dBA)

Prop 

Maximum 

Lmax (dBA)

Jet 

Maximum 

Lmax (dBA)

Unk 

Maximum 

Lmax (dBA)

NIGLIQ1 1.6 56.3 56.3 51.7 56.6 72.8 83.6 70.2 56.6

ICERD 4.1 56.8 52.1 43.0 63.8 84.9 79.7 66.0 71.4

ITKILLIK1 4.7 61.6 51.3 52.6 -- 92.0 88.9 77.3 --

NIGLIQ2 8.0 52.7 46.9 49.4 44.8 82.8 85.8 65.0 51.7

ITKILLIK2 8.5 47.4 41.6 43.5 -- 68.4 63.0 62.8 --

FSHCK2 8.9 63.1 50.5 41.9 -- 78.5 59.4 57.5 --

CLVL2 10.0 53.9 47.3 46.2 50.2 87.7 84.2 67.4 68.7

CD3 10.1 48.8 58.8 48.2 78.2 74.6 87.2 70.7 88.8

FSHCK1 12.0 57.4 44.4 43.4 -- 77.7 63.1 58.1 --

FSHCK3 13.6 49.8 52.0 45.5 -- 66.8 73.7 59.9 --

OCNPT 13.7 56.6 44.8 44.5 50.5 80.8 75.7 72.8 50.5

FSHCK4 17.0 47.8 48.1 47.7 -- 68.8 62.0 61.0 --

USGS 17.5 44.6 47.5 43.8 36.1 83.4 83.5 59.7 47.9

CLVL4 20.8 56.1 47.8 40.9 -- 90.6 65.6 63.9 --

CLVL5 26.2 53.4 40.9 38.0 -- 94.0 63.1 54.5 --

UMIRUK 32.0 -- 48.8 -- -- -- 73.1 -- --

ROCKY 36.7 70.2 46.5 -- -- 70.2 62.6 -- --

SHORTY 41.1 72.9 52.6 -- -- 80.1 57.3 -- --

ANKTVK 47.3 61.0 47.3 40.3 -- 72.5 80.8 40.3 --

UMIAT 65.4 60.4 54.5 42.3 54.1 82.3 83.7 56.5 59.4

Average N/A 56.4 49.0 44.9 54.3 79.4 73.8 62.6 61.9

a Lmax is defined here as the maximum 1-second sound level measured during an aircraft noise event, and Median Lmax is the median Lmax for all helicopter (Heli) noise events, 

propeller (Prop) noise events, jet (Jet) noise events, and unknown-source (Unk) noise events. Maximum Lmax is the maximum Lmax that was recorded for all noise events attributable 

to a particular aircraft type over the course of the study. Study sites are sorted by distance to Nuiqsut; sites NIGLIQ1, ICRD, NIGLIQ2, and FSHCK2 are located in the delineated 

GMT2 Project area and are indicated in bold print. Data are from Stinchcomb and Brinkman (unpublished data).
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3.2.4 Climate Change

Climate change impacts to resources in the project study area remain essentially as described in BLM 

(2014, Section 3.2.4). Supplemental information is taken from recent reviews of this subject including the 

Third National Climate Assessment-Alaska (Chapin et al. 2014) and the Arctic Report Card 2016 

(Richter-Menge et al. 2016). 

3.2.4.1 Climate Change in the Arctic

Climate trends in the Arctic remain essentially as described in BLM (2014, Section 3.2.4.1). The global 

warming trend of the past 50 years has been amplified in the Arctic. Positive feedback loops resulting 

from reduced overall surface reflectivity in the summer have increased the heat retention capacity of the 

Arctic system, which enables more melting (BLM 2014). The increased melting of snow and ice cover 

leads to increased thawing of permafrost and earlier greening of the tundra (Richter-Menge et al. 2016). 

Thawing permafrost releases carbon into the atmosphere in the form of carbon dioxide and methane, 

whereas increased vegetation growth pulls carbon dioxide out of the atmosphere. Overall, tundra in the 

Arctic is releasing net carbon into the atmosphere (Richter-Menge et al. 2016). 

Arctic air temperatures have increased at double the rate of global temperature increases. The average 

surface air temperature for the year ending September 2016 was by far the highest since 1900, and 

represents a 2 oC increase relative to the 1981–2010 baseline. Minimum sea ice extent at the end of the 

summer of 2016 was tied with 2007 as the second lowest sea ice cover in the satellite record. Spring snow 

cover extent in the North American Arctic was the lowest on the satellite record (Richter-Menge et al. 

2016). These observations show a continuation of the persistent warming trend occurring in the Arctic.

3.2.4.2 Climate Change on the North Slope

The North Slope experiences the same climate trends as the Arctic as a whole, including increased 

average temperatures, thawing of permafrost, expanded growing season and decreases in sea ice and snow 

cover extent (Walsh et al. 2014). Tundra travel open season on the North Slope decreased from 

approximately 200 days in 1969 to approximately 120 days in 2004 as a result of regulatory changes, a 

warming climate and methods for measuring frost depth (North Slope Borough Oil and Gas Technical 

Report 2014). Tundra travel season is likely to continue to shorten in response to rising average 

temperatures and changes in precipitation patterns on the North Slope. 

Precipitation on the North Slope is projected to increase in both summer and winter, while snow cover 

duration is expected to drop (BLM 2014). Projections for snowfall include a later date of first snowfall 

and an earlier snowmelt (BLM 2014). 

3.2.4.3 Potential Climate Change Impacts in the Project Study Area

Potential climate change impacts in the project study area remain essentially as described in BLM 2014, 

Section 3.2.4.3, and are summarized as follows. 

The project study area is located within the Arctic Coastal Plain and is dominated by features and 

processes driven by permafrost. The project study area is underlain by continuous permafrost, which on 

the North Slope ranges from depths of about 650 feet to more than 2,000 feet. During the Arctic summer, 

solar radiation thaws a shallow layer of soil at the surface, creating a seasonally unfrozen zone termed the 

active layer. Recent modeling predicted a broad range of future permafrost states due to differences in 

future greenhouse gas emission and climate scenarios; however, permafrost extent is predicted to decrease 

significantly by 2100 (Slater and Lawrence 2013). There are predictions that climate change will continue 

to warm and dry the NPR-A region more than historically recorded ranges; however, warmer 
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temperatures are not likely to accelerate the soil forming processes significantly enough to measure the 

change during the period of construction and operations addressed in this supplemental EIS (BLM 2014, 

Section 3.2.4.3, page 121). 

Structurally, the increase in the depth of the active layer is expected to have a negative effect on the 

ability of the soils to carry loads. Any traffic over the surface during non-frozen periods would be 

expected to create more damage than under the present conditions. This could result in deep ruts and 

severe channeling of water into the vehicle tracks. Such concentration of water would be likely to 

accelerate erosion and create new drainage channels that drain water from the surrounding areas. It also 

would be likely to accelerate the subsidence of the permafrost in the track areas. Similar subsidence has 

been observed in tracks from early exploration of the region in the 1960s in many other areas of the 

tundra (BLM 2012, Section 3.2.8.4, page 190). Due to the exacerbation of climate change, subsidence 

may occur over a broader area than solely in those areas which are directly impacted by vehicle traffic 

(Shiklomanov et al. 2013). Overland tundra travel by vehicles is restricted on unfrozen ground in the 

NPR-A.

As the active layer deepens, there are more opportunities for plants to send roots deeper into the profile. 

This may allow plant communities to begin migrating further north within their ranges. The overall result 

of climate change on vegetation appears to be that growing season will be longer, and soils will be 

warmer and actually drier. These differences have the potential to drive significant changes in plant 

communities of the NPR-A, leading to significant acreages of boreal cordillera, with vegetative cover 

ranging from open to closed forest canopies; western tundra, which is similar but with a moist, sub-polar 

climate, patches of stunted trees, and a greater presence of tall shrub communities; and boreal transition 

with boreal forests in valleys and lowlands, and scattered pockets of permafrost. These changes in 

vegetation will promote soil formation through greater root development and contribution of additional 

organic matter to the soil profile (BLM 2014, Section 3.2.4.3, page 122). 

A number of hydrologic shifts related to climate change will affect water resources, including seasonal 

flow patterns, ice-cover thickness and duration, and the frequency and severity of extreme flood events. 

The effects of these climatic and hydrologic changes will result in river systems that increasingly move or 

migrate over the landscape compared to a period of relatively stable climate, which may cause disruptions 

to infrastructure (such as roads and bridges), changes in fish and wildlife habitat, and possible hazards to 

shoreline communities, fish camps, and recreational users (BLM 2012, Section 3.2.10.5, page 201). 

Warmer temperatures will advance the spring warming period, which means that snowmelt will occur 

during a period of lower solar radiation, which could lead to a more protracted melt and less intense 

runoff. The effects of early and less intense spring melt will be most dramatic for catchments within the 

Arctic Coastal Plain, where snowmelt forms the major flow event of the year. Overall, the magnitude and 

frequency of high flows will decline while low flows will increase, thereby flattening the annual 

hydrograph (BLM 2014, Section 3.2.4.3, page 123). 

Suspended sediment and nutrient loading of lakes and rivers will increase as thermokarsting, land 

subsidence, slumping, and landslides increase with permafrost degradation. With expected warming, 

degrading ice wedges may progressively integrate into drainage channels with a lower base elevation 

resulting in increased frequency of lake-tapping (sudden drainage) events. Drainage rates of lakes on the 

entire North Slope, in cold continuous permafrost, were found to be one to two lakes per year, but will 

likely increase in frequency (BLM 2014, Section 3.2.4.3, page 123). 

Increasing mean air temperatures during the winter and summer will lead to increasing mean water 

temperatures which may affect Arctic fish species; however, the precise effect that warmer water 

temperatures could have on Arctic fish is complicated and difficult to predict (BLM 2014, Section 3.2.4.3, 

page 122). 
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Bird habitats worldwide are threatened by climate change, though species for which breeding is restricted 

to the Arctic regions may be the most vulnerable to climate change. The abundance and distribution of 

surface water is of crucial importance to Arctic birds as the aquatic and semi-aquatic habitats of the 

planning area support very large numbers of birds. Increased summer temperatures could lead to the 

conversion of aquatic habitats into dryer habitat types resulting in a loss of not only habitat quantity but 

also habitat quality in terms of potential decrease in food resources (invertebrate and plant). This loss of 

quantity and quality would likely lead to changes in bird distributions which might in turn lead to 

increased competition for limited resources and associated decreases in productivity (BLM 2012, Section 

3.3.5.9, page 279). 

Climate change is predicted to cause alterations to the environment and habitats of the project study area 

that could adversely affect paleontological resources, although the degree to which this might happen 

remains unclear. Mass wasting due to future climate change could result in the partial or total destruction 

of paleontological sites located on hillsides, bluff faces, river banks and terraces, and a warming climate 

may lead to more rapid decomposition of paleontological resources. On the other hand, erosion has 

exposed most of the known paleontological deposits in the NPR-A, an impact that is viewed as more 

positive than negative as it reveals the presence of sites usually with few negative results. The potential 

climate change impacts are not expected to be universal across the Arctic Coastal Plain as there are 

myriad factors that control the degree to which climate change can affect a specific location, region, 

habitat or ecosystem (BLM 2012, Section 3.2.7.2., page 183). 

Cultural resources are susceptible to the same climate change effects related to erosion and mass wasting 

as discussed above for paleontological resources. As is the case for paleontological remains, organic 

cultural artifacts are susceptible to increased decay in a warming environment. Artifacts in the project 

study area were encased in permafrost long ago, preventing them from further decay. Permanently frozen 

ground has played a key role in preserving organic artifacts, including tools, artwork, clothing, shelters, 

etc., made from plant and animal materials, and animal and plant remains that can be used to identify 

which species were hunted and gathered and how and when they were used. In addition to increased 

downslope movement and erosion, thawing permafrost will incorporate whole sites into the active layer, 

exposing subsurface artifacts and features to cryoturbation (frost mixing). Permafrost has helped to 

maintain the spatial relationships between artifacts by preserving the vertical sequence in which past 

people left them behind; i.e., in a naturally buried deposit, older artifacts will be found deeper than 

younger artifacts. As more artifacts become incorporated into the active layer, they are more susceptible 

to disturbance, increasing the likelihood that different cultural levels will become mixed. Younger 

materials can move downwards via seasonal frost cracking and older artifacts can be pushed upwards by 

frost heaving and sorting, ice wedging, and involutions (BLM 2012, Section 3.4.2.3., page 382; French 

2007; Washburn 1980; Wood and Johnson 1978). 

Climate change will not affect the existence or location of the mineral material deposits within the project 

study area; however, it may impact the ability of industry to access those resources. Gravel mining in the 

project study area involves the use of ice roads, snow trails, and ice pads for transportation of equipment 

to and from the material source, usually during the exploration and mine development phase. Depending 

on the type of material and the mining method used to extract that material, a changing climate could 

make the excavation easier, due to the melting of the permafrost, or more difficult when attempting to 

develop deposits in areas with melted permafrost, which may necessitate removing water, or the need to 

excavate in swampy conditions (BLM, 2014, Section 3.2.4.3, page 124). 

Research regarding the combined effects of climate change and built infrastructure in the Prudhoe Bay 

area indicates that human-made structures such as gravel roads and pads can contribute to and exacerbate 

thermokarsting of ice-rich tundra adjacent to the constructed feature (Walker et al. 2014). Using aerial 

photos and GIS, the research found that thermokarst has affected broad areas of the entire region, with a 

noticeable increase from 1990-2011 that corresponds with a comparable rise in regional summer air and 
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permafrost temperatures. The observed features resulting from the climate-driven thermokarst activity 

include: more abundant small ponds, greater microrelief, more active lakeshore erosion, and increased 

landscape and habitat heterogeneity. The research also showed that infrastructure resulted in an increase 

in linear “flooding” resulting from roads or gravel pads producing runoff and concentrating spring flow 

(Walker et al. 2014, page 8), and that road dust in high concentrations adjacent to the heavily traveled 

roads killed vegetation, especially low-growing mosses and lichens, which decreased the insulative active 

layer of the tundra (ibid). Both an increase in standing water and decrease in the active layer, combined 

with the increase in air and soil temperatures, led to the increase in thermokarst features adjacent to 

infrastructure.

3.3 Biological Resources

The following description of biological resources of the project study area is structured and organized to 

match BLM (2004a) and BLM (2014). The biological environment remains essentially as described in the 

2004 Alpine Satellite Development Plan EIS and the 2014 GMT1 Supplemental EIS. 

3.3.1 Vegetation and Wetlands

Vegetation and wetlands are described for the entire NPR-A in BLM (2012), and for much of the GMT2 

Project area in BLM (2004a) and BLM (2014). The location of the project area in the NPR-A is shown in 

Map 3.1-1. Additional information is also provided for the Northeast NPR-A (including the GMT2 

Project area) in BLM (2008a).

A summary of the prior assessments, which focuses on the conditions within the project area and at the 

proposed project facilities, is presented along with new information relevant to this resource. A project 

area is incorporated that defines a geographic extent of all the action alternatives and allows for a defined 

area for detailed evaluation. The project area was selected to include all major project components of the 

proposed GMT2 Project and alternatives as well as where supporting activities may be located, as 

described in Section 3.1.1.

3.3.1.1 Summary of Vegetation and Wetland Types

A summary of vegetation and wetland types occurring within the bounds of the project area is provided in 

Table 32.
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Table 32. Summary of vegetation and wetland types in the project area

Vegetation Type Wetland Type a

Acres of 

Vegetation 

Type in 

Mapped 

Project Area b

Vegetation 

Type as % of 

Total Mapped 

Project Area c

Natural Barrend Upland, E2US3P 4,590 3.2%

Human Modified Barrene Upland 456 0.3%

Brackish Water E2USH 354 0.2%

Cassiope Dwarf Shrub Tundra PSS3B, Upland 241 0.2%

Closed Low Willow PSS1B, PSS1C 2,489 1.7%

Coastal Complex E2EM1/USP 3 0.0%*

Deep Polygon Complex PUBH, PEM2H, PEM1F, 

PEM1/SS1B 823 0.6%

Dryas Dwarf Shrub Tundra Upland, PSS3B 371 0.3%

Dune Complexd Upland, PEM1B, PEM1/SS1B, 

PSS1B 25 0.0%*

Elymus Meadow Upland 23 0.0%*

Fresh Grass Marsh PEM1H, R2AB3H, L1AB3H 524 0.4%

Fresh Sedge Marsh PEM1H 1,781 1.2%

Fresh Water PUBH, R2UBH, L1UBH 27,181 18.8%

Halophytic Grass 

Brackish

Wet Meadow, PEM1R 328 0.2%

Halophytic Sedge Wet Meadow, 

Brackish PEM1R 240 0.2%

Halophytic Willow-Graminoid 

Dwarf Shrub Tundra E2SS1/EM1P, E2SS1P 150 0.1%

Moist Sedge-Shrub Tundra PEM1/SS1B, PEM1/SS1E 23,684 16.4%

Old Basin (Ice Rich) Wetland Complex PEM1F, PUBH, PEM1B, PEM1H, 

PEM1/SS1E 10,031 6.9%

Open Low Willow PSS1B 3,867 2.7%

Open Low Willow-Sedge Shrub Tundra PSS1B 636 0.4%

Open Tall Willow PSS1B, PSS1C 86 0.1%

Partially Vegetated PUSR, PUSC, Upland 1,407 1.0%

Riverine Complex R2UBH, R2AB3H, PEM1F 411 0.3%

Salt-killed Wet Meadow E2US4P 2 0.0%*

Seral Herbs PEM1A 54 0.0%*

Tussock Tundra PEM1/SS1B, PEM1/SS1E 29,908 20.7%

Wet Sedge Meadow Tundra PEM1F 32,675 22.6%

Wet Sedge-Willow Tundra PEM1F 1,892 1.3%

Young Basin (Ice Poor) 

Complex

Wetland PUBH, PEM2H, PEM1H, 

PEM1/SS1B, PEM1B 559 0.4%

Total Mapped Project Area 144,800f 100%

Unmapped Area Not determined 10,700f N/A

Total Project Area 155,500f N/A

Note: Total acreage and percentages may not reflect the sum of the individual cells due to rounding.

a Wetland types assigned based on typical conditions expected to occur in the GMT2 project area. Crosswalk from vegetation type to wetlands 

type is based upon comparisons to vegetation type in Jorgenson et al. (2004) for the broad range of plant communities within the GMT2 project 

area. Wetland types shown as National Wetlands Inventory codes based on Cowardin et el. (1979).

b Acreage of each vegetation type is rounded to the nearest 1 acre.

c Percent of vegetation type within the total mapped project area. Values that are greater than 0 but less than 0.1 percent are noted with an asterisk 

(0.0%*). Percentages are rounded to the nearest tenth. Note that the unmapped portion of project area, 10,700 acres, extends outside of the 

vegetation map coverage. 

d Wetland status interpreted as upland based on aerial imagery.

e Human Modified Barrens are areas where gravel fill has been placed and have a different biological function than Natural Barrens.

f This acreage has been rounded to the nearest 100 acres.
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Key points about vegetation and wetlands in the project area include: 

• The vegetation communities of the project area are dominated by Wet Sedge Meadow Tundra, 

Tussock Tundra, Fresh Water (ponds and lakes), and Moist Sedge-Shrub Tundra; all of these are 

potential jurisdictional wetlands that are regulated under the Clean Water Act.

• The sedge species that dominate the vegetated landscape are tolerant of cold soil and high-moisture 

conditions. The vegetation canopy is low and individual plants are mostly less than 1-foot tall.

• A shallow active-layer (soils unfrozen only during the short growing season) in which Arctic flora can 

grow are underlain by permafrost in the project area. Short growing seasons, cold soil temperatures, 

and low decomposition rates influence the type of vegetation that can survive the Arctic climate of the 

project area.

The vegetation classification used in this analysis is the same used in BLM (2004a) and BLM (2014). 

Descriptions of the classifications of habitat, vegetation, and geomorphology are provided in Jorgenson et 

al. (2004) and Wells et al. (2014). Further information on vegetation and wetlands for the NPR-A is 

provided in BLM (2008a) and BLM (2012). A vegetation map of the project area is presented in Map 3.3-

1. Twenty-eight vegetation types occur within the project area, as listed previously in Table 32. The 

vegetation types most commonly found in the project area typically meet the criteria for jurisdictional 

wetlands and waters based on Section 404 of the Clean Water Act. While wetlands and waters account for 

the majority of land cover, non-wetlands (uplands) are also present. Of the mapped area, wetlands occupy 

the most land area (approximately 77 percent), followed by water (approximately 19 percent), and 

uplands (approximately 3 percent) as shown in Table 32. When a vegetation type could be wetland or 

upland (based onsite-specific conditions), it is assumed to be wetland for this analysis. Thus, the listed 

acreages of wetlands in the study area may overestimate the total occurrence. The vegetation types, 

National Wetlands Inventory classifications, and descriptions are further discussed in Davis (2013).

Areas not classified as waterbodies or wetlands are considered uplands or Natural Barrens. These areas 

occupy just over 3 percent of the project area as shown in Table 32and include sand dunes and gravel 

islands in the Colville River. Gravel fill in the GMT2 Project area includes the community of Nuiqsut, the 

Arctic Slope Regional Corporation Mine site (initial phase only), Alpine Processing Facility/CD1, CD2, 

CD4, the Nuiqsut Spur Road, but does not include more recent gravel fill from CD5, Phase 3 of the Arctic 

Slope Regional Corporation Mine site and the CD5–GMT1 Road (not present when vegetation was 

mapped). These areas of Human Modified Barrens occupies 455 acres and is 0.3 percent of the mapped 

project area (Table 32).

Waterbodies include areas of open water such as lakes, ponds, streams, and rivers. For information about 

waterbodies in the study area, see Section 3.2.2, “Water Resources.” 

The dominant vegetation types in the mapped portion of the study area include Wet Sedge Meadow 

Tundra (23 percent), Tussock Tundra (21 percent), and Moist Sedge-Shrub Tundra (16 percent), with 

Waterbodies mapped at 19 percent cover. Wet tundra is dominated by wet/moist sedges and dwarf shrubs, 

and occupies wet environments such as drained-lake basins and poorly drained river terraces. Sedges 

(e.g., Carex spp.) dominate this tundra type. Small intermixed patches of aquatic sedges and grasses may 

occur in flooded areas. Large complexes of wet and moist tundra occur, with interspersed areas of open 

water. Wet tundra is generally characterized under National Wetlands Inventory notation as emergent 

sedge or grass wetland (e.g., PEM1F), with a water regime of semi-permanently flooded. Moist tundra is 

characterized in the National Wetlands Inventory classification system as saturated wetland, dominated by 

scrub-shrub and emergent vegetation (e.g., PSS1/EM1B). 

Areas of mixed moist and wet tundra occur in the drier parts of drained-lake basins and on poorly drained 

river terraces. Patterned ground is widespread and moist sedges and dwarf shrubs dominate areas with 
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better drainage. Wet sedges dominate lower areas and aquatic sedges and grasses may occur in flooded 

areas. Mixed high and low centered polygons with extensive thermokarst troughs are interspersed with 

lakes and ponds. High centered polygons may be dominated by dry, dwarf shrubs and fruticose lichens. 

Moist/wet tundra complexes are generally characterized under National Wetlands Inventory notation as 

saturated or inundated emergent and scrub-shrub wetland, with water regimes ranging from seasonally 

saturated to permanently flooded. As mapped, just over 3 percent of the study area is upland (nonwetland), consisting of barren ground and Dryas Dwarf-Shrub Tundra (Table 32), while 0.3 percent of the 

study area consists of human modified areas where gravel was extracted from or placed on existing 

vegetation.

There are no plant species listed under the Endangered Species Act nor as BLM Sensitive Species known 

to occur within the GMT2 Project area as discussed in Appendix F of the 2012 Final NPR-A Integrated 

Activity Plan EIS.

3.3.1.2 Invasive Plant Species

Non-native, invasive plant species occurrence in the NPR-A is discussed in BLM (2012). In summary, 

there is evidence that non-native, invasive plant species have the potential to spread into the mid- and 

lower-latitude regions of the NPR-A. However, the higher-latitude regions which include the project area 

are considered to be invasion resistant due to the short growing season compared to that of known 

invasive species (Carlson et al. 2015). The common dandelion (Taraxacum officinale) has been found 

north of the Brooks Range and there has been observation of dandelion in the NPR-A (BLM 2012). The 

mechanisms for spread of non-native, invasive plants include equipment and vehicles used for 

construction, and aircraft. Despite the documented economic consequences of non-native, invasive 

species, few quantitative data exist that have measured the ecological impacts of invasive plants, making 

the prediction of environmental impact of these species difficult (Barney et al. 2013). 

Aquatic, non-native, invasive species are of particular concern throughout Alaska because of the potential 

for floatplanes to carry these into new areas (Alaska Department of Fish and Game 2013b). Infestations of 

waterweed (Elodea spp.) in Fairbanks and Anchorage have raised concerns that this aquatic, invasive 

plant is capable of persisting in lakes of southern and interior Alaska. Like many invasive species, this 

plant is adapted to disturbance, can grow rapidly, and can survive when lakes and rivers ice up. 

Infestations have practical as well as ecological implications, as boats and floatplanes may become 

entangled and damaged in thick growths of these weeds. No reports of waterweed infestations in the 

Arctic or the NPR-A have been identified (Alaska Natural Heritage Program 2015).

3.3.2 Fish

The following sections on fish species and habitat are chiefly summarized from the BLM (2012, Section 

3.3.4; 2014, Section 3.3.2), where fish resources in the project area are discussed in more detail, with 

other relevant information incorporated. Subsistence fisheries in the project study area are described in 

Section 3.4.5, “Subsistence.” 

3.3.2.1 Fish Species

Eighteen freshwater, anadromous, and nearshore marine fish species are documented in the GMT2 Project 

area and surrounding waters. Freshwater fish species largely remain within river, stream, and lake systems 

year-round while anadromous species spawn in freshwater, but spend at least part of the life cycle in the 

ocean. Map 3.3-2 shows fish distribution in the project study area.

Industry has conducted extensive fish surveys in the project area and surrounding waters (MJM Research 

1998, 2000a, 2000b, 2000c, 2001a, 20001b, 2002a, 2002b, 2002c, 2002d, 2003a, 2003b, 2003c, 2003d, 

2003e, 2004, 2005a, 2005b, 2007a, 2007b, 2007c, 2008a, 2008b, 2009, 2013), as well as supporting long-
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term monitoring of the Colville River fall under-ice fishery (e.g., Moulton and Field 1988; Seigle et al. 

2018). Ongoing research in the region conducted by the BLM and its cooperators has also provided 

further data on fish habitat use (Heim et al. 2014a, 2015, 2017; McFarland et al. 2017; Jones et al. 2017; 

BLM unpublished data). Ninespine stickleback are the most widely distributed fish species within the 

project area and are found in most waterbodies, including many isolated, poorly connected, and/or 

shallow lake and stream systems. Arctic grayling, broad whitefish, and least cisco are also prevalent in the 

GMT2 Project area, while Alaska blackfish, burbot, humpback whitefish, round whitefish, and slimy 

sculpin are relatively common, but to a lesser extent. Arctic cisco are captured in large numbers in the 

lower Colville River, but are encountered infrequently in the NPR-A Arctic Coastal Plain to the west. The 

remaining fish species are only occasionally observed in the area. 

Studies have documented local and large-scale migrations by Arctic grayling, broad whitefish, and burbot 

in the project area, including use of main river channels, small tributary streams, and lakes (Morris 2003; 

Heim et al. 2014a, 2015, 2017). Given the variability of aquatic habitat on the Arctic Coastal Plain, it is 

likely that some individuals of other fish species also make movements among various habitat types to 

optimize seasonal life history needs, including feeding, overwintering, and spawning. 

Table 33. Fish species found in the GMT2 Project area and vicinity

Species Common Name Scientific Name Iñupiaq Name

Freshwater Alaska blackfish Dallia pectoralis Iłuuqiniq

Freshwater Arctic grayling Thymallus arcticus Sulukpaugaq

Freshwater Burbot Lota Tittaaliq

Freshwater Ninespine stickleback Pungitius Kakalisaauraq

Freshwater Northern pike Esox lucius Siulik

Freshwater Round whitefish Prosopium cylindraceum Savigunnaq

Freshwater Slimy sculpin Cottus cognatus Kanayuq

Anadromous Arctic cisco Coregonus autumnalis Qaataq

Anadromous Bering cisco Coregonus laurettae Tiipuq

Anadromous Broad whitefish Coregonus nasus Aanaaqłiq

Anadromous Chinook salmon Oncorhynchus tschawytscha —

Anadromous Chum salmon Oncorhynchus keta Iqalugruaq

Anadromous Dolly Varden Salvelinus malma Iqalukpik

Anadromous Humpback whitefish Coregonus pidschian Piquktuuq

Anadromous Least cisco Coregonus sardinella Iqalusaaq

Anadromous Pink salmon Oncorhynchus gorbuscha Amaqtuuq

Anadromous Rainbow smelt Osmerus mordax Iłhauġniq

Coastal Marine Fourhorn sculpin Myoxocephalus quadricornus Kanayuq

3.3.2.2 Fish Habitat

The majority of aquatic habitat in the NPR-A exhibits minimal or no impacts as a result of anthropogenic 

activities. Many of the more important attributes influencing fish habitat, such as stream banks and 

channels, lakeshores, substrates, water quality and quantity, floodplains, and riparian areas are largely 

unaltered from their natural condition. 

The GMT2 Project area is predominantly located within the Coastal Plain Unit of the BLM designated 

Fish Habitat Units, along with a small portion of the eastern area located in the Lower Colville Unit 
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(BLM 2012) (Map 3.3.4-4). The Coastal Plain Unit is characterized by extremely low gradient terrain that 

strongly influences aquatic habitat features and morphology. Rivers and streams are generally slow 

moving with many unstable banks, and substrates are dominated by sand and silt with relatively few 

isolated areas of gravel. A majority of the annual flow occurs during spring break-up when large expanses 

of land tend to be inundated by water. Flow is reduced significantly by mid to late summer and can even 

become discontinuous, depending on precipitation. Outside of the major river corridors, the predominant 

aquatic habitat type consists of complicated networks of lakes and small streams. Most of these small 

streams are described as “beaded” because deep pools that occur along thermally degraded ice-wedges are 

connected by narrow channels, resembling beads on a string (Arp et al. 2012, 2015). 

Fish use of waterbodies is largely dependent upon connections between streams and lakes, which can vary 

throughout the year, and water depth, which can impact timing of ice thaw, water temperature, and 

presence of overwintering habitat. Annual waterbody connectivity and flow regimes play a major role in 

determining how much potential habitat is accessible. 

The Tiŋmiaqsiġvik (Ublutuoch River) and Uvlutuuq (Fish Creek) are used by most fish species found in 

the area. Although the full extent of fish use in these higher-order streams is not well studied, deeper 

portions are known to be utilized for overwintering as shown in Map 3.3-2. While a unique reach of 

gravel substrate in the Ublutuoch River upstream of the GMT1 Access Road bridge may provide a 

productive area for fish invertebrate prey, these main channels are typically considered less productive for 

fish prey resources than smaller tributaries and connected lakes. Nevertheless, as the major drainage 

channels in the area they function as important migratory corridors that allow fish to access a variety of 

tributary habitats, primarily beaded streams and lakes.

Beaded streams are mainly used by fish during the ice-free season. Studies in the project area demonstrate 

that pockets of unfrozen water persist in deep pools (Lilly et al. 2010; Jones et al. 2013) (Map 3.3-3), but 

extremely low dissolved oxygen levels indicate that only fish species resistant to those conditions, such as 

Alaska blackfish and ninespine stickleback, may be able to survive (Arp et al. 2015). Following spring ice 

break-up, these streams can provide productive seasonal habitat for other fish species (MJM Research 

2004, 2005a, 2007b, 2009). For example, Arctic grayling begin to enter Crea Creek as soon as passage is 

open in the spring and continue to utilize the stream until freeze-up (Heim et al. 2014a, 2015), with 

multiple size classes consuming a wide range of prey resources (McFarland et al. 2017). In addition to 

supporting productive feeding grounds, beaded streams also provide fish access to numerous lakes.

Fish use of lakes largely depends on depth and connectivity (Haynes et al. 2013; Laske et al. 2016; Jones 

et al. 2017). Lakes that do not freeze to the bottom annually and are greater than 6.0 feet (Map 3.3-3) 

provide the most likely potential overwintering habitat, although morphology and landscape attributes can 

strongly influence dissolved oxygen levels and effect fish species suitability (Leppi et al. 2015). In the 

GMT2 Project area, most lakes are isolated or poorly connected (Map 3.3-4) and are either fishless or 

only inhabited by ninespine stickleback (Map 3.3-2). However, even lakes that are not used by fish in the 

winter can provide valuable feeding habitat. For example, one shallow lake connected to Crea Creek is 

used extensively by numerous juvenile Arctic grayling throughout the summer (Heim et al. 2017). 

Additionally, lakes can be an important source of prey items (e.g., zooplankton and ninespine stickleback) 

for stream-dwelling fish lower in the drainage (McFarland et al. 2017). Lake water can also provide a 

substantial portion of downstream water supply (BLM unpublished data), further influencing stream 

habitat conditions and lake access. 

Spawning habitat requirements vary for different Arctic fish species and can occur in a wide range of 

flowing or still waters. Some species can spawn successfully in areas of silt or sand substrate, while many 

others require gravel of a particular size class and relatively clear water. Except for burbot, which spawn 

under ice in late winter, Arctic freshwater fish spawn between late May and October. Although spawning 
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is a critical aspect of species persistence, specific information on spawning locations in the GMT2 Project 

area is lacking. 

Waterbodies used by anadromous fish species and documented in the State’s Anadromous Waters Catalog 

(AWC; 5 AAC 95.011) are shown on Map 3.3-4 (Alaska Department of Fish and Game 2017). These 

streams and lakes are granted protection under the Anadromous Fish Act (AS 16.05.871). For this 

purpose, “anadromous” is defined as “breeding in fresh water but spending at least part of the life cycle in 

the ocean” (Craig 1989), which is consistent with Alaska Department of Fish and Game legal use. Fish 

species included under this definition are in Table 34.

3.3.2.3 Essential Fish Habitat

The 1996 Sustainable Fisheries Act enacted additional management measures to protect commercially 

harvested fish species from overfishing. Along with reauthorizing the Magnuson-Stevens Fishery 

Conservation and Management Act Reauthorization (16 U.S.C. 1801-1882), one of those added measures 

is to describe, identify, and minimize adverse effects to essential fish habitat through the National 

Environmental Policy Act. Arctic freshwater essential fish habitat only includes habitat utilized by Pacific 

salmon (Map 3.3-4). The essential fish habitat assessment for the GMT2 Project area is in Appendix E.

3.3.3 Birds

About 90 species of birds are expected to occur annually in the NPR-A and adjacent Beaufort and 

Chukchi Sea habitats (BLM 2012, Section 3.3.5). Approximately 80 of these species are likely to occur in 

the Alpine Satellite Development Plan Area (see BLM 2004, Figure 1.1.1-1, Plan Area Vicinity and 

Location Map) or in nearshore waters of Harrison Bay. Common, scientific, and Inupiaq names and status 

of avian species in the Alpine Satellite Development Plan Area are presented in Table 34. Life history and 

general biology of avian species in the Alpine Satellite Development Plan Area and within the NPR-A is 

provided in BLM (2004, Section 3.3.3) and in BLM (2012, Section 3.3.5), which are incorporated by 

reference.

The majority of wildlife studies available for this region cover a large geographical area. For the purposes 

of this supplemental EIS, a project study area (see Section 3.1.1 and Map 3.1-1) is used to delineate a 

defined area for analysis of the affected environment and potential impacts from the proposed GMT2 

Project. 

Federal and state agencies have been conducting avian studies for similar time periods in response to 

resource development activities and for the tracking of multiple species population trajectories. Migratory 

bird aerial surveys for the Arctic Coastal Plain have been conducted by USFWS Migratory Bird 

Management annually since 1986 resulting in a long-term dataset of the estimated onshore densities of up 

to 34 species. USFWS Migratory Bird Management has also estimated annual avian population size and 

average population growth rates using their long-term (1986–2016) aerial survey data (Stehn 2014; Stehn 

et al. 2013; USFWS, unpublished data). Density classes occurring within the GMT2 Project area for the 

latest 4 years of data available, 2012–2015 (USFWS, unpublished data 2017) were determined by 

geographic information systems analysis and summaries are presented for species with available data.

Avian surveys in the Alpine Satellite Development Plan area have been conducted by ConocoPhillips and 

its predecessors since 1992 and in sections of the Colville River Delta since 1989. Data from these 

sources that support density, distribution, and trend estimates of species commonly found in the GMT2 

Project area are summarized within this section (threatened bird species are discussed in Section 3.3.5). 

ConocoPhillips’s contractor for avian studies, ABR, Inc. Environmental Research & Services has been 

conducting surveys of both the Colville River Delta, termed Colville Delta Study Area (Colville Delta 
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Special Area) in this document, the northeastern portion of the NPR-A, termed NPR-A Study Area in this 

document, and the Kuparuk Study Area in this document.

The majority of infrastructure proposed for GMT2 Project is west of GMT1 and limited to a single ABR, 

Inc. Environmental Research & Service study subarea within the NPR-A Study Area called the 

Development Subarea. The entire Development Subarea extends east to include the gravel source, Arctic

Slope Regional Corporation Mine, and north to Alpine Central Processing Facility/CD1. Map 3.3-5 shows 

the location of the GMT2 Project area and associated study areas and subareas. BLM (2014, Appendix J) 

provides a summary of available data from ConocoPhillips avian surveys in the Alpine Satellite 

Development Plan area.

Beginning in 1992, ConocoPhillips engaged in consultation with resource agencies and local communities 

to select a focal group of wildlife species, including birds, to study using annual aerial surveys in the 

Colville Delta Special Area and NPR-A Study Area. Surveys continue to collect data on distribution, 

abundance, and habitat use of these focal species. Avian species were selected using the following 

criteria: (1) threatened or sensitive status, (2) indications of declining populations, (3) restricted breeding 

range, (4) importance to subsistence hunting, or (5) concern of regulatory agencies for development 

impacts.

Table 34. Colville Delta Special Area and NPR-A Study Area subareas in relation to the GMT2 Project study 

area

Area Subarea Description

Colville Delta Study 

Area (Colville Delta 

Special Area) a

CD North Subarea A portion of this subarea crosses the project area but 

contains no project infrastructure

Northeast Delta Subarea Not contained within project area

CD South Subarea Includes GMT2 pipelines from 

rack within the project area

CD1 on existing pipe 

NPR-A Study Area a Fish and Judy Creek 

Corridor Subarea

Overlaps with Development Subarea, intersects a 

portion of the GMT2 Project area but contains no 

project infrastructure; created and used for loon 

surveys in 2008

GMT Corridor Subarea Includes the proposed GMT2 pad, road to permitted 

GMT1 pad and road/pipeline to CD5 pad; created and 

used for loon surveys in 2014

Fish Creek Delta Subarea The southeast corner of this subarea crosses 

GMT2 Project area but contains no project 

infrastructure 

the 

Alpine West Subarea Includes a portion of existing road and pipeline from 

CD4 to CD5 that will also be used by GMT2

Development Subarea Includes proposed GMT2 pad, pipeline and road to 

GMT1 and the previously permitted GMT1 to CD5 

road and pipeline that will also be used by GMT2 

Project 

a See Map 3.3-5 for study subareas in relation to the GMT2 Project area. Source: Johnson et al. (2015).

The focal avian species included the following: spectacled eider (Somateria fischeri), king eider 

(Somateria spectabilis), tundra swan (Cygnus columbianus), yellow-billed loon (Gavia adamsii), brant 

(Branta bernicla), snow goose (Chen caerulescents), greater white-fronted goose (Anser albifrons), and 

cackling (or Canada) goose (Branta canadensis).

Data were also collected on the glaucous gull (Larus hyperboreus) due to their documented predation on 

eggs of ground nesting birds (Johnson et al. 2009). Three additional species that share similar 
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conservation concerns and may occur in the GMT2 Project area are: red knot (Calidris canutus roselaari), 

short-eared owl (Asio flammeus), and golden eagle (Aquila chysaetos), as described in BLM (2004a) and 

BLM (2012). Seabirds (including gulls), passerines (notably Lapland longspur and common raven), 

ptarmigan (willow and rock), waterbirds (geese, swans, eiders, loons), shorebirds (plovers, sandpipers, 

phalarope, red knot), and raptors (golden eagle, peregrine falcon, gyrfalcon, owls) are the species groups 

discussed in this document. Most groups have been recorded regularly (ptarmigan, shorebirds, waterfowl, 

and passerines), but raptors only on an infrequent basis, during ConocoPhillips avian surveys in the 

Alpine Satellite Development Plan area (Johnson et al. 2015).

Common, scientific, and Iñupiaq names and special status of avian species in the Alpine Satellite 

Development Plan area are presented in Table 35. The status category includes species (or populations) 

listed as Birds of Conservation Concern by the USFWS (2008); or identified as sensitive species by the 

BLM (2010). Avian species listed as threatened under the Endangered Species Act (Steller’s eider and 

spectacled eider) are discussed in Section 3.3.5. Species listed as Birds of Conservation Concern are 

migratory nongame birds that are likely to become candidates for listing under the Endangered Species 

Act in the absence of additional conservation efforts. BLM Sensitive Species include those known or 

predicted to undergo a decline that could threaten the viability of the species under all or a portion of its 

range, and those that rely on unique or specialized habitats that are threatened with alterations that could 

jeopardize the viability of the species. Life history and general biology of birds in the Alpine Satellite 

Development Plan area and within the NPR-A are provided in BLM (2004a, Section 3.3.3), BLM (2012, 

Section 3.3.5), and BLM (2014, Section 3.3.3), which are incorporated by reference.
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Table 35. Common, scientific and Inupiaq names and status of avian species found in the Alpine Satellite 

Development Plan Area

Avian Category Common 

Name

Scientific Name a Iñupiaq Name b Status c

Waterfowl 

(Tinmiagruich)

and Waterbirds

greater 

whitefronted 

goose

Anser albifrons niġlivik; niġlivialuk --

snow goose Chen caerulescens kaŋuq --

cackling 

goose

Branta hutchinsii iqsraġutilik SS

Canada 

goose

Branta canadensis iqsraġutilik --

Brant Branta bernicla niġlinġaq --

tundra swan Cygnus columbianus qugruk --

Gadwall Anas strepera -- -

American 

wigeon

Anas americana kurugaġnaq; ugiihiq --

Mallard Anas platyrhynchos kurugaqtaq; ivugaq --

northern 

shoveler

Anas clypeata qaqłutuuq; alluutaq --

northern 

pintail

Anas acuta kurugaq; ivugaq --

greenwinged teal

Anas crecca qaiŋŋiq; kurukaałhusiq --

canvasback Aythya valisineria -- --

greater 

scaup

Aythya marila qaqłuqpalik --

lesser scaup Aythya affinis qaqłuqtuuq; qaqłuktuuq --

Steller's 

eider

Polysticta stelleri igniqauqtuq T

spectacled 

eider

Somateria fischeri qavaasuk T

king eider Somateria spectabilis qiŋalik --

common 

eider

Somateria mollissima amauligruaq; amaullik --

surf scoter Melanitta perspicillata avił ̣uqtuq; avił ̣uqtaq; 

aił ̣uqtuq; tuunġaaġruk

--

whitewinged 

scoter

Melanitta fusca killalik; tuunġaaġruk --

black scoter Melanitta nigra tuunġaaġrupiaq; 

nayaŋŋak; uviñauyak

--

long-tailed 

duck

Clangula hyemalis aaqhaaliq; argiq --

red-breasted 

merganser

Mergus serrator paisugruk; 

aqpaqsruayuuq 

--

Loons 

(Malgitch) and 

Grebes

red-throated 

loon

Gavia stellata qaqsrauq BCC

Pacific loon Gavia pacifica malġi --

yellow-billed 

loon

Gavia adamsii tuullik BCC, SS

red-necked 

grebe

Podiceps grisegena aqpaqsruayuuq; 

suġlitchauraq

--

horned 

grebe

Podiceps auritus subliq --

Ptarmigan willow 

ptarmigan

Lagopus aqargiq; nasaullik --

rock 

ptarmigan

Lagopus mutus niksaaktuŋiq --
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Avian 

Category

Common 

Name

Scientific Name a Iñupiaq Name b Status c

Cranes sandhill crane Grus canadensis tatirgaq; tatirgak --

Raptors and 

Owls

bald eagle Haliaeetus 

leucocephalus

tiŋmiaqpak --

northern harrier Circus cyaneus papiktuuq --

rough-legged 

hawk

Buteo lagopus qił ̣ġiq --

golden eagle Aquila chrysaetos tiŋmiaqpak SS

merlin Falco columbarius kirgaviatchauraq; 

tiŋmiaġruum kirgavia

--

gyrfalcon Falco rusticolus aatqarruaq; ukiuqtaq --

peregrine falcon Falco peregrinus kirgavik BCC

snowy owl Bubo scandiacus ukpik --

short-eared owl Asio flammeus nipaił ̣uktaq SS

Shorebirds black-bellied 

plover

Pluvialis squatarola tullisugruk; tullivak; 

tuullikpak

--

American 

golden plover

Pluvialis dominica tullik; tuulligł ̣uk --

semipalmated 

plover

Charadrius 

semipalmatus

kurraquraq --

whimbrel Numenius phaeopus siituvak; sigguktuvak BCC

bar-tailed 

godwit

Limosa lapponica turraaturaq BCC

red knot Calidris canutus -- BCC, SS

ruddy turnstone Arenaria interpres tullignaq --

black turnstone Arenaria melanocephala -- --

sanderling Calidris alba kimmitquiḷaq;

aqpaqsruayuuq

--

semipalmated 

sandpiper

Calidris pusilla livalivaq; nivilivakpak --

western

sandpiper

Calidris mauri -- -

least sandpiper Calidris minutilla livaluġauraq; 

lavluġauraq; livalivauraq

--

white-rumped 

sandpiper

Calidris fuscicollis qupilġuqsiuyuk --

Baird's 

sandpiper

Calidris bairdii puvviaqtuuyaaq;

nuvaksruk

--

pectoral 

sandpiper

Calidris melanotos puvviaqtuuq; aivigiak --

dunlin Calidris alpina qayuuttavak;

siggukpaligauraq

BCC

stilt sandpiper Calidris himantopus -- --

buff-breasted 

sandpiper

Tryngites subruficollis satqagiił ̣aq; puvviaqtuuq BCC

long-billed 

dowitcher

Limnodromus

scolopaceus

kilyaktalik; siggukpalik --

Wilson’s snipe Gallinago delicata saavġaq; aiviqiaq; 

kuukukiaq

--

red-necked 

phalarope

Phalaropus lobatus qayyiiġun; qayyiuġun --

red phalarope Phalaropus fulicarius auksruaq --
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Avian 

Category

Common 

Name

Scientific Name a Iñupiaq Name b Status c

Seabirds pomarine 

jaeger

Stercorarius pomarinus isuŋŋaġluk; isuŋŋaaluk --

parasitic jaeger Stercorarius parasiticus miġiaqsaayuk --

long-tailed 

jaeger

Stercorarius 

longicaudus

isuŋŋaq --

herring gull Larus argentatus nauyavvaaq --

Thayer's gull Larus thayeri -- --

glaucouswinged gull

Larus glaucescens -- --

glaucous gull Larus hyperboreus nauyavasrugruk --

Sabine's gull Xema sabini iqirgagiaq; igirraq; 

qargagiaq

--

black-legged 

kittiwake

Rissa tridactyla -- --

Arctic tern Sterna paradisaea mitqutaił ̣aq BCC

black guillemot Cepphus grylle iŋaġiq --

Passerines common raven Corvus corax tulugaq --

Arctic warbler Phylloscopus borealis suŋaqpaluktuŋiq --

bluethroat Luscinia svecica -- --

yellow wagtail Motacilla flava misiqqaaqauraq; piuġaq;

iksriktaayuuq

--

American tree 

sparrow

Spizella arborea misapsaq --

savannah 

sparrow

Passerculus 

sandwichensis

ukpisiuyuk; 

uqpiksiuġayuk; aanaruiñ 

suliuqpa

--

Lapland 

longspur

Calcarius lapponicus qupałuk; putukiułuk --

snow bunting Plectrophenax nivalis amaułłigaaluk; 

amautligaq; 

qupałupiaġauraq

--

common 

redpoll

Carduelis flammea saqsakiq; saksaŋiq; 

saksaŋiuraq; 

uqpiksiuyuk

--

hoary redpoll Carduelis hornemanni saqsakiq; saksaŋiq; 

saksaŋiuraq; 

uqpiksiuyuk

--

Note: BCC = USFWS Birds of Conservation Concern; SS = BLM Sensitive Species; T = USFWS Threatened.

a Scientific names from List of the 2,031 Bird Species (with Scientific and English Names) Known from the A.O.U. Checklist Area

(http://www.aou.org/checklist/north/print.php). 

b Iñupiaq names from MacLean (2012).

c USFWS 2008, 2014a; BLM 2010.

d Steller's eider (Polysticta stelleri) and spectacled eider (Somateria fischeri) are listed as Threatened under the Endangered 

Species Act, and are discussed in Section 3.3.5 with other Endangered Species Act species.

(-) no corresponding Iñupiaq name found; or species has no notable status.

Wildlife survey data and habitat maps were used to determine habitat selection and preference by focal 

birds and mammals on the North Slope (Johnson et al. 2013). This approach, known as the ecological 

land survey approach, is described in BLM (2004a). Map 3.3-6 depicts the wildlife habitat types 

delineated within the GMT2 Project area. The wildlife habitat type classification considers vegetation 

type, geomorphology, and surface forms, but also factors in ecological significance such as use by 

wildlife. A description of habitat types is provided in Appendix D,

Generally, on the Arctic Coastal Plain of Alaska’s North Slope, the following habitat characteristics are 

attractive to shorebirds, geese, ducks, and loons: availability of large deep lakes with ice floes, shoreline 

with low relief, peat or mud substrate for resting, graminoid meadows with moss, low predator and 

human population or disturbance, and proximity to coastal staging areas (BLM 2004). The most common 
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vegetation types in the project study area include, in decreasing order: Wet Sedge Meadow Tundra, 

Tussock Tundra, Moist Sedge-Shrub Tundra, Water, and Ice-Rich Basin Wetland Complex (Map 3.3-1 

and Table 32).

The following sections describe the focal avian species occurring in the project study area and the habitat 

used by those species. Steller’s eider and spectacled eider are addressed in Section 3.3.5, “Threatened and 

Endangered Species.”

3.3.3.1 Gulls

The summary presented below provides information from data collected on glaucous gulls throughout the 

Arctic Coastal Plain, as well as limited site-specific data regarding glaucous gulls in the project study 

area. This summary is supplemental to information provided in BLM (2012, Section 3.3.5.1), BLM 

(2004, Section 3.3.3.7), and BLM (2014, Section 3.3.3.1) which are incorporated by reference.

Glaucous gulls were selected as focal species for ongoing studies due to the potential for an increase in 

gull populations, resulting from their attraction to industrial development, and their known ability to prey 

on eggs and chicks. ConocoPhillips and its predecessors have been collecting data on glaucous gulls in 

the Colville Delta Special Area since 1995 and in the NPR-A Study Area since 1999 (Johnson et al. 

2014a; BLM 2014). In some years, observations of gulls were collected opportunistically as part of 

studies that focused on other bird species.

Over the entire Arctic Coastal Plain, the average annual population growth rates (total bird index) from 

1986 to 2016 for the glaucous gull was 1.034, indicating a positive population growth trend for these 

species across the Arctic Coastal Plain (Stehn 2014; Stehn et al. 2013; USFWS, unpublished data).

Estimated density indices of glaucous gulls across the Arctic Coastal Plain are found on Map 3.3-7. 

Newly estimated density indices for the Arctic Coastal Plain using the latest 4 years of data (2012–2015) 

have been generated by USFWS (USFWS, unpublished data 2017) and these updated density indices 

were used to select estimated densities within the project study area by using a GIS analysis of density 

contour data. The majority of gulls found within the project area are contained within the low and 

medium contours (Table 36).

Table 36. Estimated density contours of glaucous gulls within the project area (2012–2015)

Density Index Contour 

(birds per km2)

Acreage within 

Project Study Area

Percent of 

Project Study Area

0–0.110 14,156.0 9.1

0.111–0.263 66,424.6 42.6

0.264–0.444 64,382.9 41.3

0.445–0.707 8,575.4 5.5

0.708–1.489 2,450.1 1.6

Source: USFWS unpublished data 2017.

Estimated densities of glaucous gulls within the GMT2 Project area for the 2012–2015 aerial surveys 

range from 0.000−0.110 to 0.708−1.489 birds per square kilometer (Table 36) (Stehn 2014; Stehn et al. 

2013; USFWS, unpublished data). The highest density contour is present in 1.6 percent of the project area 

while the second and third highest density contours are present in 83.9 percent of the project area. 

Glaucous gulls were observed incidentally as part of aerial loon nesting and brood-rearing surveys in 

2014 on selected lakes within the Colville Delta Special Area and the NPR-A Study Area. Lakes surveyed 

for gulls in the NPR-A Study Area were located in the Alpine West Subarea, the Fish Creek Delta 

Subarea, and the 2014 GMT Corridor Subarea (Johnson et al. 2015). A total of 84 glaucous gull nests 
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were observed in the Colville Delta Special Area in 2014. Of the nest total, 96 percent were within CD 

North and CD South Subareas, which contain portions of the project study area (Johnson et al. 2015). Of 

a total 53 glaucous gull nests recorded in the NPR-A Study Area in 2014, 23 of the nests were found in 

the GMT Corridor Subarea, where the GMT2 Project area lies (Johnson et al. 2015). The number of 

glaucous gull nests in the Colville Delta Special Area are increasing based on survey results from 2002 to 

2015 (Johnson et al. 2015). In the NPR-A Study Area, survey areas have varied between years, thus the 

trend in glaucous gull nesting is less clear. 

Glaucous Gull nests and colonies were found in 12 different habitats in the Colville Delta Special Area 

(Johnson et al. 2015). The four most commonly used habitats also contained colonies: Deep Open Water 

with Islands or Polygonized Margins (36 percent of nests), Patterned Wet Meadow (24 percent), Tapped 

Lake with High-water Connection (15 percent), and Grass Marsh (8 percent). The largest Glaucous Gull 

colony (18 nests) was located on a large island classified as Patterned Wet Meadow. The remaining 14 

percent of nests were found on islands or complex shorelines in eight other habitats. Glaucous Gull 

broods were found in aquatic and terrestrial habitats near nest locations, often in the same habitat as the 

nest (Johnson et al. 2015).

Glaucous Gulls nested in 10 different habitats in the NPR-A Study Area study area in 2014 (Johnson et al. 

2015). Twenty-eight (53 percent) of 53 nests, including three colonies, were in Shallow Open Water with 

Islands or Polygonized Margins. Another 17 percent of the nests were located in Deep Open Water with 

Islands or Polygonized Margins. The remaining 20 percent were found on islands or complex shorelines 

of six other aquatic habitats and two terrestrial habitats. Glaucous gull broods observed during aerial 

surveys were located near nests and in the same habitats as were the nests (Johnson et al. 2015).

3.3.3.2 Passerines

A discussion of passerine species distribution, nesting habitats, foraging, and surveys on the Arctic 

Coastal Plain, as well as in the project study area, is included in BLM (2004, Section 3.3.3.8; 2012, 

Section 3.3.5.7; and BLM 2014, Section 3.3.3.2) which are incorporated by reference. Most passerines 

found in the NPR-A generally arrive on the North Slope from late May to early June and remain until 

mid- to late August (Johnson and Herter 1989). Passerines breeding in the project study area are generally 

tundra or shrub-nesting species. Savannah sparrow, redpoll, snow bunting, Lapland longspurs, common 

raven, and yellow wagtail are expected to occur in the project study area (BLM 2012). Nesting and 

foraging habitats used by passerines that are likely to occur in the project study area are summarized in 

BLM (2004). This section will address the Lapland longspur in detail because it is the most numerous 

nesting bird in the NPR-A and Colville River Delta, as indicated from surveys conducted since the 1970s 

(BLM 1978; Derksen et al. 1981; Burgess et al. 2003; Liebezeit and Zack 2006, 2007, 2008). Ravens will 

be addressed due to their known association with industrial development and their potential for preying 

on eggs and chicks (BLM 2012). 

Lapland longspurs are the most common avian species nesting across the NPR-A and Colville Delta 

Special Area (BLM 2012). Lapland longspurs were the most frequent passerine nesting in all of the 24 

breeding-bird plots (31.3 nests per square kilometer) in the NPR-A Study Area reported by Johnson et al. 

(2005) and 12 plots (45.8 nests per square kilometer on treatment plots, 37.5 nests per square kilometer 

on reference plots) on the Colville Delta Special Area (Johnson et al. 2003). Over a 3-year period, 

Lapland longspurs also were found to be the highest density nesting passerine species (40.0 to 42.5 nests 

per square kilometer) in an area near Teshekpuk Lake, which is located outside of the project study area 

(BLM 2012). In ground nest searches near the Alpine development and the NPR-A satellite developments,

Lapland longspurs accounted for greater than 80 percent of all bird nests documented each year (BLM 

2004). 
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Other passerine birds observed nesting in NPR-A included savannah sparrows (infrequent; 2 of 24 plots; 

0.8 nests per square kilometer), eastern yellow wagtail (one nest found in 2004; Johnson et al. [2005]), 

American tree sparrows, and common redpolls nesting along the channels of the Colville River.

A multi-year study of the influence of human development and predators on the nest survival of tundra 

nesting birds at seven sites on the ACP (Liebezeit et al. 2009) determined that human infrastructure had a 

negative effect on nest survival for passerines and that passerine nest survival declined within 5 km of oil 

field infrastructure that provided nesting, perching, or denning sites for nest predators but increased with 

the percentage of vegetative cover over a nest.

Common raven, though not abundant, is the only resident passerine in the NPR-A Study Area and 

Colville Delta Special Area, and is found across the Arctic Coastal Plain, but nest only where cliffs, 

bluffs, or artificial structures provide nesting habitat (BLM 2012). During a workshop designed to 

determine human influences on predators of nesting birds on the North Slope of Alaska held by the 

USFWS in 2003, participants agreed that ravens have increased in number on the Arctic Coastal Plain in 

response to human activity. However, consensus was not achieved on how much and where the increase 

in the raven population has taken place (USFWS 2003). Human activities may benefit ravens by 

increasing the over-winter survival of adults and/or young due to an increased food supply. Aerial surveys 

conducted by the USFWS across the Arctic Coastal Plain do not provide good estimates of raven 

population numbers due to the avoidance of areas of human habitation by the aircraft. 

Data has been collected using the Audubon Society Christmas Bird Counts at Prudhoe Bay between 1987 

and 2012, with the only species detected in all years being the raven 

(http://netapp.audubon.org/CBCObservation/Historical/ResultsByCount.aspx#). During that period, the 

count of ravens increased from 3 birds in 1987, to 39 birds in 1990, to 73 birds in 2000 and to 116 birds in 

the last year the survey was conducted (2012). Ravens may be surviving winter by eating anthropogenic 

foods at Prudhoe Bay and possibly enhancing their likelihood of winter survival on the North Slope (Day 

1998). There are ravens nesting in the Alpine oilfield (BLM 2012) and ravens were reported to use 

buildings as roosting sites at CD1, with nests confirmed in 2000 and 2001 (Johnson et al. 2003a). 

Common ravens are successful egg predators of passerines, shorebirds, loons, and waterfowl on the Arctic 

Coastal Plain (BLM 2012), and thus, could have an impact on local ground nesting bird populations. 

3.3.3.3 Ptarmigan

Two species of ptarmigan, the willow and rock ptarmigan, occur in the NPR-A (BLM 2012). Ptarmigan 

are ground-nesting birds in the grouse family that remain in the NPR-A year-round and are a species 

utilized for subsistence. Willow ptarmigan have been found nesting in both dense vegetation and on open 

tundra (Hannon et al. 1998; Johnson and Herter 1989). Specifically, ground-based nest searches in 2002 

found willow ptarmigan nests in three habitat types (Patterned Wet Meadow, Moist Sedge-Shrub 

Meadow, and Moist Tussock Tundra) at a study site near the GMT1 pad (as permitted), with over 66 

percent (4 of 6 nests) of the nests occurring in Moist Tussock Tundra (Burgess et al. 2003). Over 44 

percent (12 of 21 nests) of the nests occurred in Moist Tussock Tundra (Burgess et al. 2003). Rock 

ptarmigan may conduct local migrations during the fall to obtain willow forage (Johnson and Herter 

1989), and nest in dry rocky habitats and in hummocky areas of wet sedge meadows (Holder and 

Montgomerie 1993). 

Although no research studies targeting these species were identified, both species of ptarmigan have been 

recorded at low densities in various large waterbird nest searches conducted in areas representative of the 

project study area. In 2002, among four different ground-based nest search sites summing 15.7 square 

kilometers (Clover [mine site], Alpine West [Subarea], Lookout [GMT1], and Spark [a previously 

proposed location for GMT2, approximately 2.1 miles north of the current GMT2 location]), 10 

ptarmigan nests were reported, with only 1 nest located at Spark (Burgess et al. 2003). 
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3.3.3.4 Waterfowl

Waterfowl are among the most populous avian groups on the Arctic Coastal Plain and within the project 

study area. Waterfowl are present on the Arctic Coastal Plain from early spring until late fall when they 

migrate to their wintering grounds. The following section summarizes information for select species of 

waterfowl (tundra swan, brant, snow goose, king eider, greater white-fronted goose, and cackling goose) 

and is supplemental to information provided in BLM (2012, Section 3.3.5.5), BLM (2004a, Section 

3.3.3.2), and BLM (2014, Section 3.3.3.4), which are incorporated by reference here. 

Tundra Swan

The summary presented below provides information from data collected on tundra swans throughout the 

Arctic Coastal Plain and limited site-specific data in the project study area. Tundra swan was selected as a 

focal avian species because it is thought to be an indicator species for potential impacts from

development. 

ConocoPhillips and its predecessors have been conducting aerial surveys of nesting and brood-rearing 

tundra swans in the NPR-A Study Area beginning in 1999 and continuing 2001−2014, and in the Colville 

Delta Special Area since 1992. Survey areas and percentage of area surveyed differed among years. 

Tundra swans are common along the Arctic Coastal Plain, and are present in the project study area.

The average annual population growth rate (total bird index) from 1986 to 2016 for tundra swans was 

1.046, indicating a positive population growth trend for this species across the Arctic Coastal Plain (Stehn 

2014; Stehn et al. 2013; and USFWS, unpublished data). The overall trend in counts of pairs, nests, and 

broods in the Colville Delta Special Area has been one of slow increase. 

Due to variation of areas studied between years, an overall trend for pairs, nests, and broods is not 

available for the data collected on tundra swans in the NPR-A Study Area (Johnson et al. 2014). 

Estimated density indices of tundra swans are found in Map 3.3-7 of this document. Newly estimated 

density indices for the Arctic Coastal Plain using the latest 4 years of data (2012–2015) have been 

generated by USFWS (USFWS, unpublished data 2017) and these updated density indices were used to 

select estimated densities within the project study area by using a GIS analysis of density contour data. 

All onshore ranges of density index contours found on the Arctic Coastal Plain fall within the project 

study area and range from 0-0.077 to 0.522-1.231 birds per square kilometer Table 37). Table 37 shows 

that 67.1 percent of the project study area contains high to moderately high densities of tundra swans 

when compared to the entire Arctic Coastal Plain population. 

Table 37. Estimated density contours of tundra swans within project study area (2012–2015)

Density Index Contour 

(birds per km2)

Acreage within 

Project Study Area

Percent of 

Project Study Area

0–0.077 9,800.3 6.3

0.078–0.183 41,651.5 26.7

0.184–0.309 48,185.0 30.9

0.310–0.521 47,504.4 30.5

0.522–1.231 8,847.5 5.7

Source: USFWS unpublished data 2017.

Within the Colville Delta Special Area, the 21-year (1992–2014) number of and average density of tundra 

swan nests was reported at 23 nests (a greatly reduced number from the annual mean of 34 nests) and 0.04 

nests per square kilometer (Johnson et al. 2015). In 2014 5 nests were located in the CD North subarea, 7 

were in the CD South subarea, and 11 were in the Northeast Delta subarea (Johnson et al. 2015). 
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Productivity of tundra swans on the Colville Delta Special Area was very low in 2014. During the 2014 

brood-rearing survey, only 14 tundra swan broods were observed in the Colville Delta Special Area, far 

fewer than the 21-year mean of 24 broods (Johnson et al. 2015). The smallest number of broods counted 

since surveys were initiated in 1992 was 13, in 2013. Apparent nesting success was 61 percent (14 

broods/23 nests), in contrast to the long-term mean of 71 percent (Johnson et al. 2015). The mean brood 

size in the Colville Delta Special Area of 2.1 young/brood in 2014 was less than the long-term mean of 

2.5; the total of 29 young counted in 2014 was only half that of the mean of 58 young per year (Johnson 

et al. 2015). 

Tundra swans on the Colville Delta Special Area used a wide range of habitats for nesting. In over 21 

years of surveys, tundra swans nested in 20 of 24 available habitats, of which 9 habitats were preferred 

and 7 were avoided and 80 percent of the nests were found in the preferred habitats (Johnson et al. 2015). 

All of the preferred habitats are present in the project study area. Habitat selection also was evaluated for 

498 tundra swan broods recorded on the Colville Delta Special Area since 1992. Nine habitats, all of 

which are found in the project study area, were preferred including high use of salt-affected or coastal 

habitats by brood-rearing swans reflecting an apparent seasonal change in distribution or habitat 

preference, in that approximately 34 percent of all swan broods on the Colville Delta Special Area were in 

salt-affected habitats, compared with only 19 percent of all nests (Johnson et al. 2015). 

Within the NPR-A Study Area, 15 nests (0.02 nests per square kilometer) were observed in 2014 surveys, 

with 1 nest in the Alpine West Subarea, 1 nest in the Exploration Subarea, 2 nests in the Fish Creek Delta 

Subarea, and 11 nests in the Development Subarea (Johnson et al. 2015). Apparent nesting success was 67 

percent (10 broods/15 nests) with a total of 10 broods recorded in the NPR-A Study Area (0.01 broods per 

square kilometer) with an average brood size of 2 with 8 of the broods occurred in the Development 

Subarea and 2 in the Fish Creek Delta (Johnson et al. 2015). 

Tundra swans on the NPR-A Study Area used a wide range of habitats for nesting. Habitat selection was 

evaluated for 347 tundra swan nests recorded in the NPR-A Study Area since 2001 and it was determined 

that tundra swans nested in 21 of 26 available habitats, but preferred only 4 habitats in which 63 nests 

were located (Johnson et al. 2015). All of these four preferred nesting habitats occur in the project study 

area. Swan broods in NPR-A Study Area were attracted to large, deep waterbodies, similar to the habitats 

where swan broods were found on the Colville Delta Special Area. Habitat selection was evaluated for 

220 tundra swan broods recorded in the northeastern NPR-A Study Area since 2001 and broods were 

found to have used 22 of 26 available habitats with 63 percent of all broods found in the 5 preferred 

habitats (Johnson et al. 2015). All five of these preferred habitats occur in the project study area.

Brant and Snow Goose

The summary presented below provides information from data collected on brant and snow geese 

throughout the Arctic Coastal Plain, and site-specific information collected in the project study area. 

Ground-based nest searches documented nesting, brood-rearing, and fall staging of various bird species 

along a previously proposed road corridor between CD2, CD5, and the GMT1 pad area have been 

conducted (Johnson et al. 2005). These surveys were conducted 1 kilometer around proposed pad 

footprints for CD5 and CD6 (now known as GMT1 and GMT2), as well as 200 meters from the 

previously proposed road centerline between CD2, CD5, and the GMT1 pad area. Aerial surveys for 

brood-rearing and fall staging geese were also conducted in the NPR-A Study Area. In 2009, groundbased nest searches were conducted in a 400-meter buffer around the proposed GMT1 and CD5 pads as 

well as a 200-meter buffer surrounding the proposed road route between CD4 and GMT1 (Seiser and 

Johnson 2011). 
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Brant 

The average annual population growth rate (total bird index) from 1986 to 2016 for brant was 1.055, 

indicating a positive population growth trend for this species across the Arctic Coastal Plain (Stehn 2014; 

Stehn et al. 2013; USFWS, unpublished data).

Newly estimated density indices for the Arctic Coastal Plain using the latest 4 years of data (2012–2015) 

have been generated by USFWS (USFWS, unpublished data 2017) and these updated density indices 

were used to select estimated densities within the project study area by using a GIS analysis of density 

contour data (Map 3.3-8). There are no high density concentrations of brant within the project study area 

and the majority of the birds are found in the lowest density contour. Estimated density index contours 

within the project study area range from 0-0.094 to 1.345– 2.397 birds per square kilometer and are 

represented in Table 38. 

Table 38. Estimated density contours of brant within project study area (2012–2015)

Density Index Contour 

(birds per km2)

Acreage within 

Project Study Area

Percent of 

Project Study Area

0–0.094 113,112.3 72.5

0.095–0.329 28,175.93 18.1

0.330–0.714 12,386.53 7.9

0.715–1.344 2,313.8 1.5

1.345–2.397 0 0

Source: USFWS unpublished data 2017.

Nest surveys were conducted in 2004 in several subarea of the NPR-A Study Area. Within the road 

corridor study plots, 13 brant nests (1.3 nests per square kilometer) were observed and nesting success for 

all NPR-A Study Area study plots was moderate to high, with 76 percent of brant nests successful 

(Johnson et al. 2005). In 2009, two brant nests were recorded along road corridor searches (Seiser and 

Johnson 2011). Ground-based nest search data was used to determine habitat use during nesting for brant 

in 2004. In the NPR-A Study Area, nesting brant utilized shallow open water with islands or polygonized 

margins, and young basin wetland complex both habitat types that are contained within the project study 

area (Johnson et al. 2005).

Neither brood-rearing nor staging brant were observed within the project study area during aerial surveys 

in 2013 and 2014 (Johnson et al. 2015). 

Snow Goose

Currently, lesser snow geese are counted by USFWS MBM on two aerial surveys in Alaska each 

year: the Arctic Coastal Plain Breeding Pair Survey and the Teshekpuk Lake Molting Goose Survey. 

On the Arctic Coastal Plain, the 2018 snow goose total bird index was 35,215 (95% CI: 33,018 – 

37,412), 3.9% above (95% CI: -22 to 53%) the most recent 10-year average of 33,892 (95% CI: 

22,562 –45,222) birds (2009-2018; Wilson et al., In prep). The annual population growth rate 

calculated over the most recent 10 years on the Arctic Coastal Plain (2009–2018) was 1.114 (95% 

CI: 0.998 – 1.243) and 1.415 (95% CI: 1.226 – 1.632) over the long-term (1986–2018; Wilson et al., 

In prep),indicating a positive population growth trend for this species across the Arctic Coastal Plain 

(Stehn 2014; Stehn et al. 2013; USFWS, unpublished data). The 2017 Teshekpuk Lake snow goose 

count from the traditional molt survey area was 8,947 adults and 128 goslings, 20.3% above the most 

recent 10-year average of 7,435 birds (2008-2017; Shults and Zeller 2017). Snow geese represented 

the most rapid growth rate among all species surveyed on the Arctic Coastal Plain. 
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Snow geese nest in small numbers on the Colville River Delta (Johnson et al. 2005). During ground nest 

searches at CD3 (outside of the project study area) three successful snow goose nests (0.2 nests per square 

kilometer) were found around the proposed pad location in 2004; although, no brood-rearing snow geese 

were observed near CD3 in that year (Johnson et al. 2005). 

Aerial brood-rearing and fall staging surveys in the NPR-A Study Area observed 60 brood-rearing snow 

geese (0.10 bird per square kilometer) and 96 staging snow geese (0.16 bird per square kilometer) in 2004 

(Johnson et al. 2005). 

Ground-based nest search data was used to calculate snow goose nesting habitat selection in 2004. In the 

NPR-A Study Area, nesting snow goose utilized shallow open water with islands or polygonized margins, 

and young basin wetland complex within the search areas (Johnson et al. 2005). Both of these habitats are 

present in a very small percent of the project study area.

King Eider

Information presented below provides available site-specific and Arctic Coastal Plain-wide information 

regarding pre-nesting and nesting king eiders, including on-shore densities, population growth rates, and 

habitat selection of king eiders relevant to the project study area and is supplemental to information 

provided in BLM (2012, Section 3.3.5.5), BLM (2004a, Section 3.3.3.2), and BLM (2014, Section 

3.3.3.4), which are incorporated by reference here. 

King eiders breed along the Arctic coast of Alaska and are present in the project study area. The average 

annual population growth rate (total bird index) from 1986 to 2016 was 1.026, indicating a positive 

population growth trend for this species across the Arctic Coastal Plain (Stehn 2014; Stehn et al. 2013; 

USFWS, unpublished data).

Newly estimated density indices for the Arctic Coastal Plain using the latest 4 years of data (2012–2015) 

have been generated by USFWS (USFWS, unpublished data 2017) and these updated density indices 

were used to select estimated densities within the project study area by using a GIS analysis of density 

contour data. Ninety-nine percent of the estimated density index contours within the project study area 

fall in the low to moderated density ranges and are shown in Table 39ConocoPhillips and its predecessors 

have been conducting aerial surveys of pre-nesting eiders in the Colville Delta Special Area for 21 years 

(1993–1998, 2000–2016) and the NPR-A Study Area for 16 years (1999–2014). The survey areas and 

survey coverage differed among years.

The number of king eiders recorded in the Colville Delta Special Area in 2014 was well above average 

with the indicated density in 2014 about 50 percent higher than the 21-year mean (Johnson et al. 2015). 

King eiders were seen in all three of the subareas, but they achieved their highest density in the Northeast 

Delta subarea in 2014 (Johnson et al. 2015). 

King eiders were abundant in the NPR-A Study Area study area in 2014, occurring at almost three times 

the density recorded in the Colville Delta Special Area (Johnson et al. 2015). The indicated total number 

NPR-A Study Area was slightly below the 15-year mean. In 2014 the highest density of king eiders was 

seen in the Alpine West subarea (Johnson et al. 2015). 

ABR, Inc. Environmental Research & Service surveys have recorded a positive growth rate (1.064) for 

king eiders in the NPR-A Study Area over the past 13 years (Johnson et al. 2015). However, in the 

Colville Delta Special Area, where king eiders have a small breeding presence, the growth rate is minimal 

(1.006) and not significantly different from 1.0 over the past 21 years (Johnson et al. 2015). 
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Table 39. Estimated density contours of king eiders within project study area (2012–2015)

Density Index Contour 

(birds per km2)

Acreage within 

Project Study Area

Percent of 

Project Study Area

0–0.092 24,637.0 15.8

0.093–0.268 90,380.9 57.9

0.269–0.515 40,426.4 25.9

0.516–0.953 544.5 0.3

0.954–1.800 0 0

Source: USFWS unpublished data 2017.

In 2009, ground-based nest searches were conducted in a 400-meter buffer around the proposed GMT1 

and CD5 pads, as well as a 200-meter buffer surrounding the proposed road route between CD4 and 

GMT1. During these searches, five king eider nests were found (1.38 nests per square kilometer) (Seiser 

and Johnson 2011).

Pre-nesting king eiders used 19 of 24 available habitats in the Colville Delta study area over 21 years of 

aerial surveys preferring five habitats in the Colville Delta Special Area: Brackish Water, Salt Marsh, Saltkilled Tundra, River or Stream, and Deep Polygon Complex (Johnson et al. 2015). The high use of River 

or Stream, which includes the river channels primarily in the northeastern Delta Subarea, suggests that 

many birds were moving through to breeding areas farther east, because River or Stream is not a potential 

breeding habitat.

King eiders used 21 of 26 available habitats and preferred 11 habitats in the NPR-A Study Area in the 13 

years of pre-nesting surveys that were used to evaluate habitat selection with Old Basin Wetland Complex 

and both types of Deep and Shallow Open Water the most frequently used habitats and also were 

preferred (Johnson et al. 2015). The preferences for and high use of Open Nearshore Water, River or 

Stream, and Tapped Lake with Low-water Connection are likely from birds in transit or not yet settled 

into nesting habitat, because the fluctuating water levels of these waterbodies make their shorelines poor 

locations for nesting. Six habitats are significantly avoided, which include the two most available habitats 

in NPR-A Study Area, Moist Sedge-Shrub Meadow and Moist Tussock Tundra (Johnson et al. 2015). 

Greater White-Fronted Goose and Canada Goose

The greater white-fronted goose and Canada goose are common species along the Arctic Coast of Alaska 

and are present in the project study area. The summary presented below provides information from data 

collected on geese throughout the Arctic Coastal Plain and limited site-specific data in the project study 

area and is supplemental to information provided in BLM (2012, Section 3.3.5.5), BLM (2004a, Section 

3.3.3.2), and BLM (2014, Section 3.3.3.4), which are incorporated by reference here. 

As of 2004, the Canada goose was split into two species: Canada goose (Branta canadensis) and cackling 

goose (Branta hutchinsii) (Banks et al. 2004). The cackling goose is the common Canada goose species 

present in the project study area (Stehn et al. 2013). For the purpose of this section, “Canada goose” refers 

to both Canada goose and cackling goose. 

ConocoPhillips and its predecessors have been conducting aerial surveys of nesting and brood-rearing 

geese in the Alpine Satellite Development Plan and Colville River Delta Areas since 1999 and 1992, 

respectively (Johnson et al. 2005). The greater white-fronted goose was included in the Alpine Satellite 

Development Plan wildlife study surveys because of their importance as a subsistence species (Johnson et 

al. 2005). The survey areas and survey coverage have differed among years. 

Average annual greater white-fronted goose population growth rates of the greater white-fronted goose 

and Canada goose on the Arctic Coastal Plain from 1986 to 2016 were reported at 1.045 and 1.016 (total 
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bird index), respectively, indicating a positive trend in population growth for both species (Stehn 2014; 

Stehn et al. 2013; USFWS, unpublished data).

Newly estimated density indices for the Arctic Coastal Plain using the latest 4 years of data (2012–2015) 

have been generated by USFWS (USFWS, unpublished data 2017) and these updated density indices 

were used to select estimated densities within the project study area by using a GIS analysis of density 

contour data. For greater white-fronted goose, density index contours within the project study area range 

from 0.574–1.348 to 3.643–7.312 birds per square kilometer (Table 40). Moderate to high densities of 

greater white-fronted goose encompass almost 80 percent of the project study area; similar to densities 

that are exhibited across the entire Arctic Coastal Plain (Map 3.3-8). 

For Canada goose, density index contours within the project study area range from 0–0.083 to 0.543–

1.016 birds per square kilometer (Table 41). Moderate to high densities of greater white-fronted goose 

encompass almost 35 percent of the project study area (Map 3.3-8). 

Table 40. Estimated density contours of greater white-fronted goose within project study area (2012–2015)

Density Index Contour 

(birds per km2)

Acreage within 

Project Study Area

Percent of 

Project Study Area

0–0.573 0 0

0.574–1.348 31,851.1 20.4

1.349–2.323 28,856.6 18.5

2.324–3.642 33,484.6 21.5

3.643–7.312 61,796.7 39.6

Source: USFWS unpublished data 2017.

Table 41. Estimated density contours of Canada goose within project study area (2012–2015)

Density Index Contour 

(birds per km2)

Acreage within 

Project Study Area

Percent of 

Project Study Area

0–0.083 13,203.2 8.5

0.084–0.256 89,155.9 57.2

0.257–0.542 52,540.7 33.7

0.543–1.016 1,088.9 0.7

1.017–1.920 0 0

Source: USFWS unpublished data 2017

Three species of geese nested on the 40 10-hectare plots in the CD5 area in 2014 with greater whitefronted geese being the most abundant nesting waterfowl (28.7 nests/square kilometer), followed by 

Canada Geese (5.8 nests/square kilometer), and snow geese with 1 nest (Johnson et al. 2015). On the 

same plots in 2015 greater white-fronted geese were the most abundant nesting waterfowl (30.2 

nests/square kilometer) with nesting densities that have increased annually through the period of the study 

(2013–2015) and Canada geese were second in abundance (5.5 nests/square kilometer) (Rozell and 

Johnson 2016). 

In 2009, ground-based nest searches were conducted in a 400-meter buffer around the proposed GMT1 

and CD5 pads as well as a 200-meter buffer surrounding the proposed road route between CD4 and 

GMT1. Within the CD5 nest survey area, eight greater white-fronted goose nests were reported and no 

Canada goose nests, while within the GMT1 nest survey area, no nests were found for either species. 

Along the proposed road segments, a total of 55 greater white-fronted goose nests were reported, with 

approximately 73 percent found along the segment of proposed road between CD4 and the NPR-A 

boundary (Seiser and Johnson 2011).
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White-fronted geese nested in six habitats found on the nest plots in the CD5 area, though 83 percent of 

these nests were in just three habitats: Old Basin Wetland Complex, Patterned Wet Meadow, and Moist 

Sedge-Shrub Meadow and all habitats were used in proportion to availability and no habitat types were 

preferred or avoided (Johnson et al. 2015). Canada geese nested in four habitats, with most nests located 

in close proximity to waterbodies in the wetter habitats available (Johnson et al. 2015). 

3.3.3.5 Shorebirds

The summary presented below provides information from data collected on shorebirds throughout the 

Arctic Coastal Plain and limited site-specific data regarding nesting densities, nesting success, population 

growth rates, and habitat selection for shorebirds that occur in the GMT2 Project area. This information 

supplements BLM (2012, Section 3.3.5.6), BLM (2004a, Section 3.3.3.6), and BLM (2014, Section 

3.3.3.5), incorporated by reference here.

The average annual population growth rate for all shorebird species (shorebirds were not identified to the 

species level in this survey) was 1.039 (total bird index) from 1986 to 2016 (Stehn 2014; Stehn et al. 

2013; USFWS, unpublished data), indicating a positive population growth trend for shorebirds in general 

along the Arctic Coastal Plain.

A number of shorebird species were observed during ground-based nest searches conducted within 

breeding bird study plots and large waterbird survey corridors along a previously proposed road corridor 

between CD2 and the GMT1 pad area, and the GMT2 pad area proposed in BLM (2004a) (Burgess et al. 

2003; Johnson et al. 2004; Johnson et al. 2005). During the period 2001 to 2004, pectoral sandpiper (24 

nests, 10 nests per square kilometer) and semipalmated sandpiper (19 nests, 7.9 nests per square 

kilometer) were among the most common breeding shorebird species detected during the surveys 

(Burgess et al. 2003; Johnson et al. 2004; Johnson et al. 2005). Between 2002 and 2004, the five most 

abundant shorebird species within these same study plots were the pectoral sandpiper, semipalmated 

sandpiper, long-billed dowitcher, red- necked phalarope, and red phalarope. American golden plover, stilt 

sandpiper, dunlin, and bar-tailed godwit were also observed (Johnson et al. 2005). Overall shorebird nest 

density for all study plots in 2004 was 38.3 nests per square kilometer, with nesting success estimated at 

63 percent (64 percent and 60 percent in 2002 and 2003, respectively) (Burgess et al. 2003; Johnson et al. 

2004; Johnson et al. 2005). 

Four shorebird species nesting in the project study are listed by USFWS as Birds of Conservation 

Concern: whimbrel, bar-tailed godwit, dunlin, and buff-breasted sandpiper. Ground-based nest searches 

conducted in a portion of the GMT2 Project area between 2001 and 2004 recorded dunlin nests each 

breeding season at densities ranging from 1.3 to 2.5 nests per square kilometer (Burgess et al. 2003; 

Johnson et al. 2004; Johnson et al. 2005). Bar-tailed godwit nests were recorded in 2001 to 2003 at 

densities ranging from 0.4 to 1.7 nests per square kilometer (Burgess et al. 2003; Johnson et al. 2004). A 

bar-tailed godwit nest was also observed in 2009 along a study corridor between CD4 and the NPR-A 

Study Area A boundary (Seiser and Johnson 2011). Buff-breasted sandpiper nests were recorded only in 

2002 at a density of 2.5 nests per square kilometer (Burgess et al. 2003). Whimbrel nests were not 

observed during nest surveys, but individuals are reported to have been observed as part of various bird 

surveys in the NPR-A (Johnson et al. 2005). 

The red knot is a medium-sized shorebird listed as a BLM Sensitive Species. The breeding range in 

Alaska is only generally known. Within the NPR-A the red knot is a rare migrant on both the Chukchi Sea 

and Bering Sea coasts, but has been recorded breeding in small numbers near Utqiagvik (formerly 

Barrow) (BLM 2012). Nest surveys in both the Colville River Delta and NPR-A found no evidence of this 

species in the area (BLM 2004). Red knots were not surveyed in 2011 studies (Johnson et al. 2012). 
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Habitat selection for shorebirds varies depending on species and life stage. In general, habitats used by 

shorebirds for breeding, nesting, and brood-rearing differ from those used for pre-migratory staging 

(Connors and Connors 1982). Many shorebirds nest and rear broods in tundra habitats, then migrate to 

coastal littoral zone habitats for pre-migratory staging (Connors and Connors 1982). Using results of bird 

surveys and habitat information, Saalfeld et al. (2013) developed habitat suitability models for several 

shorebirds that breed on the Arctic Coastal Plain. In general, the suitability of breeding habitat for most 

shorebirds increased at lower elevations, suggesting that many shorebirds may favor wet or moist lowland 

habitats. Results of these habitat suitability models were generally consistent with observations of the 

regional spatial distributions of breeding shorebird populations (Johnson et al. 2007). For example, most 

breeding shorebirds on the Arctic Coastal Plain are observed more frequently near the coast than in the 

foothills of the Brooks Range (Johnson et al. 2007), and the low elevation wetland habitats that are 

generally preferred by several shorebirds are often located near the coast (Saalfeld et al. 2013). 

After breeding, but prior to their southern migration, many shorebirds stage on coastal littoral habitats 

where they forage and develop fat stores (Connors and Connors 1982). Species such as black-bellied 

plovers, red phalaropes, red-necked phalaropes, ruddy turnstones, and sanderlings tend to prefer gravel 

beach habitats, while dunlin and semipalmated sandpipers tend to prefer mudflats (Taylor et al. 2010). 

Other shorebird species tend to stage on salt marshes or the edges of ponds. Habitat preferences are likely 

influenced by prey availability, feeding mechanics, and foraging strategies (Connors et al. 1981). 

3.3.3.6 Raptors

Raptors are birds of prey that include falcons, hawks, eagles, and owls. Raptors that occur on the Arctic 

Coastal Plain, and therefore may be present within the project study area, are discussed in BLM (2012, 

Section 3.3.5.7), BLM (2004, Section 3.3.3.5), and BLM (2014, Section 3.3.3.6), incorporated by 

reference here.

The gyrfalcon and the snowy owl are the only raptors known to overwinter in the NPR-A; all other 

raptors migrate south to overwinter (Johnson and Herter 1989). Arctic peregrine falcons, gyrfalcons, 

merlins, golden eagles, and rough-legged hawks nest on cliffs along the Colville River and other rivers in 

the Arctic foothills region of the NPR-A where suitable habitat is present (Swem et al. 1992; Ritchie et al. 

2003). Although, the bluffs along the lower reaches of the Colville River and adjacent wetlands are 

important raptor nesting habitat, they are well outside of the GMT2 Project area; nearby bluff habitat is 

limited to small silt bluffs along the GMT2 Project area streams and some lakeshores. All of these species 

do use the general area to some extent for hunting during nesting and/or migration. The closest 

documented peregrine falcon nesting activity in 29 years of ground-based surveys is approximately 7 

miles southeast of the proposed GMT2 pad (BLM 2012). However, because peregrine falcon numbers 

have increased substantially in the past 20 years and have begun to use lake bluffs and other coastal 

habitats, not all suitable nesting habitat for peregrine falcons has been covered by the ground or aerial 

surveys in the GMT2 Project area (Ritchie et al. 2003; Ritchie 2014). Residents of Nuiqsut reported 

nesting peregrine falcons on the lower reaches of Fish Creek (BLM 2014) and at least one small bluff site 

on lower Fish Creek has been used for nesting by peregrines in recent years (Ritchie 2014). This nest site 

is approximately 8 miles northeast of the western boundary of the GMT2 Project area.

The golden eagle occurs in NPR-A as a migratory species and is listed as a BLM Sensitive Species. The 

northern distribution limit of the breeding range for the golden eagle is the northern foothills of the 

Brooks Range. The closest documented golden eagle nesting activity in 29 years of ground-based surveys 

is approximately 100 miles from the GMT2 Project area boundary along the drainages of the Chandler 

and Sagavanirktok rivers in the Brooks Range foothills (Wildman and Ritchie 2000). Golden eagles, 

predominantly subadults, have been reported in the Arctic Coastal Plain during spring and summer 

seasons (McIntryre et al. 2008; Ritchie 2014), and local residents in the Nuiqsut area have reported 
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occasional eagle sightings in the GMT2 Project area (BLM 2014). Golden and bald eagles have been 

recorded preying on yellow-billed loon nests in the NPR-A Study Area (Johnson et al. 2015). 

The snowy owl, short-eared owl (a BLM Sensitive Species), and northern harrier, all ground- nesting 

species, are widely dispersed and nest irregularly throughout the NPR-A (BLM 2012, Section 3.3.5.7). 

Northern harriers are fairly common visitants on the Arctic Coastal Plain (Johnson and Herter 1989), but 

are thought to be rare breeders. Both owl species, however, may breed more often in the NPR-A when 

high numbers of their cyclic small mammal prey occur (Holt and Leasure 1993; Parmelee 1992). 

Observations of ground-nesting raptors have been reported during ground-nest searches for large 

waterbirds in the GMT2 Project area. A single northern harrier nest was found in the CD4 area in 2001 

(Burgess et al. 2002). One short-eared owl nest was located in the Alpine search area in 1996 and three 

nests were located in the CD south search area in 2001, which were the only raptor nests found in 6 years 

of nest searches in those areas (1996−2001) (Johnson et al. 2003b; Burgess et al. 2002). Short-eared owls 

and norther harriers were reported depredating loon nests in 2013 (Johnson et al. 2015).

3.3.3.7 Yellow-billed Loon

The yellow-billed loon was selected as a focal avian species due to conservation concern. It was 

designated as a candidate for protection under the Endangered Species Act in March of 2009 and on 

October 1, 2014, the USFWS made the decision that listing the yellow-billed loon under the Endangered 

Species Act was not warranted (Federal Register, Volume 79, Number 190, page 59195). The yellowbilled loon is still recognized as a special status species by the BLM and as a species of conservation 

concern by the USFWS. Yellow-billed loons are discussed in BLM (2012, Section 3.3.5.5), BLM (2004, 

Section 3.3.3.2), and BLM (2014, Section 3.3.5.3), which are incorporated by reference here. 

USFWS (2014) estimated the worldwide population of yellow-billed loons to be between 16,000 and 

32,000 individuals, with approximately 3,000 to 4,000 individuals breeding in Alaska’s two known 

breeding locations: the Arctic Coastal Plain of the North Slope and the area surrounding Kotzebue Sound 

in northwest Alaska. The estimated population growth rate for yellow-billed loons on the Arctic Coastal 

Plain indicates a positive trend over both the long term (1.016 for 1986−2016) and the most recent 

10-year period (1.023 for 2007−2016) (Stehn 2014; Stehn et al. 2013; USFWS, unpublished data).

Newly estimated density indices for the Arctic Coastal Plain using the latest 4 years of data (2012–2015) 

have been generated by USFWS (USFWS, unpublished data 2017) and these updated density indices 

were used to select estimated densities within the project study area by using a GIS analysis of density 

contour data. Density index contours within the project study area range from 0–0.022 to 0.196–0.501 

birds per square kilometer, and encompass all five density contours present on the Arctic Coastal Plain 

(Map 3.3-9, and Table 42). Just over half of the project study area is contained within the lowest two 

density bands; and less than 2 percent of the project study area lies within the highest density contour.

Table 42. Estimated density contours for yellow-billed loons on the Arctic Coastal Plain (2012–2015)

Density Index Contour 

(birds per km2) 

Acreage within 

Project Study Area

Percent of Project 

Study Area

0–0.022 35,526.2 22.8

0.023–0.067 47,640.6 30.5

0.068–0.124 44,646.1 28.6

0.125–0.195 25,453.7 16.3

0.196–0.501 2,722.3 1.7

Source: USFWS unpublished data 2017.
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Aerial surveys covering the project area were conducted in the initial years of avian surveys from 

2001−2004. During this time, very few observations of yellow-billed loon nests or broods were recorded 

within 1 mile of the then proposed roads or facilities for GMT1 and GMT2 (BLM 2004; Johnson et al. 

2005). During 2004−2013, surveys within the NPR-A Study Area focused on the Fish and Judy Creek 

Corridor Subarea, Fish Creek Subarea, and Alpine West Subarea (all subareas include portions of the 

GMT2 Project area as described in Table 34 and Map 3.3-9 (Johnson et al. 2014). In 2014, yellow-billed 

loon surveys were expanded south of the Fish and Judy Creek Corridor Subarea, to include a 3-mile 

buffer around the proposed GMT1 and GMT2 pads labeled GMT Corridor Subarea (Map 2.1-2) (Johnson 

et al. 2015). Both Colville Delta Special Area Subareas relevant to the project area (CD North and CD 

South Subareas) have been included in aerial surveys from 1993 to 2014, with the exception of years 

1994 and 1999.

Due to variation in coverage of lakes in the Colville Delta Special Area and NPR-A Study Area during the 

different years that nesting surveys were conducted, counts of nests were not directly comparable. 

Accordingly, a surrogate comprised of territory occupancy of nests (number of nests found divided by the 

number of territories surveyed) was calculated in order to compare annual occupation of nests. Population 

trends were estimated using territory occupancy by adults and territory occupancy of nests from 1993–

2014 for the Colville Delta Special Area and from 2001–2014 for the NPR-A Study Area. Based on these 

analyses and years, the number of adults in both regions appear to have increased and 2014 nest 

occupancy values for both areas are above the combined year mean (Johnson et al. 2015).

In 2014, 32 nests were found within the Colville Delta Special Area, with approximately 97 percent of the 

nests on lakes where yellow-billed loons have nested previously with 16 nests were recorded in the CD 

South Subarea and 15 in the CD North Subarea making the 2014 total nest count the third highest in 20

years of surveys (Johnson et al. 2015). In 2015, 25 nests were recorded with 13 nests located in the CD 

North Subarea, 10 nests in the CD South Subarea, and 2 nests in the Northeast Delta Subarea with the 

total number of nests nearly identical to the long-term mean (Johnson et al. 2016).

In the NPR-A Study Area, 20 nests were recorded, with a single nest located in the Alpine West Subarea, 

6 nests in the Fish Creek Delta Subarea, 9 nests in the Fish and Judy Creek Corridor Subarea, and 4 nests 

were in the GMT Corridor Subarea (Johnson et al. 2015). Nest occupancy values recorded in the NPR-A 

Study Area were higher than the long-term mean (77 percent and 66.2 percent, respectively) (Johnson et 

al. 2015). Yellow-billed loon surveys were not conducted in the NPR-A Study Area in 2015.

During brood-rearing surveys in 2014, 4 broods were found in the Colville Delta Special Area and 11 

broods were found in the NPR-A Study Area (Johnson et al. 2015). Territory occupancy by broods in the 

Colville Delta Special Area during 2014 was 19 percent, approximately 60 percent of the long-term 

average for all survey years (31.1 percent) while territory occupancy by NPR-A Study Area broods was 

35 percent, higher than the mean for all years of 27.8 percent (Johnson et al. 2015). In both the Colville 

Delta Special Area and NPR-A Study Area surveyed during 2014, less than 10 percent of the nests found 

were within 3 miles of the proposed GMT2 pad and road (Johnson et al. 2015).

Nesting yellow-billed loons in the Colville Delta Special Area in 2014 utilized 11 of 24 available habitats, 

preferring 6 which occur in the project area, while nesting yellow-billed loons utilized 13 of 26 available 

habitats in the NPR-A Study Area, preferring 5 which occur in the project area (Johnson et al. 2015). 

Yellow-billed loons nested in 12 of 24 available habitats during nesting surveys conducted in the Colville 

Delta Special Area over 21 years with 7 habitats, supporting 435 of 481 total nests, were preferred for 

nesting (Deep Open Water with Islands or Polygonized Margins, Deep Open Water without Islands, 

Sedge Marsh, Grass Marsh, Deep Polygon Complex, Non-Patterned Wet Meadow, and Patterned Wet 

Meadow) (Johnson et al. 2016). 
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Cameras placed at yellow-billed loon nests in both the NPR-A Study Area and Colville Delta Special 

Area have documented egg predation by a variety of predators including glaucous gull, parasitic jaeger, 

common raven, golden eagle, bald eagle, red fox, wolverine, and grizzly bear. After camera monitoring in 

2008 to 2014, 47 percent of the monitored nests had predation losses of at least one egg. The results of 

this study also highlight the importance of minimizing human disturbance to nests, because the majority 

of predation occurred at unattended nests (Johnson et al. 2015). 

Three recent studies (Rizzolo et al. 2014, Uher-Koch et al. 2015, Uher-Koch et al. 2018) looked at the 

effects of disturbance on loon nest success. Rizzolo et al. (2014) studied red-throated loons at 5 sites in 

Alaska (Cape Espenberg, the Copper River Delta and the Yukon-Kuskokwim Delta while Uher-Koch et 

al. (2015) studied Pacific and yellow-billed loons on the ACP and Uher-Koch et. al (2018) looked at redthroated, Pacific and yellow-billed loons on the ACP. 

Rizzolo et al. (2014) found that models of nest survival indicated that human visits to monitor redthroated loon nests had a negative effect on nest daily survival probability, which if not accounted for 

biased nest survival strongly downward. And that nest daily survival probability at the Yukon-Kuskokwim 

Delta was negatively associated with an annual index of fox occurrence. This study also determined that 

productivity on the Yukon-Kuskokwim Delta was not sufficient to maintain population stability in 2 of 

3 years, indicating that nest depredation by foxes and poor foraging conditions during chick rearing can 

have important effects on productivity. 

Uher-Koch et al. (2015) evaluated the impacts of investigator disturbance associated with loon captures 

and nest visits on nest survival of yellow-billed and Pacific loons in the NPR-A and determined that loon 

breeding success is negatively associated with observer disturbance at the nest site. They found that 

the effect of loon captures on nest survival was similar between capture methods and that nest visits 

without captures also negatively impacted nest survival, although less than captures. Effects of 

investigator disturbance did not differ by species or between years suggesting that any source of 

disturbance that displaces incubating adult loons could potentially reduce nest survival. 

Nest predation is one of the major causes of nest failure among tundra breeding birds (Liebezeit et al. 

2011, Meixell and Flint 2017), and nest site selection may be an adaptive response to predators in some 

species (Forstmeier and Weiss 2004). Uher-Koch et al. (2018) suggest that Pacific and yellow-billed 

loons choose nest sites based on nest predation risk with Pacific and yellow-billed loons nesting on island 

and peninsula nest sites having the highest nest survival rates, likely due to reduction in terrestrial 

predator access to nests (Bergman and Derksen 1977, Petersen 1979). Shoreline nests are exposed to 

terrestrial predators (e.g., Arctic foxes), while island nests are vulnerable to avian predators (e.g., gulls 

and jaegers); however, because of their large body size, loons are usually able to defend their clutches 

from avian predators. The preference of island and peninsula sites for nesting Pacific and yellow-billed 

loons suggests that terrestrial predators have a greater influence on nest survival than avian predators. Fox 

abundance can negatively influence loon nest survival (Rizzolo et al. 2014), and high Pacific and yellowbilled loon nest survival rates have been found to coincide with years of low fox activity in other areas on 

the ACP (Bergman and Derksen 1977, North and Ryan 1988). Microtine abundance on the ACP is 

cyclical and years of high microtine abundance often coincide with years of high nest survival, as typical 

terrestrial and avian nest predators prey on more microtines and less eggs (Liebezeit et al. 2011).

3.3.4 Mammals

This section presents information about terrestrial mammals that occur, or are suspected to occur, in the 

GMT2 Project area (Table 43 and Table 44).
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The project area is entirely onshore, with all facilities and pipelines located more than 5 miles from the 

Beaufort Sea Coast line in Harrison Bay (see Map 3.1-1). Essentially all mammals with a potential for 

impact are terrestrial, with the exception of the polar bear, a marine mammal (discussed in Section 3.3.5). 

In the unlikely event of a very large oil spill reaching coastal open water, some individual marine 

mammals could be present in the affected area and may be adversely affected. A brief discussion of 

marine mammals is provided in Section 3.3.4.2. 

3.3.4.1 Terrestrial Mammals

Terrestrial mammals and their habitats are discussed in BLM (2004a; 2012; 2014). Table 43 lists 

terrestrial mammal species that occur in the vicinity of the GMT2 Project.
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Table 43. Terrestrial mammal species known or suspected to occur in the project area

Common Name Scientific Name Iñupiaq Name Size

caribou Rangifer tarandus tuttu Large

brown bear; grizzly bear Ursus arctos akjaq Large

moose Alces alces tuttuvak Large

muskox Ovibos moschatus umifmak Large

wolf Canis lupus amabuq Large

wolverine Gulo gulo qavvik Large

red fox Vulpes vulpes kayuqtuq; qianbaq; 

qibñiqtaq

Large

barren-ground shrew Sorex ugyunak ugrugnaq; ugrufnaq Small

tundra shrew Sorex tundrensis ugrugfnaq; ugrufnaq Small

Arctic ground squirrel Spermophilus parryii siksrik; sigrik Small

brown lemming Lemmus trimucronatus aviffapiaq; aviffaq; 

aviñfauraq

Small 

collared lemming Dicrostonyx groenlandicus qixafmiutaq; qixafmiutauraq Small

singing vole Microtus miurus aviñfaq; aviffaq Small

tundra vole Microtus oeconomus aviñfaq; aviffaq Small

ermine (short-tailed 

weasel)

Mustela erminea itibiaq Small

least weasel Mustela nivalis naulayuq Small

Source: Modified from Table B-8 of PAI (2002), including updated scientific names from recent taxonomic revisions (MacDonald and 

Cook 2009; Bradley et al. 2014) and inclusion of some additional Iñupiaq names (MacLean 2012). Several species considered to be 

rare or accidental (at the limits of their range) are omitted.

None of the terrestrial mammals reported to occur within the proposed GMT2 Project area is currently 

listed under the Endangered Species Act, or is on the federal or state Endangered Species Act lists. The 

BLM has identified the Alaska hare (Lepus othus) and the Alaska tiny shrew (Sorex yukonicus) as 

sensitive mammal species in Alaska that may occur in the NPR-A; however, based on Cason et al. (2016), 

there have been no reliable reports of Alaska hare on the North Slope in several hundred years, and no 

report of the Alaska tiny shrew in the NPR-A (BLM 2012). Neither species is known to occur in or near 

the project area.

Caribou

Caribou are present on the North Slope year-round. Four caribou herds calve on the North Slope: the 

Western Arctic Herd, Teshekpuk Caribou Herd, Central Arctic Herd, and the Porcupine Caribou herd. 

The Alpine Satellite Development Plan Study Area, including the proposed GMT2 Project area, is located 

at the interface between the Teshekpuk Caribou Herd and Central Arctic Herd ranges, with the Teshekpuk 

Caribou Herd generally ranging west of the Colville River delta and Central Arctic Herd ranging east of 

the delta (Lawhead et al. 2015) (Figure 10). The GMT2 Project area is on the periphery of the Western 

Arctic Herd range, and is not within the range of the Porcupine Caribou Herd (BLM and Minerals 

Management Service 2003, Lawhead et al. 2013). Therefore, the Western Arctic Herd and Porcupine 

Caribou Herd are not discussed further. 

Teshekpuk Caribou Herd and Central Arctic Herd caribou biology, population status, seasonal ranges and 

distribution, migration patterns, calving, and harvest in the NPR-A are described extensively in BLM 

(2012). ADF&G documented this information, as well as comprehensive inventory and management 

activities for the Western Arctic Herd, Teshekpuk Caribou Herd, and Central Arctic Herd in Dau (2013), 

Parrett (2015), and Lenart (2015). ConocoPhillips has conducted a study of caribou movements and 

distribution in the northeastern portion of the NPR-A since 2001 (Prichard et al. 2017). Information on 
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caribou in the Alpine Satellite Development Plan is included in BLM (2004a; 2014). The relevant content 

of these documents and references is summarized herein. 

Figure 10. Generalized ranges for the Teshekpuk Caribou Herd and Central Arctic Herd Ranges in Relation to 

the GMT2 Project Area. 

Research Activities

Caribou calving and post-calving distribution and abundance have been surveyed between the Colville 

and Kuparuk rivers annually since 1993 as part of ongoing ConocoPhillips monitoring studies. In 2001, 

ConocoPhillips began sponsoring caribou surveys in the northeastern portion of the NPR-A in advance of 

the Alpine Satellite Development Project. In the construction permit for CD4 (the first Alpine Satellite 

Development Plan development), the North Slope Borough stipulated that a 10-year study of 

development impacts on caribou distribution and movements be conducted within a 30-mile radius of 

CD4 (referred to as the “Alpine Satellite Development Plan Study Area”) (Figure 11). The study area 

encompasses the CD3, CD4, CD5, GMT1, and GMT2 Project areas. It also is used as both winter and 

summer range by the Teshekpuk Caribou Herd and as summer range for some of the Central Arctic Herd 

(BLM 2004a; 2012). The study began in 2005 and built on research that had been ongoing on caribou in 

the area since the early 1980s (Lawhead et al. 2013). The stipulation was later amended to account for 

additional development in the Alpine Satellite Development Plan area and, at the request of Nuiqsut 

residents, wording regarding the 30-mile radius was removed (Lawhead et al. 2013). The 30-mile radius 

is still used, however, in the monitoring study as a basis for comparing data among years. 

The tenth consecutive year of the Alpine Satellite Development Plan caribou monitoring study was 

completed in 2014 and is summarized by Lawhead et al. (2015). ConocoPhillips has continued the study 

past the 10 years originally stipulated, and in 2017 published the 12th annual report encompassing the 

results for 2015 and 2016 (Prichard et al. 2017). The study combines results from aerial transect surveys 

of caribou with radio-telemetry data from collared caribou. Three areas are surveyed annually: NPR-A, 
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Colville River Delta, and Colville East (Figure 11). The southeastern portion of the NPR-A survey area 

contains the proposed pipeline and road corridor to GMT2 (Lawhead et al. 2015).
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. 

Figure 11. Location of the Alpine Satellite Development Plan Caribou Monitoring Study Area (2001−2017)
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Habitat Use

Caribou use various habitats throughout their annual range during the year (Table 44). Their distribution 

and seasonal movements are heavily influenced by life history events (e.g., calving, migration) and 

environmental factors (e.g., insect harassment, plant phenology) (Lawhead et al. 2015). 

During winter and early spring, the caribou diet throughout much of their range is dominated by lichens, 

which are present throughout their winter range. However, this may not be the case for individuals that 

winter on the north slope where lichen abundance is relatively low (Parrett 2007, Joly and Cameron 

2018).In spring and early summer, caribou migrate north as vascular plants become available. The timing 

is dependent on snowmelt and temperature. Traditional calving grounds typically offer highly nutritious 

forage in the spring and have low densities of predators (BLM 2012). The availability of high quality and 

quantity of desired forage species (influenced by temperature and snow cover) probably affects specific 

calving locations and calving success (BLM 2012). Caribou in the NPR-A survey area generally showed 

selection for areas with high vegetative biomass, despite seasonal and annual variability (Lawhead et al. 

2015). 

Wilson et al. (2012) used telemetry data to analyze patterns of resource selection by Teshekpuk Caribou 

Herd caribou over the entire summer range of the herd. Patterns of selection varied from calving through 

post-calving and late summer, but caribou consistently avoided patches of flooded vegetation and tended 

to prefer areas with greater abundance of sedge-grass meadow. When insect harassment was low, 

Teshekpuk Caribou Herd animals primarily selected areas around Teshekpuk Lake. During the insectharassment season (late June to early August), caribou demonstrate preference for coastal beaches, 

riverine sand bars and dunes (specifically along Fish Creek and Judy Creek), and coastal barrens in 

response to mosquito and oestrid-fly harassment (Wilson et al. 2012; Lawhead et al. 2015). Movements to 

these insect relief areas can be abrupt and dramatic. Although analytical methods differed, these results 

generally match statistical test results from aerial survey data collected in the Alpine Satellite 

Development Plan Study Area (Prichard et al. 2017). Prichard et al. (2017) found that from 2002-2016, 

caribou in the NPR-A survey area used flooded tundra significantly less than expected (based on the 

amount of area available) during calving, post-calving, fall, and winter. Riverine habitats were used more 

than expected (relative to availability) from post-calving through late summer, possibly to access areas 

more abundant forage and seek oestrid-fly relief and were avoided during winter.

Table 44. Caribou forage habitats within the GMT2 Project area

Caribou Life Cycle Stage Habitat Type

Summer Forage/Calving Habitat Moist Sedge-Shrub Meadow, Moist Tussock Tundra

Caribou Insect Relief Habitat Barrens, Riverine

Caribou Winter Forage Habitat Lichen-Bearing Habitats

Source: BLM (2012) and Lawhead et al. (2015).

Density and Distribution

The GMT2 Project area is located near the eastern edge of the Teshekpuk Caribou Herd range (Figure 

3.3-1). Map 3.3-10 presents the seasonal utilization distribution of instrumented Teshekpuk Caribou Herd 

and Central Arctic Herd females using GPS and satellite tracking methods. The Teshekpuk Caribou Herd 

inhabits the project area throughout the year, although usually at low densities. Members of the 

Teshekpuk Caribou Herd demonstrate high fidelity to calving areas surrounding Teshekpuk Lake, 

extensive use of coastal habitat for insect relief, and broad use of the coastal plain west of the Colville 

River drainage in late summer (Parrett 2015). While the Teshekpuk Caribou Herd is unique in that the 

majority of the herd typically remains on the coastal plain through the winter in many years, its use of 
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winter ranges is highly variable (Parrett 2013). The only times of year when Teshekpuk Caribou Herd 

caribou are predictably distributed is during the insect season and late summer (Parrett 2013) and often 

during calving season. 

Absolute densities of caribou often are fairly low, as caribou herds in northern Alaska cover vast areas. 

Map 3.3-10 indicates that the project area occurs within the high use contour of collared females in three 

out of the eight displayed periods of the year, and in the medium use contour during another three periods. 

The three periods of overlap with the high use contour (fall migration, winter, and spring migration) cover 

the majority of the year, spanning about 7-8 months of the year. In some years, winter and fall densities 

can be high in absolute, as well as relative, terms (Figure 12).Although some Teshekpuk Caribou Herd 

calving occurs in the western half of the Alpine Satellite Development Plan Study Area, where the GMT2 

Project area is located, it is not considered an area where concentrated calving takes place (Lawhead et al. 

2015) (Map 3.3-10). Most Teshekpuk Caribou Herd females calve in the northeastern portion of the NPRA near Teshekpuk Lake. Wilson et al. (2012) modeled land use by pregnant females during calving and 

found that areas predicted to have a high probability of use were almost entirely restricted to the area 

surrounding Teshekpuk Lake. 

Year-round Teshekpuk Caribou Herd caribou density in the NPR-A survey area is low (< 1 caribou per 

square kilometer), and tends to decrease from west to east (Figure 3.3-2) (Lawhead et al. 2015). From 

2001-2016, the highest densities of caribou in the NPR-A survey area typically have occurred during the 

mosquito and oestrid-fly harassment periods in mid to late summer, and from mid-September through late 

October during fall migrations (Figure 12) (Prichard et al. 2017). 

Teshekpuk Caribou Herd caribou density tends to be lowest in the southeastern portion of the NPR-A 

survey area, where the proposed GMT2 Project infrastructure would be located (Lawhead et al. 2015). 

The GMT2 Project area is used by the Teshekpuk Caribou Herd in winter, but the amount of use varies 

substantially among years (BLM 1998b, Lawhead et al. 2015). During most years, the majority of the 

Teshekpuk Caribou Herd winter on the Arctic Coastal Plain, sometimes including the GMT2 Project area. 

High densities (> 2 caribou per square kilometer) have been recorded occasionally in the NPR-A survey 

area during late winter (Lawhead et al. 2015). 

The GMT2 Project area is located at the western edge of the Central Arctic Herd range. The majority of 

the Central Arctic Herd remains east of the Colville River and calves primarily in the Colville East survey 

area, well outside the GMT2 Project area (Map 3.3-10) (BLM 2004a; Lawhead et al. 2015) in addition to 

core calving area east of the Dalton Highway. Central Arctic Herd movements into the NPR-A are 

uncommon; the last substantial event occurred in July 2001 when approximately 6,000 Central Arctic 

Herd caribou were observed moving west across the Colville River delta into the NPR-A (Lawhead et al. 

2015). While overall use of the NPR-A by members of the Central Arctic Herd is low, the Alpine Satellite 

Development Plan Study Area does contain areas of high density utilization by the Central Arctic Herd, 

specifically during the mosquito and oestrid-fly seasons (Map 3.3-10). 
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Figure 12. Seasonal caribou density observed on 119 surveys of the NPR-A Survey Area, April−October 

2001−2017 

Note: Error bar represents 95 percent confidence intervals.

Source: Lawhead Prichard et al. (2018), Figure 66. 

Population Dynamics 

Both the Teshekpuk Caribou Herd and Central Arctic Herd have undergone recent changes in size, 

demography, and distribution. Both populations declined, in part due to decreased survival of adults and 

calves during the prolonged winter of 2012-2013 (Lawhead et al. 2015) and low calf production (Parrett 

2015). The Teshekpuk Caribou Herd declined in recent years due to a combination of high adult 

(specifically female) mortality and low calf production (Parrett 2015). The underlying mechanisms of 

increased mortality and decreased calf production are not totally understood, but are likely related to poor 

nutrition, difficult winter weather conditions, high calf predation, and nutritionally mediated risk of 

predation (Parrett et al. 2014). 

Between 1984 and 2008, ADF&G estimated that the Teshekpuk Caribou Herd grew from 11,822 to a peak 

of more than 68,000 animals in July 2008, a rate of approximately 7% per year (Davis et al. 1979, Carroll 

1992, Parrett 2011, Parrett 2015). A July 2011 photocensus estimated the herd numbered 55,704 animals 

(Parrett 2015), a decline of at least 19% from the 2008 estimate. A photocensus conducted in July 2013, 

produced an estimate of 39,172 animals (including ~7,000 animals that were mixed with the Western 

Arctic Herd at the time of the census; Parrett 2015), a further decrease of at least 30% since 2011. Another 

photocensus in July 2015, produced a minimum count of 35,181 caribou and an accompanying estimate 

of 41,542 animals (Lincoln Parrett, Caribou Biologist to Peter Bente, RV Management Coordinator, 

“Memorandum: Summary of Teshekpuk Caribou Herd Photocensus Conducted July 6, 2015,” December 

31, 2015) indicating the population decline had slowed. 

The Central Arctic Herd increased substantially between 1995 and 2008 at a rate of 10-13% per year, 

growing from 18,824 to 66,666 animals during that time (Lenart 2015). The herd size peaked in 2010, 
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when ADF&G estimated that there were 68,442 animals. Since 2010, the herd has declined. The 

population size was 50,753 in 2013 and decreased by over half to 22,630 caribou in 2016 (Lenart 2015, 

ADF&G 2016). 

A new digital photo system was implemented by ADF&G in 2017 to conduct photocensus estimates for 

both caribou herds on the North Slope. The 2017 photocensus of the Teshekpuk Caribou Herd showed a 

minimum herd estimate of 56,255 caribou and a statistical estimate of 55,614 (SE 2909) animals. Results 

from the newer photo equipment indicate that the population has increased since 2015 (R. Klimstra, 2017) 

(Fig. 12). 

A similar camera system was used to conduct a photocensus in July 2017, for the Central Arctic Herd. 

The results showed a minimum herd estimate of 27,115 caribou and a statistical estimate of 28,051 (SE 

765) animals. The difference in the population estimates from 2016 to 2017 is attributed to better quality 

photos rather than an increase in population size and demographic data collected during this period 

indicated the herd may be closer to stability than increasing (Lenart, 2018). 

Overlap of the Teshekpuk Caribou Herd with the Western Arctic Herd and Central Arctic Herd can be 

extensive during fall and winter. Movement between the Teshekpuk Caribou Herd and Western Arctic 

Herd, and the Teshekpuk Caribou Herd and Central Arctic Herd has been a persistent feature of these 

herds (Person et al. 2007). The calving distribution of the Teshekpuk Caribou Herd has recently expanded 

to the west and southeast, but it is not clear if this expansion has increased emigration rates within the 

Western Arctic Herd and Central Arctic Herd) (Parrett et al. 2014, Lawhead et al. 2015). Person et al. 

(2007) detected an apparent emigration rate of 6.9 percent for the Teshekpuk Caribou Herd. While 

emigration and immigration among these herds have been consistently documented (Prichard et al. 2001, 

Yokel et al. 2009, and others), they are thought to play a minor role in contributing to changes in herd 

population size (Lenart 2015). 

Muskox

The history, distribution, and habitat preferences of muskoxen are described previously in BLM (2012). 

Muskoxen historically occurred throughout northern Alaska, but no longer occur consistently in what is 

now the eastern NPR-A. Their population in northeastern Alaska was re-established by translocation to 

Barter Island and the Kavik River in 1969 and 1970. As their numbers on the Arctic Coastal Plain 

increased, their range expanded westward to the Colville River and eastward to the Babbage River in 

Yukon Territory.

Although small numbers of muskoxen have occasionally been observed west of the Colville River, they 

are neither regular nor abundant in the project area. Muskoxen have been noted in the Colville River 

Delta area since 1993. In 2012, one group moved west into the NPR-A, but the group evidently fell 

through thin ice and drowned in a lake (Lawhead et al. 2015). In previous years (2005−2007) a group of 

muskoxen were observed between the Kalikpik River and the Fish Creek Delta (Lawhead et al. 2013). 

Although the current North Slope population of muskoxen is reportedly stable or in slight decline (Arthur 

and Del Vecchio 2013), the population on the central North Slope could potentially expand into the 

GMT2 Project area. According to Danks (2000), suitable habitat exists in the northeastern portion of the 

NPR-A, although near the project area there are no ridges where winds can minimize snow depths in 

winter as on the western North Slope where muskoxen have been established since the 1970s (Harper 

2013). 

Moose

The occurrence of moose on the Arctic Coastal Plain, including the GMT2 Project area, was discussed 

previously by BLM (2004a; 2012). Moose occur at low densities on the Arctic Coastal Plain, which is at 

the northern limit of their range in Alaska (BLM 2004a). Moose are widely distributed, but generally 
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found in areas with shrub vegetation. During the summer they range from the northern foothills of the 

Brooks Range to the coast of the Arctic Ocean. As snow accumulates in autumn, moose move to riparian 

corridors of the larger river systems, where they are relatively concentrated during winter. The largest 

winter concentrations of moose occur in the inland portions of the Colville River drainage (BLM 2004a). 

As noted by BLM (2004a), only five moose were seen at Colville Village during eight years (1992–1998 

and 2001) of observations by the Helmericks family. To the southwest, moose have been recorded 

sporadically in the NPR-A Survey Area near Fish Creek (Lawhead et al. 2009, 2014a). 

Grizzly Bear

The density of grizzly bears is lower (0.5–2.0 bears per 1,000 square kilometers) on the Arctic Coastal 

Plain than in the mountains and foothills of the Brooks Range. The factors that influence grizzly bear 

density throughout the NPR-A were discussed by BLM (2004a; 2012). A study carried out between 1999 

and 2004 marked 25 grizzly bears and documented their dens in the Colville River Delta, the Fish Creek 

and Judy Creek Deltas, and other riparian areas in and near the GMT2 Project area (BLM 2004a). 

Incidental observations of grizzly bears and their dens have been recorded during surveys for caribou and 

fox dens since 2001 throughout the Alpine Satellite Development Plan Study Area (Johnson et al. 2005; 

Lawhead 2014b). The GMT2 Project area and adjacent areas of the northeastern portion of the NPR-A 

provide good habitat for grizzly bears, with suitable well-drained denning habitat and ground squirrel 

habitat (BLM 2004a, citing Shideler 2004, personal communication).

Fox

The Arctic fox is the most common furbearer in the GMT2 Project area as well as on the Colville River 

Delta and adjacent coastal plain. A discussion of Arctic fox population status, diet, habitat, and denning 

was presented by BLM (2004a). Arctic fox populations fluctuate with the availability of prey species 

(e.g., lemmings and voles) and the occurrence of rabies epidemics. Foxes not supplemented by 

anthropogenic food sources are shown to utilize vast (10,050 km) winter home ranges as the search for 

food (Pamperin 2008; Lehner 2012). For denning, they prefer well-drained soils (e.g., riparian or upland 

shrub habitat), including banks of lakes and streams, drained lake basins, and pingos. During fox den 

surveys conducted in 2001–2004 (BLM 2004a; Johnson et al. 2005), Arctic foxes were observed regularly 

in the GMT2 Project area.

Red foxes are also found in the GMT2 Project area, but generally in lower numbers than Arctic foxes. 

According to local knowledge, the number of red foxes has increased recently, corresponding with 

warmer winters (BLM 2012). A similar increase has been documented in the oilfields east of the Colville 

River (Stickney et al. 2014). Red foxes use denning habitats similar to those used by Arctic foxes. Red 

foxes are aggressive toward Arctic foxes, will displace them from feeding areas and den sites, and may 

even kill them if the opportunity arises (Johnson et al. 2005; Stickney et al. 2014). 

Wolf

Wolves occur in the GMT2 Project area, but are uncommon (Lawhead et al. 2013; Johnson et al. 2005; 

BLM 2012). In general, wolves are more abundant in the Brooks Range than on the Arctic Coastal Plain, 

probably because of better prey availability in the foothills and mountains, limited den sites on the Arctic 

Coastal Plain, and rabies outbreaks and hunting pressure on the coastal plain (BLM 2004a). In 1993, the 

population estimate for all of Game Management Unit 26A, which is all of the North Slope west of the 

Itkillik River watershed, was 240 to 390 wolves in 32 to 53 packs (BLM 2012). The highest wolf 

densities in the NPR-A are reported along the Colville River. Surveys near Umiat showed that the wolf 

density increased from 2.6 wolves per 1,000 square kilometers in 1987 to 4.1 wolves per 1,000 square 

kilometers in 1994 (Bente 1998).
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Wolverine

Wolverines may occur in the GMT2 Project area, but are uncommon (Lawhead et al. 2013, 2014b; 

Johnson et al. 2005; BLM 2012). BLM (2004a) summarized records of wolverines in the Alpine Satellite 

Development Plan Study Area. Two wolverines were seen in the NPR-A survey area in 2013 (Lawhead et 

al. 2014b). Wolverines occur across the Arctic Coastal Plain but are more common in the mountains and 

foothills of the Brooks Range (Bee and Hall 1956; BLM 1998a). In 1984, an estimated fall population of 

wolverines in Game Management Unit 26A (includes the NPR-A) was 821 individuals, based on a 

density of one wolverine per 54 square miles (BLM 2004a). Wolverines have large home ranges and use a 

broad variety of habitats, including tussock meadow, riparian willow, and alpine tundra (BLM 1998b). 

Studies in Canada and Scandinavia have shown that wolverines are more abundant in rugged areas 

protected from anthropogenic development and that they were less likely to occur at sites with oil and gas 

exploration, forest harvest, or burned areas (Fisher et al. 2013, May et al. 2006). May et al. (2006) 

hypothesized that wolverine distribution may be partly influenced by direct disturbance or higher risk of 

human-caused mortality associated with infrastructure. And that increased human development and 

activity in once remote areas may thus cause reduced ability of wolverines to perform their daily activities 

unimpeded, making the habitat less optimal or causing wolverines to avoid the disturbed area. 

Small Mammals

Data on the abundance of small mammals in the GMT2 Project area are not available, but all species 

listed in Table 45 are likely to be present. Small terrestrial mammals are important prey for predatory 

birds and mammals in the region. Arctic ground squirrels hibernate during winter, whereas lemmings, 

voles, and shrews are active throughout the year. Many small mammal species have cyclical population 

fluctuations. Arctic ground squirrels, lemming, voles, and shrews use a variety of habitat types (BLM 

2004a, 2012). 

3.3.4.2 Marine Mammals

Marine mammals are described in BLM (2004a, 2012, 2014). Marine mammals listed under the 

Endangered Species Act are discussed in Section 3.3.5. Marine mammals (common name, scientific 

name, and Iñupiaq name) addressed in this section are listed in Table 45, below. 

Table 45. Marine mammals that are reported to occur along the coast of Harrison Bay, in the Colville River 

Delta, or in the Beaufort Sea offshore north of the GMT2 Project area (not threatened, endangered, or 

candidate species)

Common Name Scientific Name Iñupiaq Name a

spotted seal Phoca largha pallas qasigiaq

bearded seal Erignathus barbatus ugruk

ribbon seal Phoca fasciata or Histriophoca fasciata b qaigullik

beluga whale Delphinapterus leucas sisuaq

gray whale Eschrichtius robustus abvibluaq

minke whale Balaenoptera acutorostrata None

narwhal Monodon monoceros None

harbor porpoise Phocoena None

killer whale Orcinus orca aabluq

a Source of Iñupiaq: http://www.alaskool.org/language/dictionaries/Inupiaq/dictionary.htm (Webster and Zibell 1970).

b Phoca fasciata are also referred to as Histriophoca fasciata due to a taxonomic debate about how closely ribbon seals are related 

to harbor, spotted, and ringed seals (Alaska Department of Fish and Game 2008).

The following marine mammals may be found along the coast of Harrison Bay or in the Beaufort Sea 

north of the project area:
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• The spotted seal may be seasonally present along the coast of Harrison Bay and in the Colville River 

Delta (BLM 2012). Spotted seals are generally distributed along the continental shelf, where their 

seasonal habitats include pack ice and land-based haul outs.

• Although bearded seals may be present throughout the year in the Beaufort Sea, the population in 

Alaskan waters is largely migratory with most individuals overwintering in the Bering Sea (Allen and 

Angliss 2013). 

• The Beaufort Sea stock of beluga whales may be seasonally present along the coast of Harrison Bay 

on rare occasions. Available evidence suggests that beluga whales show a preference for deeper 

waters (600 feet to 6,500 feet depth) during spring and fall migrations to and from summer grounds in 

the north and eastern Beaufort Sea (BLM 2008a). However, belugas do occasionally occur in coastal 

shallow water (brackish and marine) for periods of molting, thermal benefits for calves, or in pursuit 

of prey items (BLM 2012). 

• Other marine mammals that occasionally occur in the Beaufort Sea include ribbon seal, gray whale, 

minke whale, narwhal, harbor porpoise, and killer whale. The coastline of Harrison Bay north of the 

GMT2 Project area is either too shallow or outside the normal range of these mammals.

The marine mammals listed above which may be found near shore in Harrison Bay were described and 

evaluated by BLM (2014) who determined that these species were unlikely to sustain impacts. All project 

facilities and the project area are entirely inland with no facilities, pipelines, or activities related to the 

project occurring on or immediately adjacent to the marine coastal zone. As a result, the risk of impact to 

marine mammals is very low and these species will not be considered further in this analysis.

3.3.5 Threatened and Endangered Species

Three species listed as threatened under the Endangered Species Act are reported to occur or have the 

potential to occur in the GMT2 Project area (listed in Table 46): spectacled eider; Steller’s eider; and 

polar bear. Threatened and Endangered species are discussed in BLM (2004a, 2012, 2014), incorporated 

by reference here.

Bowhead whale (Balaena mysticetus) and ringed seal (Arctic subspecies; Phoca hispida hispida), which 

may be found near shore in Harrison Bay, were described and evaluated by BLM (2014) which 

determined they were unlikely to sustain impacts from the GMT1 development. Bowhead whales are 

listed as endangered under the Endangered Species Act and ringed seals are listed as depleted under the 

Marine Mammals Protection Act. All project facilities and the GMT2 Project area are entirely inland, with 

no facilities, pipelines, or activities related to the project occurring on or immediately adjacent to the 

marine coastal zone. As a result, the risk of impact to bowhead whales and ringed seals is very unlikely 

and these two species will not be considered further in this analysis.

The Pacific walrus (Odobenus rosmarus divergens) is the only subspecies of walrus occurring in Alaskan 

waters; its current range is the Bering, Chukchi, and Beaufort seas, but it is rare east of Point Barrow 

(Garlich-Miller et al. 2011). It is an Endangered Species Act candidate species and is considered 

extralimital in the southern Beaufort Sea (Federal Register, 2011). Furthermore, all project facilities are 

inland and unlikely to affect mammals in the marine environment. Accordingly, the Pacific walrus is not 

considered further in this analysis. 

In the 2011 Programmatic Biological Opinion for Polar Bears, Polar Bear Habitat, and Conference 

Opinion for the Pacific Walrus on Beaufort Sea Incidental Take Regulations, which includes the GMT2 

Project, the USFWS notes that the probability of a large spill to marine waters is considered to be “very 

unlikely to occur and cannot be said to be reasonably expected to occur” (USFWS 2011a).
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The three Endangered Species Act-listed species described in this section are listed in Table 46. The 

following sections describe the general ecology, including occurrence or likelihood of occurrence in the 

proposed GMT2 Project area for those species. Additional information is provided in BLM (2004a, 2012, 

2014), incorporated by reference here. 

Table 46 Threatened, endangered, or candidate species documented or potentially occurring in or near the 

GMT2 Project area

Common Name Scientific Name Iñupiaq Name

Likely to Occur in 

GMT2 Project Area

Conservation 

Status

Spectacled eider Somateria fischeri qavaasuk Yes Threatened

Steller’s eider Polysticta stelleri igniqauqtuq No Threatened

Polar bear Ursus maritimus nanuq Yes Threatened

3.3.5.1 Polar Bear

The polar bear was listed as threatened under the Endangered Species Act in May 2008 in response to seaice habitat loss associated with climate change (73 Federal Register 28211). Dependent on sea ice for 

survival, climate change-induced reduction in sea ice is the bear’s largest overall threat. Mortality from in 

situ anthropogenic factors like hunting and defense of life will likely exert considerably less influence on 

future polar bear population outcomes, while stressors such as trans-Arctic shipping, oil and gas 

exploration, and point-source pollution appear to impose little risk to the long-term persistence of polar 

bears (Atwood et al. 2016). 

In December of 2010, designation of critical habitat for the polar bear (denning and feeding) was 

established for more than 187,000 square miles of coastal Alaska habitat (75 Federal Register

76068−76137). In January 2013, the designation was vacated by the Alaska District Court (USFWS 

2013), but that ruling was reversed by the U.S. Ninth Circuit Court in 2016. The three habitat units of that 

critical habitat include sea ice habitat extending east from the international dateline to Canada, barrier 

islands along Alaska’s coast within the range of the polar bear, and terrestrial denning habitat extending 5 

miles inland from the coast from Utqiagvik (formerly Barrow) to the Kavik River and 20 miles inland 

from the Kavik River to Canada. 

Two subpopulations of polar bears occur in Alaska, the Chukchi/Bering Seas subpopulation and the 

Southern Beaufort Sea subpopulation. While animals from the Southern Beaufort Sea subpopulation are 

more likely to occur in the GMT2 Project area, animals from the Chukchi/Bering Seas subpopulation may 

also occur occasionally in that area. The Chukchi/Bering Seas subpopulation was estimated at 2,000 

animals in 2002 and 2006 (USFWS 2013). Recent population estimates for the Southern Beaufort Sea 

subpopulation have a range of values from 1,500 animals in 2006 with a 95 percent confidence interval of 

1,000 to 2,000 (USFWS 2013) to approximately 900 animals in 2010 with a 90 percent confidence 

interval of 606 to 1212 individuals (Bromaghin et al. 2015). A combination of declining survival, 

recruitment, and body size (Regehr et al. 2006, 2010; Rode et al. 2010) during years of reduced sea ice 

(2004 and 2005), combined with an overall declining population growth rate of 0.3 percent per year from 

2001 to 2005 (Hunter et al. 2007) suggest that the Southern Beaufort Sea subpopulation is in decline. 

Polar bears occur in maritime and coastal zones throughout the year, with specific life cycle events 

dictating location and timing. Reliant on sea ice for the majority of their hunting habitat, polar bear 

populations are sensitive to sea ice loss in optimal habitat locations (Durner et al. 2009). Polar bears use 

sea ice for hunting, feeding, breeding, maternity denning, resting, and long-distance movement. 

Additionally, polar bears use terrestrial habitats for maternity denning, scavenging, resting, and travel 

between marine habitats (Regehr et al. 2010). During late autumn to early spring, polar bear range is 

extensive and includes pack ice, land-fast ice, and land (BLM 2004a, 2012). Denning and birthing periods 

occur from late October through early April. Potential terrestrial denning habitat is defined as having 
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topographic features with greater than or equal to 8 degrees slope and greater than or equal to 1.3 meters 

in height, which provide conditions for drifting snow (Durner et al. 2013). The majority of maternal dens 

located between the Kavik River and Utqiagvik (formerly Barrow) were found to occur within 5 miles of 

the coast (Amstrup and Gardner 1994), thus the 5-mile width of the terrestrial denning habitat unit of 

critical habitat. A study by Schliebe et al. (2008) found Barter Island to have the highest on-shore 

concentration of polar bears, followed by Utqiagvik (formerly Barrow) and Cross Island, all located well 

outside of the GMT2 Project area. On-shore polar bear densities are greatly influenced by the presence of 

whale carcasses, as they provide an increasingly important protein source as sea ice extent diminishes 

(Bentzen et al. 2007).

Potential polar bear denning habitat, sightings, and den locations in relation to the proposed GMT2 

Project area are shown in Map 3.3-11. The nearest den locations reported are more than 2 miles from 

infrastructure associated with the proposed GMT2 Project (Durner 2010) (Map 3.3-11). All proposed 

GMT2 facilities are outside of the area designated critical for denning or feeding. In the GMT1 Biological 

Opinion, USFWS noted that while polar bears may be present in the GMT1 Action Area, they are 

expected to occur infrequently, with the highest numbers occurring in the portion of the action area 

closest to the coast (USFWS 2014a). The GMT2 Action Area would be even further inland.

3.3.5.2 Spectacled Eider

The spectacled eider was listed as a threatened species under the Endangered Species Act in May 1993. 

The listing was prompted by declines in the western Alaska breeding population and indications of a 

decline on the North Slope of Alaska. There is no critical habitat designated for spectacled eiders on the 

North Slope; all designated critical habitat is in western Alaska and in nearshore and offshore areas in 

Norton Sound, Ledyard Bay and the Bering Sea between St. Lawrence and St. Matthew Islands (66 

Federal Register 9146−9185). The status of the North Slope spectacled eider population prior to the start 

of the Arctic Coastal Plain aerial survey in 1992 is unknown. An estimate of 3,000 pairs was made for the 

pre-1993 Arctic Coastal Plain population based on data from limited migration and ground studies (Dau 

and Kistchinski 1977). Since 1992, aerial surveys for many waterbirds, including spectacled eider, have 

been conducted across the Arctic Coastal Plain each year. Aerial surveys have been conducted within the 

avian study series in the Colville Delta Special Area for 21 years (1993−1998, 2000−2015) and in the 

NPR-A Study Area for 14 years (1999−2006 and 2008−2014). Ground-based eider nest searches in the 

Colville River Delta (CD2, CD3, CD5, Alaska Clean Seas spill-response sites) have been conducted for 6 

years (2009−2014) and in the NPR-A Study Area since 1999 (1999−2004, 2009, 2013−2014) (Seiser and 

Johnson 2014; Johnson et al. 2015); these studies provide recent site-specific data for the GMT2 Project 

area.

The following summarizes data collected throughout the Arctic Coastal Plain, and site-specific data 

available for on-shore densities, population growth rates, site-specific habitat selection, and nesting 

locations, for spectacled eiders in the GMT2 Project area. This discussion is supplemental to information 

provided in BLM (2012, Section 3.3.5.5), BLM (2004a, Section 3.3.3.2), and BLM (2014, Section 

3.3.5.1), which are incorporated by reference.

The estimated population (total index) for spectacled eider on the Arctic Coastal Plain for the period 1992 

through 2016 is 7,030 birds with a slightly negative average annual population growth rates in both the 

long-term (0.990 for 1992 to 2016) and short-term (0.996 for 2007 to 2016) (Stehn 2014; Stehn et al. 

2013; USFWS, unpublished data). The confidence interval around both of these growth rates includes 

positive values and as such, they do not indicate a significant decline. Spatial distribution of eiders during 

the 2012–2015 survey period shows the highest concentrations of birds occurring within approximately

40 miles of the coast mostly south of Utqiagvik and north and northeast of Teshekpuk Lake (Map 3.3-12).
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Estimated density indices of spectacled eider across the Arctic Coastal Plain are presented in Map 3.3-12. 

Newly estimated density indices for the Arctic Coastal Plain using the latest 4 years of data (2012–2015) 

have been generated by USFWS (USFWS, unpublished data 2017) and these updated density indices 

were used to select estimated densities within the project study area by using a GIS analysis of density 

contour data (Table 47).

Density index contours within the project study area range from 0–0.034 to 0.035–0.101 birds per square 

kilometer, encompassing the lower three density contours present on the Arctic Coastal Plain (Table 47). 

Most of the project study area (65 percent) is contained within the lowest density band; and none of the 

project study area lies within the three highest density contours, suggesting that spectacled eiders are not 

found in high densities within the project study area. 

Table 47. Estimated density contours of spectacled eider within the project study area (2012–2015)

Density Index Contour (birds per km2) Acreage within Project Study Area Percent of Project Study Area

0–0.034 101,406.3 65.0

0.035–0.101 54,582.5 35.0

0.102–0.193 0 0

0.194–0.330 0 0

0.331–0.780 0 0

Source: USFWS unpublished data 2017.

The overall population growth trends for spectacled eiders specifically surveyed within the Colville Delta 

Special Area (21 survey years) are slightly positive but not statistically significant at 1.01 (Johnson et al. 

2015). Within the Colville Delta Special Area, the average indicated density for pre-nesting spectacled 

eiders over a 21-year study period (1993−1998, 2000−2014) is 0.10 birds per square kilometer (Johnson 

et al. 2015). Surveys conducted in 2014 indicate higher than average indicated densities at 0.14 birds per 

square kilometer and the CD North Subarea continued to exhibit the highest concentration of pre-nesting 

spectacled eiders at 0.29 birds per square kilometer (Johnson et al. 2015). Spectacled eiders were near 

average in abundance on the Colville Delta Special Area in 2015, with densities of both total indicated 

and observed spectacled eiders (0.11 indicated total birds/square kilometer and 0.12 observed birds/square 

kilometer) similar to mean values recorded over 22 years (Johnson et al. 2016). The CD North Subarea 

contained 96 percent of the spectacled eiders observed in 2015, whereas the CD South subarea contained 

none (Johnson et al. 2016). The density of spectacled eiders in the CD North Subarea during 2015 (0.25 

indicated birds/square kilometer) was about twice the density on the much larger Colville Delta Special 

Area. The distribution of spectacled eiders in 2015 was typical of previous years, when densities have 

been highest north of Alpine and low south and northeast of Alpine (Johnson et al. 2016). 

The overall population growth trends for spectacled eiders specifically surveyed within the NPR-A Study 

Area (13 survey years) are slightly positive but not statistically significant at 1.05 (Johnson et al. 2015). 

Compared with 14 previous years of pre-nesting surveys, the density of spectacled eiders in the NPR-A 

Study Area was near average in 2014 with the density being only 21 percent of the density on the Colville 

Delta Special Area (Johnson et al. 2015). Over the entire NPR-A Study Area spectacled eider densities 

were 0.02 observed birds/square kilometer and 0.03 indicated birds/square kilometer in 2014 (Johnson et 

al. 2015). Spectacled eiders were observed only in two subareas (Alpine West and Fish Creek Delta 

subareas) in the NPR-A Study Area in 2014, with the highest density in the Alpine West Subarea (0.14 

indicated birds/square kilometer) (Johnson et al. 2015). The mean density distribution also shows high 

densities have occurred in the Alpine West area near the Colville River, as well as near the coast and Fish 

and Judy creeks in the western portions of the NPR-A Study Area (Johnson et al. 2015). 
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In 2014, ground-based nest searches for eiders were conducted in select areas of the Colville Delta 

Special Area and NPR-A Study Area (Seiser and Johnson 2014). These ground-based nest searches have 

been conducted for the past 6 years in preparation for planned tundra activity during nesting season 

(Seiser and Johnson 2014). Nest search areas included pads and road routes from CD2 to CD3, Alaska 

Clean Seas spill response sites in the northern Colville River Delta, and the ice road route from CD4N to 

CD5. The majority of the area where the ground-based work took place in 2014 lies greater than 5 miles 

from the proposed GMT2 pad and road (Seiser and Johnson 2014). During the 2014 nest survey, no 

spectacled eider nests were found within the bounds of the project study area and all observed spectacled 

eider nests were north along the CD3 ice road route and in search areas around the CD3 pad and airstrip 

(Seiser and Johnson 2014). There were no nests of spectacled eiders found along the ice road route 

between CD4N to CD5.

Pre-nesting spectacled eiders used 17 of 24 available habitats during 22 years of aerial surveys on the 

Colville Delta Special Area. Seven habitats were preferred (i.e., use 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. 2016). 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 29 percent of the spectacled eider groups yet 

was available on only 2.7 percent of the Colville Delta Special Area (Johnson et al. 2016). Six habitats 

were avoided (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 availabilities (Johnson et al. 2016).

Pre-nesting spectacled eiders used 13 of 26 available habitats in the NPR-A Study Area over 13 years of 

aerial surveys (Johnson et al. 2015) preferring five habitats in the NPR-A Study Area, four of which also 

were preferred in the Colville Delta study area: 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 and were notable because 

they occupy the majority of the study area (Johnson et al. 2015).

3.3.5.3 Steller's Eider

The Alaska breeding population of Steller’s eider was listed as threatened under the Endangered Species 

Act in June 1997. There is no critical habitat designated on the North Slope for Steller’s eiders; 

designated critical habitat is located in western Alaska and along the Alaska Peninsula.

The size of the Steller’s eider Alaska breeding population is highly variable and nesting occurs at highest 

densities near Utqiagvik (formerly Barrow) (BLM 2012). Historically, Steller’s eiders have used both the 

Arctic Coastal Plain and the western coast of Alaska as breeding grounds, but their breeding range has 

contracted to the western Arctic Coastal Plain (Quakenbush et al. 1995). The Utqiagvik (formerly 

Barrow) vicinity supports the largest known concentration of nesting Steller’s eiders in Alaska (BLM 

2012). There are only three records of Steller’s eider breeding east of Admiralty Bay, approximately 30 

miles east of Utqiagvik (formerly Barrow), in the last 25 years (on the Colville River Delta in 1987, in 

Prudhoe Bay in 1993, and inland from Dease Inlet/Admiralty Bay area in 1997) (Seiser and Johnson 

2014).

The average annual population growth rate (total bird index) from 1989 to 2016 for Steller’s eider was 

0.961, indicating negative population growth for this species across the Arctic Coastal Plain (Stehn 2014; 

Stehn et al. 2013; USFWS, unpublished data). Due to the very small numbers of birds detected on these 

aerial surveys, Stehn et al. (2013) importantly notes that although showing a decline, the trend was very 
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imprecisely estimated and that these data do not support a definitive conclusion on population trend. The 

population size of Steller’s eiders on the Arctic Coastal Plain is approximately 200 birds (Stehn 2014; 

Stehn et al. 2013; USFWS, unpublished data). Since 1992, aerial and ground-based nest searches have 

been conducted in multiple locations within and adjacent to the project study area and over almost 2 

decades, no nests or indications of breeding by Steller’s eiders have been observed (Johnson et al. 2013). 

The only sightings of Steller’s eider in or near the project study area have been a few single males (seen 

in 2001 and 2007) and one pair seen on the ground in the CD North Study Area in 2001 (Johnson et al. 

2013). 

3.4 Social Systems 

Social systems associated with the GMT2 Project were described in BLM (2004, Section 3.4) and 

updated in BLM (2012, Section 3.4) and BLM (2014, Section 3.4). This section tiers to and incorporates 

by reference relevant information, while placing emphasis on the proposed GMT2 Project location and 

potential socioeconomic impacts on a narrower scale. 

3.4.1 Overview of Nuiqsut

Nuiqsut is located on the Nigliq (western) Channel of the Colville River, approximately 35 miles 

upstream from the Beaufort Sea, in an area that provides abundant opportunities for harvests of fish, land 

mammals, birds, and other resources. The Nuiqsut area was formerly a place where Iñupiat and 

Athabascans gathered to trade and fish and was also important for maintaining connections between the 

Nunamiut of the inland areas and the Taremiut of the coast (Brown 1979). After the passage of the Alaska 

Native Claims Settlement Act, a group of Iñupiat families then living in Utqiagvik resettled at Nuiqsut to 

live in a more traditional manner, and many of those who moved there had a family connection to the area 

(Impact Assessment, Inc. 1990a). Twenty-seven families from Utqiagvik (formerly Barrow) permanently 

resettled Nuiqsut in 1973. Since its resettlement over 40 years ago, Nuiqsut has grown to a population of 

415 residents living in 114 households in 2010 (North Slope Borough 2010). 

3.4.2 Cultural Resources

This section describes cultural resources of the Arctic Coastal Plain with a focus on cultural resources 

near the proposed GMT2 Project area. Cultural resources include human activity, occupation, and land 

use locations identified and inventoried through field survey, historical documentation, or oral evidence. 

Cultural resources include archaeological, historic, or architectural sites, structures, or places with 

important public and scientific uses. These resources are concrete, material places and things and may be 

of traditional cultural or religious importance to specified social and/or cultural groups. Cultural resources 

are managed for public benefit and may be (although not necessarily) eligible for the National Register of 

Historic Places (BLM 2004b, page 2). 

Because the Alpine Satellite Development Plan and NPR-A Integrated Activity Plan EISs (BLM 2004, 

2012) have already evaluated the proposed GMT2 Project (formerly referred to as CD7) and the GMT2 

study area subsumes and expands that of GMT1, this section is tiered off of the Alpine Satellite 

Development Plan and NPR-A Integrated Activity Plan EISs. While there is some redundancy to the 

GMT1 Supplemental EIS (BLM 2014), this section focuses on information that is new, updated, or not 

included in the previous environmental impact analyses. Information for this section relies on the Alaska 

Department of Natural Resources Office of History and Archaeology Alaska Heritage Resources Survey 

database, the North Slope Borough Iñupiat History, Language, and Culture Department’s Traditional Land 

Use Inventory, and relevant cultural resources literature (e.g., oral histories, reports, gray literature, 

academic journals, etc.). 
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3.4.2.1 Study Area

The study area for cultural resources includes all areas where the project may directly or indirectly impact 

cultural materials. This analysis is tiered off the Alpine development plan (BLM 2004) and includes areas 

where activities in support of GMT2 may be located, including the GMT1 footprint. The direct impact 

analysis area represents locations subjected to direct ground-disturbing activities, including existing, 

proposed, and alternative development footprints for GMT1 and GMT2 (See Map 3.1-1). Cultural 

resources that are not in the direct path of construction and supporting activities can still be affected by 

project development. For example, development can provide easier access to otherwise remote and 

difficult-to-access archaeological site locations, resulting in increased foot or vehicle traffic. Increased 

traffic can intensify erosion and/or increase the chances that cultural resources will be altered or even 

pilfered. The indirect impact analysis area consists of the project study area and includes lands beyond 

existing project facilities, and proposed GMT2 development. 

3.4.2.2 Data Sources

The Alaska Heritage Resources Survey and the National Register of Historic Places are the primary 

sources of information for historic properties in the project area; the Traditional Land Use Inventory is the 

primary source of Iñupiat traditional use areas. Recent cultural resources surveys of the area provide the 

most current archaeological site location and condition information. 

While early to mid-20th century scientific and exploration expeditions to the North Slope and Arctic 

Coastal Plain recorded certain aspect of cultural resources in the project area, full-scale systematic 

cultural resources inventories of the project area began in earnest with hydrocarbon exploration during the 

1970s. The results of these archaeological surveys, including locations and descriptions of discovered 

sites, are housed at the Alaska Heritage Resources Survey—a statewide GIS database of archaeological 

sites that provides locational information and coordinates, descriptions of site characteristics, features, 

associated artifacts, chronology and time period, National Register of Historic Places listing or eligibility 

status if available, site condition, and other important site information. There are, however, certain 

limitations to Alaska Heritage Resources Survey data. Data reported in the Alaska Heritage Resources 

Survey come from a variety of sources and can be inconsistent. Many of the sites were recorded before 

the advent of GPS technology, so reported locations and site extents are often imprecise. While ongoing 

efforts are underway to update the database, many of the sites have not been updated and may have been 

removed or destroyed since being reported, may not resemble provided descriptions, or may not be 

described accurately or in detail. Despite these limitations, however, “the Alaska Heritage Resources 

Survey files, including the GIS and map-based data, archived documents, and reports, represent the best 

available information for archaeological and historic site locations and extents for the project area” (BLM 

2014, page 172). 

Also beginning in the 1970s, following the passage of Alaska National Interest Lands Conservation Act, 

and concurrent to the onset of systematic culture resources field surveys, the North Slope Borough Iñupiat 

History Language and Culture commissioned a series of reports as part of the NPR-A field studies, the 

North Slope Borough Coastal Zone Management Plan, and establishment of the Arctic National Wildlife 

Refuge and Gates of the Arctic National Park and Preserve. These studies documented material remains, 

culturally significant places, recorded history and oral history accounts of Iñupiat land use in the North 

Slope Borough. Culturally significant locations contained in these reports were recorded in the Traditional 

Land Use Inventory, which is a living database that continues to be updated. The Traditional Land Use 

Inventory database documents places important to the Iñupiat in an effort to preserve and protect them 

from disturbance or destruction from North Slope development. It contains place names, landmarks, 

traditional land use sites, trails, travel corridors, hunting, fishing, berry picking, and other Iñupiat resource 

procurement sites, and other places of Iñupiat cultural significance. The Iñupiat History Language and 

Culture continuously updates the Traditional Land Use Inventory to also include sites used by modern 
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Iñupiat. There are, however, limitations to Traditional Land Use Inventory data. Most of the site 

information is from oral histories and informant interviews, at times with imprecise reported locations and 

imperfect recollections. These sites often have not been verified through ground-truthing or field surveys. 

The reports that formed the basis of the Traditional Land Use Inventory database covered overlapping 

areas causing single sites to receive different designations in each report, with different Iñupiat spellings 

and different locations and associations based on recollections, resulting in duplication of sites and 

discrepancies in location and descriptions. The Iñupiat History Language and Culture, however, is in the 

process of resolving many of these discrepancies and transferring information to a GIS-based system. The 

Traditional Land Use Inventory database currently represents the best effort at integrating North Slope 

history, oral history, and archaeology to understand the late prehistoric and historic period use of lands by 

the Iñupiat, and it is the most accurate and reliable source of information regarding Iñupiat cultural sites. 

This analysis relies on the most current TLUI data and numbering supplied by NSB, but at times 

supplemented with descriptions from the 1976 TLUI and information provided by individuals familiar 

with the sites and their correct locations.

Dr. Rick Reanier conducted field surveys for ConocoPhillips in preparation of this development project 

and provided additional input for this analysis regarding site details and confirming the TLUI site 

locations provided by NSB. Dr. Reanier has decades of archaeological experience working on the North 

Slope and specifically in this area, including many surveys in support of other resource development 

activities near Nuiqsut. Over the years, he has worked closely with members of the North Slope 

communities to refine the AHRS and TLUI and has extensive, detailed knowledge of not only the region’s 

prehistory and history, but also many family histories and their ties to historic properties throughout 

northern Alaska. 

Reanier surveyed the proposed GMT2 development area in the summer of 2009. He began his review of 

the area by revisiting AHRS and TLUI records, along with his own personal database of modern sites he 

has identified on the North Slope. Flying at a speed and altitude of his choice, he then conducted field 

reconnaissance along the prospective production pad location and two potential road and pipeline routes 

between GMT1 and GMT2 by helicopter to observe any terrain that might have been suitable for historic 

or prehistoric occupants. Reanier landed at the production pad to investigate it on foot and conduct shovel 

testing for buried cultural remains. Per his discretion, Reanier landed to investigate other potential site 

areas identified within the development corridor on foot. Terrain in which cultural resources are generally 

less likely to be found (e.g., flat tussock and shrub tundra and wet sedge meadows) were examined 

primarily by helicopter, while geographic features in the APE that more commonly contain cultural 

resources (e.g., pingos, riverbanks, and stream crossings) were examined on foot. 

Other sources of data include recent cultural resources surveys of the area (Potteret al. 2003, 2004; 

Reanier 2009a, 2009b, 2014a, 2014b; Reanier and Kunz 2010; Stephen R. Braund and Associates 2013) 

that provide the most current, up-to-date archaeological site location and condition information in the 

project area. Stephen R. Braund and Associates (2013) cultural resources inventories as part of the 

Foothills West Transportation Access Project and the ethno-historical report Nuiqsut Paisanich (Brown 

1979) provide further information related to traditional use of the area by the people of Nuiqsut. 

3.4.2.3 Cultural Context 

The rich cultural history of northern Alaska is described in detail in BLM (2012, Section 3.4.2). BLM 

(2008) also provides a summary of the Northeast NPR-A cultural resources, which is summarized below 

as it relates to the proposed GMT2 Project. This section provides a brief chronological overview of 

regional cultural history and broadly distinguishes between prehistoric and historic periods in Arctic 

Alaska. Prehistory occurred before history could be recorded in writing. An historic period begins with 

the introduction of a written record and extends to the modern period, which is defined arbitrarily at 50 
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years before present; Alaska’s historic period begins with the arrival of European explorers and their 

initial written descriptions of indigenous Alaskan culture.

Prehistoric Overview

The prehistoric culture history of the NPR-A mirrors the rest of Arctic Alaska and reflects a record of 

complex cultural transformations occurring since the end of the last ice age, and changing patterns of 

what people left behind allow archaeologists to identify and explain how and why cultures changed 

through time. For example, change can be a matter of adaptation. Starting with the first Alaskans, new 

technologies and ways of living allowed people to adapt to changing resources and conditions. On the 

other hand, change can reflect population migrations such as those that brought foreign people with 

unique technologies and knowledge. A brief summary of these cultures is provided here with additional 

detail found in Table 48. 

The earliest evidence for North Slope human occupation dates to the late Pleistocene around 13,700 years 

ago and belongs to the Paleoindian and Paleo-Arctic traditions2

. These populations are among the earliest 

human inhabitants of North America, residing north and west of the Laurentide and Cordilleran 

continental ice sheets that covered the majority of modern day Canada and the northern U.S. Although a 

point of contention still exists about if, when, how, why, and in what direction human populations moved 

between Alaska and open land south of the ice sheets, archaeological data suggest that at least some early 

North Americans traveled across Beringia, the land bridge that once existed between Siberia and Alaska 

when world-wide sea levels were as much as 300 feet lower than today. These early Alaskans are thought 

to have been primarily big game hunters that focused on large Pleistocene mammals such as steppe bison, 

mammoth, and horse to name a few (Anderson 1968, 1970a, 1970b, 1988; Bever 2000; Bowers 1982, 

1999; Dixon 2001, 2013; Goebelet al. 2013; Hoffecker 2011; Hoffecker and Elias 2007; Kunz 1982; 

Kunz et al. 2003; Kunz and Reanier 1995, 1996; Reanier 1982; Young and Gilbert-Young 1994). 

The ice age conditions of the Pleistocene epoch gave way to warming trends that marked the beginning of 

the Holocene Epoch. Starting roughly 12,000 years ago and lasting to the present day, the Holocene has 

been a period of substantial climatic change that significantly altered landscapes worldwide. The Arctic 

environment became generally warmer and wetter during the Holocene and soils favored vegetation 

communities better suited for these new conditions (Edwards et al. 2000; Edwards and Barker 1994; 

Mason and Bigelow 2008). Most of the large Pleistocene megafauna went extinct in Arctic Alaska while 

others such as caribou, grizzly and polar bears, musk ox, and Dall’s sheep continued to flourish. The 

initial appearance of the Northern Archaic tradition in Alaska occurred around 7,500 years ago throughout 

the Brooks Range and Arctic Coastal Plain, which then dispersed south throughout Alaska and southwest 

Yukon. The Northern Archaic tradition represents strategic and technological innovations that helped 

Arctic and subarctic people adapt to the ecological changes occurring in the middle Holocene (Anderson 

1988; Clark 1992; Esdale 2009; Workman 1978). Although Northern Archaic people still primarily 

focused on large mammal hunting, they made use of a wider range of animals than in the past, including 

those found in more upland areas (Lobdell 1986; Potter 2008a, 2008b, 2008c). Evidence that will link 

Northern Archaic people to modern populations has yet to be found, but the general consensus among 

Alaskan archaeologists is that Northern Archaic people were the ancestors of modern Athabascan groups 

in the region (Anderson 1988; Clark 1992; Potter 2008a, 2008b, 2008c, 2010; Workman 1978). 

Also referred to as Paleo-Eskimo, the Arctic Small Tool tradition (ASTt) shares ties with eastern Siberia 

(Dikovet al. 1963; Powers and Jordan 1990; Raghavanet al. 2014; Rasmussenet al. 2010; Tremayne 

2015b) and represents a wave of highly-mobile people that migrated over the Bering Sea and eastward 

across the Arctic. As the name implies, Arctic Small Tool tradition is characterized by small, finely-

 

2 Tradition is defined as “a (primarily) temporal continuity represented by persistent configurations in single technologies or

other systems of related forms” (Willey and Phillips 1958, page 37).
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crafted stone tools that were part of a tool kit used to exploit a broad range of resources. In addition to 

reflecting adept caribou hunters, these sites provide the first evidence of sea mammal hunting in Alaska 

(Tremayne 2015b), although this was limited to pinnipeds such as seal and walrus. Arctic Small Tool 

tradition people were present on Alaska’s Seward Peninsula by 4,500 years ago and managed to colonize 

the Arctic all the way to Greenland within approximately 500 years (Andreasen 1996; Slaughter 2005; 

Tremayne 2015a, 2015b). This rapid movement is credited to their ability to successfully exploit both 

land- and marine-based resources. The earliest manifestation of the Arctic Small Tool tradition was the 

Denbigh Flint complex (Giddings 1964; Tremayne 2015b), which was followed by the Choris (Anderson 

1984, 1988; Dumond 1987; Giddings and Anderson 1986; Tremayne 2015b), Norton (Anderson 1984; 

1988; Dumond 1987; Tremayne 2015b), and Ipiutak (Anderson 1988; Campbell 1962; Gerlach 1989; 

Larsen and Rainey 1948) cultures. While these cultures share some material similarities, they have been 

characterized and distinguished by the presence/absence and styling of pottery and/or finely-crafted ivory 

artwork (Tremayne 2015b; Tremayne and Rasic 2016).

Until the arrival of European explorers, the Northern Maritime tradition represents the most recent human 

migration into Arctic North America. The early Northern Maritime tradition is manifest north of the 

Bering Strait by the Birnirk culture that crossed from northeast Asia roughly 2,000 years ago (Raghavan 

et al. 2014). First documented at its type site at Point Utqiaġvik (formerly Barrow), the Birnirk cultural 

phase reflects a maritime oriented people evidently following lifeways nearly identical to those of the 

historic Iñupiat. Their primary food supply included seals, fish, (probably) whale, caribou, and birds 

hunted with a variety of hunting implements. Material used to make artifacts include ground slate, 

chipped stone, antler, bone, ivory, clay, wood, and baleen (Anderson 1984; Dumond 1987; Giddings and 

Anderson 1986; Reanier 2009a).

From Birnirk came the Thule culture, which marks the development of whaling and a lifestyle centered 

around it. While reliant upon whaling, other marine and terrestrial animals such as seals, caribou, birds, 

and fish remained important to Thule subsistence. Whale hunting requires large communal participation, 

so communities began to consolidate into large settlements, several of which continue to be occupied 

today. Thule also had well-developed transport and used dog sleds and watercraft such as umiat (large 

boats) and sleek, highly-maneuverable kayaks. Between 1,000 and 500 years ago the Thule culture 

expanded and colonized the Arctic from Alaska to Greenland, replacing Arctic Small Tool tradition 

populations. Modern Iñupiat, Yup’ik, and Inuit people are directly descended from the Thule (Anderson 

1984, 2004; Dumond 1987; Giddings and Anderson 1986; Mason 2016).

The late prehistory and history of the Arctic Coastal Plain focuses primarily on the Iñupiat of the North 

Slope who continued to have settlements based on hunting and gathering seasonal rounds, although small 

groups of Thule began establishing long-term settlements in the interior (Jensen 2016). The Taġiuġmiut 

(or Taremiut, Iñupiat who lived primarily along the coast) continued to rely heavily on sea mammals and 

fish, as well as caribou and smaller terrestrial animals. Taġiuġmiut can be compared to the Nunamiut, 

Iñupiat communities that lived further inland as far as the Brooks Range and relied almost exclusively on 

terrestrial resources (Burch 1998; Campbell 1968; Gubser 1965). In the nineteenth century, a series of 

“battles” and famines took place in the Interior, which caused population shifts leading anthropologists to 

suggest that the current ethnic boundaries may have fluctuated considerably (Burch 2005; Burch and 

Mishler 1995; Gubser 1965; Hall 1969; Ingstad 1954; McKennan 1935, 1965; Raboff 2001; West 1959). 

While direct contact with Euro-Americans may not have occurred until the mid-19th century, the Iñupiat 

Eskimo established trade routes to exchange goods along the coast and into the Interior for at least 100 

years prior. European and Euro-American goods found at proto-historic Eskimo sites include glass beads, 

metal knife blades, brass and iron artifacts, musket balls and brass fittings from muskets (Anderson 1984; 

Reanier 2009a).
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Table 48. Ancestral cultures of the NPR-A

Cultural Tradition/Age Environment/Subsistence Artifacts/Tools

Paleoindian

Mesa and Sluiceway Complexes, 

Raven Bluff Assemblage

13,700–11,800 years ago

Land bridge connects Siberia and Alaska; drier and cooler 

than now; grassland, steppe prairie—mammoth, bison, 

muskox, caribou, moose, lion, short-faced bear

Bifacial, edge-ground fluted and unfluted lanceolate 

projectile points; bifacial knives; multi-spurred 

gravers; microblades with Raven Bluff

American Paleoarctic

10,300–7,500 years ago

Climate becomes warmer and wetter; tundra replaces grass; 

land bridge subsides; mammoth and bison gone

Microblade technology; burins; bifacial projectile 

points and knives

Northern Archaic

7,500–3,000 years ago

Annual temperatures similar or a bit warmer than 20th century 

average; dependence on big game primarily caribou, no 

evidence of marine exploitation

Microblade technology; notched and stemmed bifacial 

projectile points and knives; large scrapers

Denbigh Flint Complex

5,000–2,400 years ago (beginning of 

Eskimo cultural tradition)

Climate cooled slightly, drier than preceding period; caribou is 

primary subsistence animal; first evidence of sea mammal 

hunting; orientation more toward terrestrial than marine 

resources

Microblade technology; burins; diminutive side and 

end blades; flake knives; discoids; composite tools; 

semi-subterranean houses

Choris

3,800–2,200 years ago

Climate same as during the Denbigh Flint Complex period; 

caribou is primary subsistence animal, but there is increased 

emphasis on the hunting of sea mammals, primarily seals; 

most known sites are coastal; orientation slightly more toward 

terrestrial than marine resources

Burins; large bifacial projectile points; pottery; ground 

stone; bone, antler and ivory implements; semisubterranean houses

Norton

2,600–1,800 years ago

Climate same as during the Denbigh Flint Complex period; 

caribou is primary subsistence animal, although seal hunting 

is an important aspect of the economy; generally, more 

oriented toward terrestrial than marine resources

Pentagonal projectile points; end and side blades; 

flake knives; discoids; ground stone; pottery; 

composite tools; antler, bone and ivory implements;

semi-subterranean houses

Ipiutak

1,800–1,200 years ago

Climate slightly warmer and wetter than preceding

3,000 years; marine and terrestrial resources equally 

exploited; more emphasis on sea mammal hunting

than previously

End and side blades; flake knives; discoids; no 

pottery or ground stone; composite tools; intricate 

ornamental ivory carvings; burials; semi-subterranean 

houses

Birnirk

1,600–1,000 years ago

Climate same as during Ipiutak period; coastal resources 

exploited more than terrestrial; more emphasis on sea 

mammal hunting than previously; watercraft based open 

water whaling begins

End and side blades; ground slate tools; ivory and 

antler harpoon heads; composite tools; pottery; semisubterranean houses

Thule

1,000–400 years ago

The climate cools about the middle of this period; almost 

exclusively a marine orientation; whaling technology at its 

prehistoric peak; caribou remains an important part of 

subsistence economy

End and side blades; ground slate tools; ivory and 

antler harpoon heads; composite tools; dragfloat; 

pottery, semi-subterranean houses
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Cultural Tradition/Age Environment/Subsistence Artifacts/Tools

Interior Eskimo

700–400 years ago 

During most of this period the average annual temperature is 

cooler than previous 1,000 years; some communities begin 

occupying the interior to the Brooks Range almost yearround; primarily a terrestrial subsistence economy centered 

around caribou; some exploitation of coastal ecosystem

End and side blades; long-stemmed projectile points; 

pottery, bone, antler, ivory implements; ground stone, 

semi-subterranean houses

Historic Eskimo

400 years ago–Historic

Warming begins about 150 years ago; trade and close social 

bonds between coastal and interior communities; dramatic 

shift in aspects of subsistence economy after Euro-American 

contact about 125 years ago

Bifacial stone projectile points; bone and antler 

projectile points; metal projectile points; firearms; sod 

houses; Euro-American items after 1875

Note: Modified from BLM 2012, Section 3.4.2, Table 3-24.
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Historic Overview 

The historic period of the northwestern Arctic begins with direct encounters between the Iñupiat with 

European explorers along the north and northwestern coasts of Alaska. Sir John Franklin’s 1826 

expedition sailed along the Arctic coast westward from the McKenzie River before turning back at 

Returns Island just west of Prudhoe Bay (Reanier 2009a). That same year a barge from Beechey’s 

expedition reached Point Utqiaġvik (formerly Barrow). These expeditions were the harbingers of 

European and Euro-American contact with Arctic Alaska’s indigenous people, and the following 

enculturation process that continues to this day.

Contact between the Iñupiat and outsiders dramatically increased with commercial whaling beginning in 

1848. From the 1850s to the 1920s, commercial Euro-American whaling activities often included an 

Iñupiat labor force. Many impacts to traditional lifeways, the economy, and material culture occurred as a 

result of commercial whaling (Vanstone 1984). Whaling persisted until the baleen market collapsed after 

1910 (Spencer 1984). Foreign diseases such as Spanish influenza decimated Native populations and 

caused major demographic and traditional territorial shifts. Direct contact with Euro-American 

missionaries, who first arrived in Utqiaġvik in 1890, also led to changes in traditional religious practices 

and resulted in the near universal acceptance of Christianity by the Iñupiat by 1910 (Reanier 2009a). 

Other Euro-American commercial interests attracted northern Native societies into the larger Western 

economic sphere. The fur industry sought Arctic fox pelts, which along with reindeer herding provided a 

brief economic boost for some Natives for nearly a decade after World War I. With prolonged contact, 

Euro-American trade goods entered the Native material culture realm as local populations traded for them 

or earned them in exchange for monetary wages. As commercial whaling and trading expanded, contact 

caused the disruption and eventual demise of long established Native trade networks as the Iñupiat sought 

western goods. By the 1920s, mass-produced items produced in the U.S. substantially replaced items of 

Native manufacture, resulting in Euro-American trade goods that can still be found today among sod 

house ruins and tent rings along the coast and inland to the foothills and valleys of the Brooks Range 

(Spencer 1984). The Great Depression (1929−1939) led to the decline of trapping; the trading posts 

closed, and a law requiring children to attend school depopulated the land as families moved to towns and 

villages where schools were located. Most of the Kuukpikmiut of the Colville River abandoned their 

highly mobile lifestyle and established permanent residences in Utqiaġvik. 

The Naval Petroleum Reserve Number Four (now NPR-A) was established in 1923 with the Colville 

River as its eastern boundary. Oil exploration, World War II, and the Cold War (particularly the DEW 

Line radar bases) introduced wage labor to the mixed cash and subsistence economy. The passage of 

Alaskan statehood in 1959 sparked a period of critical events in the Arctic when the new state government 

selected 105 million acres on the North Slope and began selling oil leases. 

The Iñupiat of the North Slope had been harvesting oil-soaked sod for centuries and saw the land and oil 

as their own natural resources. But state land selections and lease sales in Prudhoe Bay left Iñupiat on the 

North Slope fearful that outsiders would seize and develop their homeland, cutting local communities out 

of the profits. The movement for Alaska Native land claims grew significantly when the oil industry and 

State of Alaska made plans for the Trans-Alaska Pipeline System. After a Department of the Interiorimposed statewide freeze on land selections, the Alaska Native Claims Settlement Act was passed in 

1971. The Act established 12 regional native corporations, and the Arctic Slope Regional Corporation was 

established for the North Slope area. The Alaska Native Claims Settlement Act divided land ownership 

into regional corporations that retained subsurface rights to oil and minerals and village corporations that 

retained surface rights and subsistence uses of the land. The Iñupiat of the North Slope incorporated the 

North Slope Borough in 1972 with the same boundaries of Arctic Slope Regional Corporation. The 
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establishment of the North Slope Borough made it feasible to re-establish outlying villages such as 

Nuiqsut with schools and public facilities. Table 49 provides a synopsis of the regional history.
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Table 49. Regional history synopsis

Time Frame Historic Theme Synopsis

1820s–1880s European/EuroAmerican 

Exploration

• Begins when Captain F.W. Beechey and Sir John Franklin attempted a rendezvous at Point Utqiaġvik (formerly 

Barrow) 

• Ship crews during this period interact with coastal Iñupiat and document landscape, Iñupiaq culture, and name 

geographic features

• Ends with the failed second Franklin Expedition rescue missions

1840s–1900s Commercial 

Whaling

• Begins when the first commercial whaling vessel passes through the Bering Strait to the Arctic

• Commercial whalers slaughter Arctic whale and walrus populations, introduce venereal disease and epidemics 

that decimate Iñupiat population, disrupt indigenous trade networks, establish on-shore whaling stations, and 

provide an influx of trade goods

• Ends when commodities traditionally made from whale oil and baleen lose economic viability to similar products 

made from petroleum products and other materials (e.g., oil, corsets)

1880s–Present Ethnographic 

and 

Anthropological 

Research

• Begins with U.S. Army Signal Corps establishing a camp in Utqiaġvik to document Iñupiaq culture and other 

scientific pursuits as part of the first International Polar Expedition

• Researchers examine Iñupiaq life and cultural objects, Iñupiaq physical and cultural adaptations for Arctic 

survival, effects of resource development and cash economy on Iñupiaq culture

• Continues today as part of Iñupiaq cultural revival, academic research, and state and federal permitting process

1880s–Present Military • Begins when the U.S. Army Signal Corps sets up a scientific station at Point Utqiaġvik (formerly Barrow)

• U.S. Army and Navy personnel explore major North Slope rivers documenting ethnographic, geographic, and 

travel route information; the military conducts oil and gas exploration of the NPR-A; the Cold War spurs the U.S. 

military to establish the Distant Early Warning (DEW) line in the 1950s to detect Soviet long-range bombers; end 

of the Cold War leads to the demobilization and removal of DEW line sites across Alaska

• Continues today with increased presence of the U.S. Coast Guard patrolling the Beaufort and Chukchi seas

1890s–Present Christian 

Missionaries

• Begins with Sheldon Jackson’s arrival and becoming head of education

• Missionaries convert Iñupiat to Christianity, build schools and hospitals, help manage reindeer herds, pressure 

Iñupiat to abandon traditional cultural practices; missionaries eventually singularize efforts to spreading 

Christianity

• Continues today as missionaries seek new converts and multiple denominations continue to establish in North 

Slope communities

1890s–Present Reindeer 

Herding

• Begins when Sheldon Jackson introduces reindeer herding to the Arctic to provide a stable food source

• Incompatibility of reindeer herding with Iñupiat subsistence practices, competition between Iñupiat and nonNatives, problem-plagued governmental regulations, the checker-boarding of land ownership, and lack of 

communication between government and academic research and herders contribute to steady decline of reindeer 

herding on the North Slope (Stern et al. 1980)

• Continues today in some areas of Alaska, but in a greatly reduced form than in the first half of the 20th century
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Time Frame Historic Theme Synopsis

1890s–1970s Centralization of 

Communities

• Begins with schools, post offices, trading posts, and reindeer stations altering Iñupiat settlement patterns through 

centralization into permanent communities

• Kaktovik permanently settled following establishment of trading post by Tom Gordon in 1923

• Anaktuvuk Pass established in 1949 following formation of regular air service, postal office, and a school

• Ends with Nuiqsut, Point Lay, and Atqasuk reestablished as permanent communities in the 1970s following 

passage of Alaska Native Claims Settlement Act

1900s–1930s Trapping and 

Trading Posts

• Begins with decline in whaling and rising importance of furs as an economic driver

• Former whalers such as Charles Brower and Tom Gordon establish trading posts at Barter Island and 

Demarcation Point

• Trading posts, combined with dramatic decreases in the caribou and Iñupiat populations, lure the remaining 

inland Iñupiat to settle in coastal settlements

• Ends when the Great Depression lessens the demand for furs

1900s–Present Geologic 

Exploration and 

Oil and Gas 

Development

• Begins with Schrader and Peters (1904) and Leffingwell (1919) geologic surveys of the Brooks Range and 

Canning and Colville Rivers

• Early geological exploration leads the way to the creation of the NPR-A; governmental oil and gas exploration 

NPR-A eventually leads to private industry investigating areas of the Arctic Coastal Plain, which leads to the 

discovery of Prudhoe Bay and construction of Trans-Alaska Pipeline System and the Dalton Highway

• Exploration continues today within the northeastern portion of NPR-A, and across the North Slope

• CD5 and GMT1 are the first developments constructed within the NPR-A boundary

1930s–Present Tourism • Begins with the advent of airplanes and several well-known aviators traveling to Utqiaġvik including Charles 

Lindbergh and Wiley Post in the early 1930s

• Continues today in Utqiaġvik and other North Slope communities as well as remote areas of the North Slope for 

hiking, sightseeing, boating, polar bear viewing, and other tourist activities
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3.4.2.4 Cultural Resources in the Project Area 

As shown in Table 50, 28 total cultural sites have been identified in the project area. Of those, 13 are 

listed only in the AHRS database (ADNR OHA 2017), nine are listed only in the TLUI (NSB 2017b), and 

six are listed in both. One site (HAR-00169) is listed on the NRHP, but no other determinations of 

eligibility for the NRHP (DOEs) have been completed for sites in the study area. The sites primarily 

include historic archaeological sites consisting of graves and historic settlements or camps at which the 

remains of sod houses, caches, ice cellars, and historic artifacts can still be found. Many of these areas are 

traditional locations for hunting, fishing, and trapping, and which continue to be used by modern Nuiqsut 

residents. Almost all of these sites are historic in nature, although artifact types (e.g., HAR-00169 and 

HAR-00163) and dated materials (e.g., HAR-00059) demonstrate a prehistoric presence in the study area. 

The sites listed in Table 50 reflect all those located in the study area, however, several warrant some 

further discussion. Sites like HAR-00054, HAR-00055, and HAR-00089 have since eroded away, 

demonstrating the vulnerability of the archaeological record. In conversations with Nuiqsut elders, 

Reanier learned that TLUI site Qayaqtuaġiaq (TLUIHAR078) is erroneously plotted near the location of 

Sigirauk (TLUIHAR103) when, in reality, it is located approximately 3 miles to the south (Rick Reanier, 

personal communication 2017). Also, while Sigirauk is listed in the 1976 TLUI as being a fishing, 

hunting, and camping area located approximately 4 miles east of Nuiqsut, Reanier’s attempts to gather 

information from Nuiqsut elders about the site revealed no knowledge of the name or information about 

the location. No cultural remains have been found in the vicinity of the 1976 or 2017 locations, and had 

an archaeological site once existed there, it is likely that would have been along the bluff overlooking the 

Colville River and since eroded (Rick Reanier, personal communication 2017). 

Of the 28 cultural sites identified in the AHRS and TLUI as being within the project area, three historic 

sites have been destroyed and one TLUI site could neither be confirmed nor relocated, leaving 24 AHRS 

and TLUI sites that are considered in the finding of effect analysis presented below.
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Table 50. Cultural sites located in the GMT2 area of potential effect

AHRS TLUI Site Name Site Description

HAR-00044 NA NA Grave marker

HAR-00053 NA NA Isolated human crania Iñupiat dating between 30 and 150 years 

ago. Site marked with a wooden cross and remains were reburied 

offsite.

HAR-00054 NA NA Commercial lifeboat of unknown age. Missing, possibly drifted out 

to sea

HAR-00055 NA NA Caribou bone. Totally destroyed: eroded into river

HAR-00059 NA NA Caribou rib with stone tool cut marks dating between 340-460 

years old

HAR-00068 NA NA Sod house remains and historic artifacts

HAR-00069 NA NA Sod house and hunting camp remains with dog tethers, early 

20th Century iron stoves remains, and historic artifacts

HAR-00070 NA NA Grave

HAR-00074 NA NA Grave

HAR-00077 NA Oenga House Sod house remains

HAR-00078 NA NA Sod house remains and historic artifacts

HAR-00089 TLUIHAR081 Nappaun Sod house remains and buried historic artifacts at fishing, 

hunting, and camping location. Eroded into river by 2014

HAR-00155 TLUIHAR080 Uyaġagvik Wooden wall tent stakes. Located near beach where stones were 

collected for fishing nets, site was used for hunting, fishing, and 

trapping

HAR-00156 TLUIHAR082 Nanuq Sod house remains, sod quarry, storage pits, dog tethers, and 

scattered historic debris used by reindeer herder families

HAR-00157 NA Niglivik 2 Sod house remains, sod quarry, storage pit, and several 

scattered historic artifacts

HAR-00158 TLUIHAR079 Putu Sod house remains, sod quarry, fish curing pits, ice cellar, whale 

boat stern, and scattered historic artifacts

HAR-00163 TLUIHAR074 Itqiļippaa Graves, and many sod house remains, sod quarries, and storage 

pits and racks. Historic and prehistoric artifacts were found onsite

HAR-00169 TLUIHAR084 Niġliq Location of prehistoric and historic trade fairs. Prehistoric artifacts 

along with historic sod house remains and graves have been 

discovered onsite. An historic commercial fishing camp was also 

later established at the location. Site is listed on the National 

Register of historic places

HAR-00171 NA Qakimak Sod house remains

NA TLUIHAR041 Sikulium Paaŋa Fishing and hunting area

NA TLUIHAR063 Iļaaniġruaq Fishing area, hunting and camping area.

NA TLUIHAR075 Tuiġauraq Fishing, hunting, and trapping location

NA TLUIHAR077 Napasalgun Hunting and camping area

NA TLUIHAR078 Qayaqtuaġiaq Fishing, hunting and camping area. 2017 TLUI location is 

incorrect; 1976 TLUI location is more accurate

NA TLUIHAR083 Apqugaaluk Fishing location

NA TLUIHAR087 Tiŋmiaqsiuġvik Fishing area

NA TLUIHAR061 Nuiqsut Village site reestablished and relocated by ANLCS in 1972

NA TLUIHAR103 Sigirauk Fishing, hunting, and camping area as listed in 1976 TLUI. No 

additional information or land use knowledge is known to exist
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3.4.2.5 Nuiqsut Cultural Landscape

The concept of a Nuiqsut cultural landscape was first introduced by Brown (1979) who coined it the 

“Nuiqsut Paisanich Cultural Landscape” and described its significance to the Iñupiat of Nuiqsut as “an 

approximation of their core ideas” and representing their “geographic and spiritual homeland.” The 

cultural resources that comprise the Nuiqsut Cultural Landscape are primarily located along river 

corridors (particularly the Colville and Itkillik rivers and Fish Creek), in overland areas extending west of 

the community to Fish Creek and beyond to Teshekpuk Lake, and in coastal locations both west and east 

of the community. Several important components of the Nuiqsut Cultural Landscape are located within 

the project study area, including those associated with ongoing multi-generational customary practices 

that generally occur in similar locations as past historic or traditional practices. The continuation of these 

customary practices into current times and at modern sites within the landscape helps maintain Iñupiaq 

cultural identity to the cultural landscape.

Stephen R. Braund and Associates (2013) reviewed and updated the potential Nuiqsut Paisanich Cultural 

Landscape as part of the Foothills West Transportation Access Project using more thorough 

documentation standards that post-date Brown’s (1979) efforts. Their report presents the Nuiqsut Cultural 

Landscape squarely in terms of the National Register of Historic Places and Section 106 considerations 

by: (1) relying on National Register terminology and considerations in describing this resource; (2) 

applying the National Park Service Cultural Resource Stewardship and Partnerships definition of a 

cultural landscape found in Page et al. (1998); and (3) following National Register Bulletin No. 38 

(Parker and King 1998), Advisory Council on Historic Preservation (2012), and Alaska State Historic 

Preservation Office definitions and descriptions of Traditional Cultural Landscape characteristics 

(Stephen R. Braund and Associates 2013). The traditional cultural landscape characteristics reviewed by 

Stephen R. Braund and Associates (2013) and applied to the proposed Nuiqsut Paisanich Cultural 

Landscape include:

Land use: Land use is defined as the principal activities that have formed, shaped, or organized the 

landscape as a result of human interaction (Stephen R. Braund and Associates 2013, Appendix H, 

page 15). This refers to both historic territories and historic use areas. Historic territories are the broad 

region with which a particular Native group identifies with; while historic use areas are the results of 

systematic individual interviews aimed at identifying where people searched for and harvested 

resources. In both cases, Stephen R. Braund and Associates (2013, Appendix H, page 15) states that 

the primary Iñupiat use of the landscape is subsistence. 

Circulation: Circulation is defined as the spaces, features, and applied material finishes that 

constitute systems of movement in a landscape; for example, paths, roads, bridges, railroads, and 

navigable rivers (Stephen R. Braund and Associates 2013, Appendix H, page 22). Circulation features 

in the project area are said to include modern and historical Iñupiat travel and trade routes. Stephen R. 

Braund and Associates s (2013) discussion focuses on rivers in the area as circulation features, and 

presents that, in general, the Colville, Anaktuvuk, Sagavanirktok, Chandler, Itkillik, Kuparuk and 

Toolik rivers are important circulation features in the Nuiqsut landscape. 

Archaeological sites and places associated with cultural beliefs or practices (e.g., cultural sites):

Cultural sites are places associated with cultural beliefs or practices, and consist of archaeological, 

ancestral, historic, traditional, sacred, camp, cabin, birthplace, harvest, and subsistence locations. 

Stephen R. Braund and Associates (2013) does not include Alaska Heritage Resources Survey or 

Traditional Land Use Inventory sites in their cultural site review of the landscape, although the 

document does recommend including Alaska Heritage Resources Survey and Traditional Land Use 

Inventory sites for a more thorough analysis (Stephen R. Braund and Associates 2013, Appendix H, 

page 35). 
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Cultural traditions: Cultural traditions include “practices that have influenced the development of 

the landscape in terms of land use, patterns of land division, building forms, stylistic preferences, and 

use of materials” (Stephen R. Braund and Associates 2013, Appendix H, page 30). The report 

generally states that natural landscape features can be associated with stories, songs, events and 

places; however, it emphasizes subsistence as the primary activity contributing to cultural and 

community identity. 

Natural systems and features: Natural systems and features provide the setting in which cultural 

activities occur and in this regard influence the characteristics of a cultural landscape. Stephen R. 

Braund and Associates (2103) provides a general description of the types of natural features important 

to the Iñupiat: waterways such as lakes and rivers; topographic prominences, and subsistence 

resources. The bluffs on the Colville River around Umiat which are related to the Iñupiaq creation 

myth, the Colville and Anktuvuk rivers which are important travel corridors, and Galbraith and Toolik 

lakes are the features specifically mentioned as being important to the proposed Nuiqsut Paisanich 

Cultural Landscape.

The Stephen R. Braund and Associates report states that “SRB&A is not assessing the eligibility of the 

Nuiqsut cultural landscape for the National Register of Historic Places” (Stephen R. Braund and 

Associates 2013, Appendix H, page 1), and in most cases their report remains vague on how the 

characteristics described above are elements that contribute to the National Register of Historic Places 

significance of the proposed landscape. The integrity of these elements, both physical and cultural as well 

as National Register of Historic Places criteria considerations, remain unevaluated.

Land use includes both historic territories and historic use areas. As described in the data sources section, 

the Traditional Land Use Inventory is the best source of Iñupiat ethno-historical land use sites, and the 

Alaska Heritage Resources Survey contains the best available information for archaeological and historic 

site locations and extents for the project area. In order to mitigate redundancies and discrepancies inherent 

to early data sources which would skew the analysis, the unrefined sources utilized by Stephen R. Braund 

and Associates (2103) to identify cultural sites will not be included in the current analysis. As the Iñupiat 

History Language and Culture has resolved these sources’ discrepancies in the Traditional Land Use 

Inventory, the Traditional Land Use Inventory remains the best source of information for Iñupiat cultural 

sites related to the Nuiqsut Paisanich Landscape. Following the recommendations by Stephen R. Braund 

and Associates (2013, Appendix H, page 35) landscape review, to properly evaluate the impacts of the 

project on the contributing elements of the proposed Nuiqsut Paisanich Cultural Landscape, the 

environmental consequences analysis will include only the 24 surviving Alaska Heritage Resources 

Survey and Traditional Land Use Inventory sites in the project area that may contribute significance to the 

cultural landscape in the Cultural Resources analysis. It is important to note that subsistence is evaluated 

as a stand-alone resource, and therefore, many of the potential environmental consequences important to 

the Nuiqsut Cultural Landscape are evaluated in that analysis.

3.4.3 Sociocultural Systems

This section describes the affected environment for sociocultural resources potentially affected by the 

project. The proposed GMT2 Project has previously been evaluated and addressed within earlier NEPA 

documents: (BLM 2004) and (BLM 2012) and (BLM 2015). Therefore, this section is tiered to those 

documents and focuses on information that is new or updated since those previous EISs. This section 

includes a general overview of sociocultural systems on the North Slope, particularly for Nuiqsut, 

including history, social organization, economic organization, community institutions, community health 

and welfare, and population and employment. There are two distinct populations found in the general 

project area: local permanent residents, a majority of whom are Iñupiaq Eskimos indigenous to the area, 

and oil and gas industry workers who rotate on a shift schedule and are temporary residents. This 

discussion focuses on the sociocultural systems of the permanent residents of the North Slope with a 
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particular focus on the Iñupiat and on the community of Nuiqsut. Nuiqsut, located on the western bank of 

the Nigliq Channel of the Colville River Delta, is the closest residential community to the proposed 

project, 16.5 miles east of the proposed GMT2 drill pad. 

3.4.3.1 Population and Employment

U.S. Census data from 2010 includes socioeconomic data on Nuiqsut, but there are other sources that the 

North Slope Borough and Nuiqsut residents consider more reliable and are also used in the preparation of 

this report. In 2012, ConocoPhillips commissioned a socio-cultural study on Nuiqsut, which did not 

involve a community-wide survey, but was based on extensive fieldwork in Nuiqsut during the years 

2012, 2013, and 2015. This report, titled The Next Horizon: A socio-cultural study of the impact of oil 

development on the Native community of Nuiqsut (Redmond and Thornson 2016), also includes more 

reliable and current data than the 2010 U.S. Census. The North Slope Borough contracted with 

Circumpolar Research Associates to prepare a North Slope Borough 2015 Economic Profile and Census 

Report, which updates demographic data for Nuiqsut (NSB 2016). 

Based on the 2014 North Slope Borough census data, Nuiqsut had a total population of 449 residents with 

Inupiaq people making up 90.5 percent of the total. Individuals under the age of 16 made up 35.2 percent 

of the population while individuals 16 to 64 years of age made up 55.3 percent of the total, which is also 

the proportion of the labor force to the total population. The number of unemployed was approximately 

36.5 percent. 

The average reported household income (all households) in Nuiqsut in 2014, was $45,614; Iñupiaq 

household incomes were $43,346, while non-Iñupiaq household incomes were $60,214 (NSB 2016). 

The Nuiqsut Trapper School is a K-12 school that is part of the North Slope Borough School District. For 

the 2011-2012 school year, the Nuiqsut Trapper School had an enrollment of 104 students with a 

graduation rate of 44 percent, below the graduation rate of 57 percent for the North Slope Borough School 

District (Alaska Department of Education and Early Development 2013). Ilisaġvik College in Utqiagvik 

(formerly Barrow) provides advanced education for the North Slope. 

3.4.3.2 Social Organization

Iñupiaq social organization traditionally revolved around the bilateral family unit and their extended kin, 

in addition to trading partnerships and friendships (Hall 1984). Following European and American 

contact, the social and political organization of the Iñupiat changed. These changes were a result of 

various factors including compulsory education, which led to the centralization of people into permanent 

villages; introduction of modern technologies, which altered residents’ methods for harvesting and 

processing subsistence foods; the introduction of a cash economy; the introduction of Christianity; and 

incorporation of the Iñupiat into new systems of laws and governing systems. Alaska Natives began 

forming village councils, which were reorganized under the Indian Reorganization Act of 1934. The 

Alaska Native Claims Settlement Act was passed in 1971 and resulted in the formation of regional and 

village corporations, and the North Slope Borough formed in 1972. 

Despite the changes in social and political organization over time, the core of Iñupiaq social organization 

is similar on the North Slope today, in that it encompasses not only households and families, but also 

wider networks of kinship and friends, and individual family groups which depend on the extended 

family for support. The sharing and exchange of subsistence resources strengthen these kinship ties. In 

addition, despite the Christianization of the Iñupiat through missionaries, the Iñupiat maintain certain 

aspects of traditional Iñupiaq belief systems, which revolve around a system oriented to the environment 

and its animals and require that hunters follow proper hunting rituals to ensure successful harvests. For 

these reasons, the relationship of the Iñupiat and their natural environment remains the cornerstone of 

their cultural identity (BLM 2004). 
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The 2016 socio-cultural report on Nuiqsut (Redmond 2016) as well as the draft ‘Nuiqsut Paisanich: A 

2017 Update’ (SRB&A2017f) notes that much of the structure and dynamics of Nuiqsut today have 

changed substantially over the past 40 years, but notes that much of this change is the result of forces of 

change unrelated to oil development. However, sociocultural systems in Nuiqsut can be impacted by 

nearby oil development in a number of ways, including: 

• Employment opportunities 

• Increased or variable income

• Tensions relating to the permitting process for development

• Devaluation of the Nuiqsut cultural landscape

• Disruptions to subsistence resources, access, and activities

• Adequacy of mitigation (e.g., availability of State of Alaska NPR-A Impact Mitigation Grants)

3.4.3.3 Government and Community Institutions

The people of Nuiqsut call themselves “Kuukpikmuit,” or the “People of the Lower Colville River” 

(BLM 2004, Section 3.4.1.2; BLM 2008b). Over 440 people reside in Nuiqsut today, the majority of 

whom are Iñupiat (see Section 3.4.1.6). The Native Village of Nuiqsut is a federally recognized Tribe, and 

the Kuukpik Corporation is the local Alaska Native Claims Settlement Act village corporation. Nuiqsut 

was incorporated as a second class city in 1975. Several subsistence-related organizations exist in 

Nuiqsut. The Kuukpik Subsistence Oversight Panel, Inc. was established in 1996 in response to 

development of the Alpine oilfield. The purpose of panel is to provide a method of communication 

between Nuiqsut residents and industry and to relay concerns to industry regarding impacts on 

subsistence harvesting activities. The Kuukpik Subsistence Oversight Panel, Inc. has also been involved 

in the establishment of resource-specific panels of experts, such as the Nuiqsut Caribou Panel and the 

Qaaktaq (Arctic cisco) Panel. Another subsistence-related organization is the Nuiqsut Whaling Captains 

Association.

The proposed GMT2 Project is within the North Slope Borough. The North Slope Borough government 

offices are in Utqiagvik ( [formerly Barrow]), the seat of regional government. The North Slope Borough 

has permit authority relevant to the proposed project. Other federal and state agencies, including the BLM 

who is the land manager for all non-Native land with the NPR-A, have permit authority related to the 

project. Nuiqsut residents, along with residents from seven other North Slope communities, are members 

of the regional federally recognized tribe Iñupiat Community of the Arctic Slope, and many are 

shareholders in the Arctic Slope Regional Corporation.

3.4.4 Economy 

Oil and gas exploration, development, and production activities on Alaska's North Slope contribute to the 

economy of the nation, the State, the North Slope Borough, and local communities. Oil and gas 

development in the region supports local and non-local, direct and indirect hires, and induces jobs and 

generates federal, state, and local government revenues through rentals and royalties from oil and gas 

leases, income taxes, property taxes, sales taxes, and other payments.

BLM (2004, Section 3.4.2.1) describes the relationship of the oil and gas industry to the North Slope 

economy, the economy of the State of Alaska, and the nation’s economy. BLM (2012, Section 3.4.11) 

provides a more recent and detailed account of the structure of the North Slope Borough economy, 

including the local economies affected by oil and gas development in the NPR-A, and the revenues that 

accrue to the federal, state, and regional, and local governments. Because resources and activities 

elsewhere dilute effects to the Nation’s economy, this section does not address the U.S. economy. 

The following subsections incorporate by reference economic information contained in BLM (2014, 

Section 3.4.3), which provided a description of the existing economic conditions in the affected 
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environment. However, the economy of Alaska is currently different than it was when the GMT1 

Supplemental EIS was produced due to oil and gas prices falling in 2015 to their lowest prices in years. 

Declining state revenues have resulted in cuts to public spending that have affected many Alaskans. 

The information presented in the following subsections provide an update of the economic data and is the 

most current (using 2014, 2015, and 2016 data) regarding condition of the affected economies at the state, 

regional, and local level. 

3.4.4.1 Economic Organization

The Iñupiat traditionally participated in an economy that relied on subsistence resources and trading to 

acquire goods not readily available in their immediate area. The economy of the North Slope underwent 

major changes beginning in the mid-19th century, when commercial whaling introduced a new type of 

economy to the Iñupiat. Other economic developments followed the whaling industry, including reindeer 

herding, fur trapping, military development, and oil and gas exploration and development. 

The Iñupiat of the North Slope continue to rely on subsistence resources while also participating in the 

cash economy. Like other communities on the North Slope, Nuiqsut has a mixed economy of subsistence 

and cash, where families invest money into small-scale, efficient technologies to harvest wild foods 

(BLM 2008b). These investments (e.g., gill nets, motorized skiffs, all-terrain vehicles, and 

snowmachines) are not oriented toward sales or profits, but are used to meet the needs of families and 

small communities. The contribution of subsistence harvests toward the mixed subsistence-cash economy 

is substantial, with documented per capita harvests in Nuiqsut ranging from 399 (in 1985) and 742 (in 

1993) pounds. Subsistence activities have economic, social, cultural, and nutritional value for Nuiqsut 

residents. 

The primary sources of wage employment in Nuiqsut are the North Slope Borough (including the school 

district), the Kuukpik Corporation, and the City of Nuiqsut. Craft sales are also a small part of Nuiqsut’s 

economy. 

The Kuukpik Corporation, Nuiqsut’s village Alaska Native Claims Settlement Act Corporation, was 

established in 1973 and owns the surface rights to approximately 137,880 acres of land near Nuiqsut, 

including portions of the Alpine oil field that is located approximately 8 miles from the community. The 

corporation receives royalties for the use of its land, and its subsidiaries provide oil support services. The 

corporation has approximately 250 enrolled shareholders who receive dividends. Some shareholders are 

not residents of Nuiqsut and some are not North Slope Iñupiat; they may be Alaska Natives from other 

regions or non-Natives who have inherited or received gifted shares. Native children born after 1971 may 

not be shareholders in the Kuukpik Corporation (may not have inherited or received gifted shares) or may 

not be full shareholders, therefore they do not receive dividends (or full dividends) (see Chapter 4, 

Section 4.4.2 Sociocultural Systems). 

Industrial development in the vicinity of Nuiqsut consists of oil production infrastructure. ConocoPhillips 

operates the Alpine production facilities that include ongoing drilling and production operations, 

processing facilities, wells and pipelines, camp facilities, gravel roads and airstrip, communications and 

power generation, sanitation utilities, warehouses, and other oil field support facilities. 

The North Slope Borough owns and operates a 4,300-foot airstrip in Nuiqsut. For about 4 months per year 

(commonly January through April), ice roads connect Alpine and Nuiqsut to the Kuparuk and Prudhoe 

Bay road system. This allows residents of Nuiqsut to travel by road vehicle back and forth to urban 

centers during ice road season. Residents commonly drive for the convenience or cost savings over air 

travel for health reasons, for vacations, and to buy vehicles and other goods and drive them to their 

community. No other Inupiaq community on the North Slope has this ability, although residents 
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increasingly drive to and from Utqiaġvik over packed snow trails or on the sea ice. Snowmachines are 

also used for local transportation in the winter, and boats and four-wheelers are a source of transportation 

during the snow-free months. A non-industrial gravel road (the Nuiqsut Spur Road) connects with the 

Alpine road system, facilitates oil field training and employment opportunities for residents, and improves 

road access for subsistence activities.

The Kuukpik Alaska Commercial Company store provides commercial goods including groceries, general 

merchandise, propane, diesel, and gasoline. Except for winter access by ice road, the majority of goods 

are transported to Nuiqsut by air. 

Colville Village is the Helmericks’ family homestead on Anachlik Island, on the northeast side of the 

Colville River Delta. Established in the mid-1950s, primarily as a commercial fishing operation, this site 

consists of several homes, a lodge, an airstrip, aircraft hangers, warehouses, barn, workshops, and other 

outbuildings. Family members still use the homestead but the commercial fishing business is no longer 

operational. 

3.4.4.2 Regional Economy: North Slope Borough

The North Slope Borough is the Nation’s largest oil-producing county, and oil and gas exploration and 

development play the central role in the borough’s economic profile. Oil and gas property taxes are the 

primary source of revenue for the North Slope Borough government. The North Slope Borough projected 

$370 million in oil and gas property taxes in 2016, accounting for about 99.8 percent of the total property 

tax collected by the North Slope Borough that year. This amount accounts for approximately 96 percent 

of the total general fund revenues (North Slope Borough 2016). With significant oil and gas property tax 

revenues, the North Slope Borough has been able to finance construction projects through its Capital 

Improvement Program. The North Slope Borough government also provides a wide range of public 

services to all of its communities; the North Slope Borough's actual operating budget in fiscal year 2016 

amounted to about $384.4 million.

Oil production at Prudhoe Bay, Kuparuk, and Alpine Fields and satellite fields account for most of the oil 

production activities in the region. More recent oil and gas industry activities on the North Slope include 

ConocoPhillips’ exploration at Rendezvous and Tiŋmiaq/Willow, Hilcorp’s Liberty project, Caelus’ 

Oooguruk nearshore project and exploration in Smith Bay, ENI’s offshore Nikaitchuq project, 

ExxonMobil’s Point Thomson development project, Repsol’s Ugruk exploration in the Colville Delta, and 

Armstrong/Respol’s Nanushuk project. These industry projects have and will continue to contribute to the 

North Slope economy through taxes, oil field services contracts, and other indirect and induced effects of 

industry spending in the region. The indirect effects from government and industry spending have 

expanded the private support sector in the region. In 2014, the North Slope Borough produced 174.5 

million barrels of oil on both state-owned and federally managed land (U.S. Extractive Industries 

Transparency Initiative 2016). Annual oil production in the borough peaked in 1988 (at 722 million 

barrels) and has steadily declined since (U.S. Extractive Industries Transparency Initiative 2016). 
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Figure 13. Alaska North Slope crude oil production

Despite the importance of oil and gas exploration and production to the North Slope Borough, extremely 

few residents hold jobs directly in the industry. In 2012, there were 8,459 oil industry jobs on the North 

Slope; residents of the North Slope filled 69 positions (Alaska Department of Labor and Workforce 

Development 2013). In 2015, 1.8 percent of all jobs held by North Slope residents were in the oil and gas 

industry and only 14 percent of people who worked in the North Slope Borough were North Slope 

residents (Alaska Department of Labor and Workforce Development 2016a). More than 20,000 people 

commuted to the North Slope in 2014 to work in jobs directly and indirectly related to oil and gas. Of 

those, 40 percent came from outside of Alaska, and most of the remaining 60 percent were from 

Anchorage or the Matanuska-Susitna Borough (Alaska Department of Labor and Workforce Development 

2016a) 

The local government sector (primarily the North Slope Borough government) is the largest employer of 

North Slope residents. In 2016, the local government sector employed 1,986 residents, accounting for 59 

percent of the resident workers in the region. The next largest employment sector is trade, transportation, 

and utilities, accounting for about 9 percent of the resident working population (Table 51).

The Alaska Native Claims Settlement Act regional and village corporations on the North Slope are also 

important economic players in the region, employing local residents, participating in the oil and gas 

service industry, and creating additional wealth in the region. 

A portion of the Alaska Native Claims Settlement Act corporations’ profits goes to shareholders in the 

form of dividends. Arctic Slope Regional Corporation (ASRC) is the regional Alaska Native Claims 
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Settlement Act Corporation that is owned by, and represents the business interests of, the North Slope 

Iñupiat. For nearly two decades, ASRC has been the largest Alaskan-owned and operated company based 

on revenues. ASRC holds title to approximately 5 million acres of land on the North Slope, and many 

ASRC lands are rich in subsurface oil, gas, coal, and base metals. 

ASRC focuses on energy and federal contracting, generating $2.6 billion in revenue during 2014. Its 

annual average dividend to shareholders hit a high of $10,000 in 2013, but declined to an average of 

$5,000 because the corporation is heavily invested in oil support industries and has been hit by lower 

prices and dwindling production (Alaska Department of Labor and Workforce Development 2016a). 

Table 51. 2015 North Slope Borough resident employment by industry

Industry Number of workers Total Employed (%)

Local Government 1,986 59.1

Educational and Health Services 312 9.3

Trade, Transportation and Utilities 289 8.6

Professional and Business Services 288 8.6

Construction 163 4.9

Leisure and Hospitality 79 2.4

Other 78 2.3

Natural Resources and Mining 61 1.8

Financial Activities 47 1.4

State Government 27 0.8

Information 18 0.5

Manufacturing 10 0.3

Source: Alaska Department of Labor and Workforce Development (2016b).

Arctic Slope Regional Corporation Energy Services, Inc., a wholly owned subsidiary of ASRC, provides 

an array of oilfield engineering, operations, maintenance, construction, fabrication, regulatory and 

permitting, and other services for some of the world’s largest oil and gas companies. The company has 

emerged as one of Alaska’s largest oilfield service providers and one of Alaska’s largest private-sector 

employers (Alaska Department of Labor and Workforce Development 2011; Arctic Slope Regional 

Corporation 2017). Petro Star, Inc., another subsidiary of ASRC, is the only Alaskan-owned refining and 

fuel marketing operation in the state (Arctic Slope Regional Corporation 2017). 

Village Alaska Native Claims Settlement Act corporations in the North Slope Borough also are active in 

the oil and gas sector. The oilfield service company UMIAQ, LLC, a division of Ukpeaġvik Iñupiat 

Corporation (the village corporation for Utqiaġvik), and Kuukpik Corporation, the village corporation for 

Nuiqsut, for example, provide camp services and catering to ConocoPhillips’s Alpine development and 

BP’s offshore Northstar field. 

Federal statute requires that 50 percent of the money received by the Federal government from sales, 

rentals, bonuses, and royalties on leases issued in the NPR-A be paid to the State of Alaska. The monies 

are to be used by the State of Alaska for (a) planning, (b) construction, maintenance, and operation of 

essential public facilities, and (c) other necessary provisions of public service. The State of Alaska is 

required to prioritize allocation of these funds to cities or boroughs most directly or severely impacted by 

development of oil and gas leases (Alaska Department of Commerce, Community, and Economic 

Development 2016). NPR-A impact grants are a critical component of the economy of the North Slope 

Borough and the individual communities that are eligible to apply for and receive the funds (Utqiaġvik, 

Wainwright, Atqasuk, Anaktuvuk Pass, and Nuiqsut). Since leasing in the NPR-A restarted in 1998, over 

$157 million has been awarded to NPR-A communities for various projects through the NPR-A Impact 

Mitigation Grant Program. Over $75 million has been awarded to the North Slope Borough for projects 
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benefiting the entire NPR-A region (Alaska Department of Commerce, Community, and Economic 

Development 2016). 

The North Slope Borough is concerned about the economic impacts of changing North Slope population 

dynamics. The increased school age population is a positive sign of growth for the North Slope Borough 

population, but it has a negative effect on the regional economy. From 2010–2015, the 0 to 15 age cohort 

grew 3 percent, but the 16 to 64 age cohort (the normal labor force) declined by 3.8 percent. The segment 

of the population over 65 grew by 0.6 percent. These shifts change dependency rations and lead the North 

Slope Borough to conclude that more resources will need to go toward education and senior service while 

the labor force and the economy are shrinking (North Slope Borough 2016). 

3.4.4.3 Local Economy: Community of Nuiqsut

Nuiqsut is served by scheduled and chartered flights and residents have access to the Dalton Highway for 

approximately 4 months of the year. Freight arrives year-round by air cargo (Alaska Department of 

Commerce, Community, and Economic Development Community Profiles). 

Nuiqsut’s economy, like other North Slope communities, is based on a mix of cash and subsistence 

hunting, fishing, and whaling. More recently, Nuiqsut and its village corporation have benefited 

financially from close proximity to oil production activities on the North Slope, particularly development 

of the Alpine Field. The Kuukpik Corporation has agreements with ConocoPhillips regarding bidding for 

contracts for construction services for any resource development taking place on Kuukpik Corporation 

lands. As noted in the 2004 Alpine Satellite Development Plan (Section 2, page 294) and based on 

information feceived from the Kuukpik Corporation, Nuiqsut has received a number of economic and 

employment opportunities as a result of development of the Alpine Field, including contracts to several 

Kuukpik Corporation subsidiaries or joint ventures, including Kuukpik Drilling; Nanuq (construction); 

Kuukpik/Arctic Services (camp and catering); Kuukpik/SAE (seismic); Kuukpik/LCMF (Umiaq) 

(surveying); and Kuukpik/Nana Management Services (security). Other businesses that have benefitted 

include the Kuukpik Hotel, an office space leased from the City of Nuiqsut, and storage of ice road 

equipment. 

The North Slope Borough reported that in 2015, there were 12 Nuiqsut residents working directly in the 

oil industry (North Slope Borough 2015). The nearby Alpine development has also provided seasonal 

work opportunities to Nuiqsut residents, including environmental monitoring. If past employment trends 

continue, direct employment of Nuiqsut residents by ConocoPhillips is expected to remain low and steady 

over the next 20 years. Nuiqsut residents were employed by ConocoPhillips or its contractors in the 

following positions: subsistence resource monitor, vehicle maintenance technician, drilling rig workers, 

oil spill response technicians, water treatment technicians, cooks, ice road laborers, ice road monitors, ice 

road drivers, security worker, and electrical/plumbing technician (North Slope Borough 2015). 

The North Slope Borough government, Kuukpik Corporation (village corporation and subsidiaries), and 

the North Slope Borough school district, are the top employers of Nuiqsut residents (North Slope 

Borough 2015). The employment shown in Table 52 provides the most recent breakdown of jobs for these 

specific employers. The Alaska Department of Labor and Workforce Development demonstrates a similar 

distribution in 2016, with over 60% of workers employed by the local government, about 1.5 in mining 

and natural resources, and approximately 15.5% in construction and trade, transportation, and utilities 

(Alaska Labor and Workforce Development 2016c). In 2015, 38 percent of the Inupiaq residents of 

Nuiqsut were employed on a permanent full-time basis and 16 percent were unemployed (North Slope 

Borough 2016). 
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Table 52. 2010 Total employment by employer, Nuiqsut

Employer Total Percent

City Government 18 11

North Slope Borough Government 49 30

North Slope Borough School District 27 16

Oil Industry 14 8

Private Construction 1 1

Arctic Slope Regional Corporation/Subsidiary 3 2

Village Corporation/Subsidiary 32 19

Transportation 4 2

Other 18 11

Total 166 100

Note: The numbers include only those individuals responding to the survey and the question about employment and employer. 

Source: North Slope Borough Economic Profile and Census Report: Nuiqsut Snapshot (2010).

Many residents receive dividends from the Alaska Permanent Fund, Arctic Slope Regional Corporation, 

and the Kuukpik Corporation. Kuukpik represents the interests of roughly 250 shareholders (Kuukpik 

2015). Shareholders receive a quarterly dividend of $30 to $50 per share. Most shareholders have 100 

shares and could receive annual income from dividends between $12,000 and $20,000. However, children 

born after December 18, 1971, acquire shares by inheritance or gift only. Those shareholders may hold 

fewer than 100 shares and receive smaller dividends, proportionately. This has created disparity within the 

community (North Slope Borough 2015) (see Chapter 4, Section 4.4.2, “Sociocultural Systems”).

As of 2014, ASRC had 261 Nuiqsut-enrolled shareholders, each with 100 shares. Dividends for 2014 

were approximately $5,000 for the year (North Slope Borough 2015). 

The cost of groceries in remote Alaska communities where most food is flown in is generally 146 percent 

higher, and can be double the cost, than in urban communities (ADOLWD 2018). The Alaska Department 

of Labor and Workforce Development maintains a database of Alaskan communities that are 

economically distressed. Approximately half of all Alaskan communities qualify as distressed by the 

standards used. Despite the high cost of living and economic disparity, Nuiqsut does not qualify as 

economically distressed (Denali Commission 2017). Nuiqsut residents pay a flat rate of $25 per month for 

natural gas heating due to an agreement negotiated by Kuukpik Corporation that brought a natural gas 

pipeline to the community from Alpine.

The City of Nuiqsut’s projected fiscal year 2018 revenues of about $1.7 million (City of Nuiqsut 2017). 

Grants, revenue sharing, and mitigation funds account for approximately 56 percent of the City’s 

operating revenue. Other revenue sources include bed and tobacco tax receipts, bingo income, and rents 

(Table 53).
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Table 53. City of Nuiqsut fiscal year 2018 Projected Revenues

Income Amount Percent

State Community Revenue Sharing $81,000 5%

North Slope Borough Revenues $250,827 15%

NRP-A Mitigation Impact $410,000 24%

ASRC Grants $10,000 1%

Impact Mitigation Funds $200,000 12%

Bingo $157,687 9%

USPS Nuiqsut CPU $95,963 6%

Rents $85,000 5%

Hotel Bed & Tobacco Excise Tax / Other $411,650 24%

Total $1,702,127 100%

Source: Arnold (2017).

The Fiscal Year 2017 NPR-A Impact Mitigation Program fund allocation for the community of Nuiqsut 

included $330,000 for Local Government Operations and $80,000 for Youth Center Operations and 

Maintenance. As of June 2018, the State has disbursed approximately $256,000 of these grants to 

Nuiqsut, and both grants remain active. The City of Nuiqsut included these revenues as part of the fiscal 

year 2018 operating budget. Nuiqsut projected expenses to equal revenues in fiscal year 2018. 

NPR-A Impact Mitigation Program grants to the City of Nuiqsut for fiscal year 2019 will total $1,409,064 

(ADCCED 2018) and include: 

• Local Government Operations and Maintenance = $949,203 

• Kisik Center Maintenance Project = $192,035

• Youth Center Operations and Maintenance = $267,826 

In recent years, the State has suspended award grants to the City of Nuiqsut in response to uncompleted 

audits for fiscal years 2012, 2013, and 2014. The administrator for the City of Nuiqsut contended that 

these audits were nearly impossible to produce due to past cuts to funding. The State has historically 

refused to grant funding for outside managers, administrators, or accountants of any kind, but the City of 

Nuiqsut has inadequate capacity to manage accounts on this level (Arnold 2017). However, the City of 

Nuiqsut and the State have appeared to resolve past issues as indicated by disbursements of fiscal year 

2017 grants and the substantial grant recommendation for fiscal year 2019. The City administrator also 

indicated that “after a long period of NPR-A Impact Mitigation Program underfunding relative to the 

rapidly increasing impacts of oil and gas exploration and development within the Nuiqsut area, which had 

not allowed the City to grow its capacity to sufficiently address associated issues, the City has recently 

moved forward with a planning initiative to develop the administrative systems necessary to manage these 

impacts” (Arnold 2018).

3.4.4.4 State Economy

The oil and gas industry continues to be an important contributor to the state economy. In 2016, there 

were 11,300 direct oil and gas jobs in the state (Alaska Department of Labor and Workforce Development 

2017c). Besides the direct jobs, there are thousands of indirect jobs in security, catering, accommodations, 

facilities management, transportation, engineering services, and logistics, which support the oil and gas 

industry, but are not categorized as direct oil and gas jobs. The most recent estimate for total direct, 

indirect, and induced jobs associated with the oil and gas industry in Alaska, was 45,575 jobs in 2016. 
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These jobs contributed $3.1 billion in annual payroll to Alaska residents that year (McDowell Group 

2017).

Oil and gas industry jobs on the North Slope account for 66 percent of the direct oil and gas jobs in the 

State in 2016 (Alaska Department of Labor and Workforce Development 2017a). However, most of these 

workers commute to the North Slope on a rotational basis and live outside of the North Slope. Many live 

in Anchorage, Fairbanks, the Matanuska-Susitna Borough, and other Alaskan population centers, and 

therefore contribute to these regions’ economies. Many live outside of Alaska and, largely because there is 

no state income tax in Alaska, are not considered to contribute significantly to the Alaskan economy. A 

recent study on the economic benefits of the oil industry in Alaska estimated that the industry generated 5 

direct jobs (oil companies), 70 indirect jobs (oil and gas support sector), and 1,925 induced jobs by 

residents of the North Slope Borough. In total, the industry generated 3,000 jobs held by North Slope 

Borough residents, with an annual payroll of $115 million (McDowell Group 2014).

The price of oil declined sharply in 2014 and 2015. The economy of Alaska faces two major hurdles 

related to the drop in oil prices: significant loss of jobs and the state government budget dilemma (Alaska 

Department of Labor and Workforce Development 2017a). After oil prices fell, job losses spread through 

nearly all sectors of Alaska’s economy (Alaska Department of Labor and Workforce Development 

2017a). Initial losses were limited to direct oil industry jobs and closely related sectors. In 2016, losses 

spread to unrelated sectors and the state experienced a 2.0 percent employment decline. More broad-based 

decline is predicted for 2017: the state is forecast to lose 2.3 percent, or about 7,500 jobs (Alaska 

Department of Labor and Workforce Development 2017a). 

The Alaska Department of Revenue anticipates that the state government’s high level of dependence on 

oil revenue will continue, with revenues being very sensitive to oil price and oil production. Oil-based 

revenue continues to dominate the state’s unrestricted general fund revenue. The general fund pays for 

almost every state service, including the education system, transportation infrastructure, public health and 

safety services, and a host of other programs throughout Alaska. In fiscal year 2013, state revenues from 

the oil industry were $6.9 billion, which accounted for 92 percent of the total state unrestricted revenue 

(Alaska Department of Labor and Workforce Development 2017b). In fiscal year 2014, approximately 88 

percent of the $5.4 billion in unrestricted revenue could be attributed to oil revenue (Alaska Department 

of Revenue 2014). In 2016, the unrestricted general fund had decreased by almost $4 billion to $1.5 

billion, of which 72 percent was attributed to oil revenue. Unrestricted general fund revenue is now 

forecast to be $1.6 billion in fiscal year 2017 and $1.8 billion in fiscal year 2018. The revenue forecast is 

driven in part by an expectation for North Slope oil production to average 523,700 barrels per day in 

fiscal year 2017 before declining to an average of 459,900 barrels per day in fiscal year 2018 (Alaska 

Department of Revenue 2017).

With respect to the State of Alaska’s 50 percent share of revenues from oil and gas activity in the NPR-A, 

the latest report indicates that the State’s share of rents, royalties, and bonuses received from leases in the 

NPR-A in fiscal year 16 was $1.8 million. That amount was the lowest received in a decade, but the 

amount forecast to come to the State from NPR-A activity in 2017 and 2018 is $4.3 million each year 

(Alaska Department of Revenue 2017).

3.4.5 Land Use

Land use is governed by a series of laws, regulations, and authorizations that apply to the NPR-A and the 

proposed GMT2 Project. Both the 2013 Integrated Activity Plan and the GMT1 Supplemental EIS 

provide a detailed list of the key elements controlling land use as updated from the 2004 EIS. Land 

ownership in the project area is mixed and still changing. There are lands that have been selected by the 

local village and regional Native Corporations. BLM, the Kuukpik Corporation, and Arctic Slope 

Regional Corporation own and manage different portions of the surface land involved, while the BLM 
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and Arctic Slope Regional Corporation own and manage different portions of the subsurface mineral 

estate. Land ownership in the project area is shown in Map 3.1-1. 

The GMT2 Project area (approximately 155,500 acres) encompasses approximately 96,600 acres of 

conveyed land and 9,400 acres of selected land (BLM managed). The remaining acreage of the project 

area consists of federally managed lands managed by BLM. The majority of the proposed GMT2 Project 

facilities would be located on Kuukpik Corporation-selected lands that are not conveyed. This includes 

approximately 14.0 acres of Kuukpik-selected lands at the drill site location, and 40.0 acres of Kuukpikselected lands along the road and pipeline route of the proposed action. There are approximately 82 acres 

of Kuupik-selected land encompassed by the proposed GMT2 pipeline and access road. With 

approximately 15 acres of land that would be directly affected by the proposed GMT2 Project facilities 

still within federal ownership and are not conveyed or selected lands.

Federal oil and gas leases, permits, or rights-of-way on selected lands remain under BLM management 

until or if the land is conveyed. Administration of federal oil and gas leases is waived when the affected 

subsurface is conveyed. Lease stipulations continue to apply if the new subsurface owner choses to 

enforce the requirements; the BLM no longer has jurisdiction over the subsurface. If the surface is not 

conveyed then the BLM would continue to manage the surface

South of the proposed GMT2 pad location, but within the GMT2 Project area, is the Colville River 

Special Area (see Map 2.1-2). The Colville River Special Area was designated in 1977 to protect nesting 

and foraging habitat of the Arctic peregrine falcon. The Colville River Special Area Management Plan 

provides protections that must be followed for any activity in the area. A list of protections may be found 

in the Record of Decision for the Colville River Special Area (BLM 2008).

North of the GMT2 Project area, is the Teshekpuk Lake Special Area. The Teshekpuk Lake Special Area 

was designated in 1977, pursuant to the NPRPA with acreage expanded upon the signing of the 2013 

BLM record of decision. The best management practices that cover the area may be found within 

Appendix A of the 2013 record of decision. The outer boundary of the special area is approximately 3.1 

miles northwest of the proposed GMT2 pad. 

3.4.5.1 Local Transportation

Transportation facilities were described in BLM (2004a, Section 3.4.9), with information updated in BLM 

(2012, Section 3.4.10). This section tiers to and incorporates by reference relevant information, while 

placing emphasis on the proposed GMT2 Project location. Surface transportation in the project area 

includes local roads in Alpine and Native Village of Nuiqsut and seasonal ice and snow roads from the 

existing oil field gravel road system to Alpine, which is now connected by gravel road to the Native 

Village of Nuiqsut. The BLM has issued numerous authorizations for ice roads and snow trails from 

Alpine and Kuparuk to exploration drilling sites in the NPR-A. The BLM also issues rights-of-way for 

NPR-A-area-wide winter use for transport across the tundra with tundra-approved vehicles. Residents of 

the Native Village of Nuiqsut use snowmobile and other off-road vehicles for off-road travel. Local 

residents also use small boats to access subsistence resources. 

Air travel is supported by an airport at the Native Village of Nuiqsut and airstrip at Alpine. Helicopter use 

in the area is a concern for the people of the Native Village of Nuiqsut due to the potential impacts to 

subsistence resources and activities. BLM permittees are required to report to the BLM the number and 

location of take-offs and landings made in the NPR-A at the end of the summer. The date, time, and 

location of the take-offs and landings are collected; however, the BLM does not collect data on take-offs 

or landings outside of the NPR-A, or for flight-tracking. The location of permits change from year to 

year; the locations of aircraft landings are generally clustered around research areas and oil and gas 

development study areas. 
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A summary of projected new aircraft traffic, including helicopter use, for all alternatives is presented in 

Chapter 2 flight tables and Appendix B.

3.4.5.2 Recreation

The recreation resources of the project area are described in BLM (2004a, Section 3.4.7) and BLM (2013, 

Section 3.4.6). This section tiers to and incorporates by reference relevant information, while placing 

emphasis on the proposed GMT2 Project location. There are few specific recreation trends in the area. 

Public access to the project area is limited to those who use aircraft to the Native Village of Nuiqsut 

Airport or small fixed-wing aircraft that can land on the tundra. There are no developed recreation 

facilities within the NPR-A. The project area falls within the State of Alaska Game Management Area 

(GMU) 26-12. The BLM has two special recreation permits that cover GMU 26-12, with one permitted in 

the GMT2 Project area; however, generally they do not use the project area. Permitted recreation may 

only take place if the activity does not interfere with the purpose of the NRP-A. 

Wild and Scenic Rivers

There are no designated or proposed wild and scenic rivers located within the GMT2 Project area (BLM 

2012, Section 3.4.7) (Map 3.4.7-1).

Wilderness

The BLM (2012, Section 3.4.8) described the wilderness characteristics of the NPR-A. This section tiers 

to and incorporates by reference relevant information, while placing emphasis on the proposed GMT2 

Project location. The BLM (2012, Section 3.4.8) characterized eight specific wilderness evaluation areas. 

The project area falls within Wilderness Evaluation Area H. This area encompasses Nuiqsut and Umiat, 

and contains various oil and gas leases and legacy wells. There are roads within Nuiqsut and at Umiat, 

and both have airstrips. The land where the GMT1–GMT2 pipeline and GMT2 pad are proposed is 

completely undeveloped land that possesses wilderness characteristics. There are no new data on the 

wilderness values associated with the proposed project area since the completion of the NPR-A Integrated 

Activity Plan Record of Decision (BLM 2013a). The area was inventoried as having wilderness 

characteristics at that time and has not changed significantly since then. 

3.4.5.3 Visual Resources

This section tiers to and incorporates by reference relevant information in BLM (2012, Section 3.4.9), 

while placing emphasis on the proposed GMT2 Project location. The visual resources inventory of the 

NPR-A are described in terms of scenic quality, visual sensitivity, and distance zones (BLM 2012, Section 

3.4.9). The current visual resource management class assigned to the majority of the project area is Visual 

Resource Management Class IV with a small portion along the Colville River assigned Class III (BLM 

2013, Section 3.4.4.3). The change allowed with Visual Resource Management Class IV is high and 

activities may attract attention and dominate the view but are still mitigated. The change allowed with 

Visual Resource Management Class III is moderate and activities may attract attention but should not 

dominate the view. This section tiers to and incorporates by reference relevant information, while placing 

emphasis on the proposed GMT2 Project location.

The visual resource management system provides a way used by the BLM to analyze potential visual 

impacts and an opportunity to apply visual design techniques to ensure that any surface-disturbing 

activities are compatible with the surroundings. The classification system applies only to federally 

managed land managed by the BLM and to lands selected, but not yet transferred from federal ownership. 

BLM (2012 Section 3.4.9) and BLM (2014 Section 3.4.4.3) describes the visual modifications in the 

project area. In the years since, a spur road connecting Native Village of Nuiqsut to the existing road 
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system in the Alpine Field has been constructed; however, this was not on BLM-managed land. The 

construction of GMT1 is ongoing and has changed the landscape, but not changed the associated visual 

resource management class. 

BLM (2004b) authorized the approval of the proposed GMT2 Project, and GMT2 will be developed 

under the stipulations, required operating procedures, and best management practices described in Section 

4.7, “Mitigation Measures and Monitoring.” There has been little change in the existing or prospective 

use of the project area for oil and gas or other uses that could impact visual resources of federally 

managed land in the project area that were not considered in BLM (2004a, 2004b) and the subsequent 

authorizations for construction and operation of production facilities in the Alpine Field that were 

contemplated in 2004. BLM (2012, 2013a) considered the visual resources associated with the 

development facilities constructed since 2004, and assumed the GMT Unit would be developed by both 

the GMT1 Project and the GMT2 Project. The proposed GMT1 and GMT2 Projects have only been 

slightly modified since 2004 (see Section 2.1, “GMT2 Project Changes Over Time”).

3.4.6 Subsistence 

This section describes the affected environment for subsistence resources and traditional land use by the 

community of Nuiqsut whose residents harvest and/or rely on resources in the vicinity of the GMT2 

Project. Because the proposed GMT2 Project has already been evaluated within earlier NEPA documents, 

namely BLM (2004, 2012), this section is tiered off of those documents and focuses on information that is 

new or updated since those previous EISs. This section includes a general overview of subsistence use 

patterns for Nuiqsut, including the importance of subsistence, the seasonal round, harvest estimates, and 

subsistence use areas. Additional detail regarding Nuiqsut subsistence uses, including additional figures 

and tables, is provided in Appendix F. 

3.4.6.1 Study Area

The study area for subsistence includes all areas used by the community of Nuiqsut for subsistence 

activities because these areas could potentially be directly or indirectly affected by the proposed project. 

The project study area is defined as a 2.5-mile buffer surrounding the GMT2 Project Footprint and is the 

area where direct impacts may occur, particularly in overland areas where project components are 

proposed. Indirect impacts may occur in the project study area, but may also extend to the study area for 

impacts related to resource availability or hunter avoidance. Additional North Slope communities 

including Anaktuvuk Pass, Atqasuk, and Utqiagvik (formerly Barrow) also have subsistence use areas 

within or near the project study area; however, these use areas are located on the periphery of those 

communities’ overall subsistence use areas. The affected environment and environmental consequences 

for those communities related to broader development are discussed and analyzed in BLM (2004, Section 

3.4.3 and 4.4.3) and BLM (2012, Section 3.4.3, 4.3.13, 4.4.13, 4.5.13, 4.6.13, and 4.7.13).

3.4.6.2 Subsistence Definition and Relevant Legislation

Both BLM (2004, Section 3.4.3.1) and BLM (2012, Section 3.4.3.1) provide an overview of the 

importance of subsistence, definition of subsistence, and relevant legislation governing the regulatory 

environment in which subsistence activities are permitted under state and federal regulations. In summary, 

subsistence is recognized as a central aspect of North Slope culture and life and is the cornerstone of the 

traditional relationship of the Iñupiaq people with their environment. Residents of the North Slope of 

Alaska rely on subsistence harvests of plant and animal resources for nutritional sustenance and cultural 

and social well-being. Subsistence is not only a source of food for North Slope residents, but the activities 

associated with subsistence strengthen community and family social ties; reinforce community and 

individual cultural identity; and provide a link between contemporary Iñupiat and their ancestors. 

Subsistence customs and traditions encompass processing, sharing, redistribution networks, and 
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cooperative and individual hunting, fishing, gathering, and ceremonial activities. These activities are 

guided by traditional knowledge based on a long-standing relationship with the environment. Both federal 

and state regulations define subsistence uses to include the customary and traditional uses of wild 

renewable resources for food, shelter, fuel, clothing, and other uses (Alaska National Interest Lands 

Conservation Act, Title VIII, Section 803, and AS 16.05.940[33]). The Alaska Federation of Natives 

views subsistence to not only encompass the practices of hunting, fishing, and gathering, but as a way of 

life that has sustained Alaska Natives for thousands of years and a set of values associated with those 

practices (Alaska Federation of Natives 2012). A recent U.S. Army Corps of Engineers study conducted a 

literature review of existing subsistence definitions and provided a proposed definition of subsistence, 

which addressed the economic, social, cultural, and nutritional elements and components of subsistence 

that have not been emphasized in previous definitions. In part, this definition reads as follows:

Subsistence refers to a way of life in which wild renewable resources are obtained, processed, and 

distributed for household and communal consumption according to prescribed social and cultural 

systems and values.... 

.... The subsistence way of life satisfies to various degrees and in various contexts, the economic, 

social, cultural, and nutritional needs of subsistence-based communities (ResourceEcon et al. 

2011).

The proposed project is located primarily on federally managed lands within the northeast NPR-A. The 

pipeline and road components also cross federal, Kuukpik Corporation lands, Kuukpik Corporation 

selected lands (managed by BLM), and the ancillary water pipeline between CD1 and CD4 crosses State 

and Kuukpik Corporation lands. In addition, resources that migrate through the study area, such as 

caribou, waterfowl, and migratory fish, may be harvested outside of the study area on other state, federal, 

or private lands. In Alaska, subsistence hunting and fishing are regulated under a dual management 

system by the State of Alaska and the federal government. Federal subsistence law regulates federal 

subsistence uses; state law regulates state subsistence uses. The federal government recognizes 

subsistence priorities for rural residents on federal public lands, while Alaska considers all residents to 

have an equal right to participate in subsistence hunting and fishing when resource abundance and 

harvestable surpluses are sufficient to meet the demand for all subsistence and other uses. Subsistence 

activities on all lands in Alaska, including private lands, are subject to state and federal subsistence 

regulations. Because the project is located on federally managed lands, Section 810 of Alaska National 

Interest Lands Conservation Act is applicable and requires a subsistence evaluation. This evaluation 

includes findings on the following:

• 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. Section 3120).

3.4.6.3 Overview of Subsistence Uses

The following sections summarize BLM (2004, Section 3.4.3.2), BLM (2012, Section 3.4.3.3), and BLM 

(2014, Section 3.4.5.3) descriptions of Nuiqsut’s subsistence uses as well as incorporating new 

information that were not included in the previous EISs. Examples of subsistence baseline indicators that 

are useful in characterizing subsistence uses include:

• Subsistence use areas 

• Travel method

• Travel routes 

• Timing of harvest activity

• Duration and frequency of trips 
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• Observed change in resources

• Harvest diversity 

• Harvest amount 

• Harvest participation

• Harvest success 

• Harvest sharing

• Harvest effort

The following discussion describes how these indicators can be used in characterizing subsistence uses 

under five primary categories: (1) subsistence use areas, (2) seasonal round, (3) method of transportation, 

(4) harvest data, and (5) community participation. 

Subsistence use areas refer to the locations in which subsistence users search for and harvest subsistence 

resources. Use of an area for subsistence purposes is dependent on being able to access the area and on 

the availability of subsistence resources within the area. Subsistence use areas can range from small 

fishing locations to expansive overland caribou hunting areas and vary greatly in size depending on the 

targeted resource. Besides mapped data of these use areas, other key subsistence baseline indicators that 

are useful in characterizing subsistence use areas include frequency and duration of trips (e.g., harvest 

effort). 

Seasonal round refers to the timing of subsistence activities and is often characterized by highs and lows 

of activity for different resources throughout the year. The timing of residents’ subsistence activities can 

be influenced by a number of factors, including the availability of the wildlife and vegetation harvested 

by residents, climate and weather conditions, harvest regulations, and even personal reasons such as work 

commitments, financial means, and family needs. Rarely are individual resources pursued with equal 

intensity throughout the year. 

Method of transportation addresses user access and refers to the equipment (e.g., four-wheeler, 

snowmachine, truck, boat) used within subsistence use areas and the travel routes that are used to access 

subsistence use areas. Methods of transportation are factors in determining the size and location of 

subsistence use areas. Communities with residents who can afford airplanes, for example, may access a 

larger area than communities without, while residents with more limited means of transportation (e.g., 

four-wheelers) or limited funds often subsist within a smaller use area near the community. Travel routes 

may vary from season to season based on factors such as snow and ice conditions, water levels, and the 

presence of infrastructure which blocks or facilitates access. However, despite annual variations, 

harvesters often follow similar paths to specific harvesting locations using routes which have been proven 

to be safe and efficient based on terrain and other factors. 

Harvest data address resource availability by describing the subsistence resources that are available 

within the study area or that may move through the study area and are later harvested in other areas. 

Successful subsistence harvests depend on continued resource availability in adequate numbers and health 

in traditional use areas. Key subsistence indicators that characterize harvest data and resource availability 

include per capita and household harvest amounts, harvest numbers, percent of households harvesting, 

and harvest diversity. Habitat areas for subsistence resources are also important in characterizing resource 

availability. In some cases, habitat areas may be located outside the range of a community’s subsistence 

use areas, yet they are still important because they ensure the health and availability of those resources 

within the community’s subsistence use area. Traditional knowledge is an important source of information 

that is useful in characterizing existing resource availability, resource changes, and habitat areas.

Community participation refers to the levels of existing community involvement in subsistence 

activities. Participation in subsistence activities promotes the transmission of skills from generation to 

generation, and participation in sharing strengthens community cohesion within and among communities 
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in the region and provides for an extensive distribution network of subsistence foods. Because Alaska 

Native culture is integrally tied to subsistence activities, higher levels of participation provide more 

opportunities for community members to pass on traditional knowledge and cultural values to younger 

generations. Subsistence participation levels are most often described using baseline indicators from 

community household harvest surveys, including percent of households or harvesters using, attempting to 

harvest (harvest effort), and sharing subsistence resources. 

Sources of data that inform the above-described indicators for Nuiqsut include harvest data from the 

North Slope Borough, Alaska Department of Fish and Game, and Stephen R. Braund and Associates, and 

subsistence mapping studies such as Pedersen (1979), BLM (2004), Stephen R. Braund and Associates 

(2010a, 2010b, 2011, 2012, 2013, 2014, 2015, 2016, 2017, and 2018).Table 54 presents a summary of the 

available subsistence data for the community of Nuiqsut. Additional subsistence harvest and use area data 

not addressed in any of the previous EISs related to GMT2 include caribou use area and harvest data from 

the Nuiqsut Caribou Subsistence Monitoring Project (Stephen R. Braund and Associates 2014, 2015, 

2016, 2017, and 2018), and Alaska Department of Fish and Game Division of Subsistence’s 2016

publication: Harvests and Uses of Wild Resources in 4 Interior Alaska Communities and 3 Arctic Alaska 

Communities, 2014 (Brown et al. 2016). 
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Table 54. Community of Nuiqsut data sources, subsistence and traditional land uses

Harvest Data Subsistence Use Area Data

Study Seasonal Round

Year Resource Source Study Year Resource Source

1985 All Resources Alaska Department of Fish 

and Game (2017)

Lifetime 

to 1979

All 

Resources

Pederson (1979) Bacon et al. 2009

1992 All Resources Fuller and George (1999) Early 1970s All 

Resources

Brown (1979) Brower and Hepa 1998

1993 All Resources Alaska Department of Fish 

and Game (2017)

1973–1986 All 

Resources

Pederson (1986) Brown 1979

1994–

1995

All Resources Brower and Hepa (1998) 1994–2003 Non-Marine BLM (2004) Brown et al. 2016

1995–

1996

All Resources Bacon et al. (2009) 1995–2006 All 

Resources

Stephen R. Braund and Associates 

(2010a)

EDAW Inc. 2008

2000–

2001

All Resources Bacon et al. (2009) 2003–2007 Caribou Braem et al. (2011) Fuller and George 1999

2003–

2007

Caribou Braem et al. (2011) 2008–2016 Caribou Stephen R. Braund and Associates 

(2010b, 2011, 2012, 2013, 2014, 2015, 

2016, 2017, 2018)

Impact Assessment Inc. 1990

2010–

2015

Caribou Stephen R. Braund and 

Associates (2012, 2013, 

2014, 2015, 2016, 2017, 

2018)

2014 All 

Resources

Brown et al. (2016) Libbey et al. 1979

2014 All Resources Brown et al. (2016) Research Foundation of the 

State University of New York 

1984

Stephen R. Braund and 

Associates 2010a

a The 2016 study year data are from the draft version of the Year 9 report for the Nuiqsut Subsistence Caribou Monitoring Project. The draft report is currently being revised in 

response to comments from the Nuiqsut Caribou Panel
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Subsistence Use Areas

Figure 14shows Nuiqsut contemporary subsistence use areas for several time periods, as documented by 

Pedersen (1986), BLM (2004), Stephen R. Braund and Associates (2010a)3

, and Brown et al. (2016). All 

four study periods cover a similar area ranging from between Utqiagvik (formerly Barrow) in the west 

and Kaktovik in the east, and as far south as Anaktuvuk Pass. Stephen R. Braund and Associates (2010a) 

all resources use areas document Nuiqsut residents traveling beyond Atqasuk to Utqiagvik (formerly 

Barrow) in the west, offshore more than 50 miles northeast of Cross Island, to Camden Bay in the east, 

and beyond the Colville River in the south. The majority of Nuiqsut 1995–2006 use areas are 

concentrated around the Colville River, overland areas to the south and southwest of the community, 

offshore areas north of the Colville River Delta, and northeast of Cross Island. Pedersen (1986) and BLM 

(2004) use areas for Nuiqsut are all within the extent of Stephen R. Braund and Associates (2010a) use 

areas described above with the exception of the 1973–1986 data extending as far as Kaktovik in the east 

and Anaktuvuk Pass in the south. Alaska Department of Fish and Game recently completed a harvest 

survey in Nuiqsut with a 1-year mapping component (Brown et al. 2016).

Nuiqsut’s 2014 use areas are concentrated in areas showing the highest overlapping use documented by 

Stephen R. Braund and Associates 2010a except for more extensive 2014 overland areas located west of 

Umiat and farther south into the Brooks Range as far as Anaktuvuk Pass (Stephen R. Braund and 

Associates [2010a] notes that use areas extended farther south than field maps allowed). All four study 

periods overlap with the project study area. Subsistence use area data from ConocoPhillips’s Nuiqsut 

Caribou Subsistence Monitoring Project, including more recent information for the 2012 to 2016 study 

years (Stephen R. Braund and Associates 2010b, 2011, 2012, 2013, 2014, 2015, 2016, 2017, and 2018) 

are presented in Figure 15. These 9 years of data show high use of the Colville River and areas west of the 

community for caribou hunting during the 2008–2016 study years. Appendix F, Figures A-2 through A-9 

display individual, resource-specific, subsistence use areas for available study years in Nuiqsut.

Pedersen’s (1979) lifetime (pre-1979) use areas (Figure 16) show Nuiqsut residents utilizing a smaller 

area than the contemporary subsistence use areas shown on Figure 14, but still an extensive area centered 

around the community to harvest subsistence resources. Reported use areas extended offshore 

approximately 15 miles, as far east as Camden Bay, south along the Itkillik River, and west as far as 

Teshekpuk Lake. As part of Nuiqsut Paisaŋich-Nuiqsut Heritage: A Cultural Plan, Brown (1979) recorded 

all resources use areas (Figure 16). For all subsistence resources, the study documented early 1970s use 

areas that extended south around the Colville and Itkillik river drainages, offshore between Cross Island 

and Cape Halkett, and in overland areas east and west of the community. Both studies documented a 

similar extent of use areas because they were conducted during the same study year for the relatively 

same time period.

 3 Stephen R. Braund and Associates 2010a interviews reported information for the following resources: caribou, moose, bowhead 

whale, Arctic cisco, Arctic char/Dolly Varden, broad whitefish, burbot, geese, eider, ringed seal, bearded seal, walrus, wolf, and 

wolverine. Other resources such as ptarmigan, polar bear, vegetation, or other types of non-salmon fish and salmon were not 

documented and thus project area specific data are not available for these resources.
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Figure 14. Nuiqsut contemporary subsistence use areas, all resources
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AE Nuiqsut Caribou Subsistence Use Areas, 2008-2015 

Figure 15. Nuiqsut caribou subsistence use areas, 2008–2016
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Figure 16. Nuiqsut historic and lifetime subsistence use areas, all resources
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Seasonal Round

Table 55 provides seasonal round data based on reports from the 1970s through the 2010s. The spring 

month of April marks a transition from the late winter/early spring harvesting of furbearers, seals (through 

the ice), and upland game birds to the spring waterfowl hunting season which peaks in May and June. 

Beginning as early as May, residents travel by boat along the local river system and into the Beaufort Sea 

to harvest various resources including caribou, waterfowl, seals, and fish. Caribou (tuttu) harvests occur 

throughout the year, but with the most intensity during the summer and fall months of June through 

October. Summer harvests of non-salmon fish such as broad whitefish (aanaaqłiq) begin in July and 

continue into August and September. In addition to traveling inland along the Colville River during the 

summer for fishing and caribou hunting, residents continue to travel to the ocean to hunt for ringed seals 

(qaiġulik), bearded seals (ugruk), and king and common eiders (qiŋalik, amauligruaq) during the months 

of June, July, August, and September (Stephen R. Braund and Associates 2010a). Berry and plant 

gathering also occur during the summer months. Moose (tuttuvak) hunting takes place, often alongside 

caribou hunting, in August and September along river hunting areas south of Nuiqsut. Bowhead (aġviq) 

whaling occurs in September when whaling crews are stationed at Cross Island, with preparations for the 

whaling season beginning in August. The fall month of October is spent fishing and harvesting caribou 

close to the community. Gill netting, primarily for Arctic cisco (qaaqtaq), is most productive between 

October and mid-November. During the winter months, furbearer hunters pursue wolves (amaġuq) and 

wolverines (qavvik), target caribou and ptarmigan (aqargiq) as needed and available, and fish for burbot 

(tittaaliq) through the ice. Overall, Nuiqsut harvesters target the highest numbers of resources during the 

summer/fall months of August and September (Figure 17).

Method of Transportation

The travel methods used to access subsistence harvesting areas are important to understanding how a 

project may reduce, obstruct, or facilitate harvester access. Nuiqsut travel methods to subsistence use 

areas have been documented by Stephen R. Braund and Associates (2010a) for several species of fish, 

moose, wolf, wolverine, bowhead whale, seals, geese, and eider for the 1995–2006 time period. Stephen 

R. Braund and Associates (2018) has also documented travel methods to caribou subsistence use areas for 

the time period of 2008–2016. Figure 18 and Table 56 present the various methods of transportation used 

to travel to use areas for different resources. 

Nuiqsut residents travel by boat to access the greatest diversity of resources (nine) (Figure 18). These 

resources include caribou, moose, bowhead whale, seals, eider, Arctic char/Dolly Varden 

(paikfuk/iqalukpik), and broad whitefish. The majority of boat travel occurs along the Colville River and 

associated tributaries, in addition to the Beaufort Sea. Arctic cisco and burbot, wolf and wolverine, and 

geese were the only resources in which the primary method of travel was not by boat. For these resources, 

Nuiqsut residents reported traveling by snowmachine to net sets or jigging locations for fish, primarily on 

the Colville River, or traveling in larger overland areas to search for furbearers or to access waterfowl 

hunting areas. Residents use other travel methods less commonly, including foot travel (fish, moose, and 

geese), car/truck (Arctic cisco, burbot, caribou, and geese), four-wheeler (caribou and geese), and plane 

(wolf and wolverine). In recent years, Stephen R. Braund and Associates has documented greater use of 

four-wheelers and cars/trucks when hunting for caribou, which may reflect increased use of the recently 

constructed Spur Road for hunting (Stephen R. Braund and Associates 2017).
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Table 55. Nuiqsut annual cycle of subsistence activities

Resources Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec

Freshwater Non-salmon Moderate Limited Moderate Moderate Limited Limited Moderate High High High High Limited

Marine Non-salmon -- -- -- -- -- -- -- -- High High -- --

Salmon -- -- -- -- -- -- High Moderate -- -- -- --

Caribou Limited Limited Limited Limited Limited Moderate High High Moderate Moderate Limited Limited

Moose Limited -- -- -- -- -- Limited High High Moderate Limited Limited

Bear Moderate Moderate Moderate Limited Limited Limited Limited Limited High Moderate Moderate Moderate

Muskox -- -- -- -- -- -- -- High High High -- --

Furbearers High High High High Moderate Limited Limited Limited Limited Limited Moderate High

Small Land Mammals -- -- -- -- Limited Limited High High Limited -- -- --

Marine Mammals -- -- Moderate High Limited Limited Moderate High High Limited Limited Limited

Upland Birds Moderate Moderate High High Moderate Limited -- Limited Limited Moderate Moderate Moderate

Waterfowl -- -- -- Limited High High Moderate Moderate Moderate Moderate Limited Limited

Eggs -- -- -- -- -- High -- -- -- -- -- --

Plants and Berries -- -- -- -- Limited Limited High High -- -- -- --

Notes: Rankings of “High,” “Moderate,” and “Limited” are based on an analysis of all sources of seasonal round data listed below. For each source, the study team assigned each 

month a ranking of “1,” “2,” or “3” based on the intensity of use identified in that source’s data set. The study team then summed the individual rankings for each month across all 

sources, and then assigned a ranking of “1 (Limited),” “2 (Moderate),” or “3 (High)” based on the summed values. 

Sources: Bacon et al. (2009); Braem et al. (2011); Brower and Hepa (1998); Brown (1979); Brown et al. (2016); EDAW Inc. (2008); Fuller and George (1999) (where resource category 

data are available); Galginaitis (2014); Hoffman et al. (1988); Libbey et al. (1979); Stephen R. Braund and Associates (2010a, 2018).

(-) = No activity and/or harvest; Limited = Limited activity and/or harvest; Moderate = Moderate activity and/or harvest; High = High activity and/or harvest
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Figure 17. Nuiqsut number of subsistence resource categories by month

Sources: Bacon et al. (2009); Brown et al. (2016); Brower and Hepa (1998); EDAW Inc. (2008); Fuller and George (1999); 

Galginaitis (2014); Libbey et al. (1979); Stephen R. Braund and Associates (2010a, 2018).

Figure 18. Nuiqsut number of subsistence resource categories by travel method

Sources: (parentheses depict the study years represented by the data): Stephen R. Braund and Associates (2010a 

[1995–2006]), (2018 [2008–2016]).

0

1

2

3

4

5

6

7

8

9

10

11

12

13

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec

Number of Resources
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Table 56. Nuiqsut travel method by subsistence resource

Resources Boat Snowmachine Foot Car/Truck Four-wheeler Plane

Arctic Cisco & Burbot

Arctic Char/ Dolly Varden & 

Broad Whitefish

Caribou

Moose

Wolf & Wolverine

Bowhead Whale

Seals

Geese

Eider

Notes: For each resource, darker shades indicate greater use of a travel method; lighter shades indicate lesser use of a travel 

method. Caribou data based on Stephen R. Braund and Associates 2018, all other resources based on Stephen R. Braund and 

Associates 2010a.

Harvest Data

Data on per capita pounds are available for 3 study years and range from 399 pounds in 1985 to 896 

pounds in 2014. Resources providing the highest percentage of the total harvest vary over the study years; 

marine mammals (primarily bowhead whale) contributed the highest amount to the total subsistence 

harvest during 1992, 1995–1996, 2000–2001, and 2014; non-salmon fish were the top harvested resource 

category during the remaining 3 study years (1985, 1993, and 1994–1995). Large land mammals 

(primarily caribou, but also moose) were generally the second or third most harvested resource category 

during all study years. In terms of species, bowhead whales, caribou, Arctic cisco, broad whitefish, and 

moose were generally the top harvested species during most study years (Appendix F, Tables F-1 and F2). Other subsistence species that have contributed highly to Nuiqsut subsistence harvests over the study 

years include seals, geese, least cisco (iqalusaaq), Arctic grayling (sulukpaugaq), and burbot. In 2014, the 

most recent comprehensive household harvest survey conducted in Nuiqsut, bowhead whales were the top 

species harvested (accounting for 39.8 percent of the harvest), followed by caribou (28.3 percent), broad 

whitefish (9.8 percent), and Arctic cisco (8.7 percent) (Table F-2). Over half of Nuiqsut households 

participated in harvests of non-salmon fish, large land mammals, marine mammals, migratory birds, and 

vegetation (Table F-1). Salmon harvests are relatively minor in Nuiqsut; however, according to a recent 

study sponsored by the Bureau of Ocean Energy Management there is evidence that suggests salmon 

catches in Nuiqsut are increasing (Carothers et al. 2013). The most recent household survey in Nuiqsut 

(2014) show higher salmon harvests than in previous years (Table F-1).

Community Participation

According to the available data, in 1985, 1993, and 2014, 100 percent of Nuiqsut households reported 

using subsistence resources (i.e., harvesting, processing, storing, distributing, preparing, and/or 

consuming) and over 90 percent of households participated in subsistence activities (i.e., attempted 

harvests of subsistence resources) (Appendix F, Table F-1). During all 3 study years, households most 

commonly participated in harvests of non-salmon fish, large land mammals, and migratory birds 

(Appendix F, Table F-1). In terms of species, in 2014, the most recent comprehensive study year for 

Nuiqsut, the highest rates of harvest participation were for caribou (66 percent of households), whitefronted geese (60 percent), broad whitefish (60 percent), cloudberries (aqpik) (55 percent), and Arctic 

cisco (52 percent) (ADF&G 2017). Rates of household participation in caribou hunting were even higher 

in 2015 and 2016 (Stephen R. Braund and Associates 2017, 2018), at 84 and 76 percent of households 

attempting harvests of caribou, respectively (Appendix F, Table F-2). Participation in sharing of 
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subsistence resources is an important cultural value among Iñupiaq communities, including Nuiqsut. Over 

90 percent of households both gave and received subsistence resources during all available study years. In 

2014, marine mammals were the most commonly received resource (95 percent of households), followed 

by large land mammals (72 percent), and non-salmon fish (71 percent) (Appendix F, Table F-1). 

Subsistence Resource Importance

Understanding the relative importance of different subsistence resources to a community is important 

when considering the potential magnitude of project effects. While subsistence users consider all 

resources (including non-subsistence resources) to be of high importance to their communities, their 

region, and the environment as a whole, certain resources may provide a greater proportion of a 

community’s nutritional needs, or they may facilitate more opportunities for community participation in 

culturally important activities such as harvesting, processing, sharing, and consuming subsistence foods. 

The following analysis quantitatively ranks Nuiqsut subsistence resources in terms of their material and 

cultural importance, with the recognition that all subsistence resources are important to Nuiqsut residents’ 

health, identity, and well-being. The Alaska Department of Fish and Game Division of Subsistence, the 

North Slope Borough Department of Wildlife Management, and private consulting businesses (e.g., 

Stephen R. Braund and Associates) have collected household harvest data in Nuiqsut since the 1980s (see 

“Harvest Data,” above). These data allow for the quantitative measurement of certain aspects of the 

material and cultural importance of subsistence resources.

Material Importance 

In this analysis, material importance was measured in terms of a resource’s contribution toward Nuiqsut’s 

total subsistence harvest (i.e., edible pounds for each resource divided by the total edible pounds for all 

resources). This analysis used averages based on harvest data from Alaska Department of Fish and Game, 

North Slope Borough, and industry sponsored caribou monitoring studies (e.g., Stephen R. Braund and 

Associates 2012, 2013, 2014, 2015, 2016, 2017) for study years between 1985 and 2015. Table 57 shows 

the average percentage each resource contributed to total subsistence harvests (in terms of pounds of 

usable weight) harvested by residents of Nuiqsut for all available study years. The majority of community 

subsistence harvests come from a relatively small number of resources. Resources contributing less than 1 

percent to the total harvest are not included in Table 57 and are considered minor in terms of material 

importance. 

Resources of major material importance are those that have contributed an average of 9 percent or more 

to the total harvest in terms of pounds useable weight; resources of moderate material importance have 

contributed an average of between 2 percent and 9 percent; and resources of minor material importance 

have contributed less than 2 percent. While the minimum cutoff of 9 percent to qualify as “major” may 

seem low, it is important to note that a review of harvest amounts across communities in Alaska that 

participate in the mixed cash-subsistence economy shows that few individual resources actually 

contribute more than 9 percent. This is due in part to the high diversity of resources harvested by 

subsistence communities (i.e., a large number of individual species), and the limited number of resources 

that are available in a size or quantity large enough to provide a large portion of a community’s 

subsistence diet. As shown in Table 57, four resources are considered major in terms of material 

importance: caribou, bowhead whale, broad whitefish, and Arctic cisco. An additional three resources are 

considered moderate: moose, ringed seal, and bearded seal. Of the minor resources, seven contribute at 

least 1 percent (but less than 2 percent) to the total harvest: white-fronted geese (niglivik), least cisco, 

Arctic grayling, burbot, humpback whitefish, Arctic char, and chum salmon (iqalugruaq). All other 

species have contributed an average of less than 1 percent of the total harvest and are considered minor.
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Table 57. Average resource contribution over all available study years, Nuiqsut

Resource Level Resource Percent of Total Harvest

(Pounds of Useable Weight)

Major Resources 

(>9% of Total Harvest)

Caribou 30

Bowhead whale a 30

Broad whitefish 15

Arctic cisco 9

Moderate Resources 

(2% to 9% of Total Harvest)

Moose 3

Ringed seal 2

Bearded seal 2

Minor Resources 

(<2% of Total Harvest)

White-fronted geese 1

Least cisco 1

Arctic grayling 1

Burbot 1

Humpback whitefish 1

Arctic char 1

Chum salmon 1

Note: Table includes resources that contribute 1 percent or more toward the total harvest based on data presented in Appendix F, 

Table F-2. All other resources contributed an average of less than 1 percent and are categorized as minor, and thus, the table does 

not add to 100 percent. 

a

 Averages include unsuccessful bowhead whale harvest years.

Sources: Alaska Department of Fish and Game (2017), Fuller and George (1999), Brower and Hepa (1998), and Bacon et al. 

(2009).

Cultural Importance

Household harvest data used to quantitatively measure the cultural importance of subsistence resources 

include data related to participation (percent of households attempting harvests of each resource) and 

sharing (percent of households receiving each resource). This analysis used averages based on harvest

data from Alaska Department of Fish and Game, the North Slope Borough, and industry sponsored 

subsistence monitoring studies (e.g., Stephen R. Braund & Associates 2012, 2013, 2014, 2015, 2016, 

2017, 2018) for study years between 1985 and 2016. These measures were chosen as informing the 

cultural importance of subsistence resources because participation in subsistence activities promotes the 

transmission of skills from generation to generation, and sharing of subsistence resources between 

households strengthens cohesion in the community and region. Cultural importance of resources includes 

a multitude of other factors, including harvesting and processing activities, transfer of knowledge, 

satisfaction from eating traditional food, continuity of harvesting in traditional places, and harvesting 

resources unique to an area. While quantitative data have not been collected systematically for these 

measures, they are still important in assessing potential impacts in an environmental consequences 

analysis.

Table 58 shows the average percentage of households attempting harvests of each resource for all 

available study years, and Table 59 shows the average percentage of households receiving resources in 

each community for all available study years. The tables break subsistence resources into categories of 

major, moderate, and minor, based on their contributions toward participation and sharing. Resources 

considered to contribute highly to cultural importance were those with the majority (50 percent or more) 

of households either attempting harvests or receiving that resource. For Nuiqsut, these resources are 

caribou, broad whitefish, white-fronted geese, Arctic cisco, cloudberries, burbot, Arctic grayling, 

bowhead whale, and bearded seal. Resources of moderate (11 percent to 49 percent of households) and 

minor (10 percent or less of households) cultural importance are also shown in Table 58 and Table 59. 

These tables do not include resources with less than 5 percent of households attempting harvests or 

receiving. 
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Combined Material and Cultural Importance

The material and cultural importance of resources for Nuiqsut are combined and summarized in Table 60. 

In all cases, resources are categorized based on their highest ranking under either material or cultural 

importance. For example, to be categorized as a resource of major importance, the resource must be 

ranked as “major” under either material or cultural importance (Table 57, Table 58, and Table 59). 

Resources of major importance to Nuiqsut residents include multiple species of fish (Arctic cisco, Arctic 

grayling, broad whitefish, and burbot), white-fronted geese, caribou, bowhead whale, bearded seal, and 

cloudberries.

Table 58. Average percentage of Nuiqsut households attempting harvests, all available study years

Resource Level Resource Percent of Households

Major Resources (≥50%)

Caribou 73

Broad whitefish 69

White-fronted geese 62

Arctic cisco 61

Cloudberries 55

Burbot 51

Arctic grayling 50

Moderate Resources (11% to 49%)

Ptarmigan 48

Canada geese 42

Moose 40

Least cisco 40

Arctic char 38

Ringed seal 36

Bearded seal 32

Bowhead whale 30

Blueberries 29

Pink salmon 28

Humpback whitefish 26

King eider 24

Chum salmon 23

Red fox 22

Wolverine 22

Ground squirrel 20

Snow geese 19

Wolf 18

Brant 17

Brown bear 14

Arctic fox 14

Rainbow smelt 13

Spotted seal 13

Geese eggs 11

Dolly Varden 10
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Resource Level Resource Percent of Households

Minor Resources (≤10%)

Cranberries 9

Long-tailed duck 8

Walrus 7

Common eider 7

Northern pike 7

Saffron cod 7

Crowberries 7

Polar bear 7

Arctic cod 7

Round whitefish 5

Sourdock 5

Northern pintail 5

Weasel 5

Sources: Alaska Department of Fish and Game (2017); Fuller and George (1999); Brower and Hepa (1998); Bacon et al. (2009); 

Braem et al. (2011); Stephen R. Braund and Associates (2012–2018). 

Note: Table includes resources with at least 5 percent of households attempting harvests, based on data presented in Appendix F, 

Table F-2. All other resources had less than 5 percent attempting harvests and are categorized as minor.

Table 59. Average percentage of Nuiqsut households receiving resource, all available study years

Resource Level Resource Percent of Households

Major Resources (≥50%) Bowhead whale 96

Caribou 76

Arctic cisco 57

Bearded seal 50

Moderate Resources (11% to 49%) Broad whitefish 49

Walrus 43

Ringed seal 43

Moose 41

White-fronted geese 36

Burbot 35

Cloudberry 29

Polar bear 29

Beluga 24

Canada geese 24

Arctic grayling 24

Arctic char 22

Rainbow smelt 22

King eider 19

Brown bear 18

Least cisco 17

Pink salmon 17
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Resource Level Resource Percent of Households

Moderate Resources (11% to 49%) Blueberries 16

Ptarmigan 15

Long-tailed duck 13

Geese eggs 12

Bird eggs 12

Chum salmon 11

Minor Resources (≤10%)

Brant 9

Chinook salmon 9

Humpback whitefish 9

Dall sheep 9

Muskox 8

Lake trout 8

Snow geese 7

Northern pike 7

Sourdock 7

Arctic cod 7

Sockeye salmon 6

Wolf 6

Sheefish 6

Cranberries 5

Minor Resources (≤10%) 

(continued)

Spotted seal 5

Coho salmon 5

Unknown seal 5

Wolverine 5

Sources: Alaska Department of Fish and Game (2017); Fuller and George (1999); Brower and Hepa (1998); Bacon et al. (2009); 

Braem et al. (2011); Stephen R. Braund and Associates (2012–2018).

Note: Table includes resources with at least 5 percent of households receiving the resource, based on data presented in Appendix 

F, Table F-2. All other resources had less than 5 percent receiving and are categorized as minor.
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Table 60. Combined material and cultural importance

Major Resources Moderate Resources Minor Resources

Caribou

Bowhead whale

Bearded seal

Arctic cisco

Arctic grayling

Broad whitefish

Burbot

White-fronted geese

Cloudberries

Brown bear

Moose

Arctic fox

Ground squirrel

Red fox

Wolf

Wolverine

Beluga

Polar bear

Ringed seal

Spotted seal

Walrus

Arctic char

Burbot

Chum salmon

Humpback whitefish

Least cisco

Pink salmon

Rainbow smelt

Brant

Canada geese

King eider

Long-tailed duck

Snow geese

Geese eggs

Ptarmigan

Blueberries

Dall sheep

Muskox

Beaver

Marmot

Weasel

Arctic cod

Bering cisco

Chinook salmon

Coho salmon

Dolly Varden

Flounder

Halibut

Lake trout

Northern pike

Rockfish

Round whitefish

Saffron cod

Sculpin

Sheefish

Sockeye salmon

Common eider

Loons

Mallard

Northern pintail

Sandhill crane

Spectacled eider

Teal

Tundra swan

Brant eggs

Eider eggs

Gull eggs

Seabird & loon eggs

Snowy owl

Cranberries

Crowberries

Hudson Bay tea

Other wild greens

Sourdock

Sources: See Tables 51, 52, and 53.
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3.4.6.4 Subsistence Uses in the Project Study Area

This section describes Nuiqsut’s subsistence uses that have been documented within and near the project 

study area. Data from these harvest and subsistence mapping studies have been provided and/or discussed 

in the previous sections, and selected indicators, based on data availability, are included in the following 

section as relevant to describing subsistence uses in the project study area.

The project study area for the construction period was established using a 2.5-mile buffer around all 

project infrastructure and activity (see Map 3.3-1). The project study area for the construction phase 

includes all project components, including seasonal infrastructure needed to support construction, i.e., ice 

roads. A separate project study area was created for the drilling and operations phase, and was established 

using a 2.5-mile buffer around all permanent and temporary infrastructure and activity that would occur in 

the drilling and operation phase (see Map 4.4-1). 

Subsistence Use Areas

The project study area overlaps with Nuiqsut subsistence use areas. Table 61 indicates which types of 

subsistence use areas are overlapped by the two project study areas, by resource. According to these data, 

residents of Nuiqsut use the project study area to hunt for or harvest nearly all types of subsistence 

resources including large land mammals, furbearers and small land mammals, fish, birds, and vegetation. 

Marine mammals use areas also intersect the project study area; however, these use areas begin in the 

Colville River and extend to offshore areas. See Appendix F, Figures F-2 through F-9 for maps depicting 

resource category use areas vis-à-vis the project study area. The reader should keep in mind that the 

information presented in this “Subsistence Use Areas” section is specific to activities that occur within the 

project study area (Figure 14, Figure 15). Thus, any activities that occur outside of the specific project 

study area polygons are not included in the discussion.

Table 61. Use areas overlapping project study area by resource category a

Resource Categories Nuiqsut Use Areas Overlapping Project Study Area

Moose yes

Caribou yes

Other Large Land Mammals yes

Furbearers & Small Land Mammals yes

Marine Mammals b yes

Fish yes

Birds yes

Vegetation yes

Notes: Not all studies addressed each of the resource categories listed in this table.

a This table applies to both the construction project study area and the drilling and operation project study area.

b Marine mammal subsistence use areas begin in Colville River and extend to offshore areas.

Sources: Brown (1979), Pedersen (1979), Pedersen (1986), BLM (2004), Stephen R. Braund and Associates (2010a), Brown et al. 

(2016), Stephen R. Braund and Associates (2018). 

To characterize the subsistence uses of areas with new infrastructure, the study team removed boat use 

areas from the analysis of subsistence uses within the project study area because there are no new 

infrastructure associated with GMT2 occurring in use areas accessed by boat. The project study area is a 

2.5-mile buffer of the three action alternative footprints, including infrastructure that is east of the CD5 

development and in areas of existing infrastructure between CD1 and CD2. Except for a new pipeline 

between CD1 and CD4 that is parallel to an existing pipeline, the only areas of new infrastructure 

proposed for GMT2 occur southwest of CD5, in an area that is not directly accessible by boat. The project 
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study area includes a portion of the Colville River that is commonly accessed by boat and used for 

subsistence, but will not be overlapped by new permanent infrastructure associated with GMT2. While 

boating activities may be affected indirectly through changes in resource availability (see the discussion 

of “Resource Availability” below), or directly through an increase in levels of existing development 

activities (e.g., increased road traffic associated with GMT2 along the existing bridge over Nigliq 

Channel), a majority of new direct impacts (occurring at the same time and place) on subsistence use 

areas will be limited to inland areas that are not accessed during boating activities. Therefore, in order to 

focus on current subsistence uses within areas of new infrastructure associated with the proposed project 

and to most accurately represent the directly affected use areas by excluding boat based subsistence 

activities, the analysis of uses within the project study area for months of use and method of 

transportation excludes subsistence use areas that are accessed by boat. Instead, these sections provide 

data on subsistence use areas within the project study area that have been traditionally accessed by other 

modes of transportation such as snowmachines and four-wheelers. The purpose of this analysis is to 

provide information about uses that will be affected in areas of new infrastructure and to provide a greater 

level of detail regarding uses in the subsistence project area; it is important to note that indirect impacts 

could also occur outside the project study area. 

During their subsistence mapping project, Stephen R. Braund and Associates (2010a) documented a total 

of 758 Nuiqsut use areas that characterized the 1995–2006 subsistence use areas of 33 active and 

knowledgeable Nuiqsut subsistence harvesters. In total, 321 of the 758 individual use areas 

(approximately 42 percent) documented for the 1995–2006 time period (Stephen R. Braund and 

Associates 2010a) overlapped with the project study area (Table 62, Table 63). Excluding use areas 

accessed by boat, a total of 206 overland use areas (27 percent) overlapped with the project study area. 

Each use area represents the area in which an individual Nuiqsut respondent searched for a particular 

resource; areas vary in size depending on the resource being targeted and can range from a small net site 

for Arctic cisco to large overland areas covering many square miles in search of resources such as caribou 

or wolf and wolverine. Data from the Nuiqsut Caribou Subsistence Monitoring Project (Stephen R. 

Braund and Associates 2010b, 2011, 2012, 2013, 2014, 2015, 2016, 2017, 2018) recorded 1,692 caribou 

use areas over the 9 study years. Of these 1,692 use areas, 1,492 (88 percent) are overlapped by the 

project study area; 434 caribou use areas (26 percent) overlapped overland use areas (i.e., non-boat use 

areas) within the project study area. Similar results for the drilling and operation project area are 

presented in Table 63, with a smaller percentage of use areas reported in that area (37 percent of all 

caribou use areas and 14 percent of overland use areas).

Table 62. Sources of Project-Specific Subsistence Use Area Information, Project Area for Construction

Source

Resource 

Type Time Period

Total Number 

of Use Areas

Total Number 

(%) of Use 

Areas in 

Project Study 

Area

Total Number 

(%) of 

Overland Use 

Areas in 

Project Study 

Area

Stephen R. Braund and 

Associates (2010a) 

All 

Resources

1995–2006 758 321 (42%) 206 (27%)

Stephen R. Braund and 

Associates (2010b, 2011, 

2012, 2013, 2014, 2015, 

2016, 2017, 2018) 

Caribou 2008–2016 1,692 1,492 (88%) 434 (26%)
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Table 63. Sources of Project-Specific Subsistence Use Area Information, Project Area for Drilling & 

Operations

Source

Resource 

Type Time Period

Total Number 

of Use Areas

Total Number 

(%) of Use 

Areas in 

Project Area 

for Drilling & 

Operations

Total Number 

(%) of 

Overland Use 

Areas in 

Project Area 

for Drilling & 

Operations

Stephen R. Braund and 

Associates (2010a)

All 

Resources

1995–2006 758 231 (30%) 171 (23%)

Stephen R. Braund and 

Associates (2010b, 2011, 

2012, 2013, 2014, 2015, 

2016, 2017, 2018) 

Caribou 2008–2016 1,692 630 (37%) 230 (14%)

Table 64 and Table 65 shows the percentage of Nuiqsut respondents reporting overland use areas within 

the project study area for the 1995–2006 time period (Stephen R. Braund and Associates 2010a). Overall, 

100 percent of Nuiqsut active harvesters interviewed for the 1995–2006 time period reported overland use 

areas crossed by the project study area. Of these respondents, 100 percent of wolf and wolverine hunters 

reported hunting in the project study area, the highest of any single resource, followed closely by 91

percent of caribou harvesters hunting in the project study area. Burbot, geese, and Arctic cisco use areas 

within the project study area were reported by between 73 and 77 percent of respondents. Both Arctic 

cisco and burbot use areas in the project study area are accessed by snowmachine along the Colville River 

or overland via the frozen tundra. Broad whitefish and eider harvesters accounted for the remaining 

overland uses within the project study area at 8 percent and 7 percent, respectively.

Table 64. Percent of Nuiqsut Harvesters Using Project Area for Construction, Overland Use Areas Only

Resource Category Percent of Nuiqsut Resource 

Respondents in Project Study Area

Number of Last 10 Year 

Respondents for Resource

Wolverine 100 24

Wolf 100 23

Caribou 91 32

Burbot 77 30

Geese 76 33

Arctic cisco 73 33

Broad whitefish 8 26

Eiders 7 28

Percent of Total Harvesters 

Using Project Study Area

100 33

Total Number

Interviewed in Study 33 --

Source: Stephen R. Braund and Associates (2010a).
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Table 65. Percent of Nuiqsut Harvesters Using Project Area for Drilling & Operations, Overland Use Areas 

Only

Resource Category

Percent of Nuiqsut Resource Respondents 

in Project Area for Drilling & Operations

Number of Last 10 Year 

Respondents for Resource

Wolverine 88 24

Wolf 87 23

Caribou 84 32

Burbot 7 30

Geese 67 33

Arctic cisco 70 33

Broad whitefish 4 26

Eiders 0 28

Percent of Total Harvesters 

Using Project Study Area

100 33

Total Number 

Interviewed in Study 33 --

Source: Stephen R. Braund and Associates (2010a).

Figure 19 through Figure 27 provide additional characterization of Nuiqsut residents’ use of the project 

study area in terms of high to low overlapping use areas. This information is based on Stephen R. Braund 

and Associates (2010a) for the 1995–2006 time period and Stephen R. Braund and Associates (2018) for 

the 2008–2016 time period for caribou only. For all resource use areas combined (Figure 19), residents 

reported the highest overlapping use areas along Colville River channels (including Nigliq Channel) and 

in overland areas west of the community; areas of moderate overlapping use occurred east of the Nigliq 

Channel. 

Overlapping caribou subsistence use areas for the 1995–2006 and 2008–2016 time periods are shown on

Figure 20 and Figure 21. Similar to their all resources use for the 1995–2006 time period, Nuiqsut 

residents reported the highest overlapping use areas for caribou along the Colville River channels and 

west of the community with moderate use east of Nigliq Channel. More recent caribou use areas from 

2008 through 2016 show a changing pattern of use within the project study area with the areas of highest 

overlapping use still concentrated along the Colville River channels and directly west of the community, 

but more moderate use to the northwest and low overlapping use areas east of the Nigliq channel. Other 

land mammals hunted for in the project study area, for which there are overlapping subsistence use area 

data, include wolf and wolverine (Figure 22). These use areas show the highest overlapping use to the 

west and south of the community. These furbearers are less commonly found in areas closer to the coast, 

which show low to moderate overlapping use areas. Overland hunting patterns for land mammals in the 

project study area were discussed by Nuiqsut residents during the Stephen R. Braund and Associates 

(2010a) and caribou monitoring studies: 

[Caribou hunting] a little past Fish Creek and follow the lakes [to the south to the edge of the 

hills]. I did cross the Colville once or twice but I usually stay on the west side because there is a 

lot of willows and deep snow. The last time I crossed the river was around five years ago. Up the 

Nigliq Channel about two to three miles. December to April or May. That is about when we start 

getting low in December. We try to get as much in the fall as we can because they are fat and 

healthy. (Stephen R. Braund and Associates Nuiqsut Interview November 2006)

Not until February [did I go hunting]; I already got what I needed in the fall. I just went in this 

back yard area. Just up to Judy Creek, Tinmiaqsiugvik, I believe that’s it. I came up to somewhere 

around here and I followed this creek. No, I didn’t quite go out that way [to Fish Creek]. I 

followed this creek, went straight to Ocean Point and back home. That’s pretty much the same 

route I take every time, and you’ll see something out there. I went out, I think it was in March or 

April ....I just got a couple of caribou after whaling, so it’s still in September because it was a 

quick season [for whaling], it was after everyone came home. I gave all my caribou out, so I’ve 
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got to go out and get some more. Right in the back yard. I went everywhere in this [same area]. I 

went on maybe eight or nine Honda trips. The first one is where I caught that one, and the next 

three or four [trips], just nothing out there. These were July and August – late July and August, 

and September. (Stephen R. Braund and Associates Nuiqsut Interview November 2015)

Within the last ten years, [I hunted wolf and wolverine] within this area. I know we lost a couple 

of them [wolverine] here, on the Fish Creek area. I got some there, by the cabins and by the ocean 

there. November until the end of March. We are looking for them now, when we look for caribou. 

When we see something black, we ignore the caribou and go for it. They move constantly. The 

wolves are the same. They do travel. (Stephen R. Braund and Associates Nuiqsut Interview 

November 2005).

Although still in draft form, the Year 9 report for the Nuiqsut Subsistence Caribou Monitoring Project 

documents use of the Spur Road, CD5 Road, and connected ice roads for caribou hunting, and Year 10 

data (forthcoming) show use of the newly constructed GMT1 road. The use of roads for hunting is 

relatively new among Nuiqsut hunters, although some have reported limited use of ice roads in the past. 

Methods for use of roads vary by hunter. Some individuals reported using the roads to spot caribou, while 

others use the roads as an access point for overland areas accessed by four-wheeler or snowmachine. 

Some indicate that they use the roads out of necessity because the caribou have been diverted away from 

areas closer to the community, either as a result of the roads themselves acting as barriers or due to the 

presence of hunters along the roads. Finally, a number of hunters have reported minimal or no use of 

roads for hunting, with some avoiding the roads altogether. Several respondents described use of roads for 

hunting as follows: 

[My four-wheeler use area is] from Fish Creek all the way down and stop about right here and 

then come back. Because with that Spur Road it’s way easy, you can go back this way too. And 

normally, I go out with a group of guys. This one is just four-wheeler. [I went out in that area] 

maybe 18 times. November-December would be snowmachines and car, because normally there is 

a GMT project where we build the ice roads all the way from Mooses Tooth to here. (Stephen R. 

Braund and Associates Nuiqsut Interview November 2016).

We do a lot on the Spur Road, and with a truck. During the winter when there’s an ice road, I go on the ice 

road. We have to sign a waiver.... I went on the ice road a lot, with snowmachine and four-wheelers. I 

always go fast, so I’m not too sure [how far]. At least 15 miles from Nuiqsut. When I went out, I do a hook 

and come back [overland toward Nuiqsut]. Like I leave on the ice road then come back right behind the 

dumps....Lots [of caribou], I was getting them [on the Ice Road]. (Stephen R. Braund and Associates 

Nuiqsut Interview November 2016).
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Figure 19. All resources subsistence use areas in the project study area, 1995–2006
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Figure 20. Caribou subsistence use areas in the project study area, 1995–2006
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Figure 21. Caribou subsistence use areas in the project study area, 2008–2016
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Figure 22. Wolf and wolverine subsistence use areas in the project study area, 1995–2006
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Figure 23. Geese subsistence use areas in the project study area, 1995–2006
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Figure 24. Eider subsistence use areas in the project study area, 1995–2006
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Figure 25. Burbot subsistence use areas in the project study area, 1995–2006
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Figure 26. Arctic cisco subsistence use areas in the project study area, 1995–2006
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Figure 27. Broad whitefish subsistence use areas in the project study area, 1995–2006
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Migratory bird use areas are shown on Figure 23 and Figure 24 for geese and eiders in the project study 

area. Areas of highest overlapping use for geese occur along the waterways of Fish Creek, Colville River, 

and Kuupaqullurak, as these are the areas where the geese concentrate during spring breakup. Moderate 

use occurs in overland areas between these three locations. Within the project study area, no geese use 

areas were documented for the 1995–2006 time period west of GMT1 (except some limited use extending 

east from the Fish Creek area), and few geese use areas were documented east of the Nigliq Channel. 

Unlike geese, eiders are typically harvested offshore, although as shown in Figure 24, Nuiqsut residents 

identified a few areas of low overlapping use that intersect with the project study area, including along the 

Nigliq Channel and near CD5 and Fish Creek. During the Stephen R. Braund and Associates (2010a) 

study, Nuiqsut residents described their use of the project study area for geese hunting and more limited 

eider hunting as follows: 

Mostly [geese hunting] in the Fish Creek area. They are all over; you find a good spot by watching 

the geese and their pattern. You see them going in one area and you go find a good spot. All in 

that area and up the Colville. We don’t go very far up north. And then we go towards Fish Creek. 

As far as that second fishing hole. I don’t really go anywhere else. (Stephen R. Braund and 

Associates Nuiqsut Interview November 2006) 

One of my favorite spots is at Fish Creek but I didn’t go this last year. It is past this creek. It is a 

big area. May, snowmachine. We get the Canadian, greater Canadian and the black ones with the 

ring around their necks, black brants and the white-fronted and the snow geese. That is a hot spot. 

(Stephen R. Braund and Associates Nuiqsut Interview November 2006)

I did before with my father, here in this area [between Fish Creek and Nigliq Channel], we were 

actually on land when we were looking for them [eiders], we didn’t catch any but we were there, 

that was early June. Snowmachine. Could have been May. Last catch right off the island. Mostly 

in the channel too also. Couple of trips maybe. (Stephen R. Braund and Associates Nuiqsut 

Interview November 2006)

Fish use areas for burbot, Arctic cisco, and broad whitefish have been documented within the project 

study area (Figure 25 through Figure 27). Burbot use areas are primarily concentrated along the Colville 

River southeast of the community with a few areas of moderate use located north of Nuiqsut along the 

Nigliq Channel; these areas are primarily accessed during the winter months when burbot are in prime 

harvesting condition. Unlike burbot, Arctic cisco use areas are primarily concentrated in the Nigliq 

Channel, with fewer use areas along the main Colville River, and are also primarily accessed during the 

early winter months when cisco migrate into the river. Lastly, broad whitefish are also primarily harvested 

in the Nigliq Channel, but during the summer months. Describing their use of the Nigliq Channel for 

Arctic cisco fishing and the main Colville for burbot fishing residents said: 

This stretch of Nigliq Channel is where most of Nuiqsut sets their subsistence fish nets. [His] 

uncle has a tent camp on Nanuq Lake, by Alpine CD-2. Stayed at camp that long to watch the nets 

and save gas. He monitors the nets to make sure they are catching the right fish-too close to the 

mouth and they got too many sculpins. (Stephen R. Braund and Associates Nuiqsut Interview 

November 2004)

I caught a couple of burbot in my net. I keep them in the fall time we get them. Usually the best 

time to get those is in later part of this month and January, February, March, and April. That is 

when their liver becomes almost half their body weight, it is just rich, we don’t even need seal oil, 

the way we have our fish is frozen and dipped in seal oil and with the tittaaliq you don’t even need 

seal oil, but if you have too much of that liver you will get sick, and if it is just right you will catch 

a little buzz and get tired and nice. Right here at this point [north of Itkillik] right on that east 

bank, 1⁄4 mile of that is good fishing for tittaaliq. (Stephen R. Braund and Associates Nuiqsut 

Interview November 2006)
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Seasonal Round

Several sources provide specific data on the seasonal round and methods of transportation (see following 

section) of Nuiqsut subsistence activities in the project study area. Stephen R. Braund and Associates 

(2010) provided data on all resources subsistence use areas by month and methods of transportation 

(Stephen R. Braund and Associates 2010a); in addition, the ongoing Nuiqsut Caribou Subsistence 

Monitoring Project (Stephen R. Braund and Associates 2010b, 2011, 2012, 2013, 2014, 2015, 2016, 2017, 

2018) provides similar data specific to caribou uses by month and method of transportation. 

Figure 28 shows the percentage of overland use areas in the project study area, by month, as documented 

in Stephen R. Braund and Associates (2010a) for Nuiqsut. According to these data, overland uses of the 

project study area by Nuiqsut residents occur year-round, with the greatest peak of overland activity 

occurring in the winter from October through May with lower levels of activity in June, July, August, and 

September. Nuiqsut harvesters have provided traditional knowledge for why the project study area is most 

utilized in these months; reasons include the availability of resources, condition of animals, and traveling 

conditions: 

I go straight across here. I got one out here before, too. And one at Fish Creek, this whole area. 

One time [I went] all the way down to Judy Creek. Sometimes I go there. December until maybe 

the first week of April. It depends on the furs. When the sun comes out too early, it makes the skin 

dull. (Stephen R. Braund and Associates Nuiqsut Interview November 2005)

When we get Arctic cisco, that is the best fish we like, we mostly like to eat qaaktaq because it is 

more tasty, more meat. Nearby Alpine, sometime [in] October or November all the way to 

December, depends on how the river ice is getting thicker and thicker and when ice gets thicker 

we stop fishing, and some people keep fishing, and when ice gets 4-5 feet thick they even keep on 

fishing. Snowmachine I mostly take, and some people take their truck along. (Stephen R. Braund 

and Associates Nuiqsut Interview November 2006)

I do a lot of that [geese hunting] during May. Just right out where they first come we use to go to 

Ocean Point. Right around this area. When the snow is melting we move farther upstream about to 

where our cabin is. And when the snow is really melting again we go towards Fish Creek about 

middle of May. About right around this area. White front geese, Canadian or snow geese. No 

brant. Snowmachine. (Stephen R. Braund and Associates Nuiqsut Interview November 2006)

You don’t have to go that far with a snowmachine [to catch caribou], right around the west side, 

right around by Fish Creek. About this whole area is what we usually use during winter time. 

Sometimes we [go] past Ocean Point. Somewhere in March and April. Yeah [we also hunt] in 

October and November but the only time we catch in October is cows, [because of rutting bulls]. 

(Stephen R. Braund and Associates Nuiqsut Interview November 2006)
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Figure 28. Overland all resources subsistence use areas by month in project study area, 1995–2006

Figure 29 and Figure 30 provides a specific depiction of the timing of caribou subsistence activities 

within the project study area from Stephen R. Braund and Associates (2010a) and the Nuiqsut Caribou 

Subsistence Monitoring Project. According to these data, Nuiqsut harvesters (similar to their all resources 

use areas) access the project study area for caribou hunting primarily during the winter months. Months of 

caribou hunting activities collected during the Nuiqsut Caribou Subsistence Monitoring Project (Figure 

30) display a shift in the timing of caribou hunting activities in the project study area with a smaller

percent of caribou use areas in the project study area accessed during the winter months and a slightly 

higher percentage (30 percent) accessed in September. August overland caribou hunting activity in the 

project study area also increased during the study years for the caribou monitoring project (Figure 30) 

compared to the Stephen R. Braund and Associates (2010a) study years (Figure 29). Possible explanations 

for this shift include documentation of the use of four-wheelers by younger Nuiqsut hunters, an activity 

that occurs primarily during August and September. Another possible explanation could be more caribou 

being available in the project study area during August and September. In either case, the available data 

do not provide a definitive answer as to the reason for the shift. During Year 9 of the monitoring project, 

an increase in winter use of the project study area was evident, likely as a result of year-round access to 

roads (including ice roads) west of the community. 
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Figure 29. Overland caribou subsistence use areas by month in project study area, 1995–2006

Figure 30. Overland caribou subsistence use areas by month in project study area, 2008–2016

As shown in Table 66, use of the project study area occurs for various resources at differing times of the 

year. As defined by total number of use areas, geese hunting, Arctic cisco and burbot fishing, caribou 

hunting, and wolf and wolverine hunting are the primary activities that occur in the project study area. As 

discussed above, overland caribou hunting occurs year-round in the project study area with the greatest 

number of use areas accessed during late fall and throughout the winter (September to April), when travel 

by snowmachine and four-wheeler is most common. Wolf and wolverine hunting also peaks during the 

winter particularly from January through March. Geese hunting within the project study area primarily 

occurs during May. Fishing primarily occurs for Arctic cisco and burbot, with the peak of Arctic cisco 

harvesting occurring in October and November in the Colville River and burbot fishing occurring 

throughout the winter, particularly from November through March. Other documented hunting activities 
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are more limited within the project study area and include eider hunting (two use areas) and broad 

whitefish fishing (two use areas).

Table 66. Nuiqsut months of use in project study area1, overland use areas only

Resource 

Category Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Total Use Areas

Geese -- -- -- Med High Low -- -- -- -- -- -- 42

Arctic cisco -- -- -- -- -- -- -- -- Low High High Med 35

Burbot High High High Med Low -- -- -- Low Med High High 34

Caribou High High High Med Low -- -- Low Low High High High 33

Wolverine High High High Med -- -- -- -- -- Low Low Med 30

Wolf High High High Med -- -- -- -- -- Low Low Med 28

Eiders -- -- -- -- High High -- -- -- -- -- -- 2

Broad whitefish -- -- -- -- High High High High High High High -- 2

Note: Does not include use areas accessed by boat in order to capture the timing of overland travel in the project area.

(-) = No use; Low = 1-24% of Use Areas; Med = 25-49% of Use Areas; High = 50-100% of Use Areas

Source: Stephen R. Braund and Associates (2010a).

Method of Transportation

Residents of Nuiqsut access the project study area using various modes of travel. Figure 31 shows the

percentage of all resources use areas overlapping the project study area by reported method of 

transportation based on Stephen R. Braund and Associates (2010a). As shown in this figure, 

snowmachines are the most common mode of travel to the project study area. Less than 8 percent of use 

areas in the project study area were accessed by truck, four-wheelers, planes, or foot. As mentioned 

above, this analysis excludes use areas accessed by boat, because the area where new infrastructure is 

proposed is primarily accessed using overland methods of travel such as snowmachine and four-wheeler. 

When viewing use area data specific to caribou for the same 1995–2006 study period, Nuiqsut residents 

reported using similar methods of transportation in the project study area, with snowmachine the primary 

mode of transportation and limited use of all other travel methods (Figure 32). During the Nuiqsut 

Subsistence Caribou Monitoring Project for the 2008 through 2016 study years, Nuiqsut residents 

reported nearly equal percentages of overland caribou use areas accessed using either snowmachine (50 

percent) or four-wheeler (53 percent); of note, the caribou monitoring study reported a much higher 

percent of use areas in the project study area accessed using four-wheeler compared to the 1995–2006 

study period (Figure 32). This is consistent with the higher percentage of caribou use areas accessed in 

August and September than in previous studies (Figure 30); overland travel during these months is 

generally limited to four-wheeler. Truck use also increased to 14 percent of use areas during the Nuiqsut 

Subsistence Caribou Monitoring Project (compared to zero truck use during the 1995-2006 time period), 

likely due to the construction of the Spur and CD5 roads. 
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Figure 31. All resources subsistence use areas by method of transportation in project study area

Figure 32. Caribou subsistence use areas by method of transportation in project study area
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Figure 33. Travel method by month in project study area, caribou only

Figure 34 shows travel routes that have been documented for Nuiqsut based on Stephen R. Braund and 

Associates (2010a) interviews. Multiple travel routes within the project study area have been reported by 

residents of Nuiqsut. The majority of these travel routes head northwest of the community towards the 

coast and Utqiagvik (formerly Barrow). The Nigliq Channel of the Colville River is also a heavily utilized 

travel corridor to access use areas in the Colville Delta, Beaufort Sea, and Fish and Judy creeks.

Harvest Data

As noted above, a key indicator of resource availability is per capita harvests within a community. 

Increases or decreases in these numbers may indicate an increase or decrease in the availability of 

subsistence resources to local harvesters. This discussion focuses on providing baseline indicator data for 

eight subsistence resources harvested within the entire project study area including the Colville River area 

based on information collected by Stephen R. Braund and Associates (2010a) for 14 resources. Of those 

14 resources, the resources harvested within the project study area are as follows: caribou, geese, eiders, 

Arctic cisco, burbot, broad whitefish, wolf, and wolverine. 

Figure 35shows the average pounds per capita for six of the resources (caribou, eiders, geese, Arctic 

cisco, broad whitefish, and burbot). These data represent total harvests from all subsistence areas based on 

data presented in Appendix F; per capita data are not available specifically to the project study area. 

Because pounds per capita are generally not applied to furbearers and small land mammals, wolf and 

wolverine were excluded from the figure. Despite the limitations, these data are still useful for describing 

the relative importance of these key subsistence resources for Nuiqsut in terms of edible pounds. 
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Figure 34. Nuiqsut travel routes
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According to Figure 35, the average per capita harvest of caribou was 157 pounds, the highest of the six 

resources harvested in the project study area. Harvests of broad whitefish and Arctic cisco were similar 

with an average of 90 and 80 per capita pounds for each resource respectively. The Colville River is a 

particularly productive spawning and overwintering area for both broad whitefish and Arctic cisco. 

During years when the Arctic cisco run is strong, this resource may provide a substantial portion of the 

yearly harvest for Nuiqsut. Burbot, geese, and eiders contributed a lower amount at between 2 and 10 

pounds per capita.

Figure 35. Per capita pounds harvested for key resources, all study years

Sources: See Appendix F, Table F-2 for individual data and references. 

Data from the Nuiqsut Caribou Subsistence Monitoring Project provide project study-area-specific 

harvest data that show the percent of the caribou harvest that came from the project study area by study 

year (Table 67 ). These data only represent the harvests reported by the interviewed respondents and are 

not based on the total community harvest. For the 9 study years (2008–2016), 20 to 41 percent of 

respondents’ caribou harvest came from harvest sites located within the project study area. In general, the 

9 years of data show an upward trend of the caribou harvests coming from locations within the project 

study area. One possible reason for this increase includes increased use of four-wheelers in recent years 

(see above under “Method of Transportation”), including use along the recently constructed Spur Road. 

Another reason for this increase could be due to the effect of increased development activity in the 

Colville Delta and a shift of residents hunting patterns to areas west of the community where the proposed 

project is located. Although there are yearly exceptions, over the 9 study years (2008–2016), the Nuiqsut 

Caribou Subsistence Monitoring Project has documented a general increase in the percentage of harvests 

occurring in the area west of Nuiqsut, and a general decrease in the percentage of harvests occurring 

along Nigliq Channel (Stephen R. Braund and Associates 2018). ). From 2013 through 2016, when asked 

about places of avoidance, between 51 and 61 percent of harvesters responded that there were places they 

no longer used or avoided. In just over one-quarter of cases, those harvesters specifically identified the 

Alpine/Alpine Satellites areas; caribou harvesters also identified more general geographic locations in the 

vicinity of Alpine/Alpine Satellites, including Nigliq Channel, Colville Delta, and Tamayayak Channel, 

citing development-related reasons. For all responses related to avoidance, development-related causes 

were cited as the cause in nearly two-thirds of observations (Stephen R. Braund and Associates 2018, 

Table 47 and Table 48). A preliminary review of the data collected in Year 10 of the monitoring study 

shows an increase in reported avoidance, with nearly three quarters of active harvesters indicating that 
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there are places that they no longer use or avoid. However development causes were cited in a somewhat 

smaller percentage (approximately half) of observations.

Table 67. Percent of caribou harvested in the project study area

Caribou 

Study Year

Percent of Harvest 

in Total

2008 20

2009 26

2010 32

2011 41

2012 37

2013 31

2014 28

2015 35

2016 37

Source: Stephen R. Braund and Associates (2010b, 2011, 2012, 2013, 2015, 2015, 2016, 2017, 2018). 

Other indicators of resource availability include the percent of households attempting to harvest a 

particular resource and the percent of households that are successful. In general, the percentage of 

Nuiqsut households that successfully harvested a resource is comparable to the percentage of households 

attempting to harvest resources including caribou, broad whitefish, Arctic cisco, burbot, and geese (Figure 

36). Stephen R. Braund and Associates (2018) reports that data from the 9-year (2008–2016) monitoring 

study indicate fluctuations in those who believed they had not harvested enough caribou during the 

previous 12 months, with approximately 40 to 50 percent not harvesting enough in Years 1, 2, 5, 6, and 9, 

and between 16 and 32 percent not harvesting enough in Years 3, 4, 7, and 8. Reasons for not harvesting 

enough range from personal commitments, climate conditions, equipment failures, and developmentrelated causes. Certain resources such as burbot and geese, although not yielding a high number of per 

capita pounds (9 and 10 pounds per capita, Figure 35, have a high percent of households (51 and 77 

percent, respectively) that participate in those activities (Figure 36). Wolf and wolverine show a greater 

disparity between the percentage of households attempting harvests and the percentage of households 

reporting successful harvests, indicating that overall success rates for these resources is lower than for 

other key resources harvested in the project study area (Figure 36). However, the two indicators presented 

in Figure 36 do not provide information on whether the households harvested enough to meet their needs 

and/or how much effort (e.g., number of trips, duration of trip, costs) was expended in order to harvest the 

target resource. The table shows that, in general, Nuiqsut households that attempt to harvest key resources 

are successful in doing so. 
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Figure 36. Harvesting and attempting to harvest for key resources, all study years

Sources: See Appendix F, Table F-2 for individual data and references. 

Community Participation

As noted above, key indicators of community participation include percent of households using, 

attempting to harvest, and sharing subsistence resources. This discussion focuses on providing community 

participation baseline indicator data for the eight resources harvested within the project study area: 

caribou, geese, eiders, Arctic cisco, burbot, broad whitefish, wolf, and wolverine. Figure 37 shows the 

average percentage of households reporting using and receiving resources. Similar to per capita pound 

data, the data represent all community harvests; data for percent of households using and receiving 

resources are not available specifically to the project study area. According to the figure, the greatest

percentage of households reported using caribou and Arctic cisco (greater than 90 percent). A high 

number of households also reported using broad whitefish (86 percent), geese (85 percent), and burbot 

(64 percent). Furthermore, caribou hunting, broad whitefish and Arctic cisco fishing, and geese hunting 

are subsistence activities that are conducted by a large percent of Nuiqsut households (between 61 percent

and 77 percent, Figure 36). Among the key resources harvested in the project study area, wolf and 

wolverine use was reported among the fewest households. 

Sharing of these key resources is high among all households, particularly for caribou which had an 

average of 75 percent of households receiving the resource. Fish, geese, and eiders are also shared among 

an average of between 32 percent and 57 percent of households. Wolf and wolverine, which are not 

harvested for consumption, but for use of the furs, are shared less often.
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Figure 37 Percent of households using and receiving key resources, all study years

Sources: See Appendix F, Table F-2 for individual data and references. 

3.4.6.5 Existing Levels of Impacts on Subsistence Uses

Impacts on subsistence began shortly after the community of Nuiqsut was resettled in 1973. Therefore, 

impacts should be considered as part of the baseline of subsistence uses in Nuiqsut. This section briefly 

summarizes the various sources of impacts on subsistence in Nuiqsut over time and provides an 

assessment of current levels of subsistence impacts. 

While there are various environmental and social factors that have affected Nuiqsut subsistence 

harvesting patterns (e.g., climate change, sport hunters, technological advances), development—

particularly oil and gas development—has been the primary concern and source of impacts reported by 

Nuiqsut residents over the years (SRB&A 2009). Thus, development impacts are the focus of this 

discussion. Starting as early as the 1970s, concerns about development to the east of Nuiqsut were voiced 

during public hearings, and as development moved westward, reported impacts increased. The Alpine 

Development represented the first major oil and gas development within the Colville Delta and the 

Nuiqsut Subsistence Caribou Monitoring Project was implemented to monitor the impacts of the Alpine 

and Alpine Satellites Developments on Nuiqsut caribou hunting. However, impacts to subsistence were 

already occurring by the time development arrived in the Colville Delta. 

A review of public testimony on the North Slope by SRB&A (2009) revealed the top impact concerns as 

displacement of wildlife, EIS deficiencies, climate-development effects, release of contaminants, 

disruption of wildlife, contamination of wildlife, and cumulative impacts. Specifically for Nuiqsut, a 

review of documents associated with several development projects (Alpine Satellites, Endicott, and 

Northstar) showed that difficulty hunting and displacement of wildlife were the primary impact concerns 

reported; caribou, bowhead, and fish were the most commonly mentioned resources of concern (SRB&A 

2010c). Furthermore, during a survey of active harvesters in Nuiqsut in 2007, over half of the individuals 

interviewed indicated they had personally experienced the following impacts related to oil and gas 

development: difficulty hunting, displacement of wildlife, contamination/extraction of materials, 

disruption of wildlife, effects of development on wildlife, decrease in habitat, and ability to hunt (SRB&A 

2009). Nuiqsut residents use both the marine and terrestrial environments for subsistence, and therefore 
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both onshore and offshore oil and gas development has the potential to affect those activities. Sources of 

development-related impacts include infrastructure such as pipelines, bridges, pads, and roads; noise from 

air, ground, and vessel traffic; seismic exploration; noise from construction and drilling activities; security 

restrictions; and release of contaminants throughs spills and emissions. For a more in-depth description of 

subsistence impacts on the North Slope, see SRB&A (2009-2018) and EDAW, Inc. (2008). 

While it is difficult to provide a definitive measurement of the level of baseline subsistence impacts 

experienced by the community of Nuiqsut residents, several pieces of data are available which can help 

describe the extent and nature of such impacts: 1) Harvest data, 2) Subsistence use area data, and 3) 

Harvester reported impacts. 

Harvest Data

Harvest data can provide, among other things, an overall indicator of community harvest amounts, 

participation, and success. Based on harvest data collected for the community of Nuiqsut since the 1980s, 

the community’s harvests have remained stable over time. Harvest data from the most recent 

comprehensive household harvest survey showed harvests of most resources on the high end of previous 

study years, although low response rates for that study may have resulted in an overestimate of harvests. 

Recent caribou harvest surveys conducted for the Nuiqsut Caribou Subsistence Monitoring Project, 

including those from Year 9 (for the 2016 calendar year) (SRB&A 2018) and Year 10 (for the 2017 

calendar year) (SRB&A Forthcoming) have shown caribou harvests remaining within the range of 

previous study years. In addition, household participation in resource harvesting activities has remained 

stable, as has household success (measured as the difference between the percentage of households 

attempting harvests versus those successfully harvesting resources) for most resources. Recent caribou 

study years show an increase in the percentage of unsuccessful households, with the percentage of 

unsuccessful households ranging from zero to three percent in study years prior to 2010 (an average of 1.6 

percent), and from two to 16 percent in study years after 2010 (an average of 8.9 percent). For the most 

part, sustained harvest and participation levels are signs of the resiliency of the Nuiqsut people in the face 

of change and the availability of resources within the community’s harvesting area. However, it is 

important to note that community harvest amounts and participation rates are only one indicator of the 

health of the subsistence lifestyle, and sustained harvests may occur in spite of increased impacts on 

subsistence. For example, community harvest amounts do not provide information on the amount of effort 

(e.g., hours and distance) taken to harvest resources, the areas used to harvest resources, the quality of the 

resources harvested, or hunters’ experiences on the land. 

Subsistence Use Area Data

Subsistence use area data provide information on how a community uses the land for subsistence 

purposes, and comparison of subsistence use areas can provide information on impacts to or changes in 

use areas. A review of Nuiqsut subsistence use areas over time indicates a clear shift in use areas away the 

Prudhoe Bay/Kuparuk areas (areas which were at one time considered part of the community’s area of 

“intensive use” [Brown 1979]), and avoidance—along with physical barriers and security restrictions—

has been cited as a primary reason for this shift. Changes in use areas have occurred at a smaller scale 

since oil and gas development began in the Colville River Delta. Comparison of caribou use area data 

indicate decreased use of the Middle Colville Delta and the Nigliq Channel in recent years, and increased 

use of the area to the west of Nuiqsut, changes which have been attributed, at least in part, to hunter 

avoidance of industry. At the same time, use area data from the Nuiqsut Caribou Subsistence Monitoring 

Project show increased use of industry related roads, which are now connected to the community of 

Nuiqsut via a spur road, for hunting. While roads can benefit certain subsistence users by providing easier 

access to hunting areas, they can also cause a shift away from the use of traditional hunting grounds and 

can introduce new impacts such as user avoidance and barriers to hunters and wildlife. 
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Harvester Reported Impacts

There are various types of impacts that subsistence users experience which may not be reflected through 

harvest or subsistence use area data. One way to capture these impacts is to ask harvesters directly to 

describe their impact experiences. As noted above, public testimony is one source of harvester reported 

impacts; other sources include research targeted at documenting subsistence impacts. The Nuiqsut 

Caribou Subsistence Monitoring Project has documented harvester reported impacts annually since 2009. 

Across the first nine study years, the percentage of respondents reporting Alpine-related impacts has 

ranged from 27 percent (Year 9) to 72 percent (Year 1, which collected impacts since Alpine development 

began). While Year 9 showed an all-time low of reported impacts, preliminary review of the Year 10 data 

indicate that reported harvester impacts rose to within the range of previous years. While helicopter traffic 

had been the most commonly reported impact across all study years, recent years have shown a decrease 

in helicopter traffic impact reports and an increase in impacts related to manmade structures (e.g., roads 

and pipelines). A preliminary review of Year 10 data indicates an increase in reports of manmade structure 

impacts and “other traffic” impacts (e.g., trucks) which are related to the recent construction and 

operation of the Spur, CD5, and GMT1 roads. Other impacts which have been reported at varying levels 

throughout the monitoring study include plane traffic, seismic activity, and regulations (i.e., security 

restrictions or policies). 

In addition to direct impacts, Nuiqsut harvesters have reported indirect impacts through user avoidance 

and changes in resource availability. User avoidance may involve a harvester avoiding an area altogether, 

using an area less frequently, or simply not actively hunting when passing by or near a certain area. 

During Years 6 through 9 of the Caribou Subsistence Monitoring Project, when asked whether there are 

areas they no longer use or avoid, between 51 and 61 percent of harvesters responded in the affirmative. 

In most cases, development infrastructure or activities were cited as the cause of this avoidance. A 

preliminary review of the Year 10 data indicates an increase in reported avoidance during both the active 

harvester interviews and household harvest surveys. A similar number (but smaller percentage) of 

observations attributed the avoidance to development causes. Ultimately, harvester avoidance can result in 

decreased feelings of connection with a traditional use area and loss of knowledge about that area over 

time. The following quote from Year 9 of the monitoring project reflects the impact that the presence of 

development can have on subsistence users’ perception of the land:

So over here, the bridge [across Nigliq Channel] was one of the big impacts. [It impacts my] 

boating going towards CD4 and CD5, that area. Well, there is more increased traffic, trucks going 

over the bridge and helicopters. It’s just not—it doesn’t look right to hunt in anymore. The scenery 

has changed. I think it is more bothersome to me [than the caribou]. We have to have more caution 

about hunting close to people like that. Kind of like that area [of the Nigliq Channel]. (SRB&A 

Nuiqsut Interview November 2016).

Changes in resource availability are another harvester reported impact which may not be reflected through 

harvest data. Over the years, Nuiqsut residents have reported changes in the availability of certain 

resources resulting from development activities and infrastructure, particularly among migratory 

resources such as bowhead whales and caribou. Changes in resource availability may not always be 

reflected through harvest data if subsistence users compensate for the changes through increased time and 

effort; changes in hunting areas; or altered hunting methods. Throughout the Caribou Subsistence 

Monitoring Project Nuiqsut harvesters have reported changes in caribou migration, distribution, and 

behavior resulting from development infrastructure (e.g., pipelines and roads) and activity (e.g., air and 

road traffic). To compensate for decreased resource availability in their hunting areas, some respondents 

report taking more frequent or longer hunting trips or have changed the geographic focus of their hunting 

activities. As stated by one hunter during Year 9 of the monitoring project,
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It’s exhausting and gas wise you are wasting gas to the point you are not even catching anything. 

The gas is expensive.... So, last year when we had these people, they were drilling not too far 

from here, that was really pushing, our hunting to our side. So basically, me hunting since ’73 in 

Nuiqsut, I target the routes and areas they are actually at and now they are hardly there like they 

used to be. (SRB&A Nuiqsut Interview November 2016).

In recent years, as oil and gas development has moved to the west of the Colville Delta and permanent 

gravel roads and bridges have been constructed as part of that development, Nuiqsut harvesters are being 

faced with new potential sources of impacts and benefits to their community. Because they are relatively 

new, it is difficult to predict what impacts these developments—particularly the associated roads—will 

have on subsistence users. Preliminary data from Year 10 of the monitoring study indicate a shift toward 

use of roads for subsistence, but also an increase in reported impacts associated with roads and road 

traffic. While some respondents view the road as a benefit which provides access to caribou hunting 

grounds, others believe the road and/or road hunters are reducing the availability of caribou in traditional 

areas west of the community. Some Year 10 respondents reported using the road out of necessity, because 

the caribou were not available closer to the community. During a recent meeting of the Nuiqsut Caribou 

Panel, panel members reported impacts associated with developments to the west of the community, 

noting that caribou from the Teshekpuk Herd had approached the community in the fall/winter of 2017 

but diverted back to the west as a result of the roads and activity in the area. Panel members stressed that 

the height and grade of the GMT1 road is too steep and results in difficulties for both caribou and hunters 

trying to cross the road. In addition, the ramps which have been constructed in an effort to facilitate 

hunters getting on and off the road are placed too far apart and are too narrow and steep. As one panel 

member stated, “They need to be wider with a more gradual slope. When you are towing a sled, your sled 

goes off, which results in an accident” (Nuiqsut Caribou Panel Meeting May 2018).

Summary

The impacts of development on subsistence activities are evident through comparison of subsistence use 

areas over time and through harvester reports of direct and indirect impacts on subsistence use areas, 

harvester access, and resource availability. Harvest data indicate that development has not had 

community-level impacts on harvest amounts, success, or participation; however, Nuiqsut subsistence 

users have reported impacts on individual success rates and harvest amounts. The primary impacts which 

have been documented through existing data include changes in subsistence use areas due to harvester 

avoidance and introduction of infrastructure (e.g., roads); impacts on harvester effort and success related 

to air and road traffic, manmade structures, and security restrictions; and changes in resource availability 

within traditional hunting areas. Other impacts also reported by community residents, are not addressed in 

detail here, include contamination of resources, air pollution, and cumulative impacts on cultural identity 

and social ties.
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3.4.7 Public Health

The following section describes the community health and welfare in the community of Nuiqsut. 

3.4.7.1 Community Health and Welfare. 

The BLM NPR-A Integrated Activity Plan/EIS (2012) contains a detailed discussion regarding analysis of 

public health status in the North Slope Borough based on demographic and health infrastructure through 

2010. The following discussion of community health and welfare is tiered to BLM (2012, Section 3.4.12, 

Public Health) and BLM public health analysis for the GMT1 Project (2014, Section 3.4.6). The BLM 

NPR-A Integrated Activity Plan (2012) considers all eight villages of the North Slope Borough and 

villages of the Northwest Arctic Borough, a broader perspective than the analyses for GMT1 (BLM 2014) 

and the proposed GMT2 Project, which focus more narrowly on Nuiqsut. 

Information from the North Slope Borough Final Baseline Community Health Analysis Report (North 

Slope Borough 2012) was incorporated into BLM (2012, 2014). In 2017, the Alaska Department of 

Health and Human Services prepared a Human Health Baseline Summary for the GMT2 Project 

(Appendix G), which draws from the North Slope Borough health report (North Slope Borough 2012), the 

U.S. Census (U.S. Census ACS 2014), and the North Slope Borough Economic Profile and Census 

Reports (North Slope Borough 2010, 2016), and multiple state health databases (e.g., Alaska Behavioral 

Risk Factor Surveillance System). The 2017 Human Health Baseline Summary (Alaska Department of 

Health and Social Services 2017) provides the basis for much of the following discussion, which 

augments BLM (2012, 2014, Public Health). 

The earlier EIS prepared by the BLM for the Alpine Satellites (2004) provides a community health and 

welfare discussion that is brief and broad scale, yet it provides relevant general information when 

evaluating trends. That discussion is provided in BLM (2004, Section 3.4.1.5). 

The analysis for GMT1 (BLM 2014) addressed community health status for the eight North Slope 

villages with reference to biomedical health outcomes, health determinants, and public health. 

North Slope Borough and Nuiqsut Health: Overview

The main health conditions that burden the population in North Slope communities are the same as seen 

elsewhere in Alaska and the U.S.: cancer, heart disease, respiratory diseases, injury, overweight/obesity, 

and diabetes. However, rates for several of these health conditions are higher on the North Slope and in 

Nuiqsut than they are in the rest of the state of Alaska or the Nation. Appendix G provides a Baseline 

Human Health Summary for the community of Nuiqsut. 

There are some apparent reasons for these health differences (for example, tobacco use in the North Slope 

Borough is very high compared to most other areas of Alaska). However, researchers find that many 

health disparities (mental and physical) in Native American and Alaska Native communities are due to 

poverty, lack of access to healthy food, lack of immediate access to health care, and the effects of 

historical trauma (Yellowhorse Braveheart and DeBruyn 1998; Whitbeck et al. 2004; Basset et al. 2014; 

Diep 2015). 

In both Alaska overall and the North Slope Borough specifically, the leading causes of death are cancer, 

heart disease, and accidents/injuries. Among chronic diseases, high blood pressure (20 percent) and 

arthritis (21 percent) are the most frequently reported across the North Slope Borough. This is a lower rate 

of high blood pressure than across all Alaska (26 percent). Motor vehicle accidents represent the single 

leading cause of unintentional injury deaths in the North Slope Borough, with a rate three times that for 

all of Alaska (BLM 2012, page 508). 
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Self-reported health is one of the most consistent predictors of illness. In 2010, more than three-quarters 

(79 percent) of Nuiqsut heads of households reported their health to be at least good, and 21 percent

reported fair to poor health, which is generally consistent with other North Slope Borough villages. The

percentage of adults reporting very good to excellent health was lower in Nuiqsut (39 percent) than it was 

statewide (56 percent) (Alaska Department of Health and Social Services 2017). However, the percentage 

of adults reporting very good to excellent health in North Slope Borough villages ranged from 21% in 

Atqasuk to 56% in Point Lay, with Nuiqsut being similar to Alaska Native adults statewide (42%) (North 

Slope Borough 2012). 

The Final Baseline Community Health Analysis Report (North Slope Borough 2012) provides an 

extensive discussion of factors that are anticipated to impact the health of North Slope Borough residents. 

These factors are categorized as likely having either positive, negative, or mixed impacts on public health. 

Those considered to have positive impacts include:

• Participation in subsistence lifestyle and diet;

• Support and promotion of Iñupiaq culture and language; 

• Increase in education levels;

• Availability of health, social, emergency, and public safety services, and having health insurance 

coverage;

• Improvements in water and sanitation infrastructure;

• A local economy with below-average unemployment and poverty rates, and above-average median 

household income;

• Self-determination: civic participation and advocacy;

• Restrictive alcohol policies; 

• Tobacco taxes and indoor air quality laws (i.e., second-hand smoke); and 

• Youth that are connected and engaged with their schools and communities. 

The first two bullets above are those health factors with the most potential to be negatively affected by 

local development that occurs within a community’s subsistence harvest area. However, the next four 

bullets could also increase through development, leading to positive impacts on health relative to baseline 

conditions. The other three bullets are unlikely to be substantially affected by development.

Conversely, several factors are anticipated to negatively impact public health: 

• High rates of tobacco use;

• High levels of food insecurity and difficulty accessing food for healthy meals;

• Difficulty accessing health services;

• Historical and multi-generational trauma (such as epidemics, forced removal of children to boarding 

schools, and other traumatic events that lead to multigenerational grief and victimization);

• Drug and alcohol addiction; 

• Child neglect and abuse; 

• Education: high drop-out and low graduation rates; 

• Environmental issues (e.g., climate change, contaminants); 

• High consumption of sodas and sweetened beverages;

• Insufficient levels of physical activity;

• Low utilization of safety practices (e.g., helmets, seat belts); and

• Poverty and unemployment. 

Finally, the following factors are considered to likely have mixed impacts:

• Oil and gas development;

• Employment opportunities; and 

• Income level and distribution. 
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Specific to oil and gas development, the North Slope Borough (2012, page 45) report provides the 

following commentary: 

The health impacts of oil and gas development in the North Slope Borough are complex, as it has 

touched many aspects of community life in the region. Following the formation of the North Slope 

Borough, oil and gas revenues have created employment opportunities, provided money for 

essential services and infrastructure, and raised the average household income. An influx of 

outside interests and money can also create conflict, alter social structure, and divide communities, 

affecting community well-being. Real and potential impacts to the environment and subsistence 

are also ongoing sources of tension and concern. Natural resource development and fossil fuel 

extraction worldwide has also contributed to the climate change that is disproportionately affecting 

arctic communities.

Impacts to health factors can result from oil and gas development. The following sections summarize 

health data for Nuiqsut; complete descriptions can be found in Appendix G: Human Health Baseline 

Summary for the GMT2 Project. 

Asthma 

The prevalence of self-reported asthma has consistently been lower in the North Slope Borough than the 

prevalence statewide. In 2011–2013, the prevalence of asthma was 9.7 percent compared to 14.4 percent

for all of Alaska. Multiple environmental factors can trigger or exacerbate asthma, including tobacco 

smoke, exhaust from heating sources and vehicles, and poor indoor and outdoor air quality. 

Cancer

The prevalence of self-reported cancer in the North Slope Borough was lower than the prevalence 

statewide from 2011–2013. For this period, the prevalence of cancer in the North Slope Borough was 3.6 

percent compared to 6.7 percent for Alaska Natives statewide and 8.0 percent for all of Alaska. The North 

Slope Borough had the second lowest self-reported cancer prevalence of Alaska boroughs and census 

areas (Alaska Department of Health and Social Services 2017).

During 2013–2015, cancer was the leading cause of death among North Slope Borough residents and 

among Alaskans statewide. During that time period, the highest types of cancer that resulted in death 

among North Slope Borough residents were lung cancer (15 deaths), colorectal cancer (9 deaths), and 

stomach cancer (7 deaths) (Alaska Department of Health and Social Services 2017).

Tobacco

The high smoking rate in the North Slope Borough likely exacerbates lung cancer incidence: almost half 

of adults smoke regularly. Smoking and exposure to second-hand smoke are also associated with heart 

disease (Center for Disease Control 2016). From 2011–2013, the North Slope Borough had the thirdhighest prevalence of current tobacco users (includes current smokeless tobacco users). The prevalence of 

current tobacco users in the North Slope Borough was 52.9 percent. Comparatively, 46.5 percent of 

Alaska Natives statewide and 26.1 percent of all Alaskans reported tobacco use (Alaska Department of 

Health and Social Services 2017). 

In Nuiqsut, smoking among adults is high (62 percent) and smoking among teens (age 14-18 years, as 

reported by the household) was notably and significantly more common (43 percent) than smoking among 

teens from North Slope Borough communities overall (16 percent) (North Slope Borough 2012). 

Air Quality

Air quality concerns in rural Alaska villages include diesel emissions, indoor air quality, road dust, solid 

waste burning, and wood smoke. Residents in the North Slope Borough have also expressed concern 
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about air pollution generated by nearby oil and gas extraction activities. Emissions from anthropogenic 

sources are regulated by the EPA and fall into two broad categories: 

• Criteria Pollutants: Criteria pollutants are six common pollutants that occur all over the U.S. and are 

listed in the Clean Air Act for regulation. The EPA sets standards for allowable ambient 

concentrations of these pollutants, called the National Ambient Air Quality Standards. The national 

standards are set at a level that protects sensitive populations (children, the elderly, and people with 

compromised respiratory systems) with an ample margin of safety. The National Ambient Air Quality 

Standards are required to be reviewed periodically and adjusted if new scientific information exists 

that indicates a change is necessary to protect public health. 

• Air Toxics/Hazardous Air Pollutants: In addition to the six criteria pollutants, the EPA is required to 

regulate other hazardous air pollutants that are known or suspected to cause serious health effects or 

adverse environmental effects. There are 187 air toxics identified by the EPA, which are regulated by 

establishing limits on emissions based on the maximum achievable control technology (for stationary 

industrial sources). The EPA reviews standards for each air toxic every 8 years, and adjusts allowable 

emission levels based on the best available control technology. Air toxics can also be emitted from 

mobile sources. 

Assessments of air pollution in Nuiqsut, based on monitoring data from the ConocoPhillips air monitoring 

station, have found that pollutant concentrations are generally well below the national ambient air quality 

standards for criteria pollutants. From 2008-2010, data on volatile organic compounds (VOCs) were 

collected by the Alaska Native Tribal Health Consortium and none of the VOC concentrations exceeded 

the air quality standards and screening levels set by multiple federal agencies. VOCs specifically 

associated with crude oil development were either not detected or were found at very low concentrations 

(below all standards and screening levels) for all of the collected samples. Data on air toxics is not 

collected at air quality monitoring stations near Nuiqsut; however, modeling projections for the 

cumulative effects of emissions of hazardous air pollutants from industrial sources indicate that the 

potential risks to human health are extremely low (Section 4.2.3, Atmospheric Environment, BLM 2014). 

The most frequently identified source of air pollution during key informant interviews in Nuiqsut was oil 

and gas development (Alaska Native Tribal Health Consortium 2011). The available air monitoring and 

modeling data do not support this perception, as measured air pollutant concentrations for criteria 

pollutants are consistently low. It will be crucial to continue to monitor air quality in Nuiqsut over time as 

development continues. 

Alaska Department of Health and Social Services investigated air pollution and respiratory illness in 

Nuiqsut in response to community concerns in 2003 and 2012. In both studies, health data were collected 

from inpatient and outpatient visits for respiratory illness. For the 2012 study, air pollution data were 

collected from the ConocoPhillips monitoring station and reviewed by Alaska Department of Health and 

Social Services. Air pollution was not found to be associated with respiratory illness in these 

investigations (Alaska Department of Health and Social Services SOE 2003; Alaska Department of 

Health and Social Services 2012). 

Lower respiratory diseases can be aggravated by air pollutants that are commonly linked to oil 

development activities as well as other factors such as poor indoor air quality in homes. The North Slope 

Borough has had consistently higher rates of death due to respiratory disease since at least 1996 (North 

Slope Borough 2012). The mortality rate of North Slope Borough residents due to chronic pulmonary 

disease is 130 out of 100,000 compared to 45 out of 100,000 persons for the U.S. as a whole (Wernham 

2007). 
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Food Security

North Slope Borough households, particularly Iñupiat households, reported high levels of food insecurity 

in the North Slope Borough 2010 Census (North Slope Borough Census 2010; Table 5). In the North 

Slope Borough, 35 percent of household heads reported that there were times when they found it difficult 

to get the food needed to make healthy meals (Table 68). Nineteen percent of household heads reported 

that there were times in the previous year when household members did not have enough to eat(North 

Slope Borough Census 2010). 

However, Nuiqsut is one of the most food secure communities on the North Slope. From 2010 estimates, 

9% of Nuiqsut households reported food insecurity, compared to higher percentages food insecurity for 

other North Slope communities and 24%, collectively, for the North Slope Borough census area (Table 

68) (NSB, 2015). 

Statewide and national food insecurity data are not easily comparable with North Slope Borough data 

because state and national surveys do not ask about subsistence food security or take into account the lack 

of availability of many foods in remote communities. North Slope Borough data cited in the North Slope 

Borough Baseline Community Health Analysis Report (North Slope Borough 2012) are not directly 

comparable with statewide estimates. However, the results suggest that food insecurity is a serious 

problem across the North Slope Borough and, like other rural areas, exists at levels higher than statewide 

estimates (Alaska Department of Health and Social Services 2017).

Table 68. Food security indicators in the North Slope Borough, 2010

Community

Times Last Year 

When Household 

Found it Difficult 

to Get the Food 

They Needed to 

Eat Healthy Meals 

(%)

If Household Found 

it Difficult, Was 

Difficult Because 

They Could Not Get 

Enough Subsistence 

Foods (%)

If Household 

Found it Difficult, 

Was Difficult 

Because They 

Could Not Get 

Enough Store 

Foods (%)

Households that 

Get at Least Half 

of Their Meals 

From Subsistence 

Sources (%)

North Slope Borough 35 43 90 54

Anaktuvuk Pass 57 71 80 67

Atqasuk 59 34 100 58

Kaktovik 40 44 88 67

Nuiqsut 38 53 87 67

Point Hope 36 59 86 64

Point Lay 51 48 96 61

Utqiaġvik 38 34 90 44

Wainwright 46 36 95 67

Source: North Slope Borough Census (2010).

The Alaska Department of Fish and Game conducted a harvest study in Nuiqsut during 2015. Several 

questions focused on food security and the study found that 12 percent of Nuiqsut households worried 

about having enough food at one or more times during 2014. Approximately 26 percent of households 

reported that they lacked the resources (i.e., time, money, and equipment) to obtain either subsistence or 

store-bought foods (Alaska Department of Fish and Game 2016). In this study, Nuiqsut had a slightly 

higher percentage of food secure households (90 percent) and slightly lower very food insecure 

households (2 percent), compared to 2014 estimates for the entire state (88 percent food secure, 4 percent

very food insecure) (Brown et al. 2016). 
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Health Infrastructure and Capacity

The North Slope Borough and the Arctic Slope Native Association are jointly responsible for delivering 

health services to North Slope Borough residents (North Slope Borough 2012). With the exception of 

Utqiaġvik, all North Slope Borough communities maintain a clinic that is staffed by medical personnel 

via the Community Health Aide Program. These clinics do not have a physician or physician’s assistant in 

residence. The Samuel Simmonds Memorial Hospital is located in Utqiaġvik and is a 14-bed hospital with 

an outpatient unit that consists of a 6-room clinic and a 2-bed emergency room (Arctic Slope Native 

Association 2017). Utqiaġvik is the tertiary care center for the North Slope Borough villages; cases are 

referred to Fairbanks or Anchorage if they cannot be admitted by Samuel Simmonds Memorial Hospital. 

Utqiaġvik also has a community mental health center, a dental clinic, and is the location of the North 

Slope Borough Department of Health and Social Services (North Slope Borough 2012). 

Access to services is limited by the remote location of the villages, cost of travel, and severity of the 

climate (North Slope Borough 2010). Many of the communities in the North Slope Borough suffer from 

chronic health care workforce shortages and turnover (North Slope Borough 2012). The U.S. Health 

Resources and Services Administration characterizes the North Slope Borough as a medically 

underserved and health professional shortage area (North Slope Borough 2012). The County Health 

Rankings for 2011 report that there was only one primary care physician for every 961 people in the 

North Slope Borough, while there was one primary care physician for every 731 Alaska residents (Alaska 

Department of Health and Social Services 2017). 

Contaminants

Almost half (44 percent) of Iñupiat village residents have reported concerns that fish and animals may be 

unsafe to eat due to environmental contamination. Regardless of the actual exposure, if any, to 

environmental contamination, the perception of contamination may result in stress and anxiety about the 

safety of subsistence foods and avoidance of subsistence food sources, with potential changes in nutritionrelated diseases as a result. These health impacts (perceived or real) arise regardless of whether or not 

there is any contamination at levels of toxicological significance; the impacts are linked to the perception 

of contamination, not to measured levels. This important discussion (BLM 2012, page 512) suggests that 

impacts can occur in the absence of significant chemical release, based only on perception of a potential 

threat.

3.4.8 Environmental Justice

Environmental Justice is defined in EO 12898: Federal Actions to Address Environmental Justice in 

Minority Populations and Low-Income Populations, which requires that proposed projects be evaluated 

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

and activities on minority populations and low-income populations.” 

In 2016, the Department of the Interior released an updated Environmental Justice Strategic Plan that 

establishes goals, objectives, and detailed guidance for federal agencies to accomplish the task of ensuring 

that no racial, ethnic, cultural, or socioeconomic group disproportionately bears the negative 

environmental consequences resulting from governmental programs, policies, or activities (DOI 2016)4

 . 

Guidelines for evaluating the potential environmental effects of projects require specific identification of 

minority populations when either: (1) the minority population of the affected area exceeds 50 percent or; 

(2) the minority population percentage of the affected area is meaningfully greater than the minority 

population percentage in the general population or other appropriate unit of geographic analysis. 

 

4 Available online as of May 22, 2017: https://www.doi.gov/sites/doi.gov/files/uploads/doi_ej_strategic_plan_final_nov2016.pdf
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The community of Nuiqsut is the closest community to be potentially affected by the project study area. 

The State of Alaska socioeconomic characteristics were selected as the reasonable reference population 

(BLM 2004, page 327). 

Although the NSB (2016) has updated population numbers, the official U.S. Census data from 2010 is 

used to determine environmental justice populations due to the need to compare percentages of 

populations throughout the state. According to 2010 Census data, 87.1 percent of the population of 

Nuiqsut is Alaska Native or American Indian (specifically Iñupiat), an identified minority group. The 

statewide population is 14.8 percent American Indian or Alaska Native. The ethnic composition of 

Nuiqsut compared with the State of Alaska is shown in Table 69. Based on the census data, the minority 

population in Nuiqsut is well above the 50 percent threshold specified in the EPA guidelines, so it is 

appropriate to consider potential environmental justice issues in evaluating the effects of the proposed 

plan. 

Table 69. Ethnic composition of Nuiqsut compared with State of Alaska

Category

State of Alaska Nuiqsut

Population Percent Population Percent

Total 710,231 100.0 402 100.0

Hispanic or Latino 39,249 5.5 0 0.0

Not Hispanic or Latino 670,982 94.5 402 100

Population of One Race 658,356 92.7 391 97.3

White 473,576 66.7 40 10.0

Black or African-American 23,263 3.3 1 0.2

American Indian or Alaska Native 104,871 14.8 350 87.1

Asian 38,135 5.4 0 0.0

Native Hawaiian and Pacific Islander 7,409 1.0 0 0.0

Some Other Race 11,102 1.6% 0 0.0

Two or More Races 51,875 7.3% 11 2.7

Source: The 2010 population numbers are actual counts from decennial censuses. Alaska Department of Labor and Workforce 

Development, Research and Analysis Section, 2010 Census, Demographic Profiles for Alaska and Nuiqsut, 

http://live.laborstats.alaska.gov/cen/dp.cfm (February 13, 2017).

The Council on Environmental Quality guidance on environmental justice under the National 

Environmental Policy Act (Council on Environmental Quality 1997) directs federal agencies to apply 

Council on Environmental Quality guidance with flexibility and to consider them as a point of departure 

rather that conclusive direction in applying the terms of the Executive order on environmental justice. 

Following this guidance, analyses of potential impacts should recognize if the question of whether agency 

action raises environmental justice issues 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 the Iñupiat of the North Slope is discussed in BLM (2012, Section 4.4.5). The BLM continues to 

recognize and monitor the interrelated cultural, social, occupational, historical, or economic factors that 

are associated with the natural and physical affected environment for the GMT2 Project.

The goals established in the 2016 DOI Environmental Justice Strategic Plan are:

• Heightened Sensitivity: Ensure responsible officials are aware of the provisions of Executive Order 

12898 and are able to identify and amend programs, policies, and activities under their purview that 

may have disproportionately high and adverse human health or environmental effects on minority, 

low-income, or Tribal populations. 
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• Public Participation: Ensure minority, low-income, and Tribal populations are provided with the

opportunity to engage in meaningful involvement in the Department’s decision making process.

• Decreasing Our Impacts: The Department will, on its own or in collaboration with partners, identify

and address environmental impacts that may result in disproportionately high and adverse human

health or environmental effects on minority, low-income, or Tribal populations.

• Grants and Technical Assistance: Use existing grant programs, trainings, and educational

opportunities, as available, to aid and empower minority, low-income, and Tribal populations in their

efforts to build and sustain environmentally and economically sound communities.

• Title VI Enforcement: Integrate the DOI’s environmental justice strategies with its Title VI of the

Civil Rights Act enforcement responsibilities to improve efficiencies while preserving the integrity of

Title VI and environmental justice activities.

The analysis conducted for the GMT1 project concluded that, due to findings of adverse impacts to 

subsistence and sociocultural systems, the GMT1 project raises environmental justice issues. The BLM 

also continues to consult with Nuiqsut to identify and address environmental impacts that may result 

from GMT2. 
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Chapter 4. Environmental Consequences

4.1 Introduction 

Comprehensive analyses of environmental consequences of development of the entire Alpine Field, 

including GMT2 as it was designed in 2004, were performed in the program-specific BLM (2004). 

Environmental impacts of anticipated oil and gas development in the NPR-A, also including GMT2, were 

analyzed in BLM (2012). The analyses of potential environmental consequences of the proposed GMT2 

Project provided in this section are tiered to, and incorporate by reference these previous analyses, with 

specific references cited in the discussions in the following sections. Alternative A (ConocoPhillips's 

proposed project) and two other action alternatives for project development were carried forward through 

impact analysis. Chapter 2 describes all action alternatives and the no-action alternative (Alternative D).

The BLM has identified Alternative A, the Proponent’s Proposal, as the Agency’s preferred alternative in 

this supplemental EIS. The identification of a preferred alternative does not constitute a commitment or 

decision in principle, and there is no requirement to select the preferred alternative in the Agency’s record 

of decision. If warranted, the BLM may select a different alternative than the preferred alternative in its 

record of decision.

4.1.1 Project Study Area and Methodology

The GMT2 Project facilities are located entirely within the Northeast NPR-A, on the North Slope of 

Alaska, immediately west of the Colville River Delta. The GMT2 project study area encompasses 

158,480 acres and is comprised of all project components necessary for GMT2 to be developed (see Map 

3.1.1). The project study area includes the community of Nuiqsut, the gravel mine located 4.5 miles 

northeast of Nuiqsut, the Alpine Central Processing Facility (CPF), CD2, and CD4 in the Colville Delta 

north of Nuiqsut, bridges over the Nigliq Channel of the Colville River (and 3 smaller bridges between 

the Nigliq and CDS and over the Ublutuoch River), the CDS drill site, the CDS-GMTl access road, the 

GMTl drill site northwest of Nuiqsut, and the proposed GMT1-GMT2 access road and GMT2 drill site 

west of Nuiqsut. The discussion of the environmental consequences for each resource will focus on 

identifying the positive and negative direct and indirect impacts that could occur within the project study 

area. When relevant and applicable, discussion may focus on particular areas within the project study 

area, such as the area between GMT1 and GMT2 or the ice road route associated with a particular 

alternative; or may extend beyond the project study area if the direct and indirect impacts for that resource 

are anticipated outside of the boundary.

The potential impacts were analyzed by reviewing ConocoPhillips’ project description and design 

components intended to reduce impacts, data collected by ConocoPhillips, and other information provided 

by ConocoPhillips. Previous publications and data collected within and near the project study area by 

state, federal, and local agencies were also reviewed. ConocoPhillips’ information was verified by 

independently reviewing reference sources and previous publications on these resources. The information 

regarding existing conditions as presented in Chapter 3, “Affected Environment,” was assessed relative to 

the ConocoPhillips’ proposed action and the other alternatives described in Chapter 2, “Proposed Project 

and Alternatives,” to assess impacts.

A major change between the draft and final analysis was the removal of all impact criteria classifying 

impacts to resources as minor, moderate or major. According to BLM's NEPA guidance, the effects 

analysis must demonstrate that the BLM took a “hard look” at the impacts of the action. The level of 

detail must be sufficient to support reasoned conclusions by comparing the amount and the degree of 

change (impact) caused by the proposed action and the alternatives. NEPA does not require the agency to 

classify impacts to each resource as minor, moderate or major. The BLM found that the use of GMT2 
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Impact Criteria did not contribute to meaningfully distinguish the alternatives from each other, and 

instead detracted from the impact analysis due to confusion and differences of opinion regarding the 

criteria being applied over focusing on the identified impacts and how to mitigate them. For the Final 

Supplemental EIS, the BLM removed the impact criteria and described the specific impacts that were 

likely to occur under each alternative. 

4.1.2 Project Alternatives and Major Project Components

Table 70 lists major project components of each action alternative. The project component values, such as 

road lengths and pad acreage, are approximations based on best available data. Due to differences in data 

processing systems (e.g., GIS) and methodologies (e.g., number rounding), the values presented in the 

final supplemental EIS may differ slightly from values presented in other project-related documents such 

as permit drawings. These differences have been reviewed and determined to be insignificant to the 

analysis as well as to the overall permitting process. A brief description of each alternative is below:

• Alternative A, Proponent’s Proposal, Preferred Alternative: Alternative A consists of a 14-acre 

gravel pad with up to 48 wells connected to existing infrastructure with an 8.2-mile gravel road. See 

Section 2.5, “Alternative A,” and Map 2.5-1. 

• Alternative B, Alternate Road Alignment: Alternative B consists of a 14-acre gravel pad with up to 

48 wells connected to existing infrastructure with a 9.3-mile gravel road. See Section 2.6, 

“Alternative B,” and Map 2.6-1. 

• Alternative C, Roadless Development: Alternative C consists of a 19-acre pad with up to 48 wells 

and an airstrip. Alternative C would be serviced via aircraft and would not have a gravel access road 

connected to existing infrastructure. See Section 2.7, “Alternative C,” and Map 2.7-1. 

• Alternative D, No Action: Under Alternative D, the GMT2 Project would not be developed. 
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Table 70. Major project components of the action alternatives

Project Component

Alternative A

Proponent’s Proposal, 

Preferred Alternative

Alternative B

Alternate Road Alignment

Alternative C

Roadless Development

Drill Pad 14.0 acres 14.0 acres 19.1 acres

Occupied Structure Pad None None 18.4 acres

Air Access Facilities None None 47.3 acres; airstrip and apron

GMT1–GMT2 Access Road 8.2 miles; 62.8 acres of fill 9.4 miles, 72 acres of fill None

Tundra Access Subsistence Pullouts 3 pullouts 3 pullouts None

Airstrip Access Road None None 0.9 mile, 7.2 acres

Ice Roads and Pads Year 1–2: 52.6-mile ice road, 175-acre 

ice pad

Year 2–3: 43.9-mile ice road, 135-acre 

ice pad

Year 3–10: 10-acre ice pad to support 

drilling

Year 1–2: 51.9-mile ice road, 175-acre ice 

pad

Year 2–3: 43.3-mile ice road, 135-acre ice 

pad

Year 3–10: 10-acre ice pad to support 

drilling

Year 1–2: 51.6-mile ice road, 205-acre ice pad

Year 2–3: 51.2-mile ice road, 175-acre ice pad

Years 3–10: 7.0-mile ice road, 10-acre ice pad

Years 11–32: 7.0-mile ice road, 2.0-acre ice pad

Total Water Requirements 395 million gallons 398 million gallons 691 million gallons

Fish Stream Crossings 1 (Lake M9925 outlet) None None

GMT1–GMT2 Pipeline System 8.6 miles; 0.1 acre of fill from new 

vertical support members

9.4 miles, 0.1 acre of fill from new vertical 

support members

8.6 miles; 0.1 acre of fill from new vertical support 

members

Ancillary Pipelines None None Diesel & mineral oil supply, 2-inch water supply

Total Gravel Footprint 78.0 acres 87.2 acres 92.0 acres

Gravel Supply Arctic Slope Regional Corporation 

Mine site

Arctic Slope Regional Corporation Mine

site

Arctic Slope Regional Corporation Mine site

Total Gravel Requirement 671,300 cubic yards 747,300 cubic yards 930,000 cubic yards

Construction Schedule 4Q Year 1–3Q Year 3 4Q Year 1–3Q Year 3 4Q Year 1–3Q Year 3

Drilling Timeframe 7.1 years, 2Q Year 3–Year 10 7.1 years, 2Q Year 3–Year 10 7.1 years, 2Q Year 3–Year 10

Post-Construction Operation 30 years 30 years 30 years

Lodging Requirements-Construction Year 1–2: 305 beds

Year 2–3: 305 beds in winter, 70 beds 

in summer

Year 1–2: 305 beds

Year 2–3: 305 beds in winter, 70 beds in 

summer

Year 1–2: 305 beds

Year 2–3: 445 beds in winter, 140 beds in summer

Lodging Requirements-Drilling 75-bed drilling camp 75-bed drilling camp 120-bed drilling camp

80-bed operations camp

Lodging Requirements-Operations None None 25-bed operations camp

Access Year-round access via gravel road Year-round access via gravel road. Year-round access by aircraft only, weather 

permitting. Seasonal access by ice road.
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4.1.3 BLM Protective Measures

The NPR-A Integrated Activity Plan Record of Decision includes a number of protective measures that 

would be imposed on activities permitted by the BLM in the NPR-A. These protective measures are in the 

form of lease stipulations and best management practices, provided in Appendix J. As explained further in 

Section 4.7, “Mitigation Measures and Monitoring,” stipulations are specific to oil and gas leases, and 

describe objectives for protection of certain resources and management of certain activities. Best 

management practices apply to all activities in the NPR-A. Stipulations and best management practices

also provide a basis for analyzing potential impacts of an activity (BLM 2012, Section 2.3.5). Other 

agencies with permitting authority for the proposed project include protective measures and regulatory 

requirements as part of their permit processes, as described in Table 1 and Appendix J.

4.1.4 Potential New Mitigation Measures

In addition to project design features, BLM lease stipulations, and best management practices already 

applicable to the project, this chapter also considers several potential new mitigation measures designed 

to further avoid, reduce, or compensate for impacts from the proposed action. These measures are 

discussed in the relevant resource sections that follow, and were developed based on suggestions from 

cooperating agencies, stakeholders, and BLM staff. The mitigation measures proposed in this document 

were developed with input from the public comments received during the Draft comment period. As with 

existing BLM lease stipulations and best management practices, an objective and proposed 

requirement/standard are identified for each potential new mitigation measure, and potential benefits and 

residual/unavoidable impacts are evaluated. Except where otherwise eliminated from further 

consideration, the decision whether to adopt each new mitigation measure will be made in the record of 

decision.

4.2 Physical Characteristics 

The following discussion regarding impacts on or by the physical environment is generally categorized 

and organized as it is in BLM (2014).

4.2.1 Terrestrial Environment

The action alternatives would result in impacts to the terrestrial environment. The impacts are discussed 

in this section, organized by the two primary phases of the project: (1) construction and (2) drilling and 

operation. These impacts are described in detail by BLM (2004, Section 4F.2.1) and generally for the 

Northeast NPR-A (BLM 2008, Section 4.3.2–4.3.3) and the entire NPR-A (BLM 2012, Section 4.3.2–

4.3.3). The following discussion provides a summary of the impacts.

Impacts to the following resources of the terrestrial environment were analyzed:

• Physiography/Geomorphology

• Soils and Permafrost

• Geology and Mineral Resources

• Petroleum Resources

• Sand and Gravel Resources

• Paleontological Resources
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4.2.1.1 Physiography and Geomorphology/Soils and Permafrost

Physiography and geomorphology are closely related to soil and permafrost conditions in the project area 

and impacts are addressed together in this section. Direct impacts are related to the footprint of gravel fill 

for each action alternative. The footprint for each alternative is listed in Table 70.

Construction

Ground-impacting activities of the action alternatives could alter permafrost as described in BLM (2004, 

Section 4F.2.1.3) and BLM (2012, Section 4.5.3.2). The thermal regime of permafrost is the dominant 

control on soil formation and soil properties on the Arctic Coastal Plain. Placement of gravel on the 

tundra for roads, pads, and airstrip would directly impact the thermal regime of permafrost. Impacts to 

permafrost stem from alteration of ground temperature that can be caused by construction of 

infrastructure (e.g., gravel pads). Any disturbance that removes the insulating surface organic layer or 

decreases the solar reflectance of the surface may result in differential thawing of the permafrost and 

cause thermokarst, subsidence, and increased potential for soil erosion and sedimentation (BLM 2012, 

Section 4.3.3.2, page 105). Thermokarst often results where permafrost thawing occurs in ice-rich, finegrained sediments (BLM 2004, Section 4A.2.1.3, page 416). Soils in the project study area are subjected 

to cold and anoxic conditions that retard soil formation, allowing exposed mineral soil layers to persist for 

decades.

Characteristics of the material used for gravel fill could also impact soil near gravel structures. For 

example, saline material used as fill increases the salinity of water draining off of or leaching through the 

structure. Increased salinity at a site could alter the soil properties in the immediate vicinity of the gravel 

structure. 

Dust generated from the fill and pads will drift off from the pads and adversely affect the neighboring 

areas by adding loess materials to the soil profile up to 1,000 meters from the source (Walker 1987) as 

well as changing the albedo or reflectance of the surface (Hope et al. 1991). This combination may 

increase the rate of thaw and result in changes of soil properties.

Snowdrifts caused by gravel structures would increase the soil surface temperature in winter and increase 

thaw depth in the soil near the structures. Blockage of natural drainage patterns can lead to the formation 

of impoundments or redirection of surface water flow and may cause deposition or erosion of sediment. 

The use of adequate cross-drainage structures in gravel roads and attention to the natural drainage patterns 

during design of developments could help reduce impacts to soils from impoundments. (See also Section 

4.2.2, “Water Resources,” and Section 4.3.1, “Vegetation and Wetlands.”)

Construction of ice roads and pads would locally cause compression of soils and vegetation (see also 

Section 4.3.1, “Vegetation and Wetlands”). A recent BLM study of ice road impacts found that the wetter 

the area (evaluated during summer), the less damage to insulating vegetation and soils from large-tired 

vehicles. Recovery of vegetation would be expected within a few years after ice roads and pads are no 

longer constructed. Impacts from long-term disturbance from ice pads, ice roads, and snow trails would 

be negligible to the health of the soils and proper functioning of the landscape. Although some evidence 

of crushed tussocks may still be apparent, new growth would preclude any exposed soils or extensive 

changes in the active layer (BLM 2012, Section 4.3.3.2, page 107). A summary of ice road construction 

and associated water use for the project alternatives is presented in Section 2.5.4.1 and Table 5 Discussion 

of impacts to water resources and hydrology, vegetation, and wetlands is presented in Section 4.2.2 and 

Section 4.3.1, respectively.

Pipeline construction would displace soil during installation of vertical support members and would 

disturb a zone around the vertical support members that is approximately 24 inches in radius. Vertical 

support members would be installed in winter and spoils material would be collected at the surface for 
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proper disposal. Approximately 0.007 acre of soil would be disturbed per pipeline mile for gathering 

lines. Pipelines could also impact soils indirectly by altering snow accumulation patterns and by shading 

vegetation, which may decrease soil temperatures and could potentially affect plant growth. Soil under a 

pipeline receives less direct sunlight during the growing season than does the soil that is not under a 

pipeline. Therefore, there could potentially be a reduction in heat absorption by the ground cover, leading 

to a shallower active layer. Shading from pipelines was not part of the evaluation of indirect impacts.

Low-ground-pressure vehicles may be permitted to travel on the tundra during periods other than when 

the ground is frozen and covered with snow, as authorized by BLM. Because of restrictions that would be 

placed on this activity, impacts to soil should be limited to the compression (reduction) of the insulating 

mat, similar to what happens during winter following traffic by low-ground-pressure vehicles.

Impacts caused by spills during construction (e.g., diesel fuel) would have the potential to impact the 

terrestrial environment as described in Section 4.5, “Impacts of Oil, Saltwater and Hazardous Materials 

Spills.”

Drilling and Operation

Direct impacts to physiography and geomorphology are closely related to impacts on soil and permafrost 

and are addressed together in this section. These impacts are essentially the same as during construction.

During operations, there would be indirect impacts to vegetation and wetlands adjacent to gravel roads, 

pads, and airstrip resulting from gravel spray and dust deposition, altered snow distribution, hydrologic 

impoundments, increased flooding, and thermokarst (Table 117). The effects of these impacts are likely to 

occur most often within 300 feet from the gravel feature, based on data presented in Auerbach et al. 

(1997). Gravel and dust could smother vegetation and cause early snowmelt, reduced soil nutrients, lower 

moisture, an altered soil organic horizon, higher bulk density, and greater depth of thaw. Other potential 

impacts identified by the U.S. Army Corps of Engineers (2012, Section 5.8.3.1) include: reduction in 

vegetation biomass, early green-up of plants, increases in graminoid composition, decreases in sphagnum 

and other mosses and lichens, shallower organic horizon, and changes to soil pH.

Indirect impacts to soil and permafrost would occur for all alternatives during drilling and operation. The 

passage of vehicle traffic over gravel pads, roads, and airstrip (depending on alternative) would result in a 

gravel spray/dust shadow with measurable impacts on soil, vegetation, and permafrost extending out to 

300 feet from the edge of the gravel feature (Auerbach et al. 1997). Within gravel spray and dust 

deposition areas, soil properties such as moisture, temperature, chemistry, and nutrient regimes could be 

altered. In extreme instances, this deposition may bury the existing organic horizon of the soil with a new 

layer of higher bulk density that would restart the soil-forming processes. For this analysis, the area of 

potential indirect impact from gravel spray and dust deposition was evaluated by calculating the acreage 

within 300 feet of the edge of gravel roads, pads, and airstrip, as appropriate for each alternative.

Indirect impacts to soil and permafrost will also result from increased off road vehicle access to the 

tundra. Both Alternative A and B will provide access to the tundra for subsistence hunters via the 

GMT1—GMT2 Access Road. Several ramps along the proposed GMT2 road would allow crossing the 

elevated road from one side to the other and provide egress off the road and access back onto the road by 

four-wheelers and snow machines. Off-road vehicle use may be dispersed across the tundra while 

conducting subsistence activities, but the GMT2 road ramps will concentrate off-road vehicles use at their 

location because they will be the only way on and off the elevated roadway. Repeated passes by fourwheelers (or other wheeled vehicles) during non-frozen periods would likely result in trail braiding, 

breaking the tundra mat, ruts and channeling of water into vehicle tracks, and exposure of frozen soil with 

potential localized permafrost thawing and thermokarsting near the ramps. Four wheeler trails spoking 

away from the ramp would be susceptible to trail braiding from repeated vehicle passes until far enough 
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away from the access ramp to disperse four wheeler use cross-country (see Section 3.2.1: Terrestrial 

Environment) and (Racine and Johnson 1988, Slaughter, Racine et al. 1990). 

Other effects of the road would exacerbate tundra damage from four-wheeler traffic. Fugitive dust that 

falls out on nearby snow and ice could cause earlier melting in the spring, and snow buildup adjacent to 

the road would exacerbate small-scale thermokarst due to added insulation of deep snow which reduces 

frost penetration during winter months (O’Neill, et al, 2017). Mitigation measures would reduce fugitive 

dust but will not eliminate it. Apart from road and four-wheeler traffic effects, arctic permafrost is 

experiencing record warming (Richter-Menge, Overland et al. 2017): the volume of ice-rich permafrost 

soils is decreasing, which results in subsidence of the surface. Subsidence may occur over a broader area 

than solely in those areas that are directly impacted by vehicle traffic. Four-wheeler traffic would 

accelerate the subsidence of the permafrost in the track areas. Future four-wheeler traffic is expected to 

create more damage than under the present conditions (see Section 3.4.2.3 Climate Change) and (Racine 

and Johnson 1988, Slaughter, Racine et al. 1990, Bane 2000). 

Spills during drilling and post-drilling operation (e.g., diesel fuel) would have the potential to impact soil 

and permafrost as described in Section 4.5, “Impacts of Oil, Saltwater and Hazardous Materials Spills.”

Hydraulic fracturing will occur under all action alternatives for initial stimulation of the wells and will 

likely have negligible impacts on the Arctic Coastal Plain’s seismicity. There have been no reports of 

induced seismicity in the Arctic Coastal Plain resulting from oil and gas hydraulic fracturing operations 

(Wallace, personal communication, 2018).

Comparison by Alternative

Alternative A. Of the action alternatives, this has the smallest area affected by gravel placement and a 

shorter road than Alternative B. The road constructed under this alternative will have the lowest and 

smallest pads, thus producing the least area of both direct impact (burial) and indirect impact to adjacent 

areas. The drifting of snow is projected to be less that other action alternatives due to the lower profile. 

The distribution of dust will be less due to the shorter road length. This alternative has the least potential 

to impact water flow patterns affecting permafrost stability, but there is still ample opportunity for there to 

be restrictions or alterations in flow patterns which negatively affect permafrost. Of the action 

alternatives, Alternative A is the least impactful. 

Alternative B. Alternative B has more area affected by gravel placement than Alternative A; however, the 

gravel placement is similar in configuration to Alternative A. The roads constructed under this alternative 

will have a lower profile compared to the gravel thickness required for Alternative C, thus producing a 

moderate area of both direct impact (burial) and indirect impact to adjacent areas. The gravel area of 

Alternative B is 12 percent greater than that of Alternative A, which will result in a greater potential for 

drifting snow and dust. The distribution of dust will likely be highest under Alternative B due to the 

configuration of gravel placement (road versus pad) and the amount of traffic anticipated. More area 

disturbed and the longer road compared to Alternatives A and C will potentially mean a greater impact to 

water flow and permafrost stability.

Alternative C. Of the action alternatives, Alternative C has the greatest projected affected area and the 

greatest depth of material to be placed. Both of these factors increase the impact of the development on 

the soil resources. More equipment and materials will also need to remain onsite for longer periods of 

time since it will be more difficult to move things in and out as needed and certain safety equipment 

cannot be readily moved to the site when needed. These factors all contribute to a substantially higher 

impact than the other action alternatives. Having higher surface elevation above the tundra will result in 

more drifting (deeper and longer) of snow and allow dust to carry a further distance as well. Infrastructure 

under Alternative C will cover approximately 18 percent more surface area with gravel than Alternative 
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A, which will increase direct impacts as well as indirect impacts due to drifting snow and dust. This 

alternative also has the greatest potential for altering local water flow patterns since the size of the pad is 

so large. 

Alternative D. This is the no-action alternative and would have no additional impact on soils for this 

area.

Proposed New Mitigation Measures

Potential Mitigation Measure 1: Alaska Natural Resources Conservation Service Level II Soil 

Survey 

Objective: Establish baseline conditions of soils within 1,000-meter radius of all planned gravel 

infrastructure. This may be accomplished within the first year after the start of construction.

Requirement/Standard: The permittee shall conduct a soil survey that meets the requirements of the 

Alaska Natural Resources Conservation Service Level II soil survey (including ecological site 

description). The soil survey will extend for a 1,000-meter radius from all planned gravel 

infrastructure and will be accomplished prior to construction activities. 

Potential Benefits and Residual/Unavoidable Impacts: Establishing baseline conditions will allow the 

BLM to monitor changes to the soil profile and vegetation as a result of airborne soil movement 

resulting from industrial activity. Addition of loess material will affect albedo resulting in increased 

active layer depth. It may also affect the vegetative community composition over time. This data will 

help delineate changes based on development activities from general change from warming 

temperatures. The data will help improve future engineering, design and permitting decisions thus 

mitigating future impacts.

4.2.1.2 Geology and Mineral Resources

The primary geologic resources impacted by the project during construction would be gravel resources 

and petroleum resources. Drilling oil production wells at the GMT2 production pad would directly impact 

the physical integrity of reservoir and overlying bedrock by pulverization and fracture. Impacts to 

petroleum geology would occur primarily from extraction of petroleum hydrocarbon resources which is 

the purpose of the proposed project. 

This would constitute a loss of the committed resources, but result in beneficial economic impacts. A 

minor amount of bedrock would be disturbed and relocated to the surface during drilling. However, the 

volume of rock impacted by drilling is inconsequential compared to the total volume of bedrock in the 

project study area. Annular disposal and injection of fluids could have impacts on subsurface geology; 

however, regulations and permits control both types of activities, minimizing potential adverse effects. In 

addition to the BLM, the Alaska Oil and Gas Conservation Commission has regulatory oversight of all oil 

and gas drilling, production, and well abandonment for the protection of oil and gas resources (20 AAC 

25.005–25.990).

Direct impacts to bedrock during construction would produce no measurable effect and are considered 

negligible under the action alternatives.

4.2.1.3 Petroleum Resources

Impacts to petroleum resources are expected to be major because GMT2 will result in the irreversible and 

irretrievable commitment of petroleum hydrocarbon resources. This is, however, the stated purpose for 

the project. Impacts to petroleum geology would be major across all action alternatives. Under the no 

action alternative there would be no impacts to petroleum resources.
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4.2.1.4 Sand and Gravel Resources

Sand and gravel resources in the project study area and the region are discussed in BLM (2004, Section

3.2.1.5), BLM (2008, Section 3.2.8) and BLM (2012, Section 3.2.9). The sand and gravel material sites 

identified within the project study area include the existing Arctic Slope Regional Corporation Mine site 

located east of the Colville River and the proposed Clover site on the west side of the river described in 

BLM (2004, page 160). The Arctic Slope Regional Corporation Mine site is the gravel source proposed 

for the GMT2 Project.

A general relationship of 1 acre disturbed for a gravel mine to meet the gravel needs for 5 acres of gravel 

pad, road, airstrip, or other development is identified in BLM (2012, Section 4.2.2, page 26). However, 

more specific information regarding the Arctic Slope Regional Corporation Mine site is available since it 

was recently used for CD5 and the Nuiqsut Spur Road. Based upon this information, 23 acres of the 

Arctic Slope Regional Corporation Mine site footprint is expected to be disturbed to provide gravel for 

the GMT2 Project. For specific anticipated gravel requirements for each alternative see Chapter 2 of this 

supplemental EIS, however, all action alternatives (Alternatives A, B, and C) require similar types of 

facilities (gravel pads and roads/air access facilities) with a similar gravel footprint. The striping and 

stockpiling of overburden will affect areas adjacent to the gravel mine until that area is reclaimed. There 

may be loss of permafrost below the mine in a thermal bulb that extends well beyond the mined acreage. 

Expansion of the pit is not solely based on the GMT2 project as it also supplies materials for many other 

projects in the area.

The area west of the Colville River is characterized by an apparent scarcity of suitable gravel for 

construction (BLM 2012, Section 3.2.9). On federally managed lands in the NPR-A, subsurface sand and 

gravel are owned by the federal government, and the Secretary of the Interior can dispose of these 

resources for use in permitted activities within the NPR-A, including energy production and development.

4.2.1.5 Paleontological Resources

The following is a discussion of potential environmental impacts for paleontological resources from the 

GMT2 Project alternatives. Actions related to the construction, drilling, operations and closure of the 

proposed GMT2 Project were analyzed for their potential for direct and indirect impacts to 

paleontological resources. This section details potential effects to paleontological resources based on the 

proposed alternatives as analyzed under NEPA regulations. For a discussion of paleontological resources 

in the GMT2 Project study area see Chapter 3, Section 3.2.1.6.

Methodology

This paleontological resources impacts analysis focused on determining potential project effects to 

verifiable remains, material evidence, and specific locations with items of paleontological importance. 

Data sources used to inventory project area paleontological resources include the Alaska Department of 

Natural Resources, Office of History and Archaeology, Alaska Heritage Resource Survey database 

(Alaska Department of Natural Resources, Office of History and Archaeology 2017). Recent 

paleontological resources surveys of the study area (Reanier 2009) also provide useful contextual 

information about sites in the project area.

For paleontological resources, direct affects typically occur due to ground disturbance during 

construction. Accordingly, the area of potential effect for direct effects to paleontological resources is 

limited to the proposed GMT2 Project footprint. This includes new permanent infrastructure (e.g., roads, 

airstrip, pads, and pipelines), existing infrastructure that will be used as part of the project, mining at the 

gravel source, and ice roads. Other activities and events that can directly impact paleontological resources 

might be in the vicinity of, rather than directly within, the project footprint. These can include damage 

caused by equipment during the construction, drilling, and operation phases of the project, and 
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unanticipated incidents such as blowouts, spills, or fires and subsequent cleanup activities. Drilling, 

operations, maintenance, and closure of facilities would result in minimal new ground disturbance, with 

less of a chance for subsequent direct impacts.

Typically indirect effects to paleontological resources occur through increased use effects. These can 

include illegal collection due to increased access to an area, subsidence, and erosion. The area of potential 

effect for indirect effects relating to access consists of a 2.5-mile buffer surrounding new GMT2 new 

infrastructure components, including roads, the airstrip, pads and pipelines. 

The expected level of impacts to paleontological resources will be based on levels of intensity, duration, 

geographic extent, context, and likelihood within direct and indirect areas.

Impact intensity can be described as low, moderate, or high. A low impact would involve a perceptible 

change to the resource’s condition while not noticeably altering its function or context. Medium intensity 

impacts would result in a measurable or observable change in the resource’s condition while being able to 

be mitigated. High intensity impacts would result in changes to a resource’s condition that are clearly and 

consistently measurable, resulting in the loss of integrity that is unable to be mitigated.

Impact duration can be described as temporary, interim, or long term. A temporary impact would be 

intermittent, infrequent, and of a limited duration, and resource function, context or integrity would be 

reduced for a limited period of time, typically less than two years or the amount of time required for 

project construction, and short-term mitigation would be expected to restore pre- activity levels. Interim 

duration impacts would be more extended yet finite, affecting resource integrity, function, or context 

during project operations, anticipated to be 30 years. Long term impacts to paleontological resources 

would cause a change in the resource that would perpetuate even if the actions that caused the impacts 

were to cease.

The geographical extents of impacts can be described as local, regional, or extended. A local impact 

would be geographically limited to discrete portions of the APE, and would neither extend to a broad 

region nor affect a resource of regional or statewide significance. Regional impacts would extend beyond 

a local APE, potentially affecting resources throughout study area or ACP region, and/or affecting a 

paleontological resource of regional significance. Extended impacts would range beyond the ACP region 

and/or affect paleontological resources with statewide or national significance.

Context, in this sense, refers to the importance of a paleontological resource at a local, regional, or 

national scale; contexts can be impacted can be described as common, important, or unique. A common 

context would be a resource considered usual or ordinary in the locality or region, is not locally scarce or 

rare, is not protected by state or federal legislation, and the affected context does not fill a distinctive role 

within the locality or the region. An important context would be protected by state or federal legislation 

and/or fills a distinctive role within the locality or the region. Unique contexts include paleontological 

properties that are protected by legislation and are rare, scarce or unique, either within the locality or the 

region, while filling distinctive roles within the locality or the region.

The likelihood of an impact occurring is characterized as no impact (i.e., impacts are unlikely), potential 

impact (i.e., an impact could occur within the project timeline, although it is uncertain), or probable 

impact (i.e., an impact to the resource is likely to occur within the project timeline).

For the GMT2 Project, direct impacts could occur in the project footprint during the construction and/or 

operation phase of the action. Examples of direct impacts to paleontological resources could include 

ground-disturbing activities that result in physical destruction of or damage to all or part of a 

paleontological resource, or removal or moving of the resource from its original location.
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Indirect impacts to paleontological resources for the GMT2 Project could occur away from the project 

infrastructure footprints within the 2.5-mile area of potential effect. Indirect impacts to paleontological 

resources could occur throughout the construction and operation phases of the project and during project 

closure. Examples of indirect impacts to paleontological resources in the analysis area could include 

removal, trampling, or dislocation of paleontological resources and sensitive areas by personnel and 

visitors; complete or partial destruction of a site from erosion, melting permafrost, subsidence, vibrations, 

or other landscape changes caused by new GMT2 infrastructure components; neglect of a resource that 

causes deterioration; and vandalism or the illegal collection of the resource.

Impacts Resulting from Alternative A

ConocoPhillips’s proposed GMT2 Project (Alternative A) includes a drill pad, a gravel access road 

(GMT1–GMT2 Access Road), and pipelines (Map 2.5-1). This section presents paleontological resource 

impacts by Alternative A and the analysis will only focus on potential site impacts due to infrastructural 

expansion under this alternative. As development under Alternative A overlaps with existing infrastructure 

relating to the village of Nuiqsut, the Alpine units (BLM 2004), and GMT1 (BLM 2014), this section will 

first delineate between (a) sites within the area of potential effects for Alternative A that may already be 

impacted by existing infrastructure, and (b) those sites that may be impacted by expansion under 

Alternative A. The resulting sites that may be potentially impacted due to expansion will then be assessed 

by expected effects due to construction, drilling, and operations under Alternative A.

Potentially Impacted Sites

No known sites reported in the Alaska Heritage Resources Survey are located within the Alternative A 

direct effects area of potential effect. Gravel for construction of Alternative A road and pads will come 

from the existing Arctic Slope Regional Corporation gravel mine which will not result in any new direct 

or indirect effects to paleontological resources.

The Alaska Heritage Resources Survey indicates five paleontological sites within the 2.5-mile indirect 

effects area of potential effect. Two of these sites (HAR-00057 and HAR-00170) have been totally 

removed by excavation and cannot, therefore, be impacted by development in support of GMT2 

Alternative A. Nuiqsut currently provides easier access to HAR-00031 than any development relating to 

Alternative A would, so Alternative A will not provide any easier access to this site. Site HAR-00066,

which falls just along the 2.5-mile margin for GMT2 Project, is already in the vicinity of existing 

development areas for the Alpine units (BLM 2004) and GMT1 (BLM 2014) that overlap with Alternative 

A, so development relating to Alternative A will have no effect on accessibility to this site.

Site HAR-00067 could potentially be impacted by increased accessibility due to Alternative A. The site, 

which is located within a 0.25 mile of the southern GMT2 ice roads, is reportedly an intact deposit of bird 

and small mammal remains of an unknown age, thought to be from a former carnivore den.

Construction

The potential for the discovery of unanticipated paleontological deposits during construction activities 

exists within proposed disturbance areas and could result in direct effects. Unanticipated discoveries 

could result in displacement or loss—either complete or partial—of paleontological material. Such 

disturbance affects the potential to understand the context of the site and limits the ability to extrapolate 

data regarding prehistoric biology and ecology. Given the number of previous surveys conducted in the 

study area, the relatively few number of paleontological resources documented, and the low probability of 

the construction footprint areas for containing shallow-buried paleontological resources, impacts from 

unanticipated discoveries are considered unlikely.
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In terms of site HAR-00067 within the vicinity of the ice road, any impacts that alter accessibility will be 

a seasonal, winter, occurrence that is dependent on suitable conditions for constructing and maintaining 

the ice road. It can be expected that these snow-covered and frozen conditions will hinder surface 

visibility and soil erodibility and penetrability, thus limiting the likelihood of illegal collection, 

subsidence, and erosion due to increased access to an area. Construction activities for Alternative A would 

cause a low intensity, temporary, and local impact. 

Drilling

Direct or indirect effects to undocumented and/or buried paleontological resources would be associated 

with those identified for the construction phase outlined above. Other components of the drilling phase for 

Alternative A (e.g., mobilization, moving, and demobilization of drilling equipment) are not expected to 

affect paleontological resources because they are temporary in duration and would occur within areas that 

have been previously disturbed during construction. 

In terms of site HAR-00067 within the vicinity of the ice road, any impacts will be limited only to the 

construction phase of Alternative A.

Operations

Drilling is expected to proceed year-round for approximately 7 years, with operations continuing for an 

estimated 23 years post drilling. No major ground-disturbing activities are associated with the operations 

phase of Alternative A. The potential for spills would still exist, but this is a low probability. During 

operations, spills of hydrocarbons or toxic materials could disturb or contaminate the surface of shallowly 

buried unidentified paleontological resources; however, given the large amount of survey coverage and 

absence of known Alaska Heritage Resources Survey sites in the direct and indirect effects study areas, 

this is a remote possibility. 

In terms of site HAR-00067 within the vicinity of the ice road, any impacts will be limited only to the 

construction phase of Alternative A.

Impacts Resulting from Alternatives B and C

Although there are several differences in construction between Alternatives A and C, and routing between 

Alternatives A and B, there is no change of potential impacts to known paleontological resources in the 

2.5-mile area of potential effect between alternatives. 

Impacts Resulting from Alternative D: No Action

Under Alternative D, the GMT2 Project and associated infrastructure would not be permitted, leaving the 

current uses of the land in the project area unchanged. No ground-disturbing activities associated with the 

proposed project would occur and there would be no concomitant adverse effects to known 

paleontological sites located in the study area. Therefore, no adverse effects or impacts to paleontological 

resources are anticipated under Alternative D. 

Mitigation 

Use of practical and reasonable mitigation measures would reduce impacts to paleontological resources 

from implementation of the proposed action and alternatives. Specific measures to protect paleontological 

resources can be implemented by best management practices. The implementation of best management 

practices and potential mitigation measures that were described in the NPR-A Integrated Activity Plan

Record of Decision for the protection of paleontological resources could also reduce the cumulative 

effects to paleontological resource from oil and gas, and non-oil and gas activities in the GMT2 Project 
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area. Potential impacts to paleontological resources from the GMT2 Project can also be mitigated by 

design, construction procedures, and operational features.

Avoidance and Minimization

BMP E-13 from the NPR-A Integrated Activity Plan Record of Decision states that “Lessees shall conduct 

a cultural and paleontological resources survey prior to any ground-disturbing activity including ice roads. 

Upon finding any potential cultural or paleontological resource, the lessee or their designated 

representative shall notify the authorized officer and suspend all operations in the immediate area of such 

discovery until written authorization to proceed is issued by the authorized officer” (BLM 2013). See 

Appendix J for further information. 

Conclusion

Direct impacts to paleontological resources are uniform across the three action alternatives. Under each 

alternative, no paleontological sites are known to exist in the direct footprint. Under Alternatives A, B, 

and C, only one known site (HAR-00067) could potentially be impacted by the ice road construction, as 

the road passes within 0.25 mile of this site. However, by each alternative, the increased access to this 

location will be temporary and minimal, lasting for only two winters and then being removed thereafter. 

Further, the snow-covered and frozen conditions will hinder surface visibility and soil erodibility and 

penetrability, thus limiting the likelihood of illegal collection, subsidence, and erosion due to increased 

access to an area.

4.2.1.6 Wildland Fire

This section describes the proposed action and project alternatives impacts to wildland fire in the project 

area. 

Alternatives A, B, and C

The area around the GMT2 Project is not prone to frequent wildfire. The risk of a loss of infrastructure 

from wildfire would increase because infrastructure would be added to an area with none. The risk of a 

human-caused fire would increase because people would be onsite during warm, dry weather conditions 

when the vegetation would be prone to wildfire. The effect would be difficult to measure as the fire 

history database has only two fires recorded, both in 2012, within a few miles of the proposed action.

Alternative D: No Action Alternative

A no-action alternative would not affect fire management in the project area.

4.2.2 Water Resources

The water resources evaluated in this section include the available quantity, quality, and use of 

groundwater and surface water (lakes/ponds, streams/rivers, estuaries, and near shore environments [Map 

4.2-1], and the hydrologic regime.

This analysis is an evaluation of the potential direct and indirect impacts to water resources within the 

project area. The potential project-related impacts on water resources were evaluated in BLM (2004a, 

Section 4F2.2) for the proposed activities in the project area. In addition, BLM (2012, Section 4.3.4) 

provides a recent and thorough update of the potential impacts of oil and gas development on water 

resources, as does the Point Thomson Final EIS (U.S. Army Corps of Engineers 2012a, Section 5.6).

Potential impacts to surface water quality are described in BLM (2012, Section 4.5.4.2) and BLM (2004a, 

Section 4F.2.2.2). Hydrology and surface water quality are closely linked, and the discussion regarding 
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potential impacts to water resources is combined in this section. Project development activities that have 

the potential to impact water resources include:

• Gravel mining

• Placement of gravel fill for infrastructure ( e.g., roads, pads, airstrip)

• Installation of culvert(s)

• Construction of pipeline

• Construction of ice roads and pads

• Extraction of water supply from local lakes (for ice roads, construction, drilling, and operation)

Potential impacts are generally categorized as follows (BLM 2004a, Section 4F.2.2):

• Shoreline disturbances and thermokarst

• Blockage or convergence of natural drainage

• Increased stages and velocities of floodwater

• Increased channel scour

• Increased bank erosion

• Increased sedimentation

• Increased potential for overbank flooding

• Removal or compaction of surface soils and gravel, and changes in recharge potential

• Produced-water spills

• Petroleum hydrocarbon spills

• Demand for water supply

Major areas of concern for surface water impact are described in BLM (2004a, Section 4F.2.2.2) and 

BLM (2012, Section 4.5.4.2).

Avoidance or reduction of potential impacts to water resources would be provided through siting and 

design and mitigation. Project activities that could impact water resources will be subject to federal, state, 

and local permit requirements, as well as additional BLM stipulations and best management practices. As 

a result, impacts to water resources are expected to be minor and within the range described in BLM 

(2004a).

4.2.2.1 Methodology

The methodology of analysis of impacts for water resources in these documents was adopted from the 

analysis performed in BLM (2004a and 2012) and U.S. Army Corps of Engineers (2012a). This 

methodology involves examining the type of impact expected to occur with GMT2, including changes to 

natural drainage patterns, stream water levels and streamflow, erosion or sedimentation, and lake levels 

and the duration of the impact. Hydrologic resources evaluated in this section include lakes, streams, and 

shallow groundwater which may provide hydrologic connections between lakes and streams. Surface 

waters (streams, lakes, and drainage basins) were identified using the National Hydrology Dataset and 

Watershed Boundary Dataset, at a nominal scale of 1:24,000-scale (U.S. Geological Survey 2015a). 

Impacts to hydrology and the existing hydrologic regime were evaluated by using the GMT2 Project area

and defined impact areas within the project area, consisting of the proposed infrastructure development. 

Impacts are evaluated qualitatively, and include an evaluation of short- and long-term potential impacts 

on water resources. Impacts were evaluated by reviewing those water resources within the proposed 

development footprint along with direct discharges and water withdrawals outside of the development 

footprint. Potential impacts to drainage that may be caused by the GMT1–GMT2 Access Road were 

evaluated using a snowmelt water equivalent inundation analysis.
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4.2.2.2 Construction

Several activities during construction have the potential to impact water resources. These activities are 

described below and include gravel mining, placement of gravel fill for infrastructure (e.g., roads, pads, 

airstrip), installation of culvert(s), construction of pipeline, and water supply extraction. Oil spills during 

construction could impact water resources and are addressed in Section 4.5.

Gravel Mining

The preferred source of gravel for the GMT2 Project is the existing Arctic Slope Regional Corporation 

Mine site. The footprint of impact would vary according to the gravel demand for each alternative.

Approximately 23, 26 and 32 acres will be disturbed as part of gravel extraction for Alternatives A, B and 

C, respectively.

During gravel mining, it is probable that shallow taliks and supra-permafrost water zones would be 

temporarily eliminated in the immediate vicinity of the gravel mine. However, the effect of this loss on 

water resources would be negligible, because the area of impact would be localized and supra-permafrost 

water zones would re-establish over time, after the mine pit fills with water. The subsurface water-bearing 

zone would be permanently eliminated in the immediate footprint of the mine, but would be replaced by 

surface water that is connected to the shallow groundwater.

Removal of gravel from areas near (or within) streams and lakes can result in changes to stream or lake 

configurations, stream-flow hydraulics, lake shoreline flow patterns, erosion, sedimentation, and ice 

damming (National Research Council [NRC] 2003). Gravel extraction could produce sedimentation as 

discussed in BLM (2012, Section 4.5.4.2, pages 12 and 13). The proposed gravel source, the Arctic Slope 

Regional Corporation Mine site, is located in the vicinity of the Colville River and several lakes. Gravel 

mining from the Arctic Slope Regional Corporation Mine site will be performed in accordance with 

relevant permits. No gravel will be extracted from streams or lakes within the NPR-A. 

Groundwater impacts associated with gravel mining are likely to be moderate to major, but limited in area 

and temporary, only extending for the period of use and rehabilitation. Long-term impacts of gravel 

extraction from the Arctic Slope Regional Corporation Mine site on the drainage pattern would be 

medium intensity and local extent. The water in the flooded pit would likely remain unfrozen near the 

bottom, altering the thermal regime, and creating a thaw bulb around and beneath the pit, potentially 

resulting in localized thermokarst. The steep side slopes of the excavation will likely slough as they thaw, 

becoming more gradual over time, and causing slight infilling. A reclamation plan is in place for the 

Arctic Slope Regional Corporation Mine site for the areas mined under Phase 1 and Phase 2. 

Construction of Infrastructure

Construction associated with the action alternatives (e.g., the placement and construction of gravel pads, 

roads, air access facilities, and culvert[s]) could affect natural drainage patterns (creation of new channels, 

inundation of dry area and starving wetlands on the downstream side of the road), stream stage (water 

level) and streamflow (volume), stream velocity (which influences erosion and sedimentation rates), 

groundwater flow, and lake levels. Modification of the natural surface water drainage patterns may result 

from blockage or redirection of flow. Disruption of streambeds and stream banks can also remove 

protective shoreline vegetation and lead to channel erosion and sedimentation, formation of meltwater 

gullies, plunge pools from perched culverts, and formation of alluvial fans in streams and lakes (BLM 

2012, 4.4.4.2, page 377). 

A few examples of construction activities that could impact hydrology include displacement of a lake or 

pond by fill or placing fill (such as for an airstrip or road) transversely across grade, thereby blocking the 
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natural drainage of sheet flow runoff, shallow groundwater, stream input, or rain catchment. Placing fill 

transversely across grade would also change snow accumulation patterns, which, in turn, would change 

drainage patterns once the snow melts. Placing fill transversely across grade or the predominant wind 

direction may also change snow accumulated patterns, which, in turn, may change drainage patterns once 

the snow melts. 

Impacts to drainage patterns may result in increased inundation (flooding) or drying of affected areas. 

Increased inundation may in turn increase thermokarst action in the affected area.

Gravel fill on tundra could potentially change recharge potential, block natural drainage and change 

existing hydrologic regime; erosion of roads and pads could increase sedimentation into waterways. 

During construction, sediments and dust could be disturbed and deposited on snow and ice during the 

winter or on tundra and open water during the summer. The sediments and dust could be introduced into 

the water column, causing an increase in turbidity. Snow roads, ice roads, and ice pads are temporary 

structures and impacts, if any, are expected to be minor and short-term. Details related to erosion and 

sedimentation during the construction phase is provided in BLM (2004a, Section 4F.2.2.2). 

Where gravel fill is placed in wet areas to construct a road, pad, or airstrip, the receiving waters could 

temporarily have higher suspended solids concentrations and greater turbidity. 

A road or airstrip aligned perpendicular to stream channels and the direction of sheet flow have a greater 

potential to impound sheet flow and shallow groundwater, than a road or airstrip aligned generally 

parallel to existing drainage patterns. The 8.2-mile GMT1–GMT2 Access Road (Alternative A) 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 (Map 4.2-2). The 9.3-mile 

GMT1–GMT2 Access Road (Alternative B) is routed along the hydraulic divide between the 

Tiŋmiaqsiġvik (Ublutuoch) River hydrologic drainage basin and the Outlet Fish Creek hydrologic 

drainage basin (Map 4.2-3). Both roads are parallel to the predominate northeast surface water gradient 

for both of these hydrologic basins. Both roads avoid crossing any of the larger primary creeks or rivers 

within these drainage basins and they are not situated in lowlands potentially prone to flooding such as in 

the Colville River Delta. The Alternative A route includes a culvert crossing over the small unnamed 

beaded stream pool outlet draining from Lake M9925. The road route transverses 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 potentially 

could result in localized increased inundation (flooding) upgradient of the road, and decreased inundation 

downgradient of the road as discussed in BLM (2012, Section 4.3.4). 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. In Alternative 

C, the airstrip and Airstrip Access Road are predominantly situated directly upon the local high ground 

between the two adjoining hydrologic drainage basins with minimal potential for localized cross-gradient 

flow impoundment and inundation. Prolonged inundation could impact ground cover and result in 

thermokarst.

A direct impact from winter road and pipeline construction is the potential disturbance of tundra soils and 

vegetation (Sections 4.2.1 and 4.3.1, respectively). Disturbed and exposed soils are more susceptible to 

erosion and subsequent sedimentation during spring breakup than non-impacted areas. Fugitive dust from 

construction can also be deposited on snow and ice during the winter. Further information regarding 

turbidity during the construction phase is provided in BLM (2004a, Section 4F.2.2.2). 

The proposed pad(s), airstrip, and road (depending on alternative) have been designed to account for 

thermal criteria (minimum thickness to prevent permafrost degradation) and hydrologic criteria for 

minimal impact to the surrounding tundra. However, the construction of permanent gravel roads and pads 
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will compact underlying soil, potentially impact thaw depths, and reduce infiltration. Locally, this may 

result in inundation of previously dry areas during breakup, changes in stream flow, and potential lake 

recharge. The configuration of gravel fill also affects impacts. For example, a linear road running 

perpendicular to the hydraulic gradient will result in a larger extent of hydrological impacts than a 

consolidated, square pad of similar acreage. The duration of impacts will be long term because the roads 

and pads will remain during the period of operation. 

Increased or decreased stream velocities could result in increased erosion or sedimentation. Flow 

constrictions such as through culverts would most likely lead to increased stream velocity, which may 

increase erosion. Similarly, flow blockages or other obstructions can lead to decreased velocity, 

potentially resulting in inundation and potentially increased sedimentation. Diversions may also affect 

erosion and sedimentation. The impacts that could be caused by the construction and continued presence 

of a road (through the project life) are addressed together in this section.

Potential impacts to drainage that may be caused by the GMT2 proposed infrastructure for each 

alternative were evaluated using a snowmelt water equivalent inundation analysis. This assumes the 

greatest runoff occurs during the spring breakup process. For Alternatives A and B, the GTM1-GMT2 

Access Road and pad were analyzed (Maps 4.2-2 and 4.2-3). The airstrip, gravel pad, and Airstrip Access 

Road were analyzed for Alternative C (Map 4.2-4). In the analysis (modeling), snowmelt hydrographs 

were used to estimate the maximum headwater depth and associated area of inundation using the 

following methodology. 

An estimate of the amount of water contained within a snowpack, the snow water equivalent was 

determined by reviewing measurements of snow studies in the NPR-A and East of Colville River Delta in 

2011 (Michael Baker Jr. Inc. 2015). The average snow depth in 2011 was estimated to be equivalent to a 

2-year recurrence interval (Q2) based on comparisons to historical snow depth measurements and 

regional regression equations. An average value of 4 inches was used to represent the amount of snow 

water equivalent on the surface of the contributing basins at the beginning of the snowmelt runoff. This 

value is assumed to be consistent over the entire contributing basin. To account for losses due to lakes, 

ponds and tundra, a factor of 0.67 is applied to the snow water equivalent, resulting in a total runoff depth 

of 2.68 inches.

The overland flow areas intercepted by the road and pad were delineated using U.S. Geological Survey 

HUC 12 boundaries and contour lines extracted from the National Elevation Dataset (U.S. Geological 

Survey 2015b). For Alternative A, three basins were identified along the road and pad. The basin located 

closest to GMT1 was subsequently delineated into three subbasins so that inundation along the road could 

be modeled effectively. For Alternative B, seven basins were identified, with two subbasins. Because the 

southern routes for Alternatives A and B were identical, Basin A-3 was identical to Basin B-7. For 

Alternative C, two basins contribute runoff to the airstrip, gravel pads, and Airstrip Access Road. The area 

of each basin and subbasin is multiplied by the effective snow water equivalent of 2.68 inches to estimate 

the volume of runoff that will reach the infrastructure. 

To estimate the time it takes for the snow to melt, the average number of days of snowmelt runoff is 

estimated by analyzing hydrograph data from U.S. Geological Survey stream gage 15798700 (Nunavak C 

NR Utqiagvik [formerly Barrow] AK), which is located approximately 120 miles west of GMT2. The 

gage’s historical data indicate that typical duration of snowmelt runoff is 7 days in the region, with a peak 

occurring at approximately 3.5 days after the start of runoff. It is assumed that the duration of snowmelt 

runoff at the U.S. Geological Survey gage is applicable to conditions along the GMT2 Road. To provide a 

conservative estimate for this analysis, the duration of snowmelt runoff was condensed to a 5-day period 

with peak flow conditions occurring 2.5 days after the start of runoff. 
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The volume of runoff in each basin is assumed to melt over the 5-day period with equal time and a steady 

pace on both the rising and falling limb with the peak at occurring at 2.5 days. This results in a 

hydrograph with discharge as the y-axes and time as the x-axis with the area under the triangle being 

equal to the volume of snowmelt runoff. A summary of the estimates are shown in Table 71 for 

Alternative A and Table 73 for Alternative B.

Table 71. Summary of discharge estimates for Alternative A

Basin Subbasin Peak Inflow (cfs) Runoff Volume (cubic feet)

A-1 A-1-1 53.5 11,550,000

A-1-2 38.7 8,366,000

A-1-3 23.8 5,146,000

A-2 -- 20.4 4,397,000

A-3 -- 4.6 992,300

Note: (--) cells indicate that no subbasin was identified as part of impact analysis.

For the conveyance of runoff under the road, culverts are assumed to be 2 feet in diameter and spaced at 

1,000 foot intervals. The hydrographs for each basin are modeled through the culverts using PondPack, a 

detention pond analysis and design software. Results of the analyses for Alternatives A and B are 

summarized in Table 71 and Table 74. 

For Alternative C, the same methodology was followed with the exception of modeling conveyance by 

culverts, which are not included in the airstrip design. The expected inundation at the airstrip, gravel pad, 

and Airstrip Access Road was determined by estimating the volume of runoff for each basin. The 

elevation of the inundation is determined by creating area-elevation and elevation-volume curves for each 

basin and determining the elevation that corresponds to the volume of snowmelt. Two basins contribute 

flow to the infrastructure with Alternative C. The basins are generally small due to the proposed location 

of the infrastructure on local high ground. Results of the inundation analysis for Alternative C are shown 

in Table 75. 

Table 72. Potential altered inundation area by new infrastructure for Alternative A

Basin Subbasin

Peak 

Inflow

(cfs)

Peak 

Outflow

(cfs)

Contributing

Basin Area 

(acres)

Area of Potential

Increased Stage 

(ponding) Upstream

of Gravel

Infrastructure

(acres)

Area of Potential

Decreased Stage

(Drying) Downstream

of Gravel

Infrastructure

(acres)

A-1

A-1-1 53.5 16.1 1,187 33.3 14.2

A-1-2 38.7 15.5 860 44.5 7.7

A-1-3 23.8 14.1 529 69.7 20.9

A-2 -- 20.4 15.6 452 20.2 29.3

A-3 -- 4.6 4.5 102 10.9 11.3

Totals: 3,130 178.6 83.4

Note: (--) cells indicate that no subbasin was identified as part of impact analysis
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Table 73. Summary of discharge estimates for Alternative B

Basin Subbasin Peak Inflow (cfs) Runoff Volume (cubic feet)

B-1 -- 5.7 1,224,000

B-2 -- 3.7 788,100

B-3 -- 0.5 114,700

B-4 -- 2.6 551.100

B-5 -- 0.3 72,100

B-6 B-6A 3.9 848,200

B-6B 22.7 4,903,600

B-7 -- 4.6 992,300

Note: (--) cells indicate that no subbasin was identified as part of impact analysis.

Table 74. Potential altered inundation area by new infrastructure for Alternative B

Basin Subbasins

Peak

Inflow

(cfs) 

Peak

Outflow

(cfs) 

Contributing

Basin Area

(acres)

Area of Potential

Increased Stage 

(ponding) Upstream of 

Gravel

Infrastructure (acres)

Area of Potential

Decreased Stage (drying) 

Downstream of Gravel 

Infrastructure (acres)

B-1 -- 5.7 4.2 126 10.0 11.9

B-2 -- 3.7 2.2 81 4.6 12.6

B-3 -- 0.5 0.5 12 0.1 2.8

B-4 -- 2.6 2.0 57 3.1 8.8

B-5 -- 0.3 0.3 7 0.8 2.5

B-6

B-6A 3.9 2.2 87 18.2 15.9

B-6B 22.7 17.3 504 20.2 30.3

B-7 -- 4.6 4.5 102 10.9 11.3

Totals 976 67.9 96.1

Note: (--) cells indicate that no subbasin was identified as part of impact analysis.

Table 75. Potential altered inundation area by new infrastructure for Alternative C

Basin

Contributing 

Basin Area

(acres)

Area of Potential Increased Stage 

(ponding) Upstream of Gravel 

Infrastructure

(acres)

Area of Potential Decreased State 

(drying) Downstream of Gravel 

Infrastructure a

(acres)

C1-2 40 21.1 55.3

C1-3 56 33.8 60.2

The extent of downstream indirect impacts for Alternatives A and B were calculated by assuming a typical 

hydraulic expansion angle of 3:1 from each culvert and spacing between culverts of 1,000 feet. The 3:1 

ratio results in a downstream impact zone of 167 feet. In this zone, the area directly downstream of the 

culvert would potentially be inundated with flow while the area between culverts, downstream of the road 

embankment, would receive less flow and be somewhat drier. The extent of downstream indirect impacts 

for Alternative C was estimated by assuming an area equal to the length of the infrastructure multiplied by 
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a downstream projection of 500 feet. It is not possible to determine an amount or percentage of how much 

wetter or drier the areas would be without a detailed modeling exercise.

Based on these methods and assumptions, the potential upstream inundation area for Alternative A was 

calculated to be approximately 178.6 acres (Table 72) as shown on Map 4.2-2. Alternative B was 

calculated to be approximately 67.9 acres (Table 74) as shown on Map 4.2-3. The potential upstream 

inundation area for Alternative C was calculated to be approximately 54.9 acres (Table 75) as shown on 

Map 4.2-4. These values are considered typical potential inundation scenarios for the purpose of 

comparing the infrastructure alternatives under typical conditions.

Pipeline construction within the project area could have minor impacts on water resources related to the 

ice road construction and associated water withdrawals from local lakes. Narrow drainages would be 

crossed using elevated pipelines on suspension spans. Pipelines would be routed to avoid lakes. Once 

installed, above-ground pipelines would have no impact on water flow characteristics, but would have the 

potential to impact water resources in the event of an oil spill. The proposed GMT1–GMT2 Access Road 

(Alternative A) is orientated west and northwest of the pipeline route which would allow the road to act as 

a barrier to protect water in the event of a potential pipeline spill where the road is downgradient of the 

pipeline (generally eastern half of the GMT1–GMT2 Access Road (see Map 4.2-2).

Buried pipelines are not included in the project designs for the GMT2 to GMT1 pipeline segment. 

However, there are existing buried road crossings as part of the CD5 to CD4N pipeline segment, and a 

new 20-inch produced fluid pipeline would be installed on this existing pipeline system as part of GMT2. 

The three existing pipeline road crossing locations have crossing casings to allow for installation of new 

pipelines without significant ground disturbance as noted in Appendix A, Sheets 28 and 29.

Water Withdrawal and Ice Road Construction

Water withdrawal to support components of each alternative (e.g., winter ice roads and camp water use) 

could affect the water levels of lakes used as water sources, and any connected, such as streams or 

wetlands. Only permitted lakes, rivers, or reservoirs (under Alaska Department of Natural Resources

Temporary Water Use Authorizations and if required, Alaska Department of Fish and Game Fish Habitat 

Permits) would serve as water sources. Excessive water withdrawal could result in a reduction of volume 

and change in water quality (e.g., dissolved oxygen). Water withdrawals under permitted conditions could 

result in minor, temporary impacts to groundwater levels (shallow or deep), surface water levels, or 

drainage patterns associated with groundwater withdrawals during the summer season. Lakes would be 

the principal supply for fresh water during construction. Details about water demand for each alternative 

are provided in Appendix B.

Ice roads and ice pads would be used extensively during the winter season for access. Under all of the 

alternatives, no long-term impacts are anticipated from ice roads, ice pads, or ice bridges as discussed in

BLM (2012, Section 4.5.4.2, pages 12–13).

Ice road construction over lakes that do not freeze to the bottom could affect dissolved oxygen

concentrations. An ice road across such an intermediate-depth lake could freeze the entire water column 

below the road, isolating portions of the lake basin and restricting circulation. With mixing thus reduced, 

isolated water pools with low oxygen could result. Details related to dissolved oxygen concentrations 

during ice road construction are provided in BLM (2004a, Section 4F.2.2.2).

Ice roads built over creek and river crossings have the potential to restrict fish passage, resulting in 

mortality or redirection of fish. Water withdrawal and ice roads would support construction activities, and 

impact would therefore be temporary for all action alternatives. However, Alternative C requires annual 

ice roads to provide vehicle access to GMT2 throughout life of the project (see also Section 4.2.2.3, 
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“Drilling and Operation”). Under Alternative C, an annual ice road would be necessary for 33 years to 

support construction and drilling, with additional roads required annually through the period of operation. 

Treatment of surface water is required prior to use as a potable water source. A potable water treatment or 

domestic wastewater treatment system must undergo Alaska Department of Environmental Conservation

plan review and approval before use. Further information regarding drinking water sources during the 

construction phase is provided in BLM (2004a, Section 4F.2.2.2).

The discussion in BLM (2004a, Section 3.2.2.2) and BLM (2012, Section 3.2.10.2) regarding alkalinity 

and pH indicates that freshwater within the project area is only weakly buffered with low alkalinities in 

ponds and lakes. Details related to how construction, and domestic needs could affect water quality, and 

specifically alkalinity and pH is discussed in BLM (2004a, Section 4F.2.2.2).

During the construction phase, temporary camps would be used. It is expected that sewage and all solid 

waste would be transported to CD1 for disposal in existing systems. Discharges of treated domestic 

wastewater to tundra will not be needed for the GMT2 Project.This applies for all action alternatives and 

will not be analyzed further in this document.

No injection of wastes is proposed during the construction phase; any waste injection would be offsite, at 

a permitted UIC well, with associated impacts to the deep aquifer expected to be negligible to minor.

4.2.2.3 Drilling and Operation

Impacts to hydrology associated with construction of gravel pads, roads, and airstrip and ice roads would 

persist through the life of the project, including: natural drainage patterns, stream stage and streamflow, 

stream velocity, groundwater flow, and lake levels as described for the construction phase. The duration 

of impacts would be long-term because the gravel structures would remain during the period of operation.

Ice roads and ice pads would be used extensively for seasonal vehicle access for Alternative C; no postconstruction ice roads are required for Alternatives A and B. Ice roads may require breaching at stream 

crossings if fish passage is a concern during breakup. Under all of the alternatives, no long-term impacts 

are anticipated from ice roads, ice pads, or ice bridges as discussed in BLM (2012, Section 4.5.4.2, pages

12–13).

The Alternative A route crosses a small, unnamed, beaded-stream-pool outlet draining from Lake M9925. 

There are no additional new stream or river crossings proposed for the GMT2 Project, although smaller, 

periodic drainages may be crossed. These smaller drainages are not well defined in the area. There are no 

known areas affected by the proposed GMT2 Project infrastructure where channelized flow occurs with a 

50-year reoccurrence interval of 500 cubic feet per second or greater (see BLM 2004a, Section 2.3.9.1). 

No bridges would be required.

Culverts are considered appropriate for GMT1–GMT2 Access Road water crossings. The design criteria 

for all culverts is such that they will prevent raising the water level on the upstream side of the crossings 

by more than 6 inches (compared to the down gradient side) for more than 1 week after peak discharge. 

Culverts will be installed at regularly spaced intervals to mitigate the risk of sheet flow interruption and 

thermokarst action. Final design of the culverts for the GMT1–GMT2 Access Road will also depend on 

breakup characteristics for those drainages that could affect the roads (BLM 2004a, Section 4F.2.2.1). At 

this time, such crossings are not expected to present technical challenges beyond what is currently 

practiced for the region.

For preliminary permit drawings, only the more evident culvert locations will be identified from aerial 

photographs. During the preliminary road alignment, a field reconnaissance will be conducted to identify 

and mark as many obvious culvert locations as possible. With the combined ground survey of the road 

alignment, collected field data, and aerial photography, cross-drainage culverts will be identified and 
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placed in the design drawings. After the road centerline has been staked, a final field visit will be 

conducted and additional cross-drainage culverts will be located as required. Thus far, detailed 

information regarding culvert placement and design has not yet been gathered, but will be accomplished 

during final road alignment. In conjunction with culverts placed in specific drainage locations, crossdrainage culverts will be placed under the road approximately every 500 to 1,000 feet. Cross-drainage 

culverts may be up to 48 inches in diameter, but are typically 24 inches in diameter (BLM 2004a, Section

2.3.9.1).

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

BLM (2004a, 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. These potential impacts need to be minimized by incorporating 

design features to protect the structural integrity of the road- and pipeline-crossing structures to 

accommodate all but the rarer flood events. The GMT1–GMT2 Access Road crosses relatively dry terrain 

with numerous small drainages and no major streams, only crossing a small, unnamed, beaded-streampool outlet draining from Lake M9925 (Alternative A only). Once installed, above-ground pipelines 

would have no effect on stream and water flow characteristics.

Water withdrawal to support components of each alternative could affect the water levels of lakes used as 

water sources, and any connected waterbody, such as streams or wetlands. Only permitted lakes, rivers, or 

reservoirs (under Alaska Department of Natural Resources Temporary Water Use Authorizations and if 

required, Alaska Department of Fish and Game Fish Habitat Permits) would serve as water sources. Water 

withdrawal in the summer from lakes could also result in a temporary lowering of the shallow 

groundwater in adjacent wetlands as the lakes recharge. The impacted area would be localized around the 

perimeter of the lakes. Lakes could supply fresh water for (1) the seasonal construction of ice roads and 

pads; (2) drilling; (3) hydrostatic testing; (4) dust abatement on roads, pads, and airstrips during summer; 

(5) potable water; and (6) fire suppression and maintenance activities.

Water use for Alternatives A and B would be approximately 395 million gallons each. For Alternative C, 

water withdrawals to support annual ice road construction would be necessary during drilling and 

throughout operations, resulting in a total estimated water use of 691 million gallons. A 2-inch water line 

would be constructed from CD1 to GMT2 in Alternative C. Details related to water withdrawal from 

lakes during the operation period is provided in BLM (2004a, Section 4F.2.2.2).

Drilling wastes (muds and cuttings) would be disposed of through annular disposal onsite and/or 

transported to an approved disposal well offsite. No GMT2 disposal well is planned.

As discussed in BLM (2004a, Section 4F.2.2.2), discharges to tundra of treated domestic wastewater in 

the drilling and operation period could occur in accordance with Alaska Pollutant Discharge Elimination 

System permit requirements. This applies to all the action alternatives.

As stated in BLM (2004a, Section 4F.2.2.2), the following changes to water quality may occur during the 

drilling and operations phase of the project:

• Increased turbidity of waterbodies in the project area may result from dust fallout, flooding, erosion, 

or bank failure.

• Water withdrawals for drilling and/or operations may have short-term (lasting only one season) 

impacts on alkalinity, pH, or oxygen content in the water source. Typically water for drilling and 

operations will be provided by CD1, using permitted sources.
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• Only treated (secondary treatment) domestic wastewater would be discharged to 

waterbodies/wetlands in the project area; and therefore, it is not anticipated that there would be an 

increase in fecal coliform counts over the naturally occurring concentrations.

• Pipelines on vertical support members over streams and drainages should have no effect on stream 

habitat and flow characteristics provided these are elevated sufficiently to avoid flooding (BLM 2012, 

Section 4.3.7.2, page 154). Pipelines will be installed 7 feet above tundra, which should provide 

sufficient clearance from stream flow.

Oil spills could occur from pipelines; storage tanks; production facilities/infrastructure; drill rigs; and 

vehicles during drilling and operation phase. Spills occurring from pipelines or leaving pads and roadbeds 

could enter water sources reaching tundra ponds, lakes, creeks, or rivers.

Spills can occur at any time during the year. The potential impacts from oil spills are described in BLM 

(2012, Section 4.3.4.2) and in Section 4.5 of this document.

4.2.2.4 Comparison of Alternatives

A major difference between the action alternatives is proposed access (i.e., with or without the GMT1–

GMT2 Access Road). In general, the GMT1–GMT2 Access Road (Alternatives A and B) could cause 

direct impacts to hydrology and water resources. Alternative C impacts would be more focused around 

GMT2 pad and air access facilities. The Alternative A route includes a culvert crossing over the small,

unnamed, beaded-stream-pool outlet draining from Lake M9925. There are no major stream or river 

crossings proposed under any of the alternatives.

The impacts to drainage basins under Alternative C would be less than those for Alternatives A and B. 

The 0.9-mile gravel access road (Alternative C) that would be constructed from GMT2 pad to the 

occupied structure pad and air access facilities would be relatively short and, for the most part, situated on 

topographically higher ground. It does not traverse any major drainages and would therefore, cause 

relatively minor impacts to the drainage patterns and associated ephemeral stream or sheet flow. To the 

extent there are impacts to drainage patterns, they would be localized. 

For Alternatives A and B, culverts are considered at all water crossings. Alternatives A and B would 

potentially require an estimated 46 culverts and 50 culverts, respectively (Table 76). Alternative C would 

have a 0.9-mile Airstrip Access Road, which could require an estimated five culverts. Discussion of water 

crossings is included in Section 4.2.2.3.

In Alternatives A and B, year-round vehicle traffic (described in Section 2.5.4.2) along the GMT1–GMT2

Access Road would cause impacts resulting from gravel spray/dust deposition onto adjacent waterbodies. 

There would be some road gravel spray/dust deposition associated with Alternative C, but it would be less 

because the areas available for vehicle traffic are less and traffic would travel slower than along the major 

GMT1–GMT2 Access Road. There would be gravel spray/dust generated by aircraft during takeoff and 

landing at the GMT2 airstrip (as well as the airstrip of origin, if unpaved).

Alternative C would require more years of major access ice roads than Alternatives A and B. Ice roads 

would be constructed within the same general footprint each year and impacts may be additive, although 

there is limited documentation of this occurring (U.S. Army Corps of Engineers 2012a, page 5–149), and 

a BLM best management practice is in place (C-2[e]) as a protective measure to reduce or avoid such 

impacts. The ice roads could the alter drainage during spring breakup because the ice would melt more 

slowly than the surrounding tundra and streams. Blockage of streamflow and increased stream stage could 

occur over more years with Alternative C.
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Under Alternatives A and B, no ice roads are planned during drilling and operations to support resupply 

and transport of heavy equipment for the project; however, it is possible that they may be required. 

Due to reliance on an ice road for access to GMT2, the degree of ice road construction and water usage 

for ice road construction, drilling and camp use is greater in Alternative C than in Alternatives A and B. 

There are also more ice road miles during the construction phase under Alternative C. Alternative C 

would require the most water withdrawal because this alternative requires the most years of project 

operation. Therefore, the impacts of ice roads under Alternative C could be greater and of longer duration 

compared to Alternative A.

Table 72 and Table 74 and Maps 4.2-2 and 4.2.3 show potentially altered inundation areas caused by the 

proposed GMT1–GMT2 Access Road and pads for Alternatives A and B. Table 75 and Map 4.2-4 show 

potentially altered inundation areas caused by the proposed 0.9-mile Airstrip Access Road connecting 

GMT2 pad and the occupied structure pad and air access facilities in Alternative C.

Alternative A potential upstream inundation area was calculated to be approximately 168.5 acres of 

upstream inundation across the tundra along the road route and approximately 78.2 acres of drying area 

downstream of the road. Potential upstream inundation areas for Alternative B was calculated to be 

approximately 52.3 acres of upstream inundation across the tundra along the road route and 

approximately 45.7 acres of drying area downstream of the road. Alternative C was calculated to be 54.9 

acres inundated; drying area was calculated to be 115.5 acres. These inundation areas are summarized in 

Table 76. 

Alternative A and B will result in impacts from gravel extraction of 671,300 and 747,300 cubic yards, 

respectively. Alternative C would result in impacts from gravel extraction of 930,000 cubic yards. While 

the levels of impacts are different due to the amount of gravel required for each alternative, the types of 

impacts are expected to be similar.

The remainder of this section addresses the specific impacts for each alternative and describes the level of 

impact on water resources for each alternative. Major project components with potential for hydrologic 

impact are shown for each alternative in Table 76. 

Table 76. Summary of major components potentially impacting hydrologya

Alternative

Total Gravel Fill 

Footprint 

(acres) b 

Total 

Length of 

New 

Roads 

(miles)

Estimated 

Number of 

Culverts c 

Area of Potential 

Increased Stage 

(ponding) Upstream 

of Gravel 

Infrastructure (acres)

Area of Potential 

Decreased Stage 

(drying) Downstream 

of Gravel 

Infrastructure (acres)

A 78.0 8.2 46 168.5 78.2

B 87.2 9.3 50 52.3 45.7

C 92.0 0.9 5 54.9 115.5

a All values are estimates subject to change in final design.

b Total gravel footprint acreage does not include 0.1 acre from the installation of new pipeline vertical support members between 

GMT2 and GMT1.

c Culvert would be installed along gravel roads to maintain surface flow. The number of potential culverts to be installed assumes 

one culvert per 1,000 linear feet of new road. More may be necessary for drainage depending on local conditions, and placement 

would be determined during road layout to coincide with low areas to maximize drainage.

Project activities under Alternative C that could impact the hydrologic regime are similar to Alternatives 

A and B, and include placement of gravel infrastructure for pads and access facilities, pipeline 

construction, gravel extraction, and water withdrawal from area lakes and reservoirs for construction of 

temporary ice infrastructure.
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The differences in the size, location, and construction of infrastructure among the action alternatives 

generally correlate with impacts. The stipulations and design requirements, described in Section 4.2.2.5, 

“Mitigation,” and more comprehensively (for all resources) in Section 4.7, “Mitigation Measures and 

Monitoring,” specify measures to protect natural flow characteristics and water quality.

As described in BLM (2004a, Section 4F.2.2.1), adequate monitoring and adherence to withdrawal 

regulations would limit potential impacts on lake water levels to short-term duration. Long-term (longer 

than 1 year) potential impacts on lake water levels are likely to be minor because natural annual recharge 

processes are sufficient to fully recharge the lakes each year BLM (2004a, Section 4F.2.2.1). Thus 

potential impacts on lake water levels would be short-term and low intensity.

All action alternatives have the potential for spills to water resources including tundra ponds, lakes, and 

creeks resulting from pipelines; storage tanks; production facilities/infrastructure; drill rigs; vehicles; 

and/or vessels. Because the location and length of oil transit pipelines under the action alternatives are 

similar, the potential risk to water resources from a pipeline spill is also expected to be similar. Alternative 

C would require a diesel pipeline to provide fuel to the GMT2 pad in addition to other pipelines, which 

would pose additional spill risk along the pipeline system.

However, we expect greater differences in the risk to the surrounding environment regarding spill 

response capabilities as discussed in Section 2.9.3. A portion of the Alternative A GMT1- GMT2 Access 

Road lies downgradient from the pipeline, and would act as a barrier to spill migration. The GMT1–

GMT2 Access Road would also be used for pipeline inspections and spill response. Because Alternative C 

is roadless and relies upon air support and yearly ice road construction for incident response, risks to 

water resources from an oil spill are increased throughout the life of the project. Spills are discussed 

further in Section 4.5.

For Alternative C, the 5,000-foot airstrip and associated GMT2 drill pad and occupied structure pad 

would not cross any major drainages or streams. The airstrip and pads would have minor impacts to the 

localized drainage pattern due to the acreage of impact. To minimize surface water runoff from 

precipitation and snow melt that could cause ponding adjacent to the gravel embankments, the gravel 

surface may need to be contoured to direct surface water runoff to the down-gradient edges of the pad. 

The width of the pads and airstrip are too large to traverse with culverting. If ponds develop, additional 

mitigation may be needed (e.g., route runoff along the edges of the airstrip). Over the compacted gravel 

surface there will be less infiltration of precipitation, however, this impact is expected to be localized and 

of low intensity.

Ice roads and pads could alter the drainage pattern during spring breakup because the ice would melt 

more slowly than the surrounding tundra and streams. Blockage of streamflow and increased stream stage 

could occur due to ice roads that are not adequately slotted or breached.

The types of impacts to lakes and ponds would be the same for Alternative C as discussed for Alternatives 

A and B. However, there would be considerably more water usage over the life of the project due to the 

annual ice roads required for Alternative C, as described in Section 4.2.2.3. Alternative C water usage 

would be almost twice as much than that of Alternatives A and B. The major difference occurs during 

operations, due to the annual requirement for an ice road in Alternative C. However adequate monitoring 

and adherence to water withdrawal regulations would limit potential impacts on lake water levels to 

minor and of short-term duration. In addition, Alternative C requires approximately 24 percent to 39

percent more gravel mined than Alternatives A and B, with associated increase in related impacts.

Potential water quality impacts under Alternative C could result from construction and operation of the 

project in a manner similar to Alternatives A and B. The primary difference is absence of the GMT1–

GMT2 Access Roads, which reduce the opportunity for associated water quality impacts (e.g., dust and 
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gravel spray). However, there would be a comparable amount of gravel discharged onto the tundra surface 

for construction of an airstrip and additional pad space for living quarters and storage (occupied structure 

pad), and there would be associated impacts (e.g., dust and gravel spray from aircraft landing/takeoff). 

The additional facilities required for project development under Alternative C would increase the required 

gravel footprint. Gravel transport from its source to its final location also has the potential for gravel 

spillage onto the frozen tundra, and if not thoroughly cleaned up, could result in an increase in turbidity 

when tundra wetlands and waterbodies thaw.

In comparison to Alternatives A and B, Alternative C may result in higher spill risk due to increased 

activity with aircraft operations, year-round living accommodations, and potential delayed spill response 

when air access is restricted during periods of adverse weather. Spills are discussed further in Section 4.5.

4.2.2.5 Mitigation

All roads would be designed and constructed to provide adequate cross flow to prevent raising the water 

level on the upstream side of roads by more than 6 inches compared to that for the downstream side for 

more than 1 week after peak discharge (BLM 2004a, Section 2.4.6.1, page 103). Potential impacts and 

associated mitigation measures for the proposed project are listed in Table 77.

Table 77. Summary of potential impact to water resources and mitigation measures a

Resource Activities Potential Impact Mitigation

Groundwater

and Shallow

Lakes

Construction of

the GMT2 gravel

pad and access

road

Compaction of surface soils or 

removal of gravels and changes in 

recharge potential

The GMT2 pad and access roads are 

designed to limit acreage of fill and to 

prevent changes in recharge

Groundwater Underground 

disposal (via

injection) of nonhazardous waste

Contamination of groundwater 

(note: groundwater is not typically 

a potable water source on the 

North Slope); change(s) of 

groundwater flow patterns.

Underground injection will be performed

in accordance with applicable permits to 

prevent impacts to groundwater resources

Lakes and

Ponds

Construction of

gravel access

road and ice roads a

Increased bank erosion and 

sedimentation

Gravel roads will have culverts installed to

maintain surface flow; gravel roads and

pads will have erosion control

mechanisms as well as Stormwater 

Pollution Prevention Plans in place for

construction and operations

Lakes and

Ponds

Construction and

use of road and

pads

Dust fallout on ice and snow

which melts in spring, or direct

fallout on waterbodies in summer,

resulting in increasing turbidity

Traffic and dust control measures for

roads and construction areas to avoid

impacts of dust on nearby waterbodies

Lakes Ice road

construction, 

camp use, and

drilling activities

Water withdrawals from lakes; 

impacts to fish

Water withdrawn only from permitted

lakes, with only permitted amount of

water withdrawn, using methods required

by permit

Streams Construction of

the gravel access

road, pipeline, and

culverts

Blockage of natural drainage 

(channels and sheet flow); 

increased stages and velocities of 

floodwater, channel scour, bank 

erosion, sedimentation, and 

potential for over-bank flooding

Road, pipeline, and water crossings will

be designed to maintain existing

hydrology including during flood periods;

gravel roads and culverts, will be

designed to have erosion control

mechanisms and will follow the Alpine 

Processing Facility Erosion Control Plan

Streams Construction of ice

roads

Blockage of natural drainage and 

increased floodwaters

Ice bridges across rivers will be removed, 

slotted, or scored prior to spring breakup

a No gravel GMT1–GMT2 Access Road in Alternative C.
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Specific measures to protect water resources are provided in BLM (2008a and 2013a: A-1 through A-7, 

B-1, B-2, C-2, C-3, C-4, E-2, E-3, E-4, E-6, E-8, K-1, and K-2). For example, impacts to water resources 

will be mitigated by:

• BMP A-6: Requires all cuttings and drilling mud to be disposed of by injection, allowing on-pad 

temporary storage of muds and cuttings, as approved by the Alaska Department of Environmental 

Conservation. Freshwater aquifers are protected by surface casing installed and cemented in place at

varying depths. The EPA establishes aquifer exemption depths for certain disposal well classes. The 

BLM and Alaska Oil and Gas Conservation Commission both authorize casing setting depths for 

protection of fresh water aquifers on federal leases.

• BMP B-2: Provides standards for water and ice removal from lakes.

• BMP C-2: Provides standards for cross country travel (e.g., snow trails, ice roads, seismic activity).

• BMP E-2: Prohibits construction camps from being placed on frozen lakes or water ice.

• BMP E-6: Requires that stream and marsh crossings be designed and constructed to ensure free 

passage of fish, reduce erosion, maintain natural drainage, and minimize adverse impacts to natural 

stream flow.

• Lease Stipulation E-2: Requires that permanent oil and gas facilities and infrastructure be more than 

500 feet from lakes, with essential pipeline and road crossings evaluated on a case-by-case basis; 

limits pipelines within 500 feet of fish-bearing waters and crossing of lakes; restricts discharge of 

pollutants from vehicle and equipment use, personnel camps, and produced fluids. Note: The BLM 

authorized a deviation from this stipulation (BLM 2004b).

• Lease Stipulation K-1: Establishes setbacks from major rivers, including Fish Creek, Tiŋmiaqsiġvik 

(Ublutuoch River), and the Colville River in the project area, with exceptions for essential road and 

pipeline crossings allowed. Note: The BLM authorized a deviation from this stipulation (BLM 

2004b).

• Lease Stipulation K-2: Establishes a 0.25-mile development setback from deep water lakes, defined 

as those greater than 13 feet, except essential road and pipeline crossings considered on a case-bycase basis.

With adherence to best management practices, permit requirements, and lease stipulations, impacts to 

water resources are possible, but likely to be localized in extent and temporary in duration.

In addition to BLM lease stipulations and best management practices, project activities that could impact 

water resources will be subject to federal, state, and local permit requirements, which provide additional 

resource protections. In particular, the U.S. Army Corps of Engineers has an obligation under the Clean 

Water Act (Section 404(b)(1) guidelines) to focus on impacts to the “aquatic ecosystem.”

4.2.2.6 Conclusions

The likelihood of impacts to the water resources identified in this analysis can be separated into 

reasonably foreseeable and potential (Table 78). No evaluated effects were determined to have impacts.
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Table 78. Likelihood of impacts; water resources

Reasonably Foreseeable Impacts Potential/Speculative Impacts

Temporary elimination of shallow taliks 

and supra-permafrost water zones in 

the immediate vicinity of the gravel

mine from mining activities

Contamination from spills.

Changes in water quality from ice road construction over lakes, streams,

and periodic drainages.

Changes to groundwater from gravel 

mining activities

Increased sedimentation and turbidity from mining activities, gravel fill on

tundra, and operation of vehicles on gravel infrastructure (roads, pads,

and airstrip).

Changes to natural drainage patterns, stream stage, streamflow, stream

velocity, groundwater flow, and lake water levels from placement and

construction of gravel infrastructure and culverts and changes in snow

accumulation patterns.

Changes in surface water levels and water quality, and related lowering

of nearby shallow groundwater, from water withdrawal

In general, all action alternatives have 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 short-term, temporary impacts from ice 

infrastructure (e.g., roads and pads). These impacts tend to be proportional to the amount of area impacted 

by infrastructure and the configuration of gravel placement, with modifications due to specific activities 

and locations. However, for all action alternatives the intensity of impacts would be minor and localized.

Potential surface water quality impacts may be categorized as follows, and discussed in BLM (2004a, 

Section 4F.2.2.2, pages 1092–1093):

• Accidental release of fuels and other substances

• Reductions in dissolved oxygen and changes in ion concentrations in lakes

• Increases in turbidity and suspended solids

Impacts on hydrology from Alternatives A and B would result primarily from construction of gravel 

infrastructure (e.g., roads and pads), which could modify drainage patterns and streamflow. These impacts 

would be long term, localized, and of low intensity. Ice roads and ice pads could seasonally affect natural 

drainage patterns and streamflow during spring breakup. However, this impact would be limited to the 

construction phase, and thus temporary. Water withdrawal for ice roads, drilling, and camp use has the 

potential to temporarily lower lake levels. The overall hydrological impacts of ice roads and the 

associated water usage is negligible; the impacts of roads and pads are characterized as minor due to the 

longer duration. Erosion and sedimentation associated with road and pad building could increase 

sedimentation into waterways. However, based on previous studies, no measurable effect on water quality 

is expected, as reported in MJM Research (2007d) and Michael Baker Jr. Inc. (2009b, 2010).

Because gravel fill construction would take place over winter when most waterbodies are frozen, impacts 

on water quality would be limited. Discharges of treated wastewater could occur to tundra in accordance 

with Alaska Pollutant Discharge Elimination System permit requirements, so it is not expected that there 

would be an increase in fecal coliform counts over the naturally occurring concentrations. As stated in 

BLM (2004a, Section 4F.2.2.2, page 1091), increased turbidity of waterbodies in the project area would 

result from dust fallout, flooding, erosion and sedimentation, or bank failure. It is not expected that 

alkalinity and pH of surface waterbodies would be affected beyond the snowmelt period. Adherence to 

federal and state operational guidelines and permit requirements, safety practices, planning requirements, 
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lease stipulations, and best management practices would all serve to reduce impacts from these activities. 

The overall degree of impact for Alternatives A and B to the hydrology and water quality is considered 

minor.

Impacts on hydrology from Alternative C would be of similar type as described for Alternatives A and B, 

but the intensity, duration, and geographic extent of impacts varies with the configuration of the gravel 

placement. In general, the impacts to the drainage pattern would be of a greater intensity, but would be 

more localized. Impacts on water level in lakes would be of similar magnitude as Alternatives A and B, 

but could occur for more seasons due to the annual withdrawals to support ice road construction. 

Alternative C would have a larger gravel footprint than Alternatives A and B and require more gravel 

mining, with an increased risk of gravel spillage in waterbodies, and an associated impact to water quality 

(e.g., increased turbidity). Greater use of lake water would increase the potential for dissolved oxygen

depletion at the source lake(s) if not carefully monitored. Dust fallout, erosion, and sedimentation could 

potentially affect the turbidity of smaller waterbodies in the vicinity of the airstrip and new infrastructure. 

Overall, Alternative C would have less impact than Alternatives A and B, but impacts to hydrology and 

water quality still considered minor.

Global climate change could have unpredictable impacts on winter temperatures, water balance, 

water availability, and timing and magnitude of spring floods (BLM 2012, Section 4.2.4.4). These 

changes could alter the impacts discussed for each alternative. A longer and warmer growing 

season could result in increased potential evapotranspiration reducing available water in lakes. 

Premature melting of ice roads could occur with sudden spring melts, requiring emergency 

demobilization in order to protect the tundra, and potentially leave less time for proper 

abandonment of ice bridges. Increased snowfall combined with late summer rainfall could 

increase the magnitude of spring peak flows above the normal range of flows, causing increased 

erosion and sedimentation. All alternatives under consideration would be affected, although 

impacts under Alternative C may be greater due to a greater reliance on ice roads for operation.

4.2.3 Atmospheric Environment

4.2.3.1 Climate and Meteorology

A potential contributor to changes in climate and meteorology is the impacts from changes in greenhouse 

gas emissions. Changes in greenhouse gas emissions, in recent decades, have been driven by 

anthropogenic forces. The concentrations of greenhouse gases in the atmosphere are chemically stable 

and can stay in the atmosphere for 10 to 100 years before chemically breaking down or being absorbed by 

the hydrosphere or vegetation. Significant research has shown a positive correlation between an increase 

in GHG emissions to the atmosphere and atmospheric temperature increases. GMT2 Project greenhouse 

gas emissions under all four proposed alternatives are tabulated below and summarized in the emission 

inventory reports submitted to the BLM (Kleinfelder and Ramboll Environ 2017a, 2017b, 2017c) except 

for Alternative D, the no-action alternative. Note that emissions of carbon dioxide equivalent (CO2e) 

account for certain pollutants global warming potentials. A global warming potential is a GHG’s potency

relative to carbon dioxide (CO2) taking into account residence time in the atmosphere. The global 

warming potential is a factor that is multiplied to a certain greenhouse gas pollutant’s emissions to 

determine the emissions of CO2e. The Federal Register has published a global warming potential factor 

for CO2 of 1, for methane (CH4) of 25, and for nitrous oxide (N2O) of 298.
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Table 79. Summary of greenhouse gas emissions for GMT2 Project alternatives in carbon dioxide equivalents 

(tons per year)

GMT2 Project Alternative

Year 1

(CO2e tons 

per year)

Year 2

(CO2e tons 

per year)

Year 3

(CO2e tons 

per year)

Year 4–10

(CO2e tons 

per year)

Year 11 on

(CO2e tons 

per year)

Alternative A 2,617 27,030 41,545 32,276 5,687

Alternative B 2,673 28,667 43,110 32,593 5,705

Alternative C 2,795 32,595 56,851 38,087 10,406

Alternative D 0 0 0 0 0

The project year of maximum GHG emissions under each of the alternatives is Year 3, where operations 

are primarily from construction and developmental drilling, and are temporary. Routine GHG emissions, 

shown in Year 11, from the GMT2 Project are an order of five to seven times lower and will have a 

smaller, less consistent impact. GHG emissions from the GMT2 Project are similar in magnitude to other 

projects in the area such as ConocoPhillips’s Greater Mooses Tooth 1 (GMT1) (BLM 2014) and 

Armstrong Energy LLC’s Nanushuk Project (SLR International Corporation 2017b). A detailed analysis 

of GMT2 Project impacts are discussed in Section 4.2.4, “Project Effects on Climate Change.”

4.2.3.2 Air Quality

The BLM Arctic District Office in Fairbanks, Alaska, published the Notice of Intent to prepare a 

Supplemental Environmental Impact Statement (EIS) for the GMT2 Project in July 2016 (BLM 2016). As 

air quality was one of the key areas identified by the BLM that will require analysis in the supplemental 

EIS, the BLM requested assistance with the air quality analysis. Under the June 23, 2011, Memorandum 

of Understanding between the U.S. Department of Agriculture, U.S. Department of the Interior (DOI), 

and EPA Regarding Air Quality Analyses and Mitigation for Federal Oil and Gas Decisions through the 

National Environmental Policy Act (NEPA). An air quality technical working group including the BLM, 

EPA, U.S. Fish and Wildlife Service (USFWS), National Park Service, U.S. Forest Service, and Alaska 

Department of Environmental Conservation was created to review and comment on the potential nearfield and far-field air quality impacts through modeling.

The BLM contracted with Kleinfelder, Inc. and Ramboll Environ to conduct the near-field and far-field 

modeling of the GMT2 Project, which began with the development of emission inventories for 

Alternatives A, B, and C. An emission inventory was not completed for Alternative D because it is the noaction alternative with no direct project emissions, and thus, no impacts. From the completed emission 

inventories, near-field modeling was conducted for ambient air impacts, and far-field modeling was 

conducted for ambient air, visibility, and deposition impacts at Class II areas. The emissions inventories, 

near-field modeling air quality impacts analysis, and far-field modeling air quality impact analysis were 

reviewed by the Air Quality Technical Working Group. As part of the NEPA analysis, near-field modeling 

analyzes the impacts within a 50 kilometer (km) radius of the proposed GMT2 drill pad. Potential farfield (greater than 50 km) air quality impacts are evaluated through a separate modeling analysis and 

report. These analyses are in following with the guidelines of the June 23, 2011 Memorandum of 

Understanding (MOU) between the USDA, EPA, and USDOI on procedures for assessing air quality 

impacts due to on-land oil and gas development activities on Federal lands under NEPA.

As detailed in the following discussion, the GMT2 Project under any of the proposed alternatives has 

estimated emissions of the listed criteria, hazardous air, and greenhouse gas pollutants below major 

source thresholds for state permitting requirements. Exact air quality permitting requirements shall be 

determined upon an application for a permit. 
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Federal air quality regulations may apply to the GMT2 Project considering it is expected to use dieselfired equipment and hydraulically fracture oil wells, and has the potential to emit greenhouse gas 

pollutants. Exact federal regulation applicability and requirements will be determined at the time of 

permitting the GMT2 Pad. Regulations under 40 CFR Part 60, 40 CFR Part 61, 40 CFR Part 63, and 40 

CFR Part 98 should be evaluated upon equipment installation and operation for applicability to GMT2 

operations.

Emission inventories were prepared for Alternatives A, B, and C, assuming Construction Schedule 1, 

described in Section 2.4.1 of this document. Construction Schedule 1 was determined to be the more 

conservative construction schedule in terms of air emissions because Construction Schedule 1 has 

activities compacted into 2 years, rather than Construction Schedule 2 which is spread across 3 years. 

Each emission inventory was prepared using the information provided in Sections 2.4 for all alternatives, 

2.5 for Alternative A-specific project parameters, 2.6 for Alternative B-specific project parameters, and 

2.7 for Alternative C-specific project parameters, of this document. 

Each alternative would utilize ice roads during construction, although the length of the ice roads would 

vary depending on the alternative. Likewise, the drilling schedule would be the same under each 

alternative, as would the first date of production from the wells. Drilling would commence in May of Year 

3 of the project and occur year-round for each alternative until all planned wells are drilled. The date of 

first production is expected in December of Year 3.

The emissions inventories are divided into four categories and include the following:

• Construction,

• Developmental drilling, 

• Infill drilling, and

• Routine operations.

Emissions from construction, developmental drilling, and infill drilling are short-term and temporary. 

Construction emission sources include camp generators, aircraft activity, non-mobile support equipment 

for pipeline, powerline, fiber optic line and vertical support member installations, gravel roads, ice roads, 

and pad construction, facilities installation at GMT2, Alpine Central Processing Facility, and CD5, 

tailpipe and dust emissions from truck traffic, and fugitive dust from construction. Construction would 

take place from late Year 1 through Year 3 of the project during Construction Schedule 1. Drilling 

emissions, within the developmental and infill emission inventory categories, result from drilling and well 

intervention sources such as drill rigs, well intervention rigs, tailpipe and dust emissions from truck 

traffic, well flowback flaring, and non-mobile support equipment including heaters, welders, and 

generators. Developmental drilling would take place during Year 3, and infill drilling would take place 

from Years 4 through 10 of the GMT2 Project. 

Emissions from routine operations are long term and permanent for the life of the wells. Emissions from 

routine operations will begin in December of Year 3 and will continue through the life of the GMT2 

Project. Therefore, routine operation emissions will coincide with drilling and well intervention activities 

starting December of Year 3 through Year 10 of the GMT2 Project. Sources of emissions during routine 

operations include a line heater, venting from pigging operations, fugitive component leaks, an emergency 

generator, aircraft activity, tailpipe and dust from truck traffic, and wind erosion. 

Each of the above emission categories is further divided into subcategories based on the equipment and 

processes described and generally includes emissions associated with the following:
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• Fuel combustion emissions from non-mobile sources,

• On-road tailpipe emissions from vehicle traffic,

• Non-road equipment tailpipe emissions,

• Fugitive dust emissions, and 

• Aircraft emissions.

For each category, emissions were estimated for criteria, hazardous air, and greenhouse gas pollutants, as 

applicable. Criteria pollutants include NOx, CO, SO2, VOC, PM10, and PM2.5. Hazardous air pollutants 

include benzene, toluene, ethylbenzene, xylenes, n-hexane, and formaldehyde. Greenhouse gas pollutants 

include CO2, CH4, and N2O reported as CO2e. In all cases, CH4 and N2O are converted to CO2e using the 

global warming potential factors found in 40 CFR Part 98, Subpart A, Table A-1 of 25 and 298,

respectively.

In general, emissions were calculated on both a short-term and a long-term basis to support hourly, daily, 

and annual average modeling for comparison to the National Ambient Air Quality Standards and Alaska 

Ambient Air Quality Standards. Emissions were also summarized on a monthly basis based on the GMT2 

Project schedule to identify the time periods when emissions would be highest to help define near field 

modeling scenarios. Details and the short-term and long-term emission rates used in the near-field and 

far-field modeling are included in the near-field air quality impacts analysis (Kleinfelder and Ramboll 

Environ 2017d) and far-field air quality impacts analysis (Ramboll Environ and Kleinfelder 2017). 

From the emission inventories, near-field modeling scenarios were defined in order to model dispersion 

effects of criteria and toxic pollutants. For the near-field, AERMOD version 16216r, the EPA regulatory 

air dispersion model, was used to determine potential impacts of the GMT2 Project. Based on the 

emissions, three modeling scenarios were created:

• Construction,

• Developmental drilling, and

• Infill drilling.

The construction modeling scenario included sources and potential emissions expected to occur during 

Year 2 of the GMT2 Project. The developmental drilling modeling scenario included sources and 

potential emissions expected to occur during Year 3 of the GMT2 Project, and the infill drilling modeling 

scenario included sources and potential emissions expected to occur during Year 4 of the GMT2 Project. 

As discussed previously, the emissions from routine operations occurs simultaneously with infill drilling 

operations, and therefore in the near field model, emission sources related to routine operations were 

included in the infill drilling modeling scenario. The equipment modeled in each of the modeling 

scenarios along with their hourly, daily, and annual emission rates are detailed in the near field air quality 

impacts analysis (Kleinfelder and Ramboll Environ 2017d).

Meteorological data from the Nuiqsut Monitoring Station from years 2011 through 2015 were processed 

in version 16216 of AERMET to be compatible for use in AERMOD. The single background design 

concentrations in Table 23 were added to the GMT2 modeled impacts for all modeling scenarios except 

for the NO2 and PM10 models. For the NO2 and PM10 models (1-hour NO2, annual NO2, and 24-hour 

PM10), a seasonally varying background value was applied to account for the natural variability of 

pollutant background concentrations. No background values exist for hazardous air pollutants and were 

therefore not added to the modeled impacts. A detailed methodology of the near field analysis including 

background data is included in the near-field air quality impact analysis (Kleinfelder and Ramboll 

Environ 2017d).
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For major sources or major modifications, a prevention of significant deterioration analysis is required in 

order to determine air quality impacts on Class I and Class II areas as described in Chapter 3. Similar to 

the National Ambient Air Quality Standards and Alaska Ambient Air Quality Standards, prevention of 

significant deterioration increments exist for comparison of air quality impacts from a project. These 

values are used as a comparison of consistent, continuous project impacts (e.g., routine operations) 

without considering background concentrations. For projects that are not major sources or major 

modifications, project impacts to prevention of significant deterioration increments are used to inform 

state and federal agencies of the potential for increment consumption. Referenced from 40 CFR Part 52 

Subpart A, the prevention of significant deterioration increments for Class II areas are shown in Table 80

below. The infill drilling scenario was used for a comparison for prevention of significant deterioration 

increments, as it is the only modeling scenario that includes regular routine operation emissions and 

would be conservative because it also includes temporary emissions from drilling and well interventions. 

A prevention of significant deterioration analysis is most appropriate at sensitive receptors such as the 

town of Nuiqsut, a sensitive Class II area. Therefore, the prevention of significant deterioration increment 

analysis was conducted at the Nuiqsut community. Class I area prevention of significant deterioration 

increments are not shown, as the nearest Class I area is over 600 kilometers away.

Table 80. Prevention of significant deterioration increments for Class II areas

Pollutant Average Time Class II Increment

NO2 Annual 25 μg/m3

SO2 3-hour 512 μg/m3

SO2 24-hour 91 μg/m3

SO2 Annual 20 μg/m3

PM10 24-hour 30 μg/m3

PM2.5 24-hour 9 μg/m3

PM2.5 Annual 4 μg/m3

Hazardous air pollutants have the potential to cause adverse health impacts depending on the level and 

duration of exposure. The acute reference exposure limits or the immediately dangerous to life or health 

values were used as a comparison for short-term or 1-hour GMT2 Project impacts and non-cancer 

reference concentrations for chronic inhalation were used as a comparison for GMT2 Project annual 

impacts. The immediately dangerous to life or health value was used if a reference exposure limit was not 

available. The acute reference exposure limits and non-cancer reference concentrations for chronic 

inhalation used in the comparison are listed in Table 81 below and in the near-field air quality impacts 

analysis (Kleinfelder and Ramboll Environ 2017d), as well as in each of the alternative sections below. 

Some hazardous air pollutants from the GMT2 Project are also known to pose potential cancer risk; 

results of the modeling showed pollutant levels well below threshold levels. Cancer inhalation risk was 

calculated at the Nuiqsut receptor since that location is the closest nearby occupied residency. The 

hazardous air pollutants from the GMT2 Project that have a potential to cause cancer are benzene, 

ethylbenzene, and formaldehyde. Two exposure scenarios to determine the potential cancer risk at the 

Nuiqsut community were considered: the maximum exposed individual and the most likely exposure. The 

annual model result of benzene, ethylbenzene, and formaldehyde at the Nuiqsut receptor was multiplied 

by the pollutant’s cancer unit risk factor (shown in Table 81 and the exposure adjustment factor (0.43 

based on a 30-year project life and 70-year exposure). Assuming most residents of Nuiqsut would stay in 

the area long term, the most likely exposure used the same cancer unit risk factor and exposure 

adjustment factor as the maximum exposed individual. The calculated potential cancer risk is the sum of 

the benzene, ethylbenzene, and formaldehyde cancer risks at the Nuiqsut receptor and was compared to a 

risk range of 1 to 100 in 1 million or IE-06 to 100E-06 (EPA 2006). ). For purposes of this analysis, a 
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cancer risk threshold of 1 in 1 million (1E-06) was used meaning the calculated cancer risk is less than 1 

person in 1 million. A detailed methodology of calculating the cancer risk is included in the near-field air 

quality impacts analysis (Kleinfelder and Ramboll Environ 2017d). 

Table 81. Acute, chronic, and cancer risk thresholds for hazardous air pollutants

Pollutant

Acute RELs 

(μg/m3)1

Non-cancer 

Chronic RfC 

(μg/m3)2

Cancer Unit Risk 

Factors (1/(μg/m3))2

Benzene 1,300 30 7.8E-06

Toluene 37,000 5,000 N/A

Ethylbenzene 350,0003 1,000 2.5E-06

Xylenes 22,000 100 N/A

n-hexane 390,0003 700 N/A

Formaldehyde 55 9.8 1.3E-05

The purpose of the GMT2 far-field air quality analyses are to assess the impact of air emissions from 

GMT2 Project sources and other potential future regional emissions sources on National Ambient Air 

Quality Standards and Air Quality Related Values, namely, visibility and deposition. The impacts were 

assessed at two sensitive Class II areas within 300 kilometers of the project: the Gates of the Arctic 

National Park and Preserve, and the Arctic National Wildlife Refuge, that were previously identified by 

federal cooperating agencies for the GMT1 far-field analysis following the 2011 memorandum of 

understanding between the U.S. Department of Agriculture, DOI, and EPA on procedures for assessing air 

quality impacts due to on-land oil and gas development activities on federal lands under NEPA (U.S. 

Department of Agriculture 2011). There are no Class I areas (i.e., areas with higher air quality protections 

than Class II areas) within 300 kilometers of the GMT2 Project area; the nearest one is the Denali 

National Park which is over 600 kilometers away. A map presenting the location of the GMT2 Project in 

relation to the two sensitive Class II areas is shown in Figure 38 and listed in Table 82. 
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Figure 38. GMT2 Project Location (Black Star), Gates of the Arctic National Park and Preserve Receptors, 

Arctic National Wildlife Refuge Receptors, Meteorological Data Region (4km Weather Research and 

Forecast), Far-Field Air Modeling Region (CALPUFF Domain)

Table 82. Class II areas of concern

Area of Concern Managing Agency PSD Classification

Gates of the Arctic National Park National Park Service Class II

Alaska National Wildlife Refuge USFWS Class II

To assess far-field air quality and air quality-related values impacts, the air dispersion model CALPUFF 

was used. Details on CALPUFF’s regulatory status, the model version utilized, and additional preprocessing and post-processing performed may be found in the GMT2 far-field air quality modeling 

report (Ramboll Environ and Kleinfelder 2017). The modeling procedures followed the Federal Land 

Managers’ Air Quality Related Values Work Group and Interagency Workgroup on Air Quality Modeling 

recommendations—in particular, Federal Land Managers’ Air Quality Related Values Work Group (2000, 

revised October 2010) and Interagency Workgroup on Air Quality Modeling (1998) guidance documents. 

The CALPUFF model options used are described in detail in the far-field modeling air quality impacts 

analysis report (Ramboll Environ and Kleinfelder 2017) and are summarized here:
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• Regulatory Options: CALPUFF was run in the regulatory mode (MREG =1). 

• Modeling Period: Five years were modeled (2009–2013) using 4 kilometer horizontal resolution 

meteorology driven by the Weather Research and Forecast meteorological model.

• Downwash: Downwash effects were not considered, because they have little effect at source-receptor 

distances greater than 50 kilometers.

• Background Ammonia: CALPUFF runs performed for GMT2 used 1.0 ppb ammonia concentration, 

appropriate for the remote area with little agriculture.

• Background Ozone: Hourly surface ozone is measured at the Nuiqsut Monitoring Station. These 

hourly observed ozone concentrations were used in the CALPUFF modeling, with the maximum 

value over the 5-year modeling period (59.8 ppb) used for the 758 missing hours. 

• Visibility Impact Assessment: Visibility impacts were calculated using the recommended Method 8 

included as the default option in CALPOST (Federal Land Managers’ Workgroup 2010). The annual 

average natural conditions tables for monthly species background concentrations and relative 

humidity adjustment factors for the closest Class I area, Denali National Park, were used (Federal 

Land Managers’ Workgroup 2010).

To be protective of the environment, and for the sake of simplicity, the far-field modeling conservatively 

used the maximum of the short-term and long-term emission rates for each pollutant. That is, the 1-hour

NOx emission rate was used for the both visibility (normally a 24-hour emission rate) and deposition 

(normally an annual emission rate) portions of the air quality related value analysis, and for both the 1-

hour and annual NO2 concentrations for the National Ambient Air Quality Standards and Alaska Ambient 

Air Quality Standards and Class II prevention of significant deterioration increment analysis. Most 

emission sources were assumed to operate 24 hours per day, 7 days per week, and 52 weeks per year,

regardless of whether the potential for emissions to occur during a certain period is present due to 

operating schedules or environmental conditions. Moreover, even though fugitive dust would not occur 

during winter months, PM10 and PM2.5 emission rates were held constant at their maximum emission rate. 

A detailed methodology into the model set up for the far field analysis is included in the far field air 

quality impact analysis (Ramboll Environ and Kleinfelder 2017).

The following sections outline the air quality impact analysis for each GMT2 alternative. Emissions and 

methodologies for each alternative, other than the no-action alternative, were calculated and analyzed and 

were presented in separate reports (Kleinfelder and Ramboll Environ 2017a, 2017b, 2017c). The 

approved final emission inventories for each alternative were utilized for the air quality impact analysis in 

the near-field and far-field modeling analyses. The potential cumulative impacts of GMT2 Project sources 

and reasonably foreseeable developments are presented in Section 4.6.5, “Cumulative Impacts to Air 

Quality.”

Alternative A

The emission inventory for Alternative A was prepared for the BLM in order to begin the modeling 

process to compare predicted air quality impacts to the National Ambient Air Quality Standards and 

Alaska Ambient Air Quality Standards and prevention of significant deterioration increments in the near 

field and National Ambient Air Quality Standards and Alaska Ambient Air Quality Standards and Air 

Quality Related Values in the far-field. For the far-field, the only locations for analysis were the Gates of 

the Arctic National Park and Preserve and the Arctic National Wildlife Refuge which are Class II areas. 

There are no Class I areas within 300 kilometers of the GMT2 Project area. 
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Emission Inventory

A detailed report was prepared describing the calculation methodologies, assumptions, and data sources 

for the Alternative A emission inventory (Kleinfelder and Ramboll Environ 2017a). Considering the 

similarities between the recently approved GMT1 Project and the proposed GMT2 Project, the same basic 

equipment was assumed for GMT2 as GMT1, but was scaled as necessary based on GMT2 Projectspecific data. For example, GMT2 will have a larger gravel pad than GMT1, so the equipment for pad 

construction was scaled based on the increased pad acreage. In general, emissions were determined using 

published emission factors, information from Chapter 2 of this document, and equipment specifics found 

in GMT1 (BLM 2013), unless updated based on information from ConocoPhillips for GMT2. The 

Alternative A project year totals for each of the criteria pollutants (NOx, CO, VOC, PM10, PM2.5, and SO2) 

and select hazardous air pollutants (benzene, toluene, ethylbenzene, xylenes, n-Hexane, and 

formaldehyde) emissions are presented in Table 83 (Kleinfelder and Ramboll Environ 2017a). The table 

also details the month with the highest emissions of the specified pollutant.

Table 83. GMT2 Project Alternative A criteria and hazardous air pollutant emissions summary

GMT2 Project Alternative A Year 1 Year 2 Year 3

Year

4–10

Year 11 

on

Maximum Month 

of Emissionsa

NOx (tons per year) 12.8 89.0 119.0 87.2 8.9 Year 2 Month 2

CO (tons per year) 5.2 45.4 77.5 63.7 6.4 Year 2 Month 2

VOC (tons per year) 1.6 15.1 20.9 16.2 8.0 Year 2 Month 2

PM10 (tons per year) 0.75 193.0 116.0 58.8 5.3 Year 2 Month 7

PM2.5 (tons per year) 0.58 23.7 17.8 10.6 1.2 Year 2 Month 7

SO2 (tons per year) 0.02 0.19 0.34 0.45 0.21 Year 3 Month 12

Benzene (tons per year) 0.02 0.18 0.16 0.06 0.006 Year 2 Month 2

Toluene (tons per year) 0.02 0.17 0.12 0.04 0.01 Year 2 Month 2

Ethylbenzene (tons per year) 0.005 0.04 0.02 0.01 0.01 Year 2 Month 2

Xylenes (tons per year) 0.02 0.15 0.10 0.04 0.02 Year 2 Month 2

n-Hexane (tons per year) 0.003 0.02 0.04 0.23 0.23 Year 3 Month 12

Formaldehyde (tons per year) 0.19 1.4 0.97 0.20 0.005 Year 2 Month 2

The construction phase, while having high short-term emissions, is temporary and does not translate to 

the consistent, permanent emissions from the routine operations beginning in Year 4. Maximum annual 

emissions would occur during the construction and drilling phases (Years 2 and 3), and once construction 

and drilling are complete and emissions are from routine operations alone (Year 11 on), emissions are 

approximately 10 times less. 

Impacts Analysis

Alternative A was modeled as it is ConocoPhillips’ proposed alternative. The methodology briefly 

described above, and detailed in the near-field air quality impacts analysis (Kleinfelder and Ramboll 

Environ 2017d) was followed using modeled results from AERMOD to compare GMT2 Project 

Alternative A impacts to the applicable National Ambient Air Quality Standards and Alaska Ambient Air 

Quality Standards for criteria pollutants and reference exposure limits and reference concentrations for 

chronic inhalation for hazardous air pollutants. The results of the near-field modeling for Alternative A are 

presented in Table 84 and Table 85 for criteria pollutants and Table 87 and Table 88 for hazardous air 

pollutants. The results shown include impacts from Alternative A operations, ambient background 

concentrations, and impacts from cumulative sources. 
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Table 84. GMT2 Project Alternative A near-field criteria pollutants impacts summary (μg/m3)

Criteria 

Pollutant

Averaging 

Period Construction

Developmental 

Drilling

Infill 

Drilling

Maximum 

Scenario

NAAQS/

AAAQS

Percent 

of 

Standard

CO 1-hour 1,375 1,600 1,492 1,600 40,000 4%

CO 8-hour 1,299 1,400 1,396 1,400 10,000 14%

NO2 1-hour 165.6 166.2 148.0 166.2 188 88%

NO2 Annual 25.1 35.9 33.4 35.9 100 36%

SO2 1-hour 34.2 34.2 34.2 34.2 196 17%

SO2 3-hour 39.1 39.1 39.1 39.1 1,300 3%

SO2 24-hour 22.1 22.1 22.1 22.1 365 6%

SO2 Annual 0.74 0.74 0.75 0.75 80 1%

PM101 24-hour 78.8 133.2 109.7 133.2 150 89%

PM2.51 24-hour 25.9 25.9 25.9 25.9 35 74%

PM2.51 Annual 2.9 4.1 4.0 4.1 12 35%

1 The results for PM10 and PM2.5 are based on revised model runs completed in August 2018 for a 35 miles per hour speed limit 

rather than 20 miles per hour speed limit used in the model runs completed in September 2017. An addendum to the AQIA 

details the methodology and results of the speed limit change.

For each of the criteria pollutant models, the GMT2 Project maximum impacts, including background 

concentrations, are less than 90 percent of their respective National Ambient Air Quality Standards and 

Alaska Ambient Air Quality Standards for each pollutant, and less of their respective standards for each 

pollutant at the community of Nuiqsut. The potential impacts at the Nuiqsut community; a single receptor 

at the coordinates 70.21720, -150.99556 modeled below 36 percent of their respective increments (shown 

below in Table 85). 

Table 85. GMT2 Project Alternative A Near Field Criteria Pollutants Impacts Summary at the Nuiqsut 

Community Receptor (μg/m3)

Criteria 

Pollutant

Averaging 

Period Construction

Developmental 

Drilling

Infill 

Drilling

Maximum 

Scenario

NAAQS/

AAAQS

Percent 

of 

Standard

CO 1-hour 1,237 1,240 1,236 1,240 40,000 3%

CO 8-hour 1,231 1,231 1,231 1,231 10,000 12%

NO2 1-hour 63.6 63.6 63.6 63.6 188 34%

NO2 Annual 17.3 17.3 17.2 17.3 100 17%

SO2 1-hour 10.9 10.9 10.9 10.9 196 6%

SO2 3-hour 9.74 9.74 9.74 9.74 1,300 1%

SO2 24-hour 6.03 6.03 6.03 6.03 365 2%

SO2 Annual 0.090 0.090 0.090 0.090 80 0.1%

PM101 24-hour 41.4 41.4 41.4 41.4 150 28%

PM2.51 24-hour 10.5 10.5 10.5 10.5 35 30%

PM2.51 Annual 2.13 2.13 2.13 2.13 12 18%

1 The results for PM10 and PM2.5 are based on revised model runs completed in August 2018 for a 35 miles per hour speed limit 

rather than 20 miles per hour speed limit used in the model runs completed in September 2017. An addendum to the AQIA 

details the methodology and results of the speed limit change.
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As detailed in the near-field air quality impacts analysis (Kleinfelder and Ramboll Environ 2017d), a 

number of conservative assumptions were used in these models including a dust control efficiency of 50

percent for watering of gravel pads and roads where GMT1 used 75 percent for some dust control 

efficiencies via watering (AECOM 2013a). Also, it was assumed that drilling, construction, and well 

interventions would all occur during the same 1-hour period for short-term impacts where the likelihood 

of that occurring is minimal for safety and practical purposes. Lastly, a conservative assumption worked 

into the near-field model was monthly averages for vehicle truck traffic where it is known vehicle traffic 

will vary month to month, especially during construction where activities are not evenly spread. Best 

management practices for dust control are discussed later in this section. 

Table 86. GMT2 Project Alternative A prevention of significant deterioration increments for Class II Areas

Pollutant Average Time Nuiqsut Receptor Class II Increment

NO2 Annual 8.61 μg/m3 25 μg/m3

SO2 3-hour 3.54 μg/m3 512 μg/m3

SO2 24-hour 1.23 μg/m3 91 μg/m3

SO2 Annual 0.087 μg/m3 20 μg/m3

PM10 24-hour 1.41 μg/m3 30 μg/m3

PM2.5 24-hour 3.16 μg/m3 9 μg/m3

PM2.5 Annual 0.026 μg/m3 4 μg/m3

The potential impacts at the Nuiqsut receptor from the Infill Drilling scenario of Alternative A were used 

for comparison to the Class II increments, as the Infill Drilling scenario included emissions from drilling, 

well interventions, and routine operations. The use of the Infill Drilling scenario for this evaluation is 

conservative as it includes emissions from the temporary drilling and well intervention sources, and PSD 

increment analyses generally only include consistent, and continuous routine operations. The potential 

impacts at the Nuiqsut community modeled below 36% of their respective increments. The concentrations 

listed in Table 86 above only include total impacts, so as to be conservative, without background, as PSD 

increment comparison do not include background concentrations in the modeled impacts. There is also a 

prevention of significant deterioration increment for annual PM10 of 17 μg/m3

. Since the short-term 

impact at the Nuiqsut receptor for 24-hour PM10 is also below the annual increment, it can also be 

concluded the annual increment for PM10 will model below its increment.

Table 87. GMT2 Project Alternative A near-field hazardous air pollutant impacts summary (μg/m3)

Hazardous Air 

Pollutant

Averaging 

Period Construction

Developmental 

Drilling

Infill 

Drilling

Maximum 

Scenario

Threshold

Level

Benzene 1-hour 64.07 54.09 47.34 64.07 1,300

Benzene Annual 0.33 1.29 0.99 1.29 30

Toluene 1-hour 61.94 48.26 53.24 61.94 37,000

Toluene Annual 0.32 0.99 0.64 0.99 5,000

Ethylbenzene 1-hour 13.49 9.33 17.01 17.01 350,000

Ethylbenzene Annual 0.064 0.19 0.18 0.19 1,000

Xylenes 1-hour 56.25 40.12 27.78 56.25 22,000

Xylenes Annual 0.27 0.81 0.55 0.81 100

n-Hexane 1-hour 6.74 65.59 1,335 1,335 390,000

n-Hexane Annual 0.035 0.31 3.54 3.54 700

Formaldehyde 1-hour 10.29 10.39 1.17 10.39 55

Formaldehyde Annual 0.24 0.30 0.046 0.30 9.8
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Table 88. GMT2 Project Alternative A Near Field Hazardous Air Pollutant Impacts Summary at the Nuiqsut 

Community Receptor (μg/m3) 

Hazardous Air 

Pollutant

Averaging 

Period Construction

Developmental 

Drilling

Infill 

Drilling

Maximum 

Scenario

Threshold 

Level

Benzene 1-hour 1.43 1.02 0.95 1.43 1,300

Benzene Annual 0.0015 0.0024 0.00078 0.0024 30

Toluene 1-hour 1.38 0.91 1.07 1.38 37,000

Toluene Annual 0.0015 0.0018 0.00050 0.0018 5,000

Ethylbenzene 1-hour 0.30 0.18 0.34 0.34 350,000

Ethylbenzene Annual 0.00030 0.00034 0.00014 0.00034 1,000

Xylenes 1-hour 1.25 0.76 0.56 1.25 22,000

Xylenes Annual 0.0013 0.0015 0.00043 0.0015 100

n-Hexane 1-hour 0.15 1.24 26.8 26.8 390,000

n-Hexane Annual 0.00016 0.00058 0.0028 0.0028 700

Formaldehyde 1-hour 0.30 0.12 0.024 0.30 55

Formaldehyde Annual 0.00054 0.00056 0.000040 0.00056 9.8

Benzene Cancer 

Risk - 5.2E-09 8.1E-09 2.6E-09 8.1E-09 1.0E-06

Ethylbenzene 

Cancer Risk - 3.2E-10 3.7E-10 1.5E-10 3.7E-10 1.0E-06

Formaldehyde 

Cancer Risk - 3.0E-09 3.1E-09 2.2E-10 3.1E-09 1.0E-06

Total Cancer 

Risk - 8.5E-09 1.2E-08 3.0E-09 1.2E-08 1.0E-06

The maximum 1-hour and annual hazardous air pollutant impacts for GMT2 Alternative A are 

considerably lower than their respective reference exposure limits and reference concentrations for 

chronic inhalation, as all of the potential impacts from the maximum scenario are below their respective 

thresholds. In turn, the model results demonstrate that the potential for the health of the most sensitive 

individuals to be negatively affected by the GMT2 Project is low. For all hazardous air pollutants, except 

formaldehyde, a conservative unitized run was conducted, as described in the near-field air quality 

impacts analysis (Kleinfelder and Ramboll Environ 2017d). Formaldehyde was modeled using actual 

emissions for each individual source, similar to the criteria pollutants, so as to demonstrate that the 

unitized emission methodology over-estimated impacts. Based on the near-field modeling, the sum of the 

cancer risks of benzene, ethylbenzene, and formaldehyde based on the methodology discussed above (i.e., 

the potential cancer risk) at the Nuiqsut community, the nearest long-term occupied residency, was 

determined to be considerably below the minimum cancer risk threshold of 1 in 1 million (EPA 2006). 

Far-field air quality modeling was conducted for Alternative A, because it is ConocoPhillips’ proposed 

action alternative and is in keeping with the air quality impact procedures outlined in the June 23, 2011 

MOU between USDA, EPA, and USDOI. Emissions were estimated for each year of the life of the 

project. The year with highest emissions was selected for each pollutant to create a worst-case emissions 

scenario for CALPUFF modeling. In other words, all emissions activities that could occur simultaneously 

are calculated to estimate the total emissions in a given year. The worst-case emissions year varies for 

each pollutant. The worst-case year was selected for each pollutant modeled together to create a worstcase emissions scenario. For Alternative A, the highest NOx, SO2, and PM10 emissions occurred when 

developmental drilling activities predominate, while the highest PM2.5 emissions occurred when 

construction activities predominate. Importantly, other activities such as construction, well intervention, 

and routine operations that could also occur simultaneously in the year with the highest emissions, are 

also included in the modeled CALPUFF emissions for Alternative A worst-case emissions scenario. e.g., 
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A detailed description of emission rates used in the CALPUFF National Ambient Air Quality Standards

modeling to estimate project impacts is provided in the far-field air quality impacts analysis (Ramboll 

Environ and Kleinfelder 2017).

Table 89 and Table 90summarize the predicted GMT2 Project-specific maximum concentrations for 

Alternative A at the Arctic National Wildlife Refuge and the Gates of the Arctic National Park, 

respectively. The tables indicate predicted concentrations are all less than 50 percent of the relevant 

National Ambient Air Quality Standards and Alaska Ambient Air Quality Standards and increments.

Table 89. GMT2 Project Alternative A air quality impacts at the Arctic National Wildlife Refuge

Pollutant

Averaging 

Period

Maximum 

Predicted 

Impact 

(μg/m3)

Class II 

Increment 

(μg/m3)

Over 

Increment?

Ambient 

Background 

(μg/m3)

Total 

Concentration 

(μg/m3)

NAAQS/

AAAQS 

(μg/m3)

NO2 1-hour 0.151 -- -- 41.9 42.1 188

NO2 Annual 0.00171 25 No 3.8 3.8 100

SO2 1-hour 0.0014 -- -- 5.9 5.9 196

SO2 3-hour 0.0011 512 No 6.2 6.2 1,300

SO2 24-hour 4.00E-04 91 No 4.8 4.8 365

SO2 Annual 1.68E-05 20 No 0.003 0.003 80

PM10 24-hour 0.0612 30 No 45.2 45.3 150

PM2.5 24-hour 0.0185 9 No 7.3 7.3 35

PM2.5 Annual 8.00E-04 4 No 2.1 2.1 12

Table 90. GMT2 Project Alternative A air quality impacts at Gates of the Arctic National Park and Preserve

Pollutant

Averaging 

Period

Maximum

Predicted 

Impact 

(μg/m3)

Class II 

Increment 

(μg/m3)

Over 

Increment?

Ambient 

Background 

(μg/m3)

Total 

Concentration 

(μg/m3)

NAAQS/

AAAQS 

(μg/m3)

NO2 1-hour 0.0385 -- -- 41.9 41.9 188

NO2 Annual 8.34E-04 25 No 3.8 3.8 100

SO2 1-hour 4.00E-04 -- -- 5.9 5.9 196

SO2 3-hour 4.00E-04 512 No 6.2 6.2 1,300

SO2 24-hour 2.00E-04 91 No 4.8 4.8 365

SO2 Annual 8.26E-06 20 No 0.003 0.003 80

PM10 24-hour 0.03 30 No 45.2 45.2 150

PM2.5 24-hour 0.009 9 No 7.3 7.3 35

PM2.5 Annual 4.00E-04 4 No 2.1 2.1 12

The deposition analysis results are shown in Table 91 and indicate that GMT2 Project-specific maximum 

nitrogen and sulfur deposition fluxes are well below the deposition analysis threshold in both sensitive 

Class II areas.
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Table 91. GMT2 Project Alternative A deposition impacts

Class II Area Pollutant

Averaging 

Period

Maximum 

Impact 

(kg/ha-yr)

Deposition 

Analysis 

Threshold

(kg/ha-yr)

% of 

Deposition 

Analysis 

Threshold

Meteorological 

Year of 

Maximum 

Impact

Arctic National 

Wildlife Refuge

Nitrogen Annual 0.0001 0.005 2 2012

Gates of the Arctic 

National Park and 

Preserve

Nitrogen Annual 0.0001 0.005 2 2010

Arctic National 

Wildlife Refuge

Sulfur Annual 3.90E-06 0.005 0.076 2012

Gates of the Arctic 

National Park and 

Preserve

Sulfur Annual 2.00E-06 0.005 0.04 2010

Table 92 summarizes the predicted change in visibility at each sensitive Class II area for each modeled 

year. As indicated in Table 92, the highest 98th percentile change in delta-deciviews is well below the 0.5 

Δdv threshold for project-specific impacts established by the Federal Land Managers for each year. Thus, 

GMT2 Project impacts on visibility at the two Class II areas would be minimal in Alternative A.

Table 92. GMT2 Project Alternative A visibility impacts

Class II Area

Days 

Exceeding 

1.0 Δdv

Days 

Exceeding 

0.5 Δdv

98th 

Percentile 

Δdv 2009

98th 

Percentile 

Δdv 2010

98th 

Percentile 

Δdv 2011

98th 

Percentile 

Δdv 2012

98th 

Percentile 

Δdv 2013

Arctic National 

Wildlife Refuge

0 0 0.054 0.045 0.052 0.039 0.034

Gates of the 

Arctic National 

Park and 

Preserve

0 0 0.030 0.022 0.024 0.022 0.023

Alternative B

The GMT2 Project Alternative B completed an emissions inventory based on alternative specifics 

(Kleinfelder and Ramboll Environ 2017b). From the emissions inventory, and comparison of Alternative 

B to Alternative A, it was determined that near-field and far-field modeling analyses were not required for 

Alternative B, as the impacts analysis from Alternative A would be representative of the impacts of 

Alternative B. 

Alternative B differs from Alternative A only in the GMT2 to GMT1 gravel access road and pipeline alignment 

and length. The access road and pipeline in Alternative B would be longer than in Alternative A. From an air 

emission perspective, this difference translates to slightly more emissions from construction activities for 

Alternative B, as detailed below and at the end of this section (Table 105). Drilling and operation emissions 

would be the same between the two alternatives except for increased emissions from truck traffic on the 

longer Alternative B access road (
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Table 106 and Table 107). Therefore, due to the similarity in emissions between Alternative A and 

Alternative B, the Alternative B near-field and far-field impacts for the GMT2 Project are expected to be 

similar to those of Alternative A.

Emission Inventory

Considering the similarities between Alternative B and Alternative A, a letter was prepared outlining the 

differences between the two alternatives and how that resulted in emission differences (Kleinfelder and 

Ramboll Environ 2017b). As mentioned, Alternative B has a larger gravel access road and pipeline length 

that follows the watershed boundary to the south. The letter for the emissions inventory for Alternative B 

details that truck traffic and fugitive dust emissions related to travel and construction are expected to be 

higher in Alternative B compared to Alternative A. The Alternative B project year totals for each of the 

criteria pollutants (NOx, CO, VOC, PM10, PM2.5, and SO2) and speciated hazardous air pollutant (benzene, 

toluene, ethylbenzene, xylenes, n-Hexane, and formaldehyde) emissions are presented in Table 93

(Kleinfelder and Ramboll Environ 2017b). The table also details the month with the highest emissions of 

the specified pollutant.

Table 93. GMT2 Project Alternative B criteria and hazardous air pollutant emissions summary

GMT2 Project Alternative B Year 1 Year 2 Year 3

Year

4–10

Year 11 

on

Maximum Month of 

Emissionsa

NOx (tons per year) 13.0 93.3 121.0 87.2 8.9 Year 2 Month 2

CO (tons per year) 5.3 47.1 78.3 64.4 7.1 Year 2 Month 2

VOC (tons per year) 1.6 15.5 21.0 16.4 8.1 Year 2 Month 2

PM10 (tons per year) 0.77 212.0 119.0 62.4 6.2 Year 2 Month 7

PM2.5 (tons per year) 0.60 25.9 18.2 11.0 1.2 Year 2 Month 7

SO2 (tons per year) 0.02 0.20 0.34 0.46 0.21 Year 3 Month 12

Benzene (tons per year) 0.02 0.19 0.16 0.07 0.008 Year 2 Month 2

Toluene (tons per year) 0.02 0.19 0.13 0.04 0.01 Year 2 Month 2

Ethylbenzene (tons per year) 0.005 0.04 0.02 0.01 0.01 Year 2 Month 2

Xylenes (tons per year) 0.02 0.16 0.10 0.04 0.02 Year 2 Month 2

n-Hexane (tons per year) 0.004 0.02 0.04 0.23 0.23 Year 3 Month 12

Formaldehyde (tons per year) 0.19 1.5 1.0 0.22 0.03 Year 2 Month 2

Alternative B emission totals for criteria and hazardous air pollutants are slightly higher than that of 

Alternative A. The construction phase, while having high short-term emissions, are temporary and do not 

translate to the consistent, permanent emissions from the routine operations beginning in Year 4. 

Maximum annual emissions would occur during the construction and drilling phases (Years 2 and 3), and 

once construction and drilling are complete and emissions are from routine operations alone (Year 11 on), 

emissions are approximately 10 times less.

Impacts Analysis

An impacts analysis for Alternative B was not conducted because it was determined that the potential 

impacts in the near-field and far-field for Alternative A would be representative of Alternative B. As 

shown in the final emissions reports (Kleinfelder and Ramboll Environ 2017a, 2017b) and in Table 87, 

Table 88, and Table 93, emissions between Alternative A and B are slightly higher in Alternative B due to 

increased construction, road mileage, and pipeline length as detailed in Section 2.6. Also, the pad size and 

road alignment nearest the GMT2 Pad is the same between the two alternatives; therefore, emission 

source locations are also similar. The sources on the GMT2 Pad in Alternatives A and B are the same and 

the differences exist for pipeline construction due to the longer pipeline length, road construction due to 
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the longer road length, and truck traffic from travelling on a longer road. While overall higher emissions 

from truck traffic and road construction would result from the longer road and higher emissions would 

result from pipeline construction from the longer pipeline, the emissions per road segment, per pipeline 

segment, or emissions per mile, would be the same as the equipment or trucks used in Alternative A 

would be the same for Alternative B. The size of the GMT2 Pad and the road access is the same between 

the two alternatives, and the highest project impacts occur near or on the fenceline of the GMT2 Pad. 

Therefore, with the similarities between Alternative A and B in emission source location and emissions 

per mile (either road or pipeline), Alternative B was not modeled as enough similarities exist between 

Alternative A and B that impacts would also be similar.

Alternative C

The GMT2 Project Alternative C completed an emissions inventory based on the project parameters 

detailed in Chapter 2, Section 2.7 of this document. Enough differences exist between Alternative A and 

Alternative C that a separate report was created (Kleinfelder and Ramboll Environ 2017c) detailing the 

additional emission sources not covered in the Alternative A report. Considering these differences, it was 

determined that near field and far field modeling analyses would be required for Alternative C. 

Alternative C differs from Alternative A in that Alternative C would not have a GMT2 to GMT1 Access 

Road, but would rather have an airstrip and support pad near the proposed GMT2 drill pad. A short access 

road would connect the proposed GMT2 Drill pad and airstrip and support pad. Pad construction 

emissions would increase due to the extra support pad and air strip in Alternative C; however, the access 

road construction emissions would decrease in Alternative C. While emissions from drilling and well 

intervention engines and heaters will be the same in Alternatives C and A, the emissions from operations 

that support drilling and well intervention will vary between the two alternatives. The most prominent 

difference stems from Alternative C having limited offsite access resulting in increased onsite aircraft and 

truck traffic during drilling and well intervention phases due to the onsite airstrip and higher onsite truck 

mileage. Lastly, emissions from routine operations will vary between Alternatives A and C because

Alternative C will have a greater amount of activity occurring at the GMT2 drill and support pads rather 

than remotely as in Alternative A.

Emission Inventory

A detailed report was prepared describing the additional calculation methodologies, assumptions, and data 

sources for the Alternative C emission inventory (Kleinfelder and Ramboll Environ 2017c). A majority of 

the same sources exist between Alternative A and Alternative C; however, the level of activity varied. The 

additional emission sources in Alternative C include a waste incinerator at the occupied structure pad for 

onsite waste processing, an emergency generator at the occupied structure pad for additional backup 

power generation, and onsite aircraft activity from the GMT2 airstrip. Since Alternative C would require 

more onsite activities, truck traffic from other locations would be limited. 

Similar to Alternative A, the same basic equipment was assumed for Alternative C, but was scaled as 

necessary based on the alternative specific data. Alternative C will have a larger gravel pad along with 

additional construction for the airstrip and occupied structure pad, so the equipment for pad construction 

was scaled based on the acreage between the two alternatives. In general, emissions for the additional 

Alternative C sources were determined using published emission factors, information from Chapter 2 of 

this document, and equipment specifics found in GMT1 for their Alternative D1 (BLM 2013), unless 

updated based on information from ConocoPhillips for GMT2. The Alternative C project year totals for 

each of the criteria pollutants (NOx, CO, VOC, PM10, PM2.5, and SO2) and speciated hazardous air 

pollutant (benzene, toluene, ethylbenzene, xylenes, n-Hexane, and formaldehyde) emissions are presented 

in Table 94(Kleinfelder and Ramboll Environ 2017c). The table also details the month with the highest 

emissions of the specified pollutant.
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Table 94. GMT2 Project Alternative C criteria and hazardous air pollutant emissions summary

GMT2 Project Alternative C Year 1 Year 2 Year 3

Year 

4–10

Year 

11 on

Maximum Month of 

Emissionsa

NOx (tons per year) 13.2 104.0 145.0 97.6 17.6 Year 2 Month 4

CO (tons per year) 5.4 54.8 123.0 109.0 17.0 Year 3 Month 5

VOC (tons per year) 1.7 18.3 27.3 22.1 11.2 Year 2 Month 4

PM10 (tons per year) 0.82 290.0 74.4 57.9 26.9 Year 2 Month 8

PM2.5 (tons per year) 0.62 34.7 18.0 14.7 7.1 Year 2 Month 8

SO2 (tons per year) 0.02 0.22 0.66 0.79 0.31 Year 3 Month 8

Benzene (tons per year) 0.02 0.21 0.27 0.13 0.02 Year 2 Month 4

Toluene (tons per year) 0.02 0.20 0.20 0.08 0.02 Year 2 Month 4

Ethylbenzene (tons per year) 0.006 0.04 0.04 0.02 0.01 Year 2 Month 4

Xylenes (tons per year) 0.02 0.17 0.16 0.06 0.03 Year 2 Month 4

n-Hexane (tons per year) 0.004 0.02 0.05 0.18 0.18 Year 4 Month 6

Formaldehyde (tons per year) 0.20 1.67 1.83 0.71 0.12 Year 2 Month 4

a Year 3 Month 6 is not the maximum month of emissions for NOx, CO, VOC, and SO2. Well interventions were conservatively 

assumed to occur in the span of 1 month for purposes of the emission inventory and to avoid underestimating short-term emissions 

for the modeling (Kleinfelder and Ramboll Environ 2017c). 

Both the construction and drilling phases, while having high short-term emissions, are temporary and do 

not translate to the consistent, permanent emissions from the routine operations beginning in Year 4. 

Maximum annual emissions would occur during the construction and drilling phases (Years 2 and 3), and 

are higher than Alternative A totals for the same year and pollutants. Emissions are from routine 

operations alone (Year 11 on), emissions are approximately 8 times less.

Impacts Analysis

Alternative C was explicitly modeled as operations and construction differ from Alternative A due to the 

extra support pad and airstrip. Alternative C is the only alternative with an onsite airstrip; therefore, onsite 

aircraft emissions were modeled for Alternative C only. Also, due to the location of emission sources and 

the fact that there are additional Alternative C emission sources and construction activities compared to 

Alternative A, Alternative C was modeled. 

The methodology briefly described at the beginning of this section, and detailed in the near-field air 

quality impacts analysis (Kleinfelder and Ramboll Environ 2017d) was followed using AERMOD to 

compare GMT2 Project Alternative C impacts to the applicable National Ambient Air Quality Standards 

and Alaska Ambient Air Quality Standards for criteria pollutants and reference exposure limits and 

reference concentrations for chronic inhalation for hazardous air pollutants. The results of the near-field 

modeling for Alternative C are presented in Table 95 and Table 96 for criteria pollutants and Table 98 and 

Table 99 for hazardous air pollutants below. The results shown include potential impacts from Alternative 

C operations, ambient background concentrations, and impacts from cumulative sources.
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Table 95. GMT2 Project Alternative C near-field criteria pollutants impacts summary (μg/m3)

Criteria 

Pollutant

Averaging 

Period Construction

Developmental 

Drilling

Infill 

Drilling

Maximum 

Scenario

NAAQS/

AAAQS

Percent 

of 

Standard

CO 1-hour 1,497 1,772 1,651 1,772 40,000 4%

CO 8-hour 1,315 1,458 1,503 1,503 10,000 15%

NO2 1-hour 161.9 170.5 179.0 179.0 188 95%

NO2 Annual 25.3 34.7 37.4 37.4 100 37%

SO2 1-hour 48.1 48.1 48.1 48.1 196 25%

SO2 3-hour 88.3 88.3 88.3 88.3 1,300 7%

SO2 24-hour 36.2 36.2 36.2 36.2 365 10%

SO2 Annual 0.75 0.75 0.75 0.75 80 1%

PM10 24-hour 91.7 122.8 129.8 129.8 150 87%

PM2.5 24-hour 25.9 25.9 25.9 25.9 35 74%

PM2.5 Annual 3.4 4.6 5.1 5.1 12 42%

Table 96. GMT2 Project Alternative C Near Field Criteria Pollutants Impacts Summary at the Nuiqsut 

Community Receptor (μg/m3)

Criteria 

Pollutant

Averaging 

Period Construction

Developmental 

Drilling

Infill 

Drilling

Maximum 

Scenario

NAAQS/

AAAQS

Percent 

of 

Standard

CO 1-hour 1,241 1,240 1,238 1,241 40,000 3%

CO 8-hour 1,231 1,232 1,231 1,232 10,000 12%

NO2 1-hour 63.6 63.6 63.6 63.6 188 34%

NO2 Annual 17.3 17.3 17.3 17.3 100 17%

SO2 1-hour 10.9 10.9 10.9 10.9 196 6%

SO2 3-hour 9.74 9.74 9.74 9.74 1,300 1%

SO2 24-hour 6.03 6.03 6.03 6.03 365 2%

SO2 Annual 0.090 0.090 0.090 0.090 80 0.1%

PM10 24-hour 41.3 41.3 41.3 41.3 150 28%

PM2.5 24-hour 10.5 10.5 10.5 10.5 35 30%

PM2.5 Annual 2.13 2.13 2.13 2.13 12 18%

For each of the criteria pollutant models, the GMT2 Project maximum impacts including background 

concentrations are less than their respective National Ambient Air Quality Standards and Alaska Ambient 

Air Quality Standards for each pollutant. Furthermore, the potential impacts at the Nuiqsut community; a 

single receptor at the coordinates 70.21720, -150.99556 are less than their respective National Ambient 

Air Quality Standards and Alaska Ambient Air Quality Standards. The potential impacts at the Nuiqsut 

community modeled below 36 percent of their respective increments. Therefore, GMT2 Project impacts 

are not expected to consume increments resulting in no potential air quality degradation at the Nuiqsut 

community. As detailed in the near-field air quality impacts analysis (Kleinfelder and Ramboll Environ 

2017d), a number of conservative assumptions were used in these models including a dust control 

efficiency of 50 percent for watering of gravel pads and roads where GMT1 used 75 percent for some 

dust control efficiencies via watering (AECOM 2013). Also, it was assumed that drilling, construction, 

and well interventions would all occur during the same 1-hour period for short-term impacts where the 

likelihood of that occurring is minimal for safety and practical purposes. Lastly, a conservative 

assumption worked into the near-field model was monthly averages for vehicle truck traffic where it is 
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known vehicle traffic will vary month to month especially during construction where activities are not 

evenly spread. Best management practices for dust control are discussed later in this section. 

The prevention of significant deterioration increments for Class II areas are shown in Table 97below 

along with the modeled impacts for GMT2 Alternative C’s infill drilling scenario. The infill drilling

scenario was used for a comparison for prevention of significant deterioration increments, because it is 

the only modeling scenario that includes regular routine operation emissions and would be conservative 

because it also includes temporary emissions from drilling and well interventions. 

Table 97. GMT2 Project Alternative C prevention of significant deterioration increments for Class II Areas

Pollutant Average Time Nuiqsut Receptor Class II Increment

NO2 Annual 8.65 μg/m3 25 μg/m3

SO2 3-hour 3.54 μg/m3 512 μg/m3

SO2 24-hour 1.23 μg/m3 91 μg/m3

SO2 Annual 0.087 μg/m3 20 μg/m3

PM10 24-hour 1.35 μg/m3 30 μg/m3

PM2.5 24-hour 3.16 μg/m3 9 μg/m3

PM2.5 Annual 0.027 μg/m3 4 μg/m3

The potential impacts at the Nuiqsut receptor from the Infill Drilling scenario of Alternative C were used 

for comparison to the Class II increments, as the Infill Drilling scenario included emissions from drilling, 

well interventions, and routine operations. The use of the Infill Drilling scenario for this evaluation is 

conservative as it includes emissions from the temporary drilling and well intervention sources, and PSD 

increment analyses generally only include consistent, and continuous routine operations. The potential 

impacts at the Nuiqsut community modeled below 36% of their respective increments. The concentrations 

listed in Table 96 above only include total impacts, so as to be conservative, without background, as PSD 

increment comparison do not include background concentrations in the modeled impacts. There is also a 

prevention of significant deterioration increment for annual PM10 of 17 μg/m3. Since the short-term 

impact at the Nuiqsut receptor for 24-hour PM10 is also below the annual increment, it can also be 

concluded the annual increment for PM10 will model below its increment.

Table 98. GMT2 Project Alternative C near-field hazardous air pollutant impacts summary (μg/m3)

Hazardous Air 

Pollutant

Averaging 

Period Construction

Developmental 

Drilling

Infill 

Drilling

Maximum 

Scenario

Threshold 

Level

Benzene 1-hour 86.33 410.3 107.7 410.3 1,300

Benzene Annual 0.73 1.37 1.74 1.74 30

Toluene 1-hour 83.39 222.5 112.3 222.5 37,000

Toluene Annual 0.69 1.00 0.98 1.00 5,000

Ethylbenzene 1-hour 16.36 50.39 57.02 57.02 350,000

Ethylbenzene Annual 0.14 0.21 0.26 0.26 1,000

Xylenes 1-hour 75.49 54.30 101.0 101.0 22,000

Xylenes Annual 0.59 0.82 0.80 0.82 100

n-Hexane 1-hour 9.11 29.76 1,642 1,642 390,000

n-Hexane Annual 0.075 0.28 2.37 2.37 700

Formaldehyde 1-hour 25.40 12.06 2.29 25.40 55

Formaldehyde Annual 0.23 0.32 0.051 0.32 9.8
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Table 99. GMT2 Project Alternative C Near Field Hazardous Air Pollutant Impacts Summary at the Nuiqsut 

Community Receptor (μg/m3)

Hazardous Air 

Pollutant

Averaging 

Period Construction

Developmental 

Drilling

Infill 

Drilling

Maximum 

Scenario

Threshold 

Level

Benzene 1-hour 3.84 7.71 3.30 7.71 1,300

Benzene Annual 0.0013 0.0035 0.0018 0.0035 30

Toluene 1-hour 3.71 4.18 3.44 4.18 37,000

Toluene Annual 0.0013 0.0026 0.00099 0.0026 5,000

Ethylbenzene 1-hour 0.73 0.95 1.75 1.75 350,000

Ethylbenzene Annual 0.00025 0.00053 0.00027 0.00053 1,000

Xylenes 1-hour 3.36 1.02 3.09 3.36 22,000

Xylenes Annual 0.0011 0.0021 0.00081 0.0021 100

n-Hexane 1-hour 0.41 0.56 50.3 50.3 390,000

n-Hexane Annual 0.00014 0.00072 0.0024 0.0024 700

Formaldehyde 1-hour 1.44 0.30 0.061 1.44 55

Formaldehyde Annual 0.00050 0.00070 0.00018 0.00070 9.8

Benzene Cancer 

Risk - 4.5E-09 1.2E-08 5.9E-09 1.2E-08 1.0E-06

Ethylbenzene 

Cancer Risk - 2.7E-10 5.7E-10 2.9E-10 5.7E-10 1.0E-06

Formaldehyde 

Cancer Risk - 2.8E-09 3.9E-09 1.0E-09 3.9E-09 1.0E-06

Total Cancer 

Risk - 7.6E-09 1.6E-08 7.2E-09 1.6E-08 1.0E-06

The maximum 1-hour and annual hazardous air pollutant impacts for GMT2 Alternative C are 

considerably lower than their respective reference exposure limits and reference concentrations for 

chronic inhalation. For all hazardous air pollutants, except formaldehyde, a conservative unitized run was 

conducted, as described in the near-field air quality impacts analysis (Kleinfelder and Ramboll Environ

2017d). Based on the near-field modeling, the sum of the cancer risks of benzene, ethylbenzene, and 

formaldehyde based on the methodology discussed above (i.e., the potential cancer risk) at the Nuiqsut 

receptor was also determined to be considerably below the cancer risk threshold of 1 in 1 million (EPA 

2006). 

Far-field air quality modeling was conducted for GMT2 Alternative C, the roadless alternative. 

Alternative C was explicitly modeled because operations and construction differ from Alternative A due

to the extra support pad and airstrip resulting in different air emissions. Emissions were estimated for 

each year of the life of the project. The year with highest emissions was selected for each pollutant to 

create a worst-case emissions scenario for CALPUFF modeling. In other words, all emissions activities 

that could occur simultaneously are calculated to estimate the total emissions in a given year. The worstcase emissions year varies for each pollutant. The worst-case year was selected for each pollutant 

modeled together to create a worst-case emissions scenario. For Alternative C, the highest NOx, SO2, and 

PM2.5 emissions occurred when developmental drilling activities predominate, while the highest PM10

emissions occurred when infill drilling activities predominate. Importantly, other activities such as 

construction, well intervention, and routine operations that could also occur simultaneously in the year 

with the highest emissions, are also included in the modeled CALPUFF emissions for Alternative C 

worst-case emissions scenario.A summary of emission rates used in the CALPUFF National Ambient Air 

Quality Standards modeling to estimate project impacts is provided in the far-field air quality impacts 

analysis (Ramboll Environ and Kleinfelder 2017).
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Table 100 and Table 101summarize the predicted maximum concentrations for Alternative C at Arctic 

National Wildlife Refuge and Gates of the Arctic National Park and Preserve, respectively. The modeling 

results indicate that predicted concentrations are all less than 50 percent of the relevant National Ambient 

Air Quality Standards and Alaska Ambient Air Quality Standards and increments.

Table 100. GMT2 Project Alternative C air quality impacts at the Arctic National Wildlife Refuge

Pollutant

Averaging 

Period

Maximum 

Predicted 

Impact 

(μg/m3)

Class II 

Increment 

(μg/m3)

Over 

Increment?

Ambient 

Background 

(μg/m3)

Total 

Concentration 

(μg/m3)

NAAQS/

AAAQS 

(μg/m3)

NO2 1-hour 0.218 -- -- 41.9 42.1 188

NO2 Annual 0.00247 25 No 3.8 3.8 100

SO2 1-hour 0.0018 -- -- 5.9 5.9 196

SO2 3-hour 0.0014 512 No 6.2 6.2 1,300

SO2 24-hour 5.00E-04 91 No 4.8 4.8 365

SO2 Annual 2.57E-05 20 No 0.003 0.003 80

PM10 24-hour 0.0446 30 No 45.2 45.3 150

PM2.5 24-hour 0.0127 9 No 7.3 7.3 35

PM2.5 Annual 8.00E-04 4 No 2.1 2.1 12

Table 101. GMT2 Project Alternative C air quality impacts at Gates of the Arctic National Park and Preserve

Pollutant

Averaging 

Period

Maximum 

Predicted 

Impact 

(μg/m3)

Class II 

Increment 

(μg/m3)

Over 

Increment?

Ambient 

Background 

(μg/m3)

Total 

Concentration 

(μg/m3)

NAAQS/

AAAQS 

(μg/m3)

NO2 1-hour 0.0556 -- -- 41.9 41.9 188

NO2 Annual 0.00121 25 No 3.8 3.8 100

SO2 1-hour 5.00E-04 -- -- 5.9 5.9 196

SO2 3-hour 5.00E-04 512 No 6.2 6.2 1,300

SO2 24-hour 3.00E-04 91 No 4.8 4.8 365

SO2 Annual 1.26E-05 20 No 0.003 0.003 80

PM10 24-hour 0.0222 30 No 45.2 45.2 150

PM2.5 24-hour 0.0062 9 No 7.3 7.3 35

PM2.5 Annual 0.0003 4 No 2.1 2.1 12

The deposition analysis results are shown in Table 102. CALPUFF-predicted maximum nitrogen and 

sulfur deposition fluxes are well below the deposition analysis threshold at both sensitive Class II areas. 
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Table 102. GMT2 Project Alternative C deposition impacts

Class II Area Pollutant

Averaging 

Period

Maximum 

Impact 

(kg/ha-yr)

Deposition 

Analysis 

Threshold

(kg/ha-yr)

% of 

Deposition 

Analysis 

Threshold

Meteorological 

Year of 

Maximum 

Impact

Arctic National Wildlife 

Refuge

Nitrogen Annual 0.0001 0.005 2 2012

Gates of the Arctic 

National Park and 

Preserve 

Nitrogen Annual 0.0001 0.005 2 2010

Arctic National Wildlife 

Refuge

Sulfur Annual 6.60E-06 0.005 0.142 2012

Gates of the Arctic 

National Park and 

Preserve 

Sulfur Annual 3.20E-06 0.005 0.074 2010

Table 103 summarizes the 98th percentile predicted change in visibility at each sensitive Class II area for 

each modeled year. As shown, the highest 98th percentile change in extinction is well below the 0.5 Δdv 

(~5 percent threshold) established by the Federal Land Managers for each year. Thus, GMT2 Project 

impacts on visibility at the two Class II areas would be minimal in Alternative C.

Table 103. GMT2 Project Alternative C visibility impacts

Class II Area

Days 

Exceeding 

1.0 Δdv

Days 

Exceeding 

0.5 Δdv

98th 

Percentile 

Δdv 2009

98th 

Percentile 

Δdv 2010

98th 

Percentile 

Δdv 2011

98th 

Percentile 

Δdv 2012

98th 

Percentile 

Δdv 2013

Arctic National 

Wildlife Refuge

0 0 0.077 0.064 0.074 0.057 0.050

Gates of the 

Arctic National 

Park and 

Preserve 

0 0 0.043 0.033 0.035 0.031 0.031

Alternative D

Alternative D is the no-action alternative and no pollutant air emissions would occur from the GMT2 

Project. Therefore, an emission inventory and subsequent near-field and far-field modeling were not 

completed for GMT2 Alternative D. No air quality impacts are expected in the No Action Alternative. 

Ozone and Secondary PM2.5

Review of the ozone hourly data at the Nuiqsut Monitoring Station shows that of the past 3 years for 

which data were available, the maximum 1-hour value for O3 was 57 ppb, which is 81 percent of the 

current National Ambient Air Quality Standards (SLR International Corporation 2015, 2016, 2017). 

Therefore, these data are in agreement with the USEPA’s designation that the GMT2 Project area is an 

attainment area for O3. Ozone concentrations may at times be influenced by natural events that transport 

ozone rich air from the stratosphere down to the surface (Gregory et al. 1992). These type of events are 

referred to as stratospheric ozone intrusion events. The Alaskan North Slope has minimal O3 diurnal 

variation, and only slight increases in O3 have occurred at the Barrow Monitoring Station indicating that 

Alaskan North Slope regional O3 is not highly sensitive to local increases in ozone precursor emissions of 

NOx and VOCs. The GMT2 Project will increase O3 precursor emissions; however, emissions from the 

GMT2 Project and other reasonable foreseeable developments are also not expected to meaningfully 

change regional O3 levels. A detailed discussion in existing ozone background and potential GMT2 
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Project impacts on regional O3 is found in the near-field GMT2 air quality impacts analysis (Kleinfelder 

and Ramboll Environ 2017d). 

Secondary formation of PM2.5 impacts are not in the same place and at the same time as primary PM2.5

impacts, as secondary PM2.5 impacts usually occur at a later time and at greater distances from the source 

than primary impacts because of the time required for complex chemical reactions to occur in the 

atmosphere. Accordingly, secondary PM2.5 impacts are much less than primary impacts. As detailed in 

Table 84, Table 85 and Table 96 for the near-field and Table 91, Table 92, Table 102, and Table 103 for 

the far-field, all PM2.5 standards in all modeling scenarios are less than the National Ambient Air Quality 

Standards and Alaska Ambient Air Quality Standards under Alternative A and Alternative C. Since 

Alternative A impacts results are representative of Alternative B, it can also be concluded that Alternative 

B impacts are also below the PM2.5 standards. Currently, all areas in the Alaskan North Slope are in 

attainment for PM2.5. Therefore, secondary PM2.5 impacts will be less than primary impacts that are not 

modeled to exceed current thresholds. NOx is also a known precursor for secondary PM2.5. EPA notes that 

in the Alaskan North Slope, actual NOx emissions from facilities near Deadhorse are on the order of 

magnitude of 65,000 tons per year and yet primary and secondary PM2.5 concentrations are low (AECOM 

2013). Since the total of GMT2 Project onsite project sources, offsite project sources, and non-project 

cumulative sources will result in NOx emissions well below 65,000 tons per year, it can be concluded that 

the GMT2 Project will also have minimal, if any, impacts on secondary PM2.5 formation. A detailed 

discussion in existing PM2.5 background and potential GMT2 Project impacts on secondary PM2.5

formation is found in the near-field air quality impacts analysis (Kleinfelder and Ramboll Environ 

2017d). 

Mitigation

Best management practices and best available control technology will be implemented by ConocoPhillips 

for GMT2 construction, drilling, and routine operations in order to reduce project-related emissions and 

therefore impacts on the GMT2 Project area. Below are a list of potential mitigation measures that are 

proven emission reduction strategies and technologies that will be evaluated by BLM for adoption in its 

Record of Decision. 

Potential Mitigation Measure 1 — Warm Building for vehicle storage 

Objective: Reduce air quality impacts from idling vehicles

Requirement/Standard: Construct building with sufficient size and capacity to heat vehicles to reduce 

the amount of idling vehicles. 

Potential Benefits and Residual/Unavoidable Impacts: Actions taken to minimize impacts to air 

quality will assist with minimizing impacts to overall human health by reducing the potential sources of 

exposure that local residents may experience. Could reduce emissions by reducing numbers of idling 

vehicles. Would add to the footprint of the development, potentially increasing construction emissions. 

May concentrate emissions from numerous vehicles in a single area that would otherwise be distributed 

by moving vehicles throughout the project area.

Potential Mitigation Measure 2—Minimize methane waste 

Objective: Reduce air emissions of methane and protect human health and the environment.

Requirement/Standard: Measurement and reporting of all natural gas waste from venting, flaring and 

leaks. A methane waste capture plan would be developed and submitted with the APD. Also, 

ConocoPhillips would implement a leak detection and repair (LDAR) program in order to conduct 

preventative maintenance. Using either a Method 21 instrument such as a photo ionization detector or 
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flame ionization detector or an optical gas imaging instrument such as a FLIR camera, inspections shall 

be conducted on a regular schedule to identify leaks and the need for repairs. As an additional measure of 

preventative maintenance, there should also be regular auditory, visual, and olfactory inspections.

Potential Benefits and Residual/Unavoidable Impacts: These preventative maintenance procedures 

will reduce the potential for hydrocarbon emissions such as VOC, hazardous air pollutants, and CH4. 

These measures might also prevent or lessen the impacts of a potentially significant major unintentional 

release of material. This measure would also improve worker safety through reduction of accidental 

releases. The proponent would incur financial and man-power costs due to purchase of capital assets and 

necessary on-going labor to conduct this program.

As of this writing, it is not known how BLM’s 2016 Methane Waste Prevention Rule might impact this 

mitigation measure due to on-going litigation.

Potential Mitigation Measure 3—Use of Alternative Fuels (new subparagraph to BMP A-10)

Objective: Prevent unnecessary or undue degradation of the lands and protect health and ensure 

effectiveness of previously required mitigation measures. 

Requirement/Standard: To the extent practicable, all oil and gas operations (vehicles and equipment) 

must be powered by natural gas or electric power rather than diesel fuel. To the extent natural gas and 

electric power are not practicable, the permittee will use gasoline rather than diesel to the extent 

practicable. Any vehicles and equipment that require diesel fuel must use ULSD as defined by the Alaska 

Department of Conservation, Division of Air Quality. ConocoPhillips will provide an annual report 

beginning one year after the ROD date to BLM Arctic District Office and BLM Alaska State Office Air 

Program lead reporting their use of and feasibility of natural gas, electric and gasoline powered 

equipment.

Potential Benefits and Residual/Unavoidable Impacts: Natural gas has fewer impurities, is less 

chemically complex, and generally results in less pollution when combusted than diesel fuel. In most 

applications, using natural gas produces less CO2, SO2, and particulate matter, than diesel fuel, resulting 

in reduced health risks from fuel combustion in equipment associated with oil and gas operations. Natural 

gas is an available fuel for stationary combustion sources on the North Slope; however, vehicle fueling 

with natural gas may not be currently feasible due to a lack of infrastructure and availability of 

appropriate vehicles. Where use of natural gas is not practicable, use of gasoline generally results in less 

pollution when combusted than diesel fuel. Use of natural gas-generated electric power to operate GMT1 

sources, rather than diesel-fired electric power generation, is environmentally beneficial. Reporting 

requirements will allow BLM to evaluate the effectiveness of this mitigation measure.

Potential Mitigation Measure 4—Implementation of Air Quality Monitoring Data (new 

subparagraph to BMP A-10)

Objective: Provide BLM oversight and technical review of air quality monitoring near the GMT2

project; address concerns in the local community regarding oversight of air quality.

Requirement/Standard: 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 BLM, the State, NSB, and the local 

community and tribal government pursuant to BMP A-10(h). The permittee is required to provide funding 

for BLM technical review of these documentsvia an ongoing cost reimbursement agreement. BLM may 

elect to have a contractor or another agency perform the technical review. Permittee will begin providing 

quarterly monitoring reports beginning at the end of the first quarter of calendar year 2019. The format 
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and exact content of the reports as well as the cost reimbursement agreement will be negotiated with 

permittee by January 30, 2019.

Potential Benefits and Residual/Unavoidable Impacts: Members of the public have expressed concern 

over air quality in the project vicinity. Providing for a technical BLM review of the monitoring results 

provides certainty for 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.

Potential Mitigation Measure 5-- Electrification 

Objective: To the extent possible, power on-site combustion sources with electricity rather than fossil 

fuels.

Requirement/Standard: Under all GMT2 Alternatives, it is expected that grid power will be available 

for electric support at the GMT2 drill pad. The onsite pad generator is expected to be used for emergency 

purposes only when grid power is not available. Power lines will be installed between GMT2 and nearby 

power generation facilities and should be relied upon in place of fossil-fuel combustion equipment.

Potential Benefits and Residual/Unavoidable Impacts: Will reduce on-site emissions from combustion 

sources. There will be some combustion sources that cannot be electrified, so there will be some residual 

combustion source emissions. May increase emissions from the source generating electricity for the site.

Potential Mitigation Measure 6: Require Near Real Time Monitoring to Prevent Excess 

Emissions of Regulated Air Pollutants

Objective: Protect human health and the environment.

Requirement/Standard: To get real-time and site-specific data, ConocoPhillips should implement a 

telemetry monitoring system to provide effective management of production exceptions, while reducing 

the number of vehicle trips and miles traveled. In addition to the current ConocoPhillips-operated Nuiqsut 

Monitoring Station, other monitoring systems should include supervisory control and data acquisition to 

monitor for malfunctioning equipment and production exceptions. 

Potential Benefits and Residual/Unavoidable Impacts: These types of continuous monitoring systems 

would reduce the need for regular site inspections, reducing onsite truck traffic, and would alert field 

personnel of emission exception events in real-time therefore reducing emissions to the atmosphere that 

otherwise would have gone unnoticed.

Potential Mitigation Measure 7-- Air Quality Monitoring

Objective: Increase air quality monitoring to better determine actual impacts from development

Requirement/Standard: Due to the concern over ambient air in the GMT2 Project area and near 

Nuiqsut, and in line with the NPR-A Final Record of Decision BMP A-10 (BLM 2013a) to reduce

unnecessary and undue degradation of the land and protect health, additional air quality monitoring will 

be required at the GMT2 pad. Permittee will begin air quality monitoring beginning after pad and road 

construction but before additional development (assumed to begin in January 2020). Permittee will set up 

the monitoring station as a telemetry monitoring system and will provide annual reports to BLM on air 

quality monitoring results. Data and reports will be provided through the end of the drilling phase of the 

GMT2 Project. Permittee should consider using a mobile air quality monitoring system similar to the 

BLM Wyoming Air Resource Monitoring System.
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Potential Benefits and Residual/Unavoidable Impacts: There is very little ambient air quality 

monitoring data currently on the North Slope and in the vicinity of recent development. A telemetry 

monitoring system will allow permittee to take actions to reduce emissions in the event of an emissions 

exception, as well as provide BLM land managers useful air quality data to evaluate air strategy 

effectiveness. A mobile station will allow the permittee to move the air quality monitoring system to new 

developments as they are permitted. 

Potential Mitigation Measure 8: Use ofTier 4 eEgines

Objective: Reduce air quality impacts from diesel engines

Requirement/Standard: When possible, the use of Tier 4 diesel engines instead of Tier 2 or Tier 3 

engines should be operated in the field for drill rigs, completion rigs, generators, and other diesel-fired 

engines. 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. 

Potential Benefits and Residual/Unavoidable Impacts: 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.

Potential Mitigation Measure 9-- Selective and non-selective catalytic reduction devices: 

Objective: Reduce emissions from combustion sources

Requirement/Standard: For engines, heaters, and other combustion devices, selective and nonselective catalytic reduction devices should be used to reduce criteria and hazardous air pollutant 

emissions such as NOx, CO, VOC, and formaldehyde, when feasible. Some selective catalytic reduction 

devices inject ammonia into the exhaust to reduce NOx emissions; however, these types of devices should 

be avoided to prevent ammonia emissions.

Potential Benefits and Residual/Unavoidable Impacts: A reduction in combustion source emissions 

would result, commensurate with the number of devices that can be used. Impacts to local air quality 

would decrease as well as impacts to air quality and AQRVs at Federal Class II areas.

Potential Mitigation Measure 10-- Flaring or closed-loop systems 

Objective: Reduce greenhouse gas emissions

Requirement/Standard: CH4, a greenhouse gas, is the primary constituent of natural gas. Instead of 

venting natural gas during hydraulic fracturing or pigging operations, flaring will reduce VOC, hazardous 

air pollutant, and CH4 emissions. 

Potential Benefits and Residual/Unavoidable Impacts: Combustion emissions from flaring, in 

result, increase pollutant levels of NOx, CO, and CO2. Overall greenhouse gas impacts would go down 

since the global warming potential of CH4 is 25 times greater than CO2. The hydrocarbon destruction 

efficiency of most flares is upwards of 95 percent. Also, a closed-loop system with 100 percent capture by 

re-routing gas from hydraulic fracturing or pigging operations to a sales line or onsite process results in 

no additional emissions to the atmosphere.
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Potential Mitigation Measure 11-- Use of no-bleed or low-bleed pneumatic devices 

Objective: Reduce hydrocarbon emissions

Requirement/Standard: In place of high-bleed or intermittent-bleed pneumatic devices for pressure, 

temperature, or liquid level control, no-bleed and low-bleed pneumatic devices should be installed, if 

feasible.

Potential Benefits and Residual/Unavoidable Impacts: No-bleed and low-bleed pneumatic 

devices will reduce hydrocarbon emissions, such as those of VOC, hazardous air pollutant, and 

CH4 pollutants. Low-bleed pneumatic devices are classified as those with a bleed rate less than 

6 standard cubic feet per hour (scfh). No-bleed pneumatic devices are those that are 

mechanically driven or solar-powered instead of powered by natural gas. Conclusions

The emissions and impacts analysis discussed above detail the methodology, procedures, and results of 

the GMT2 Project impacts in the near-field and far-field. The following conclusions were drawn from the 

emissions and modeling analysis as it relates to the GMT2 Project.

• The GMT2 Project criteria pollutant emissions for Alternatives A, B, and C, except for PM10 and 

PM2.5, are highest during its developmental drilling phase (Year 3 of the Project). PM10 and PM2.5

show highest annual emissions during Year 2 of the project, the construction phase.

• GMT2 Project routine operations emissions are calculated to be below major source thresholds, 

making GMT2 a minor source under the Clean Air Act. 

• Construction Schedule 1 would result in higher impacts than Construction Schedule 2, because the 

activities are compacted into 2 years compared to 3 years under Construction Schedule 2. Therefore, 

the dispersion modeling analysis was done on Construction Schedule 1 and is a conservative estimate 

of Construction Schedule 2.

• Near-field modeling demonstrates GMT2 Project impacts below the National Ambient Air Quality 

Standards and Alaska Ambient Air Quality Standards for all criteria pollutants and averaging periods 

for all Alternative A and C modeling scenarios.

• Alternative A near- and far-field impacts are considered representative of Alternative B, as their 

location, operations, and emissions are similar. 

• Near-field modeling demonstrates GMT2 Project maximum impacts are below the reference exposure 

limit and reference concentration for chronic inhalation thresholds for hazardous air pollutants for all 

alternatives’ modeling scenarios.

• Near-field modeling demonstrates GMT2 Project impacts will not cause a cancer risk above the 1 in 1

million threshold at the Nuiqsut community.

• Far-field modeling demonstrates potential impacts from the GMT2 Project are minimal at the nearest 

Class II areas: Gates of the Arctic National Park and Preserve and the Arctic National Wildlife 

Refuge. All potential impacts were much less than 50 percent of the applicable evaluation thresholds 

of the National Ambient Air Quality Standards and Alaska Ambient Air Quality Standards, prevention 

of significant deterioration Class II increments, and air quality related values. 

For a direct comparison between GMT2 Alternatives, summary Table 104 through Table 107 show the 

comparison of criteria pollutants, total hazardous air pollutants, and greenhouse gas pollutant emissions in 

CO2e for each emission inventory category of the GMT2 Project. As detailed in the tables, Alternative B 

emissions for each of the pollutants are slightly higher or equal to Alternative A. This is largely due to the 

longer access road resulting in additional construction (Table 104) and increased truck travel for drilling 

and operational activities (Table 105 through Table 107). For Alternative C, emissions are higher 
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compared to Alternatives A and B, since more operations will take place on or near the GMT2 Pad. 

Additional emissions would result from the construction of the occupied structure pad and airstrip. Since 

waste processing and air travel will be onsite along with additional ice road travel during drilling and 

routine operations, combustion emissions during developmental drilling, infill drilling, and routine 

operations are higher in comparison to other alternatives. Despite the shorter access road in Alternative C 

compared to Alternatives A and B, the increased acreage of the GMT2 Project area results in higher PM 

emissions during routine operations. Alternative D, as the no-action alternative, will result in no project 

emissions. 

Comparing routine operations emissions (Table 104) of GMT2 Alternatives A, B, and C, Alternative A has 

the lowest consistent, regular criteria, hazardous air, and greenhouse gas pollutant emissions. Alternative 

B’s emissions are slightly higher due to the additional truck mileage to travel to the GMT2 Pad compared 

to Alternative A. Alternative C’s emissions are roughly two to six times higher than Alternative A due to 

more ice road travel, waste processing, air travel, and wind erosion. 

Table 104. Maximum construction emissions for each GMT2 Alternative (Year 2)

Pollutant Alternative A Alternative B Alternative C Alternative D

NOx (tons per year) 89.0 93.3 104.0 0.0

CO (tons per year) 45.4 47.1 54.8 0.0

VOC (tons per year) 15.1 15.5 18.3 0.0

PM10 (tons per year) 193.0 212.0 290.0 0.0

PM2.5 (tons per year) 23.7 25.9 34.7 0.0

SO2 (tons per year) 0.19 0.20 0.22 0.0

Total hazardous air pollutants 

(tons per year)

2.0 2.1 2.3 0.0

Greenhouse Gases in CO2e (tons 

per year)

27,030 28,667 32,595 0.0

Table 105. Maximum developmental drilling emissions for each GMT2 Alternative (Year 3)

Pollutant Alternative A Alternative B Alternative C Alternative D

NOx (tons per year) 119.0 121.0 145.0 0.0

CO (tons per year) 77.5 78.3 123.0 0.0

VOC (tons per year) 20.9 21.0 27.3 0.0

PM10 (tons per year) 116.0 119.0 74.4 0.0

PM2.5 (tons per year) 17.8 18.2 18.0 0.0

SO2 (tons per year) 0.34 0.34 0.66 0.0

Total hazardous air pollutants 

(tons per year)

1.4 1.4 2.5 0.0

Greenhouse Gases in CO2e (tons 

per year)

41,545 42,739 56,851 0.0
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Table 106. Maximum infill drilling emissions for each GMT2 Alternative (Year 4)

Pollutant Alternative A Alternative B Alternative C Alternative D

NOx (tons per year) 87.2 87.2 97.6 0.0

CO (tons per year) 63.7 64.4 109.0 0.0

VOC (tons per year) 16.2 16.4 22.1 0.0

PM10 (tons per year) 58.8 62.4 57.9 0.0

PM2.5 (tons per year) 10.6 11.0 14.7 0.0

SO2 (tons per year) 0.45 0.46 0.79 0.0

Total hazardous air pollutants 

(tons per year)

0.40 0.43 0.97 0.0

Greenhouse Gases in CO2e (tons 

per year)

32,276 32,222 38,087 0.0

Table 107. Maximum routine operations emissions for Each GMT2 Alternative 

Pollutant Alternative A Alternative B Alternative C Alternative D

NOx (tons per year) 8.9 8.9 17.6 0.0

CO (tons per year) 6.4 7.1 17.0 0.0

VOC (tons per year) 8.0 8.1 11.2 0.0

PM10 (tons per year) 5.3 6.2 26.9 0.0

PM2.5 (tons per year) 1.2 1.2 7.1 0.0

SO2 (tons per year) 0.21 0.21 0.31 0.0

Total hazardous air pollutants 

(tons per year)

0.10 0.13 0.18 0.0

Greenhouse Gases in CO2e (tons 

per year)

5,687 5,705 10,406 0.0

4.2.3.3 Acoustical Environment

Potential impacts of project-related noise on the acoustical environment and noise-sensitive receptors in 

the project area were evaluated in BLM (2004, Section 4F.2.3.3), addressed in the recent GMT1 

Supplemental EIS (BLM 2014, Section 4.2.3.3), and further addressed in resource-specific sections of 

those documents and for NPR-A generally in BLM (2012, Section 4.4.21.2 and other sections). The Point 

Thomson Final EIS (U.S. Army Corps of Engineers 2012, Appendix O) also presented a thorough 

modelling analysis of potential impacts of that larger development project on the acoustical environment 

and sensitive receptors in a similar coastal plain environment. 

For the purpose of the following analysis, noise-sensitive receptors include people and wildlife that would 

be exposed to noise generated by project activities. Nuiqsut is the community nearest to the proposed 

project, located approximately 17 miles east of the proposed GMT2 pad; 15 miles east of the proposed 

GMT2 airstrip (Alternative C); approximately 7 miles south of the Alpine airstrip that would support 

project-related aviation activities; within approximately 11 (Alternative B) to 13 miles (Alternative A) of 

proposed new road and pipeline construction; within 1 to 3 miles of ice roads that would be used in 

support of the project; and approximately 4.5 miles west of the Arctic Slope Regional Corporation gravel 

mine where blasting and other mining activities would occur in support of the project. Local residents 

also travel widely throughout the project area beyond Nuiqsut, where they engage in a variety of 

subsistence activities. Additional information concerning noise impacts on Nuiqsut residents and 

subsistence users is presented in Section 4.4.5, “Subsistence.” 

Project activities that have the potential to impact the acoustical environment and sensitive receptors 

include: 
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• Mining of gravel to support construction;

• Construction of gravel pads, roads, and airstrip;

• Construction of ice roads and pads;

• Construction of pipelines;

• Construction of on-site facilities;

• Drilling;

• Operation of production and processing facilities;

• Operation of trucks and other large vehicles on roads and pads for site access and transportation of 

personnel, equipment, and other materials;

• Operation of aircraft (including overflights, landings, and take-offs) for site access and transportation 

of personnel, equipment, and other materials; and

• Operation of aircraft to support monitoring, other environmental studies, and clean-up activities.

Methodology

This analysis relies on reported noise levels generated by sources and activities similar to those included 

in one or more of the project alternatives under consideration (Table 28). Noise and ambient sound data 

are very limited for the project area, so it is necessary for purposes of impact analysis to rely on relevant 

proxy data obtained from published reports or other sources. In selecting this proxy data, preference is 

given to those data which are accompanied by clear specification of the measurement distance because 

sound levels attenuate rapidly with increasing distance from the source, and because of the importance of 

attenuation for assessing potential impacts. Also, because sound levels are inherently variable in time and 

can be described quantitatively by a large number of acoustical metrics that in some way account for 

temporal variability, preference is given to those data which also are accompanied by specification of the 

acoustical metric and measurement period. 

The analysis also relies on the simplifying assumption that noise levels generally attenuate by 6 dBA with 

each doubling of distance from the source, although the accuracy of this approach declines with 

increasing distance due to effects of meteorological conditions, land-surface characteristics, and the 

potential presence of acoustical barriers including structures and topographic features. Wind conditions 

and vertical temperature gradients may contribute to the attenuation of noise levels by up to 5 to 20 dB or 

may enhance noise levels by up to 1 to 5 dB (Attenborough 2014) relative to estimates based on distance 

alone. Greater consideration of these factors would require modelling analyses such as those conducted in 

support of the Point Thomson EIS (U.S. Army Corps of Engineers 2012, Appendix O). 

In evaluating potential impacts of project-related noise on people and wildlife, it is necessary to consider 

noise levels in relation to existing ambient sound levels at the location of the receptor. Table 108 presents 

examples to illustrate how the effects of project-related noise on overall noise levels and the relative 

audibility of project noise are dependent on the ambient sound level that exists at the location of the 

receptor. Project noise that is 10 or more dBA below the existing ambient sound level likely would be 

inaudible to the human ear, and noise that is approximately equal to existing ambient would only be 

marginally or slightly audible, depending on the hearing capabilities of the individual receptor. If project 

noise is 10 dBA or greater above existing ambient, then project noise becomes the dominant element of 

the acoustical environment. Project noise with a level of 40 dBA would be readily audible in a setting 

with an existing ambient sound level of 35 dBA or less, but likely would be inaudible in a setting where 

the existing ambient sound level is 50 dBA or more. In reference to Table 108 and its applicability to 

impact analyses, it is important to note that the relative audibility of different types and levels of sound is 

species specific, contingent on species’ sensitivity to and perception of different sound frequencies and 

amplitudes (Fletcher 2014). As a result, a noise that is relatively inaudible to a human receptor may be 

readily audible and potentially impactful to a wildlife receptor, dependent on the species and context of 

the noise.
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Table 108. Relative audibility of project-related noise levels in relation to different ambient sound levels 

Existing Ambient 

Sound Level 

(dBA)

Project-Related 

Noise Level (dBA)

Ambient Sound 

Level + Project 

Noise Level 

(dBA)

Noise Level 

Increase Above 

Ambient Sound 

Level (dBA) Relative Noise Audibility

35a 20 35.1 0.1 Likely inaudible

35 25 35.4 0.4 Likely inaudible

35 30 36.2 1.2 Marginally audible

35 35 38.0 3.0 Slightly audible

35 40 41.2 6.2 Audible

35 45 45.4 10.4 Audible and dominant

35 50 50.1 15.1 Audible and dominant

35 55 55.0 20.0 Audible and dominant

50b 30 50.0 0.0 Inaudible

50 35 50.1 0.1 Likely inaudible

50 40 50.4 0.4 Likely inaudible

50 45 51.2 1.2 Marginally audible

50 50 53.0 3.0 Slightly audible

50 55 56.2 6.2 Audible

50 60 60.4 10.4 Audible and dominant

50 65 65.1 15.1 Audible and dominant

50 70 70.0 20.0 Audible and dominant

a Characteristic value for natural ambient sound level in the project area in the absence of high winds (see Section 3.2.3.3). 

b Estimate for a characteristic ambient sound level in a natural setting with moderate winds or running water, or during daytime in a 

village setting in the absence of high noise levels attributable to other sources such as off-road vehicles, snowmobiles, aircraft, or 

truck traffic.

The analysis places emphasis on those activities that have the potential to generate the greatest overall 

impacts on the acoustical environment and sensitive receptors due to noise intensity, duration, context, 

and/or geographic extent.

Construction

Several activities during construction have the potential to generate noise that may impact the acoustical 

environment and noise-sensitive receptors. These include gravel mining, operation of vehicles and various 

other types and combinations of mechanized equipment, and aircraft operations. 

The existing Arctic Slope Regional Corporation gravel mine east of the Colville River would be the 

source of gravel for project-related construction. The mining permit issued by the U.S. Army Corps of 

Engineers requires that blasting, excavation, and other high-noise activities not be conducted from 20 

May through 1 August to avoid disturbances to spectacled eiders during pre-nesting and nesting seasons. 

Blasting to support gravel needs for the GMT2 Project would be audible in Nuiqsut (4.5 miles from mine 

site), with noise levels potentially as high as 110 dB depending on meteorological conditions and the size 

and type of charge (Table 109). Contingent on these factors, blast noise could exceed 100 dB more than 

10 miles from the source and up to 4 miles into NPR-A, and potentially could be audible more than 20 

miles from the source. Other excavation-related activities are not likely to be audible in Nuiqsut, as noise 

generated by one to five pieces of heavy equipment at the mine site would be expected to attenuate to a 

level less than ambient before reaching Nuiqsut 4.5 miles away (Table 109). Due to blast noise, overall 

impacts of gravel mining on the acoustical environment would be of high intensity and regional extent, 
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but temporary. Noise impacts attributable to gravel mining would be expected to vary among the action 

alternatives, with Alternative A having the least impacts and Alternative C having the greatest impacts due 

to differences in total gravel requirements (Table 70).
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Table 109. Estimated project-related noise levels (in dBA, unless otherwise noted) received at Nuiqsut and at distances 1 to 10 miles from the noise 

sourcea

Noise Source and Location

Estimated

Noise 

Level at 

1,000-ft 

Distance 

(dBA)

Distance 

of 

Source 

Location 

from 

Nuiqsut 

(mi)

Estimated

Noise 

Level at 

Nuiqsut 

(dBA)

Estimated

Noise 

Level,

1.0 mi 

from 

Source 

(dBA)

Estimated

Noise 

Level,

2.5 mi 

from 

Source 

(dBA)

Estimated

Noise 

Level,

5.0 mi 

from 

Source 

(dBA)

Estimated

Noise 

Level,

7.5 mi 

from 

Source 

(dBA)

Estimated

Noise 

Level,

10.0 mi 

from 

Source 

(dBA)

Blasting, Arctic Slope Regional Corporation gravel 

mine b

140.3 4.5 112.8 125.8 117.9 111.9 108.3 105.9

Drill rig, GMT2 pad, maximum noise level b 84.4 17 45.3 69.9 62.0 56.0 52.4 50.0

Drill rig, GMT2 pad, median noise level b 52.4 17 13.3 37.9 30.0 24.0 20.4 18.0

C-130, Alpine airstrip c 76.7 7 45.3 62.2 54.3 48.3 44.7 42.3

C-130, GMT2 airstrip c 76.7 15 38.7 “ “ “ “ “

Helicopter, Alpine airstrip b 66.7 7 35.3 52.2 44.3 38.3 34.7 32.3

Helicopter, GMT2 airstrip b 66.7 15 28.7 “ “ “ “ “

Propeller (single & twin engine), Alpine airstrip b 65.2 7 33.8 50.7 42.8 36.8 33.2 30.8

Propeller (single & twin engine), GMT2 airstrip b 65.2 15 27.2 “ “ “ “ “

Construction or heavy vehicle traffic, 5 pieces of 

equipment b

62.0 1 

(minimum 

distance)

47.5 47.5 39.6 33.6 30.0 27.6

Construction or heavy vehicle traffic, 3 pieces of 

equipment b

59.8 1 

(minimum 

distance)

45.3 45.3 37.4 31.4 27.8 25.4

Construction or heavy vehicle traffic, 1 piece of 

equipment b

55.0 1 

(minimum 

distance)

40.5 40.5 32.6 26.6 23.0 20.6

a Estimates assume noise attenuation of 6 Decibels (dBA) per doubling of distance from source and do not account for potential effects of meteorological conditions, sound barriers, 

and landscape characteristics.

b See Table 28 for noise-measurement details.

c Estimates presented for a C-130 are assumed to generally represent DC-6 noise levels (no DC-6 data were discovered). Noise estimates are for a C-130 in level flight at 180 knots 

(see Table 28for details) and are expected to be lower than noise levels generated during take-off and landing phases at Alpine and GMT2 airstrips.
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Excluding mine blasts and aircraft, noise levels generated by other construction activities would be 

expected to attenuate to 35 dBA or lower within 2.5 to 5 miles from the noise sources, depending on 

meteorological conditions and the number and specific types of heavy equipment pieces or vehicles that 

are operated simultaneously in close proximity. For example, maximum noise levels emitted by one 

typical piece of construction equipment would be estimated to attenuate to 35 dBA at a distance of 1.9 

miles from the source, whereas noise generated by simultaneous operation of five pieces of heavy 

equipment would be estimated to attenuate to 35 dBA at a distance of 4.2 miles (Table 28). Equipment 

operation on the ice road proposed for construction just northwest of Nuiqsut could contribute to higher 

noise in the village, but the increase in noise level might only be marginally audible to residents if 

ambient noise levels in the village are 50 dBA or greater (compare construction noise data in Table 

109with Table 108). In close proximity to equipment operations (e.g., within 1 mile), construction noise 

could dominate the acoustical environment for the duration of the construction activity, assuming a 

natural ambient sound level of 35 dBA in the absence of construction noise. Overall impacts of 

construction noise on the acoustical environment would be of high intensity and local extent, but would 

be temporary and would attenuate to low intensity with increasing distance from the source. Potential 

impacts of temporary construction noise on wildlife would be expected to vary by species, timing, and 

behavioral context, and could result in or contribute to local avoidance and displacement, but would be 

unlikely to result in population-level impacts. To the degree that construction noise causes or contributes 

to local changes in patterns of wildlife movement and distribution, such changes would have the potential 

to impact subsistence users. Noise impacts attributable to construction activities would be expected to 

vary among the action alternatives, with Alternative A having the least impacts and Alternative C having 

the greatest impacts due to differences in total gravel footprint (Table 70). In addition, total vehicle trips 

and vehicle miles are projected to be higher for Alternative C than for Alternatives A and B, which would 

be expected to result in a greater overall amount of vehicle-related noise in Alternative C. 

Proposed aircraft operations during the construction phase of the project include transport of cargo into 

the Alpine airstrip by Twin Otter (DHC6) and CASA twin-engine (2E) turboprop aircraft (Alternatives A 

and B), transport of cargo by DC-6 (primarily) and C-130 four-engine (4E) aircraft into the GMT2 airstrip 

(Alternative C), transport of personnel into GMT2 by Twin Otter/CASA aircraft and helicopters 

(Alternative C), and helicopter flights into the project area in support of required special studies, 

monitoring, and ice-road clean-up (all alternatives). Potential impacts of aircraft noise vary according to 

the type of aircraft, the phase of aircraft operations (i.e., take-off and landing versus level flight), the 

location (Alpine and GMT2 airstrips, versus pipeline and ice-road corridors, versus in-transit flight paths 

and dispersed locations of special studies), and timing of aircraft operations in relation to locations and 

activities of noise-sensitive receptors, and flight altitude above ground level. Aircraft noise generated 

during landing, take-off, and climb-out generally is greater than noise generated during level flight, but 

the following analysis assumes that noise estimates for level flight provide a reasonable basis for 

evaluating potential aircraft noise impacts. No noise estimates were located for DC-6 aircraft, so the 

analysis also assumes that estimates of C-130 noise are generally representative of DC-6 noise levels. 

These two are discussed together as 4E cargo aircraft. 

The existing Alpine airstrip and the proposed GMT2 airstrip would be specific point sources of projectrelated noise generated by landing and take-off operations of 2E and 4E cargo aircraft and helicopters. 

Nuiqsut is approximately 7 miles from the Alpine airstrip and 15 miles from the proposed location of the 

GMT2 airstrip. Depending on meteorological conditions, noise generated by 4E cargo aircraft at Alpine 

would be expected to attenuate to approximately 45 dBA at Nuiqsut (Table 108), whereas noise generated 

by helicopters and 2E cargo aircraft would attenuate to approximately 34-35 dBA. Assuming an ambient 

noise level of 50 dBA in Nuiqsut, noise from 4E aircraft at Alpine could be marginally audible in the 

village, but noise from helicopters and 2E aircraft likely would be inaudible under most conditions. 

Depending on meteorological conditions and the ambient noise level at the time, noise generated by 4E 

aircraft operations at Alpine and GMT2 airstrips could temporarily dominate the acoustical environment 
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for a distance of 5 to 7.5 miles from the airstrips, and noise generated by helicopters and 2E aircraft could 

temporarily dominate the acoustical environment for a distance of 1 to 2.5 miles. 

During transit flights, the intensity of aircraft noise received by a receptor on the ground is affected by the 

aircraft’s flight altitude above ground level as well as by the distance from the ground trace of the 

aircraft’s flight path to the location of the receptor5

. Flight altitudes relevant to project-related aircraft 

operations are less than 3,000 feet. At these relatively low flight altitudes, altitude is a strong determinant 

of aircraft noise levels only within a distance of about 0.5 miles from the ground trace of the flight path. 

For example, the ground-level noise from an aircraft flying directly overhead at 3,000-foot altitude is 

estimated to be 21.5 dBA less than noise from an aircraft flying overhead at 250-foot altitude, 

independent of the type of aircraft and not accounting for meteorological conditions. But at a distance of 

0.5 miles from the ground trace, the corresponding difference in noise levels due to flight altitude is only 

3.5 dBA, a difference which would be only marginally detectable. This pattern has implications for 

assessment and mitigation of aircraft noise impacts. 

Noise generated by 4E aircraft in transit could temporarily dominate the acoustical landscape for a 

distance of about 5 to 7.5 miles from the ground trace and could be audible for more than 10 miles from 

the ground trace, assuming an ambient sound level of approximately 35 dBA. Noise generated by 

helicopters and 2E aircraft could temporarily dominate the acoustical environment for a distance of about 

1 to 2.5 miles from the ground trace and could be audible up to 5 miles from the ground trace. Within 

about 0.5 mile of the ground trace, aircraft noise levels and impact intensity would increase significantly 

with decreasing flight altitude. Project-related aircraft activity during the construction phase also would 

be expected to increase the frequency and total number of aircraft noise events for locations within 5 to 

7.5 miles of ground traces of 4E cargo aircraft and within 1 to 2.5 miles of ground traces of helicopters 

and 2E cargo aircraft. 

Overall impacts of aircraft noise on the acoustical environment would be of high intensity and regional 

extent, but would be temporary and would attenuate to low intensity with increasing distance from the 

source. This would be the case for concentrated locations of aircraft activity (Alpine airstrip and proposed 

GMT2 airstrip), for dispersed landing sites, and for linear zones of audible aircraft noise centered along 

ground traces of aircraft flight paths. 

As with noise generally, wildlife responses to aircraft noise vary among species and can depend on 

several non-acoustical factors. Caribou have been found to be relatively sensitive to low-altitude (less 

than 300 feet) helicopters (Harrington and Veitch 1991) and fixed-wing aircraft (Valkenburg and Davis 

1983), with evidence that noise and visual stimuli both affect the way in which caribou respond to the 

aircraft (literature cited by Anderson [2007]). Snow geese, black brant, and greater white-fronted geese 

also have been found to respond to low-altitude aircraft (literature cited by Anderson [2007]). Disturbance 

by aircraft noise has the potential to cause or contribute to local changes in movement and distributional 

patterns of caribou, waterfowl, and other wildlife, but would be unlikely to result in population-level 

impacts. To the degree that aircraft noise does trigger wildlife responses, altered patterns of movement 

and distribution would have the potential to impact subsistence users. Noise impacts attributable to 

aircraft operations during the construction phase would be greater for Alternative C than for Alternatives 

A and B due to much higher levels of aircraft use in the absence of gravel access roads in Alternative C. 

 5 Geometrically, flight altitude and distance to ground trace can be conceptualized as two perpendicular sides of a right triangle, 

with the hypotenuse of the right triangle formed by a line representing the line-of-sight distance from the noise receptor to the 

airborne aircraft, referred to as slant distance. Slant distance is the distance used to estimate attenuation of noise from airborne 

aircraft.
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Drilling and Operation

During drilling and operations phases of the project, activities that would generate noise and have the 

potential to impact the acoustical environment and sensitive receptors include drilling, operation of 

vehicles and various other types and combinations of mechanized equipment (including production and 

processing facilities), and aircraft operations. Findings of the recent Point Thomson EIS (U.S. Army 

Corps of Engineers 2012) were that drilling and aviation would have the greatest noise impacts during the 

drilling and operations phases of that project.
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Table 110. Estimated levels of aircraft noise (dBA) received at the ground surface at distances 0 to 10 miles from the ground trace of the flight path a 

Aircraft 

Noise 

Source

Flight Altitude 

(ft) 

Estimated

Noise 

Level,

0.0 mi 

from 

Ground 

Trace

(dBA)

Estimated

Noise 

Level,

0.25 mi 

from 

Ground 

Trace 

(dBA)

Estimated 

Noise 

Level,

0.5 mi 

from 

Ground 

Trace 

(dBA)

Estimated 

Noise 

Level,

0.75 mi 

from 

Ground 

Trace 

(dBA)

Estimated 

Noise 

Level,

1.0 mi 

from 

Ground 

Trace 

(dBA)

Estimated 

Noise 

Level,

2.5 mi 

from 

Ground 

Trace 

(dBA)

Estimated 

Noise 

Level,

5.0 mi 

from 

Ground 

Trace 

(dBA)

Estimated 

Noise 

Level,

7.5 mi 

from 

Ground 

Trace 

(dBA)

Estimated 

Noise 

Level,

10.0 mi 

from 

Ground 

Trace 

(dBA)

C-130 b 3,000 67.2 66.4 64.7 62.8 61.0 54.1 48.2 44.7 42.2

2,000 70.7 69.1 66.3 63.8 61.7 54.2 48.2 44.7 42.2

1,000 76.7 72.3 67.7 64.5 62.1 54.3 48.3 44.8 42.3

500 82.7 73.7 68.1 64.7 62.2 54.3 48.3 44.8 42.3

250 88.7 74.1 68.2 64.7 62.2 54.3 48.3 44.8 42.3

Range c (dBA) 21.5 7.7 3.5 1.9 1.2 0.2 0.1 0.1 0.1

Helicopter d 3,000 57.2 56.4 54.7 52.8 51.0 44.1 38.2 34.7 32.2

2,000 60.7 59.1 56.3 53.8 51.7 44.2 38.2 34.7 32.2

1,000 66.7 62.3 57.7 54.5 52.1 44.3 38.3 34.8 32.3

500 72.7 63.7 58.1 54.7 52.2 44.3 38.3 34.8 32.3

250 78.7 64.1 58.2 54.7 52.2 44.3 38.3 34.8 32.3

Range c (dBA) 21.5 7.7 3.5 1.9 1.2 0.2 0.1 0.1 0.1

Propeller e 3,000 55.7 54.9 53.2 51.3 49.5 42.6 36.7 33.2 30.7

(Single & 2,000 59.2 57.6 54.8 52.3 50.2 42.7 36.7 33.2 30.7

Twin 1,000 65.2 60.8 56.2 53.0 50.6 42.8 36.8 33.3 30.8

Engine) 500 71.2 62.2 56.6 53.2 50.7 42.8 36.8 33.3 30.8

250 77.2 62.6 56.7 53.2 50.7 42.8 36.8 33.3 30.8

Range c (dBA) 21.5 7.7 3.5 1.9 1.2 0.2 0.1 0.1 0.1

a Estimates assume noise attenuation of 6 Decibels (dBA) per doubling of distance from source and do not account for potential effects of meteorological conditions, sound barriers, 

and landscape characteristics. Noise estimates are provided for three classes of aircraft at flight altitudes 250 to 3,000 feet above ground level.

b Aircraft at 180 knots in level flight, with maximum 1-second noise level estimated for 1,000-foot distance using the U.S. Air Force OMEGA10R noise model (U.S. Army Corps of 

Engineers 2004, Appendix H).

c Range of estimated noise levels (dBA) at the ground due to the 250 to 3,000-foot range in aircraft flight altitude.

d B206 helicopter at 160 knots in level flight, with maximum 1-sec noise level estimated for 1,000-foot distance using the Federal Aviation Administration’s Integrated Noise Model 

(Miller et al. 2003). 

e C207 and DHC6 propeller aircraft at 160 knots in level flight, with maximum 1-sec noise level estimated for 1,000-foot distance using the Federal Aviation Administration’s Integrated 

Noise Model (Miller et al. 2003).
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Other than aircraft activities, drilling itself would be expected to generate the highest noise levels during 

the drilling and operations phases. Maximum noise levels generated by drilling could be up to 84.4 dBA 

at 1,000 feet (Table 109 (Ambrose and Florian 2014). This level of noise would be expected to attenuate 

to approximately 45 dBA at Nuiqsut, located approximately 17 miles from the proposed GMT2 pad 

where drilling would occur. Assuming the ambient noise level in Nuiqsut is approximately 50 dBA, this 

maximum level of drilling noise would be marginally audible. But median noise levels (52.4 dBA at 

1,000 feet, Table 109) would be expected to attenuate to approximately 13 dBA at Nuiqsut, well below 

the likely level of audibility. Maximum noise attributable to drilling likely would be very intermittent and 

would occur only during a small percentage of the time, but it could occasionally dominate the acoustical 

environment for more than 10 miles away (Table 109), estimated noise level 50 dBA at 10 miles, in 

relation to potential natural ambient of 35 dBA). In contrast, median sound levels attributable to drilling 

would be expected to attenuate to ambient levels at approximately 1.9 miles from the source, would be 

only be slightly audible at 1 miles from the source, and would only dominate the natural acoustical 

environment for a distance of approximately 0.4 mile from the source, assuming a natural ambient sound 

level of 35 dBA and without accounting for effects of meteorological conditions. Overall impacts of 

drilling noise on the acoustical environment would be of high intensity and regional extent for maximum 

noise levels, but median noise levels would be expected to be of high intensity to a limited extent. In both 

cases, impacts would be temporary and would attenuate to low intensity with increasing distance from the 

source. Drilling noise could contribute to local avoidance of infrastructure by wildlife, but would be 

unlikely to result in population-level impacts. Noise impacts attributable to drilling itself would not be 

expected to vary among the action alternatives under consideration. 

Other than drilling and aircraft noise, other project-related noise and associated impacts during the 

drilling and operations phases would be similar to or lower than noise levels and impacts described above 

for construction activities excluding mine blasting and aircraft operations. Impacts would be of high 

intensity and local extent, but would be of interim duration due to their occurrence through the entire 

operational phase of the project. 

Most of the aircraft operations proposed for the drilling and operations phases would occur under 

Alternative C, but not under Alternatives A and B. The exceptions would be helicopter flights into the 

project area in support of required special studies, monitoring, and ice-road clean-up (all alternatives). 

Under Alternative C (no gravel road access), flight activities also would include transport of cargo by 4E 

aircraft into and out of the GMT2 airstrip, and transport of personnel and cargo into and of GMT2 by 2E 

aircraft. Aircraft noise levels and associated impacts generally would be similar to those described above 

for the construction phase. Noise impacts would be of high intensity and regional extent, but would be of 

interim duration due to their occurrence through the entire operational phase of the project. Impacts of 

aircraft noise would be the same under Alternatives A and B, and would be greatest under Alternative C. 

Comparison of Alternatives

Table 111 summarizes the major project components that have the potential to impact the acoustical 

environment and noise-sensitive receptors. The major design factor that determines the degree to which 

potential noise impacts would vary among alternatives is proposed access to GMT2. In Alternatives A and 

B, access to the GMT2 pad would be via vehicle travel on seasonal ice roads during the construction 

phase, and year-around on a gravel road between GMT1 and GMT2 during subsequent project phases. 

Under Alternative C, the gravel road between GMT1 and GMT2 would not be constructed, with yearround access by aircraft and seasonal access via vehicle travel on ice roads for the entire duration of the 

project. To support aircraft access under Alternative C, an airstrip and operations camp would be 

constructed at GMT2, thus resulting in greater gravel requirements and a greater overall gravel 

infrastructure footprint relative to Alternatives A and B. The greater gravel requirements would be 

expected to result in a higher total number of blast-noise events associated with gravel mining under 
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Alternative C. The greater infrastructure footprint associated with Alternative C also could result in a 

greater total amount of construction-related noise relative to Alternatives A and B. 

With respect to potential noise impacts, the greatest factor that distinguishes Alternative C from 

Alternatives A and B is the reliance on aircraft for transport of personnel and cargo under Alternative C. 

As described above, aircraft noise is louder and therefore would be expected to result in noise impacts to 

the acoustical environment and sensitive receptors within a much greater geographic area than would be 

expected with vehicle use on roads under Alternatives A and B.

Mitigation

Several best management practices related to facility design and construction were specified in the 2013 

NPR-A Record of Decision for the purpose of mitigating potential noise-related impacts on wildlife and 

subsistence users. These include BMP E-1 (protection of subsistence use, access, and wildlife generally), 

E-11 (protection of federally protected and BLM special status species), and E-18 (protection of federally 

protected species). 

In addition, BMP F-1 directly addresses use of aircraft for permitted activities, with the objective of 

minimizing the effects of low-flying aircraft on wildlife, sensitive activities, and local communities. In 

general, this best management practice specifies seasonal buffers, spatial buffers, and/or minimum flight 

altitudes designed to protect noise-sensitive resources. Specified minimum flight altitudes range from 

1000 to 3000 feet, with requirement that flight operations associated with permitted activities remain at or 

above the specified altitude unless doing so would endanger human life or violate safe flying practices.
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Table 111. Summary of major components potentially impacting the acoustical environment and noise-sensitive receptors a

Alternative & 

Phase

Total Gravel 

Requirement 

(cy) b

Total 

Gravel 

Footprint 

(acres) c

Total 

Vehicle 

Trips

Total Vehicle 

Miles d

Total 

Otter/CASA/D

C-6 Flights 

into Alpine

Total 

Otter/CASA 

Flights into 

GMT2

Total DC-6/C130 Flights 

into GMT2

Total 

Helicopter 

Flights into 

NPR-A 

A: Construction 671,300 78.0 166,700 1,342,800 415 0 0 1,121

A: Drilling - - 63,100 1,569,800 0 0 0 540

A: Operations - - 161,000 287,500 0 0 0 2,070

A: Total 671,300 78.0 390,800 3,200,100 415 0 0 3,731

B: Construction 747,300 87.2 171,400 1,436,200 415 0 0 1,121

B: Drilling - - 63,100 1,569,800 0 0 0 540

B: Operations - - 161,000 287,500 0 0 0 2,070

B: Total 747,300 87.2 395,500 3,293,500 415 0 0 3,731

C: Construction 930,000 92.0 182,400 1,695,600 274 865 193 1,217

C: Drilling - - 182,500 1,295,300 0 6,126 1,399 858

C: Operations - - 501,400 1,616,900 0 5,281 974 3,289

C: Total 930,000 92.0 866,300 4,607,800 274 12,272 2,566 5,364

a All values are estimates subject to change in final design.

b Values are assumed to be roughly proportional to noise attributable to gravel mining.

c Values are assumed to be roughly proportional to noise attributable to infrastructure construction, excluding vehicle trips and aircraft activity.

d Values are assumed to be roughly proportional to noise attributable to vehicle use.
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Given the known frequent occurrence of low cloud ceilings below minimum specified flight altitudes in 

the project area, as well as the observation that differences in estimated levels of aircraft noise due to 

differences in altitude are small beyond about 0.5 miles from the ground trace (Table 110), minimum 

flight altitudes and spatial buffers currently specified in F-1 may warrant reconsideration by appropriate 

resource specialists and stakeholders. An alternative approach could be to work with resource specialists 

and stakeholders to develop and recommend preferred low-altitude flight corridors that specifically are 

designed to avoid and protect noise-sensitive resources while recognizing and accommodating the 

frequent need for low-altitude flight due to environmental conditions. If such an approach were to be 

developed, an effectiveness monitoring program could be designed to collect pertinent data on aircraft 

noise levels and resource (wildlife) responses to aircraft noise events at specific sensitive locations before 

and after implementation of the flight corridors. 

As indicated above, blast noise associated with gravel mining is likely to be the loudest noise generated 

by project-related activities. Acoustical data that accurately characterizes the frequency, timing, and level 

of blast noise in proximity to Nuiqsut are necessary for determining the need for mitigation measures. 

Conclusion

Under all of the action alternatives, noise generated by a wide range of project-related activities would 

have reasonably foreseeable impacts on the acoustical environment. In addition, project-related noise 

would have the potential to impact noise-sensitive receptors including people and wildlife that would be 

exposed to elevated noise levels during all project phases. All impacts on the acoustical environment 

would be of high intensity, but the geographic extent would vary from limited (median noise levels during 

drilling and operations, excluding aircraft noise), to local (construction noise), and to regional (blast 

noise, maximum noise levels during drilling, and aircraft noise). Impacts attributable to individual noise 

events would be temporary. But persistent noise from production facilities and generators, as well as the 

frequent recurrence of many distinct, but temporary high-intensity noise events, would be of interim 

duration, together lasting for the life of the project. High-intensity blast noise and aircraft noise are 

considered unique in context, because blast noise would impact the community of Nuiqsut, and aircraft 

noise would impact acoustical conditions and sensitive receptors in concentrated subsistence areas. 

Overall noise impacts are considered moderate for all three action alternatives, with reasonably 

foreseeable noise impacts of Alternative C greater than impacts of Alternatives A and B.

4.2.4 Project Effects on Global Climate Change

This section discusses the potential impacts of the project alternatives on global climate change. The 

impacts of climate change on the environmental resources in the Arctic generally and the project study 

area specifically are addressed in Section 3.2.4, “Climate Change.”

According to the National Climate Assessment published by the U.S. Global Change Research Program, 

the warming trend observed over the last 50 years was driven primarily by human activity resulting in the 

emission of heat trapping gases, also known as greenhouse gases (U.S. Global Change Research Program

2014). Heat trapping gases produced by human activity that contribute to climate change include carbon 

dioxide, methane, nitrous oxides, and fluorinated gases (EPA 2017d). In addition to these gases, other 

atmospheric compounds, referred to as “short-lived climate forcers,” such as black carbon can affect 

climate on shorter timescales (AMAP Assessment 2015). The primary activity causing the release of 

greenhouse gases to the atmosphere is the combustion of fossil fuels such as oil, natural gas, and coal 

(U.S. Global Change Research Program 2014). In 2009, the EPA made an endangerment finding for 

greenhouse gases which stated that six well mixed greenhouse gases—carbon dioxide (CO2), methane 

(CH4), nitrous oxide (N2O), hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride (SF6)—in the 

atmosphere threaten the public health and welfare of current and future generations (EPA 2009). 
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4.2.4.1 Methodology

Our current understanding of climate change does not allow us to relate specific sources of greenhouse 

gas emissions or other short-lived climate forcers to any specific climate-related impact. While emissions 

from oil and gas developments contribute to the effects of climate change to some extent, it currently is 

not possible to associate any of these particular actions with the creation of any specific climate-related 

environmental effects. The tools necessary to quantify climatic impacts of single projects are presently 

unavailable. As a consequence, impact assessments of specific effects of anthropogenic activities cannot 

be determined. 

Climate change is by its very nature a cumulative global problem, and no single project or action 

contributes a significant amount of greenhouse gases when compared to global greenhouse gas emissions. 

Specific thresholds for greenhouse gas emissions have not been established by the EPA, and thus there is 

no threshold of significance against which to compare project-level greenhouse gas emissions to 

determine major, moderate, or minor impacts. The methodology for evaluating the GMT2 Project’s 

contribution to global climate change is to quantify the amount of greenhouse gas emissions that will 

result from the development of this project under each alternative. Under this methodology, the emissions 

themselves serve as a proxy for the impacts of climate change, with higher emissions equating to higher 

impacts. For ease of comparison, all greenhouse gases have been converted to CO2 equivalent (CO2e), 

which describes the global warming potential of each greenhouse gas in terms of the amount of CO2 that 

would result in the same level of warming (EPA, Understanding Global Warming Potentials, 2016). Note 

that while the GMT2 Project’s black carbon emissions were not explicitly quantified, black carbon 

emissions are a component of PM2.5 and are part of the PM2.5 emissions used in the air quality impact 

analysis. The effects of black carbon on Arctic climate are described based on review of available, peerreviewed literature, see Black Carbon Effects on Climate for more detail.

Indirect greenhouse gas emissions resulting from the transportation, refinement, and consumption of oil 

produced from the GMT2 Project were estimated using the Bureau of Ocean Energy Management’s 

Greenhouse Gas Lifecycle Model (Wolvovsky et al. 2016). This model was developed to support the 

Outer Continental Shelf Oil and Gas Leasing Program: 2017–2022 PEIS, and it represents the best 

available resource for estimating indirect greenhouse gas emissions from petroleum products refined and 

consumed domestically. A full description of the model’s capabilities and methodology can be found in 

Appendix H.

Direct emissions resulting from the construction and operation of the GMT2 Project were calculated as 

part of the emissions inventory developed to evaluate air quality impacts. The BLM and their contractor, 

Kleinfelder and Rambol Environ, worked with the project proponent to develop an inventory of all 

emissions sources (vehicles, aircraft, drill rigs, generators, etc.) that would be required to construct and 

operate GMT2 throughout the project life. 

4.2.4.2 Greenhouse Gas Emissions from the Action Alternatives

The proposed action and alternatives would result in impacts to climate change through direct and indirect 

emissions of the heat trapping gases—carbon dioxide, methane, and nitrous oxides. The GMT2 Project 

will also produce small amounts of sulfur dioxide, a greenhouse gas that has an overall cooling effect; 

however, the countervailing effect of sulfur dioxide emissions will be negligible. 

Direct emissions resulting from the GMT2 Project for each alternative include, but are not limited to,

emissions from vehicle traffic, air traffic, power generation and drill rig emissions associated with the 

construction and operation of the GMT2 Project. Indirect emissions are the result of the transportation, 

refinement, and downstream consumption of the oil extracted from the GMT2 Project. Natural gas 

extracted from the GMT2 Project will be reinjected into the well and will not be transported for 
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consumption. All action alternatives will produce the same amount of oil and have the same amount of 

indirect greenhouse gas emissions. 

Table 112. Total greenhouse gas emissions for each action alternative

Greenhouse Gas Emissions 

(metric tons of CO2 equivalent)

Alternative A, 

Proposed Action

Alternative B, 

Alternate Road 

Alignment

Alternative C, 

Roadless 

Development

Direct Emissions 457,108 457,595 651,268

Indirect Emissions 73,549,488 73,549,488 73,549,488

Total Emissions 74,006,596 74,007,083 74,200,756

Assumptions

Assumptions of the Greenhouse Gas Lifecycle Model and its application to the GMT2 Project are listed

below: 

• Although the model was developed to assess indirect greenhouse gas emissions from offshore oil 

production, the model can be applied to the GMT2 Project because the indirect emissions for both 

onshore and offshore projects occur onshore, and are therefore treated in the same manner in the 

model. All oil produced on Alaska’s North Slope, whether onshore or offshore, is transported from 

Deadhorse using the Trans-Alaska Pipeline System to the Valdez tanker terminal. Alaska crude oil is 

then transported by tanker to the U.S. West Coast and refined and consumed domestically. Because 

both onshore and offshore production share this transportation, refinement, and consumption pattern, 

the Greenhouse Gas Lifecycle Model is also applicable to onshore North Slope oil and gas 

developments for the purpose of estimating indirect greenhouse gas emissions from downstream 

consumption. 

• First oil is assumed to occur in the year 2021 for purposes of modeling. 

• Greenhouse gas emissions from natural gas consumption were removed from the model to account 

for the fact that natural gas will be reinjected into production wells for the GMT2 Project. 

• A full description of the assumptions and methodology of the base Greenhouse Gas Lifecycle Model 

are available in Appendix H.

Black Carbon Effects on Climate

Black carbon’s influence on arctic climate is complex and still an active area of research. Black carbon is 

a short-lived pollutant, relative to other atmospheric compounds that can affect climate. It has a lifetime 

on the order of several days to weeks (Paris et al, 2009; AMAP 2011; and AMAP Assessment 2015), and 

is removed from the atmosphere by wet or dry deposition. Black carbon is a by-product of incomplete 

combustion of fossil fuels and biomass. In Alaska’s North Slope black carbon comes from a variety of 

sources including transport from international sources (Stohl, 2006; Matsui, 2011; and Xu et al., 2017), 

biomass burning (Stohl, 2006; Creamean et al., 2018; and Xu et al., 2017), shipping (Corbett et al., 2010; 

and Lack, D. and Corbett, J. 2012), oil and gas exploration and production activities (Stohl et al., 2013; 

and Creamean et al., 2018), and residential combustion (Stohl et al., 2013). Although black carbon 

emissions from the GMT2 Project are not explicitly quantified, black carbon is part of the GMT2 Project 

PM2.5 emissions inventory used in the air quality impact analysis. Black carbon would be emitted during 

the GMT2 Project as part of the PM2.5 emissions from diesel-fired equipment, such as engines, boilers, 

heaters, and pumping units, and other equipment including aircrafts and flares. 
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Given the wide variety of black carbon emissions sources affecting the North Slope, black carbon 

concentrations vary by season (Eck et al, 2009; AMAP Assessment 2015), spatial location (Creamean et 

al., 2018), and vertical height in the atmosphere (Creamean et al., 2018; Stohl et al., 2013; Xu et al., 

2017). As described in more detail below, all of these factors influence whether black carbon emissions 

warms or cools the climate and by how much. Bond et al. (2013) estimate that the total climate forcing of 

black carbon from warming and cooling processes is +1.1 Watts per square meter (W m-2

), where positive 

forcing values indicate net climate warming6

. Although this estimate is highly uncertain (Bond et al 

estimates a range of 90% uncertainty) and new climate forcing mechanisms have been uncovered since 

(AMAP Assessment 2015), there is a “very high probability that black carbon emissions...have a positive 

forcing and warm the climate.” 

There are multiple mechanisms involving black carbon that affect the degree to which black carbon 

warms the climate. Black carbon is the component of fine particulate mass that is most efficient at 

absorbing solar energy and by itself has a warming effect through direct absorption of solar radiation 

(referred to as the direct radiative effect). Bond et al. (2013) estimate the direct radiative effect of black 

carbon is +0.71 W m-2

. In addition to the direct radiative effect, black carbon can influence the formation 

and radiative properties of clouds (+0.23 W m-2

). When deposited to snow or ice surfaces, black carbon 

decreases the ability of the surface to reflect incoming solar energy and thus accelerates melting further 

darkening the surface enhancing what is referred to as the “snow- and ice-albedo feedback effect” (+0.13 

W m-2

). This snow- and ice-albedo feedback effect is magnified when black carbon is emitted within the 

Arctic (Sand et al. 2013) rather than transported from lower latitudes because the black carbon emitted in 

the Arctic has a higher probability of depositing onto a snow or ice surface than black carbon emissions 

emitted at lower latitudes. Furthermore, black carbon in the lower troposphere and boundary layer that 

has not deposited to snow- or ice-surfaces leads to increased warming as the absorbed solar radiation 

heats the air locally leading to decreased cloud cover which increases melting and the snow/ice-albedo 

feedback. Another mechanism that caused enhanced warming is that black carbon is often mixed with 

other chemical compounds in the atmosphere (AMAP Assessment 2015) which is predicted to increase 

the warming effect of black carbon on the Arctic (Kodros, et al. 2018). The extent of the increased 

warming is dependent on the “mixing state” of black carbon and other compounds. “Mixing state” refers 

to chemical compounds that form a coating around black carbon particles, and includes consideration of 

the chemical composition of the coating, the size and shape of the black carbon particle core, and coating 

thickness.

While overall black carbon is predicted to have a warming effect on climate, there are several 

mechanisms by which black carbon cools the climate. As mentioned above, black carbon’s effects on 

cloud formation can lead to cooling (-0.2 W m-2 Bond et al. 2013). In addition, Flanner (2013) and Sand et 

al. (2013) found that when black carbon is higher in the Arctic atmosphere it has a cooling effect. This 

cooling occurs for several reasons: there is a net cooling when incoming solar radiation is prevented from 

reaching the surface (commonly referred to as ‘surface dimming’); black carbon surface dimming further 

decreases heat energy transfer from lower latitudes to the Arctic by decreasing the equatorial-polar 

temperature gradient; and black carbon increases higher altitude cloud cover which reflects incoming 

solar radiation preventing it from penetrating to the surface (AMAP Assessment 2015). In addition to 

these processes that generally decrease warming, black carbon is co-emitted with other pollutants and it 

has been found that these co-pollutants can reduce the amount of warming predicted by black carbon 

alone (-0.06 W m-2 Bond et al. 2013).

 6 Note that in the following paragraphs, the estimated amount of black carbon climate forcing is provided for different 

mechanisms. The quantitative forcing for individual mechanisms is provided for informational purposes to show the expected 

relative difference in potential climate forcing. The estimated climate forcing provided for individual mechanisms do not add to 

the total black carbon climate forcing. 
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Altogether, black carbon effects on climate are highly variable depending on location and timing of 

emissions; associated co-emissions and atmospheric mixing state; and predominant meteorological, 

dynamical, and removal processes. Furthermore, there are still many uncertainties to resolve to better 

understand the complex mechanisms and feedbacks between black carbon and its effect on Arctic climate. 

4.2.4.3 Greenhouse Gas Emissions from Alternative D, the No-Action Alternative

Under Alternative D, direct and indirect greenhouse gas emissions from the GMT2 Project would be zero. 

However, it is important to note that global greenhouse gas emissions would not see a net reduction 

equivalent to the total emissions from the GMT2 Project. Under a no-action alternative, the energy that 

would have been produced from the GMT2 Project would be replaced by alternate energy sources, and 

the production and consumption of these replacement energy sources would have associated greenhouse 

gas emissions. In order to place the no-action alternative in an appropriate context, the BLM used the 

Bureau of Ocean Energy Management’s Market Simulation Model (MarketSim) to predict how energy 

produced from the GMT2 Project would be replaced under a no-action alternative. The Greenhouse Gas 

Lifecycle Model was then used to predict indirect emissions from the consumption of these replacement 

energy sources. 

The results of this analysis are not directly comparable to the emissions of the action alternatives because 

direct emissions for the replacement sources of energy are not available and cannot be included in the noaction alternative analysis. Despite this limitation, MarketSim and the Greenhouse Gas Lifecycle Model 

represent the best available data and THE BLM is including this information here to give the public and 

decision makers an idea of how the no-action alternative would impact global climate change. As with the 

action alternatives, greenhouse gas emissions are used as a proxy for the impacts of climate change. 

Bureau of Ocean Energy Management’s Market Simulation Model

The Bureau of Ocean Energy Management developed the MarketSim to calculate the energy sources that 

would be anticipated instead of new lease offshore oil and natural gas production in the absence of a new 

Outer Continental Shelf (OCS) Program. These substitute energy sources include additional oil and gas 

imports, onshore oil and gas production, fuel switching (e.g., coal), and reduced consumption of energy. 

Since the analysis was originally conducted for the Draft EIS, BOEM completed a new MarketSim model 

update which is described in more detail in the documentation: “Consumer Surplus and Energy 

Substitutes for OCS Oil and Gas Production: The 2017 Revised Market Simulation Model (MarketSim)”. 

BOEM also updated the underlying baseline data in the model from 2016 to the 2018 Annual Energy 

Outlook from the Energy Information Administration (EIA). 

MarketSim models oil, gas, coal, and electricity markets and is calibrated to a special run of the EIA’s 

National Energy Modeling System. The baseline used in the MarketSim is a modified version of the EIA’s 

Annual Energy Outlook (AEO) Reference case. For the Final EIS, BOEM used the 2018 EIA AEO 

Reference case modified to exclude new OCS lease sales starting in 2019. Removing the EIA’s 

expectation of production from new OCS leasing allows investigation of alternative new OCS leasing 

scenarios within the EIA’s broad energy market projection using the MarketSim. MarketSim uses price 

elasticities derived from EIA and other published economic studies to quantify the changes that would 

occur to prices and energy production and consumption over the time period of production.

Applicability of MarketSim to BLM Decisions

While the MarketSim is specifically designed to calculate the energy market substitutes for new offshore 

oil production, the basic model calculations allow for its use in modeling the substitutes for other oil and 

gas sources including new onshore production. Since MarketSim is designed to treat new lease offshore 

production as the exogenous variable, modelling substitution effects of new onshore production requires 
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inputting the projected GMT2 production as new offshore oil production. This modelling approach results 

in a couple limiting assumptions, including: 

• Additional onshore production from the GMT2 Project essentially generates the same types of energy 

market substitutes as offshore production. 

• No substitution involving new lease offshore production for the new Alaska onshore production. The 

model does assume some substitution of existing offshore production (meaning for areas currently 

under lease). 

Even with these assumptions, BOEM believes the model provides results that are generally comparable to 

those calculated if the model were explicitly designed for onshore production. BLM received a comment 

questioning the application of BOEM’s MarketSim to the BLM data as the baseline AEO data in the 

MarketSim assumes new onshore leasing that would already occur in the model, and thus double counts 

the GMT2 project. While that is technically correct, the model does not account for the new oil and gas 

production that would occur from new OCS leasing from 2019 forward. As such, any double counting of 

the additional onshore production is likely offset by the underestimation of new offshore oil and gas 

leasing.

Results of MarketSim 

For the final analysis, BLM updated the production estimates for GMT2 (see Section 4.4.3, Economy). 

The updated production estimate includes production of 170.1 million barrels of oil (mmbbl) over 34 

years. Production is assumed to begin in 2021.

Table 113 shows the energy market substitutions predicted by the MarketSim if the GMT2 Project is not 

approved. The table shows the volume and percent replacement of each substitute source in the absence 

of GMT2. For example, if the production from GMT2 did not occur, the model predicts an estimated 141 

mmboe of additional imports (replacing 83% of the GMT2 production). Given the slight increase in price 

in the absence of GMT2’s production, oil demand would decrease slightly. This would result in a 9.9 

mmbbl reduction in oil demand. However, given changes in the prices of other fuels, demand for natural 

gas, coal, and electricity (from sources other than oil, natural gas, and coal) would increase slightly. In 

net, there would be a reduction of 6.1 mmboe in energy demand (replacing 3.6% of the estimated GMT2 

production). 
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Table 113. Energy substitutions for GMT2 Project

Energy Category

Change in Sector

(mmbbl) a, b

Change as % 

of Forgone

Onshore Production 14.2 8.3%

Oil 10.5 6.2%

Natural Gas 3.7 2.1%

Existing Offshore Production 2.0 1.2%

Oil 2.0 1.2%

Natural Gas 0.0 0.0%

Imports 141.0 82.5%

Oil 140.9 82.4%

Natural Gas 0.1 0.0%

Other 6.7 3.9%

Biofuels 0.5 0.3%

Other Oil 6.2 3.6%

Other Natural Gas 0.0 0.0%

Coal 0.7 0.4%

Domestic 0.7 0.4%

Imported 0.0 0.0%

Electricity 0.1 0.1%

Nuclear 0.0 0.0%

Hydro 0.0 0.0%

Solar 0.1 0.0%

Wind Onshore 0.0 0.0%

Wind Offshore 0.0 0.0%

Other Electric 0.0 0.0%

Imports 0.0 0.0%

Reduced Demand 6.1 3.6%

Oil 9.9 5.8%

Natural Gas -2.6 -1.5%

Coal -0.3 -0.2%

Electricity -0.8 -0.4%

Total Substitution 171.0 100.0%

a All changes by sector are expressed in millions of barrels of oil equivalent.

b Coal, gas, and oil-fired electricity generation are not included as sub-categories under electricity because electricity produced from 

these fuels is reflected in the results reported for these fuels themselves.

Indirect Greenhouse Gas Emissions for Alternative D, No-Action Alternative

The BLM used the Greenhouse Gas Lifecycle Model to estimate indirect greenhouse gas emissions for 

Alternative D. Indirect greenhouse gas emissions for Alternative D were estimated to be 41,019,354 

metric tons of CO2 equivalent. This is approximately 3.33 million metric tons less than the indirect GHG 

emissions for the action alternatives (73,549,488 metric tons CO2e).

4.2.4.4 Social Cost of Carbon

Another approach to analyzing possible climate change impacts is to calculate what is commonly known 

as the social cost of carbon. A social cost of carbon protocol was developed by a federal Interagency 

Working Group to assist agencies in addressing EO 12866, which required federal agencies to assess the 

cost and the benefits of intended regulations as part of their regulatory impact analyses. The social cost of 
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carbon estimates economic damages associated with increases in carbon emissions and includes, but is 

not limited to, changes in net agricultural productivity, human health, and property damages associated 

with increased flood risks over hundreds of years. However, a recent EO titled, “Promoting Energy 

Independence and Economic Growth,” issued March 28, 2017, directed that the Interagency Working 

Group be disbanded and that technical documents issued by the Interagency Working Group be 

withdrawn as no longer representing federal policy. 

The social cost of carbon is typically expressed as the cost in dollars per metric ton of emissions, and a 

wide range of cost estimates are available. One factor that creates significant variation in estimates is the 

discount rate. In social cost of carbon estimates, the discount rate is used to estimate the present value of 

costs/damages that may occur far out into the future. Small differences in the discount rate can create 

large variations in estimated social cost of carbon. There is disagreement over which discount rate to use.

In addition, as discussed in the comprehensive technical review commissioned by the Electric Power 

Research Institute (Rose et al. 2014), a number of technical issues have been identified with the social 

cost of carbon modeling approach and estimates. Several of these issues arise from the use of three 

separate underlying models—with differing frameworks, assumptions, and uncertainties. The Electric 

Power Research Institute technical review “reveals significant variation across models in their structure, 

behavior, and results and identifies fundamental issues and opportunities for improvements” (Rose et al. 

2014). 

It should also be noted the social cost of carbon protocol does not measure the actual incremental impacts 

of a project on the environment and does not include all damages or benefits from carbon emissions. 

NEPA does not require a cost-benefit analysis (40 CFR Part 1502.23) and one has not been conducted in 

this supplemental EIS. Without monetized estimates of other effects, including the social benefits of 

energy production, inclusion of a global social cost of carbon analysis would be unbalanced and of 

limited use to the decision-maker. Given the uncertainties associated with assigning a specific and 

accurate social cost of carbon resulting from the GMT2 Project, the BLM has elected not to utilize this 

tool in its analysis.

4.2.4.5 GMT2’s Contributions to Domestic Greenhouse Gas Emissions

Climate change is driven by a series of smaller independent actions whose cumulative effects result in 

measurable changes. The climate change analysis is essentially a cumulative effects analysis, and no 

additional cumulative effects analysis is included in Section 4.6, Cumulative Effects. In order to provide 

the reader and decision-maker context for which to evaluate GMT2’s contributions to global climate 

change, estimated oil production at GMT2 is presented here as a percentage of oil produced on the North 

Slope, oil produced in Alaska, and oil produced in the US. The comparison only extends to 2027, which is 

the last year for which production forecasts are available for the North Slope and State of Alaska (ADOR, 

2018). Comparing production estimates through 2027 will capture peak oil production at GMT2 

(approximately 38,000 barrels of oil per day in 2025). 

The majority of GMT2’s greenhouse gas emissions will result from downstream consumption of the oil 

produced at GMT2, and comparing estimated oil production of GMT2 (rather than the estimated 

greenhouse gas emissions) allows a direct comparison to production estimates for the North Slope, State 

of Alaska, and the US. Results are shown in table 114. 
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Table 114: GMT2 Oil Production As A Percentage of North Slope, Alaska and U.S. Crude Oil Production

Project Year

Anticipated 

Production at 

GMT2, All 

Alternatives 

(barrels of oil per 

day)

Anticipated 

North Slope Oil 

Production 

(barrels of oil per 

day)a

GMT2 As a 

Percentage of 

North Slope Oil 

Production

Anticipated Oil 

Production in 

Alaska (barrels 

of oil per day) a

GMT2 As a 

Percentage of 

Alaska Oil 

Production

Anticipated Oil 

Production in the 

United States 

(barrels of oil per 

day) b

GMT2 As a 

Percentage of

U.S. Oil 

Production

2021 1,500 518,300 0.3% 541,100 0.3% 10,980,000 0.01%

2022 28,000 502,500 5.6% 523,200 5.4% 11,110,000 0.25%

2023 33,000 492,600 6.7% 510,500 6.5% 11,130,000 0.30%

2024 36,000 491,100 7.3% 506,800 7.1% 11,360,000 0.32%

2025 38,000 493,400 7.7% 507,700 7.5% 11,380,000 0.33%

2026 35,500 494,800 7.2% 507,700 7.0% 11,440,000 0.31%

2027 31,950 492,900 6.5% 504,400 6.3% 11,550,000 0.28%

a ADOR, 2018.

b USEIA, 2018
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4.3 Biological Environment

The following discussion regarding impacts on or by the biological environment is generally categorized 

and organized as it is in BLM (2014). 

4.3.1 Vegetation and Wetlands

The proposed project and the action alternatives would result in impacts to vegetation and wetlands 

during construction, drilling, and operation. The latter two periods overlap to a considerable extent, 

especially in Alternative C. These impacts are described specifically for the Alpine satellites area, which 

include GMT1 and GMT2 (BLM 2004a), in general for the Northeast NPR-A (BLM 2008a), and even 

more generally for the entire NPR-A (BLM 2012). The following discussion summarizes the impacts to 

vegetation and wetlands.

4.3.1.1 Methodology

This analysis is an evaluation of impacts resulting from loss of, or alteration to, vegetation and wetlands 

within the project area (as defined in Section 3.1). The analysis is based on integrated terrain unit 

mapping that was done of the project area. Effects on vegetation and wetlands from project components 

were calculated using GIS. The footprints of project components for each alternative were overlain on the 

baseline integrated terrain unit mapping described in Section 3.3.1, “Vegetation and Wetlands,” and the 

areas of each vegetation and wetland type determined.

An analysis of effects on aquatic resources, which may employ more detailed measures, will be 

conducted during the Clean Water Act Section 404 permit review process that will be performed by the 

U.S. Army Corps of Engineers for purposes of determining the least environmentally damaging 

practicable alternative.

The impacts on vegetation and wetlands may also affect related resources such as soils, hydrology, water 

quality, and wildlife habitat described in other parts of Chapter 4. This section focuses on the potential 

impacts on vegetation and wetland ecosystems that are not covered in Section 4.2.2, “Water Resources.”

4.3.1.2 Construction Activities

Gravel Placement and Pipeline Construction

Gravel placed on the tundra surface for the construction of roads, pads, and airstrips would cover the 

vegetation and possibly alter the natural soil horizons by compression. The areal extent of impacts from 

placement of gravel by vegetation type for all action alternatives is presented in Table 115. The depth of 

gravel would vary depending on the hydrology and topography of each specific location, but must be a 

minimum of 5 feet thick to maintain the integrity of the underlying permafrost. This results in a great deal 

of weight applied on each unit area of tundra (at about 2,750 pounds per cubic yard, a 5 foot-thick layer

would weigh about 4,580 pounds per square yard applying a pressure of 3.5 pounds per square inch). 

Heavy vehicles using the gravel roads and pads would add to the weight.

Pipelines would alter snow accumulation and drifting patterns and partially shade vegetation. Each 

vertical support member installed to elevate pipelines would displace approximately 3.1 square feet of 

tundra. Buried, hot-oil pipelines are not included in project design, thus avoiding impacts of thermokarst 

and subsidence that can be associated with them. However, pipelines would cross under gravel roads at 

various locations along the GMT1 to CD1/Alpine Processing Facility pipeline segments. These crossings 

would occur along an existing pipeline route where impacts have been previously evaluated and the route 

permitted as described in Section 2.4.4. To ensure that the existing thermal regime (i.e., permafrost) is 
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maintained at these pipe-road crossings, the pipelines would be installed with rigid insulation between the 

pipelines and existing ground surface as shown in Appendix A, Sheets 28, 29, and 30. The pipeline routes 

for Alternatives A and C are the same. The pipeline route for Alternative B differs from the former two 

where the road for Alternative B diverges from the road route in Alternative A so that the pipe remains 

within a similar distance of the road. Temporary trenching (about 400 square feet) will also be required to 

allow the power and fiber optic cables to cross the existing Alpine gravel access roads.

Gravel Mining

Gravel for the construction of roads, pads and airstrips would be supplied from the Arctic Slope Regional 

Corporation Mine site located on ASRC lands just east of the development. Phase 3 of the gravel mine 

development would encompass approximately 465.3 acres of which GMT2 will only use about 35 acres

and result in the loss of vegetation within the mine footprint. The type of vegetation lost in the mine 

development would be Wet Sedge Meadow Tundra, Water (pond), and both Open and Closed Low 

Willow. To develop the mine the surface vegetation and overburden would be removed during excavation 

of gravel and temporarily stockpiled on an adjacent ice pad. This ice pad would be built once and the 

gravel mined from the site would be hauled directly to the construction sites. Gravel extraction for all 

action alternatives is planned to occur within one season, since opening/closing a gravel cell in one season 

and completing rehabilitation activities would minimize the impacts to the area around the mine site.

The proposed GMT2 development would only use approximately 35 acres or 7.5% of the Phase 3 

expansion. It is unknown exactly where the gravel would come from within the mine, but no more than 35 

acres of habitat would be impacted from gravel extracted for the development. The mined gravel would 

be transported from the Arctic Slope Regional Corporation Mine site to the project area over ice roads 

during Year 1 of construction.

After cessation of gravel mining, the site would be closed and rehabilitated. This would include 

replacement of overburden, contouring, and creation of stable sidewalls. Over the course of time, natural 

sheet flow would fill the mine site with water and create open water habitat.

Ice Road and Pad Construction

Construction activities would require seasonal ice roads and pads. A summary of ice roads and pads is 

provided in Appendix B. The impacts associated with ice road construction would continue during the 

operations period for Alternative C, the “roadless” alternative.

Compared to gravel roads and pads, seasonal ice infrastructure has less impact to tundra vegetation 

communities. However, seasonal ice infrastructure may still cause disturbance such as delayed plant 

development in spring, plant stress, freezing of plant tissues, and physical damage resulting in visible 

traces on the tundra surface (Reynolds, J.F. and J.D. Tenhunen, Editors. 1996). Plant communities 

dominated by shrubs and other woody species are the most susceptible to physical damage and stress 

caused by construction. Flooded and wet tundra types generally exhibit little or no impact from ice road 

construction (Reynolds, J.F. and J.D. Tenhunen, Editors. 1996; Guyer et al. 2005). The impacts to 

wetlands and vegetation from seasonal ice pads would be similar to those of ice roads. Generally, changes 

in the thermal regime or compaction of soil have not been found to result from ice road construction. 

Standard ice road construction practices include preconstruction routing surveys and placement of roads 

to avoid tussock tundra areas, steep stream banks, and deep water holes to the extent possible. As-built

data from previous years’ ice roads would be considered in design and construction crews would deviate 

from planned alignments in the field if unexpected environmental conditions were encountered. Any 

impoundment of snowmelt runoff up-gradient of ice roads, caused by the ice taking longer to melt than 
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the surrounding snow, is expected to be of such short duration each year that its impacts to tundra 

communities while soils are still frozen are expected to be negligible.

4.3.1.3 Drilling and Operation

Drilling activities would not have specific impacts to wetlands and vegetation. Direct impacts to wetlands 

and vegetation originates from the construction of gravel roads and pads prior to the beginning of drilling 

operations. Discussion of potential impacts to wetlands and vegetation from hydrocarbon spills or leaks 

that could occur during drilling is presented in Section 4.5.

Gravel Spray and Dust Deposition

During operations, there would be indirect impacts to vegetation and wetlands adjacent to gravel roads, 

pads, and an airstrip resulting from gravel spray and dust deposition, altered snow distribution, hydrologic 

impoundments, disruption of sheet flow during breakup, increased flooding and thermokarst. 

Maintenance of gravel roads would include periodic watering to aid in dust suppression.

The effects of these impacts would most likely occur within 328 feet (100 meters) of the gravel feature 

(Auerbach et al. 1997). Gravel and dust could smother vegetation and cause early snowmelt, reduced soil 

nutrients, increased soil pH, increased salinity, lowered soil moisture, altered soil organic horizon, higher 

soil bulk density, and greater depth of active layer thaw. Auerbach et al. (1997) also noted that total 

biomass was lower next to roads despite higher graminoid biomass near the road. Mosses were negatively 

affected by road presence; Sphagnum was unable to reproduce near the road due to heavy dusting and 

increased soil pH.

An area of indirect impact that extends 328 feet to either side of gravel infrastructure is considered a

reasonable estimate for an impact zone (Auerbach et al. 1997). It double the 164 feet used previously to 

estimate indirect gravel impacts in the NPR-A by BLM (2012) and for the Point Thomson EIS by the U.S. 

Army Corps of Engineers (2012a),. For this analysis, as for the GMT1 analysis before it (BLM 2014), the 

area of indirect impact was determined by applying a 328-foot-wide buffer to the perimeter of gravel 

filled areas and calculating the area of each vegetation and wetland type within the impact zone using 

GIS. Impacts within the 656-foot zone of indirect impact for all action alternatives are presented in Table 

116 and shown in Map 4.3-1.

Tundra Travel

Although not currently planned, off-road tundra travel during the snow-free season using specialized, 

low-ground-pressure vehicles may occur for maintenance of pipelines and other infrastructure if certain 

conditions are met. Impacts to vegetation may range from light impacts such as compression to more 

severe impacts such as displacement or removal. The degree of impacts generally depends on the 

vegetation type and the number of passes over the tundra (Walker et al. 1977). Several best management 

practices apply to off-road tundra travel to protect wetlands and vegetation. The Alaska Department of 

Natural Resources has tested and approved several vehicle types for tundra travel on state lands during 

summer (Alaska Department of Natural Resources 2015b).

Other Potential Impacts

Water impoundment often occurs where gravel roads and infrastructure with insufficient cross-drainage 

are constructed across areas susceptible to sheet flow during the spring snowmelt and runoff period. A 

site-specific analysis of potential inundation by road and project component fill is presented in Section 

4.2.2, “Water Resources.” Mitigation involves culverts spaced at approximately 1,000-foot intervals along 

roads, or more closely as needed and/or stipulated by permit.
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Equipment used to haul and place gravel fill could harbor nonnative plant seeds, and the placement of fill 

would create barren areas that pose the greatest risks for establishment of invasive, nonnative species. 

Although such establishment is unlikely at the latitude of GMT2 (Carlson et al. 2015), climate warming 

could eventually present conditions under which such species could become established and spread in the 

NPR-A within the 32-year lifetime of the GMT2 Project. This could be at the expense of other, naturally 

occurring plant species that may be displaced, as well as to the wildlife species that use those plants 

(BLM 2012). BLM (2013) has a mandatory best management practice meant to mitigate this possibility.

If non-native invasive species do become established, an integrated vegetation management approach will 

be taken. This may include hand, mechanical and herbicide treatments in accordance with BLM current 

policies. Any herbicide use must be on both the BLM and the Alaska DEC approved list. Only herbicides 

labeled for application to water will be used in this area if they are needed. Minimal use of herbicides is 

expected over the life of this project.
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Table 115. Acreage of direct impacts of construction on vegetation and wetlands for action alternatives

Vegetation 

Type Wetland Typea

Acres of 

Vegetation 

Type in 

Mapped 

Project Areab

Vegetation 

Type as % of 

Total Mapped 

Project Areac

Alternative 

A (acres)d

Alternative 

A (%)e 

Alternative 

B (acres)f

Alternative 

B (%)e 

Alternative 

C (acres) g

Alternative 

C (%)e 

Natural 

Barren

Upland, 

E2US3P 4,590 3.2% -- -- -- -- -- -- 

Human 

Modified 

Barren

Upland 456 0.3% -- -- -- -- -- -- 

Brackish 

Water E2USH 354 0.2% -- -- -- -- -- -- 

Cassiope 

Dwarf Shrub 

Tundra

PSS3B, Upland 241 0.2% -- -- -- -- -- -- 

Closed Low 

Willow PSS1B, PSS1C 2,489 1.7% -- -- -- -- -- -- 

Coastal 

Complex E2EM1/USP 3 0.0%* -- -- -- -- -- -- 

Deep Polygon 

Complex

PUBH, PEM2H, 

PEM1F, 

PEM1/SS1B

823 0.6% -- -- -- -- -- -- 

Dryas Dwarf 

Shrub Tundra Upland, PSS3B 371 0.3% -- -- -- -- -- -- 

Dune 

Complex

Upland, PEM1B, 

PEM1/SS1B, 

PSS1B

25 0.0%* -- -- -- -- -- -- 

Elymus 

Meadow Upland 23 0.0%* -- -- -- -- -- -- 

Fresh Grass 

Marsh

PEM1H, 

R2AB3H, 

L1AB3H

524 0.4% -- -- -- -- -- -- 

Fresh Sedge 

Marsh PEM1H 1,781 1.2% -- -- 0.5 0.0%* 5.7 0.3%

Fresh Water PUBH, R2UBH, 

L1UBH 27,181 18.8% -- -- -- -- 

Halophytic 

Grass Wet 

Meadow, 

Brackish

PEM1R 328 0.2% -- -- -- -- -- -- 
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Vegetation 

Type Wetland Typea

Acres of 

Vegetation 

Type in 

Mapped 

Project Areab

Vegetation 

Type as % of 

Total Mapped 

Project Areac

Alternative 

A (acres)d

Alternative 

A (%)e 

Alternative 

B (acres)f

Alternative 

B (%)e 

Alternative 

C (acres) g

Alternative 

C (%)e 

Halophytic 

Sedge Wet 

Meadow, 

Brackish

PEM1R 240 0.2% -- -- -- -- -- - 

Halophytic 

WillowGraminoid 

Dwarf Shrub 

Tundra

E2SS1/EM1P, 

E2SS1P 150 0.1% -- -- -- -- -- -- 

Moist SedgeShrub TundraPEM1/SS1B, 

PEM1/SS1E 23,684 16.4% 19.0 0.1% 18.9 0.1% 10.3 0.0%*

Old Basin (Ice 

Rich) Wetland 

Complex

PEM1F, PUBH, 

PEM1B, 

PEM1H,

PEM1/SS1E

10,031 6.9% 7.9 0.1% 8.6 0.1% -- -- 

Open Low 

Willow PSS1B 3,867 2.7% -- -- -- -- -- -- 

Open Low 

Willow-Sedge 

Shrub Tundra

PSS1B 636 0.4% -- -- -- -- -- -- 

Open Tall 

Willow PSS1B, PSS1C 86 0.1% -- -- -- -- -- -- 

Partially 

Vegetated

PUSR, PUSC, 

Upland 1,407 1.0% -- -- -- -- -- -- 

Riverine 

Complex

R2UBH, 

R2AB3H, 

PEM1F

411 0.3% -- -- -- -- -- -- 

Salt-killed Wet 

Meadow E2US4P 2 0.0%* -- -- -- -- -- -- 

Seral Herbs PEM1A 54 0.0%* -- -- -- -- -- --

Tussock 

Tundra

PEM1/SS1B,

PEM1/SS1E 29,908 20.7% 49.3 0.2% 57.2 0.2% 74.4 0.2%

Wet Sedge 

Meadow 

Tundra

PEM1F 32,675 22.6% 1.8 0.0%* 2.0 0.0%* 1.7 0.0%*

Wet SedgeWillow Tundra PEM1F 1,892 1.3% -- -- -- -- -- -- 
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Vegetation 

Type Wetland Typea

Acres of 

Vegetation 

Type in 

Mapped 

Project Areab

Vegetation 

Type as % of 

Total Mapped 

Project Areac

Alternative 

A (acres)d

Alternative 

A (%)e 

Alternative 

B (acres)f

Alternative 

B (%)e 

Alternative 

C (acres) g

Alternative 

C (%)e 

Young Basin 

(Ice Poor) 

Wetland 

Complex

PUBH, PEM2H, 

PEM1H, 

PEM1/SS1B, 

PEM1B

559 0.4% -- -- -- -- -- -- 

Total Acres of Direct Impact for Each Alternativeh 78.0 N/A 87.2 N/A 92.0 N/A

Note: Total acreage and percentages may not reflect the sum of the individual cells due to rounding. 

Figure 39 Wetland types assigned based on typical conditions expected to occur in the GMT2 project area. Crosswalk from vegetation type to wetlands type is based upon comparisons to 

vegetation type in Jorgenson et al. (2004) for the broad range of plant communities within the GMT2 project area. Wetland types shown as National Wetlands Inventory codes based 

on Cowardin et el. (1979).

b Acreage of each vegetation type is rounded to the nearest 1 acre.

c Percent of vegetation type within the total mapped project area. Values that are greater than 0 but less than 0.1 percent are noted with an asterisk (0.0%*). Percentages are rounded 

to the nearest tenth. (--) cells indicate the vegetation/wetland type is not present within area considered for impact analysis. Note that the total mapped project area is 144,800 acres 

(rounded up to the nearest 100 acres).

d Values are derived in GIS from overlaying Alternative A gravel footprint (provided by ConocoPhillips on May 19, 2017 ) on vegetation types derived from Jorgenson (2004) and Wells 

et al. (2014) mapping.

e Percent of vegetation type within the mapped project area that is directly impacted by the alternative.

f Values are derived in GIS from overlaying Alternative B gravel footprint (provided by ConocoPhillips on June 2, 2017) on vegetation types derived from Jorgenson (2004) and Wells et 

al. (2014) mapping.

g Values are derived in GIS from overlaying Alternative C gravel footprint (provided by ConocoPhillips on April 23, 2018) on vegetation types derived from Jorgenson (2004) and Wells 

et al. (2014) mapping.

h Total acreage does not include 0.1 acre of fill associated with VSM installation.
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Table 116. Acreage of Indirect impacts of construction on vegetation and wetlands for action alternatives 

Vegetation Type

Wetland Type

(Cowardin 

Code) a

Project

Area

b (acres) 

Vegetation 

Type as

% of Total

Project

Area

Alternative 

A (acres)

Alternative 

A (%)

Alternative 

B (acres)

Alternative 

B (%)

Alternative 

C (acres)

Alternative 

C (%)

Barren Us (upland) 4,766.8 3.0% -- -- -- -- -- --

Cassiope Dwarf 

Shrub Tundra

PSS3B 219.8 0.1% 0.3 0.1% -- -- -- -- 

Closed Low 

Willow

PSS1B 2,615.6 1.7% -- -- -- -- -- -- 

Deep Polygon 

Complex

PUBH, PEM2H, 

PEM1F,

313.4 0.2%

-- -- -- -- -- -- 

PEM1/SS1B

Dryas Dwarf 

Shrub Tundra

Upland, PSS3B 215.3 0.1% -- -- -- -- -- -- 

Fresh Grass 

Marsh

PEM1H, 

R2AB3H

532.6 0.3% -- -- -- -- -- -- 

Fresh Sedge 

Marsh

PEM1H 1,993.5 1.3% 7.3 0.4% 12.5 0.6% 7.1 0.4%

Halophytic Grass 

Wet Meadow, 

Brackish

PEM1R 350.4 0.2%

-- -- -- -- -- -- 

Halophytic Sedge 

Wet Meadow, 

Brackish

PEM1R 253.9 0.2%

-- -- -- -- -- -- 

Moist SedgeShrub Tundra

PEM/SS1B 26,255.8 16.7% 172.3 0.7% 172.3 0.7% 37.9 0.3%

Old Basin (Ice 

Rich) Wetland 

Complex

PEM1F, PUBH, 

PEM1B

10,570.2 6.7% 67.3 0.6% 67.8 0.6% 2.4 0.0%*

Open Low Willow PSS1B 3,666.2 2.3% 1.4 0.0%* -- -- -- --

Partially 

Vegetated

PUSR 1,230.5 0.8% -- -- -- -- -- --

Riverine Complex R2UBH, 

R2AB3H

490.4 0.3% -- -- -- -- -- --

Tussock Tundra PEM/SS1B 31,414.0 20.0% 349.4 1.1% 441.9 1.4% 178.2 0.6%
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Vegetation Type

Wetland Type

(Cowardin 

Code) a

Project

Area

b (acres) 

Vegetation 

Type as

% of Total

Project

Area

Alternative 

A (acres)

Alternative 

A (%)

Alternative 

B (acres)

Alternative 

B (%)

Alternative 

C (acres)

Alternative 

C (%)

Water PUBH, R2UBH 27,711.9 17.6% 2.9 0.0%* 0.6 0.0%* -- --

Wet Sedge PEM1E, PEM1F, 33,678.8 21.4% 20.6 0.1% 16.7 0.0%* 5.2 0.0%*

Meadow Tundra PEM1F

Young Basin PUBH, PEM2H, 509.6 0.3%

Wetland Complex PEM1H, -- -- -- -- -- -- PEM1/SS1B, 

PEM1B

Unmapped Area No Data 

Available

10,465.3 6.6% -- -- -- -- -- --

Total Acres of Impact for Alternative 621.8 N/A 711.9 N/A 230.8 N/A

Note: Values that are greater than zero but less than 0.1 are noted with an asterisk (0.0%*). (--) cells indicate the vegetation/wetland type is not present within area considered for 

impact analysis.

a Wetland types are from the Cowardin classification system used by the National Wetland Inventory (http://www.fws.gov/wetlands/; Cowardin et al. [1979]).

b Percent of vegetation type within the mapped vegetation portion of the project area. Note that the study area is 157,408.4 acres and that 10,465.3 acres (6.6 percent) of the project 

area extends outside of the vegetation map coverage.
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4.3.1.4 Comparison of Alternatives

Table 115 lists the total direct impacts (area in acres) on vegetation and wetlands. The specific impacts for 

each alternative are addressed below.

Alternative A

Alternative A would have a direct impact to vegetation totaling 78.0 acres from the construction of the 

access road and the GMT2 pad (see Table 115). These structures would cover parts of four different 

vegetation types, including tussock Tundra, Moist Sedge-Shrub Tundra, Old Basin (Ice Rich) Wetland 

Complex, and Wet Sedge Meadow Tundra. Direct impacts are minor compared to the overall acreage of 

the project area with impacts to Tussock tundra at 0.2 percent and to Moist Sedge-Shrub Tundra at 0.1

percent of the project area. The impact from vertical support members is negligible and estimated to 

involve only 0.1 acre of total project area.

The indirect impacts of Alternative A, which would occur primarily as a result of the gravel road: gravel 

spray and dust deposition extending up to 328 feet from the edge of the gravel footprint, total 688.6 acres 

(Table 116). The majority of the vegetation types potentially affected includes Tussock Tundra, Moist 

Sedge-Shrub Tundra, Old Basin (Ice Rich) Wetland Complex, and Wet Sedge Meadow Tundra. The area 

of potential indirect impacts for Alternative A would be 0.34 percent of the total project area. This area 

does not include more than 5 percent of any vegetation type within the project area, which is below the 

threshold for low intensity.

The majority of areas with direct and indirect impacts from Alternative A are within potential wetlands, 

only 0.2 acres of direct impacts would affect uplands or non-wetlands areas (ABR 2016). All areas of 

direct impact are expected to remain impacted for more than 10 to 15 years, which will result in a 

permanent loss of wetland function. The impacts of Alternative A to vegetation and wetlands are 

characterized as low intensity because less than 5 percent of any vegetation type in the project area would 

be impacted; long-term duration; important in context since wetlands are protected by legislation; and 

limited in geographic extent since the indirect impacts are expected to be limited to within 328 feet of the 

project components. Overall, Alternative A is rated minor for impacts to vegetation and wetlands.

A major component of Alternative A is the GMT1–GMT2 Access Road. This is an 8.2-mile linear feature 

that could result in impacts to vegetation due to inundation (see Section 4.2.2.4, “Comparison of 

Alternatives, Water Resources”). These impacts would be mitigated by installation of culverts to allow 

maintenance of the existing hydrologic regime.

The GMT1–GMT2 Access Road allows year-round vehicle traffic (see Section 2.5.4.2 and Appendix B), 

which would cause indirect impacts resulting from gravel spray and dust deposition onto the vegetation as 

discussed above. Ice roads would be required during Years 1 and 2 to support construction activities. 

Because ice roads take longer to melt than the surrounding snow, they have a potential to cause temporary 

flooding during spring break-up (see Section 4.2.2.4, “Comparison of Alternatives, Water Resources”). 

Tundra flooding could also occur where ice roads cross streams, but this effect would be mitigated by 

slotting or breaching ice roads in the stream channel. The impacts on vegetation of seasonal ice roads 

from construction would be limited and would occur only during Years 1 and 2.

Alternative B

Alternative B would have a direct impact to vegetation totaling 87.2 acres (excluding impacts from 

vertical support members), with the largest portion consisting of Tussock Tundra vegetation. The impact 

of vertical support members is estimated to involve only 0.1 acre of total impact. The GMT1–GMT2

Access Road and the GMT2 pad would cover parts of five different vegetation types, including Tussock 

Tundra, Moist Sedge-Shrub Tundra, Old Basin (Ice Rich) Wetland Complex, Wet Sedge Meadow Tundra, 
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and Fresh Sedge Marsh. The direct impacts would affect minor amounts of these and none of the other 

vegetation types within the project area, with the greatest relative impact being to 0.2 percent of Tussock 

Tundra and 0.1 percent of Moist Sedge-Shrub Tundra.

The indirect impacts of Alternative B, which would occur primarily as a result of gravel spray and dust 

deposition extending up to 328 feet from the edge of the gravel footprint, total 786 acres (Table 116). The 

majority of the vegetation types potentially affected includes Tussock Tundra, Moist Sedge-Shrub Tundra, 

Old Basin (Ice Rich) Wetland Complex, and Wet Sedge Meadow Tundra. The area of potential indirect 

impacts for Alternative B would be 0.5 percent of the total project area. This area does not include more 

than 5 percent of any vegetation type within the project area, which is below the threshold for medium 

intensity.

All areas of direct and indirect impacts from Alternative B are within potential wetlands. All areas of 

direct impact are expected to remain impacted for more than 10 to 15 years, which will result in a 

permanent loss of wetland function. The impacts of Alternative B to vegetation and wetlands are 

characterized as low intensity because less than 5 percent of any vegetation type in the project area would 

be impacted; long-term duration; important in context since wetlands are protected by legislation; and 

limited in geographic extent since the indirect impacts are expected to be limited to within 328 feet of the 

project components. Overall, Alternative B is rated minor for impacts to vegetation and wetlands.

A major component of Alternative B is the GMT1–GMT2 Access Road. This is linear feature would be 

slightly longer than that for Alternative A could result in slightly greater impacts to vegetation due to 

inundation (see Section 4.2.2.4, “Comparison of Alternatives, Water Resources”). These impacts would be 

mitigated by installation of culverts to allow maintenance of the existing hydrologic regime.

The GMT1–GMT2 Access Road allows year-round vehicle traffic (see Section 2.5.4.2 and Appendix B), 

which would cause indirect impacts resulting from gravel spray and dust deposition onto the vegetation as 

discussed above. Ice roads would be required during Years 1 and 2 to support construction activities. 

Because ice roads take longer to melt than the surrounding snow, they have a potential to cause temporary 

flooding during spring break-up (see Section 4.2.2.4, “Comparison of Alternatives, Water Resources”). 

Tundra flooding could also occur where ice roads cross streams, but this would be mitigated by slotting or 

breaching ice roads in the stream channel. The impacts on vegetation of seasonal ice roads from 

construction would be limited and they would occur only during Years 1 and 2.

Alternative C

Alternative C would have direct impacts to vegetation totaling 92.0 acres (excluding impacts from 

vertical support members), with the largest area involving tussock tundra vegetation. The impact of 

vertical support members is estimated to involve only 0.1 acre of total impact. The GMT2 pad, airstrip 

and Airstrip Access Road would occupy mostly Tussock Tundra with small amounts of Moist SedgeShrub Tundra. Air access facilities and the occupied structure pad would occupy mostly Tussock Tundra, 

with smaller amounts of Moist Sedge-Shrub Tundra, Fresh Sedge Marsh, and Wet Sedge Meadow Tundra.

The direct impacts would affect minor amounts of each vegetation type within the project area, with the 

greatest relative impact being 0.2 percent of Tussock Tundra and 0.3 percent of Fresh Sedge Marsh. 

The indirect impacts of Alternative C, occurring from gravel spray and dust deposition from all gravel 

infrastructure extending up to 328 feet from the edge of the gravel footprint, would total an estimated 

251.7 acres. The majority of the acreage affected would include these vegetation types: Tussock Tundra, 

Moist Sedge-Shrub Tundra, Fresh Sedge Marsh, Wet Sedge Meadow Tundra, and Old Basin Wetland 

Complex. The area of potential effect from indirect impacts for Alternative C would be 0.1 percent of the 

total project area. This area does not include more than 5 percent of any single vegetation type within the 

project area, and thus falls below the threshold for medium intensity.
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All areas of direct and indirect impacts of Alternative C are within potential wetlands. All areas of direct 

impact are expected to remain impacted for more than 10 to 15 years, which will result in a permanent 

loss of wetland function. The impacts of Alternative C to vegetation and wetlands are characterized as 

low intensity because less than 5 percent of any vegetation type in the project area would be impacted; 

long-term duration; important in context since wetlands are protected by legislation; and limited in 

geographic extent since they are expected to occur within 328 feet of the project components. Overall, 

Alternative C is rated minor for impacts to vegetation and wetlands.

Alternative C includes additional pads (occupied structure pad and air access facilities) and a 0.9-milelong Airstrip Access Road, totaling a 2.3-mile-long feature that could result in impacts to vegetation due 

to inundation (see Section 4.2.2.4, “Comparison of Alternatives, Water Resources”). While these impacts 

are typically mitigated by installation of culverts to allow maintenance of the existing hydrologic regime, 

culverts would only be feasible along the Airstrip Access Road; the pads and airstrip are too wide to allow 

use of culverts.

Year-round access would be provided by aircraft, while summer vehicle traffic would be limited to the 

Airstrip Access Road (see Section 2.6.4 and Appendix B). Aircraft landing at the airstrip and vehicle 

traffic would cause indirect impacts resulting from gravel spray/dust deposition onto the vegetation as 

discussed above. Dust distribution (and therefore impacts) associated with air strips may not be the same 

as with roads.

Ice roads would be required to support construction activities. Additionally, an annual 7.0-mile-long ice 

road would be required between the GMT1 pad and the occupied structure pad to allow vehicle access 

during winter throughout 30 post-construction drilling and operating years. The ice road may alter 

drainage during spring break-up and thus temporarily flood vegetation because the ice would melt more 

slowly than the surrounding snow (see Section 4.2.2.4, “Comparison of Alternatives, Water Resources”). 

Blockage of streamflow could have the same effect, but this would be mitigated by slotting or breaching 

ice roads.

Gravel Mining

Gravel for roads and pads would be required to construct each of the action alternatives. Gravel would be 

mined under Phase 3 of the Arctic Slope Regional Corporation Mine expansion, which would encompass 

approximately 465.3 acres. The proposed GMT2 development would only use approximately 35 acres of 

7.5% of the Phase 3 expansion.

Other Potential Impacts

There are no known occurrences of BLM sensitive plant species near the proposed facilities for any of the 

action alternatives. The nearest documented occurrence is approximately 7 miles away as described in 

Section 3.3.1, “Vegetation and Wetlands.” Overall, potential impacts to sensitive plant species are 

expected to be none to negligible under all the alternatives.

All action alternatives have the potential for spills to vegetation and wetlands resulting from pipelines, 

storage tanks, production facilities and infrastructure, drill rigs, or vehicles. Generally, because the 

location and length of oil transit pipelines under the action alternatives are similar, differences in the 

potential risk from a pipeline spill are minimal. Alternative C has a slightly greater potential risk of a 

pipeline spill due to the additional ancillary diesel pipeline.

However, greater differences in the risk to the surrounding environment are expected in regards to spill 

response capabilities as discussed in Section 2.9.2, “Spill Prevention and Response.” Over half of the 

GMT1–GMT2 Access Road (Alternatives A and B) is downgradient from the pipeline, and would act as a 

barrier to spill migration. The GMT1–GMT2 Access Road would also be used during pipeline inspections 
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and spill response. Because Alternative C is roadless and relies upon air support and yearly ice road 

construction for incident response, risks to vegetation and wetlands associated with an oil spill are 

increased throughout the life of the project.

Potential impacts of oil spills are described in BLM (2012), and in Section 4.5 of this document. The 

extent of environmental impacts from a spill would depend on the type and amount of spilled material, the 

location of the spill, and the effectiveness of the cleanup. Based on North Slope spill history, it is 

anticipated that the majority of spills would be contained on a gravel road or pad with little or no impacts 

to wetlands or vegetation.

Alternative D

Alternative D, no action, would not permit the GMT2 Project and would have no new impacts on 

vegetation or wetlands from the GMT2 Project.

Comparison of Alternatives

A major difference in access between action alternatives is the inclusion of the GMT1–GMT2 Access

Road (Alternatives A and B) or inclusion of the occupied structure pad, air access facilities, and Airstrip 

Access Road (Alternative C). Alternative C has the largest impact of all alternatives (92.0 acres), followed 

by Alternative B (87.2 acres), and Alternative A (77.9 acres). Alternative D (no action) would have no 

impact on vegetation/wetlands. Alternative C has a larger footprint than Alternatives A or B because of 

the need for the occupied structure pad, air access facilities, and the Airstrip Access Road.

The area of potential effect for indirect impacts as a result of gravel spray and dust deposition (within 328 

feet of the gravel footprint) differs among alternatives. Alternative B has the largest footprint (786 acres), 

followed by Alternative A (688.6 acres) and Alternative C (251.7 acres). The areas for Alternatives B and 

A are significantly larger than that for Alternative C because they each include a linear feature (GMT1–

GMT2 Access Road). Because Alternative C is more compact (all features are within 2.3 miles) the area 

of potential affect for indirect impacts is smaller.

Under all action alternatives, gravel placement would cover between 0.0 and 92.0 acres of each of five 

vegetation/wetland types (Alternative A: Moist Sedge-Shrub Tundra, Old Basin (Ice Rich) Wetland 

Complex, Tussock Tundra, and Wet Sedge Meadow Tundra; Alternative B: Fresh Sedge Marsh, Moist 

Sedge-Shrub Tundra, Old Basin (Ice Rich) Wetland Complex, Tussock Tundra, and Wet Sedge Meadow 

Tundra; Alternative C: Fresh Sedge Marsh, Moist Sedge-Shrub Tundra, Tussock Tundra, and Wet Sedge 

Meadow Tundra; Table 115). Map 3.3-2 depicts the GMT2 Access Road route and vegetation types that 

would be crossed.

Alternatives A and B include construction of the GMT1–GMT2 Access Road and the GMT2 drill pad. 

Alternative C includes pads, air access facilities, and the 0.9-mile long connecting Airstrip Access Road. 

These features could result in impacts to vegetation from inundation (see Section 4.2.2.4, “Comparison of 

Alternatives, Water Resources”). Impacts would be mitigated by installation of culverts where feasible to 

allow maintenance of the existing hydrologic regime. For Alternatives A and B, culverts are considered at 

all water crossings. Alternatives A and B would potentially require an estimated 46 culverts and 50 

culverts, respectively (Table 76). Alternative C would have a 0.9-mile Airstrip Access road, which could 

require an estimated five culverts. Discussion of water crossings is included in Section 4.2.2.3.

Alternatives A and B would require year-round vehicle traffic along the GMT1–GMT2 Access Road 

while Alternative C would provide year-round access via aircraft and vehicle access only during the iceroad season. Indirect impacts resulting from gravel spray/dust deposition onto the vegetation would result 

from vehicle traffic along the GMT1–GMT2 Access Road (Alternatives A and B) or from aircraft landing 

and vehicle traffic along the Airstrip Access Road (Alternative C). There would be less gravel spray/dust 
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deposition associated with Alternative C from vehicle traffic due to the shorter Airstrip Access Road and 

typical vehicle traffic being slower than along the GMT1–GMT2 Access Road, but the amount of dust 

deposition from aircraft is not known.

Alternatives A and B would require 2 years of ice roads to support construction, while Alternative C 

would have 30 additional years of a 7.0-mile long annual ice road. These annual ice roads within the same 

corridor could result in the vegetation being scuffed or compressed year after year. Additionally, ice roads 

could alter drainage during spring break-up and temporarily inundate vegetation because the ice would 

melt more slowly than the surrounding snow. For all alternatives, blockage of streamflow could occur and 

thus temporarily inundate vegetation if ice roads are not adequately slotted or breached.

4.3.1.5 Mitigation

Design features and activities intended to minimize impacts from the project would be included in all the 

action alternatives. These include relocation of facilities, use of existing infrastructure, construction and 

use of ice roads and pads, winter construction, avoidance of river crossings, avoidance of standing water 

creation, and avoidance of gravel contaminants. 

Lease stipulations and best management practices, if properly implemented, should effectively reduce the 

impacts of development on vegetation (BLM 2012) and would provide additional protection. Specifically, 

BMPs A-1 through A-7 on solid and liquid-waste disposal, fuel handling, and spill cleanup would reduce 

the potential for intentional or unintentional releases, spills, and solid waste onto the tundra. BMPs A-9 

and A-10 would reduce air pollution. BMP C-2 regarding overland moves (and seismic work) would also 

effectively minimize impacts to vegetation. In addition to BLM best management practices, certain State 

of Alaska statutes and regulations also protect vegetation and wetlands. Appendix J lists State 

environmental protection regulations.

Best management practices affecting development (BMP E-4, E-5, E-6, and E-12) such as facility design 

and construction of pipelines, roads, pads, airstrips, and other facilities, are expected to effectively 

minimize the amount of habitat that would be altered by gravel pads and other surface disturbances. 

Proposed minimization measures include the following: access road designed to maintain natural water

flows and to minimize impacts to permafrost; equipment and techniques designed to reduce surface 

compaction; erosion control planning; design, spill prevention and response planning; and minimization 

of impacts to subsistence. Lease Stipulation G-1 would facilitate the regrowth of native vegetation 

following facility abandonment. The setbacks outlined in Lease Stipulations K-1 and K-2 associated with 

development near rivers and lakes would minimize impacts in high-value wetlands such as areas 

dominated by pendant grass, riparian or floodplain habitats. BMP L-1 would minimize impacts to 

vegetation of summer tundra travel, if such an action is proposed and permitted.

Potential Mitigation Measure 1: Reclamation of Wetlands, Natural Soils and Vegetation

Objective: Ensure project infrastructure is dismantled when no longer in use to promote reclamation of 

wetlands, soils and vegetation.

Requirement/Standard: When wells and facilities have met their useful life and are to be abandoned, 

recommendations found in the reclamation plan will be applied whenever feasible. Any planned 

reclamation goals will be in consultation with the local community, tribal government, and interested 

stakeholders.

Potential Benefits and Residual/Unavoidable Impacts: Reclamation can begin after the following two 

conditions are met: 1) the operator determines that a portion of a developed site will no longer be used for 

oil and gas operations and 2) BLM determines that environmental conditions are favorable for the 
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replacement and reestablishment of natural soils and vegetation. Returning vegetation and wetlands to a 

more natural state after removing gravel roads and pads will contribute to the long-term rehabilitation of

the region. The permittee will report to the BLM on the latest research and methods related to reclamation

of oil and gas infrastructure and roads in the arctic every 2 years. Abandonment and reclamation activities

within the NPR-A are governed by 43 CFR Part 3160, subpart 3162, which requires lessees to reclaim the 

land in accordance with plans approved by the BLM (43 CFR 3162.3-4 and 3162.5-1). 

In addition to the BLM’s existing and proposed mitigation, ConocoPhillips may also be subject to 

mitigation measures imposed by the Corps of Engineers in their Record of Decision. Appendix R 

includes a description of the mitigation measures proposed by ConocoPhillips as part of their application 

for a permit to place fill in waters of the U.S. 

4.3.1.6 Conclusions

The likelihood of impacts to vegetation and wetlands identified in this document can be separated into 

reasonably foreseeable and potential as shown in Table 117. No evaluated effects were determined to be

without impacts of one or the other category.

Plant communities and wetlands would be impacted by gravel mining and placement. They could also be 

altered by dust deposition, salinity of gravel fill used in construction, snowdrifts, and blockage of natural 

drainage patterns. 

Table 117. Likelihood of impacts; vegetation and wetlands

Reasonably Foreseeable Impacts Potential 

Smothering and loss of vegetation and alteration of the 

natural soil horizon by compression from gravel 

placement.

Changes to vegetation or potential destruction caused 

by changes to natural drainage patterns or dewatering 

discharges from mining operations.

Alteration of snow accumulation patterns from gravel 

infrastructure and pipelines.

Physical damage and stress to plant communities from 

seasonal ice infrastructure and altered drainage 

patterns during spring break-up.

Shading of vegetation from pipelines. Contamination from spills or leaks.

Smothering of vegetation and changes in soil 

composition resulting from gravel spray/dust deposition 

caused by vehicle activity or aircraft traffic on gravel 

pads, road, and airstrip.

Damage to vegetation by impoundment of water from 

gravel infrastructure.

Introduction of nonnative plant species by equipment 

use.

Compression/alteration of wetlands from off-road 

tundra travel.

Direct and Indirect Impacts

The direct impacts of construction and operation of the project alternatives include destruction of 

vegetation and wetlands during construction of gravel pads, roads, and airstrip; and from excavation of 

material sites and construction of vertical support members. These impacts are characterized as long-term. 

The direct impacts would be slightly lower for Alternative A, intermediate for Alternative B, and greatest 

for Alternative C as described in Table 115. The area of potential effect for indirect impacts from 

Alternatives A and B are roughly 2.7 and 3.1 times, respectively, that from Alternative C (see Table 116).

Overall, all alternatives are predicted to have minor impacts to vegetation and wetlands. The primary 

difference is the relative immediacy of impact, with Alternative A and B having less direct impact and 

more indirect impact, and Alternative C having the most direct impact and least indirect impact. 

Alternative D would have no impacts to vegetation or wetlands.. 
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Risk of inundation would be similar for all action alternatives: Alternative B contains the longest access 

road and would have a slightly greater risk of inundation than Alternative A or C. Impacts would be 

mitigated by installation of culverts for cross drainage (as for Alternative A), however, change in 

vegetation over time is still possible due to alteration and channelization of sheet flow through culverts. 

Alternative C contains the shortest access road, and would have culverts installed at similar intervals 

along the Airstrip Access Road, but culverts could not be installed across the airstrip since they are too 

wide to allow use of culverts. For all alternatives, culverts could not be installed across the GMT2 drill 

pad since it is too wide to allow use of culverts.

Potential Impacts Due to Climate Change

Studies of climate change in the Arctic have shown that warming temperatures affect the distributions and 

growth rates of plant species, resulting in changes to the composition of Arctic tundra toward increased 

shrub height and cover extent (Chapin et al. 1995; Sturm et al. 2001; Walker et al. 2006) and increased 

grass and sedge species in some areas. These increases would likely be at the expense of lichen and moss 

cover (Chapin et al. 1995; Cornelissen et al. 2001, Jorgenson and Buchholtz 2003c; Epstein et al. 2004;

Walker et al. 2006). Warming may also increase the potential for thermokarst resulting from disturbance 

of organic mats or creation of impoundments. As the climate warms, spread of invasive plants northward 

would become more likely (Carlson et al. 2015), and project components would provide vectors and 

establishment sites for such plants (BLM 2012). There also exists a potential for interaction between 

project impacts and climate change effects. In particular, climate change could cause vegetation changes 

and wetland drying that may exacerbate the indirect impacts of gravel fill, including dust deposition and 

tundra drying. The latter may occur on the downgradient sides of gravel fills. Other effects of climate 

change are discussed in Section 3.2.4, “Climate Change.”

4.3.2 Fish

The potential impacts of oil and gas development on fish resources in the NPR-A, including the project 

study area, are discussed in BLM (2012, Section 4.3.7); potential impacts from the nearby GMT1 

development that will be connected to GMT2 are found in BLM (2014, Section 4.3.2). The discussion 

here largely focuses on comparison of the alternatives.

4.3.2.1 Construction

Construction of infrastructure for GMT2 will occur over two or three winter seasons. Impacts to fish are 

substantially similar across both construction schedules. Impacts resulting from construction are described 

below.

Ice Roads and Pads

The potential effects of ice roads and pads on fish include impacts to water-source lakes and fish in those 

lakes, water quality impairment during runoff, and fish barriers at stream crossings during spring breakup 

(BLM 2012, Section 4.3.7.2). These effects are mitigated by BMPs A-3, A-4, and A-5 (hazardous 

materials), B-1 and B-2 (water use), and C-3 and C-4 (stream crossings). 

The amount of lake water use and water quality impairment risk associated with each alternative is 

proportional to the miles of ice road that would be required. From this perspective, during the 

construction phase the potential incidence of impacts on fish would be greatest under Alternative C (102.8

miles, 251.3 million gallons) and slightly less under Alternative A (96.5 miles, 227.9 million gallons) and 

Alternative B (95.2 miles, 230.8 million gallons). 

Ice road stream crossings for the construction phase of each of the alternatives would occur at the Nigliq 

Channel and Tinmiaqsigvik (Ublutuoch) River during both years and additionally at the Colville River, 
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Barely Creek, and Crea Creek during one of the years. In the past decade, industry has utilized the 

shallow upper Ublutuoch River crossing several times. The lower crossing would be in the vicinity of the 

permanent bridge where water depths are much greater (MJM Research 2005a) and overwintering habitat 

exists for several species of fish (Map 3.3-3) (Morris 2003). In-season monitoring would be necessary 

here to avoid impacts to fish habitat, similar to data collected annually at the Colville River ice bridge 

(e.g., Michael Baker Jr. Inc. 2013b). Portions of the ice road spanning the smaller streams would also 

require adequate breaching in the spring to ensure the passage of fish.

Gravel Mining

The potential effects on streams from gravel mining include changes in geomorphology as well as 

increased turbidity and sedimentation (BLM 2012, Section 4.3.7.2). Mitigation would occur under BMP 

E-8 (gravel mine site design and reclamation), which allows for site-specific considerations in developing 

a mining plan. 

The Arctic Slope Regional Corporation Mine site is the proposed gravel source for the GMT2 Project, 

regardless of the action alternative. The Arctic Slope Regional Corporation Mine is adjacent to the 

Colville River, which is a valuable fishery resource for the region (Morris 2003; MJM Research 2007; 

Moulton et al. 2010). Alternative C would require the most gravel (930,000 cubic yards), followed by 

Alternative B (747,300 cubic yards), with the least amount of gravel required for Alternative A (671,300 

cubic yards). However, since the Arctic Slope Regional Corporation Mine site does not directly disturb 

fish-bearing waters, none of the alternatives should have an impact on fish habitat due to gravel mining.

The placement of gravel on the tundra (gravel fill) for the construction of roads, pads, and airstrips would 

potentially cause an increase in turbidity and sedimentation in streams and lakes during the following 

spring breakup period. The longer-term potential impacts from gravel fill are discussed under Section 

4.3.2.2, “Drilling and Operation.”

4.3.2.2 Drilling and Operation

Ice Roads and Pads

Only Alternative C would require ice roads (7.0 miles annually) during the drilling and operation phase of 

the project, necessitating a greater amount of winter water needs (drilling: 2.5 million gallons per year; 

operations: 7.5 million gallons per year) compared to Alternatives A and B (0.0 miles per year; drilling 

2.5 million gallons per year; operations: 0.5 million gallons per year). The annual ice road program under 

Alternative C would be necessary over the life of the project, making fish resources the most susceptible 

to winter impacts under that alternative.

Roads, Pads, and Airstrips

Possible effects of roads, pads, and airstrips (i.e., gravel fill) on fish resources are related to runoff 

patterns, runoff content, and stream crossings (BLM 2012, Section 4.3.7.2). These potential effects are 

mitigated by Lease Stipulations/BMPs A-2 (wastewater), A-3, A-4, and A-5 (hazardous materials), A-7 

(produced water), Lease Stipulation E-2 (infrastructure setback from fish-bearing waters), E-5 (minimize 

footprint), E-6 and E-14 (stream and marsh crossings), and K-1 (Fish Creek and Ublutuoch River 

setbacks). The specific location of gravel infrastructure under each alternative most strongly influences 

the potential effects on surrounding waters.

Alternatives A and B require a gravel road between GMT1 and GMT2, while Alternative C only requires 

an airstrip access road. Generally, the greater the road length, the more likely surface water flow may be 

altered and potentially impact natural water levels in streams and lakes. Similarly, the greater the road 

surface area, the more likely fish resources may be impacted from runoff content (e.g., water quality) or 
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further effects on runoff patterns caused by the addition of this impervious surface. Alternative B requires 

the longest road (9.3 miles) and largest surface area (72 acres). Alternative A requires slightly less length 

(8.2 miles) and area (62.8 acres), while Alternative C requires much less than either of the other 

alternatives (0.9 mile, 7.2 acres). However, while the road under Alternative B would be slightly longer 

than under Alternative A, Alternative B more closely follows a watershed boundary, potentially reducing 

possible impacts to surface water drainage. Additionally, the road under Alternative B does not cross any 

fishbearing streams. The road under Alternative A crosses a small stream (outlet from Lake M9925) 

where ninespine stickleback have been observed. A culvert designed to allow passage of ninespine 

stickleback seasonally into Lake M9925 could mitigate impacts to the system.

The placement of the GMT2 drill pad is the same for all alternatives; the pad is situated in an area of 

localized high terrain with minimal contributing upstream catchment area or surface water cross drainage. 

However, pad size is greater under Alternative C (19.1 acres) than under Alternatives A and B (14.0 

acres). Additionally, Alternative C would require an occupied structure pad (18.4 acres) and an airstrip 

(47.3 acres) while the other alternatives would not, further contributing to a greater likelihood of impacts 

to fish resources from gravel pads under Alternative C. 

A final consideration for potential impacts of roads, pads, and airstrips on fish resources is the proximity 

of these structures to lakes and streams. For example, the E-2 Lease Stipulation requires that permanent 

oil and gas facilities be set back greater than 500 feet from fishbearing waterbodies. The only gravel 

infrastructure that would be located within 500 feet of a fishbearing waterbody is the road for Alternative 

B, which would be located within that distance from Lake M9925. 

Pipelines

The potential for pipelines to effect fish resources is related to inspection and maintenance, stream 

crossings, length (fluid spill potential), proximity to fishbearing waterbodies, and number of different 

pipes (BLM 2012, Section 4.3.7.2). These elements would be mitigated by BMP A-3 (spill prevention and 

response plan), Lease Stipulation E-2 (infrastructure setback from fish-bearing waters), BMP E-4 

(pipeline design, construction, and operation), and BMP L-1 (summer tundra travel), and State of Alaska 

statutes and regulations (see Appendix J).

Only slight differences exist among the alternatives regarding the risk of a pipeline impacting fish. The 

maintenance plan would be the same, there are no stream crossings, and the lengths are very similar, with 

Alternative B having a marginally longer pipeline (9.4 miles) compared to Alternatives A and C (8.6 

miles). However, the Alternative B pipeline does remain set back greater than 500 feet from all 

fishbearing waterbodies, while Alternatives A and C are closer than that to Lake M9925. Finally, 

Alternative C would have an additional pipe for diesel and mineral oil, which would not be required under 

Alternatives A and B.
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Table 118. Comparison of impacts by alternative and project phase

Project Component Alternative A Alternative B Alternative C

Years of ice roads 2-3 2-3 32

Miles of ice roads 

(construction)

96.5 95.2 102.8

Estimated winter water 

needs for ice roads and 

pads (construction) a

227.9 MG 230.8 MG 251.3 MG

Ice road stream 

crossings (construction)

Nigliq Channel & 

Ublutuoch River (2 years 

each); Colville River, 

Barely Creek, & Crea 

Creek (1 year each)

Nigliq Channel & 

Ublutuoch River (2 years 

each); Colville River, 

Barely Creek, & Crea 

Creek (1 year each)

Nigliq Channel & 

Ublutuoch River (2 years 

each); Colville River, 

Barely Creek, & Crea 

Creek (1 year each)

Miles of ice roads (drilling 

& operation)

0 0 7.0

Estimated winter water 

needs for ice roads and 

pads (drilling & 

operation) a

Drilling: 2.5 MG/year

Operations: 0.5 MG/year

Drilling: 2.5 MG/year

Operations: 0.5 MG/year

Drilling: 9.5 MG/year

Operations: 7.5 MG/year

Ice road stream 

crossings (drilling & 

operation)

0 0 0

Gravel mine needs 671,300 cubic yards 747,300 cubic yards 930,000 cubic yards

Gravel road length 8.2 miles 9.3 miles 0.9 miles

Gravel road surface area 62.8 acres 72 acres 7.2 acres

GMT2 drill pad 14.0 acres 14.0 acres 19.1 acres

Occupied structure pad 0 0 18.4 acres

Airstrip & apron 0 0 47.3 acres

Gravel road stream 

crossings 

1 (M9925 outlet) 0 0

Fishbearing waterbodies 

within 500 feet of gravel 

infrastructure

1 (M9925) 1 (M9925) 0

Pipeline length 8.6 miles 9.4 miles 8.6 miles

Fishbearing waterbodies 

within 500 feet of 

pipeline

1 (M9925) 0 1 (M9925)

Additional pipeline 

components?

none none Diesel & mineral oil supply

a MG = million gallons.
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4.3.2.3 Comparison of Alternatives

In general, the potential impacts of each action alternative on fish and fish habitat are related to individual 

project components most relevant to fish resources, as listed in Table 118.

All alternatives pose similar risk to fish and fish habitat during the first 2 to 3 years of the construction 

phase. After that, much less risk would occur during winter under Alternatives A and B, as compared to 

Alternative C, which would require an annual ice road. In considering year-round potential impacts, 

Alternatives A and B would have similar types of possible effects from permanent roads, although 

Alternative A would place fish resources at the greatest risk due to a stream crossing. Alternative C would 

have the least year-round potential impacts to fish; however, the substantial increase in impervious 

surface area required for the airstrip and occupied structure pad could lead to increased impacts under 

Alternative C in the vicinity of the GMT2 pad. The impact risk associated with Alternative C would be 

localized at the GMT2 pad, while the impact risk from Alternatives A and B would span the landscape. 

The risk to fish resources from oil pipelines would be very similar under all the alternatives, although the 

additional diesel (and mineral oil) pipe required for Alternative C makes that alternative more likely to 

result in an impact from pipelines. 

4.3.2.4 Mitigation

The risk of impacts to fish and fish habitat related to project activities would be reduced by adherence to 

best management practices and lease stipulations that are part of the NPR-A IAP (BLM 2012). These best 

management practices and lease stipulations include requirements and guidelines for handling hazardous 

materials, water use, ice road stream crossings, culvert placement and design, and size and location of 

pads, roads, and pipelines. A list of best management practices and lease stipulations that will reduce the 

risk of impacts to fish and fish habitats is outlined below. However, information in the list only 

summarizes the broad intention of the BMPs; the full language of each BMP is found in the NPR-A IAP 

(BLM 2012) and it should be noted that some of the BMPs do allow for exceptions, if warranted. In 

addition to BLM best management practices, certain State of Alaska statutes and regulations also protect 

fish resources. A list of State environmental protection regulations can be found in Appendix J.

• BMP A-2: Pumpable waste be injected and that mud and cuttings be stored only temporarily until 

they are used to facilitate injection or backhauled.

• BMPs A-3 and A-4: Require impermeable containment, spill prevention, and response planning.

• BMP A-5: Prohibits equipment refueling within 500 feet of the active floodplain of any waterbody

and fuel storage exceeding 210 gallons must also be outside of this setback.

• BMP A-6: Prohibits surface discharge of reserve-pit fluids.

• BMP B-1: Prohibits winter water withdrawals from rivers and streams.

• BMP B-2: Limits withdrawal based on maximum depth and fish species present; requires intake 

screens on water withdrawals and screen design must be approved by Alaska Department of Fish and 

Game, Division of Habitat; sets restrictions on withdrawals during ice-free periods; limits compaction 

or removal of snow from an area of grounded ice.

• BMP C-3: Streambank protection; removal, breaching or slotting of snow and ice bridges before 

spring breakup.

• BMP C-4: Location of winter transportation bridges.

• Lease Stipulation E-2: Prohibits permanent oil and gas facilities being constructed within 500 feet 

from fish-bearing waterbodies. Note: The BLM authorized a deviation from this stipulation (BLM 

2004a). 
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• BMP E-4: Requires that pipelines be built and operated with the best available technology for 

detecting and preventing corrosion or mechanical defects.

• BMP E-5: Minimization of impervious surfaces by encouraging a reduced development footprint.

• BMP E-6: Mandates fish passage and emphasizes that bridges, rather than culverts, are the preferred 

method for channel crossings; addresses stream and marsh crossings, is to reduce the potential for 

altering natural drainage patterns. (Examples of fish-passage culvert design are provided as an 

attachment to Appendix A.) 

• BMP E-8: Requires approval of the gravel mine site design and reclamation in consultation with other 

appropriate federal, state, and North Slope Borough agencies and would be subject to additional 

protections under AS 16.05.871.

• BMP E-14: Requires hydrology and fish studies to determine the appropriate structures at stream 

channel crossings to reduce impacts on fish.

• Lease Stipulation D1: Restricts drilling in rivers, streams, and fish-bearing lakes.

• Lease Stipulation E-2: Requires that permanent oil and gas facilities and infrastructure be more than 

500 feet from lakes, with essential pipeline and road crossings evaluated on a case-by-case basis; 

limits pipelines within 500 feet of fish-bearing waters and crossing of lakes; restricts discharge of 

pollutants from vehicle and equipment use, personnel camps, and produced fluids.

• Lease Stipulation K-1: Establishes setbacks from major rivers, including Fish Creek and 

Tiŋmiaqsiġvik (Ublutuoch) River; exceptions for essential road and pipeline crossings. Note: The 

BLM authorized a deviation from this stipulation (BLM 2004a).

• Lease Stipulation K-2: Establishes a 0.25-mile development setback from deep-water lakes, defined 

as those greater than 13 feet except essential road and pipeline crossings considered on a case-by-case 

basis.

Proposed New Mitigation Measure for Fish

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.

Requirement/Standard: Two weeks before placing culverts, submit to 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 in an effort to increase the likelihood that the 

objective of BMP E-6 is met.

4.3.2.5 Conclusion

As described above, the potential impacts to fish include injury at water-use intakes, altered water quality, 

physical habitat changes (water quantity, flow patterns, and geomorphology), point and non-point source 

pollution, increased turbidity and sedimentation, and barriers to fish movement. Collectively, these could 

contribute to reduced success at different life history stages, behavioral changes, diminished condition, 

susceptibility to pollutants or disease, shifts in fish species distribution, and mortality.

Based on the various project components most relevant to fish (Table 118), and the potential impacts 

associated with those, Alternative C would have the greatest potential impact on fish resources during the 

winter (due to ice road stream crossings and lake water withdrawals) and the greatest impacts from 
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pipelines due to reduced capacity to detect and respond to spills. Impacts from gravel infrastructure would 

likely be more extensive under Alternatives A and B. While there are slight differences between some 

project components within Alternative A and B, the magnitude of risk would be very similar. 

The context of all alternatives would be “important”, with anadromous fish species and anadromous 

waters in the project area protected by legislation, along with the existence of seasonal habitats critical to 

the life history of many fish species. Similarly, the geographic extent of all alternatives would be 

“regional”, due to the fact that many fish species make extensive seasonal movements and utilize a 

variety of habitats that can extend beyond the project areaIn the immediate area between GMT1 and 

GMT2, the intensity of effects would likely be “low” and the duration would likely be “temporary”.

4.3.3 Birds

The potential direct and indirect impacts to birds from the activities and infrastructure associated with the 

proposed GMT2 Project and other action alternatives are addressed in this section.

The GMT2 Project has the potential to impact birds; bird behavior; and their nesting, brood-rearing, 

foraging, and molting habitats; through habitat loss and alteration; disturbance from noise and visual 

activity; displacement from habitats; or attraction to habitats altered by thermokarst and early green-up 

adjacent to gravel infrastructure (BLM 2012, U.S. Army Corps of Engineers 2012).

The size and percentage of the project area covered by potential high-value habitats for each focal bird 

species, shown in the first column of Table 119 and Table 120, are used in evaluation of direct and 

indirect impacts. Potential high-value habitats were selected using statistical analysis which identified 

species preference for select habitat types within the Alpine Satellite Development Plan project area and 

Colville River Delta whenever available (Johnson et al. 2013). For some species groups (e.g., gulls, geese, 

shorebirds, and passerines), potential high-value habitats were selected by habitat use documented in 

Johnson et al. (2013) and BLM (2004). The evaluation of birds is divided into two project phases: (1) 

construction and (2) drilling and operation.

4.3.3.1 Construction

Birds and bird habitats could be impacted during construction by habitat loss and alteration, disturbance 

and displacement, and mortality.

Habitat Loss and Alteration

Long-term bird habitat loss and alteration would be initiated during gravel extraction and placement of 

fill. These activities would be completed during the winter, when most birds are absent from the project 

area. No birds or nests would be lost as a direct result of gravel mining or placement of fill. During 

construction of roads and pads, gravel mine sites and tundra covered by gravel would be lost to use by 

birds. This loss of habitat would continue through the duration of the construction and operation of the 

project (BLM 2012). Habitat restoration are likely to create habitats that are different from the ones 

initially lost to gravel extraction and placement and may not be able to support species that may have 

been displaced.

In addition to permanent habitat loss, temporary loss of habitat associated with gravel placement could 

occur on tundra adjacent to gravel structures, where accumulated snow from snow-plowing activities or 

snowdrifts would become compacted and lead to delayed snowmelt. Delayed snowmelt persisting into the 

nesting season could preclude tundra-nesting birds from nesting in those areas (BLM 2012).

Gravel infrastructure such as roads and pads can result in gravel spray and dust deposition (e.g., from 

vehicle traffic or wind), which can affect bird habitat by causing early snowmelt, and thus, early green-up 
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on tundra adjacent to roads, pads, and airstrips which could attract waterfowl and shorebirds early in the 

season when other areas are not yet snow-free. Dust deposition could also increase thermokarst and soil 

pH, and reduce the photosynthetic capabilities of plants in areas adjacent to roads (Auerbach et al. 1997). 

Ground and air traffic (including helicopters), and wind can influence the amount of dust that may be 

deposited adjacent to roads and pads (BLM 2012). For this analysis, a distance of 300 feet from the edge 

of gravel roads and pads was used to estimate the zone of impact for dust deposition, as discussed in 

Section 4.3.1, “Vegetation and Wetlands.”

Tundra ice roads would cause temporary bird habitat loss and alteration. Ice roads remain in place until 

after most birds have initiated nesting, causing temporary nesting habitat loss (Yokel et al. 2007) (Section 

4.3.1 “Vegetation and Wetlands”). Ice roads also compress the vegetation, especially standing dead 

vegetation used for concealment by some nesting birds. Standing dead vegetation would require multiple 

growing seasons to reestablish, likely resulting in interim duration habitat alteration (U.S. Army Corps of 

Engineers 2012). Generally, changes in the thermal regime or compaction of soil have not been found to 

result from ice road construction. A study by Yokel et al. (2007) suggests that seasonal ice roads and pads 

constructed within the same footprint each year do not have additive effects over years.

Relatively slow melting ice roads could act as temporary dams, causing impoundments of water. 

Impoundments created by ice roads or gravel structures could be ephemeral (drying up early during the 

summer) and could cause temporary or permanent flooding on adjacent tundra, or they could become 

permanent waterbodies that would persist from year to year. Hydrological impacts along roads and pads, 

such as impoundments are discussed in Section 4.2.2, “Water Resources.” Tundra covered by impounded 

water could result in a loss of nesting and foraging habitat for some birds. Impoundments could also 

create new foraging and brood-rearing habitat that would be beneficial to some bird species, although the 

proximity to roads also may increase the potential for traffic-induced mortality, especially of young 

(inexperienced) birds (BLM 2012).

Water withdrawal from lakes during ice road construction has the potential to lower the level of lakes and 

affect waterfowl and shorebirds that use adjacent habitats, particularly small islands and shoreline areas 

that loons and waterfowl use for nesting. Changes in the surface levels of lakes due to water withdrawal 

would be dependent on the amount of water withdrawn, the volume of the lake, and the recharge rate. 

There is also potential for impacts to birds resulting from potential impacts to invertebrate and fish food 

resources from varying winter water levels if pumped lakes do not fully recharge (BLM 2012).

Disturbance and Displacement

Gravel mining and placement of gravel fill would occur during winter when most birds are not present. 

Road work such as grading, compacting, and reshaping of roads and pads would occur during summer 

when birds are present. The noise and vehicle traffic during these activities would likely disturb and 

displace birds away from gravel roads and pads. Disturbance causes birds to expend energy in 

responding, although it may not necessarily reduce their survival or productivity (U.S. Army Corps of 

Engineers 2012). Noise would likely cause the greatest disturbance to birds between June 1 and July 15

when birds on nests would be unable to move away from the disturbance (U.S. Army Corps of Engineers

2012). Construction-related disturbances to birds are also discussed in BLM (2004).

Some birds that may have nested at sites previously not covered by gravel could be displaced and move to 

adjacent areas to nest. Johnson et al. (2003a) reported that waterbirds nesting near the Alpine oil field that 

were displaced from nesting sites by gravel placement probably moved their nests to nearby adjacent 

habitats. In addition, there may be a functional loss of habitat in areas near roads and pads, if 

development-related disturbances preclude birds from utilizing these habitats. Impacts related to habitat 

loss may be more severe for species that have specific habitat requirements or exhibit site fidelity (BLM 

2012).
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Noise and visual cues from air traffic would likely disturb birds, although the amount and impact from air 

traffic is unknown and likely to vary by species. Bird responses to aircraft include alert and concealment 

postures, interrupted foraging behavior, flight, and a reduction in nest attendance (U.S. Army Corps of 

Engineers 2012). The impacts of routine aircraft flights could range from bird avoidance of certain areas 

to abandonment of nesting attempts or lowered survival of young. The potential impact to birds from 

aircraft noise would probably be greatest during the nesting period when the movements of incubating 

birds are restricted and the molting period when, in addition to being a period of restricted movements, 

birds may be energetically stressed and sensitive to disturbance (BLM 2012).

Aircraft noise levels would be highest during take-offs and landings, and most aircraft-related disturbance 

would be concentrated around the airstrip for brief time periods. Disturbance may also increase as a 

function of flight frequency, and birds in areas that experience many flights may experience larger 

disturbance impacts than those in areas with few flights. The behavioral response of birds to aircraft 

disturbances near the existing and planned airstrips (see Chapter 2, “Proposed Project and Alternatives”) 

would not necessarily result in lowered nest success. 

Although the potential exists for displacement of some nesting birds near routinely used airstrips, because 

of numerous over flights, landings, and takeoffs, some birds may habituate to routine air traffic. Within 

the project study area, the duration of flights would be short and occur in a specific area, and although 

likely to cause disturbance to birds, depending on the species and time of year that disturbance may be 

minimal. However, temporary displacement from high-value habitats could affect energy budgets of some 

birds, and incubating birds could be temporarily displaced from nests, making the nests more vulnerable 

to predation (BLM 2012). The mitigation measure of hazing birds at or near airstrips would likely result 

in temporary disturbance and possible displacement of birds.

Oil spill response training activities using watercraft may be conducted on rivers and lakes during the 

open-water season. Spill response training activities would have the potential to disturb foraging, nesting, 

or brood-rearing waterfowl and other birds.

When considering all potential types of disturbance to birds, the proposed project could result in 

temporary or permanent displacement from high-value habitats, potentially resulting in decreased nesting 

and nest attendance, nest abandonment, nest predation, and increased energy expenditures that could 

affect an individual bird’s survival or reproduction. Roads can cause disturbance to birds by impacting 

habitat and vehicles using the roads can impacts birds through direct mortality or disturbance of natural 

behaviors. 

Disturbances could displace birds from feeding habitats and negatively affect energy budgets. 

Disturbances would impact birds during the entire time the birds are using the project area, although the 

impacts may vary depending on the species involved, including the pre-nesting period when birds gather 

to feed in open areas near roads, during nesting if the disturbance causes the bird on the nest to leave the 

nest exposing the nest to an increased rate of predation, and during brood-rearing and fall staging when 

some geese exhibit higher rates of alertness in areas near roads than do birds in undisturbed areas. Some 

evidence suggests that pedestrian traffic may have a greater impact on some species of birds than 

vehicular traffic (Meixell and Flint 2017, BLM 2012). Various studies have documented reduced 

densities of birds breeding near trafficked roads (e.g., Veen, 1973; Räty, 1979; Van der Zande et al., 

1980; Ellenberg et al., 1981; Illner, 1992; Reijnen and Foppen, 1994). Reijnen et al. (1995) observed that 

bird densities in open grasslands declined where the traffic noise burden exceeded 50 dbA. Based on the 

observed relationship between noise burden and bird densities, Reijnen, Veenbaas and Foppen (1995) 

created a simple model predicting the distance to which breeding bird populations might be affected by 

traffic noise. The traffic volume from this project are expected to be only a fraction of that in the model 

and it is not expected to produce the same effect.
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Mortality

Birds may collide with structures necessary for operation such as communication towers, flare towers, 

buildings, antenna guy-wires, and elevated pipelines. Descriptions of such structures associated with 

GMT2 can be found in (Section 2.4.3, “Drill Pad and Support Facilities”). Satellite dishes, elevated radio 

antennae, and radio repeater sites would also act as potential collision hazards. Although bird collisions 

with oil field structures are expected to be infrequent, some collisions and resultant mortality are 

probable.

Bird collision events with infrastructure during poor weather conditions are rare and episodic, but would 

have the potential to occur for the life of the project (long-term). Facilities would always be lighted, a 

situation which can attract birds (U.S. Army Corps of Engineers 2012). Poor visibility due to fog and low 

light conditions, which are common in the project study area (see Section 3.2.3.1, “Climate and 

Meteorology”) would contribute to the risk of collisions with infrastructure. The potential for impact is 

lessened by the mitigating measure of downward shielded lighting. Most infrastructure collisions would 

likely involve individual birds or several birds from small flocks, but under certain conditions could 

involve large numbers of individuals.

Vehicle traffic on infield gravel roads poses the greatest threat to birds during the summer, when the 

largest numbers of birds are present in the project study area, possibly resulting in bird collision mortality. 

Among other species that are at risk, geese attracted to roadsides by early vegetation sprouting, broodrearing waterfowl, and ptarmigan utilizing roadside grit are susceptible to collisions with vehicles. 

Although geese may gain access to nutritious forage near roads, their exposure to vehicle disturbances 

also increases. Overall, vehicle collision mortality is generally thought to be low within North Slope oil 

fields, although this is poorly documented (U.S. Army Corps of Engineers 2012).

Predation

Ravens, gulls, Arctic fox and red fox, bears and other predators may be attracted to areas of human 

activity where anthropogenic sources of food and shelter are present. Survival of these predators could 

increase due to the availability of anthropogenic food sources and infrastructure that may provide nesting 

or denning sites, particularly during the winter. Other food sources for predators can arise from roadkill 

on new roads creating opportunities for scavenging predators. The BLM has included recommendations 

for a roadkill monitoring and reporting system in Section 4.7, “Mitigation Measures and Monitoring.”

Increased levels of bird and egg predation due to elevated numbers of predators could adversely affect 

bird populations (BLM 2012).

Oil field operators have installed predator-proof dumpsters at camps and implemented new refuse 

handling techniques in recent years to minimize the attraction of predators. In addition, oil field workers 

undergo training to make them aware of the problems associated with feeding wildlife. Backensto (2010) 

found ravens in the North Slope oil fields to be very productive and that they used processing facilities, 

bridges, towers and inactive drill rigs being most often for nesting. At the Alpine oil field, Johnson et al. 

(2003a) reported that ravens were rarely observed in the area prior to development of infrastructure, but 

were commonly observed after development with nests confirmed in multiple years since. Although 

ravens were commonly observed after the construction of the Alpine development, Johnson et al. (2003a) 

reported no post-development increase in predation rates of loon and waterfowl nests.

Given the benefits of loon nest site selection on nest survival found by Uher-Koch et al. (2018), reducing 

predation risk and changes to landscape features selected for loon nesting may assist in ameliorating any 

negative population trends for local populations, particularly for the yellow-billed loon, a species of 

conservation concern. Artificial human-made floating “island” nesting platforms have been found to be an 

effective way to increase breeding success in loons (Merrie 1996, Hancock 2000, Piper et al. 2002) by 
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reducing the impacts of mammalian egg predation and lake level fluctuations on nest survival. Predator 

control (e.g., fox removal) can also improve nest success of tundra nesting birds (Anthony et al. 1991).

4.3.3.2 Drilling and Operation

Habitat Loss and Alteration

After initial placement of gravel to construct roads and pads in the project study area, some habitat 

alterations from the indirect impacts of snowdrifts, dust fallout, thermokarst, and ponding would continue 

during project operation as described above (Section 4.3.3.1., “Construction”). An oil spill could impact 

birds using terrestrial or aquatic habitats, and could have a particularly large effect on congregations of 

shorebirds and waterfowl. Potential impacts to birds would depend on the location and size of the spill 

and on the time of year.

Disturbance and Displacement

The types of disturbance and displacement impacts that occur during the construction phase of this project 

(Section 4.3.3.1, “Construction”) would continue through the drilling and operations phase of the project, 

including noise and visual cues from vehicles, aircraft, pedestrians, bird hazing (as a mitigation measure), 

and other disturbances. The potential displacement of birds caused by the installation of infrastructure, 

including gravel fill, pipelines, and other facilities would continue through the drilling and operations 

phase. The impacts of physical displacement by these structures would be exacerbated by the addition of 

traffic noise and visual activity on and near these facilities. Potential for disturbance associated with 

drilling would be present year-round for all action alternatives. 

Mortality

The potential for mortality from sources such as direct collisions with ground vehicles would be highest 

during the drilling and operations phase of the summer season when traffic volume is high and large 

numbers of birds are present in the project area. Birds attracted to the roadside by altered habitat, 

described above, would be at risk of mortality by vehicle strikes (BLM 2012). Mortality impacts that 

occur during the construction phase of this project, such as collisions with infrastructure (see Section 

4.3.3.1, “Construction”) would continue through the drilling and operations phase of the project.

An oil discharge in molting, staging, or brood-rearing habitats could impact large numbers of birds that 

congregate in these areas. Increased predation on nests from predators attracted to development is a 

concern for birds nesting in the GMT2 Project Study Area. Predators such as fox, bear, and predatory 

birds are attracted to the increased scavenging opportunities associated with development and humans.

Abandonment and Reclamation

The abandonment and reclamation of project facilities may involve removing gravel pads and roads or 

alternatively leaving these in place indefinitely. Revegetation of abandoned facilities could be 

accomplished by seeding with native vegetation or by allowing natural colonization. Winter activities 

would cause little disturbance or displacement, because most birds would be absent from the area. 

Depending on the types of abandonment and reclamation that actually occurs, summer road and air traffic 

could cause disturbance, displacement, and mortality to birds that would be similar in type, but at 

potentially lower intensity levels and for shorter durations than caused by traffic during the construction 

and operations phases.

Gravel pads, roads, and airstrips that are not revegetated would have diminished value to most birds. 

Revegetation without gravel removal would not return the site to its current utility for and use by birds 

(BLM 2012).
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4.3.3.3 Comparison of Alternatives

In general, the potential impacts of each action alternative on birds and bird habitat are related to 

individual project components most relevant to bird resources, as listed in Table 70.

All alternatives pose a similar extent of risk to birds and bird habitat during the first 2 years of the 

construction phase. After that, much less risk would occur during winter under Alternatives A and B, as 

compared to Alternative C, which would require an annual ice road. In considering year-round potential 

impacts, Alternatives A and B would have similar types of possible affects from permanent roads, which 

would be much less under Alternative C. However, the substantial increase in impervious surface area 

required for the airstrip and occupied structure pad could lead to increased impacts under Alternative C in 

the vicinity of the GMT2 pad. The risk to bird resources from oil pipelines would be very similar under 

all the alternatives, although the additional diesel (and mineral oil) pipe required for Alternative C makes 

that alternative potentially more likely to result in an impact from pipelines.

A major difference in components within Alternatives A and B, as compared to Alternative C, is with 

regard to the proposed access (i.e., with or without a gravel road from GMT1). Alternatives A and B 

require a gravel road which is a narrow linear feature crossing a variety of habitats; Alternative C has a 

similar sized gravel footprint, but in a concentrated location crossing fewer habitats. Direct impacts 

resulting from the footprint of Alternative C would be focused in the immediate vicinity of GMT2. The 

impacts associated with the presence or absence of a gravel road are noted throughout this section along 

with comparison of the alternatives as a whole.

Habitat loss and alteration would vary somewhat among the alternatives. The direct impacts (acres) of 

habitat loss due to gravel placement on potential high-value habitats for a suite of bird species/groups are 

shown in Table 119. Table 119 presents the predicted area of indirect impacts (acres) to potential highvalue bird habitats (for the same suite of bird species/groups as in the direct impact analysis) within a 

300-foot buffer around gravel infrastructure. Although the spatial extent of indirect impacts on bird 

habitats are greater than those for direct impacts, most direct impacts on birds (loss of habitat) are 

expected to be more significant than indirect impacts (potential change in vegetation).

Considered individually, each of the action alternatives would result in a direct impact (total gravel 

footprint) representing less than 1 percent of all the potential high-value habitats for selected bird species 

available within the project study area. In addition, none of the alternatives would directly impact more 

than the 1 percent of any single habitat identified as a potential high-value bird habitat (Table 119). 

Alternative C has the largest gravel footprint and the largest number of acres (92.0 acres) of potential 

high-value habitats directly impacted by the placement of gravel compared to 77.7 and 87.2 acres 

impacted by Alternatives A and B, respectively (Table 119).

Indirect impacts (based on a 300-foot zone extending out from gravel fill) to potential high-value bird 

habitat under Alternatives A, B, and C would each amount to less than the 1 percent (Table 120) of 

potential high-value habitats for birds for all of the habitats analyzed. In addition, none of the alternatives 

would indirectly impact more than the 2 percent of any single habitat identified as a potential high-value 

bird habitat (Table 120).
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Table 119. Direct impacts to potential high-value bird habitat types from GMT2 infrastructure within the GMT2 Project area

Habitat Type a, b, c

Project Area 

(Acres) d, e

Habitat Type as 

Percent of Total 

Project Area f

Alternative A Alternative B Alternative C

Acres (%) Acres (%) Acres (%)

Deep Open Water without Islands (GU, KE, TS) 10,276 7.1% -- -- -- -- -- --

Moist Low Shrub (PA) 7,015 4.8% -- -- -- -- -- --

Moist Sedge-Shrub Meadow (TS, SB) 23,682 16.4% 19.8 0.1% 19.7 0.1% 10.3 0.0%*

Moist Tussock Tundra (TS, PA, SB) 29,899 20.6% 51.0 0.2% 59.1 0.2% 74.4 0.2%

Non-Patterned Wet Meadow (YL, SB) 8,442 5.8% -- -- -- -- 1.7 0.0%*

Old Basin Wetland Complex (KE, SB) 10,031 6.9% 5.1 0.1% 5.9 0.0%* -- --

Patterned Wet Meadow (YL, TS, SB) 26,111 18.0% 1.8 0.0%* 2.0 0.0%* -- --

Sedge Marsh (KE, YL, TS, SB) 1,781 1.2% -- -- 0.5 0.0%* 5.7 0.3%

Shallow Open Water without Islands (KE, TS) 1,218 0.8% -- -- -- -- -- --

Total High Value Habitat 118,455 75.3% 77.7 0.06% 87.2 0.07% 92 0.08%

Unmapped Area 10,465 6.6% -- -- -- -- -- --

Notes: Values greater than 0 but less than 0.1 are noted with an asterisk (0.0 percent*). (--) cells indicate the habitat is not present within area considered for impact analysis.

a Information is only presented for those habitats that have been determined to be potential high value bird habitats, totaling 118,455 acres (75 percent of the total acreage of the 

GMT2 Project Study Area) mapped for habitat.

b Source information for habitat preferences of pre-nesting KE, nesting/brood-rearing TS, nesting YL based on Monte Carlo analysis in Tables 5, 7, 11, 17, 23, and 25 of Johnson et al. 

(2015). Source information for habitat of nesting/brood-rearing SB and nesting/foraging PA, BLM (2004a, Section 4F.3.3, pages 1134–1153). 

c Bird species/groups analyzed for habitat preferences/use: King Eider (KE), Passerines (PA), Shorebirds (SB), Tundra Swan (TS), Yellow-billed Loon (YL). 

d Note that 10,465.3 acres (6.6 percent) of the GMT2 Project area extends outside of the habitat map coverage. All project facilities under all action alternatives are within areas of 

mapped vegetation.

e Total acreage of the GMT2 Project Study Area, including both the mapped habitat area and the unmapped area is 157,408.4 acres.

f Total impacted acreage may differ slightly from other impact totals listed within the document due to rounding of individual calculated habitat impacts and presentation of only 

preferred avian habitats.
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Table 120. Indirect impacts to potential high-value bird habitats within the project study area (300-foot zone of influence) 

Habitat Type a, b, c

Project Area

(Acres) d, e

Habitat Type as

Percent of Total

Project Area

Alternative A Alternative B Alternative C

Acres (%) Acres (%) Acres (%)

Deep Open Water without Islands (GU, KE, TS) 10,276 7.1% -- -- 0.6 0.0%* -- --

Grass Marsh (YL, TS) 525 0.4% -- -- -- -- -- --

Moist Dwarf Shrubf 241 0.2% 0.3 0.0%* -- -- -- --

Moist Low Shrub (PA) 7,015 4.8% 1.4 0.0%* -- -- -- --

Moist Sedge-Shrub Meadow (TS, SB) 23,682 16.4% 172.3 0.7% 172.3 0.7% 37.9 0.2%

Moist Tussock Tundra (TS, PA, SB) 29,899 20.6% 349.4 1.2% 442.0 1.5% 178.2 0.6%

Non-Patterned Wet Meadow (YL, SB) 8,442 5.8% -- -- 0.0%* 0.0%* 4.2 0.0%*

Old Basin Wetland Complex (KE, SB) 10,031 6.9% 67.3 0.7% 67.8 0. 7% 2.4 0.0%*

Patterned Wet Meadow (YL, TS, SB) 26,111 18.0% 20.6 0.0%* 16.7 0.0%* 1.0 0.0%*

Sedge Marsh (KE, YL, TS, SB) 1,781 1.2% 7.5 0.4% 12.5 0.7% 7.1 0.4%

Shallow Open Water without Islands (KE, TS) 1,218 0.8% 2.9 0.2% -- -- -- --

Total High Value Habitat g 119,221 75.7% 621.7 0.5% 711.9 0.6% 230.8 0.2%

Unmapped Area 10,465 6.6% -- -- -- -- -- --

Notes: Values that are greater than 0 but less than 0.1 are noted with a dash (0.0 percent*). (--) cells indicate the habitat is not present within area considered for impact analysis.

a Information is only presented for those habitats that have been determined to be potential high value bird habitats, totaling 119,221 acres (76 percent of the total acreage of the 

GMT2 Project Study Area) mapped for habitat.

b Source information for habitat preferences of pre-nesting KE and nesting/brood-rearing TS based on Monte Carlo analysis in Tables 5, 8, 21, 23 of Johnson et al. (2013). Source 

information for habitat of brood-rearing/molting GE found in Table 26 of Johnson et al. (2013); not based on Monte Carlo analysis. Source information for habitat of nesting GU found in 

Table 30 and page 73 of Johnson et al. (2013); not based on Monte Carlo analysis. Source information for habitat of nesting/brood-rearing SB and nesting/foraging PA, BLM (2004, 

Section 4F.3.3, pages 1134–1153).

c Bird species/groups analyzed for habitat preferences/use: Geese, inclusive of brant and snow geese (GE), Gulls, inclusive of glaucous and Sabine's gulls (GU), King Eider (KE), 

Passerines (PA), Shorebirds (SB), Raptors and Owls (RO), Tundra Swan (TS). 

d Note that 10,465.3 acres (6.6 percent) of the GMT2 Project area extends outside of the habitat map coverage. All project facilities under all action alternatives are within areas of 

mapped vegetation.

e Total acreage of the GMT2 Project Study Area, including both the mapped habitat area and the unmapped area is 157,408.4 acres.

f Moist Dwarf Shrub is not considered a high value habitat for any bird species included in the project area.
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The Arctic Slope Regional Corporation Mine site is the proposed gravel source for all alternatives. The 

Arctic Slope Regional Corporation Mine site is an existing commercial gravel source on the East Channel 

of the Colville River, approximately 6 miles southeast of CD4, 21.0 miles east of GMT2, and 4.5 miles 

east-northeast of Nuiqsut. The habitats that would be expected to be impacted as part of gravel extraction 

for the GMT2 Project from the Arctic Slope Regional Corporation Mine site include Deep Open Water 

without Islands, Non-Patterned Wet Meadow and Patterned Wet Meadow, Moist Low Shrub and Shallow 

Open Water Without Islands, all of which are potential high-value bird habitats,

Table 121. Area of potential high-value bird habitats impacted at the Arctic Slope Regional Corporation Mine 

site for all action alternatives

Habitat Type (acres within 

mapped project area) a

Project Area 

Mapped b

(acres)

Direct Impact Acres 

(% Project Area)

Deep Open Water without Islands 10,276 26.0 (0.3%)

Moist Low Shrub 7,015 12.2 (0.2%)

Non-Patterned Wet Meadow 8,442 200.9 (2.4%)

Patterned Wet Meadow 26,111 225.0 (0.9%)

Shallow Open Water without Islands 1,218 1.4 (0. 1%)

Totals 53,062 465.5 (0.9%)

a It is assumed that the gravel resources in Phase 3 of the Arctic Slope Regional Corporation Mine site are similar to those in 

Phase 2 of the Arctic Slope Regional Corporation Mine site. As it is as yet unknown the exact area from the Phase 3 gravel pit the 

gravel for GMT2 will be extracted, this table presents information from the entirety of the Phase 3 area although the estimated area 

impacted by gravel extraction as based on the Phase 2 permit would be 83 acres of surface disturbance for 2 million cubic yards of 

gravel (U.S. Army Corps of Engineers 2013).

b GMT2 Project area based on mapped area of 146,943.11 acres.

The gravel mine site will be rehabilitated as required under the approved Arctic Slope Regional 

Corporation Gravel Mine Reclamation Plan (U.S. Army Corps of Engineers 2016). The reclamation and 

mitigation goal is for waterfowl habitat with a matrix of undisturbed tundra, deep water, shallow and very 

shallow littoral, and waterfowl nesting islands. All reclamation work will occur as part of an overall 

gravel mining operation because both the overburden material and heavy equipment necessary for the 

activities would be available (BLM 2014). 

Vehicle traffic on gravel roads may disturb or displace birds. Under all action alternatives, traffic would 

be most intense during construction, then taper off during drilling, and decrease again with post-drilling 

operation. 

Alternatives A and B, share a common road (GMT1–GMT2) where impacts from disturbance and 

displacement of birds from ground transportation would be similar for both alternatives. Alternatives A 

and B disturb similar amounts of high-value bird habitat types with Alternative A directly disturbing 77.7 

acres and Alternative B directly disturbing 87.2 acres, with the majority of those acres for both 

alternatives being Moist Tussock Tundra (Table 119). Indirect effects from Alternatives A and B would 

again primarily impact Moist Tussock Tundra (Table 120). Alternative C does not utilize a gravel road 

between GMT1 and GMT2; instead, it involves seasonal traffic across the tundra on ice roads. Alternative 

C includes a year round 0.9-mile gravel access road between GMT2 pad and the associated occupied 

structure pad and airstrip. Alternative C would directly impact 92 acres of high-value bird habitat with 81

percent of the habitat being Moist Tussock Tundra (Table 119). Indirect effects from Alternative C would 

again primarily impact moist tussock tundra (Table 120). Indirect effects from Alternative C are much 

smaller (37 percent of Alternative A and 32 percent of Alternative B) than from the other action 
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alternatives due to the gravel area being concentrated in a much smaller area compared to the long linear 

feature (gravel road) created by Alternatives A and B. Alternatives A and B would have very similar, low 

intensity, impacts to birds and Alternative C would also have low intensity impacts that would be less than 

those for the other alternatives attributed to vehicle traffic.

The presence or absence of the GMT1–GMT2 Access Road would affect type and frequency of aircraft 

traffic in the project study area throughout the life of the project. Additional information and detail on 

aircraft traffic is provided within in Chapter 2, Sections 2.5.4, 2.6.4, 2.7.4 and Appendix B. Potential 

disturbance impacts to birds from aircraft traffic under Alternatives A and B would originate from new 

flights to/from the Alpine Processing Facility/CD1 airstrip and special studies utilizing rotary aircraft. 

Alternative C would involve all-season air traffic between the Alpine Processing Facility/CD1 airstrip (or 

Kuparuk, Deadhorse, or airports outside the North Slope) and the gravel airstrip at GMT2 and special 

studies utilizing rotary aircraft.

Under all alternatives numbers of flights are the greatest during the construction period, then once 

construction is complete flight numbers drop to a lower level for drilling and annual operations postdrilling. For Alternatives A and B after construction is completed aircraft traffic, primarily during the May 

–September time period when migratory birds are present in the area, consists exclusively of helicopter 

flights to support a variety of activities including fish and wildlife studies and visits to spill response 

equipment. Under Alternative C flights to the Alpine Central Processing Facility/CD1 site are the most 

intensive until the GMT2 airstrip is constructed and deemed operable. Afterwards, aircraft flights would 

go directly to the GMT2 airstrip. Flights would be required for routine access to the GMT2 drill pad 

during the non-ice road season (April–December). During ice road season, aircraft would still be utilized 

for support of equipment and personnel. Air traffic to/from the GMT2 airstrip would be greatest during 

drilling. Once drilling is complete, flights decrease in support of essential operations and special studies.

Potential impacts to birds from aircraft under Alternative C is greater than Alternatives A or B due to the 

requirement to use aircraft to access the GMT2 drill pad when ice roads are not feasible (roughly nine 

months of the year).

The impacts associated with aircraft traffic for all alternatives are expected to be of low intensity, longterm duration, and of local extent.

Alternatives A and B would have annual ice roads constructed in Years 1–3 to allow for construction of 

gravel infrastructure. Post-construction of gravel infrastructure there would be no ice roads needed for 

these two alternatives. Alternative C requires annual ice roads to be constructed for the life of the project. 

Few birds are present in the area during ice road season and Yokel et al. (2007) found that repeated years 

of ice road construction provided only minimal evidence of additive impacts from building ice roads over 

the same path in two subsequent years making it unlikely that multiple ice road construction seasons 

would negatively impact to potential high value bird habitats.

Given the observed recovery of the tundra during the three years of study (Yokel et al. 2007), it is 

doubtful that any significant environmental benefit would be gained by requiring that all ice roads be 

completely offset from paths of previous years. A more appropriate mitigation would be to require that ice 

road routes follow the wetter habitats to the greatest extent possible without significantly increasing their 

length.

Overall, Alternatives A, B, C are expected to result in minor impacts to birds and their habitats due to the 

small amount of habitat loss expected to ccur as compared to the amount of habitat available. 

Alternative D, No Action, would result in no impacts to birds.
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4.3.3.4 Mitigation

Numerous stipulations and best management practices are in place to effectively protect birds and their 

habitats within the NPR-A (BLM 2012). These include BMPs A-1 through A-7 and E-9, which ensure that 

solid, liquid, and hazardous wastes (including fuels) do not impact birds or their habitats, and to reduce 

the potential for garbage and shelters that attract predators. The protection of bird habitats and food 

sources are addressed by BMPs B-1, C-3, C-4, and Stipulations E-2 and L-1, among others. It should be 

noted that the BLM authorized a deviation from Stipulation E-2 (BLM 2004a). In addition to BLM best 

management practices, certain State of Alaska statutes and regulations also protect birds and their 

habitats. A list of State environmental protection regulations and BLM best management practices can be 

found in Appendix J.

A wildlife avoidance and interaction plan and a predator management plan, incorporating federal, state, 

and local stipulations on wildlife interactions would be developed as part of the operational permitting 

process.

The following design measures are recommended as part of the project design to avoid or minimize 

impacts on birds (U.S. Army Corps of Engineers 2012):

• Implementing controls to minimize nesting opportunities for predatory/nuisance birds, including the 

following:

o Blocking off nooks and crannies with fabric/netting or other bird-nest deterrent.

o Using scare devices to deter birds when they land in places likely to be nesting sites.

o Removing nests as the birds try to construct them (before they have a chance to lay eggs).

Potential Mitigation Measure 1: Roadkill Monitoring System for Birds and Wildlife (BMP 2 in 

Terrestrial Mammals)

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 Authorized Officer reporting 

roadkill of birds and mammals to help the BLM determine whether additional preventative measures on 

vehicle collisions should be made.

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.

Potential Mitigation Measure 2: 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: (see public comment)
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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.

Potential Mitigation Measure 3: Gravel Pit Rehabilitation

Objective: To prevent subsidence within gravel excavation pits and improve site rehabilitation for the 

benefit of nesting waterfowl. 

Requirement/Standard: A 3:1 side slope and perimeter berm during excavation on the ASRC pit. Once 

the pit fills with water, the perimeter berm shall be pushed into the pit. 

Potential Benefits and Residual/Unavoidable Impacts: (see public comment)

The DSEIS indicates the new cells mined for the GMT2 development will be rehabilitated as a matrix of 

undisturbed tundra, deep water, shallow, and very shallow littoral, and waterfowl nesting islands. The 

previous rehabilitation efforts of Phase 1, mined in the late 1990s and early 2000s, to create similar 

habitats as described above have failed. The latest photo (2017) shows an approximately 95% reduction in 

the overburden islands and continued subsidence of the channel cut islands and complete subsidence of 

the littoral shelf to the north. In order to avoid repeating previous failures, Phase 3 of the ASRC pit be 

mined without the intention of creating shallow habitats. BMPs should be used during excavation (3:1 

side slopes and a perimeter berm to prevent thermokarsting and for safety.) Once the pit fills with water 

the perimeter berm can be pushed into the pit creating the desired matrix of habitats. 

4.3.3.5 Conclusion

Overall, Alternatives A, B, and C are predicted to result in minor impacts to birds and bird habitats. 

Alternative D, no action, would result in no impacts to birds or bird habitats.

Birds that could be affected by the action alternatives include loons, waterfowl, shorebirds, raptors, 

passerines, and ptarmigan. Most species in these groups migrate to wintering areas located outside of the 

NPR-A, and would not be directly affected by winter construction activities, although their habitats could 

be affected. A few species, such as ptarmigan, gyrfalcon, and snowy owl, may remain in the project study 

area during the winter, and could be temporarily displaced from high-value feeding or resting habitats by 

winter construction, drilling, or operations activities.

Activities related to the action alternatives, such as vehicle, aircraft, boat traffic, routine maintenance 

activities, heavy equipment use, facility noise, and oil spill cleanup activities, could cause disturbances 

that would affect birds. Summer fixed-wing or helicopter aircraft activity in support of the GMT2 Project, 

including related research, could result in disturbance to birds, causing temporary or permanent 

displacement from high-value feeding, nesting, staging, or brood-rearing habitats in localized areas near 

areas of activity.

Placement of gravel on the tundra for roads and pads, and removal of gravel at mine sites, could result in 

permanent habitat loss, especially if habitat restoration expected to take place after infrastructure features 

are retired is not successful. Temporary habitat loss or alteration could also occur in areas adjacent to 

gravel roads due to snow and/or dust deposition, thermokarst, and the formation of impoundments. Some 
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types of habitat alteration, such as the formation of impoundments, could be beneficial to some species, 

while having a negative impact on others.

Withdrawal of water from source lakes during winter could impact birds if water levels or prey 

availability in source lakes were affected. Lake surveys conducted prior to water withdrawal, limits on the 

amount of water that may be withdrawn from lakes due to lease stipulations, and the ability of lakes to 

naturally recharge, would likely negate any potential negative impacts related to water withdrawal.

Bird mortality could result from collisions with ground or air vehicle or vessel traffic, or with towers, 

buildings, pipelines, bridges, or other facilities. It is expected that collisions would only be a minor source 

of bird mortality; however, over the course of the life of the GMT2 Project these mortalities may 

accumulate for some species. Predators attracted to areas of human activity could also impact tundranesting birds by causing depredation of eggs and young; however, lease stipulations designed to eliminate 

attraction of predators to camps or equipment maintenance sites would help mitigate potential increases in 

predators. Adherence to lease stipulations that require proper disposal of garbage to avoid human-caused 

changes in predator populations would likely minimize potential impacts to birds from increased 

predation pressure.

Although impacts to birds could occur as a result of the action alternatives, long-term studies of bird 

density and abundance in the Prudhoe Bay Oilfield, located on the Arctic Coastal Plain, indicate that oil 

production, as practiced in Prudhoe Bay, does not necessarily lead to substantial declines in bird density 

or productivity in or near the developed area (Bart et al. 2013).

Impacts to birds from climate warming may include a suite of impacts, both positive and negative. A 

longer open-water season may increase productivity of some species and increase productivity in aquatic 

and semi-aquatic systems, which provide food for many species of birds. Warmer soil temperatures are 

likely to increase thermokarst and may inundate low-lying tundra areas, increasing aquatic and wet tundra 

vegetation types. The increasing thickness of the active layer of soil above Arctic permafrost is likely to 

cause changes in moisture regimes and the distribution of vegetation types over much of the Arctic in 

coming years. Drying of wetlands would result in negative impacts to those species that relay on shallow 

water and wet meadows, and shrub expansion may reduce the quality and availability of some types of 

habitats. Such impacts could accelerate or exacerbate changes in soil thermal regimes that occur with 

development to bird habitat (BLM 2012).

4.3.4 Mammals

This section presents the potential impacts to terrestrial and marine mammals that would result from 

implementation of the proposed project and other action alternatives. 

4.3.4.1 Terrestrial Mammals

The proposed GMT2 Project has the potential to impact terrestrial mammals as described in BLM (2004a) 

for the Alpine satellites area, for the entire NPR-A in BLM (2012), and for portions of the GMT2 Project 

area in BLM (2014). The following discussion summarizes the impacts and is supplemented with 

information related to terrestrial mammal impacts from the Point Thomson Final EIS related to terrestrial 

mammal impacts (U.S. Army Corps of Engineers 2012a). These documents are incorporated by reference.

Potential impacts to terrestrial mammals are based on habitat use, seasonal distributions, and seasonal 

movement patterns. Direct impacts to terrestrial mammals were evaluated and quantified using a 2.5-mile 

buffer around all project infrastructure and activity. The 2.5-mile buffer was established based on 

displacement distances evaluated in studies of caribou behavioral responses to disturbance and totals 

approximately 155,500 acres. (Dau and Cameron 1986; Cameron et al. 1992, 1995; Wolfe 2000; Noel et 

al. 2004; Haskell et al. 2006; Haskell and Ballard 2008; Wilson, et al. 2016). Although some studies have 
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documented caribou responses to development activities beyond the 2.5 miles (e.g., up to 8.5 miles, 

Boulanger et al. 2012), the 2.5-mile buffer is generally considered acceptable for current development 

activities on the North Slope. The size of the area within the GMT2 and associated infrastructure’s 2.5-

mile buffer is approximately 155,500 acres.

Caribou are common in the project area, are an important subsistence game species (see Section 4.4.5, 

“Subsistence”), and are well studied relative to other terrestrial mammals in the study area. Therefore, this 

impact analysis and subsequent discussion focuses on caribou. Potential impacts to other terrestrial 

mammals (grizzly bear, muskox, fox, wolf, wolverine, and small mammals) are described qualitatively.

Terrestrial mammal habitat loss is based on calculations presented in Section 4.3.1, “Vegetation and 

Wetlands.” Impacts were evaluated by comparing the infrastructure footprints for the alternatives. Loss or 

alteration of habitats were evaluated based on estimated acreages obtained from GIS analysis of project 

facility dimensions. Direct impacts to habitat are those in which habitat would be covered or structurally 

altered by development (e.g., placement of gravel over tundra). Indirect impacts to habitat are those which 

occur as a result of the construction or presence of infrastructure (specifically, roads). These impacts 

include gravel spray or dust deposition, snow drifting, thermokarsting, and altered hydrology (see Section 

4.2, Physical Characteristics) Indirect impacts to terrestrial mammal habitat were evaluated by using a 

300-foot indirect impact zone extending out from the outer edge of proposed areas of gravel placement 

(Auerbach et al. 1997)

In addition to habitat impacts from road construction and other infrastructure development, terrestrial 

mammals may be disturbed by construction or operation activities, or may be killed or injured as a result 

of activities associated with the action alternatives. These impacts are also evaluated within the project 

area.

Construction

Construction of ice roads, gravel roads, the airstrip, pipelines, and other infrastructure would primarily 

occur during the winter. However, some construction would occur in summer. Construction under project 

action alternatives would affect terrestrial mammals through direct and indirect habitat impacts, 

disturbance, and potential mortality due to vehicle collisions, burial during construction (small mammals), 

or in defense of life or property. Construction-related impacts to terrestrial mammals were evaluated for 

the project area in BLM (2004a) and for oil and gas activities for the NPR-A in BLM (2012).

Habitat Impacts (Loss, Alteration, or Fragmentation)

Under the project action alternatives, construction would result in direct and indirect habitat loss due to 

gravel extraction (see Section 4.2-1, “Terrestrial Environment”) and the installation of permanent gravel 

roads, pads, and the airstrip (Table 116, and Table 123). Caribou and muskoxen would lose 77.9, 87.2, 

and 92 acres (Alternative A, B, C respectively) of foraging habitat due to direct placement of gravel for 

roads, pads, and in Alternative C an air strip, although forage habitat lost to road, well pad, or airstrip 

construction could provide novel insect relief habitat (Table 122, Pollard et al. 1990, 1996a, 1996b, Noel 

et al. 1998, Balllard et al. 2000, Murphy and Lawhead 2000). Up to an additional 621.8, 711.9, and 230.8 

acres (Alternative A, B, C respectively) of foraging habitat may be lost from use due to indirect impacts. 

Arctic ground squirrels and other small mammals would lose minor amounts of foraging and burrow 

habitat due to gravel fill and mining. Grizzly bears would lose minor amounts of foraging habitat and 

could lose minor amounts of denning habitat. Road and facility construction may create denning habitat 

for bears and foxes, although it may disturb existing dens. Wolverines may be negatively affected by 

increased human development and activity once remote areas making the habitat less optimal or causing 

wolverines to avoid the disturbed area (May et al. 2006).
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Ice road construction would crush standing dead vegetation, reducing summer concealment habitat, for 

small mammals and potentially increasing their risk of predation. Compaction of standing dead vegetation 

is expected to be interim in duration, requiring several growing seasons for standing dead vegetation 

density to recover. Damage to dwarf shrubs and tussock tundra from ice road construction could result in 

long-term impacts to vegetation cover (Yokel et al. 2007; Yokel and Ver Hoef 2014). Tundra ice roads 

and ice pads to support construction for Alternatives A and B would be required for 3 winter seasons and 

would cause temporary loss of approximately 159 (ice road) and 175 (ice pad) acres in years 1- 2, and 323 

(ice road) and 135 (ice pad) acres in year 2 -3 of winter forage habitat for both small and large herbivores 

and would also cause the same amount of temporary loss of subnivean habitat for small mammals. 

Alternative C would require ice roads and pads to be constructed for the life of the project, construction 

would cause temporary loss of approximately 159 (ice road) and 205 (ice pad) acres in years 1- 2 and 323 

(ice road) and 175 (ice pad) acres in years 2 - 3 of winter forage habitat for both small and large 

herbivores and would also cause the same amount of temporary loss of subnivean habitat for small 

mammals. Clearing and piling of snow from the pads, roads, and airstrip during the winter could result in 

the collapse of subnivean tunnel systems used by small mammals. Habitat loss due to snow piling (from 

plowing snow off of roads and pads) would be seasonal, but snow piling would likely occur annually in 

the same locations and would continue as long as the facilities were maintained, resulting in long-term 

habitat alteration. Ice roads and snow drifts would not melt before most birds begin nesting in late May to 

early June, altering the distribution and availability of avian prey to mammalian nest predators.

Indirect habitat impacts caused by snow piles or drifts, gravel spray or dust deposition, altered hydrology, 

or thermokarsting could reduce the forage available to terrestrial mammals on an additional 621.8, 711.9, 

or 230.8 acres each year (Alternatives A, B and C respectively). Terrestrial mammals may be affected by 

indirect impacts to varying degrees depending on the season and types of habitats that are impacted. Deep 

snow drifts would likely reduce availability of winter forage for large mammals, but may provide 

additional protection for small mammals using subnivean habitats. Myers-Smith et al. (2006) 

demonstrated that dust accumulation along the Dalton Highway substantially altered vegetation 

composition; areas adjacent to the road had higher graminoid cover and less non-vascular (lichen and 

moss), evergreen, or forb cover. Chen et al. (2017) supported these findings. These studies suggest that 

dust deposition would reduce seasonally important food resources for caribou (e.g., lichen) within the 300 

foot impact area. Conversely, dust deposition on snow along gravel roads would lead to early snow melt 

and green-up (particularly of graminoids) that may attract caribou, muskoxen, or small herbivores 

(Lawhead et al. 2004). Dust deposition would be greatest during construction when vehicle traffic would 

be highest. 

Movements of small mammals such as lemmings and voles would be impeded by construction during 

both summer and winter. Although movement over roads occurs, risk avoidance behavior such as 

avoiding exposed environments may lead to increased avoidance of gravel roads. Additionally, small 

mammals crossing gravel roads during winter would be exposed to decreased air temperatures and higher 

winds compared to protected subnivean environments.

Disturbance

Disturbance of terrestrial mammals during construction would occur. Disturbance-related impacts to most 

terrestrial mammals would be minor. However, May et al. (2006) hypothesized that wolverine distribution 

may be partly influenced by direct disturbance or higher risk of human-caused mortality associated with 

infrastructure. During construction, caribou could be disturbed by low-level aircraft, light and heavy 

vehicle traffic, blasting at the ASRC mine site, construction and use of ice roads and ice pads, 

construction of the pipeline and on-site facilities, and the presence of newly-constructed roads, and 

increased hunting pressure along the proposed GMT1-GMT2 Access Road (Calef et al. 1976; Horejsi 

1981; Shideler 1986; Tyler 1991; Murphy and Lawhead 2000). Caribou response to these disturbance 

sources would likely be highly variable: ranging from no reaction to escape behavior depending on prior 
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exposure, distance from human activity, speed of the approaching disturbance source, frequency of 

disturbance, sex, age, and physical condition of the animals, caribou group size, and season, terrain, and 

weather (Webster 1997). These impacts are discussed below.

Aircraft

Aircraft would land at the CD1/Alpine Processing Facility during construction under all alternatives. The 

predicted number of construction-related fixed-wing and helicopter flights for Alternatives A and B are 

identical (See Table 16). Aircraft traffic of all types would be highest under Alternative C. Helicopter use 

during construction would be limited to emergency response, ice road clean-up, and flights associated 

with required monitoring studies.

Proposed aircraft operations during the construction phase of the project include transport of cargo into 

the Alpine airstrip by Twin Otter (DHC6) and CASA twin-engine (2E) turboprop aircraft (Alternatives A 

and B), transport of cargo by DC-6 (primarily) and C-130 four-engine (4E) aircraft into the GMT2 airstrip 

(Alternative C), transport of personnel into GMT2 by Twin Otter/CASA aircraft and helicopters 

(Alternative C), and helicopter flights into the project area in support of required special studies, 

monitoring, and ice-road clean-up (all alternatives). The degree to which noise may cause disturbances to 

wildlife is dependent on many factors and are described in Section 4.2.3.3 of this document.

The existing Alpine airstrip and the proposed GMT2 airstrip (Alternative C only) would be specific point 

sources of project-related noise generated by landing and take-off operations of cargo aircraft and 

helicopters. Depending on meteorological conditions and the ambient noise level at the time, noise 

generated by 4E aircraft operations at Alpine and GMT2 airstrips could temporarily dominate the 

acoustical environment for a distance of 5 to 7.5 miles from the airstrips, and noise generated by 

helicopters and 2E aircraft could temporarily dominate the acoustical environment for a distance of 1 to 

2.5 miles. 

Noise generated by 4E aircraft in transit could temporarily dominate the acoustical landscape for a 

distance of about 5 to 7.5 miles from the origin. Noise generated by helicopters and 2E aircraft could 

temporarily dominate the acoustical environment for a distance of about 1 to 2.5 miles from the origin and 

could be audible up to 5 miles. 

Overall impacts of aircraft noise on the acoustical environment were found to be of high intensity and 

regional extent, but would be temporary and would attenuate to low intensity with increasing distance 

from the source. This would be the case for concentrated locations of aircraft activity (Alpine airstrip and 

proposed GMT2 airstrip), for dispersed landing sites, and for linear zones of audible aircraft noise 

centered along ground traces of aircraft flight paths. 

Noise impacts attributable to aircraft operations during the construction phase (years 1 - 3) would be 

greater for Alternative C (2392 flights) than for Alternatives A and B (1302 flights for each alternative) 

due to much higher levels of aircraft use in the absence of gravel access roads in Alternative C (Table 16).

Numerous studies have explored the impacts of aircraft on caribou. The significance of these impacts is 

not conclusive, but general patterns have been documented. Caribou response to aircraft varies depending 

on the season, degree of habituation, aircraft, altitude, airspeed, flight patterns, weather conditions, 

frequency of overflights, and the sex and age composition of caribou groups (Wolfe et al. 2000). Lowlevel aircraft may elicit escape behavior (increased speed and direction changes) that can increase 

individuals’ chance of injury (Harrington and Veitch 1991). This is particularly a concern during the 

calving season, when young calves are most vulnerable to trampling or other injuries (Wolfe et al. 2000). 

Low-level aircraft traffic in the vicinity of calving grounds and early post-calving aggregations can reduce 

calf survival (Wolfe et al. 2000). The calving grounds of the TCH and CAH are not within the boundary 
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of the project area. Thus, aircraft associated with construction is not anticipated to adversely affect young 

calves or consequently, adult recruitment. 

Prolonged exposure to low-level aircraft could increase daily energy expenditure and decrease individual 

fitness or reproductive capacity over time if not properly mitigated (Webster 1997). Alternatively, caribou 

can become habituated to aircraft; particularly when aircraft consistently maintain altitudes greater than 

500 feet above ground level and do not engage in hazing or harassing behavior (Valkenburg and Davis 

1983). Habituated animals do not associate aircraft with danger and, as a result, exert minimal additional 

energy when overflown (Webster 1997). 

Hazing animals off airstrips would disturb caribou, which often gather on these areas for insect relief. 

Hazing would be conducted if necessary for safe aircraft operations. Impacts to individual animals are 

expected to be temporary and minor. 

Roads and Vehicle Traffic

The most frequently discussed disturbance to caribou associated with roads is vehicle traffic. Vehicle 

traffic for all alternatives would be highest during the construction period (years 1 – 3; Table 15) and 

most of the construction associated with the GMT2 Project would occur during winter. 

Impacts from roads and vehicle traffic attributable to construction activities vary among the action 

alternatives, with Alternative A (671,300 cubic yards of gravel) having the least impacts and Alternative 

C (930,000 cubic yards of gravel) having the greatest impacts due to differences in total gravel footprint 

to be constructed and associated amount of gravel mining necessary (Table 70). In addition, total vehicle 

trips and vehicle miles are projected to be higher for Alternative C (181,800 trips and 1,692,500 miles) for 

construction years 1 – 3) than for Alternatives A and B (166,100 trips and 1,339,700 miles and 170,800

trips and 1,433,300 miles respectively for construction years 1 – 3), which would result in a greater 

overall amount of vehicle-related noise in Alternative C. 

The proposed GMT1-GMT2 Access Road is on the edge of TCH distribution, but is within a fall 

migration corridor (See Maps 4.3-2 and 4.3-3). From 2004 to 2017, 5% of the GPS collared caribou 

crossed the proposed road alignment during fall migration (Lawhead et al. 2015). Annual collared caribou 

crossings ranged from 0% to 31% (Lawhead et al. 2015, L. Parrett pers. comm.). This suggests that, under 

Alternatives A and B, a relatively small percentage of the TCH would encounter the newly constructed 

road and, although the frequency of encounters would vary annually, caribou encounters with the road 

would persist. Encounters would most likely be during fall, but caribou could be present in the vicinity of 

the road year-round.

The impacts of roads and vehicle traffic on caribou have been explored extensively in Alaska, but 

concrete conclusions regarding specific causes of behavioral changes (characteristics of a road that alter 

movement patterns), and whether behavioral change is context-dependent (i.e. exacerbated or mitigated 

by environmental variables, herd-dependent, or individual-dependent) have not been made. Thus, 

predicting a herd’s response to a newly-constructed road is largely speculative. The following points, 

however, offer insight in to the potential impacts of the proposed GMT1-GMT2 Access Road on the 

TCH:

1) Studies in northern Alaska have shown that traffic volumes of 15 or more vehicles per hour may 

deflect caribou movements or delay successful road crossing (Cronin et al. 1994, Curatolo and 

Murphy 1986, Murphy and Curatolo 1987), and that caribou are most likely to approach 

infrastructure during reduced traffic periods (Haskell et al. 2006, Haskell and Ballard 2008, Pazacci et 

al. 2013). Thus, if traffic on the GMT1-GMT2 Access Road approaches this threshold, some local 
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displacement of caribou may occur. Vehicle traffic during construction may exceed 15 vehicles an 

hour. 

2) Similar to disturbance associated with aircraft traffic, multiple studies suggest that caribou habituate 

to infrastructure and roads. Wolfe et al. (2000) reported that, once caribou were initially exposed to 

infrastructure, crossing transportation corridors occurred more often than expected. Habituated cowcalf groups crossed roads as frequently as bulls, and roads did not have an observable effect on 

animal distribution or individual energetic cost. Boertje et al. (2012) and Nicholson et al. (2016) 

found that large ranges, historic movement patterns, and large-scale migratory behavior persist even 

when highways and roads bisected those ranges. This suggests that habituation to the GMT1-GMT2 

Access Road is likely, but will take time. It also suggests that the historic range of the TCH will 

remain intact.

3) Individual caribou’s responses to roads can be dramatic. Wilson et al. (2016) documented some 

collared animals moving nearly 60% faster after crossing the Red Dog Mine road and taking nearly 

10 times as long to cross the road itself. However, while 40% of the animals demonstrated noticeable 

responses to the road, the remaining 60% of collared individuals crossed the road without incident or 

perceptible change in their movement patterns. Annual variability of responses was high. It is worth 

noting that collared members of the TCH were unaffected by the road in this study. The authors 

postulate that the TCH’s greater exposure to industrial development may explain the behavior 

discrepancy in the presence of the Red Dog Mine road between collared TCH and WAH caribou, but 

do not state this conclusively. They also caution the application of their results to other herds and 

situations, suggesting that caribou behavior is very context-dependent.

4) Cows with calves appear most sensitive to vehicle traffic (and industrial infrastructure in general), in 

early summer during, and immediately after, calving (Cameron et al. 2005). It is unlikely that cows 

and young calves would be affected by the road during this sensitive time period, as they would likely 

be northwest of the project area in the vicinity of Teshekpuk Lake.

5) Traditional ecological knowledge and, to some extent, recent literature suggest that initiation of 

migration and annual migratory paths are dictated by experienced adult cows (Padilla 2010, Guttal 

and Couzin 2011). The onset of fall migration would not coincide with peak construction activities 

and highest traffic levels (during winter), although fall traffic or the presence of the road itself could 

still affect adult cows initiating and leading the fall migration. 

These points suggest that some members of the TCH may alter their movement patterns in response to a 

newly constructed road, but the road would not disrupt the integrity of the herd’s historic range. Altered 

movement patterns would likely be most noticeable if the leaders of the fall migration are disrupted, but it 

is difficult to predict these changes on the periphery of the herd’s range.

Mortality or Injury

Construction of ice and gravel roads would likely result in some small mammal mortality. Small 

mammals active in winter (e.g., lemmings, voles, and shrews) may relocate to avoid being covered by 

construction materials, while those animals in hibernation (Arctic ground squirrels) would die if 

construction occurred over occupied burrows. While Arctic ground squirrels would be most vulnerable to 

this impact, road routes tend to avoid the raised land features that are amenable to digging burrows. 

Therefore, mortality would be relatively low. 

Vehicle collisions with both small and large mammals may occur during construction, particularly during 

winter, when poor visibility is common and hard road surfaces are amenable to travel by animals (BLM 

2004a). Speed limits on oil field roads are enforced, and ConocoPhillips has instituted wildlife avoidance 
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policies and trainings which would be implemented on the GMT1-GMT2 Access Road as well, thereby 

likely reducing collision-related animal mortalities.

Caribou - Under Alternative C, caribou would likely use the proposed airstrip as insect relief habitat. 

Aircraft could potentially collide with caribou during takeoffs or landings. Caribou would be hazed from 

the airstrip for human safety, thereby reducing the potential for collisions and collision-related animal 

mortality.

Alternatives A and B would enable local hunters to use the developed road system, potentially having a 

minor increase on localized mortality of caribou, moose, muskoxen, or grizzly bears. While harvest could 

increase, overharvest of big game, specifically the TCH, as a result of this improved access is not 

anticipated. Harvest limits and hunting regulations are set by the Board of Game and the Federal 

Subsistence Board. Harvestable surplus is estimated by ADF&G using annual population and harvest 

surveys (see: Parrett 2015). If population levels, demographic characteristics, or annual harvest suggest 

that the TCH or other large mammal populations cannot sustain harvest at current (or elevated) levels, the 

Board of Game and Federal Subsistence Board will adjust hunting regulations concerning the affected 

populations as appropriate.

Bears may attack humans for either predatory or defensive purposes. Foxes may become conditioned to 

humans and bite or threaten to bite personnel associated with the action alternatives. In these events, 

killing bears, foxes, or other mammals in defense of life or property (DLP) may be necessary. While this 

is uncommon in oil field developments, it remains a potential impact. ConocoPhillips has proposed 

implementation of design and operational measures that would minimize the potential for wildlife to 

become attracted to humans and infrastructure, thereby reducing potential DLP-related mortalities. These 

measures are summarized in ConocoPhillips’ Wildlife Avoidance and Interaction Plan.

Spills of refined products could occur during construction. The extent of impacts to terrestrial mammals 

would depend on the type, location, and amount spilled, the season, and the effectiveness of the response. 

Such incidents would be rare, and the majority of spills would be contained on the work surface, thereby 

not impacting terrestrial mammals or habitat. Although unlikely, terrestrial mammals could be coated 

with spilled liquids or ingest contaminated vegetation. This may result in mortality or decreased fitness.

Altered Survival or Productivity

Improperly managed food, garbage or petroleum products (e.g., fuel), and the availability of infrastructure 

for thermal protection, escape cover, or den sites can potentially increase the survival and productivity of 

Arctic foxes, bears, and weasels (Burgess 2000, Shideler and Hechtel 2000, National Research Council 

2003, USFWS 2003). Staged construction materials and equipment would create additional artificial 

escape and den habitat for predators. Studies of Arctic foxes and grizzly bears in the Prudhoe Bay oil 

fields have documented that these additional habitats contributed to increased densities and productivity 

of both species. Lehne (2012) showed that the availability of subsidized anthropogenic food sources 

reduced the probably size of Arctic fox winter home ranges to approximately 0.0023% the size of nonsubsidized foxes. Operational procedures and controls established to protect terrestrial mammals (see 

Mitigation section) would minimize factors that commonly attract them to oil field infrastructure.

While both the TCH and CAH have undergone recent changes in size, demography, and distribution, 

these changes are not thought to be related to oil field development (Parrett 2015, Lenart 2015). The 

GMT2 Project area does not overlap the calving grounds of the TCH or CAH, and construction activities 

would not affect parturient or lactating cows’ access to high-quality forage, calf production, or adult 

recruitment.
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Drilling and Operation

The drilling and operation phases of the action alternatives could affect terrestrial mammals through 

direct and indirect habitat impacts, disturbance, and potential mortality due to vehicle collisions or 

defense of life or property.

Habitat Impacts (Loss, Alteration, or Fragmentation)

Drilling and operations would not result in additional direct habitat loss beyond that described for 

construction. Indirect habitat impacts such as dust deposition from driving or moving equipment on 

gravel roads would occur over the life of the project and would be similar to those described for 

construction. Alteration of tundra foraging areas which may result from delayed melt of ice roads and 

pads, will be greatest under Alternative C, which would require ice roads and ice pads through the life of 

project as compared to ice pad only use in Alternatives A and B which would be terminated after 7 years 

(drilling).

Tundra ice pads to support drilling for Alternatives A and B would be required for 7 winter seasons and 

would cause temporary loss of approximately 10 acres per year from winter forage habitat for both small 

and large herbivores and would also cause the same amount of temporary loss of subnivean habitat for 

small mammals. There would be no ice roads built for drilling or operations for Alternatives A and B. 

Alternative C would require ice roads and pads to be constructed for the life of the project, drilling would 

cause temporary loss of approximately 29.7 (ice road) and 10 (ice pad) acres in years 3 – 10 (drilling) and 

29.7 (ice road) and 2 (ice pad) acres in years 11 – 32 (operations) of winter forage habitat for both small 

and large herbivores and would also cause the same amount of temporary loss of subnivean habitat for 

small mammals.

Disturbance

Disturbance of terrestrial mammals during drilling and operations would occur. During drilling and 

operations, caribou could be disturbed by low-level aircraft, light and heavy vehicle traffic, construction 

and use of ice pads (during drilling for Alternative A and B) and ice roads (for the life of the project in 

Alternative C), noise from drill rig (during the entire drilling phase), the presence of gravel roads and 

pads, and increased hunting pressure along the proposed GMT1-GMT2 Access Road. May et al. (2006) 

hypothesized that wolverine distribution may be partly influenced by direct disturbance or higher risk of 

human-caused mortality associated with infrastructure.

Other than aircraft activities, drilling itself would be expected to generate the highest noise levels during 

the drilling and operations phases. Section 4.2.3.3 of this document found that the overall impacts of 

drilling noise on the acoustical environment would be of high intensity and regional extent for maximum 

noise levels, but median noise levels would be expected to be of high intensity to a limited extent. In both 

cases, impacts would be temporary and would attenuate to low intensity with increasing distance from the 

source. Drilling noise could contribute to local avoidance of infrastructure by wildlife, but would be 

unlikely to result in population-level impacts. Noise impacts attributable to drilling itself would not be 

expected to vary among the action alternatives under consideration.

Disturbance from vehicle traffic on gravel and ice roads and air traffic would continue during drilling and 

operation. Maximum traffic levels would likely occur when drilling activities occur simultaneously with 

final construction. Although the levels may differ, disturbance would be similar to that described for 

construction.

Aircraft

Alternatives A and B would require no fixed-wing aircraft flights for either the drilling or operations 

phases of the project. Alternative C would require 7525 fixed-wing aircraft flights (1210/year) for drilling 
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and 6255 fixed-wing aircraft flights (270/year) for operations. Alternatives A and B would require 540 

helicopter flights (90/year) for drilling and 2070 helicopter flights (90/year) for operations. Alternative C 

would require 858 helicopter flights (143/year) for drilling and 3,289 helicopter flights (143/year) for 

operations. Under Alternative C flight activities would include transport of cargo by 4E aircraft into and 

out of the GMT2 airstrip, and transport of personnel and cargo into and of GMT2 by 2E aircraft. Aircraft 

noise levels and associated impacts generally would be similar to those described above for the 

construction phase. Noise impacts would be of high intensity and regional extent, but would be of interim 

duration due to their occurrence through the entire operational phase of the project. Impacts of aircraft 

noise would be the same under Alternatives A and B, and would be greatest under Alternative C. 

Low-level overflights for permit-required studies, routine operations, maintenance, and surveillance of 

pipelines may elicit responses in un-habituated caribou, although caribou will likely demonstrate some 

level of habituation after the 2-3 year construction period. There will be a greater number of flights under 

Alternative C over the life of the project, but these impacts are expected to be brief (Wolfe et al. 2000), 

and are not expected to impact caribou to a greater degree than Alternative A or B. 

Hazing animals off airstrips would continue under drilling and operations. Impacts will be the same as 

those described under construction.

Roads and Vehicle Traffic

Alternatives A and B would have similar lengths of gravel road (8.2 and 9.4 miles respectively) while 

Alternative C will have only a 0.9 mile gravel airstrip access road and an annual ice road of 7 miles. 

For all Alternatives vehicle traffic will decrease substantially post construction with Alternative C having 

the highest traffic levels during the drilling and operation periods due to exclusively using ice roads for 

vehicle traffic. During drilling Alternatives A and B will require 9,000 trips annually while Alternative C 

will require 22,500 annually. During operations Alternatives A and B will require 700 trips annually 

while Alternative C will require 21,800 annually.

Impacts to caribou associated with roads and vehicle traffic would be similar to those described for 

construction. It is likely that some habituation of the TCH to the GMT1-GMT2 Access Road will have 

occurred during the 2-3 year construction period, although the extent to which caribou alter their 

movements in the presence of the road is not known.

Mortality

Animal mortalities associated with vehicle or aircraft collision could occur throughout the life of the 

project. The cause and effects of such collisions and mortality are the same as described for construction. 

Vehicle collisions would likely decline during operations because of reduced personnel and transportation 

requirements on the GMT1-GMT2 Access Road for Alternatives A and B, and on ice roads in Alternative 

C. However, occasional vehicle collisions would still be possible. In addition to collision-related 

mortalities, other types of wildlife mortality such as entanglement, or DLP incidents could occur during 

operations, as has occurred in the Prudhoe Bay oil field (Streever et al. 2006, 2007; Sanzone et al. 2008, 

2009).

Spills of refined products could occur during drilling and operations. Such incidents would be rare, but 

impacts to terrestrial mammals would be the same and those described for construction.

Altered Survival or Productivity

Factors altering survival or productivity during drilling and operations would be similar to those 

described for construction. 
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Comparison of Alternatives

Action alternatives differ primarily in how the GMT2 drill site is accessed, and these access 

considerations lead to differences in infrastructure development and operations. Under Alternative A or B, 

access to GMT2 relies on travel via a gravel road, except for seasonal ice roads used during construction. 

Under Alternative C, year-round access to GMT2 would be via aircraft, and seasonal access would be via 

winter ice roads. Alternative C requires construction of an airstrip at GMT2; Alternatives A and B require 

construction of the gravel GMT1–GMT2 Access Road. Vehicle traffic on gravel roads would be 

comparatively higher for Alternative A or B, than for C, and air traffic would occur only for Alternative C. 

Habitat and disturbance impacts to terrestrial mammals are compared for the three Alternatives.

The direct impacts of gravel placement on potential caribou use habitats are summarized in Table 122. 

Direct habitat impacts are greatest for Alternative C. Each alternative would have a total gravel fill 

footprint representing less than 1 percent of the total area of caribou habitat in the approximately 155,500-

acre project area, and would impact less than 1 percent of specific habitats identified as potential caribou 

use habitats. Indirect impacts based on a 300-foot zone surrounding gravel infrastructure are highest for 

Alternatives A and B. Indirect impacts would impact less than 1 percent of the total project area in all 

Alternatives.

Phase 3 expansion of the Arctic Slope Regional Corporation Mine site would result in loss of the existing 

vegetation and wetlands within the mine footprint. The vegetation types within the expected footprint of 

excavation are Wet Sedge Meadow Tundra (426 acres), Closed Low Willow (12 acres), and Open Low 

Willow (less than 1 acre), which are potential caribou use habitat. This impact, as a result of gravel 

extraction, would represent approximately 1.3 percent of the total 32,682 acres of Wet Sedge Meadow 

Tundra within the mapped project area, 0.5 percent of the 2,490 acres of Closed Low Willow, and less 

than 0.1 percent of the 3,868 acres of Open Low Willow. Mined gravel would be transported from the 

Arctic Slope Regional Corporation Mine site to the project area over ice roads during Year 1 (January–

April 2019).

All action alternatives have the potential for spills resulting from pipelines, storage tanks, production 

facilities/infrastructure, drill rigs, or vehicles. Generally, because the location and length of oil transit 

pipelines under the action alternatives are similar, the risk of a pipeline spill occurring is similar among 

alternatives, although Alternative C has a slightly greater risk due to the additional ancillary diesel 

pipeline.

Difference does exist, however, in the risk to the surrounding environment. Over half of the GMT1–

GMT2 Access Road under Alternative A is downgradient from the pipeline, and would act as a barrier to 

spill migration. The GMT1–GMT2 Access Road would also be used for pipeline inspections and spill 

response. Alternative B would move much of the road to the watershed divide, reducing this benefit of a 

road barrier. Because Alternative C is roadless and relies upon air support and yearly ice road construction 

for incident response, risks to terrestrial mammals and associated habitat associated with an oil spill are 

increased throughout the project life. Spills could potentially cause terrestrial mammal mortality, 

contamination of food sources, and damage of terrestrial mammal habitat.

Potential impacts of oil spills are described in Section 4.5 of this document. The extent of environmental 

impacts of a spill would depend on the type and amount of fluids spilled; the location of the spill; and the 

effectiveness of the cleanup. It is anticipated, based on North Slope spill history, that the majority of spills 

would be contained on a gravel road or pad with little or no impacts to terrestrial mammal habitat.

Alternatives A, B and C would have similar impacts to terrestrial mammals from habitat loss or alteration. 

As shown in Table 4.3-13, direct and indirect habitat impacts for Alternatives A and B are expected to be 

of low intensity (less than 5 percent of high-valued habitat will be altered by development), long-term 

duration (habitat will be altered by infrastructure for over 5 years), and limited in extent (habitat impacts 
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occur within 300 feet of developed infrastructure). The affected resources, which in this case include 

important subsistence food resources for local communities, are rated important because caribou fill a 

distinctive ecosystem role within the locality and region (Section 4.4.5, “Subsistence”).

The project area is not within the concentrated caribou calving area of the TCH (Lawhead et al. 2015). 

Therefore, potential impacts to calving caribou are rated as low intensity to reflect the low likelihood that 

calving caribou would be impacted by habitat changes or disturbance (Table 122). Impacts to calving 

caribou would be long term and limited in extent, but unlikely. Potential impacts from habitat changes or 

disturbance to non-calving caribou are considered to be of medium intensity, long-term duration, and 

limited in extent (Table 123). The medium intensity rating is due to infrequent occasions when a large 

number of caribou are present in the project area (e.g., during some insect relief periods or fall migration), 

brief disturbance of non-calving caribou could potentially affect between 5 percent and 10 percent of the 

local caribou population (Prichard et al. 2017). 

Both Alternative A and B would lead to increased vehicle traffic in the GMT2 Project area on roads 

connecting CD1/Alpine Processing Facility, GMT2 (proposed) and Nuiqsut. This new traffic would be 

primarily for industrial use, but would also include some traffic from Nuiqsut residents using the new 

GMT1–GMT2 Access Road. Annual ice roads would require construction activity and potentially disturb 

caribou throughout the project life for Alternative C. Impacts to terrestrial mammals from traffic on gravel 

and ice roads is expected to be of low to medium intensity, limited in extent, and important in context 

(Table 122) Re-use of annual ice road routes and ice pad locations could damage mammal habitat (tundra 

vegetation), a potential long-term impact. 

The use of aircraft to access the site under Alternative C differentiates this alternative from Alternatives A 

and B. Aircraft noise during take-offs and landings associated with the high number of flights required for 

transport of personnel and for special studies for Alternative C is expected to result in only low intensity 

impacts to caribou in the project area due to the research finding that impacts to caribou from aircraft 

noise is expected to be of only short duration (Wolfe et al. 2000). 

Considering multiple types of impacts to terrestrial mammals, all alternatives are expected to have 

impacts that are typically of low to medium intensity, long-term duration, and limited in extent and for 

caribou, important in context.

Alternative D, which would not approve GMT2 Project, would result in no new impacts to terrestrial 

mammals.
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Table 122. Estimated direct impacts of action alternatives to potential caribou-use habitats

Potential Caribou-Use 

Vegetationa

Mapped 

Project

Areab 

(acres)

Vegetation 

Type as % 

of Mapped

Project

Area

Alternative A Alternative B Alternative C

Acres (%) Acres (%) Acres (%)

Barren 5,046 3.5 NP NP NP NP NP NP

Closed Low Willow 2,490 1.7 NP NP NP NP NP NP

Deep Polygon Complex 823 0.6 NP NP NP NP NP NP

Moist Sedge–Shrub

Tundra

23,682 16.4 19.8 -- 19.7 -- 10.3 --

Open Low Willow 3,868 2.7 NP NP NP NP NP NP

Partially Vegetated 1,407 1.0 NP NP NP NP NP NP

Riverine Complex 410 0.3 NP NP NP NP NP NP

Tussock Tundra 29,899 20.6 51.1 0.2 59.1 0.2 74.4 0.2

Wet Sedge Meadow

Tundra

32,682 22.6 1.8 -- 2.0 -- 1.7 --

Total Acres of Impact for Alternativec 77.9 N/A 87.2 N/A 92.0 N/A

Note: Values that are greater than zero but less than 0.1 are noted with a dash (--). (NP) cells indicate the vegetation type is not 

present within area considered for impact analysis.

a Includes potential forage and insect relief areas as discussed in “Methodology,” Section 4.3.4.1.

b Percent of vegetation type acreage within the mapped vegetation portion of the project area. Note that 10,465.3 acres (6.6

percent) of the project area extends outside of the vegetation map coverage.

c Total of Impact for alternative does not include 0.1 acre from the installation of new pipeline vertical support members between 

GMT2 and GMT1.

Table 123. Estimated indirect (300-foot zone) impacts of action alternatives to potential caribou-use

Potential Caribou-Use 

Vegetation a 

Mapped 

Project 

Area b 

(acres)

Vegetation 

Type as % 

of Total 

Project 

Area

Alternative A Alternative B Alternative C

Acres (%) Acres (%) Acres (%)

Barren 5,046 3.5 NP NP NP NP NP NP

Closed Low Willow 2,490 1.7 NP NP NP NP NP NP

Deep Polygon Complex 823 0.6 NP NP NP NP NP NP

Moist Sedge–Shrub 

Tundra

23,682 16.4 172.3 -- 172.3 -- 37.9 --

Open Low Willow 3,868 2.7 1.4 -- 0.0 -- 0.0 --

Partially Vegetated 1,407 1.0 NP NP NP NP NP NP

Riverine Complex 410 0.3 NP NP NP NP NP NP

Tussock Tundra 29,899 20.6 349.4 1.2% 441.9 1.4% 178.2 0.6%

Riverine Complex 490.4 0.3 NP NP NP NP NP NP

Wet Sedge Meadow 

Tundra

32,682 22.6 20.6 -- 16.7 -- 5.2 --

Total Acres of Impact for Alternative 621.8 N/A 711.9 N/A 230.8 N/A

Note: Values that are greater than zero but less than 0.1 are noted with a dash (--). (NP) cells indicate the vegetation type is not 

present within area considered for impact analysis.

a Includes potential forage and insect relief areas as discussed in “Methodology,” Section 4.3.4.1.

b Percent of vegetation type acreage within the mapped vegetation portion of the project area. Note that 10,465.3 acres (6.6

percent) of the project area extends outside of the vegetation map coverage.
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Mitigation

Existing Mitigation

Specific stipulations and best management practices that will decrease the risk of impact to mammals and 

their habitats within the NPR-A are summarized below:

Ensure that solid, liquid, and hazardous materials/wastes do not impact wildlife or their habitats, and to 

reduce the potential for garbage that attract predators:

• BMP A-2: requires comprehensive waste management planning, including methods to avoid 

attracting wildlife and affecting quality of local waters and wetlands;

• BMP A-3 and A-4: requires liners and impermeable containment, spill prevention and response 

planning;

• BMP A-5: prohibits fuel storage and refueling of equipment within 500 feet of the active floodplain of 

any waterbody;

• BMP A-6 and A-7: prohibit discharge of reserve-pit fluids and produced water;

• BMP A-8: requires bear-interaction plans to minimize conflicts.

Protect mammal habitat:

• BMP C-1: prohibits cross-country use of heavy equipment and seismic activity within 0.5 miles of 

grizzly bear dens;

• BMP E-5: requires design and location of infrastructure to minimize development footprint;

• BMP E-8: requires approved gravel mine site design and reclamation plan that minimizes impact on 

wildlife resources;

• BMP E-12: requires ecological land classification mapping of development area before facility 

construction is approved; 

• BMP E-19: requires digital, spatial representation of all new infrastructure to be provided to BLM, for 

use in monitoring and assessing wildlife movements during and after construction;

• BMP G-1: requires reclamation of land used for infrastructure after oil and gas production ends;

• BMP L-1: requires BLM approval for use of low-ground-pressure vehicle traffic during summer to 

minimize impacts to habitat for caribou and other terrestrial mammals;

• Protect wildlife from disturbance by oil field infrastructure and related activities;

• BMP E-7: requires design standards for roads and pipelines to allow free movement of caribou (e.g., 

pipelines minimum 7-feet above tundra; minimum separation of roads and pipelines of 500 feet);

• BMP F-1: restricts the minimum altitude of air traffic to 1,500-feet above ground level whenever 

feasible to avoid disturbing caribou. Some required studies require lower altitudes and are exempted 

(e.g., avian, caribou, hydrology); requires submission of an aircraft use plan;

• BMP I-1: orient personnel on reducing resource conflicts, e.g., avoid disturbing biological resources 

and their habitat;

• BMP M-1: prohibits chasing wildlife with ground vehicles.

Potential New Mitigation Measures

The BLM considered and applied new mitigation measures for mammals in the GMT1 Supplemental EIS 

(BLM 2015), and it is recommended that similar supplemental best management practices be applicable 

to GMT2. The BLM will determine whether to adopt the new potential mitigation measures in the record 

of decision. The new potential mitigation measures are discussed below.
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Potential Mitigation Measure 1: 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 Authorized Officer reporting 

roadkill of birds and mammals to help the BLM determine whether additional preventative measures on 

vehicle collisions should be made.

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.

Potential Mitigation Measure 2 (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. If caribou are observed regularly 

within 0.5 miles of the road (i.e. observed daily for 3 or more consecutive days) then additional 

strategies would be implemented including restricting vehicle traffic or requiring vehicles to 

travel in convoys. 

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 caribou are trying to cross the road. Any 

individual or group of caribou moving steadily toward the road within a distance of 0.25 miles 

(approximately 400 meters) should be considered attempting to cross the road. Sections of road 

will be closed to vehicle traffic whenever an attempted crossing by 100 caribou or more 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 annually 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. 

In addition to the mitigation measures noted above, there are BLM best management practices and 

stipulations that regulate the types of activities that can occur near waterbodies, including rivers and 

streams, and types of equipment that can be used in the planning area. These would also serve to protect 

mammals and their habitats. A list of protective measures for mammals, including additional mitigation 

from the 2004 Record of Decision (BLM 2004b) is provided in Section 4.7, “Mitigation Measures and 

Monitoring.”
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Conclusions

The likelihood of impacts to mammals identified in this document can be separated into reasonably 

foreseeable and potential as shown in Table 124. All of the evaluated effects were determined to have 

some impacts to the mammal populations in the study area.

Table 124. Likelihood of impacts, terrestrial mammals

Reasonably Foreseeable Impacts Potential Impacts

Habitat loss and alteration from gravel extraction and 

gravel placement.

Increased insect relief habitat from gravel fill (raised 

gravel roads and pads).

Temporary loss of winter forage habitat from ice road 

construction.

Creation of denning habitat for bears and fox from

gravel fill and facility construction.

Temporary subnivean habitat loss for small mammals 

from ice road construction.

Increased risk of predation for small mammals from ice 

road construction and reduced concealment cover.

Alteration of the distribution and availability to 

mammalian predators of nests and prey from ice roads 

and snow drifts.

Increased predation and vehicle collision mortality due 

to terrestrial mammals being attracted to early 

vegetation greening along roadways. 

Habitat loss from snow piling and snow drifts around 

roads and pipelines.

Deflection or delay of caribou movements due to 

presence of gravel and ice roads and traffic on them.

Disturbance to caribou and muskoxen from 

infrastructure and human activity causing displacement 

from the immediate area.

Disturbance of Arctic fox dens, grizzly bear den habitat, 

and small mammal burrow habitat due to construction 

of ice roads and vehicle traffic.

Hazing caribou near airstrips that would likely result in 

temporary disturbance and temporary displacement. 

Increased hunting pressure caused by increased 

access for Nuiqsut residents.

Blocking of movements of small mammals by gravel fill. Increased risk of predation by loss of subnivean habitat 

from ice road construction.

Small mammal mortality from construction of ice and 

gravel roads.

Wildlife mortality due to exposure to flares, 

entanglement, and trapping and destruction of nuisance 

animals.

Increased mortality or injury from vehicle collisions 

along ice and gravel roads.

Oil discharge causing coating of furor the ingestion of 

contaminated vegetation.

Temporary disturbance to caribou caused by aircraft 

traffic.

Increased survival and productivity for Arctic foxes, 

bears, and weasels due to improperly managed human 

food or garbage, and the availability of infrastructure for 

thermal protection, escape cover, or den sites. Habitat alterations in areas near gravel fill caused by 

deposition of gravel spray and (or) dust, altered 

hydrology, and thermokarsting could reduce the forage 

available to small and large terrestrial mammals.

4.3.4.2 Marine Mammals

In general, marine mammals are not expected to occur either within the project area, or north of the 

project area along the coastline of Harrison Bay. The water along the coast is either beyond their 

geographical range or too shallow for most species to use during limited migrations through the area. Of 

the 10 marine mammals initially considered, it was determined that 6 are not expected to occur in the 

project area (as discussed in Section 3.3.4), and are not further evaluated. The four exceptions are polar 

bear, covered under Section 4.3.5, “Threatened and Endangered Species,” spotted seal, bearded seal, and 

the beluga whale. These marine mammals were described and evaluated in BLM (2014), which is 

incorporated by reference, and summarized below.

As noted in Section 3.3.4, the BLM performed an evaluation of GMT1 development, and determined that 

the spotted seal, bearded seal, and beluga whale were unlikely to sustain impacts from that project (BLM 

2015). As with GMT1, GMT2 Project facilities and project area are entirely inland, with no facilities, 
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pipelines, or activities related to the project occurring on or immediately adjacent to the marine coastal 

zone. In the unlikely event of a large oil spill reaching open water during summer or fall, small numbers 

of beluga whales, bearded seals, and larger groups of spotted seals could be negatively impacted. No 

difference in impacts to marine mammals is expected under any of the action alternatives. In conclusion, 

assuming that no large oils spills reach the open water environment, impacts to marine mammals are 

expected to be negligible.

4.3.5 Threatened and Endangered Species

Impacts to threatened and endangered species are described in BLM (2004) and BLM (2012). The types 

of potential impacts to threatened and endangered species under the GMT2 Project are similar to that of 

other birds and mammals, and include habitat loss and alteration, disturbance and displacement, mortality, 

obstruction of movement, and predation. Section 4.3.3, “Birds,” and 4.3.4.2, “Marine Mammals,” provide 

discussion of potential impacts to birds and marine mammals in general.

The threatened and endangered species that have been reported to occur in or near the project study area 

are: Steller’s eider, spectacled eider, and polar bear. There are only three records of Steller’s eider 

breeding east of Utqiagvik (formerly Barrow) in the last 25 years (on the Colville River delta in 1987 and 

in Prudhoe Bay in 1993; and inland from Dease Inlet/Admiralty Bay area in 1997 [Seiser and Johnson 

2014]). Therefore, this species was not analyzed in depth for the GMT2 Project.

Impact evaluation for spectacled eider primarily utilizes habitat mapping and species-specific habitat 

preference based on 20 years of avian survey data, as described in Section 3.3.3, “Birds.”

Potential impacts to threatened and endangered species from project elements and activities vary among 

the different action alternatives during construction, drilling, and operations (i.e., production). Discussion 

of the potential impacts and comparison of alternatives is presented below.

4.3.5.1 Steller’s Eider

Nest searches in the Colville River Delta, Kuparuk River Unit, and northeast NPR-A over approximately 

25 years have found no nests or indications of breeding by Steller’s eiders (Johnson et al. 2013). In a 

similar time period, only a few sightings of individuals have been recorded (Johnson et al. 2013; Seiser 

and Johnson 2014). Therefore, there is a low probability for their presence in the future at the project 

study area (Johnson et al. 2013). There is no designated critical habitat for this species on the North 

Slope. No impacts to Steller’s eiders are expected to occur as a result of any of the action alternatives and 

they are not further addressed in this section. There would be no impacts under the no-action alternative.

4.3.5.2 Spectacled Eider

Impacts to spectacled eiders from construction and drilling and operation within the project study area are 

discussed in BLM (2004) and in BLM (2012). Results from these previous analyses are summarized in 

this section and a comparison of alternatives with regard to project activities and infrastructure is 

provided, as well as conclusions regarding potential impacts to spectacled eider.

No direct impacts from gravel placement to potential high-value habitats within the GMT2 Project area

have been identified, as there are no potential high value habitats found in the direct impact area. Only 

one potential high-value habitat was found in the indirect impact area within the project study area and 

that habitat, along with the area of potential indirect impact is listed for spectacled eider in Table 125 and 
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were selected using statistical analysis which identified species preference for select habitat types within 

the NPR-A Study Area (Johnson et al. 2015). Two terrestrial habitats—Moist Sedge-Shrub Meadow and 

Moist Tussock Tundra—were significantly avoided and were notable because they occupy over 35

percent of the study area (Johnson et al. 2015). The spectacled eider could be indirectly impacted by the 

proposed project under all action alternatives as a result of habitat alteration, disturbance and 

displacement, obstruction of movement, various sources of mortality (e.g., vehicle collisions, nest 

predation), or spills.

There is no designated critical habitat for the spectacled eider on the North Slope. Data collected in multiyear surveys indicate the spectacled eider is present in the project study area; the species occurs in high 

concentrations on the Colville River delta, and north of Nuiqsut. 

Table 125. Indirect impacts to potential high-value habitats of spectacled eider within the project study area

(300-foot zone of influence) 

Habitat Type a

Project 

Area b

(acres) 

Habitat 

Type as

Percent

of Total

Project

Area

Alternative A Alternative B Alternative C

Indirect 

Impact 

(acres) % 

Indirect 

Impact 

(acres) % 

Indirect 

Impact 

(acres) % 

Shallow Open Water without Islands 1,218 0.8% 2.9 0.2% -- -- -- --

Total c 1,218 0.8% 2.9 0.2% -- -- -- --

Unmapped Area d 10,465 6.6% -- -- -- -- -- --

Note: (--) cells indicate the habitat is not present within area considered for impact analysis.

a Source information for habitat preferences of pre-nesting spectacled eiders based on Monte Carlo analysis in Tables 5 and 8 of 

Johnson et al. (2013). 

b Total acreage of the GMT2 Project Study Area, including both the mapped habitat area and the unmapped area is 157,408.4 

acres.

c Total impacted acreage may differ slightly from other impact totals listed within the document due to rounding of individual 

calculated habitat impacts and presentation of only preferred avian habitats.

d Note that 10,465.3 acres (6.6 percent) of the GMT2 Project area extends outside of the habitat map coverage. All project facilities 

under all action alternatives are within areas of mapped vegetation

Construction

The majority of activity that would result in habitat loss, disturbance, displacement, and mortality under 

any of the action alternatives would occur during the construction phase. 

Habitat Loss and Alteration 

Spectacled eiders are not expected to experience any habitat loss or alternation from gravel extraction or 

fill placement for roads, pads, or airstrips. Eight potential high-value spectacled eider habitats occur 

within the GMT2 Project area, but none occur in the locations where gravel extraction or fill placement is 

proposed. 

Temporary loss of spectacled eider habitat (indirect impact) associated with gravel fill could occur on the 

adjacent tundra, where accumulated snow from snow-plowing activities or snowdrifting is compacted, 

leading to delayed snowmelt. Delayed snowmelt persisting into the nesting season could preclude 

spectacled eiders from nesting in those areas (BLM 2012).

Gravel infrastructure such as roads and pads can result in gravel spray and dust deposition (e.g., from 

vehicle traffic or wind), which can affect spectacled eider habitat by causing early snowmelt, and thus, 

early green-up on tundra adjacent to roads, pads, and airstrips which could attract eiders early in the 
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season when other areas are not yet snow-free. Dust deposition could also increase thermokarst and soil 

pH, and reduce the photosynthetic capabilities of plants in areas adjacent to roads (Auerbach et al. 1997). 

Ground and air traffic (including helicopters), and wind can influence the amount of dust that may be 

deposited adjacent to roads and pads (BLM 2012). For this analysis, a distance of 300 feet from the edge 

of gravel roads and pads was used to estimate the zone of impact for dust deposition, as discussed in 

Section 4.3.1, “Vegetation and Wetlands.”

Tundra ice roads would cause temporary spectacled eider habitat loss and alteration because ice roads can 

remain in place until after eiders have arrived in the general area. Ice roads also compress the vegetation, 

especially standing dead vegetation that might be used by spectacled eiders for concealment. Standing 

dead vegetation would require multiple growing seasons to reestablish, likely resulting in interim duration 

habitat alteration (U.S. Army Corps of Engineers 2012). Relatively slow melting ice roads could act as 

temporary dams, causing impoundments of water. Generally, changes in the thermal regime or 

compaction of soil have not been found to result from ice road construction. A study by Yokel et al. 

(2007) suggests that seasonal ice roads and pads constructed within the same footprint each year do not 

have additive effects over years.

Impoundments created by ice roads or gravel structures could be ephemeral (drying up early during the 

summer) and could cause temporary or permanent flooding on adjacent tundra, or they could become 

permanent waterbodies that would persist from year to year. Hydrological impacts along roads and pads, 

such as impoundments, are discussed in Section 4.2.2, “Water Resources.” Tundra covered by impounded 

water could result in a loss of nesting and foraging habitat for spectacled eiders. However, impoundments 

could also create new feeding and brood-rearing habitat that could be beneficial (BLM 2012).

Water withdrawal from lakes during ice road construction has the potential to lower the level of lakes and 

affect spectacled eiders that use adjacent habitats, particularly small islands and shoreline areas that may 

be used for nesting. Changes in the surface levels of lakes due to water withdrawal would depend on the 

amount of water withdrawn, volume of the lake, and recharge rate. There is also potential for impacts to 

spectacled eiders resulting from potential impacts to invertebrate and fish food resources from varying 

winter water levels if pumped lakes do not fully recharge (BLM 2012). The impacts of lowered lake water 

levels are expected to be temporary.

Displacement and Disturbance

Gravel mining and placement of gravel fill would occur during winter when spectacled eiders are not 

present. Road work such as grading, compacting, and reshaping of roads and pads would occur during 

summer when these birds are present. The noise and vehicle traffic during these activities would likely 

disturb and displace spectacled eiders away from gravel roads, pads and airstrips. Disturbance would 

cause the spectacled eiders to expend energy in responding, although it may not necessarily reduce their 

survival or productivity (U.S. Army Corps of Engineers 2012). Noise would likely cause the greatest 

disturbance to spectacled eiders between June 1 and July 15 when they would be on nests and would be 

unwilling to move away from the disturbance (U.S. Army Corps of Engineers 2012).

Johnson et al. (2003a) reported that waterfowl nesting near the Alpine oil field that were displaced from 

nesting sites by gravel placement may move their nest sites to nearby habitats. In addition, there may be a 

functional loss of habitat in areas near roads, pads, and airstrips, if development-related disturbances 

preclude spectacled eiders from utilizing these habitats.

Noise and visual cues from air traffic could disturb spectacled eiders. Responses to aircraft could 

potentially include alert and concealment postures, interrupted foraging behavior, flight, and a reduction 

in nest attendance (U.S. Army Corps of Engineers 2012, Section 5.9.3.1). The impacts of routine aircraft 

flights could range from avoidance of certain areas to abandonment of nesting attempts or lowered 
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survival of young. The potential impact to spectacled eiders from aircraft noise would probably be 

greatest during the nesting period when the movements of incubating birds are already restricted due to 

the need to incubate eggs and birds may be energetically stressed and sensitive to disturbance (BLM 

2012, Section 4.3.8.2, page 176).

Aircraft noise levels would be highest during take-offs and landings, and most aircraft-related disturbance 

would be concentrated around an airstrip for brief time periods. Disturbance may also increase as a 

function of flight frequency, and spectacled eiders in areas that experience many flights may experience 

larger disturbance impacts than those in areas with few flights. Although the potential exists for 

displacement of some nesting spectacled eiders near routinely used airstrips, as a result of numerous overflights, landings, and takeoffs, some eiders may habituate to routine aircraft traffic. Within the project 

study area, the duration of flights would be short and occur in a specific area. Although likely to cause 

disturbance to spectacled eiders, depending on the time of year disturbance from aircraft traffic may be 

minimal.

However, disturbance to spectacled eiders could also result in temporary or permanent displacement from 

high-value habitats, potentially resulting in decreased nesting and nest attendance, nest abandonment, nest 

predation, and increased energy expenditures that could affect an individual eider’s survival or 

reproduction (BLM 2012). Disturbances could displace spectacled eiders from feeding habitats and 

negatively impact energy budgets. Disturbances would impact spectacled eiders during the entire time 

that they would be using the project area, although the impacts may vary depending on reduced forage 

opportunity during nesting if the disturbance causes the eider on the nest to leave the nest exposing the 

nest to an increased rate of predation, and during brood-rearing when some eiders exhibit higher rates of 

alertness in areas near roads than do birds in undisturbed areas. Some evidence suggests that pedestrian 

traffic may have a greater impact on some species of birds than vehicular traffic (BLM 2012). The 

mitigation measure of hazing birds at or near airstrips would likely result in temporary disturbance and 

possible displacement of spectacled eiders.

Mortality

Spectacled eider mortality could result from collisions with vehicles, aircraft, or structures, or predation, 

as described in Section 4.3.3, “Birds.” Minor impacts could be sustained, but are unlikely, due to the low 

density of spectacled eiders in the project study area.

Spectacled eiders may collide with structures necessary for operation such as communication towers, flare 

towers, buildings, antenna guy-wires, and elevated pipelines. Descriptions of such structures associated 

with GMT2 are included in Section 2.4.3, “Drill Pad and Support Facilities.” Satellite dishes, elevated 

radio antennae, and radio repeater sites would also add potential collision hazards. Although bird 

collisions with oil field structures are expected to be infrequent, some collisions and resultant mortality to 

some spectacled eiders are probable.

Bird collision events with infrastructure during poor weather conditions are rare and episodic, but would 

have the potential to occur for the life of the project (long-term). Facilities would always be lighted, a 

situation which can attract birds (U.S. Army Corps of Engineers 2012). Poor visibility due to fog and low 

light conditions, which are common in the project study area (see Section 3.2.3.1, “Climate and 

Meteorology”) would contribute to the risk of collisions with infrastructure. The potential for impact may 

be lessened by downward shielded lighting.

Vehicle traffic on infield gravel roads poses the greatest threat to birds during the summer, when the 

largest numbers of spectacled eiders are present in the project study area, possibly resulting in bird 

collision mortality. Overall, collision mortality is generally thought to be low within North Slope oil 

fields, although this is poorly documented (U.S. Army Corps of Engineers 2012).
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Predation

Ravens, gulls, Arctic fox and red fox, bears, and other predators may be attracted to areas of human 

activity where anthropogenic sources of food and shelter are present. Survival of these predators could 

increase due to the availability of anthropogenic food sources. Other food sources for predators can arise 

from roadkill on new roads creating opportunities for scavenging predators. The BLM has included 

recommendations for a roadkill monitoring and reporting system in Section 4.7, “Mitigation Measures 

and Monitoring.” Increased levels of bird and egg predation due to elevated numbers of predators could, 

in turn, impact spectacled eider populations over time (BLM 2012). In recent years, oil field operators 

have installed predator-proof dumpsters at camps and implemented new refuse handling techniques to 

minimize the attraction of predators. In addition, oil field workers undergo training to make them aware 

of the problems associated with feeding wildlife. At the Alpine oil field, Johnson et al. (2003a) reported 

that ravens (a predatory species) were rarely observed in the area prior to development of infrastructure, 

but were commonly observed after development with nests confirmed in 2000 and 2001. Although ravens 

were commonly observed after the construction of the Alpine development, Johnson et al. (2003a) 

reported no post-development increase in predation rates of waterfowl nests.

Drilling and Operation

The following section describes impacts to spectacled eiders during the drilling and operations phase.

Habitat Loss and Alteration

After initial placement of gravel to construct roads, pads and airstrips in the project study area, some 

habitat alterations from the indirect impacts of snowdrifts, dust fallout, thermokarst, and ponding could 

continue during project operation as described in Section 4.3.3.1, “Construction.”

An oil spill could impact spectacled eiders using terrestrial or aquatic habitats. Potential impacts to 

spectacled eiders would depend on the location and size of the spill, and on the time of year. An oil 

discharge in nesting or brood-rearing habitat could impact spectacled eiders that might congregate in 

these areas. Impact from spills is addressed in Section 4.5, “Impacts of Oil, Saltwater, and Hazardous 

Material Spills.”

Disturbance and Displacement

Road work such as grading, compacting, and maintenance of roads and pads would occur during summer 

when these birds are present. The noise and vehicle traffic during these activities would likely disturb and 

displace spectacled eiders away from gravel roads, pads and airstrips. The potential displacement of birds 

caused by the installation of infrastructure, including gravel fill, pipelines, and other facilities would 

continue through the drilling and operations phase; the impacts of physical displacement by these 

structures would be exacerbated by the addition of traffic noise and visual activity on and near these 

facilities. Potential for disturbance associated with drilling would be present year-round for all action 

alternatives. However, in general, vehicle and aircraft traffic would significantly reduce after construction 

is complete.

The potential displacement of spectacled eiders caused by the installation of infrastructure, including 

gravel fill, pipelines, and other facilities would continue through the drilling and operations phase; the 

impacts of physical displacement by these structures would be exacerbated by the addition of traffic noise 

and visual activity on and near these facilities. Potential for disturbance associated with drilling would be 

present year-round for all action alternatives.
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Oil spill response training activities using watercraft could be conducted on rivers and lakes during the 

open-water season. Spill response training activities would have the potential to disturb foraging, nesting, 

or brood-rearing spectacled eiders.

Mortality

The potential for mortality such as direct collisions with ground vehicles would be highest during the 

drilling and operations phase of the summer season when traffic volume is high and spectacled eiders are 

present in the project area. Mortality impacts that occur during construction of this project, such as 

collisions with infrastructure would continue through the drilling and operations phase of the project.

An oil discharge in molting, staging, or brood-rearing habitats could impact birds that congregate in these 

areas. Increased predation on nests from predators attracted to development is a concern for spectacled 

eiders nesting in the GMT2 Project Study Area. Predators such as fox, bear, and predatory birds are 

attracted to the increased scavenging opportunities associated with development and humans.

Abandonment and Reclamation

Abandonment and reclamation of project facilities may involve removing gravel pads, roads, and airstrip 

or alternatively leaving these (or some facilities) in place indefinitely. Revegetation of abandoned 

facilities could be accomplished by seeding with native vegetation or by allowing natural colonization. 

Winter activities would cause little disturbance or displacement, because most spectacled eiders would be 

absent from the area. Depending on the types of abandonment and reclamation that actually occurs, 

summer road and air traffic could cause disturbance, displacement, and mortality to spectacled eiders that 

would be similar in type, but at potentially lower intensity levels and for shorter durations than caused by 

traffic during the construction and operations phases.

Gravel pads, roads, and airstrips that are not revegetated would have diminished value to most birds in 

general. Revegetation without gravel removal would not return the site to its current utility for most birds. 

If gravel was removed, habitat similar to that currently existing in the area could be created and used by 

birds, although the precise mix of habitat types would likely not be the same as what prevailed at the time 

of disturbance (BLM 2012).

Comparison of Alternatives

In general, the potential impacts of each action alternative on spectacled eiders and their habitats are 

related to individual project components most relevant to bird resources, as listed in Table 70.

All alternatives pose a similar extent of risk to spectacled eiders and their habitats during the first 2 years 

of the construction phase. After that, much less risk would occur during winter under Alternatives A and 

B, as compared to Alternative C, which would require an annual ice road. In considering year-round 

potential impacts, Alternatives A and B would have similar types of possible affects from permanent 

roads, which would be much less under Alternative C. However, the substantial increase in impervious 

surface area required for the airstrip and occupied structure pad could lead to increased impacts under 

Alternative C in the vicinity of the GMT2 pad. The risk to spectacled eiders from oil pipelines would be 

very similar under all the alternatives, although the additional diesel (and mineral oil) pipe required for 

Alternative C makes that alternative potentially more likely to result in an impact from pipelines.

A major difference in components within Alternatives A and B, as compared to Alternative C, is with 

regard to the proposed access (i.e., with or without a gravel road from GMT1). Alternatives A and B 
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require a gravel road which is a narrow linear feature crossing a variety of habitats; Alternative C has a 

similar sized gravel footprint, but in a concentrated location crossing fewer habitats. 

Habitat loss and alteration would vary somewhat among the alternatives. The direct impacts (acres) of 

habitat loss due to gravel placement will not occur on potential high-value habitats for spectacled eiders. 

Table 125 presents the predicted area of indirect impacts (acres) to potential high-value spectacled eider 

habitats within a 300-foot buffer around gravel infrastructure. Indirect impacts to potential high-value 

habitats of spectacled eider within the project study area would only occur under Alternatives A and 

would each amount to less than the 1 percent (Table 125) of potential high-value habitats in the project 

study area for all of the habitats analyzed.

Vehicle traffic on gravel roads may disturb or displace birds. Under all action alternatives, traffic would 

be most intense during construction, then taper off during drilling, and decrease again during the postdrilling operation phase. 

Alternatives A and B, share a common road (GMT1–GMT2), thus, impacts from disturbance and 

displacement of birds from ground transportation would be similar for both alternatives. No alternative 

directly disturbs high value spectacled eider habitat. Alternative A is the only alternative to indirectly 

disturb high-value spectacled eider habitat types with Alternative A directly disturbing 2.9 acres of 

Shallow Open Water without Islands habitat (Table 125). 

The presence or absence of the GMT1–GMT2 Access Road would affect type and frequency of aircraft 

traffic in the project study area throughout the life of the project. Additional information and detail on 

aircraft traffic is provided within in Chapter 2, Sections 2.5.4, 2.6.4, 2.7.4 and Appendix B. Potential 

disturbance impacts to birds from aircraft traffic under Alternatives A and B would originate from new 

flights to/from the Alpine Processing Facility/CD1 airstrip and special studies utilizing rotary aircraft. 

Alternative C would involve all-season air traffic between the Alpine Processing Facility/CD1 airstrip (or 

Kuparuk, Deadhorse, or airports outside the North Slope) and the gravel airstrip at GMT2 and special 

studies utilizing rotary aircraft.

Under all alternatives numbers of flights are the greatest during the construction period, then once 

construction is complete flight numbers drop to a lower level for drilling and annual operations postdrilling. For Alternatives A and B after construction is completed aircraft traffic, primarily during the May 

–September time period when spectacled eiders are present in the area, consists exclusively of helicopter 

flights to support a variety of activities including fish and wildlife studies and visits to spill response 

equipment. Under Alternative C flights to the Alpine Central Processing Facility/CD1 site are the most 

intensive until the GMT2 airstrip is constructed and deemed operable. Afterwards, aircraft flights would 

go directly to the GMT2 airstrip. Flights would be required for routine access to the GMT2 drill pad 

during the non-ice road season (April–December). During ice road season, aircraft would still be utilized 

for support of equipment and personnel. Air traffic to/from the GMT2 airstrip would be greatest during 

drilling. Once drilling is complete, flights decrease in support of essential operations and special studies.

Potential impacts to spectacled eiders from aircraft under Alternative C is greater than Alternatives A or B 

due to the requirement to use aircraft to access the GMT2 drill pad when ice roads are not feasible 

(roughly nine months of the year).

Alternatives A and B would have annual ice roads constructed in Years 1–3 to allow for construction of 

gravel infrastructure. Post-construction of gravel infrastructure there would be no ice roads needed for 

these two alternatives. Alternative C requires annual ice roads to be constructed for the life of the project. 

Spectacled eiders are not present in the area during ice road season and Yokel et al. (2007) found that 

repeated years of ice road construction provided only minimal evidence of additive impacts from building 
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ice roads over the same path in two subsequent years making it unlikely that multiple ice road 

construction seasons would negatively impact to potential high value spectacled eider habitats.

Given the observed recovery of the tundra during the three years of study Yokel et al. 2007), it is doubtful 

that any significant environmental benefit would be gained by requiring that all ice roads be completely 

offset from paths of previous years. A more appropriate mitigation would be to require that ice road routes 

follow the wetter habitats to the greatest extent possible without significantly increasing their length.

Overall, Alternatives A, B, C are expected to result in minor impacts to spectacled eiders and their 

habitats due to the very small amount of high value habitat loss expected to occur as compared to the 

amount of high value habitat available and to the low numbers of spectacled eiders found in the project 

study area.

Alternative D, No Action, would result in no impacts to birds.

4.3.5.3 Polar Bear

Potential impacts to polar bears are described in BLM (2004a, 2012, 2014) and are summarized and 

incorporated in this section.

The Beaufort Sea coastline, creek and river banks, and bluffs along lakes throughout the coastal area of 

NPR-A provide important areas for polar bear resting, feeding, denning, and seasonal movements. There 

have been no polar bear dens documented within 1 mile of the proposed infrastructure (for any of the 

action alternatives) (Map 3.3-6). However, den locations are not static, and polar bears have been known 

to den as far inland as the GMT2 Project area. Female polar bears have fidelity to general areas of suitable 

denning habitat, but not specific denning sites (USFWS 2011b). The GMT2 Project area is outside the 

region where den concentration is expected to be highest (Amstrup and Gardner 1994; Durner et al. 

2013). Mapping of potential polar bear denning habitat (described in Section 3.3.5.3) suggests that the 

GMT2 proposed pad location, the GMT1–GMT2 Access Road route, and most of the pipelines would be 

outside the area designated as critical denning habitat. All proposed GMT2 facilities would be outside the 

area designated as critical for feeding (Durner et al. 2013; USFWS 2014a).

Incidental take regulations promulgated in August 2016 under the Marine Mammal Protection Act 

authorized nonlethal, incidental, unintentional take of small numbers or polar bears for oil and gas-related 

activities in the Beaufort Sea and adjacent northern coast of Alaska (81 FR 52276). Under the Incidental 

take regulations, letters of authorization can be requested from industry to authorize the take of small 

numbers of polar bears and Pacific walrus incidental to the development and production operations 

associated with this project. Project stipulations require that no activities occur within 1 mile of known or 

suspected polar bear dens.

Construction

While no dens are known to have occurred within a mile of GMT2 proposed infrastructure, human-made

features may create suitable denning habitat in addition to the topographic features that naturally occur. 

Denning habitat within/adjacent to infrastructure can be created through drifting of snow.

Polar bears are also attracted to infrastructure through the smell of food or food waste. While the GMT2 

Project area is between 12 and 18 miles inland, bears may move further inland in search of food as sea ice 

becomes scarce during summer and fall.

Stipulations require that no construction activities occur within 1 mile of known or suspected polar bear 

dens. The primary causes of impact to denning or non-denning polar bears would be related to noise 
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caused by vehicle and aircraft traffic or construction activity. Non-denning polar bears could be attracted 

to or avoid the construction activity, depending on the individual bear.

Drilling and Operation

Impacts to denning or non-denning polar bears during drilling and operations would mainly be attributed 

to noise from vehicles, facilities, and aircraft (as described above for construction). Polar bears in the 

Beaufort Sea rarely venture far inland in the summer (Amstrup 2000). Therefore, they are less likely to be 

affected by drilling and operations during the summer. Drilling and operations would occur year-round in 

all action alternatives.

Comparison of Alternatives

All action alternatives could cause similar impacts to denning or non-denning polar bears during 

construction. Impacts (if any) during drilling and operations would be primarily during the winter when 

some female polar bear come ashore for maternity denning.

Habitat Loss and Alteration

Polar bears generally den in areas of topographic relief greater than 1.3 meters (e.g., along river and lake 

banks, coastal areas, and abandoned human-made gravel pads) where drifting snow accumulates early in 

the winter and provides adequate snow cover throughout the denning season (Durner et al. 2013). Bears 

will generally select the leeward side of features relative to the prevailing winds, and generally avoid 

human activity (Durner et al. 2013). Map 3.3-6 shows potential denning habitat within the GMT2 Project 

area (i.e., topographic features which may result in adequate snow depth for a polar bear to create a den).

The proposed GMT2 pad location, the GMT1–GMT2 Access Road (Alternatives A and B), and airstrip 

and occupied structure pad (Alternative C) would be located more than 5 miles from the Beaufort Sea 

coast and thus out of designated critical habitat where polar bears are more commonly reported (USFWS 

2014a).

Under all the action alternatives, habitat loss and alteration impacts to polar bears are expected to be 

minor. There would be no impacts under Alternative D.

Disturbance and Displacement

Denning female polar bears could potentially be disturbed by project-related activities as described for 

terrestrial mammals (see Section 4.3.4.1, “Terrestrial Mammals”). Denning polar bear females are 

sensitive to disturbance, and if disturbance occurs after establishing a den, abandonment of the den could 

occur resulting in mortality of cubs.

Annual ice road construction could impact polar bears already in dens. However, polar bear den detection 

methods (e.g., forward-looking infrared or dog surveys) prior to road construction would identify den 

sites along the proposed route, and dens would be avoided.

The presence of camps or human activity may attract polar bears to the project vicinity and could result in 

incidental or intentional harassment for the protection of both bears and humans. BMP A-8 and USFWS 

LOA requirements on personnel training and harassment protocols should minimize this impact.

Potential disturbance and displacement impacts to polar bears would be minor for all the action 

alternatives. There would be no impacts under Alternative D.
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Mortality

Polar bears could experience mortality from project-related activities as described for terrestrial mammals 

(see Section 4.3.4.1, “Terrestrial Mammals”), or in the event a large oil spill reached marine waters. 

Potential impacts of oil spills are described in Section 4.5 of this document. The extent of environmental 

impacts of a spill would depend on the type and amount of material spilled, the location of the spill, and 

the effectiveness of the cleanup. It is anticipated, based on North Slope spill history, that the majority of 

spills would be contained on a gravel road or pad with little or no impacts to polar bears. Polar bear 

deaths resulting from vehicle collisions, ingestion of hazardous chemicals, and defense of life kills or 

other impacts are unlikely to occur. Waste management protocols at the work site, personnel training, and 

permit/lease stipulations are designed to minimize such occurrences.

Subsistence hunters regularly use the project area. However, it is not expected this would result in an 

increased level of mortality to polar bears as the GMT2 Project does not increase access to areas where 

there are higher concentrations of polar bears (along the coastline). Subsistence take quotas are 

established under the Iñuvialuit-Iñupiat Polar Bear Management Agreement (76 FR 47021), and harvests 

are generally lower than the quota.

The potential mortality impacts to polar bears resulting from all the action alternatives are expected to be 

minor. There would be no impacts under Alternative D.

Mitigation

Specific measures to protect polar bears are provided in BLM (2013a):

• BMP A-8: Preparation and implementation of bear-interaction plans to minimize conflicts between 

bears and humans.

• BMP C-1: Prohibition of heavy equipment within one mile of known or observed polar bear dens.

Conclusion

The potential impacts to polar bears resulting from all the action alternatives are expected to be minor, 

with negligible impacts on the population. There would be no impacts to polar bears under Alternative D.

4.3.5.4 Threatened and Endangered Species Evaluated but Unlikely to Sustain Impacts

Ringed Seals

Ringed seals prefer stable, land-fast ice or drifting pack ice and are not expected to occur in locations 

where the GMT2 Project area overlaps with the Tiŋmiaqsiġvik (Ublutuoch) River or the Fish Creek delta. 

No facilities or pipelines are proposed on or immediately adjacent to the marine coastal zone or on 

waterway crossings with connectivity to marine habitat.

Overall, the potential impacts to ringed seals as a result of the GMT2 Project are expected to be 

negligible. There would be no impacts to ringed seals under Alternative D.

Bowhead Whale

Bowhead whales migrate through the Beaufort Sea, but generally do not occur in the nearshore waters 

north of the GMT2 Project area. However, potential impacts are considered here because of the ecological 

and cultural importance of the bowhead. No impacts to population, habitat, migration, foraging, breeding, 

survival, or mortality are expected (BLM 2004).
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There would be no marine transportation-related impacts (e.g., barging) to bowhead whales associated 

with the GMT2 Project, as there is no marine activity involved. In summary, there are no potential 

impacts to bowhead whales expected to occur resulting from the GMT2 Project.

Other Species

As described in BLM (2012) the fin whale and humpback whale (both listed as endangered) do not occur 

in the GMT2 Project area. The Pacific walrus (candidate) is also extralimital in the Southern Beaufort Sea 

(76 Federal Register 47040, August 3, 2011), and there is a very low probability of adverse impacts from 

the GMT2 Project. Potential impacts to these three species were described in BLM (2012), but due to the 

proposed inland location of GMT2 within the NPR-A, impacts are not further considered in this 

document. The fin whale, humpback whale, and Pacific walrus are, however, subject to the same 

protective measures as other Endangered Species Act or Marine Mammals Protection Act-listed species.

4.4 Social Systems

This section analyzes the potential impacts (“environmental consequences”) of the GMT2 Project on 

social systems. The organization of this section follows that of Chapter 3’s description (“Affected 

Environment”) of social systems, and thus, includes cultural resources (including archaeological and 

traditionally used sites), socio-cultural systems, economic impacts, several aspects of current land use, 

subsistence, public health, and environmental justice.

4.4.1 Cultural Resources

The following is a discussion of potential impacts to cultural resources from the GMT2 Project 

alternatives. Actions related to the construction, drilling, operations and closure of the proposed GMT2 

Project were analyzed for their potential for direct and indirect impacts to cultural resources. This section 

details potential effects to cultural resources based on the proposed alternatives as analyzed under NEPA 

and National Historic Preservation Act regulations. For a discussion of cultural resources in the GMT2 

Project study area see Chapter 3, Section 3.4.1. 

4.4.1.1 Methodology

This cultural resources impacts analysis focused on determining potential project effects to verifiable 

remains, material evidence, and specific locations associated with past human activity or of traditional 

religious or cultural importance. Data sources used to inventory project area cultural resources include the 

Alaska Department of Natural Resources, Office of History and Archaeology, Alaska Heritage Resources 

Survey database (Alaska Department of Natural Resources Office of History and Archaeology 2017), and 

the North Slope Borough Traditional Land Use Inventory (North Slope Borough 2017b). Recent cultural 

resources surveys of the study area (Reanier 2009a, 2009b, 2014a, 2014b; Reanier and Kunz 2010) also 

provide useful contextual information about sites in the project area.

Section 106 regulations define the area of potential effect for cultural resources as: “the geographic area 

or areas within which an undertaking may directly or indirectly cause alterations in the character or use of 

historic properties, if any such properties exist. The area of potential effect is influenced by the scale and 

nature of the undertaking and may be different for different kinds of effects caused by the undertaking” 

(36 CFR 800.16[d]).

For cultural resources, direct affects typically occur due to ground disturbance during construction. 

Accordingly, the area of potential effect for direct effects to cultural resources is limited to the proposed 

GMT2 Project footprint. This includes new permanent infrastructure (e.g., roads, airstrip, pads, and 

pipelines), existing infrastructure that will be used as part of the project, mining at the gravel source, and 

ice roads. Other activities and events that can directly impact cultural resources might be in the vicinity 
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of, rather than directly within, the project footprint. These can include damage caused by equipment 

during the construction, drilling, and operation phases of the project, and unanticipated incidents such as 

blowouts, spills, or fires and subsequent cleanup activities. Drilling, operations, maintenance, and closure 

of facilities would result in minimal new ground disturbance, with less of a chance for subsequent direct 

impacts.

Typically, indirect effects to cultural resources occur through increased use or visual or noise effects. 

These can include illegal collection due to increased access to an area, subsidence and erosion, or changes 

to the landscape due to development that alters the viewshed and soundscape. The area of potential effect 

for indirect effects relating to access consists of a 2.5-mile buffer surrounding new GMT2 new 

infrastructure components, including roads, the airstrip, pads and pipelines. The area of potential effect 

for indirect effects relating to visual or noise effects consists of a 5-mile buffer surrounding the project’s 

new infrastructure components. This analysis area is based on descriptions of noise and visibility 

discussed in BLM (2004a, Section 3.2.3, 4A.2.3.3, 3.4.8, 4.4.8) and BLM (2012, Section 3.4.9).

Under the National Historic Preservation Act, historic properties are defined as any prehistoric or historic 

district, site, building, structure, or object included in, or eligible for inclusion in, the National Historic 

Preservation Act maintained by the Secretary of the Interior (36 CFR Part 800.16(l)(1)). To evaluate 

impacts, historic properties are subject to the criteria of adverse effect. A significant or adverse effect to 

historic properties, as defined both by 36 CFR Section 800.5 would include:

• An undertaking that directly or indirectly alters any of the characteristics of a historic property that 

qualify the property for inclusion in the National Historic Preservation Act. This includes diminishing 

the integrity of the property's location, design, setting, materials, workmanship, feeling, or 

association.

• Adverse effects on historic properties include, but are not limited to: (i) physical destruction of or 

damage to all or part of the property; (ii) alteration of a property, including restoration, rehabilitation, 

repair, maintenance, and stabilization; (iii) removal of the property from its historic location; (iv) 

change of the character of the property's use or of physical features within the property's setting that 

contribute to its historic significance; and (v) introduction of visual, atmospheric or audible elements 

that diminish the integrity of the property's significant historic features.

• Effects may be considered not adverse when the property is of value only for its potential contribution 

to archaeological, historical, or architectural research, and when such value can be substantially 

preserved through the conduct of research.

For the GMT2 Project, direct impacts could occur in the project footprint during the construction and/or 

operation phase of the action. Examples of direct impacts to cultural resources could include grounddisturbing activities that result in physical destruction of or damage to all or part of a cultural resource, 

removal of the resource from its original location, change in the character of the resource’s use or change 

of the physical features within the resource’s setting that contribute to the importance of the resource, 

change in access to traditional use sites by traditional users, or loss of cultural identity with a resource.

Indirect impacts to cultural resources for the GMT2 Project could occur away from the project 

infrastructure footprints within the 2.5-mile area of potential effect. Indirect impacts to cultural resources 

could occur throughout the construction and operation phases of the project and during project closure. 

Examples of indirect impacts to cultural resources in the analysis area could include removal, trampling, 

or dislocation of cultural resources and culturally sensitive areas by personnel and visitors; complete or 

partial destruction of a site from erosion, melting permafrost, subsidence, vibrations, or other landscape 

changes caused by new GMT2 infrastructure components; the loss of traditional meaning or importance 

of a resource or loss of cultural association with a resource; neglect of a resource that causes 

deterioration; and vandalism or the illegal collection or looting of artifacts.
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The noise and visual indirect impact analysis area for cultural resources extends 5 miles from proposed 

GMT2 new infrastructure components. Examples of noise and visual impacts to sites may include 

interrupted views that would adversely affect character, nature, or feeling of cultural resources, such as 

direct views of project components from cultural resource sites; and loss or degradation of viewshed 

features. Altering the soundscape and viewshed of a property can alter the integrity setting and feeling, 

which can be critical for demonstrating that a site conveys its significance for the National Historic 

Preservation Act (Hardesty and Little 2009, pages 62–64). 

The analysis of impacts on cultural resources includes direct and indirect impacts to Alaska Heritage 

Resources Survey and Traditional Land Use Inventory sites by alternative. Impacts to other important 

features of the Nuiqsut cultural landscape, such as altering the way subsistence hunters access hunting 

areas, decreased use of subsistence areas due to decreased availability of subsistence resources, 

accompanying loss of cultural association with those areas and gradual shifting of cultural activities away 

from areas within the cultural landscape due to avoidance of project components, are assessed in 

“Sociocultural” and “Subsistence” Sections (4.4.2 and 4.4.5) and are not repeated in this analysis.

4.4.1.2 Impacts by Alternative A

ConocoPhillips’ proposed GMT2 Project (Alternative A) includes the drill pad, gravel access road, and 

pipeline, along with the ice roads and gravel source used to construct GMT2 (Map 2.5-1). This section 

presents cultural resource impacts by Alternative A and the analysis focuses on potential site impacts due 

to GMT2 within the whole study area regardless of land status. Alternative A development overlaps with 

existing infrastructure relating to the village of Nuiqsut, the Alpine units (BLM 2004), and GMT1 (BLM 

2014). This section first addresses sites in the APE, identifying which sites require no further discussion 

due to reasons such as removal and which sites require further consideration. The resulting sites that may 

be potentially impacted due to expansion will then be assessed according to phase (construction, drilling, 

and operations), activity, proximity to those activities under Alternative A.

Potentially-Impacted Sites 

As shown in Table 126, no TLUI or AHRS sites are located within the Alternative A direct effects APE. 

No sites are located in the footprint of the GMT2 Alternative A gravel road or pad, nor are any sites 

located in the direct footprint of the proposed ice road routes. Three sites, however, are plotted in or in 

close proximity to the footprint of the ASRC gravel mine located outside the NPR-A and warrant some 

discussion. Two sites listed in the TLUI (Qayaqtuaġiaq—TLUIHAR078 and Sigirauk—TLUIHAR103) 

are plotted within the footprint of the ASRC gravel mine—Phase 3. Qayaqtuaġiaq is mis-plotted in the 

modern TLUI 3 miles north of where it has been verified to be (Rick Reanier, personal communication 

2017). As discussed above, to date the existence of either a site named Sigirauk or a fishing or hunting 

camp at the plotted location in the TLUI remains unheard of by Nuiqsut elders and unconfirmed, and 

without traces of cultural remains, no cultural site can be verified at this location (Rick Reanier, personal 

communication 2017). The most current information available suggest that GMT2 Alternative A will not 

result in any direct effects to cultural resources.

Table 126. AHRS and TLUI sites within GMT2 Project

Alternative

Direct Impact 

Analysis Area

Indirect Impact 

Analysis Area

Visual and Noise 

Impact Analysis 

Area

Total Number of 

Cultural Sites in 

Analysis Areas

Alternative A 0 10 14 24

Alternative B 0 10 14 24

Alternative C 0 10 14 24
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The AHRS and TLUI indicate 15 sites within the 2.5-mile indirect effects APE. Two of these sites, HAR00055 and Nappaun (HAR-00089/TLUIHAR081), have been totally destroyed due to erosion, while the 

commercial lifeboat at HAR-00054 is no longer present. Therefore, Alternative A will not contribute to 

any access, viewshed, or soundscape impacts to these three sites and they will be discussed no further. 

Four TLUI sites, (Nuiqsut—TLUIHAR061, Napasalgun—TLUIHAR077, Tuiġauraq—TLUIHAR075, 

and Qayaqtuaġiaq—TLUIHAR078) are located within or just south of Nuiqsut. GMT2 development does 

not provide any easier access to these locations than is already provided, so Alternative A will not alter the 

accessibility, viewshed, or soundscape to these sites and they will be discussed no further. The Putu site—

TLUIHAR079/HAR-00158, is located between 600 and 1,800 meters of the ice road used for hauling 

gravel between the ASRC mine and the GMT2 development area; Putu will be addressed further in the 

construction section below. Sites such as Tiŋmiaqsiuġvik (TLUIHAR087), Apqugaaluk (TLUIHAR083), 

Nanuq (TLUIHAR082/HAR-00156), Uyaġagvik (TLUIHAR080/HAR-00155), and Niglivik 2 (HAR00157) are located between 100 and 1800 meters of both the existing road system and the temporary ice 

roads that closely parallel the permanent Alpine Development roads out of Nuiqsut; these will be 

addressed further in the construction and operations sections below. The plotted location for Nanuq north 

of CD4 is notable as it falls approximately 150 and 100 meters from the permanent road and proposed ice 

roads route, respectively, which will warrant some further discussion below in the construction and 

operations sections.

The AHRS and TLUI indicate 15 sites within the 5-mile visual and noise effects APE. Sites Iļaaniġruaq—

TLUIHAR063 and Itqiļippaa—HAR-000163/TLUIHAR074 are located south of Nuiqsut. As is the case 

with the three sites within and just south of Nuiqsut, GMT2 development does not provide any easier 

access to these locations than is already provided, so Alternative A will not alter the accessibility, 

viewshed, or soundscape to these sites and they will be discussed no further. Nine other sites in the visual 

and noise effects APE including HAR-00044, HAR-00059, HAR-00068, HAR-00070, HAR-00074, 

HAR-00077, HAR-00078, Niġliq (TLUIHAR084/HAR-00169), and HAR-00171, are located north and 

east of CD1, CD2, CD4, and CD5 and the connecting road system; these will be addressed further in the 

construction and operations sections below. Three sites including HAR-00053, HAR-00069, and Sikulium 

Paaŋa (TLUIHAR041) are located to the northwest of the GMT2 development pad and road, which will 

be addressed further in the construction and operations sections below.

Construction

The potential for the discovery of unanticipated archaeological deposits during construction activities 

exists within proposed disturbance areas and could result in direct effects. Unanticipated discoveries 

could result in displacement or loss—either complete or partial—of archaeological material. Such 

disturbance affects the potential to understand the context of the site and limits the ability to extrapolate 

data regarding prehistoric activity, settlement and subsistence patterns. However, given the number of 

previous surveys conducted in the study area, the relatively small number of cultural resources 

documented, and the low probability of the construction footprint areas for containing cultural resources, 

impacts from unanticipated discoveries are considered unlikely.

No sites fall within 5 miles (the visual and noise boundary) of the gravel road, pad, or pipeline that will be 

constructed for GMT2. Therefore, construction phase for these elements is not expected to impact any 

sites.

Putu (historic sod house site) is located within the 2.5-mile vicinity of the gravel source ice road, and any 

impacts to this site would be limited to the construction phase. In terms of impacts, the intensity of 

building an ice road 500 or more meters from Putu is expected to be low and without a perceptible change 

to either resource. Any impacts that alter accessibility, viewshed, or soundscape will occur only through 

the winter over one to two years, thus any potential impacts will be temporary in duration. Any potential 
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impacts would be local in extent, and would not affect a resource of regional or statewide significance, 

particularly as Putu’s context is a common resource type on the North Slope. Overall, the likelihood of an 

impact affecting this site as a result of Alternative A is highly unlikely.

Tiŋmiaqsiuġvik (fishing area), Apqugaaluk (fishing area), Uyaġagvik (a location for fishing, hunting, 

trapping, and collecting net weight stones), and Niglivik 2 (historic sod house site) are located within the 

2.5-mile vicinity of the existing road system and the temporary ice roads that closely parallel the 

permanent Alpine Development roads out of Nuiqsut. Any impacts to these sites due to the ice roads 

would be limited to the construction phase. In terms of impacts, the intensity of building an ice road 500 

or more meters from one of these sites is expected to be low without a perceptible change to any of the 

resources. Any impacts from the ice roads that alter accessibility, viewshed, or soundscape will occur only 

through the winter over one to two years, thus any potential impacts will be temporary in duration. Any 

potential impacts would be local in extent, and would not affect a resource of regional or statewide 

significance, particularly as the fishing, hunting, and trapping locations and historic sod house ruins are 

common context types for cultural resources on the North Slope. Overall, the likelihood of the winter ice 

roads having an impact occurring at any of these locations as a result of Alternative A is highly unlikely.

Nanuq (historic sod house site used by reindeer herder families) is plotted approximately 100 meters from 

the existing gravel and a temporary ice roads between CD1 and CD5, which warrants further discussion 

due to the site’s context and its proximity to GMT2 development. Due to the sizes of domestic sites on the 

North Slope that often span one or more hundred meters wide, there is a substantial possibility that an ice 

road may cross through the site. The expected intensity of building an ice road 100 meters or less from 

this site would be moderate with a potentially perceptible change to the resource but unlikely to result in 

the permanent loss of context. Any impacts from the ice road that alter accessibility, viewshed, or 

soundscape will occur only through the winter over one to two years, thus any potential impacts will be 

temporary in duration. Any impacts would be regional or extended in extent as Nanuq is associated with 

Reindeer herding that occurred out of the Barrow herds (Hedman and Meinhardt 2006; Mager 2012; 

Simon 1998; Sonnenfeld 1959; Stern 1980; Stern, et al. 1980) and is expected to be of regional, if not 

statewide, significance. The context can be considered important; despite not having been assessed for 

eligibility on the national register, the abundance of cultural remains described in the AHRS and its ties to 

a significant event in the history of North Slope Iñupiat (the historic reindeer herding that occurred 

between the late 19th and first half of the 20th centuries) suggest that this site is significant to regional 

Iñupiat history. Overall, it is highly unlikely that the Alternative A winter ice roads will impact the Nanuq 

site, primarily due to the short duration over the course of two winters and the frozen and snowy 

conditions. It can be expected that these snow-covered and frozen conditions will hinder surface visibility 

and soil erodability and penetrability, thus limiting the likelihood of illegal collection, subsidence, and 

erosion due to increased access to an area.

HAR-00044 (grave marker), HAR-00059 (prehistoric caribou rib with cut marks), HAR-00068 (historic 

sod house site), HAR-00070 (grave), HAR-00074 (grave), HAR-00077 (historic sod house site), HAR00078 (historic sod house site), Niġliq (Location of prehistoric and historic trade fairs; registered on 

NRHP), HAR-00171 (historic sod house site), HAR-00066 (Fragmentary mammal fossils), HAR-00053 

(memorial site), HAR-00069 (historic sod house site), and Sikulium Paaŋa (fishing and hunting area) are 

located north, west and east of the existing gravel and a temporary ice roads connecting CD1, CD2, CD4, 

CD5, GMT1, and GMT2. 

Any impacts to these sites due to the ice roads would be limited to the construction phase, and would be 

limited to visual and audible changes. In terms of impacts, the intensity of building an ice road more than 

2.5 miles from one of these sites is expected to be extremely low without a perceptible change to any of 

the resources. The ice roads do not provide substantially-improved access to the sites, making it 

extremely unlikely that the ice roads will contribute to physical disturbance to these sites. Any impacts 

from the ice roads that alter accessibility, viewshed, or soundscape will occur only through the winter 
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over one to two years, and any potential impacts to site integrity due to the ice roads will be temporary in 

duration. HAR-00059, HAR-00068, HAR-00077, HAR-00078, HAR-00171, HAR-00066, HAR-00069 

and Sikulium Paaŋa can be considered to have contexts that are common throughout the North Slope, and 

if any aspects of integrity were impacted by the Alternative A ice roads, they would not affect resources 

beyond the local level. On the other hand, HAR-00044, HAR-00070, HAR-00074, and HAR-00053 

contain human remains or grave markers and are considered unique contexts as they fulfill a distinctive 

role across the Iñupiat communities of the North Slope. If any aspects of their integrity were impacted by 

the Alternative A ice roads, the impacts would extend across the region, if not the state and nation. Finally, 

Niġliq is on the NRHP and considered to have a unique context with a significant role in the history of 

Iñupiat communities of the North Slope; impacts to this site would affect cultural resources and 

communities across the region. Overall, however, it is highly unlikely that the Alternative A winter ice 

roads will impact the physical integrity, viewshed, or soundscape of any of these sites given the >2.5-mile 

distance between the sites and the roads and the limited duration over two winters that the ice roads will 

be in use.

Drilling

Drilling is expected to proceed year-round for approximately 7 years. Direct effects to undocumented 

and/or buried cultural resources during the physical drilling process would be limited to the GMT2 pad 

footprint. No surficial cultural remains have been identified within 5 miles of the pad, and no buried 

remains were identified through subsurface testing at the GMT2 pad site. Therefore, it is unlikely that any 

unknown cultural remains will be disturbed by drilling at GMT2. With no known cultural resources 

located within a 5-mile radius of the GMT2 drill pad, no indirect affects relating to access, visibility, or 

sound are expected to affect these resources in the APE due to drilling.

Other components of the drilling phase for Alternative A (e.g., mobilization, moving, and demobilization 

of drilling equipment along the road systems) are not expected to affect cultural resources as they are 

temporary in duration and would occur within the road systems addressed in the construction section 

above and the operations section below. Indirect effects to undocumented and/or buried cultural resources 

would be identical to those identified for the construction phase addressed above.

Operations

Drilling is expected to proceed year-round for approximately 7 years, with operations continuing for an 

estimated 32 years. No major ground-disturbing activities are associated with the operations phase of 

Alternative A. The potential for spills would still exist, and spills of hydrocarbons or toxic materials could 

disturb or contaminate the surface of shallow-buried, unidentified cultural resources. Visual and/or noise 

effects could also occur from GMT2 equipment operation, drill tower installation, and pipeline operation. 

However, as addressed above for the construction and drilling phases, surface and subsurface surveys in 

the drill pad and surrounding area for cultural remains did not reveal any sites within 5 miles of the 

GMT2 drill pad, access road, or pipeline. Without any known cultural resources located within a 5-mile 

radius of the GMT2 drill pad, road, or pipeline, these operations are not expected to directly or indirectly 

affect cultural resources. 

GMT2 operations will rely on vehicle traffic over the existing Alpine road system throughout the year, 

including snow-free seasons when some cultural materials could be visible from the surface. However, 

this road system is already constructed and in use by ConocoPhillips employees and Nuiqsut residents 

and would not contribute any direct impacts to cultural resources. GMT2 operations could contribute to 

indirect access-, visual-, or noise-related effects through increased vehicle traffic on the Alpine road 

system. The GMT2 production pad will require an estimated 75 operations and maintenance workers that 

would need to travel between GMT2 and the CD1 facilities daily. The increase in personnel transport is 

expected to have a negligible effect on access-related indirect impacts due to BLM’s (2013) Best 
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Management Practices I-1 that addresses training employees to not disturb cultural remains. GMT2 

operations are expected to last up to 32 years, after which the drilling operation will be abandoned and 

vehicle traffic in support of GMT2 will cease. Therefore, the increase in personnel transport to and from 

GMT2 is expected to have a temporary effect on visual- and noise-related indirect impacts.

Impacts to the Nuiqsut Cultural Landscape

Alternative A can have both direct and indirect impacts on the Nuiqsut Cultural Landscape. Direct 

impacts to the Nuiqsut Cultural Landscape could include physical destruction or damage to the landscape 

through ground-disturbing activity; restricted access to multi-generational camps, hunting areas, and 

travel routes used by Nuiqsut residents due to physical barriers and user avoidance of industrial areas; and 

the destruction or degradation of any, including unknown or unrecorded, cultural sites or areas through 

construction activities or incidents associated with project activities. Indirect impacts of Alternative A to 

the Nuiqsut Cultural Landscape may include altering the way subsistence hunters access hunting and 

fishing areas away from the community (e.g., a shift from overland travel by snowmachine or fourwheeler to the use of roads); altering routes used to access hunting areas and to travel between villages, 

cabins, and camps; decreased use of the landscape in the vicinity of project components due to decreased 

availability of subsistence resources, and accompanying loss of cultural association with those areas; and 

gradual shifting of cultural activities away from areas within the cultural landscape due to avoidance of 

project components. Visual and noise impacts to the cultural landscape include disruptions to ambient 

noise levels caused by construction, operation, and reclamation of project components; changes to the 

viewshed due to project components; and the introduction of new landmarks associated with industrial 

infrastructure in culturally sensitive areas.

Project components associated with Alternative A overlap the Nuiqsut Cultural Landscape. As 

demonstrated by the GMT1 Supplemental EIS (BLM 2014, Section 4.4.1, Map 3.3-9, Map 3.4-3), 

cultural activity has historically occurred and continues to occur within the overarching GMT2 Project 

study area, with a heavy occurrence of overland travel routes north and west of Nuiqsut to Fish Creek and 

along the Nigliq Channel. Subsistence use areas also encompass the entire GMT2 Project study area. 

However, new construction, transportation, and operations for GMT2 will extend away from the Nuiqsut 

travel routes illustrated by Stephen R. Braund and Associates (BLM 2014, Map 3.3-9). By this measure, it 

can be expected that increased traffic over transportation routes established by GMT1 and the Alpine 

Units in support of Alternative A will likely contribute to traditional travel routes disruption resulting 

from GMT1 and Alpine development. However, development relating to Alternative A will likely avoid 

further encroachment into such travel routes. The anticipated impacts on traditional uses of the cultural 

landscape is addressed in more detail in the Sections 4.4.2, 4.4.3, 4.4.4, and 4.4.5.

4.4.1.3 Impacts by Alternative B

Alternative B includes a drill pad, a gravel access road (GMT1—GMT2 Access Road), and pipelines, but 

realigns the GMT1—GMT2 Access Road to follow the watershed boundary between Fish Creek and the 

Tinmiaqsiugvik River drainage basins (Map 2.6-1). The potential for direct or indirect impacts to cultural 

resources in the APE is not affected by this rerouting and site impact potential remains identical between 

Alternatives A and B.

Potentially-Impacted Sites

Direct, indirect, and visual and noise impacts to cultural resources under Alternative B are similar to those 

identified for Alternative A.
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Construction

Direct, indirect, and visual and noise impacts to cultural resources due to the Alternative B construction 

phase are similar to those identified for Alternative A.

Drilling

Direct, indirect, and visual and noise impacts to cultural resources due to the Alternative B drilling phase 

are similar to those identified for Alternative A.

Operations

Direct, indirect, and visual and noise impacts to cultural resources due to the Alternative B operations 

phase are similar to those identified for Alternative A.

Impacts to the Nuiqsut Cultural Landscape

Direct, indirect, and visual and noise impacts to cultural resources, including the Nuiqsut Cultural 

Landscape are similar to those identified for Alternative A.

4.4.1.4 Impacts by Alternative C

Alternative C is similar to Alternative A, except with (1) increased development in the vicinity of the 

GMT2 production pad for a larger drill pad, airstrip, apron, occupied structure pad, and airstrip access 

road and (2) without a gravel access road between GMT1 and GMT2 under Alternative C. Access would 

instead be year-round by aircraft and seasonally by an ice road in lieu of the Alternative A access road. 

The ice road would follow a route identical to that of the Alternative A gravel access road (Map 2.7-1 and 

Map 2.7-2). Given the near-identical development plans between Alternatives A and C, this section will 

address only the differences during construction and operations under Alternative C.

Potentially Impacted Sites

Direct, indirect, and visual and noise impacts to cultural resources under Alternative C are similar to those 

identified for Alternative A.

Construction

There is potential for discovering unanticipated archaeological deposits during construction of the larger 

drill pad, airstrip, apron, occupied structure pad, and airstrip access road under Alternative C. 

Unanticipated discoveries could result in displacement or loss—either complete or partial—of 

archaeological material. However, surface and subsurface surveys in the drill pad and surrounding area 

for cultural remains have not revealed any such remains within 5 miles of the GMT2 drill pad. Given the 

number of previous surveys conducted over this area, the relatively small number of cultural resources 

documented, and the low probability of the construction footprint areas for containing cultural resources, 

impacts from unanticipated discoveries are considered unlikely.

All other direct, indirect, and visual and noise impacts to cultural resources due to the Alternative C 

construction phase are similar to those identified for Alternative A.

Drilling

Despite a larger production pad, there is no difference in the planned number of wells between 

Alternatives A and C. Direct, indirect, and visual and noise impacts to cultural resources due to the 

Alternative C drilling phase are similar to those identified for Alternative A. 
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Operations

The Alternative C access road for the operations phase would be an ice road that follows a route identical 

to that of the Alternative A gravel access road. There are no difference in sites impacted due to the GMT2-

GMT1 access roads between Alternatives A and C. Increased air traffic during operations without use of 

an ice road would not result in an increase to site accessibility, and would temporarily affect the viewshed 

and soundscape for sites in the APE for the estimated 32 year duration of GMT2 operations.

All other direct, indirect, and visual and noise impacts to cultural resources due to the Alternative C 

operations phase are similar to those identified for Alternative A.

Impacts to the Nuiqsut Cultural Landscape

Most direct, indirect, and visual and noise impacts to cultural resources, including the Nuiqsut Cultural 

Landscape, will be similar to those identified for Alternative A, with the exception of disturbance due to 

increased aircraft in the area during the spring, summer, and fall. The anticipated effects of aircraft on 

traditional uses of the cultural landscape is addressed in more detail in the Sections 4.4.2, 4.4.3, 4.4.4, and 

4.4.5.

4.4.1.5 Impacts by Alternative D: No Action

Under Alternative D, the no-action alternative, the GMT2 Project and associated infrastructure would not 

be permitted, leaving the current uses of the land in the project area unchanged. No ground-disturbing 

activities associated with the proposed project would occur and there would be no concomitant adverse 

effects to Alaska Heritage Resources Survey sites, Traditional Land Use Inventory sites, historic 

properties, or locations of cultural significance located in the study area. Therefore, no adverse effects or 

impacts to cultural resources or the Nuiqsut cultural landscape are anticipated under Alternative D.

4.4.1.6 Mitigation

Use of practical and reasonable mitigation measures would reduce impacts to cultural resources from 

implementation of the proposed action and alternatives. Specific measures to protect cultural resources 

can be implemented by best management practices. The implementation of best management practices 

and potential mitigation measures that were described in the GMT1 EIS and the NPRA-Record of 

Decision for the protection of cultural resources could also reduce the cumulative effects to cultural 

resource from oil and gas, and non-oil and gas activities, in the GMT2 Project area. Potential impacts to 

cultural resources from the GMT2 Project can also be mitigated by design, construction procedures and 

operational features.

Avoidance

BMP E-13 states that “Lessees shall conduct a cultural and paleontological resources survey prior to any 

ground-disturbing activity including ice roads. Upon finding any potential cultural resource, the lessee or 

their designated representative shall notify the authorized officer and suspend all operations in the 

immediate area of such discovery until written authorization to proceed is issued by the authorized 

officer” (BLM 2013).

North Slope Borough regulations mandate that development activities implement avoidance measures to 

ensure protection of these cultural resource sites during project activity by establishing a 500-foot 

avoidance buffer (North Slope Borough 2017a).

Cultural resource surveys should also include research and consultation or interviews with Nuiqsut 

residents regarding locations of previously unidentified cultural resources to help ensure that no 

unidentified cultural resources are adversely impacted by construction and operation activities and 
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potentially assist in identifying the significance of sites and mitigating impacts. Knowledgeable residents 

from Nuiqsut should also be included during cultural resource field surveys as resource advisors.

Minimization

BMP E-1 states that “All roads must be designed, constructed and maintained to create minimal 

environmental impacts and to protect subsistence use areas and access...”—which will ensure continued 

use of travel routes identified as elements of the Nuiqsut Cultural Landscape. Alternative A incorporates 

subsistence access and pullouts into the proposed project design to mitigate impacts to travel routes. 

ConocoPhillips will continue to consult with the local community on the locations of proposed 

subsistence access areas as part of the proposed GMT2 Project.

Potential visual impacts to two cultural resources near the far margin of the 5-mile impact buffer would be 

minimized by using the recommended mitigation in BLM (2004a) that would blend structures and 

permanent facilities into their surroundings and reduce impacts from lighting on facilities over 20-feet 

high. Potential mitigation measure for visual resource impacts, as described in BLM (2004a), include:

All structures would be painted to blend with the natural environment. All colors would be preapproved including emergency spill containers along river channels. [The] BLM will use 

computer-generated colors to determine the color for structures that blend in best with the 

background colors of the natural landscape and may do a color test onsite. Self-weathering steel, 

or best management practice, will be used on all metal structures not otherwise painted, including 

but not limited to pipelines, communications towers and drill rigs, thus providing a more natural 

color of brown.

Reduction of potential noise impacts is provided through design and operations, mitigation described in 

Section 4.7, Protective Measure F-1 of the BLM (2013a), and BMPs A-9, A-10, E-1, and E-8 from the 

2013 NPRA-Record of Decision.

4.4.1.7 Conclusion

Direct impacts to cultural resources are identical across the three action alternatives, with the only 

differences being minor changes in the access routes and methods between GMT1 and GMT2. There are 

no anticipated direct or indirect impacts to cultural resources as a result of the GMT2 development plan 

alternatives. 

Of the 28 cultural sites listed in the AHRS and TLUI as being in the APE, four either no longer exist or 

cannot be identified, 10 are in the 2.5-mile indirect impact area, and 14 are in the 5-mile visual/noise 

impact area. Seven sites in the APE are located within or south of Nuiqsut and are not expected to be 

impacted by GMT2 (GMT2’s development and construction routes will not extend any closer to these 

sites than is already provided by the village and its existing infrastructure).

The construction phase is not expected to result in any direct or indirect impacts to cultural resources. 

Under each alternative, no cultural sites are known to exist in the direct footprint, and given the number of 

previous surveys conducted in the study area, the relatively small number of cultural resources 

documented, and the low probability of the construction footprint areas for containing cultural resources, 

direct impacts from unanticipated discoveries are considered unlikely. Further, all permanent 

infrastructure constructed for GMT2 (pad, access roads, pipeline, and other support features for 

Alternative C) are beyond the 5-mile visual/noise boundary from any documented cultural sites and are, 

therefore, not expected to result in any indirect impacts. 

Gravel extraction from the ASRC mine’s Phases 2 and 3 is not expected to result in any direct or indirect 

impacts to any cultural resources, nor are any such impacts expected within the 2.5- and 5-mile vicinities 

of ice roads that will be constructed for the purpose of hauling gravel from the mine to the GMT2 
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development area. The gravel operation would be temporary, lasting for up to two winters, and it can be 

expected that snow-covered, and frozen conditions will hinder surface visibility and soil erodability and 

penetrability, thus limiting the likelihood of illegal collection, subsidence, and erosion due to increased 

access to sites in the 2.5- and 5-mile vicinities of gravel extraction and transport areas.

Similarly, it is unlikely that use of ice roads that parallel the Alpine Development road system for 

transporting heavy equipment to GMT2 will impact sites within the 2.5- and 5-mile vicinities of the road 

system. One site, Nanuq—an historic sod house site used by reindeer herder families, is an important site 

located within the 2.5-mile indirect effects area, close (approximately 100 meters) to the temporary ice 

and permanent gravel road systems. However, it is unlikely that this site would be impacted due to ice 

road construction and use due to the frozen, snow-covered conditions that would hinder surface visibility 

and soil erodability and penetrability over the short, two year construction phase. Five sites (four grave 

sites and Niġliq—a traditional prehistoric/historic trade fair site that is registered on the NRHP) are 

located within the 5-mile indirect effects area north of the Alpine ice roads. While these site contexts have 

significant roles in the history of North Slope Iñupiat communities, it is highly unlikely that the winter ice 

roads will impact the physical integrity, viewshed, or soundscape of any of these sites given the >2.5-mile 

distance between the sites and the roads, and the limited duration over two winters that the ice roads will 

be in use.

The drilling phase is not expected to result in any direct or indirect impacts to cultural resources. Without 

any surficial remains identified within 5 miles of the GMT2 pad area, and no buried remains identified 

through subsurface testing at the GMT2 pad site, direct and indirect effects to cultural resources during 

the drilling phase are considered unlikely. Other components of the drilling phase for Alternative A (e.g., 

mobilization, moving, and demobilization of drilling equipment along the road systems) are also not 

expected to affect cultural resources as they are temporary in duration and would occur within the road 

systems (addressed in the construction and operations sections).

The operations phase is not expected to result in any direct or indirect impacts to cultural resources. 

Without any known resources located within a 5-mile radius of the GMT2 drill pad, road, or pipeline, it is 

unlikely that any cultural resources will be directly impacted by hydrocarbon or toxic material spills, or 

indirectly impacted by unauthorized collecting and disturbance or changes to sites’ viewshed and 

soundscape.

GMT2 operations and maintenance will require increased traffic along the road system between CD1 and 

GMT2 throughout the year, including snow-free seasons when some cultural materials could be visible 

from the surface. However, by following BMP I-1 (BLM 2013), informing GMT2 personnel on the 

importance of cultural remains and how to avoid disturbance, indirect impacts such as unauthorized 

collection and disturbance of cultural resources near the road system can be avoided. As GMT2 

operations are expected to last up to 32 years, visual- and noise-related impacts resulting from increased 

transport to and from GMT2 would be temporary.

4.4.2 Sociocultural Systems

Sociocultural systems on the North Slope, as described in Section 3.4.2, are based in large part on the 

family structure and cultural values of the community, with a particular emphasis on the relationship of 

the Iñupiat with the land and its resources. Potential impacts on sociocultural systems from oil 

development are described by BLM (2004, Section 4F.4.1.1; 2012, Section 4.5.14.2–4.5.21.1; and 2014, 

Section 4.4.2). 

Many North Slope Iñupiat experience some general effects of living as indigenous Americans in a period 

of rapid change. Determining which social impacts are attributable to nearby oil development is 

challenging; it requires isolating the impacts of nearby development from the overarching impacts of 
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colonization and technological advances. Different Inupiaq entities and individuals are impacted 

differently. A 2015 sociocultural study on Nuiqsut concluded: “That development has brought changes is 

obvious to all, but whether such changes are perceived, experienced or defined as negative impacts or 

positive benefits is ultimately only something which each citizen of Nuiqsut can decide for him or 

herself,” (Redmond and Thornsohn 2016, page 169). Similarly, the draft ‘Nuiqsut Paisaŋich: A 2017 

Update’ (SRB&A2017f, page 67) concludes that “most in the community have come to an understanding 

that not all development and change can be prevented; therefore, Nuiqsut residents share a common 

goal—to work together to ensure that the community’s interests are put at the forefront and that 

compromises are reached in the event of inter- and intra-community conflict.”

Sociocultural impacts are inherently complex with widely varying positive and negative effects.

Individual outlooks and experience and generational and gender differences can play roles, and there is a 

variety of opinions on the various effects people experience.

In the past, factors related to oil development near Nuiqsut that have been understood as likely to affect 

sociocultural systems have included:

• Employment opportunities

• Increased or variable income and economic disparity

• Tensions related to the permitting process

• Changes to the Nuiqsut Cultural Landscape

• Disruptions to subsistence activities and uses

• Adequacy of mitigation (e.g., availability of State of Alaska NPR-A Impact Mitigation 

Grants)

Alternatives A and B are analyzed together due to insignificant differences in anticipated impacts. 

Alternative C would likely have less support from residents of Nuiqsut (see Subsistence Section 4.4.5) 

and some sociocultural factors would likely be more affected by it. 

4.4.2.1 Impacts Common to All Action Alternatives

Construction and operation of the proposed project is not expected to result in an appreciable influx of 

new, non-resident workers to the community. Oil industry construction and operations personnel would 

be housed in temporary camps or at Alpine. Ice road construction personnel (e.g., employees of Nanuq 

and Arctic Frontier Construction) would be housed in the Kuukpik Hotel in town and adjacent camps. 

Because industry will provide housing, food, health care, and other services for oil industry workers, 

GMT2 would not be expected to result in an appreciable increase in demand on community resources.

An important result of nearby oil development is the annual ice road that connects Nuiqsut to the Dalton 

Highway. Nuiqsut residents appreciate and support the connection to the Dalton and urban centers 

annually during ice road season. There are clear social and economic benefits, such as providing residents 

the ability to travel to communities on the road system with their own vehicles. This gives them much 

greater freedom logistically and economically to travel, visit friends and family, and shop in places where 

groceries and other items are much less expensive and for items that are unavailable in Nuiqsut.

The connection the ice road provides facilitates the importation of alcohol and other drugs to Nuiqsut and 

other North Slope Borough communities. Alcohol and drugs are brought to North Slope villages by a 

variety of means throughout the year, but there is a noticeable increase in the bootlegging economy in 

Nuiqsut and the availability of drugs during the ice road season (Paskewitz 2014; Native Village of 

Nuiqsut Tribal Council 2014a). 
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It is likely that the activities associated with gravel mining will have negative sociocultural impacts to a 

some residents because the noise and vibrations associated with blasting can be can be unnerving (NVN 

2018c). Nuiqsut residents reported gravel mining as an oil development impact as early as 1979 (Brown 

1979 pgs 38-39). Some residents experience stress associated with the physical impacts of the concussion 

waves, which can rattle objects and cause structures to shake. The risk of damage to heating or plumbing 

infrastructure is a concern, and there is confusion over who would be liable for any damage.7 Some 

residents are concerned about the dust and odors that result from the blasting, especially when they are 

perceptible in town or the dust settles on the ice covering the Colville River (NVN 2018a). 

Residents believe that the cultural, spiritual, or other personal value that they place on their families’ 

camping, hunting, and fishing sites is substantially diminished when industrial infrastructure is developed 

nearby. Many express emotions of considerable grief and loss in describing those impacts and explain that 

they have “lost” these areas. Nuiqsut’s 1979 Paisanich (translated as Nuiqsut Heritage or Cultural Plan)

explains that the cultural landscape of Nuiqsut is occupied by a “heritage community that perpetuates 

Iñupiat culture” by harvesting resources, by “preserving places and ideals of value, and by transmitting 

this heritage to future generations.” A 2017 draft update to the Paisanich states “the presence of oil and 

gas infrastructure in traditional hunting areas represents a loss of land to community residents,” (SRB&A 

2017f p. 61). Although some residents take advantage of new infrastructure (i.e., road), “[t]o many 

hunters, these areas are no longer available to them for subsistence harvesting activities,” (ibid). As shown 

on Map 3.3-9, cultural activity occurs throughout the project study area with a heavy occurrence of travel 

routes, trails, and cultural sites in the overland area north and west of the community to Fish Creek and 

along the Nigliq Channel. All alternatives would build permanent oil and gas infrastructure in subsistence 

use areas west of the community. 

Economic Disparity

Some residents of Nuiqsut express tension and conflict with other NSB communities and the NSB 

government associated with nearby oil development. One source of frustration is that the NSB and other 

communities are eligible for and receive NPR-A impact mitigation funds through the State of Alaska, 

while many Nuiqsut residents believe that Nuiqsut should be eligible for the majority of those funds 

because they are the most impacted by development. Other issues involve perceptions on the part of other 

NSB residents that all Nuiqsut residents are extremely wealthy, while some Nuiqsut residents feel they 

have the highest cost of living on the North Slope and are the only NSB residents dealing with the 

negative impacts of oil development (URS Corporation 2005). Tension over competition for NSB 

infrastructure funds and other programs are not specific to Nuiqsut or to GMT2 but are heightened in 

Nuiqsut due to the relatively high-stakes development issues.

As described under the “Economy” sections in Chapter 3 and Chapter 4, the GMT2 Project will provide 

economic benefits for the community of Nuiqsut, for the Kuukpik Corporation, for Arctic Slope Regional 

Corporation, the North Slope Borough, and the State of Alaska. Those sections also provide an overview 

of how all residents of Nuiqsut benefit economically from development. In addition to employment 

opportunities, Nuiqsut residents pay a flat rate of $25 per month for natural gas heating due to an 

agreement negotiated by Kuukpik Corporation that brought a natural gas pipeline to the community from 

Alpine (developing GMT2 (any alternative) would not result in any noticeable changes to this 

arrangement). The Kuukpik Corporation and ConocoPhillips also regularly donate substantial amounts to 

various community groups and causes. The Kuukpik Corporation, as the primary driver of local economic 

 7 7 ASRC (2018) notes that any impacts to local infrastructure are likely not due to blasting at the gravel mine but due to ground 

settling due to climate change as reported in Brubaker, M., et al. (2014). Climate Change in Nuiqsut, Alaska, Strategies for 

Community Health. www.anthc.org/chs/climate/climateandhealthreports.cfm, ANTHC.
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growth in Nuiqsut, has pursued benefits for all residents and represented the interests of the entire 

community with great success (Redmond and Thornsohn 2016; SRB&A 2017f, page 7). 

Rental paid to the Kuukpik Corporation and mineral royalties to the Arctic Slope Regional Corporation 

(ASRC) could result in increased dividend payments to their shareholders and would occur under all 

alternatives. It is assumed that mineral royalties would be the same under all alternatives (BLM does not 

have specific information on royalty agreements between Kuukpik, ASRC, and CPAI). An impact 

associated with income disparity is the competitive intra-community nature of securing impact mitigation 

funds and disagreements over the methods of dispersing other mitigation funds, described in Sections 

3.4.4, 4.4.4, and 4.4.7.

As noted in the 2017 draft update to the Nuiqsut Paisanich, downsides to increased economic 

development and westernization include income inequality. “Economic and political divisions in Nuiqsut 

are one source of social conflict. The three tri-lateral entities of Nuiqsut – Native Village of Nuiqsut, City 

of Nuiqsut, and Kuukpik Corporation —sometimes have different agendas and goals, and disagreements 

can cause divisions in the community. Divisions have also arisen from the establishment of the Kuukpik 

Corporation in the 1970s and the lack of shareholder status for some in the community. In particular, the 

issue of “after-borns”—residents who were born after the initial shares were distributed—is a point of 

contention and conflict between the older and younger generations” 8

. (SRB&A 2017f, page 65). 9This 

issue is relevant to all GMT2 action alternatives because continued development on Kuukpik land 

exacerbates this particular sociocultural issue.

Kuukpik Corporation leadership is working on a proposal to enroll younger residents that will be accepted 

by the majority of its existing shareholders (SRB&A 2017f, page 65), but it is a difficult process (see 

Redmond [2016] for a detailed description10). Kuukpik Corporation reports that approximately two-thirds 

of the original 212 full shareholders are still alive (Kuukpik 2018). The original 21,200 shares were

owned by approximately 368 shareholders in 2013,

11 fewer than half of whom were full shareholders. 

Approximately one-third of the original shareholders never moved to Nuiqsut (Redmond 2016 p. 173). 

This situation, combined with tension inherent in balancing a corporation’s concern with economic 

enterprise with the community’s concern to protect subsistence,, leads to a degree of distrust of the village 

corporation by some community members. (Kuukpik 2018). This analysis does not assert that that distrust 

is either merited or misguided: it only discloses that distrust of Kuukpik is a relevant sociocultural issue in 

the community affected by the proposed action.

Tensions Related to Permitting Processes for Development

The range of impacts that can be directly associated with the permitting process for development in 

Nuiqsut were described for the GMT1 project (BLM 2014, Section 4.4.2). These types of impacts have 

 

9 The Kuukpik Corporation maintains that the authors of The Next Horizon, primarily film producers, are 

not formally trained sociologists and did not base the book on formal, objective scientific analysis. 

Kuukpik contends that the report gets many facts wrong, it is not an authoritative source, and states that 

Kuukpik withdrew its support for the project. Based on these objections, other sources are cited in this 

analysis to corroborate any citations to The Next Horizon, and corrections have been included where the 

information has been provided.

10 The Kuukpik Corporation maintains that the authors of The Next Horizon are not qualified, that the report gets many facts 

wrong, it is not an authoritative source, and states that Kuukpik withdrew its support for the project. Other sources are cited to 

corroborate any citations and corrections have been included where the information has been provided. 

11 11 These statistics are quoted in Redmond (2016, p. 172) citing former Kuukpik president Isaac Nukapigak’s written president’s 

message. A footnote gives the source as Kuukpik Corporation newsletter, Page 1, Volume, Issue 1, Spring 2013.
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been researched on the North Slope and in Nuiqsut in recent decades, notably by Michael Galganaitis 

(Research Foundation of the State University of New York 1984), John Kruse (2006), Adrian Redmond 

(2001, 2016), and SRB&A (2017f). 

These impacts include observations that development-related meetings have taken over a large part of 

social life in the community, confusion about the scheduling and steps in a permitting process, the 

powerlessness many residents experience with regard to oil development decision making, and distrust of 

the government and industry. Importantly, these are unique among social impacts because they are 

impacts that can be isolated from general effects of colonialism and modernization: they are impacts 

created specifically by nearby industrial development.

To better assess the intensity of social impacts and specifically illuminate tensions related to the 

permitting process (social impacts that are directly related to nearby oil development), a computerassisted qualitative analysis of testimony given by Nuiqsut residents at public meetings on oil 

development was conducted. Appendix N of this document includes a description of the analysis, initial 

findings, and the complete codebook used in analysis. 

In the testimony, the most frequent comments on social impacts associated with proposed oil development 

concerned Inupiaq culture, social conflict, bureaucracy12, economy, distrust, future generations, lack of 

power (disenfranchisement), and the lack of analysis of social impacts. Comments on these social impacts 

make up 8 (more than a third) of the top 20 subjects (all types) testified about. Table 127Error! 

Reference source not found.shows the number of codes, by meeting, for each of the 47 separate intuitive 

codes used for testimony. Other social issues that were coded include community capacity to navigate the 

permitting process, the pace of permitting processes, the meetings themselves, and how testimony is 

documented and weighed (“comments”). 

 12 Bureaucracy is the code for comments describing difficulty or confusion with any aspects of the NEPA process or land 

management, including the documents themselves, any acronyms and jargon, what stage of the process the agency is at, and the 

significance of “alternatives” presented in draft NEPA documents. Confusion about the various land owners or managers, 

including which entities own or manage which land, how land conveyance occurs, and what the various authorities of the entities 

are and complaints about information overload and frustration with red tape were also coded for bureaucracy.
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Table 127. Code counts for Nuiqsut residents’ testimony on oil development

Topic

P 1: 2004_2_10

Draft Alpine 

Satellite Dev. Plan

P 2: 2004_8_9 

NE NPR-A 

Amendment 

Draft EIS

P 3: 2010_9_16 

NPR-A IAP/EIS

Scoping

P 4: 2012_5_16

NPR-A Draft 

IAP/EIS

P 5: 2014_3_12

GMT1 EIS 

Scoping

P 6: 2015_5_30

GMT1 

Compensatory 

Mitigation Funds

P 7: 2015_9_22 

GMT1 

Compensatory 

Mitigation Funds

P 8: 2016_3_21 

Nanushuk EIS 

scoping meeting

P 9: 2016_4_22 

Nuiqsut trilateral 

on GMT1 

Compensatory 

Mitigation Funds

P10: 2016_4_22

GMT1 

Compensatory 

Mitigation Funds TOTALS

Abundance of Fish & Wildlife 8 4 3 3 6 3 3 6 3 2 41

Access/Land Loss/Avoidance 16 5 7 18 8 4 7 8 5 3 81

Air Quality 5 0 1 8 3 5 0 8 0 1 31

Air Traffic 6 2 3 0 10 0 0 8 0 1 30

Allotment 1 3 1 2 0 0 0 1 0 0 8

Blowout 0 0 0 2 1 2 1 8 0 2 16

Bridges 10 0 2 0 1 1 0 0 0 0 14

Bureaucracy 4 3 11 4 2 4 21 4 9 1 63

Community Capacity 6 0 0 1 1 0 2 0 7 0 17

Climate Change 1 0 1 1 2 0 0 0 0 0 5

Colville River 6 1 4 3 2 2 4 11 13 4 50

Comments 5 3 1 9 0 2 1 2 0 1 24

Conflict 0 0 3 1 4 11 36 6 7 0 68

Cultural Sites 5 2 0 1 0 0 0 0 0 0 8

Cumulative Impacts 12 4 2 6 6 3 7 6 1 2 49

Lack of Power/Disrespect/

Disenfranchisement 10 1 1 3 1 2 17 4 1 0 40

Distrust 9 1 4 9 4 2 14 11 1 2 57

Economy/Jobs/Poverty/

Royalties

14 6 1 9 5 14 2 7 3 1 62

Environmental Justice 1 0 0 0 0 2 1 0 0 1 5

Fish Creek 5 1 2 2 4 2 4 0 3 6 29

Flooding 5 0 0 0 0 1 0 4 0 0 10

Food (Native & Store-bought) 2 1 1 8 2 0 0 5 1 1 21

Future Generations 7 6 0 9 10 5 6 8 2 0 53

Additional Human Health Issues 5 3 2 1 1 5 1 4 0 0 22

Hunting (competition, regs, 

enforcement) 1 0 3 0 0 1 4 3 18 0 30

Inupiaq Culture 16 6 2 18 7 2 9 4 3 4 71

Judy Creek 0 0 0 0 1 0 0 0 0 0 1

Lack of Environmental Analysis 21 0 4 3 12 1 1 3 4 2 51

Lack of Social Analysis 7 1 1 4 3 2 8 2 3 2 33

Legacy Wells 0 0 0 1 0 1 0 3 0 0 5

Meetings 0 2 1 5 2 2 0 1 0 1 14
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Topic

P 1: 2004_2_10

Draft Alpine 

Satellite Dev. Plan

P 2: 2004_8_9 

NE NPR-A 

Amendment 

Draft EIS

P 3: 2010_9_16 

NPR-A IAP/EIS

Scoping

P 4: 2012_5_16

NPR-A Draft 

IAP/EIS

P 5: 2014_3_12

GMT1 EIS 

Scoping

P 6: 2015_5_30

GMT1 

Compensatory 

Mitigation Funds

P 7: 2015_9_22 

GMT1 

Compensatory 

Mitigation Funds

P 8: 2016_3_21 

Nanushuk EIS 

scoping meeting

P 9: 2016_4_22 

Nuiqsut trilateral 

on GMT1 

Compensatory 

Mitigation Funds

P10: 2016_4_22

GMT1 

Compensatory 

Mitigation Funds TOTALS

Migration Changes 22 9 3 9 6 3 3 10 1 0 66

Compensatory Mitigation 5 7 4 6 6 28 38 6 58 12 170

Nigliq Channel 9 0 1 2 1 2 0 4 1 2 22

Noise 1 0 0 0 0 1 0 1 0 0 3

Offshore Oil Development 0 0 0 1 1 0 1 0 0 0 3

Oliktok 0 0 0 0 0 0 0 0 0 0 0

Overcrowding 0 0 0 4 0 1 0 0 1 0 6

Pace 2 2 2 3 0 1 3 4 4 2 23

Drill Pads & Wells 4 0 0 0 2 1 1 5 0 0 13

Pipelines 19 4 6 5 1 0 0 3 0 0 38

Positive Impacts 3 4 2 0 3 0 0 1 23 1 37

Proximity of Development 11 1 1 3 4 1 2 7 0 0 30

Roads 14 0 3 2 6 1 1 3 27 1 58

Regulations and Enforcement 14 15 5 7 6 8 7 16 6 1 85

Seismic Exploration 0 0 0 1 0 0 0 0 0 0 1

Oil Spills 3 0 2 0 1 2 0 6 0 2 16

Teshekpuk Lake 1 3 1 2 1 0 3 0 0 0 11

Tingmiaqsigvuk 0 0 0 0 0 0 0 0 0 0 0

Traditional Knowledge 9 1 0 3 4 1 0 0 0 0 18

Umiat 1 0 1 1 1 0 0 1 2 0 7

Vegetation 1 0 0 0 0 0 0 0 0 0 1

Water resources 2 0 3 0 1 0 0 0 0 0 6

Water Quality 0 0 0 2 1 1 0 0 3 1 8

Totals 309 101 95 182 143 130 208 194 210 59 1631
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Depicting the code counts by code category (‘family’) indicates that despite extra attention to the 

permitting process at specific meetings, codes in that category tend to occur at a high frequency at most 

meetings. Figure 40 shows that the range of issues characterized as related to the permitting process are 

the most frequently discussed, issues categorized as subsistence are the second most frequently discussed, 

and comments about the impact of development on Inupiaq culture and way of life are the third most 

common.

Figure 40. Counts by Code Family

The coding software allows users to analyze co-occurrences of all codes (or co-occurrences of specific 

codes). Looking at the frequency of co-occurrences with Distrust, for example, the data shows that its 

highest co-occurrences are with Regulations and Enforcement and Lack of Power/Disenfranchisement (14 

times with each). The second highest co-occurrence frequency for Distrust is with Cumulative Impacts, 

Social Conflict, and Access/Land Loss: each co-occur with Distrust nine times.

Pace and Capacity

The pace of the permitting process for development projects around Nuiqsut is recognized as a social 

impact, particularly for individuals or entities that do not have the capacity to engage professionals and 

legal teams to assist with their effective participation. (Please see Section 4.6.8.9 – Cumulative Impacts: 

Subsistence for a description of other current development projects.) As noted in the 2005 Nuiqsut Village 

Profile, “Planning participation is fragmented. Timelines and meetings are spread out so it is hard to keep 

track of what is happening,” (URS Corporation 2005).

In May 2016, the Native Village of Nuiqsut Tribal council adopted a resolution and sent a letter to the 

Secretary of the Interior requesting that the BLM not move forward with the permitting process for 

GMT2 until after the GMT1 project is fully constructed and impacts could be assessed. 

Moving forward with the public review process for GMT-2 would only add to the challenges and 

lasting harm to the community suffered through in the GMT1 permitting []. In order for Native 

Village of Nuiqsut to be a fully informed cooperating agency in the permitting process, Native 

Village of Nuiqsut will rely on our traditional knowledge and observations of the impacts from 

the completed GMT1 project, which has not even broken ground yet. We are also only beginning 
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to understand the full range of impacts from the recently completed, and soon-to-be-expanded, 

CD-5 development, (Native Village of Nuiqsut 2016).

In May 2018 comments on the Draft GMT2 SEIS, the Native Village of Nuiqsut expanded on the effects 

of the pace of development proposals and its capacity to participate:

NVN asks that [the] BLM not permit GMT2 at this time. Development is happening too fast and 

the full effects of the Alpine Satellite Field, including the Greater Mooses Tooth One (GMT1) 

project have not been fully felt or understood by the community. While predicted within the final 

GMT1 SEIS, the impacts of this project are still not actually known. We suggest that any 

permitting for GMT2 be delayed for five years, starting when all of GMT1’s construction is 

complete. 

[W]e are inundated with development proposals and planning exercise. The Nanushuk and 

Liberty projects NEPA processes are both underway, BLM’s regional mitigation strategy for the 

northeastern NPR-A has yet to be finalized, ConocoPhillips is moving forward with developing 

the Willow prospect, and the ACOE also recently sought comments on the dSEIS for GMT2. NVN 

strives to be an active and engaged entity in these review processes, but the amount of planning 

currently underway in the region presents serious capacity challenges in our ability to have 

constructive and meaningful involvement. By delaying GMT2, the true impacts development will 

be more understood and NVN will have greater time to consider the risks of development and 

rigorously engage in this proposed project,” (Native Village of Nuiqsut 2018).

The Kuukpik Corporation noted that it reviewed a letter from environmental organizations to the Corps of 

Engineers requesting that the Corps not issue a 404 permit for GMT2 until GMT2 can be considered in 

tandem with the proposed Willow project. Noting that this would be a delay of at least several years, 

Kuukpik opposed this request (Kuukpik 2018). 

Community control over the pace of development was a main objective of Nuiqsut Paisanich-Nuiqsut 

Heritage: A Cultural Plan (Brown 1979): 

The main objectives of this plan are to:

1. Control the pace and magnitude of change to promote stable and beneficial socioeconomic 

conditions in the village.

2. Protect the natural environment and wild resources from adverse effects of industrial and 

technological activities. 

3. Establish the historical/cultural/subsistence resources and values of the village as major 

considerations in land-use planning, development, and operations.

4. Adapt imposed landownership and jurisdiction to the traditional law of free access and use by the 

homeland people. 

5. Perpetuate traditional activities to assure transmission of cultural values to future generations 

(Brown 1979, page 43)

The three primary Nuiqsut entities (the Tribal government [Native Village of Nuiqsut], the village Alaska 

Native Claims Settlement Act corporation [Kuukpik Corporation], and the City of Nuiqsut) signed a tripartite agreement in 1996 to cooperate, present a united front to oil industry and government agencies, 

and let Kuukpik Corporation represent the community on development issues. The tri-partite agreement 
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stated that the 1979 Cultural Plan would be “adopted in whole and is representative of the common 

goal(s) of local control and self-determination," (Redmond and Thornsohn 2016, page 120). Although the 

Native Village of Nuiqsut council formally withdrew from the tri-partite agreement in 2014 (see BLM 

2014 Section 4.4.2), all entities continue to support the 1979 Cultural Plan and have supported the 

production of the draft Nuiqsut Paisanich: A 2017 Update (SRB&A 2017f). Although entities and 

individuals may have divergent opinions on what pace is desirable, the request made by the 

democratically elected Tribal council to postpone permitting for GMT2 reflects the opinion of many 

residents of Nuiqsut. The Kuukpik Corporation did not initially support exploratory drilling at the Putu 1 

well north of Nuiqsut during the 2016/2017 winter operational season due to its proximity to town, the 

need to explore potential alternatives, and the need to reduce impacts (such as air emissions by requiring 

low emission generators) (Brehmer 2017). The Kuukpik Corporation did subsequently support 

exploratory drilling at Putu 2, a different surface location, after the operator committed to extensive 

mitigation measures, and drilling occurred in winter 2017/2018. The Native Village of Nuiqsut council 

has also formally opposed the Nanushuk development project (NVN 2018d).

Meetings

The frequency and nature of meetings related to the permitting process are recognized as a social impact 

on the North Slope. Residents have been participating in (or invited to participate in) an increasing 

number of governmental and industry meetings throughout recent decades. Overarching issues include 

meeting burnout, culturally inappropriate timing of meetings, frustration at the perceived ineffectiveness 

of testifying or disrespect for traditional knowledge, cultural communication differences, and constraints 

on subjects that can be discussed.

Participants in development meetings are often informed that only certain types of comments and input 

can be considered in the NEPA process (“substantive comments”). Many residents do not have adequate 

or appropriate evidence that government agencies are incorporating their comments and traditional 

knowledge in planning decisions. As corroborated by the testimony content analysis, a perennial concern 

is that they do not know what happens to their input, they suspect that the government is not doing 

anything with it, and this issue is aggravated when agencies return for each EIS process to request it. The 

inability for most people to effectively review and comment on an EIS contributes to feelings of 

disenfranchisement and lack of control over events that will affect their lives. A 2009 survey found that 

70 percent of Nuiqsut respondents have reported concerns about EIS deficiencies (Stephen R. Braund and 

Associates 2009c). In a review of scoping testimony from three development projects in the Nuiqsut area 

(Alpine Satellite, Northstar, and Endicott), “lack of influence” was the most commonly identified concern 

(Stephen R. Braund and Associates 2013c). 

An Inupiaq anthropology student recently focused on this subject for his master’s thesis and found that, 

from 2006 to 2015, the annual average number of development meetings in Utqiagvik more than doubled 

over previous year (Stotts 2016). Although many issues in terms of timing, respect for traditional 

knowledge, and communication styles have improved and residents’ acceptance of development projects 

has increased, meeting attendance is declining. After extensive interviews and observation of public 

meetings in Utqiagvik, Stotts (2016) discussed multiple issues, including what residents refer to as “the 

broken record”—local concerns receiving little to no response. Stotts’ research (2016) also found that 

interviewees felt they had little voice in the stakeholder engagement process and that, although they 

believe meetings are largely necessary, the number of meetings have negatively affected the local 

community. 

These effects are concentrated in Nuiqsut, a much smaller, more traditional community with much more 

recent industrial development. Meetings there have replaced many regular community gatherings (e.g., 
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“singspirations” and potlucks), and disagreements over development that are distressing in the meetings 

sometimes spread to other aspects of life.

For several reasons, federal government meetings tend to be the least popular. Stotts’ research (2016) 

found that federal government meetings on the North Slope are more constrained, rigid, official, and 

culturally obtuse. One reason is the lack of gifts and food at federal government meetings, which can be 

understood as standard compensation for time and effort. Federal government rules prohibit door prizes, 

raffles, and, with rare exceptions, the use of federal money to purchase meeting refreshments. 

Another reason federal meetings are less popular is their purpose. Most BLM meetings in Nuiqsut, in 

keeping with the mandate of NEPA, are to provide the public an opportunity to share insights and 

concerns about impacts. Recent Alaska Native studies have found that meetings and outreach that focus 

on the negative (e.g., industrial impacts on subsistence and Inupiaq culture) are the opposite of what 

constitutes positive and life-affirming, inter-cultural interactions in villages (Peter et al. 2016). Thus, the 

government’s responsibilities to understand and be transparent about impacts result in meetings that are 

rarely enjoyable and with the potential to remind residents of upsetting aspects of their history. Combined 

with a belief that providing input has proven largely pointless, these meetings are often emotional and 

conflict-ridden. 

Nuiqsut’s 1979 Cultural Plan recognized these issues: 

Commonly, state and federal agencies throw curve balls (that is, problems) at outlying villages, 

especially by means of public participation meetings. Seldom are the alternatives presented by 

officials at such meetings true alternatives. Rather, they tend to be variations on decisions already 

made. (“Would you like OCS development to proceed this way or that way?”) Village 

participation in such meetings is often limited to bemused listening and watching. The meetings 

are too tightly scheduled, the official presentations are too long, and there is neither time nor 

provision for translation into the Inupiaq tongue. Assuming that some “input” or “feedback” 

does go on the record, it often remains there – as evidence of input or feedback but not as a public 

contribution to be acted upon. Thus, public participation becomes a pro forma exercise that 

fulfills procedural requirements of the laws that the agency is supposed to substantively 

administer. Thus, the problems remain with the village as agency officials fly off to the next 

meeting. This scenario reflects cross-cultural confusion and communication problems more than 

bad faith, but the results are the same for the village, (Brown 1979, page 50).

As Stotts (2016) notes, many improvements have rendered meetings more meaningful for both agencies 

and residents. Nevertheless, and particularly in Nuiqsut, required development meetings present a 

negative social impact to residents who participate and give up potentially enjoyable free (personal, 

family, or hunting) time for a largely negative experience with no compensation for the hours spent or 

acceptable proof of effectiveness. 

Development meetings can also present negative social impacts for residents who do not participate in 

them. Some residents feel that they should attend the meetings because the future of their region and 

livelihoods are being weighed, but they have to decide between attendance versus hunting or family care 

or jobs. Others may feel they should attend, but they fear social or political repercussions from taking a 

position contrary to that of community leaders or they do not have the emotional resources to tolerate 

negativity and conflict. Subsequently, they may experience guilt over not participating, complicated by 

exacerbated feelings of powerless in regards to the decision-making process, and they may feel that they 

have less standing to provide input in the future. 
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This dilemma—impacts stemming from participation and non-participation—was foreseen in Nuiqsut’s 

1979 Cultural Plan. In the attempt to save their heritage, village people who dedicate themselves to the 

bureaucratic process could become “immersed and indirectly co-opted. If, in frustration, they withdraw to 

pursue traditional activities, they may forfeit their heritage by inaction. Neither extreme is in the best 

interest of the village” (Brown 1979, page 44).

The 2017 draft Update to the Nuiqsut Paisanich reports: “Since the 1970s, the community of Nuiqsut has 

increasingly been overwhelmed with public meetings where residents are expected to voice their 

concerns. Some have indicated they no longer attend these meetings because they do not see the point. 

Others have embraced the view that, while they cannot stop development, they must work with agencies 

and developers to ensure that the land is developed in an environmentally responsible manner and in a 

way that benefits the community,” (SRB&A, 2017, p. 68).

4.4.2.2 Alternatives A and B

Alternatives A and B would provide employment opportunities for the community of Nuiqsut and 

associated non-economic sociocultural benefits. The ability to commute to work daily in personal vehicles 

via the existing Kuukpik Spur Road and the GMT1–GMT2 Access Road and to return home after a shift 

to be with family, attend social events, and participate in subsistence activities would be beneficial for 

current employees, potential employees, and the families of those employees. Currently, permanent 

employees in skilled positions are required to stay at work for 2-week shifts and, unless it is ice road 

season, they are flown back to Nuiqsut for their days off. The community would like to have many more 

young people take advantage of the numerous seasonal or temporary jobs that do not require technical 

skills; however, many of these jobs are available in the non-ice road season and young people are 

particularly averse to giving up their social lives for jobs. The road connection to GMT2 that would be 

provided under Alternatives A and B may make employment at GMT2 significantly more socially 

acceptable for local residents. A strong community desire for this was cited in the 2005 Nuiqsut Village 

Profile: “People should be able to come home from Alpine during the workweek” (URS Corporation 

2005). Employment opportunities will be highest during the construction phase (305 new jobs), and will 

decrease as the GMT2 Project moves into the drilling phase (75 new jobs) and the operations phase (11 

new jobs). 

One difference between Alternatives A and B is economic, which could translate into sociocultural 

impacts. Under Alternative B, the gravel road would not be constructed on land owned by the Kuukpik 

Corporation and the corporation would therefore not receive rental payments for the use of its land. A 

detailed discussion of local, regional, and statewide economic impacts is included in this document in 

Section 4.4.4, “Economy.” Native Corporation shareholders13 and other residents of Nuiqsut will likely 

experience economic benefits from development of GMT2. Economic security is one key component in 

the overall resilience of a sociocultural system. 

Section 4.4.5 discusses potential impacts of Alternatives A and B on subsistence uses. Subsistence hunting 

and harvesting activities are central to the cultural identity and social cohesion of the community of 

Nuiqsut. Disruption of subsistence activities may affect social and kinship ties, many of which are based 

on the harvesting, processing, distribution, and consumption of subsistence resources. If subsistence 

harvesting opportunities are impacted, opportunities to engage in cooperative harvesting activities would 

also change. Reduced participation in subsistence activities could also negatively affect the community’s 

ability to pass on traditional knowledge about subsistence harvesting patterns and cultural values to 

younger generations. As discussed in Section 4.4.5, the GMT2 Project will introduce permanent oil and 

gas infrastructure into traditional hunting areas to the west of the community and contribute to the 

 13 Almost all Inupiaq residents of Nuiqsut are shareholders in Arctic Slope Regional Corporation and many are shareholders, or 

related to shareholders, in Kuukpik Corporation.
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community’s sensitivity to being surrounded by development. Disruptions to subsistence harvesting 

patterns or perceptions of exclusion from traditional lands may result in social stresses on residents and on 

the community as a whole.

4.4.2.3 Alternative C

Sociocultural impacts associated with GMT2 under Alternative C would differ from those under 

Alternatives A and B because there could be resentment that the development scenario generally opposed 

by residents was the one being constructed. It is likely that local supporters of development would oppose 

construction of Alternative C. Construction of Alternative C would likely result in high levels of 

dissatisfaction with the public process, and residents would feel their input was ignored. This would be a 

particularly sensitive impact for those who invested the most time and energy to participate in the GMT2 

Supplemental EIS process. North Slope residents who have participated in that process and similar 

processes have clearly stated that an alternative based on gravel road access is much preferred over any 

alternative where access is provided by air and ice roads.

Under Alternative C, Nuiqsut residents would not be able to use a permanent gravel road to access the 

GMT2 area for subsistence hunting and fishing. Residents employed at GMT2 would be restricted to 

flying home periodically on industry aircraft or using ice roads in the winter. This would occur with a 

backdrop of repeated requests to increase local hire, especially for the temporary, less-skilled jobs that are 

available and that are more attractive to young people and/or people with families and/or people who need 

to undertake subsistence activities in their off hours. 

4.4.2.4 Alternative D

No changes from baseline conditions would be expected under Alternative D because no action would 

take place under this alternative. The Native Village of Nuiqsut Tribal council has expressed frustration 

that the BLM cannot select Alternative D as a preferred alternative and has requested the Department of 

the Interior to delay permitting for GMT2, and the council has not articulated a preference between the 

GMT2 Supplemental EIS action alternatives. The range of sociocultural benefits associated with 

increased wage and dividend incomes and investment in the community that could occur under 

Alternatives A and B would not be realized. 

4.4.2.5 . Effectiveness of Lease Stipulations and Best Management Practices 

Existing mitigation that addresses sociocultural and public health-related issues is provided by the 

following protective measures of BLM (2013, A-1, A-2, A-4, A-10, A-11, A-12, and I-1). These measures 

set numerous standards for industry in order to protect health and human safety from hazardous waste 

disposal (A-1), to precise fuel containment methods (A-4), and BMP A-10, which prevents degradation of 

air quality by requiring pre-development monitoring, inventory and monitoring of emissions, and 

emission reduction plans. BMP A-10 also establishes BLM’s authority to establish new measures if air 

emissions are detected above the maximum acceptable levels. A-12 established that the BLM will, in the 

case of an oil spill, minimize impacts by considering the immediate health impacts and responses for 

affected communities and individuals and establish long-term monitoring for contamination of 

subsistence foods and public health. BMP I-1 requires cultural and environmental training of personnel 

involved in oil field activities. Orientation and training must familiarize personnel with stipulations and 

best management practices and on the specific cultural concerns of the area. Personnel are trained to 

avoid disturbing sites, resources, and subsistence activities. 

These mitigation measures have been in effect and have been added to and improved on for oil 

exploration activities in the NPR-A since the 1998 Northeast NPR-A Integrated Activity Plan. However, it 

should be noted that the BLM lacks the ability to eliminate negative sociocultural impacts for Nuiqsut 

residents through mitigation. 
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Following federal and Alaska guidance, the BLM has undertaken regular government-to-government 

consultation with the Native Village of Nuiqsut throughout the GMT2 Supplemental EIS process and, in 

compliance with Executive Order 12898 on environmental justice, works with Tribal members to confirm 

impacts and to develop mitigation measures.

A report on subsistence mitigation measures related to Nuiqsut (Stephen R. Braund and Associates 2013c) 

found that while industry and agencies have become more effective at addressing environmental 

concerns, several residents expressed the belief that Nuiqsut concerns regarding social impacts were not 

being adequately addressed (Stephen R. Braund and Associates 2013c, page 73). BLM, as a land 

management agency of the federal government, only has authority to make decisions regarding the use of 

BLM-managed lands.

4.4.2.6 Impacts and Concerns that Cannot Be Mitigated Under BLM’s Authority

Numerous sociocultural concerns related to industry have been described to the BLM throughout the 

Alpine Satellites Development planning process, including GMT1 and GMT2, and merit attention in 

order to ameliorate community/industry and community/government relations. The BLM has limited or 

no authority to establish traditional mitigation measures to address the following concerns and impacts 

identified through the consultation process. 

• Lack of a community rehabilitation program: Failure to pass drug tests is one reason that the

percentage of local residents employed in the oil field has declined. Many people would like to work 

temporary seasonal jobs in the field, but if they fail the drug test, they are ineligible until the 

following year. Oil development and oilfield services companies in Nuiqsut have policies requiring a 

permanent employee who fails a drug test to undergo evaluation and treatment before the individual 

can be reconsidered for employment. This can be a straightforward process for non-resident 

employees who have access to certified drug evaluation and treatment programs in urban centers and 

can return to employment within a short period of time. Local residents do not have easy access to 

either of these systems: there is several month waiting list for evaluations. Only once an evaluation 

has been obtained can the individual make an appointment for the required treatment, but there are 

only a few counselors who service the entire North Slope Borough and thus scheduling treatment is 

also difficult. The policies themselves are standard, but the system to address violations 

disenfranchises local residents from the employment opportunities presented by development. 

• Inadequate compensation systems: Residents are frustrated because they experience the negative 

impacts of nearby development, but feel that they do not prosper economically in a manner that is 

proportionate and they feel that mitigation funds are inadequate to respond to impacts. Some residents 

also feel that the compensation systems that have been put in place have exacerbated intra-community 

conflicts and conflicts with the North Slope Borough (Stephen R. Braund and Associates 2013c). 

There is a substantial amount of frustration that the federal government does not have the authority to 

establish and monitor direct compensation programs.

• Throughout the years of oil development on the North Slope and with regards to GMT1, residents and 

leaders have asked the government to require industry to:

o Give preference to local hire, and 

o Provide training programs for local residents.

4.4.2.7 Potential New Mitigation Measures

Many of the measures proposed to mitigate impacts to subsistence (Section 4.4.5.6) will also address 

some sociocultural impacts. They are presented in this final supplemental EIS for GMT2 and, if adopted

and within the authority of the BLM to implement, will be established with the record of decision for 

GMT2. 
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Locally Requested Mitigation Measures

Through the consultation process, local entities and residents have suggested numerous potential benefits 

to the community that they believe could begin to offset the negative impacts to their way of life. 

Although the BLM lacks the authority to require implementation of these measures, many of which could 

be considered social services, they are presented here. 

Heritage Center in Nuiqsut

When asked what could offset the sociocultural impacts Nuiqsut would experience with development of 

GMT1, several residents articulated the need for a local heritage center and a place for youth sports and 

activities. This mitigation measure would address the fact that the community of Nuiqsut’s community 

center is no longer an ideal location for social events due to the regular development-related meetings that 

are held there, and would be a place where the community could meet, pass on traditional knowledge, and 

actively participate in cultural activities.

Support Cultural and Educational Projects

Support projects that document, teach, and protect culture, history, and language, such as: establishing a 

library with a focus on Iñupiat culture that is open year-round; establishing a community-based 

photojournalism/media institute; and building recreation centers, teen centers, playgrounds, and/or picnic 

areas.

Provide Administrative and Technical Support

Assist communities in communicating with levels of government to get issues of concern addressed, such 

as hiring permanent grant writers to submit proposals for impacts mitigation and other grants and to 

produce grant requests, and assist local entities with obtaining technical and legal expertise to advise them 

on the permitting process.

Nuiqsut Drug Rehabilitation Program

The 2005 Nuiqsut Village Profile, based on data compiled during a comprehensive survey of every North 

Slope Borough household, noted this issue as a community priority: “Social services – A rehabilitation 

program, with certified counselors, is needed in the community” (URS Corporation 2005). The lack of 

local counseling and drug rehabilitation programs is understood by some locals as preventing local 

employment in the oil field. 

Provide Educational Support

Assist with the implementation/expansion of Science Technology Engineering Math programs within 

local schools, such as the Alaska Native Science and Engineering Program in impacted communities. 

Support the development and implementation of job training programs in North Slope communities, 

including local oversight/monitoring of development activities (e.g., staff, training, funding to contract for 

technical and scientific expertise).

The NSB suggests that industry could fund a local science center that could be associated with one of the 

suggested buildings. The Borough reports great success despite minimal local resources conducting 

science within NSB communities, typically with the assistance and support of local hunters and the 

participation of local residents. With a dedicated facility containing basic equipment, industry could 

support occasional important scientific research in Nuiqsut with the support and participation of local 

residents.
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Provide Economic and Community Development Opportunities

Develop and implement programs that support local entrepreneurial and economic development in 

impacted communities. Fund the development of long-term community development plans for impacted 

communities. Build new housing to meet growing demand in impacted communities.

Residents have noted that many past workforce development efforts have been geared exclusively 

towards oil industry jobs, while the majority of the jobs available on the North Slope are no longer for 

industry (or that industry jobs are not feasible for parents or caregivers who must stay in town). The 

concern is that everyone who is qualified for a job in industry is quickly hired and relocated to 

Anchorage. The suggestion is that workforce development efforts should refocus to support preparation 

for those jobs that are available in the communities, primarily teachers and nurses. 

Establish a BLM Field Office in Nuiqsut

Local residents have not only requested that an office be established by the BLM in the community of 

Nuiqsut, but that it be staffed by a local who is charged with inspection and enforcement authority on 

behalf of the federal government. By having an office in Nuiqsut, local residents would be able to more 

easily receive timely information and answers to questions; and report issues, local concerns and 

violations to stipulations or best management practices.

Search and Rescue Assistance

Local residents of Nuiqsut have expressed concern regarding the ability of current Search and Rescue 

capabilities within the community given that local hunters are traveling farther away to harvest resources, 

leading to safety concerns both in terms of increased potential for local residents to need assistance, and 

increased capacity for Search and Rescue response. Specific Requests include:

• Upgrades for Search and Rescue Equipment

• Upgrades for Search and Rescue communications, radio and satellite

• Additional training for Search and Rescue Responders

Potential Mitigation Measure #1: Nuiqsut Area Environmental Information Dissemination

Objective: Make data and summary reports derived from local studies available locally. 

Requirements/Standard: The permittee will create a simple, user-friendly website where data, studies, 

reports, and research summaries associated with required monitoring studies are maintained and made 

accessible. These documents will be made accessible via the website within 2 months of finalization. 

The website should not require the creation of accounts or passwords or restrictions on access of any kind. 

When new documents are added to the website, the permittee will notify residents and the BLM by email 

and by posts to any industry-maintained social media accounts (i.e., the Nuisagmiut Facebook group). 

The permittee will also print copies of summary 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 website and notification system will include all data and 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 (non-industry contracted) research on the same area accessible 

in the same manner. 

Potential Benefits and Residual/Unavoidable Impacts: Much of the data that is used by federal 

agencies conducting NEPA analyses is either information derived from studies and research paid for by 
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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. In addition, residents have stated that many of the 

reports that present the data or study results are too complicated, and not effective at communicating 

important information that they need to be able to assist with the NEPA process. This contributes to a 

pervasive belief among local residents that much of this data is compromised, in that the entities who paid 

for or collected the information have a vested interest in manipulating the data in some way (i.e., 

downplaying, minimizing or increasing results; sabotaging accurate data collection; or summarizing 

information in non-meaningful ways). These conflict of interest concerns could be mitigated, in part, by 

the new methodology and peer review requirements established by Potential Subsistence Mitigation 

Measure 8 (section 4.4.5.6) and this Nuiqsut Area Environmental Information Dissemination measure 

would 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.

4.4.2.8 Summary and Comparison of Alternatives

Many sociocultural impacts are similar for Alternatives A and B. Alternative C would result in greater 

sociocultural impacts than Alternatives A and B due to the increased amount of seasonal ice road 

construction and the lack of potentially countervailing benefits that could result from access to the site via 

a permanent gravel road. BLM is not aware of any support by North Slope stakeholders for this 

development scenario. 

Based on testimony by residents of Nuiqsut and on sociocultural research on the community, all GMT2 

action alternatives would result in considerable sociocultural impacts. This conclusion is based on several 

sources (e.g., Lampe 2004; Leavitt 2014; Native Village of Nuiqsut 2016) including oral and written 

testimony of residents from disparate entities and opinion groups contending that social impacts of oil 

development around Nuiqsut are substantial and have been underestimated by previous NEPA analyses. 

This testimony expands on examples and explanations of the impacts described here and many others. In 

addition to the impacts to subsistence described in Section 4.4.5, examples center on the feelings of loss 

associated with the devaluation of traditional sites, powerlessness and disenfranchisement experienced by 

many residents in regards to control over land use decisions, cultural issues that discourage employment 

in the oil fields, and multi-faceted conflict that the proposed GMT2 Project is causing in Nuiqsut. 

Preliminary analysis (computer-assisted qualitative analysis described above in Section 4.4.2.1 and in 

Appendix N) of testimony at the April 2018 Nuiqsut public meeting on the Draft GMT2 SEIS (Nuiqsut 

2018) corroborates the prevalence of these sociocultural impacts. The top code occurrences in the 

transcript for that meeting are depicted in table 128.
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Table 128. Top code occurrences for the April 2018 Nuiqsut public meeting on the Draft GMT2 SEIS

Sociocultural impact Occurrences in 

meeting transcript

Roads (permanent gravel, ice roads, access roads, can be positive or negative) 84

Air Quality 83

Distrust (of government, industry, and/or analyses) 76

Regulations and Enforcement (coded as Rules) 58

Social and political conflict (intra-community conflict exacerbated by the permitting 

process, intercommunity conflict due to impact funds and level of experiencing impacts)

47

Access to Land/Land Loss/ Avoidance of Land 38

Migration changes/localized deflection 36

Lack of Power/Disrespect/Disenfranchisement 32

Pace of development 18

Inupiaq culture and way of life 17

Lack of environmental analysis 16

Economy/jobs/poverty/royalties (positive or negative, can include costs associated with 

traveling further to hunt)

14

Compensatory mitigation (e.g., State of AK NPR-A Impact Mitigation Program) 14

Food (Native food or store bought food, health and safety of food) 12

Bureaucracy (difficulty and confusion with permitting process or land management) 11

Climate change 11

The economic benefits experienced by many residents of Nuiqsut may outweigh or balance out adverse 

sociocultural impacts of GMT2 Alternatives A and B. Many residents acknowledge that development 

helps the community, they have positive attitudes towards industry personnel, and they understand that 

social and environmental impacts are unfortunate but unintended consequences. 

Kuukpik Corporation states, “Regardless of the precise extent of any benefits from the GMT2 road, they 

won’t be enough to offset the development’s impacts on Nuiqsut residents. [ ] [T]here will be some 

modest economic benefits to the community due to Kuukpik and ASRC’s interest in the oil to be 

produced at GMT2, [but] most of those benefits will not be substantial, direct, or immediate enough to 

meaningfully impact those most affected by the development,” (Kuukpik 2018).

This analysis distinguishes that the sociocultural impacts of GMT2 (under either Alternative A or B) will 

be different for many individuals. Impacts would likely be less for individuals who do not use or value the 

GMT2 area as much as others; individuals who have not invested time, energy, and social capital into the 

permitting process; and some individuals whose economic gain from GMT2 Project outweighs any 

negative impacts they experience from the project. 

4.4.3 Economy

This section addresses the potential economic impacts associated with the construction and operation of 

the various GMT2 Project alternatives on the local economy of Nuiqsut, the regional economy of the 

North Slope Borough, and the statewide economy of Alaska. 

The primary economic impacts of the action alternatives are expected to be moderate and would include 

the following:

• Increased economic activity in the community of Nuiqsut, the North Slope Borough, and the State of 

Alaska, resulting from direct industry spending on goods and services during the construction phase, 

operations phase, and until the decommissioning of facilities. 
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• Additional indirect and induced (i.e., multiplier) impacts resulting from supply chain purchase 

resulting from direct industry spending and spending of income earned by workers and government 

spending of revenues for capital and operating programs.

• Increased job opportunities for Alaskans, including residents of Nuiqsut and other communities in the 

North Slope Borough.

• Increased revenue to the City of Nuiqsut, the North Slope Borough, and the State of Alaska, resulting 

from shared royalties, state corporate income taxes, severance taxes, property taxes, bed taxes, NPRA Impacts grant funds, and other fees. 

• Increased revenues to Alaska Native corporations from shared royalties.

• Increased oil production on the North Slope that will result in additional secondary economic impacts, 

including increasing oil into the Trans-Alaska Pipeline System and State revenues.

Despite the decrease in the price of oil over the last several years, the economic impacts associated with 

the GMT2 Project action alternatives are within the range of impacts analyzed in BLM (2004, 2012, 

2014). General impacts to the state, regional, and local economy resulting from potential oil and gas 

activity in the NPR-A are described in BLM (2004, Section 4F.4.2), BLM (2012, Section 4), and BLM 

(2015 Section 4.4.3). 

BLM (2004, 2012) considered broader development scenarios than the GMT2 Project. BLM (2004) 

evaluated development of five satellites (including GMT2); two in the Colville Delta (CD3 and CD4) and 

three in the NPR-A (CD5, GMT1 [formerly CD6], and GMT2 [formerly CD7]). On the other hand, BLM 

(2012) addressed development scenarios encompassing the entire NPR-A. The development scenarios 

included oil production in the Mooses Tooth and Bear Tooth units and at Umiat. The analysis also 

considered production of yet-to-be-discovered oil and gas resources in other parts of the NPR-A. 

The economic impacts presented in the following subsections are specific to the proposed GMT2 Project

and the other alternatives as described in a previous section of this document.

4.4.3.1 Construction

The proposed GMT2 Project includes construction of a drill pad, an 8.2-mile gravel access road, three

subsistence access road pull-outs, 8.6 miles of pipeline, and ice roads. Both proposed construction 

schedules for Alternatives A and B would see drilling begin in the second quarter of Year 3 and first 

anticipated oil in the fourth quarter of Year 3. 

Project-related employment would include temporary jobs during the construction season. The winter 

construction workforce is estimated at 305 workers and summer season workforce is estimated to add up 

to 50 workers. The construction workforce would include specialized tradesmen (at particular short 

periods during construction). Construction seasons will either be 2 or 3 consecutive years. 

As noted in BLM (2004), many of the construction workers hired would need skills and experience in 

drilling and pipeline construction. However, it is expected that there will be employment opportunities for 

residents of Nuiqsut and other North Slope Borough communities. For example, during the 2013–2014 

winter construction activities at CD5, 32 Nuiqsut residents and Kuukpik shareholders were employed as 

construction workers including subsistence representatives and ice road monitors.

The City of Nuiqsut is also projected to receive increased bed taxes resulting from higher hotel occupancy 

during the construction phase of the project. The City of Nuiqsut has a 12 percent bed tax. During the offconstruction season of August 2016–November 2016, City of Nuiqsut bed tax averaged $3,395 per 

month. During the GMT1 construction season of December 2016 through April 2017, it averaged $27,824 

per month (Arnold 2017). Bed taxes from GMT2 are anticipated to be similar. 
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Indirect and induced economic impacts, also referred to as multiplier or spin-off effects, would result 

from in-state industry spending on goods and services, workers’ spending of wages, and government 

spending of royalties and tax payments during construction. 

Like other development projects in the North Slope, it is expected that many of the materials and 

equipment would be purchased outside of Alaska and would be shipped to the job site. A portion of the 

total projects costs, both capital and operating costs, will be paid to companies in Alaska for construction 

of the project. It can be expected that some of the contracts for construction of the facilities would be 

awarded to Alaska private corporations, including North Slope regional and village corporations. These 

payments to local businesses will in turn generate additional economic activity within the state, resulting

in indirect economic effects in the form of additional business sales, employment, and labor income. 

4.4.3.2 Operation 

Operations at GMT2 are expected to begin in late Year 3 (possibly 2020), and oil production would be 

expected to ramp up and peak at approximately 38,000 barrels of oil per day by 2025, then decline at a 

nominal annual exponential rate of approximately 15 percent, to fewer than 1,000 barrels of oil per day by 

2050. 

Table 129 shows the Alaska Department of Revenue’s projections of crude oil production at Alpine and 

the total for the Alaska North Slope through 2024. Note that the Alaska Department of Revenue

production volumes at Alpine include production at Alpine, Fiord, Nanuq, Qannik, and Mustang14 (after

2016). 

Table 129 also shows that oil production on the North Slope is expected to continue to decline into the 

future. With development of GMT2, the annual production volumes at Alpine would increase by 

approximately 52 percent during GMT2’s ramp-up period from approximately 2020–2024. In these same 

years, oil production at GMT2 would add about 4 percent to the total North Slope oil production. Note 

that this does not include projected production at GMT1. According to ConocoPhillips, the combined 

projected production at GMT1 and GMT2 from 2020 to 2024 could add about 8 percent to the total 

projected North Slope oil production for those years. 

Any additional oil production on the North Slope extends the life of the Trans-Alaska Pipeline System

and benefits the State of Alaska through oil revenues. Oil revenues are dependent on the oil production 

levels and the price of oil at the wellhead. The State of Alaska would receive revenues from oil

production in the NPR-A. However, revenues from the NPR-A are treated differently than those from 

state lands and the outer-continental shelf. As noted in Section 3.4.3, “Economy,” federal law designating 

the NPR-A established a requirement that 50 percent of lease sale revenues, royalties, and other revenues 

be paid to the State of Alaska, and the other half be paid to the General Fund of the U.S. Treasury. 

As stated in BLM (2012), the State of Alaska General Fund receives shared revenues from federal leases 

two times per year and the State makes those available as grants to eligible municipalities in the following 

fiscal year. Communities in the North Slope Borough have historically received these grants. Additional 

state-administered NPR-A Impact Grants for planning, construction, maintenance of public facilities, or 

for provision of essential public services can be expected by municipalities in the North Slope region 

from revenues associated with production at GMT2. 

As described in Section 1.1, the GMT Unit has mixed land status with federally managed land, Native 

interim conveyed, and Native selected lands. The GMT Unit Agreement identifies notional participating

area boundaries. The boundaries delineate the leases or areas of leases (tracts) which are expected to

14 Development plans for Mustang indicate that oil will be processed onsite and will tie in to the Alpine and Kuparuk pipelines 

and Trans-Alaska Pipeline System. 
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contribute a portion of the production from each reservoir to the agreement. In the GMT Unit, where only 

exploration drilling has occurred to date, these boundaries represent a theoretical interpretation of the 

reservoir locations. As geophysical data are evaluated, exploration and production wells are drilled, and 

the physical extents of each reservoir are discovered, enough information is collected to reasonably 

determine which leases should be included in a participating area. The BLM uses these boundaries to 

allocate production for royalty purposes to each committed tract within the participating area. Royalties 

are calculated using the allocation method defined in the unit agreement (BLM 2014). 

Until these proposed participating areas are formally established in the GMT Unit, the exact acreage of 

each lease dedicated to each participating area is unknown. While the actual production area from these 

wells has yet to be formally delineated, Arctic Slope Regional Corporation will receive the royalties for 

the percentage of participating area contribution from Arctic Slope Regional Corporation-owned leases. 

Note that the proposed GMT2 drill pad is wholly on land selected by Kuukpik Corporation (Nuiqsut 

Village Corporation) under the Alaska Native Claims Settlement Act within the northeastern portion of 

the NPR-A, and as such will recover subsurface hydrocarbon resources owned by Arctic Slope Regional 

Corporation, on which Kuukpik has an overriding royalty interest. The associated revenue will be 

distributed to Arctic Slope Regional Corporation and Kuukpik shareholders. Other Alaska Native regional 

corporations will also receive royalties through application of Section 7(i) and 7(j) revenue sharing 

provisions of Alaska Native Claims Settlement Act. 

Production from federal leases would also result in royalties paid to the federal government, and the State 

of Alaska will receive 50 percent of these royalties. Tract allocations will be finalized at the time adequate 

geology, geophysics, and reservoir engineering information exists to appropriately describe each reservoir 

area. Participating area boundaries and tract allocations will be established pursuant to the requirements 

of 43 CFR 3137 and the GMT Unit Agreement between Arctic Slope Regional Corporation, 

ConocoPhillips, and BLM, and royalties will be paid according to that agreement. 

It is estimated that total royalties from GTM2 production over the period 2020 to 2050 would amount to 

approximately $1.45 billion in 2015 dollars. This estimate is based on the federal royalty rate of 

16.67 percent of wellhead value for high oil potential areas (BLM 2012), the expected annual production 

volumes at GMT2 (as shown in Table 129), and future oil prices as projected by the Energy Information 

Administration (Energy Information Administration’s Annual Energy Outlook 2015). As described above, 

these royalty payments will be shared among the resource owners and the allocation of royalty payments 

among resource owners will be determined according to the GMT Unit Agreement. 

In addition to royalties, the State of Alaska and the North Slope Borough would receive property tax 

payments associated with the taxable oil infrastructure that will be developed at GMT2. The property tax 

payments would be based on the assessed valuation of the facilities developed onsite. The annual levy is 

based on the full and true property value of property taxable under AS 43.56. For production property, the 

full and true value is based on the replacement cost of a new facility, less depreciation. The depreciation 

rate is based on the economic life of the proven reserves. Pipeline property is treated differently from 

production facilities in that it is valued on the economic value of the property over the life of the proven 

reserves. The state property tax rate is 20 mills. A local tax is levied on the State’s assessed value for oil 

and gas property within a city or borough and is subject to local property tax limitations. The current 

North Slope Borough property tax rate is 18.5 mills, hence, the state portion of the property tax is 1.5 

mills. Based on the above approach, it is estimated that the proposed GMT2 Project would generate total 

property tax revenue of about $226 million (in 2015 dollars) through 2050. Of this amount, approximately 

$209 million would accrue to the North Slope Borough and about $17 million to the State of Alaska.
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Table 129. Projected crude oil production; Alpine, total Alaska North Slope, GMT2

Year

Alpine 

Barrels Per Day

Total Alaska North Slope 

Barrels Per Day

GMT2* 

Barrels Per Day

2015 66,700 509,500 -

2016 64,300 524,100 -

2017 60,300 534,100 -

2018 60,500 533,400 -

2019 55,500 525,700 -

2020 47,200 526,800 -

2021 40,100 518,300 1,500 

2022 34,400 502,500 28,000 

2023 29,800 492,600 33,000 

2024 26,000 491,100 36,000 

2025 Not available 493,400 38,000 

2026 Not available 494,800 35,500 

2027 Not available 492,900 31,950 

2028 Not available Not available 28,755 

2029 Not available Not available 25,880 

2030 Not available Not available 23,292 

2031 Not available Not available 20,962 

2032 Not available Not available 18,866 

2033 Not available Not available 16,980 

2034 Not available Not available 15,282 

2035 Not available Not available 13,753 

2036 Not available Not available 12,378 

2037 Not available Not available 11,140 

2038 Not available Not available 10,026 

2039 Not available Not available 9,024 

2040 Not available Not available 8,121 

2041 Not available Not available 7,309 

2042 Not available Not available 6,578 

2043 Not available Not available 5,920 

2044 Not available Not available 5,328 

2045 Not available Not available 4,796 

2046 Not available Not available 4,316 

2047 Not available Not available 3,884 

2048 Not available Not available 3,496 

2049 Not available Not available 3,146 

2050 Not available Not available 2,832 

Note: Production numbers for Alpine and the North Slope stop at 2024 because Alaska Department of Revenue has only projected 

out to that year. 

Source: 2018 Spring Revenue Forecast, Alaska Department of Revenue, Tax Division (Alpine and Total ANS crude production)

(ADOR 2018). GMT2 production volume estimates were developed based on new information on peak production volume and 

decline rates provided by ConocoPhillips. These estimates assume peak production of 38,000 bopd in 2025 down to less than 3,000 

bopd by 2050.
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State

The State of Alaska would also receive additional corporate income tax on petroleum activity and 

severance taxes from oil production. The corporate income tax is calculated as 9.4 percent of the Alaska 

share of worldwide income for each corporation. The Alaska income is calculated using a “modified 

apportionment formula,” which averages the Alaska share of the corporate worldwide property, sales, and 

extraction and applies that formula to calculate the Alaska share of worldwide income. The Alaska tax 

base for the special corporate income tax on petroleum depends on not only activity and profits within 

Alaska, but also on activity and profits in other locations. However, the model15 used to estimate state 

corporate income taxes for the proposed GMT2 Project does not take into consideration the modified 

apportionment formula because data on the project proponent’s worldwide income is not readily 

available. The model simply evaluates all of the GMT2 Project costs and revenues and the resulting state 

income tax, as if the project proponent did not have any other projects in Alaska or elsewhere. Based on 

the model, that proposed project would generate approximately $308 million (in 2015 dollars) in total 

state corporate income taxes through 2050. Finally, based on the State of Alaska’s current fiscal terms for 

petroleum activity (known as More Alaska Production Act), GMT2 would generate an estimated $379 

million (in 2015 dollars) in total severance taxes net of credits through 2050.

Employment

Project-related employment would include permanent operations and maintenance jobs. The drilling crew 

is estimated to total 75 workers. 

Operations manpower requirements for the GMT2 production pad were presented in BLM (2004) (see 

Table 130). Each 12-hour position represents two people and is equivalent to 4,380 manhours per year. 

The manpower forecast is an estimate of the number of 12-hour positions (that is, two people per 

position) that would work onsite at the production pad location.

Table 130. Operations manpower requirements for GMT2 production pad

Field Personnel Number of Positions

ConocoPhillips Operator 0.25

ConocoPhillips Maintenance 0.10

Contract Operator 0.25

Contract Maintenance 0.10

Heavy Equipment Operator 0.10

Heavy Equipment/Vehicle Repair 0.10

Incremental Number of 12-hour Positions at Production Pad 0.90

Periodic workovers of the wells and eventual removal of facilities would also generate additional 

employment for several years. 

Year-round employment opportunities during the operation of the project would be available for local 

North Slope Borough residents and other Alaskans. With on-going and future training programs geared 

towards special skills required in oilfield services sponsored by both public and private entities, it is 

anticipated that local hire opportunities will be higher than historical rates. However, not all residents of 

Nuiqsut are able to or interested in work for the oil industry for various reasons, including employment 

 15 The model used to estimate state corporate income taxes and severance taxes is the same model (that was developed by Alaska 

Department of Natural Resources and modified to fit the GMT1 project) used in estimating property taxes, as described in the 

comment above.
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demands, perceived prejudices, cultural isolation when employed in the oil field, and their views of 

impacts from industry on their community (see Section 4.4.2, “Sociocultural Systems”). 

Indirect and Induced Economic Impacts

Indirect and induced economic impacts, also referred to as multiplier or spin-off effects, would result 

from in-state industry spending on goods and services, workers’ spending of wages, and government 

spending of royalties and tax payments during the drilling and operation phases of the proposed project. 

The proposed development of GMT2 is estimated to cost about $1.8316 billion (in 2015 dollars). This 

includes the costs of all the facilities: drill site, road, pipeline, other ancillary facilities, and the drilling 

costs. The total cost of the project during the operations phase (from 2020 to 2050) is estimated to amount 

to over $1.65 billion17 (in 2015 dollars). Like other development projects in the North Slope, it is 

expected that many of the materials and equipment would be purchased outside of Alaska and would be 

shipped to the job site. A portion of the total projects costs, both capital and operating costs, will be paid 

to companies in Alaska for transportation, logistics, and other oilfield services. It can be expected that 

some of the contracts for operations and maintenance of the facilities would be awarded to Alaska private 

corporations, including North Slope regional and village corporations. These payments to local businesses 

will in turn generate additional economic activity within the state, resulting in indirect economic effects in 

the form of additional business sales, employment, and labor income. 

Likewise, local spending by workers and government spending of revenues resulting from the proposed 

project would also generate multiplier effects statewide.

4.4.3.3 Summary and Comparison of Alternatives

The preceding section describes the projected economic effects associated with Alternative A, the 

proponent’s proposed design alternative for GMT2. This section discusses how the projected economic 

effects of Alternative A compare with the expected economic effects of the other alternatives being 

considered.

Table 131 summarizes the differences in estimated capital expenditures and projected royalties and taxes 

among the alternatives being considered. Estimated capital expenditures are based on information 

provided by ConocoPhillips, the project proponent, for the various alternatives.

The differences in capital expenditures are primarily due to the differences in infrastructure, including 

drilling expenditures, required under each alternative. The additional facilities and differences in logistics 

are explained in more detail in the discussion below for each of the alternatives.

 16 The estimated project cost is based on information provided by ConocoPhillips. 17 Estimated total cost of the project during the operations phase is based on estimates of operating expenditures on a per barrel 

basis ($ per barrel of oil) of other existing oil fields in the North Slope. The model assumes that OPEX cost is about $17.50 (in 

2015 dollars) per barrel of oil produced.
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Table 131. Comparison of estimated capital expenditures, royalties, and taxes (billions, in 2015 dollars) by 

alternative

Action 

Alternative Description Total CAPEX Royalties Property Tax

State 

Corporate 

Income 

Tax

Severance 

Tax

Royalties 

+ Tax

Alternative A ConocoPhillips 

Proposed 

Project

$1.60

$2.13 $0.17 $0.59 $1.41 $3.22 

Alternative B Alternate Road 

Alignment

Alt A +~$22 

million =Alt A > Alt A < Alt A < Alt A < Alt A

Alternative C Roadless 

Access to GMT2

Alt A + ~$700 

million =Alt A > Alt A < Alt A < Alt A < Alt A

Note: These are estimates of total expenditures, taxes, and revenue that occur at different times. They are not discounted present 

values. CAPEX will occur during Years 1–3. Royalties and severance tax apply to 30 years of production. 

As noted in the discussion of economic effects of Alternative A, property taxes are based on the assessed 

value of oil and gas property. Alternative C would require additional facilities and higher drilling costs 

relative to Alternatives A and B. Estimated property taxes are lowest under Alternatives A and B, because 

these alternatives have lower facilities and drilling costs compared to Alternative C. However, severance 

taxes and state corporate income taxes are expected to be higher under Alternatives A and B compared to 

C due to the current tax structure which is based on an operator’s net income.

Alternative B

Alternative B is very similar to Alternative A because it would involve the same drill site location and 

facility design and would be connected to GMT1 by a permanent road. The difference is the alternate road 

alignment in Alternative B, with the proposed road following the watershed boundary between the Fish 

Creek and the Tinmiaqsiugvik River drainage basins. This alternative would require a slightly longer road 

and pipeline, and may require additional surveying and engineering costs. The associated larger gravel 

requirements and road and pipeline routes would result in slightly larger capital expenditures for this 

alternative compared to Alternative A. 

The impacts to the economy under Alternative B would be similar, but slightly higher than those under 

Alternative A. Royalties would be the same because production schedules and productions values are the 

same for both alternatives. However, there will be slight differences in employment, income, and taxes 

due to the differences in infrastructure requirements and value of facilities (capital costs) as noted above. 

While it is expected that property tax payments under Alternative B would be slightly higher, other state 

taxes (such as corporate income tax and production taxes) would be slightly lower due to the State of 

Alaska’s current tax structure that is based on net profits. Employment and income, particularly during the 

construction phase, are expected to be slightly higher given the additional infrastructure required under 

Alternative B. 

Alternative C

Additional construction and drilling facilities would be required under this alternative (see Table 11 for 

the comparison of project components, facilities, and access for the various alternatives). The need for 

additional facilities at GMT2 under this alternative results in larger capital expenditures compared to 

Alternatives A and B. It is estimated that the total capital cost of Alternative C would be 43 percent higher 

compared to the cost of Alternative A and B. 

While royalties under Alternative C would be the same as under Alternatives A and B because production 

schedule and production volume are the same, property tax revenues under Alternative C would be higher 

compared to Alternatives A and B due to the additional facilities and amenities that would be required 
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during the construction and operations phases. However, state corporate income taxes and severance taxes 

under Alternative C would be lower compared to Alternatives A and B due to higher costs (current fiscal 

terms are based on net income). 

Employment and income impacts under this alternative will be higher compared to Alternatives A and B. 

Year 2 of construction is expected to require 140 additional workers compared to Alternatives A and B. 

Drilling workforce under this alternative is also higher compared to Alternatives A and B, requiring 200 

workers and an additional 20 people for camp operations. Alternative C may lead to increased economic 

activity in Nuiqsut due to additional income from use of the hotel. 

Alternative D

There will be no direct economic impacts to the state and local economy under the no-action alternative.

The range of economic effects associated with construction and operations as described under Alternative 

A would not be realized. Under Alternative D, the Kuukpik Corporation would not receive overriding 

royalty interest on Arctic Slope Regional Corporation’s subsurface hydrocarbon resources, and thus,

Arctic Slope Regional Corporation and Kuukpik shareholders would not receive royalties. Likewise, other 

Alaska Native regional corporations would not receive royalties through application of Section 7(i) and 

7(j) revenue sharing provisions of Alaska Native Claims Settlement Act. 

Summary

Projected royalties paid to the royalty owners are the same for Alternatives A, B, and C, because they 

have the same production and price forecasts.

The estimated taxes include severance (production) tax, ad valorem (property tax), and state corporate 

income tax. Local governments, i.e. the North Slope Borough, participate only in the shared ad valorem 

taxes; the other taxes are paid to the State of Alaska. Note that under the State of Alaska’s oil and gas 

fiscal system (known as the More Alaskan Production Act), the severance tax is based on the net value of 

oil and gas produced, which is the value at the point of production less all qualified lease expenditures. 

Qualified lease expenditures include certain capital and operating expenditures. The State also has various 

tax credits that can partially offset the severance tax, including qualified capital expenditure credit, 

carried-forward annual loss credit, well lease expenditures credit, transferable tax certificate, transitional 

investment expenditure credit, new area development credit, small producer credit, and per-taxable-barrel 

credit. 

As shown in Table 131, Alternative A would generate the highest tax revenue, but as CAPEX increase for 

the other alternatives, and the associated loss carry forward tax credit increases, the net (severance taxes 

less the various tax credits) state tax revenue diminishes. The other tax credits mentioned above can also 

reduce the net tax revenue to the state.

4.4.4 Land Use

All of the action alternatives would result in some level of impact to land use during construction, 

drilling, and operation. These types of impacts are described by BLM (2004, 2012, 2014). This section 

covers land ownership and land management (Section 4.4.4.1), local transportation (Section 4.4.4.2), 

recreation (Section 4.4.4.3), wild and scenic rivers (Section 4.4.4.4), wilderness (Section 4.4.4.5) and 

visual resource management (Section 4.4.4.6). 

4.4.4.1 Land Ownership and Land Management

Land use in the project area largely reflects ownership of the surface and subsurface resources. Land 

ownership is complex and has evolved since 2004, with additional surface land now owned by the 

Kuukpik Corporation (Village Corporation of Nuiqsut) and additional subsurface and surface estate 
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conveyed to Arctic Slope Regional Corporation. Kuukpik also has selected surface acreage and Arctic 

Slope Regional Corporation has selected subsurface and surface acreage in the vicinity of the proposed 

GMT2 facilities. East of the NPR-A, the State owns both the surface and subsurface resources of lands 

not conveyed to Arctic Slope Regional Corporation or the Kuukpik Corporation, as well as the bed of 

navigable waters such as the Colville River. 

As explained in BLM (2004a), the BLM continues to manage selections and land ownership options in 

the NPR-A made under the provisions of Alaska Native Claims Settlement Act and Alaska National 

Interest Lands Conservation Act. The end result of the selection process is a transfer of ownership and 

management of the surface estate and subsurface estate to the village and regional corporations, which 

were established by Alaska Native Claims Settlement Act. In the project area, the BLM remains the 

manager of Kuukpik-selected land and Arctic Slope Regional Corporation-selected subsurface and 

surface estates until ownership has been conveyed. When the surface and subsurface have both been 

transferred out of federal ownership, the BLM no longer manages the federal oil and gas leases. 

Construction

During construction, land use in developed portions of the project area would change. The intensity of 

change would be high, temporary in duration, with a common local context. Human presence would be 

most intense during this phase. Common causes of impacts on land use among the action alternatives 

include construction of gravel pads, roads, and airstrips; pipelines, including installation of vertical 

support members; and excavation and transport of gravel at the Arctic Slope Regional Corporation Mine

site. Ice roads and ice pads would be constructed to assist in development of the project infrastructure. All 

of this construction requires a labor force to complete the work, thus increasing human activity.

On the North Slope, the Borough has a land classification system developed through the municipal 

planning process, and administered by the Zoning Commission and the Borough Assembly. On the 

Official North Slope Borough Zoning Map, some of the GMT2 Project area is zoned for “resource 

development,” and some of the project area is zoned for “conservation” (http://www.northslope.org/assets/images/uploads/b3.pdf). Under the North Slope Borough Municipal Code (North Slope 

Borough MC Section 19.40.070 [A]), the conservation district encompasses the undeveloped areas of the 

Borough, and is intended to conserve the natural ecosystem for all the various plants and animals upon 

which Borough residents depend for subsistence. Subject to this overall intent, the conservation district 

can accommodate resource exploration and development on a limited scale, but major resource 

development projects must apply for rezoning to the resource development district.

ConocoPhillips and the North Slope Borough are currently engaged in the process of rezoning the GMT1 

Project development areas for resource development. With the proposed project construction and North 

Slope Borough rezoning, the actual land use would change from primarily undeveloped land used 

principally for wildlife habitat, subsistence, research, and some recreation, to further oil and gas 

development (industrial use), which is consistent with the purpose of the NPR-A. With the project 

construction, industrial land uses would dominate in the immediate vicinity of the project footprint.

Drilling and Operation

After the construction phase, drilling is expected to take approximately 7 years for Alternatives A and B,

and 7.1 years for Alternative C. During the drilling activities, the impact would be high intensity and land 

use would be reasonably expected to convert to another use after the life of the project. The effected area 

would be the immediate vicinity of the project footprint. Once drilling is completed, human presence 

would be determined by operation, maintenance, and inspection needs, which, in turn, is largely 

determined by the alternative. For Alternative C, an occupied structure pad and air access facilities would 

be occupied year round and an ice road would be occupied annually resulting in a long-term greater 
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human presence. Proposed activities are within the range of development activities evaluated in BLM 

(2004a, 2012). 

The BLM has determined the subsurface resources should be offered for oil and gas leasing with 

requirements for environmental protection and for due diligence to explore for oil and gas to maintain 

ownership of the lease. When a federal oil and gas lease is renewed, previous conditions are reviewed to 

see if they comply with current land use plans. For GMT2, federal oil and gas leases AA-081800 (Unit 

Case File Number), AA-081784, AA-081803, and AA-081781 reflects stipulations in BLM (2008b) 

(BLM 2014, Section 4.4.4). Surface uses on BLM-managed lands must meet the land use plan currently 

in effect (e.g., those best management practices in BLM [2013a]).

Comparison of Alternatives

All action alternatives include drill site development on Arctic Slope Regional Corporation-selected, 

federally managed land and construction of aboveground pipelines (from GMT1 to GMT2) that would 

cross both federal, Native-selected, and private lands (Native patent or interim conveyed). The GMT1–

GMT2 Access Road (Alternative A) would cross federal, Native-selected, and private lands (Native patent 

or interim conveyed). The access road for Alternative B would cross federal and Native-selected lands. 

An access road would not be constructed for Alternative C. For this alternative, the 0.9-mile Airstrip 

Access Road would be located on Arctic Slope Regional Corporation-selected land and on federally 

managed land. The GMT2 drill pad, occupied structure pad, and air access facilities are all on Arctic 

Slope Regional Corporation-selected, federally managed land. The approximate distribution of federal, 

Native selected and Native-owned land crossed by components of each action alternative is listed in Table 

132.

Alternative D would not authorize activity on federally managed land, and would not change land use or 

management in the NPR-A.

Table 132. Land ownership

Linear Component Land Owner

Alternative A 

(Approximate 

Percentage 

[%])

Alternative B 

(Approximate 

Percentage 

[%])

Alternative C 

(Approximate 

Percentage 

[%])

Pipeline Length GMT1 to GMT2 Federal BLM 24 51 24

Pipeline Length GMT1 to GMT2 Native Patent or IC 12 None 12

Pipeline Length GMT1 to GMT2 Native Selected 64 49 64

GMT1–GMT2 Access Road (Gravel) Federal BLM 23 51 23

GMT1–GMT2 Access Road (Gravel) Native Patent or IC 14 None 14

GMT1–GMT2 Access Road (Gravel) Native Selected 63 49 63

GMT2 Air Access Facilities * Federal BLM None None 21

GMT2 Air Access Facilities * Native Patent or IC None None None

GMT2 Air Access Facilities * Native Selected None None 79

GMT2 Airstrip Access Road (Gravel) Federal BLM None None None

GMT2 Airstrip Access Road (Gravel) Native Patent or IC None None None

GMT2 Airstrip Access Road (Gravel) Native Selected None None 100

GMT2 Occupied Structure Pad Federal BLM None None None

GMT2 Occupied Structure Pad Native Patent or IC None None None

GMT2 Occupied Structure Pad Native Selected None None 100

Subsistence Access Pullouts Federal BLM None 33 None

Subsistence Access Pullouts Native Patent or IC 33 None None

Subsistence Access Pullouts Native Selected 67 67 None
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The different route and design elements (among the action alternatives) would cause small differences in 

the area of land use modification, from the current state of near natural to small areas of development for 

the purpose of hydrocarbon production. Development of GMT2 is consistent with the NPR-A Integrated 

Activity Plan adopted by the BLM in 2013 (BLM 2013a), and the GMT2 oil and gas lease(s) issued to 

ConocoPhillips.

In addition to differences in ownership of land affected, the use of the land and access would be changed 

by the construction of the GMT1–GMT2 Access Road (Alternatives A and B). The GMT1–GMT2 Access 

Road would provide vehicle (e.g., off-road vehicle, truck) access to new areas (with agreements in place 

for use of the road for subsistence use). Three pullouts are being incorporated into the GMT1–GMT2

Access Road to support access for subsistence activities. The impacts to land use regarding subsistence 

are addressed in Section 4.4.5, “Subsistence.”

Excluding mine site development, the action alternatives would directly impact various amounts of land 

based on the footprint. The Arctic Slope Regional Corporation Mine site (privately owned; not federally 

managed land) is ConocoPhillips’s preferred material source and is a commercial gravel source that has 

been operating for more than 15 years. Mining will continue as long as marketable gravel resources are 

available at the site (Section 2.4.6). Once mining is complete and the material source no longer viable, the 

Arctic Slope Regional Corporation Mine site would be reclaimed under the terms of the approved 

reclamation plan, as required by relevant agencies.

For all alternatives, there would be a change in land use from primarily undeveloped land used principally 

for wildlife habitat, subsistence, research and some recreation to industrial use. There would be an 

increased access to the project area via gravel GMT1–GMT2 Access Road for subsistence users and 

members of local communities with Alternatives A and B (see Section 4.4.5, “Subsistence”).

Mitigation

ConocoPhillips has included the following design measures as part of the project design to avoid or 

minimize impacts on land ownership, use and management:

• Consulting with land owners or managers within or adjacent to the project area,

• Ensuring project activities do not encroach on Native allotment or traditional land use sites through 

survey and demarcation, and

• Avoiding trespass or impact to Native allotment or other private lands.

Potential impacts to land use are also mitigated by design, and operational features described in Section 

4.7. Adherence to lease stipulations and best management practices of BLM (2013a) will reduce the 

impacts and total area of disturbance; these include: A-1, A-3, A-4, A-5, A-10, C-2, C-3, E-1, E-5, I-1, K1(e) and K-1(g).

4.4.4.2 Local transportation

All of the action alternatives would result in some level of impact to local transportation during 

construction, drilling, and operation. These types of impacts are described in BLM (2004, 2012, 2014). 

Outside the local community of Nuiqsut, the local transportation system is primarily the industrial use 

gravel roads and the new Nuiqsut Spur road. Impacts on this local transportation are expected to be low to 

medium, and are described below, by phase, based generally on qualitative evaluation criteria. The BLM 

has issued rights-of-way and permits within the project area. For any permitted winter activity, the user 

would avoid crossing into the proposed project area and would need to reroute their travel. This may add 

miles to the permitted route activity for a regional extent and a long-term common context. For permitted 
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summer activity, the user would avoid the activity also resulting in a regional extent and a long-term

duration of common impacts.

Construction

Under Alternatives A, B, and C, construction activities would vary by season, but most constructionrelated vehicle traffic would occur on industry-constructed ice roads with restricted public access. Impacts 

to local transportation resulting from these alternatives are anticipated to be low and likely not noticeable. 

For Alternatives A and B, construction activities would be limited to winter until the GMT1–GMT2

Access Road has been constructed. Construction activities may interfere with some winter travel over 

frozen tundra, but this would be a temporary impact, occurring only during the two winter construction 

seasons. Construction of ice roads may also facilitate overland travel; conditional use by local residents 

would be allowed, based on safety restrictions. Local subsistence travel would generally be allowed on 

the GMT1–GMT2 Access Road. Travel of local residents would be allowed through construction areas, 

based on case-by-case conditions, with safety as the principal consideration.

Alternative C would not have year-round road access to the drill site and would rely on seasonally 

constructed ice roads and aircraft for transportation to support construction. The estimated number of 

flights that would be required during construction are listed for each action alternative in Chapter 2 flight 

requirements tables. The primary impact of this air traffic during construction would be to ambient noise, 

wildlife, and subsistence, addressed in Sections 4.2.3.3, 4.3.4 and 4.4.5, respectively.

Drilling and Operation

Operation of the facilities under the action alternatives would result in lower levels of vehicle traffic than 

expected during construction. Traffic on the GMT1–GMT2 Access Road would be limited to the 

transportation of personnel and supplies between GMT2 and CD1/Alpine Processing Facility. These trips 

would likely be coordinated with operations at GMT1, resulting in effectively increased traffic between 

GMT1 and GMT2. Traffic on the authorized GMT1 to CD5 road would also increase with the additional 

traffic to GMT2. The regional and statewide transportation systems have adequate capacity to 

accommodate the level of activity anticipated during construction and operation of the GMT2 Project. 

After drilling is completed (approximately Year 9), traffic would drop off considerably in support of longterm operations. During drilling and operation for Alternative C, vehicle traffic would be limited to use of 

annual ice roads (for access between GMT2 pad and CD1/Alpine Processing Facility) and the 0.9-mile 

Airstrip Access Road. Outside the ice road season, the infield access road would have no connection to 

the established road system in the project area.

Summaries of the estimated number of flights that would be required during drilling and operation are 

listed for each action alternative in Chapter 2 flight requirements tables and provided in Appendix B. 

These flights are not available for public use and not expected to result in appreciable impact to public 

airport traffic.

Comparison of Alternatives

In general, all the action alternatives would impact common transportation opportunities and constraints 

within the region, which include both air and land transportation modes. Transportation components 

under Alternatives A and B would link GMT2 to existing and authorized GMT1 infrastructure by the 

GMT1–GMT2 Access Road. The impacts would be expected to be low in intensity, temporary in duration 

(limited to the construction phase), and would likely impact an area outside the project area. The Nuiqsut 

Spur Road links Nuiqsut by gravel road to the CD5 road, proposed CD5–GMT1 Road, as well as the 

CD1/Alpine Processing Facility. Alternative A would increase local access possibilities by the 8.2-mile 

gravel road from GMT1 to GMT2 while Alternative B would increase by a 9.4-mile gravel road.
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There are several hazards commonly associated with roads in the area. Ice fog exacerbated by emissions 

can impede visibility and whiteouts are frequent in the winter. Heavy industrial traffic on the road can 

lead to increased accidents involving residents traveling on or across the road, particularly when residents 

will likely be traveling in smaller passenger vehicles or on snow machines or all-terrain vehicles. Hunters 

traveling overland by snow machine or all-terrain vehicles may not be able to see if there is traffic on the 

road before they gain speed to cross it. Without mitigation (e.g., road perimeter markers), the road may 

not be visible to overland travelers during periods of low visibility.

Under Alternative C, there would be no GMT1–GMT2 Access Road and access to the GMT2 pad would 

be by vehicle on the ice road and/or aircraft. The estimated number of flights required during construction 

and drilling are listed in Appendix B. A large increase in air traffic would occur at the CD1/Alpine 

Processing Facility airstrip and in the regional airspace between CD1/Alpine Processing Facility and 

GMT2 pad. The increased air traffic to access GMT2 facilities under Alternative C would be mostly 

small, fixed-wing aircraft. Helicopter flights would more than double, mostly to transport special studies 

personnel that would otherwise travel by road under Alternatives A and B. These include flights to 

perform work required by permits or emergency response; most are necessary during the summer season 

when birds and other wildlife are present. Related impacts of air traffic on these resources are addressed 

in Sections 4.6.7 and 4.6.8, respectively. Emergency response depending on the severity and the timing of 

the emergency could increase air traffic under Alternatives C. Overall, impacts to local transportation 

under Alternatives C are expected to be medium intensity, long-term duration, and of regional extent.

Alternative D would not authorize activity on federally managed land, and would not change local 

transportation in the NPR-A.

Mitigation

The transportation components of the GMT2 Project are designed to tie into existing transportation 

infrastructure without additional modification. The GMT1–GMT2 Access Road would allow access to 

CD1/Alpine Processing Facility, but not to an extensive network (e.g., Spine Road, Dalton Highway). The 

GMT1–GMT2 Access Road would connect with the CD5 road which connects with the Nuiqsut Spur 

Road, allowing local residents to travel further into the NPR-A for subsistence hunting and fishing (see 

Section 4.4.5, “Subsistence”).

Potential impacts to transportation are also mitigated by design, and operational features described in 

Section 4.7. Adherence to lease stipulations and best management practices of the BLM (2013a) is 

expected to reduce the impacts and total area of disturbance. These include C-2, E-1, E-5, and F-1.

Conclusions

Overall, impacts to local transportation, including hydrocarbon transportation by pipeline, are expected to 

be low to moderate in intensity with some noticeable change in air and vehicle traffic. Alternatives A and 

B would have long-term impacts to local transportation for the duration of the project that would extend 

beyond the project area. The impacts from Alternative C would be moderate and higher than Alternatives 

A and B due to the increased requirement for air transportation of personnel and equipment to GMT2 

facilities without a GMT1–GMT2 Access Road. This determination includes consideration of 

transportation of produced hydrocarbon from GMT2, which would have a beneficial impact by assuring 

continued operations of existing facilities (CD1/Alpine Processing Facility). These impacts are within the 

range of impacts analyzed by BLM (2004a, 2012).

4.4.4.3 Recreation

All action alternatives would result in minimal impacts to recreation during construction, drilling, and 

operation. These types of impacts are described by BLM (2004a, Section 4F.4.7) and generally for the 
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Northeast NPR-A (BLM 2008a, Section 4.3.16, 4.4.16, 4.5.16, and 4.6.16) and the entire NPR-A (BLM 

2012, Section 4.3.16). The following discussion summarizes the impacts.

There are no public recreational facilities in the project area (BLM 2014). Recreation impacts discussed 

here are not related to subsistence. Impacts to subsistence use is discussed in Section 4.4.5. Existing 

recreational opportunities in the project area are a function of the natural setting. Public recreational use 

in the project area is low intensity and primarily represented by non-local visitors that float the Colville 

River between Umiat and Nuiqsut. The project area offers opportunity, but limited access, for primitive 

unconfined recreation (e.g., backpacking, sightseeing, photography, hunting, and fishing).

Limited access and the remote nature of the area inherently restrict the ability of the public and local 

residents to access outdoor recreational opportunities in the project area, particularly with the vast amount 

of similar opportunity across the North Slope. Under existing conditions, most recreational access is 

currently provided by chartered aircraft landing at or near a specific destination. From the landing spot, 

land access would continue by chartered aircraft during the summer or by snow machine/dog sled during 

the winter. The Nuiqsut Spur Road extending northward from Nuiqsut provides pickup/car/off-road 

vehicle travel to the Alpine gravel road system (which can be used by the local population, but not by 

outside recreational users) for subsistence activities and to the GMT2 pad vicinity under Alternatives A 

and B. Little recreational use is expected. Except for ice roads, there is no road access between Nuiqsut 

and the Dalton Highway.

Construction

Most construction of features such as roads, pipelines, gravel pads, and airstrips, would occur during the 

winter to minimize impacts to the tundra. Very little organized recreation occurs during these harsh winter 

periods, and only limited recreation occurs in the area during the summer. However, the BLM does have 

one special recreation permittee (wildlife and nature viewing) authorized to conduct activity in the GMT2 

area. The permittee would likely not use the immediate area to avoid contact with external entities. 

During construction in any of the action alternatives, the extra activity and noise of mobilizing equipment 

to the site and the outdoor activity associated with gravel mining and construction of road, airstrip, and 

pads would make the site somewhat more conspicuous to recreational users than during drilling and 

operation. Overall, construction is expected to result in minimal change to the recreational environment. 

Impacts from the action alternatives on recreation would be expected to be temporary in duration but 

could limit recreational activity or potential in the project area, as recreation users would likely avoid the 

area.

Drilling and Operation

Similar to construction, drilling, and operation would be expected to have minimal change to the 

recreational environment, but impacts could be expected to be long-term in duration and extend through 

the life of the project. Although minimal, there could be impacts from the action alternatives as recreation 

users would likely avoid the area.

Comparison of Alternatives

Under all of the alternatives, residents of Nuiqsut would continue to have access to existing Alpine Field 

facilities including limited access on winter ice roads; little of this use would be expected to be 

recreational.

The BLM has determined that adverse impacts to primitive recreational uses associated with a community 

generally are indistinguishable to users that are at least 5 miles from a community, and by inference, at 

least 5 miles from a permanent oil and gas facility (BLM 2012, Section 4.8.7.19, pages 122, 279). 
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Impacts to primitive, unconfined recreation would be expected to have little or no evident change in the 

recreational environment, recreational opportunities, or quality of the experience beyond five miles of the 

project area. Within 5 miles of the project area, impacts to recreational users would be long-term in 

duration, but the impacts would be localized and likely low due to limited use of the area.

No alternative would provide year-around surface transportation to the Dalton Highway or additional 

public airport facilities.

Alternative D would not authorize activity on federally managed land, and would not change recreation in 

the NPR-A.

Mitigation

In the reasonably foreseeable future, development of oil and gas facilities is unlikely to change the overall 

number of visitors that would participate in outdoor recreation in the project area.

Best management practices and design features that would reduce the visual impact and noise could also 

reduce the area of impact on recreation, including: A-1, A-5, C-2, C-3, C-4, E-5, E-6, E-7, E-17, F-1, H-3, 

I-1, and M-2. Impacts would be expected to be minor and within the range described in BLM (2004a, 

Section 4F.4.7).

Conclusions

Impacts to recreation would be expected to be negligible to minimal as a result of all the alternatives. 

Recreation use in the project area could be negatively impacted under all action alternatives due to the 

presence of permanent facilities and associated noise. However, these impacts would be localized. The 

duration of impacts would be temporary to long-term depending on the activity taking place. A change in 

the environment, opportunities, or the quality of the experience under the proposed project could be 

recognizable to a local subsistence user, but not necessarily to an outside recreational visitor.

4.4.4.4 Wild and Scenic Rivers

No designated wild and scenic rivers are found in the project area. The Colville River has been 

determined to be not suitable for inclusion in the national system; primarily because federal ownership 

stops at mean high water of the west bank of the Colville River and there is a general lack of support by 

the State and Native land owners of the river bed and the east river bank (BLM 2014).

No alternative would be expected to have an impact on existing or future potential of the Colville River, 

Tiŋmiaqsiġvik (Ublutuoch River), or Fish Creek to be added to the National Wild and Scenic Rivers 

System.

4.4.4.5 Wilderness

The project area 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. Therefore, there 

would not be any effects to designated wilderness areas, or proposed wilderness. Development of 

infrastructure such as the work pad, roads and a pipeline would introduce human-made structures to the 

area, thus eliminating the site’s wilderness characteristic of naturalness. During the Integrated Activity 

Plan revision, the BLM (2012, 2013d) did not recommend existing ConocoPhillips oil and gas leases or 

other oil and gas ownerships be cancelled so the federally managed lands surrounding GMT2 would still 

possess wilderness characteristics. Adherence to lease stipulations and best management practices (BLM 

2013a) are expected to reduce the impacts to wilderness characteristics in areas adjacent to the developed 

areas; these include: A-1, A-4, A-5, A-6, C-2, C-3, E-5, F-1, I-1, and M-2.
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4.4.4.6 Visual resources

This section discusses potential impacts to visual resources that could result from the proposed project. 

Based on BLM (2013a), approximately 8.4 million acres of federally managed land in the NPR-A 

including the GMT Unit are classified as Visual Resource Management (VRM) Class IV (see BLM 

2013a, Map 3). VRM Class IV is the least restrictive visual classification, allowing high relative change 

to the existing visual character of the area. Developments in VRM Class IV may attract attention and 

dominate the view, but are still mitigated. The proposed project facilities are located on VRM Class IV 

land, or private land. A small zone buffering the Colville River is classified as VRM Class III. VRM Class 

III is more restrictive than VRM Class IV, with the objective of retaining the existing character of the 

landscape while allowing moderate changes. VRM considerations do not apply to land owned by Native 

Corporations within NPR-A. Until transferred from BLM ownership, pending valid selections by Native 

Corporations continue to be managed by the BLM (i.e., VRM considerations will apply).

Oil and gas activities, including the proposed GMT2 alternatives, would change the existing undeveloped 

visual character of federally managed land in the project area, but still be consistent with VRM Class IV. 

The BLM (2004b) approved the authorization of the proposed GMT2 Project, and BLM (2013a) assumes 

that GMT Unit, including GMT2, would be developed under the lease stipulations, and best management 

practices described in Section 4.7. There has been little change in the existing or prospective use of the 

project area for oil and gas or other uses that could impact visual resources of federally managed land in 

the project area that were not considered in BLM (2004a, 2004b) and the subsequent authorizations for 

construction and operation of production facilities in the Alpine Field that were contemplated in 2004. 

The BLM (2012; 2013a, 2014) considered the visual resources associated with the development facilities 

constructed since 2004, and assumed the GMT Unit would be developed by both the GMT1 Project and 

the GMT2 Project. The proposed GMT2 Project has only been slightly modified from the project 

authorized for permitting in BLM (2004b).

Construction

Activities such as gravel placement for GMT2 pad construction and GMT1–GMT2 Access Road 

construction would have negligeable impacts to visual resources in VRM Class IV. Since 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, any impact to visual resources would be temporary. 

Drilling and Operation

Under the action alternatives, the drill rig would be the most noticeable and direct impact during the

drilling phase. The drill rig would create a noticeable disturbance to visual resources when viewed from a 

distance of 5 miles or less, resulting in an adverse impact for the duration of time the drill rig is moved 

and operated. During the summer when there is adequate daylight, the drill rig would introduce vertical 

lines and dominate the landscape. Pad facilities would introduce a strong contrast with the natural 

landscape. Most buildings associated with the action alternatives are less than three stories high. 

However, communication towers can be as much as 200-feet high, in contrast to the predominant 

horizontal line of the surrounding landform. These facilities would also contrast in color with natural 

vegetation. Pipelines would repeat the horizontal line of the landform, but would contrast with the colors 

in the surrounding landscape. Emergency response containers strategically placed along water channels 

would also contrast with the colors of the surrounding landscape.

Lighting on tall structures could have a negative impact unless design criteria are included, such as 

directing artificial light inward and downward, rather than upward and outward. BMP E-10 requires 

artificial exterior lighting to be directed inward and downward from August 1 through October 31.
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Nuiqsut, the closest community, is approximately 16.0 miles from the GMT2 drill pad, and may have 

little, if any, visibility of project development. The greatest impact would be on local residents coming to 

or near the area for subsistence activity, which is addressed in Section 4.4.5.

Comparison of Alternatives

Alternatives A and B would result in noticeable disturbances to visual resources across much of the 

project area and up to 2.5 miles from project developments with the impacts being long-term in duration. 

The impacts would be mitigated by BLM best management practices (2013a). Alternative C would not 

create the visual impact associated with the GMT1–GMT2 Access Road, but all action alternatives would 

include an elevated pipeline. Although there would be no visual disturbance from a road under Alternative 

C would still impact visual resources with the 5,000-foot gravel airstrip, instrumentation for all-weather 

aircraft use, the occupied structure pad with year-round workforce and camp, the 0.9-mile Airstrip Access 

Road, and increased air traffic to the site. However, the visual impact of the air access facilities, Airstrip 

Access Road, and occupied structure pad would be more focused in the GMT2 pad vicinity, and not 

across the tundra. Due to the remote location of the project, impacts to visual resources would be 

expected to remain compliant with the objectives of VRM Class IV.

Alternative D would not authorize activity on federally managed land, and would not affect the visual 

resources in the NPR-A.

Mitigation

BLM (2013) BMP E-17 address visual resources and requires “At the time of application for construction 

of permanent facilities, the lessee/permittee shall, after consultation with the authorized officer, submit a 

plan to best minimize visual impacts, consistent with the Visual Resource Management Class for the lands 

on which facilities would be located. A photo simulation of the proposed facilities may be a necessary 

element of the plan.”

Adherence to lease stipulations and best management practices of BLM (2013a) would reduce the impacts 

and total area of disturbance; these include: A-1, A-3, A-4, A-5, A-6, C-2, C-3, E-5, E-17, F-1, I-1, and M2. 

Conclusions

Overall, construction and operation of all the action alternatives would result in moderate impacts to 

visual resources. Pad and road construction activities would have a low impact, as these activities would 

occur in the winter when snow and darkness make viewing more difficult. Summer introduces more 

daylight and increases the opportunities for viewing operational activities. Facilities and structures (e.g., 

GMT1–GMT2 Access Road, air access facilities) would introduce a moderate contrast with the natural 

landscape when viewed from the foreground-middle-ground zone. In Alternatives A and B the GMT1–

GMT2 Access Road structure would be visible across the tundra. Whereas in Alternatives C, there would 

be no GMT1–GMT2 Access Road across the tundra, but the air access facilities, Airstrip Access Road, 

and occupied structure pad unique to these alternatives would create contrast in the vicinity of GMT2 pad.

For all action alternatives, there would be noticeable disturbances to visual resources that would likely be 

seen 2.5 miles from project developments. The impacts would range from temporary to long-term in 

duration. For all action alternatives, GMT2 Project would be within the visual objectives of VRM Class 

IV, the current rating.

4.4.5 Subsistence

Impacts to subsistence areas and uses in the Nuiqsut area are discussed and analyzed in BLM (2014 

Section 4.3.5, 4.4.5, and 4.6.10.8), BLM (2004a, 2008a) and BLM (2012, Section 4.3.13, 4.4.13, 4.5.13, 
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4.6.13, and 4.7.13). Harvest surveys and subsistence use area mapping provide quantitative data, 

ethnographic and sociocultural studies provide qualitative data, and the residents of Nuiqsut themselves 

provide original source data. 

New information since BLM (2014) includes Stephen R. Braund and Associates’ (SRB&A) caribou use 

area and harvest data from the Nuiqsut Caribou Subsistence Monitoring Project Years 5, 6, 7, 8, and 9

(SRB&A 2014, 2015, 2016, 2017a, and 2018). These reports include geographically specific data and 

document the types of resources, percent of harvest (for caribou), percent of harvesters, timing of 

activities, and methods of transportation within the GMT2 Project study area. The Alaska Department of 

Fish and Game Division of Subsistence conducted a comprehensive harvest survey in Nuiqsut in 2015 

(Brown et al. 2016) and data from that survey is incorporated into the description of the affected 

environment in Chapter 3 (§ 3.4.6 Subsistence) and in the associated Appendix F, “Overview of Nuiqsut 

Subsistence Uses.” 

Subsistence information on the area includes original subsistence use are mapping (Pedersen 1979), 

surveys by the North Slope Borough Department of Wildlife Management (George and Nageak 1986; 

Brower and Opie 1996; Brower and Hepa 1998), by Impact Assessment Inc. (1990), and by the Alaska 

Department of Fish and Game Division of Subsistence (Pederson 1995; Pedersen et al. 2000; Pedersen 

and Taalak 2001; Braem et al. 2011). This information is the basis for the detailed description of the 

GMT2 Project’s affected environment for subsistence in this document (Chapter 3, § 3.4.5 “Subsistence”) 

and the accompanying “Overview of Nuiqsut Subsistence Uses” (Appendix F).

Original sources considered in analyzing the potential relevance of impacts that could be a result of 

GMT2 Project include input provided in recent decades by Nuiqsut residents on federally managed land 

use plans and proposed oil and gas activities. These sources include testimony and recommendations 

made at BLM scoping and draft EIS meetings, NPR-A Subsistence Advisory Panel meetings 1998-2016, 

NPR-A Working Group meetings 2014-2016, and at Northeast NPR-A Regional Mitigation Strategy 

workshops, 2015–2016. A description of the extensive additional ethnographic and other research 

focusing on Nuiqsut is included in BLM (2014, Section 4.4.5, “Subsistence”).

The primary impacts to subsistence identified in EISs, ethnographic reports, and testimony of residents in 

recent decades are reduced access to traditional subsistence use areas, hunter avoidance of industrial 

areas, disturbance from aircraft and traffic, and reduced availability of subsistence resources 

Impacts on subsistence could result in increased risks and investments in time, money, fuel, and 

equipment (BLM 2014, Section 4.4.5, “Subsistence”). Similar to the effects of previous development in 

the Nuiqsut subsistence use area, impacts could last for multiple generations and affect key subsistence 

use areas and overall Nuiqsut subsistence activities (BLM 2014). The types of impacts are expected to be 

similar to those identified in BLM (2004, 2012) and, more specifically, those identified in BLM (2014). 

These impacts do not affect all subsistence activities equally; the impacts change over time, and 

individuals themselves, perhaps younger generations in particular, experience impacts differently.

The primary unavoidable adverse impact to subsistence that is directly attributable to oil development (as 

opposed to substantial changes that result from globalization, modern transportation methods, economic 

issues, climate change, etc.) is the loss of traditionally used subsistence areas. This is regularly confirmed

through monitoring, literature reviews, interviews, government-to-government consultation with the 

Native Village of Nuiqsut tribal council, and computer-assisted analysis of testimony and comments made 

by North Slope Inupiaq at oil development meetings (see § 4.4.2). 
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4.4.5.1 Methodology

This supplemental EIS evaluates direct impacts to subsistence activities (e.g., loss of traditionally used 

land and restrictions to hunter access in overland areas where project components are proposed). The 

SEIS also analyzes indirect impacts to the larger Nuiqsut subsistence use area (e.g., hunter avoidance of 

infrastructure, the potential for localized deflection of caribou, wolves, and wolverines, disturbance from 

aircraft and ground traffic, and community participation).

GMT2 Area of Potential Effects for Subsistence

Direct impacts to subsistence were evaluated and quantified using a 2.5-mile buffer around all project 

infrastructure and activity. The 2.5-mile buffer was established based on displacement distances evaluated 

in studies of caribou behavioral responses to disturbance (Dau and Cameron 1986; Cameron et al. 1992, 

1995; Wolfe 2000; Noel et al. 2004; Haskell et al. 2006; Haskell and Ballard 2008; Wilson, et al. 2012). 

Another consideration in establishing the buffer distance was restrictions on hunter access from safety 

considerations of hunting near infrastructure. Community interviews indicate some local hunters do not 

feel it is safe to discharge a large caliber rifle within 2 miles of infrastructure, and the 2.5-mile buffer is 

large enough to account for direct impacts resulting from safety considerations of hunting near 

infrastructure (HDR 2015). The area of potential effects for the construction phase includes all project 

components, including seasonal infrastructure needed to support construction, i.e., ice roads (see Map 3.3-

1). Direct impacts from the drilling and operation phase were evaluated using an area of potential effect 

that excludes seasonal infrastructure needed for construction (see Map 4.4-1). Potential subsistence 

impacts are identified based upon the proposed activities associated with (1) construction (2 to 3 years), 

and (2) drilling and operation (6 years of drilling with concurrent operation, total 30 years of operation). 

Potential impacts to the community of Nuiqsut are the focus of the impact analysis.

Indirect effects to subsistence resulting from the GMT2 Project could affect land use patterns outside the 

area of potential effects, thus, indirect impacts were evaluated using the totality of the contemporary

Nuiqsut subsistence use areas for all resources. 

Evaluating Impacts to Subsistence

Impacts to subsistence are assessed by analyzing Nuiqsut’s subsistence uses that have been documented in 

the GMT2 Project area. Subsistence baseline indicators that are useful in characterizing subsistence 

impacts include:

Subsistence use areas 

Travel methods

Travel routes 

Timing of harvest activity

Duration and frequency of trips 

Observed change in resources

Harvest diversity 

Harvest amount 

Harvest participation

Harvest success 

Harvest sharing 

Harvest effort

Harvest data have generally been the most reliable and available source of subsistence data in Alaska and 

provide high-level information regarding whether harvests are increasing or decreasing. In the absence of

other data, they are a good measure of the health of the subsistence lifestyle (SRB&A, 2017b). However, 

harvest data are not the only measure of the health of the subsistence lifestyle, nor are they always 

reflective of changes in the subsistence lifestyle. Subsistence is important both for its material (e.g., 

economic, nutritional) and cultural (e.g., cultural, social) value. Harvest data provide information 

primarily about the material health of the subsistence lifestyle; however, a multitude of other variables 

provide information about the material and cultural health of the subsistence lifestyle. These include data 

on subsistence use areas, harvest timing, community participation, and harvest effort (number of trips, 
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duration of trips). For the subsistence lifestyle to be healthy, there must be continued harvests (material 

value) at continued levels of traditional land use, identification with traditional land use areas, community 

and harvester participation, processing, consumption, and sharing (cultural values). These indicators are 

used in informing subsistence impacts under three primary categories: (1) subsistence use areas and user 

access, (2) resource availability, and (3) community participation (SRB&A, 2017b). 

Data for these indicators are drawn from information that has been presented in the affected environment 

“Subsistence” section (Section 3.4.6) and in Appendix F.The GMT2 Project does not have any marinebased components. Thus, the emphasis of this analysis is on mammals, fish, and birds occurring within 

the terrestrial environment. This review includes subsistence uses of large land mammals (caribou,

moose, wolves, and wolverines), fish, and migratory waterfowl. Potential impacts to the biological 

environment for fish, birds, and mammals are reviewed in Section 4.3, “Biological Resources.”

In addition to potential impacts associated with new permanent infrastructure, subsistence resources may 

be disturbed by vehicle traffic (on gravel roads and ice roads), aircraft traffic (fixed-wing and helicopter), 

construction activities, noise, and odors. GMT2’s direct impacts would result from the proposed drill pad, 

road, and pipelines located in an area referred to generally as “west of Nuiqsut,” “towards Fish Creek,” or 

simply “on the west side” by local hunters. In order to characterize the subsistence uses of areas with new 

infrastructure, the BLM removed river-based hunting data (“boat use areas”) from the analysis of 

subsistence uses within the area of potential effects because there would be no new infrastructure 

associated with GMT2 occurring in use areas accessed by boat. Except for a new pipeline between CD1 

and CD4 that is parallel to an existing pipeline, the only areas of new infrastructure proposed for GMT2 

occur southwest of CD5, in an area that is not directly accessible by boat. The project study area includes 

a portion of the Colville River that is commonly accessed by boat and used for subsistence, but will not 

be overlapped by new permanent infrastructure associated with GMT2. While boating activities may be 

affected indirectly by GMT2-related traffic and activities on existing infrastructure and through changes 

in resource availability (see the discussion of “Resource Availability” below), a majority of potential 

direct impacts (occurring at the same time and place) on subsistence use areas will be limited to inland 

areas that are not accessed. 

Alternatives A and B are analyzed together because available information indicates that any differences in 

impacts to subsistence under these development scenarios would be insignificant. An exception is the 

greater amount of gravel required for Alternative B. Alternative B, described in Section 2.6, “Alternative 

B,” was developed to have the GMT2 Access Road follow the watershed boundary between Fish Creek 

and the Tinmiaqsiugvik River drainage basins. This could potentially move the road to slightly higher 

ground and prevent contamination of two watersheds in the event of a spill. The difference in the case of 

GMT2 is minimal and Alternatives A and B for the GMT2 Access Road and pipeline do not involve major 

differences: neither route includes bridges or is located within the Fish Creek setback. Alternative C is 

analyzed separately from Alternatives A and B.

Methodology of SRB&A and ADF&G Subsistence Studies

The analysis in this section relies heavily on studies conducted by Stephen R. Braund and Associates 

(SRB&A) and the Alaska Department of Fish and Game (ADF&G). The methodologies used for these 

studies are described below. 

Stephen R. Braund and Associates Subsistence Mapping and Monitoring Reports

The Nuiqsut Caribou Subsistence Monitoring Project is an ongoing, multi-year program meant to 

measure impacts and changes over time in Nuiqsut residents’ caribou hunting activities that may result 

from ConocoPhillips Alpine satellite development sites and associated activities. The methodology used 

for the annual Nuiqsut Caribou Subsistence Monitoring Project (see outline below) includes ongoing 
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community engagement via the Nuiqsut Caribou Panel and the Kuukpik Subsistence Oversight Panel 

(KSOP). Since the monitoring program was established in 2009, the study team has incorporated 

additional components to the study design to provide additional context for measuring impacts. The study 

has two primary components: 1) active harvester interviews, which are conducted with a sample of active 

caribou harvesters each year and that document caribou hunting areas, harvest locations, hunting patterns, 

health of harvested caribou, and hunting impacts; and, 2) household harvest surveys, which are conducted 

with an attempted census of households in the community and collect data on harvest amounts, 

participation, sharing, and hunting impacts. For the active harvester interviews, there is an interview and 

data recording process whereby hunting areas, harvest locations, and impact locations are mapped and 

digitized and a multi-layered reviews process.

• Respondent Selection: Over the 8 study years, SRB&A has developed a list of 111 active caribou 

harvesters. The study team initially (in Year 1) obtained a list of active harvesters from KSOP and 

then developed the list by asking respondents in Years 1 and 2 to recommend (nominate) other 

active harvesters in the community. The study team kept track of the number of nominations

received for each individual and made a special effort to interview individuals with a high 

number of nominations. Subsequent study years have focused on interviewing individuals who 

have participated in multiple previous years (to maintain consistency in the sample) while also 

interviewing new individuals who have been recommended as particularly active (to ensure 

adequate representation of active harvesters). The study team also has reviewed the list of active 

harvesters with the Nuiqsut Caribou Panel formed for the study in order to ensure that the list of 

active harvesters is accurate and thorough. Eligibility for the interview is assessed annually for 

each harvester. Harvesters are eligible if they went caribou hunting during the previous year, lived 

in Nuiqsut the majority of the year, and are healthy enough to participate fully in the interview 

process.

• Interview Process: 

1. Geographic information is recorded on an acetate sheet positioned over a 1:250,000 USGS 

map. Registration marks are put on clear acetate corresponding to locations on USGS base 

maps and later registered on identical USGS base maps for digitizing. Geographic data 

collected includes hunting areas, harvest locations and impact locations. 

2. Each mapped feature is recorded as either a polygon(hunting or impact area), a line (hunting 

impact location), or a point (impact location or harvest location). 

3. Numbers are assigned to each feature on the map and in the notes about the feature to link 

them; the numbers are later used to create distinct feature codes in the GIS and Access 

database. 

4. Interviewers record data next to the relevant questions on the field protocol used to guide the 

interview, this information is later referenced while entering data to ensure the accuracy of 

the notes.

• Data Review Process:

- Draft Report is submitted to ConocoPhillips (e.g., Jan. 2015)

- Comments are received from ConocoPhillips (e.g., March 2015)

- Revised Draft Report is submitted to ConocoPhillips (e.g., April 2015)

- SRB&A team presents results to NSB (e.g., May 2015)

- SRB&A team presents draft findings to Nuiqsut Caribou Panel (e.g., May 9 2015) 

- Team revises and releases Finalized Report
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Alaska Department of Fish and Game Subsistence Reports

ADF&G Division of Subsistence utilizes quantitative and qualitative methods of social science research 

to document the harvest and use of subsistence resources. Principles of ethical research guide the work to 

emphasize community approval of research design, informed consent, anonymity of study participants, 

community review of draft study findings, and the return of findings to study communities. Local 

Research Assistants are hired in each community to help administer the surveys. Division of Subsistence 

research generally relies on a standard survey instrument to produce data that are comparable between 

years and between communities.

The division conducts household surveys in communities to collect harvest information for all finfish, 

shellfish, wildlife, and wild plants (Fall, 1990). Following community approval, voluntary, confidential 

surveys are administered, usually in people’s homes. Knowledgeable individuals report their household’s 

harvests for the previous year. A census survey is attempted in smaller communities (up to 50 

households), and random samples are selected in larger communities. Harvests for home use include all 

wild resources taken under subsistence, personal use, general, and sport regulations, including harvests 

that are shared, bartered, or exchanged in customary trade. They include fish removed from commercial 

harvests for personal use, but not fish that are sold.

4.4.5.2 Summary of Nuiqsut Subsistence Uses 

Harvest data for all resources is available for 7 non-consecutive years from 1985-2014 (see Appendix F). 

While there are fluctuations, in general the data show a sustained yield over time for overall edible 

pounds of subsistence foods as a whole. The average subsistence harvest in edible pounds for all 

resources was approximately 200,000 pounds, with a high in 2014 (371,992 pounds) and a low in 1994-

1995 (83,228 pounds). Another key indicator of resource availability is harvest pounds per capita. Data on 

per capita harvest pounds for all resources is available for 3 non-consecutive years; 1985 (399 pounds per 

person), 1993 (742 pounds per person) and 2014 (896 pounds per person).

Harvest data for caribou is available for 18 non-consecutive years from 1985-2016 (see Appendix F). In 

general, they show a sustained yield over time in number of animals harvested. The average yearly 

harvest was 495 caribou, with a low of 258 caribou in 1994-1995, and a high of 774 caribou in 2014. Per 

capita pounds harvested for caribou is available for 14 non-consecutive years between 1985 and 2016. In 

general, per capita pounds have remained relatively stable. The average harvest was 157 pounds of 

caribou per person, with a low of 102 pounds per person in 2005-2006, and a high of 253 pounds per 

person in 2014 (see Appendix F). 

The GMT2 Project study area overlaps with many of Nuiqsut’s most concentrated subsistence use areas 

(see Figure 18). A comprehensive discussion of documented harvest locations for Nuiqsut (1979–2013) is 

provided in the Supplemental EIS for GMT1 (BLM 2014, Section 3.4.), and updated data on harvest areas 

and on the number of use areas overlapped by the GMT2 Project area are described in detail in Section 

3.4.6.3, “Overview of Subsistence Use Areas” of this SEIS. Complete data on Nuiqsut subsistence 

harvests and annual cycle of subsistence activities, including maps depicting use areas for each resource, 

are included in Appendix F.

The importance of particular subsistence use areas that could be impacted by GMT2 can be determined 

through archaeological and ethnohistorical research and subsistence mapping and harvest studies. The 

1979 Nuiqsut Paisanich-Nuiqsut Heritage: A Cultural Plan (Brown 1979) is seen as the foundation for 

Nuiqsut area management and was created by the community to help inform federal land management 

decisions. The Paisanich was re-affirmed by the Nuiqsut tribal government in 2005, and the Nuiqsut 

trilateral entities (tribe, corporation, and city) agreed on preparation of the draft‘Nuiqsut Paisanich: A 
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2017 Update’(SRB&A2017f) ““to reaffirm the community of Nuiqsut’s cultural ties to their land and 

document both continuity and change” since 1979. The original 1979. plan includes a cultural landscape 

map depicting Nuiqsut’s intensive subsistence use area as the land bounded on the west by the eastern 

side of Teshekpuk Lake, south to Umiat and the lower section of the Anaktuvuk River, east to Prudhoe 

Bay, and north to include the Beaufort Sea (Brown 1979). The draft 2017 Update (page 11) states 

“Nuiqsut people continue to identify with the places of their ancestors, and in these places they hunt, fish, 

camp, collect berries, and process the wild foods they have harvested using traditional techniques passed 

on to them over generations. However, it also documents that subsistence use areas have shown a marked 

shift to the west—away from the Prudhoe Bay complex—over time (SRB&A 2017f, page 61).

The NPR-A 105 (c) report (based on research conducted in 1977) notes that varying expenses for different 

subsistence resources create a gradient of access. Whaling is the most expensive and spring hunting for 

wolf and wolverine is the second most costly. Hunting for caribou is the “bread-and-butter” component of 

the Nuiqsut subsistence complex (Hoffman et al. 1988) since it is possible to hunt caribou with a 

relatively small cash outlay. Since the founding of Nuiqsut, there have been some caribou in Fish Creek 

area each year, throughout the year. Residents of Nuiqsut continue to stress the importance of Fish Creek 

and undeveloped areas to the west of town in terms of harvesting resources and food security (BLM 

2016). This area is only about 12 miles (19 kilometers) from the village and the cost of traveling there by 

snowmachine is small (Hoffman et al. 1988, pages 18–19). 

Recent caribou use areas (2008 –2016) show a changing pattern of use within the GMT2 Project area. The 

areas of highest overlapping use are still concentrated along the Colville River channels and directly west 

of the community. More moderate use is to the northwest, and low overlapping use areas are east of the 

Niqliq channel (SRB&A 2010b, 2011, 2012, 2013b, 2014, 2015, 2016, 2017a, 2018). Although there are 

yearly exceptions, over the 8 study years (2008–2015), the Nuiqsut Caribou Subsistence Monitoring 

Project has documented a general increase in the percentage of harvests in the area west of Nuiqsut (an 

area defined by the monitoring project as extending from the Nigliq Channel in the east to the confluences 

of Fish Creek and Judy Creek in the west, and the Ocean Point area to the south) (SRB&A 2018a). In 

recent years, this may partly be due to the growing use of four-wheelers that can access overland areas 

during summer and fall. The monitoring report has also documented a general decrease in the percentage 

of harvests along the Nigliq Channel. 

Table 133, Table 134, and Table 135 provide baseline information about trip length, trip frequency, and 

changes in harvest activity as reported in Years 1-8 of the Caribou Subsistence Monitoring Report 

(SRB&A, 2017a).

Table 133. Caribou Hunting Trip Duration, Study Years 1-8 a

Trip Duration

Year 1

(2008 

data)

Year 2

(2009 

data)

Year 3

(2010 

data)

Year 4

(2011 

data)

Year 5

(2012 

data)

Year 6

(2013 

data)

Year 7

(2014 

data)

Year 8

(2015 

data)

More than 2 weeks 0% 1% 0% 0% <1% 2% 1% 0%

1-2 weeks 1% 1% 1% 1% 1% 1% 0% 0%

2-6 Nights 7% 15% 7% 8% 9% 10% 6% 6%

1 Night 5% 2% 2% 1% 2% 4% 3% 1%

Same Day 87% 81% 90% 90% 88% 84% 91% 93%

Number of Use Areas 135 176 212 193 209 196 190 153

a Percentages in all cells refer to the percentage of total caribou use areas accessed by different trip lengths.

Source: SRB&A, 2017a. 
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Table 134. Caribou Hunting Number of Trips, Study Years 1-8 a

Number of Trips Year 1 Year 2 Year 3 Year 4 Year 5 Year 6 Year 7 Year 8

20+ 0% 0% 9% 7% 4% 7% 7% 8%

6-20 Trips 30% 28% 21% 28% 16% 19% 21% 20%

4-5 Trips 23% 21% 19% 15% 15% 13% 17% 15%

2-3 Trips 27% 26% 27% 29% 34% 28% 26% 28%

1 Trip 20% 24% 24% 21% 32% 33% 28% 29%

Number of Use Areas 121 174 212 193 210 196 204 153

a Percentages in all cells refer to the number of times use areas were visited. For example, in Year 1, no use areas were visited 

more than 20 times, while 30% of use areas were visited between 6 and 20 times. 

Source: SRB&A, 2017a.

Table 135. Changes in Harvest Activities, Years 1-8 a

Type of Change Year 1 Year 2 Year 3 Year 4 Year 5 Year 6 Year 7 Year 8

Changed Hunting Area b 31% 28% 39% 34% 36% 40% 28% 38%

Frequency of Hunting Trips 

Changed c 50% 77% 65% 60% 63% 67% 70% 67%

Duration of Trips Changed d 39% 32% 21% 21% 23% 26% 39% 28%

Time of Year Changed e 19% 15% 12% 21% 21% 18% 11% 20%

Harvest Amount Changed f 75% 85% 68% 72% 54% 63% 82% 57%

a Percentages in all cells refer to the percentage of active harvesters reporting each type of change. Changes refer to both increases 

and decreases. Detailed information on changes in harvest activities was not included in the Year 8 Report; therefore, the following 

footnotes summarize Year 7 results. 

b Over all 7 study years, Personal Factors (49%) were the most commonly cited reasons for a change in use area, followed by

Resource Distribution or Migration factors (27%), Environmental Factors (11%), and Development Activities (10%).

c In Year 7, 40% of respondents reported taking fewer trips, and 30% reported taking more trips. Over the seven study years, 

personal factors have been the most frequently cited causes of an increase in trip frequency (55%), followed by resource 

distribution/migration factors (30%) and development activities (8%).

d In Year 7, 19% of respondents reported taking longer trips compared to the previous year, and 19% reported taking shorter trips. 

Over the seven study years, resource distribution or migration was the primary factor for taking longer trips (61%). Personal factors 

(lack of time/equipment/money) was the most commonly cited reason for taking shorter trips (58%).

e Over the seven study years, Personal Factors were the most commonly cited reasons for a change in harvest

seasons (70%), followed by Resource Distribution or Migration factors (19%). 

f In Year 7, 53% of respondents reported harvesting less than the previous year, 30% reported harvesting more, and 21% harvested 

about the same amount of caribou. Over all seven study years, resource distribution or migration factors have been the most 

frequently cited types of causes for harvesting less caribou (36%), followed closely by causes related to personal factors (35%). 

Source: SRB&A, 2017a, SRB&A 2016.
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Figure 41. Nuiqsut contemporary subsistence use areas, all resources, and GMT2 Construction Project Study Area

Note: GMT2 Project area (solid black line) overlain on Nuiqsut subsistence use areas for all resources documented by Pederson from 1973 – 1986 (dashed lines), by the BLM in 2004 

(purple line), and by Alaska Department of Fish and Game in 2014 (yellow line). The graded red-yellow shows the highest concentration of overlapping use, documented by Stephen 

R. Braund and Associates (2010a).
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4.4.5.3 Impacts Common to All Action Alternatives

Impacts that are not analyzed separately for the alternatives include oil spills, rehabilitation of 

infrastructure, and community participation.

Spills

As discussed in BLM (2012, Section 4.3.13.2), impacts to subsistence species that could occur as a result 

of an oil spill would depend on the size and location of the spill. A history of spills and potential impacts 

are discussed in Section 4.5 of this supplemental EIS. 

Spills contained on a road or pad would likely have little impact to subsistence species because state and 

federal regulations require spill prevention measures, reporting, and cleanup. Small spills on the tundra 

could affect a small number of terrestrial mammals or birds in the immediate vicinity of the spill if they 

were unable to avoid the oil, but population level impacts are not expected. Spills to water resources or 

that reach water resources, such as fish-bearing streams, could spread and thus have a wider potential 

impact area. In the case of a large spill, areas that could be impacted include nearshore or marine waters. 

Spills of this nature could have regional impacts, which could vary in duration based on migration of the 

spill and feasibility of cleanup. 

Subsistence users would be unlikely to harvest subsistence resources near a spill or an area perceived to 

have been impacted, which could result in additional travel time or energy expenditures for harvesters. 

Decades after the event, Inupiaq elders who lived in Utqiagvik in 1944 remembered that a spill in Elson 

Lagoon (20,000 gallons of heavy fuel oil) suffocated seals and birds and deterred the migration of whales 

from the area for 4 years. This led to suffering for local families who were accustomed to catching small 

whales in the area for their winter food supply (Perkins 2014). 

The potential for spills is present under all alternatives. The risk of a large spill in water is low, and the 

impacts to subsistence would be major.

Rehabilitation of Infrastructure

If the BLM requires the GMT1–GMT2 gravel road (under Alternatives A and B) to be removed upon 

project abandonment, benefits associated with road-based travel on it by Nuiqsut residents would cease. 

Removal of the road would also remove hindrances to tundra travel via snowmachine or four-wheeler. 

Road removal may be an environmental benefit to the extent that rehabilitation is successful in restoring 

natural conditions, but data are inconclusive on whether that is achievable. The best methods to 

rehabilitate infrastructure in future decades cannot be known at the time development is planned, and the 

NPR-A Working Group (2014) asserts that decisions about whether and how to rehabilitate infrastructure 

should only be made through consultation with local communities.

Community Participation 

Impacts on subsistence from GMT2 could result in reduced opportunities to participate in hunting, 

fishing, cooking/processing, and sharing of subsistence resources, which are the basis of Inupiaq culture. 

The sharing of subsistence foods is essential to the maintenance of family ties, kinship networks and 

community well-being. Over 90 percent of Nuiqsut households both gave and received subsistence 

resources during all available study years (see Section 3.4.6.3). Disruption of subsistence harvest patterns 

could alter these cultural values and affect community social structure. For the system of sharing to 

operate properly, some households must consistently produce a surplus of subsistence goods. For this 

reason, the supply of subsistence foods in the sharing network is more sensitive to harvest disruptions 

than the actual harvest and consumption of these foods by the primary producer. Thus, when disturbance 

to the subsistence harvest occurs, it could disrupt the community culture.
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Some hunters are able to afford and are willing to respond to impacts by traveling farther or taking more 

trips. Some hunters are less likely to bring younger family members along if they anticipate longer and/or 

riskier trips. Other harvesters may not be able to afford or may not be willing to take more or more distant 

hunting trips. 

Direct and indirect impacts to subsistence are associated with indirect impacts to the community and 

cultural traditions. When subsistence users’ opportunities to engage in traditional activities are limited, 

transmittal of knowledge about those activities is reduced. If residents decrease use of the project area, the 

opportunity to transmit traditional knowledge about the area would diminish and could eventually be lost 

to younger generations. The high level of concern that Nuiqsut residents place on future generations’ 

ability maintain traditional subsistence is described in Section 4.4.2, “Sociocultural Systems.” Individuals 

and families’ loss of intimate familiarity with an area could constitute a permanent reduction in Nuiqsut’s 

subsistence use area, and residents have reported that oil development activities have led to a decline of 

hunting in areas east of the community (SRB&A 2010a p. 222). 

If harvests or the number of active participants in harvesting declines, younger generations would have 

fewer opportunities to learn the skills necessary to hunt, harvest, and process subsistence resources. Fewer 

opportunities to participate in the sharing and consumption of traditional Inupiaq food would affect the 

social cohesion of the community. Any changes to residents’ ability to participate in subsistence 

activities, to harvest resources in traditional places at the appropriate times, and to eat traditional Inupiaq 

foods could have long-term or permanent effects on culture by diminishing social ties within the

community that are strengthened through harvesting, processing, and sharing (SRB&A 2010b).

4.4.5.4 Construction 

Alternatives A and B: Construction Phase

This section analyzes potential impacts to subsistence activities for the GMT2 action alternatives during 

the construction phase. Land overlain by the direct footprint of new permanent infrastructure, by 

temporary construction infrastructure (ice roads and pads), and land within the industry-established drill 

site safety area would be removed from the subsistence use area during the 2-3 year GMT2 construction 

phase.

Ice roads would be used to support GMT2 construction activities during 3 winter seasons to access the 

gravel source and construction areas (e.g., road, drill pad, and pipelines) (see Map 2.5-3). The GMT2 

construction ice roads are expected to be open for 80 days (February 1 – April 20), however construction 

begins in November and clean up extends into late spring/early summer. Due to heavy equipment size and 

frequency of construction traffic, safety considerations dictate use of separate ice roads for pipeline 

construction, gravel placement, lake access, and general traffic.

During Year 1–2 of construction, ice pads would be built at the gravel source and along the gravel haul 

route. During Year 2–3 of construction, ice pads would be built at both ends of the pipeline route, plus an 

additional pad for construction laydown, see Section 2.5, Alternative A, and Section 2.6 Alternative B, for 

more information.

User Access

Overland uses of the GMT2 Project area by Nuiqsut residents occur year-round, with the greatest peak of 

overland activity occurring in the winter from October through May (see Figure 31, Table 67). Overland 

harvest activity will overlap directly in time and space with construction activity for the GMT2 Project.

During the period November–May, subsistence hunting in the project area is supported by four-wheeler 

and snow machine. Of Nuiqsut active harvesters interviewed for Stephen R. Braund and Associates’ 
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subsistence mapping study, 100 percent reported overland use areas crossed by the GMT2 Project area for 

one or more resources. Of these respondents, 100 percent of wolf and wolverine hunters and 91 percent of 

caribou harvesters reported hunting in the GMT2 Project area (SRB&A 2010a). Data from the Nuiqsut 

Caribou Subsistence Monitoring Project (Stephen R. Braund and Associates 2010b, 2011, 2012, 2013b, 

2014, 2015, 2016, 2017a) recorded 1,497 caribou use areas over the 8 study years. Of these 1,497 caribou 

use areas, 1,309 (87 percent) are overlapped by the GMT2 area. When considering only overland use 

areas, 374 caribou use areas (25 percent of total use areas) overlapped use areas within the project study 

area.

Table 136. Percent of Nuiqsut Harvesters using Construction Area of Potential Effect a

Resource Category

Percent of Nuiqsut Hunters 

Utilizing GMT2 Area of 

Potential Effect a

Overland Use Areas

Overlapped by the 

GMT2 Area of Potential Effect

Wolverine 100% --

Wolf 100% --

Caribou 91% 25%

Burbot 77% --

Geese 76% --

Arctic cisco 73% --

Broad whitefish 8% --

Eiders 7% --

All Resources 100% 27%

Source: Stephen R. Braund and Associates (2010a, 2010b, 2011, 2012, 2013, 2014, 2015, 2016, 2017).

a Boat use areas covered by the area of potential effect are excluded. See 4.4.5.1, Methodology, for more information.

Access to winter overland harvest areas within the project area near the GMT2 drill pad would be 

restricted during the construction seasons due to physical barriers to tundra travel and/or security 

restrictions (legal barriers). Blasting of overburden and extraction of gravel at the mine site would occur 

in winter on the east side of the community; gravel would then be hauled via an ice road to the GMT2 

project area during the first winter construction season. Gravel hauling would occur 24 hours per day and 

no public use of the gravel haul ice road would be permitted.

ConocoPhillips does not require permits for access by local residents to its development area, but does 

require that residents abide by safety policies when traveling in those areas. In addition to heightened 

security measures near the drill pad established by ConocoPhillips during construction that affect hunter 

access to the area, concerns about shooting near traffic, infrastructure, or towards pipelines are all reasons 

that residents may be restricted from hunting in the GMT2 area during construction, even if resources are 

present in those areas. Increased risks to hunters can also affect access to an area by presenting physical 

restrictions on access. For example, after construction of the CD5 road, some hunters managed to 

navigate around the road entirely by traveling under the bridge on the Nigliq Channel of the Colville on 

the east side of the road. This route became impassible and dangerous during spring overflow conditions 

on the river, requiring hunters to backtrack and go all the way around the CD5 pad (Nukapigak 2014).

GMT2 Access Road

During the GMT2 construction phase under Alternatives A and B, the permanent gravel road from the 

GMT1 drill site to the proposed GMT2 drill site would be under construction for at least 9 months after 

the ice road for gravel hauling is constructed. During this time, access onto or via the road would be

physically and legally restricted. Overland tundra travel through the area would be physically restricted 

for hunters on snowmachines and four-wheelers who would not be able to cross the road. The GMT1-
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GMT2 Access Road would intersect several main traditional travel routes that lead to coastal areas west 

of the community and to the lower Fish Creek area, where subsistence cabins and tent platforms are 

located (see Figure 34: Nuiqsut travel routes). 

The GMT1-GMT2 Access Road, once it is completed and a road access agreement is finalized, would be 

open to Nuiqsut subsistence users and could facilitate access to subsistence resources. This would likely 

occur before the overall GMT2 construction phase is complete. The GMT2 road would be a private, 

industrial road; it is not designed or intended to be a public road (ConocoPhillips 2016). Temporary 

physical and legal restrictions will result from industrial traffic on the road, including movements of the 

drill rig and other equipment. 

Construction of GMT2 is anticipated to require 172,200 vehicle trips over 2-3 years. Rules and 

restrictions on use of the GMT1-GMT2 Access Road would apply once the road is open to residents. 

Relevant restrictions and the longer-term effects anticipated from the GMT1-GMT2 Access Road are 

discussed below in Section 4.4.5.5, Alternatives A and B: Drilling and Operations Phase. 

Air Traffic

During the construction phase of the GMT2 project, fixed-wing air traffic for all alternatives would land 

at the Alpine Central Processing Facility (APF). Fixed-wing air traffic during the construction of the 

GMT2 development under Alternatives A and B is expected to consist of 270 flights to facilitate crew 

changes and is not expected to increase over current levels once construction is completed. Helicopter 

traffic will occur over the larger GMT2 project area May through September to support environmental 

studies and ice road clean up, and is expect to total 1032 flights during the construction phase of 

development. More detail on aircraft traffic is provided in Appendix B, and the impacts of air traffic on 

subsistence are discussed below as part of the drilling and operations phases of each alternative. 

Helicopter traffic, an impact that is discussed below, is the most commonly reported disturbance to 

subsistence hunting (see Appendix K: Aircraft Disturbance Information). Considering only new helicopter 

flights that would occur in the GMT2 area due to construction of the GMT2 Project, Alternatives A and B 

would result in:

• 538 new helicopter flights in Years 1-2 of GMT2 construction, and 

• 494 new helicopter flights in Years 2-3 of GMT2 construction.

The numbers of additional flights that will result from construction, drilling, and long-term operation of 

GMT2 under all alternatives are included in this document in Section 2.9.1, “Comparison of 

Alternatives,” Table 14. Those tables include numbers for helicopters versus all other aircraft and for 

flights into the GMT2 area versus into Alpine.

Avoidance

In addition to the restrictions resulting from temporary and permanent infrastructure, traffic, and safety 

zones described above, subsistence access during construction could be impacted because hunters are 

likely to avoid the project area. Hunter avoidance could affect access to the area due to concerns over 

safety, disturbances, and contamination of resources. Hunter avoidance could also result from actual or 

perceived reduced availability of subsistence resources in the GMT2 area.

It is likely that hunter avoidance of the GMT2 project area could be greater during construction than 

during drilling and operation. The actual footprint of the proposed GMT2 Project overlaps with a small 

portion of Nuiqsut’s highly used subsistence area (the red area depicted in Figure 15), but the linear 

components will be constructed between town and Fish Creek. User avoidance could be most acute near 

the construction activities for the proposed GMT2 pad and pipeline, but avoidance of the area would be at 

a greater distance than the footprint. Therefore, the avoidance of subsistence use areas, often characterized 
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by users as loss of an area, could be larger than the direct overlap of the project with documented use 

areas (NRS 2003; MMS 2007).

A more detailed description of avoidance is described in Section 4.4.5.5 Drilling and Operation –

Alternatives A and B: Avoidance. 

Resource Availability

Direct impacts from construction on resource availability could occur primarily from disturbance and 

displacement of subsistence resources. The effects of construction on the availability and abundance of 

caribou, wolves, and wolverines are described in Section 4.3.4, “Terrestrial Mammals,” and are 

summarized below. The geographic scope of the Terrestrial Mammals analysis contains the entire range of 

the Teshekpuk Caribou Herd (TCH). Impacts to subsistence are analyzed on a smaller scale and focus on 

the core subsistence use areas utilized by the community of Nuiqsut. This section discusses potential 

impacts in the core subsistence use areas.

As noted above, a key indicator of resource availability is per capita harvests within a community. 

Increases or decreases in these numbers may indicate an increase or decrease in the availability of 

subsistence resources to local harvesters. Per capita harvest information for all resources is available for 3 

non-consecutive years (1985, 1993 and 2014) and shows a general increase in total per capita harvest. 

More comprehensive data is available for per capita harvest of caribou. Per capita harvest data for caribou 

is available for 13 non-consecutive years and shows a generally flat trend in per capita harvest (see 

Appendix F). 

It is important to note that subsistence harvests have generally increased in areas where there is no 

development, and decreased in areas east of the community where development has occurred (see 

Appendix F). Most hunters have continued to harvest caribou in desired amounts, but many also report 

avoiding use areas due to development (SRB&A 2017a). Future research will reveal how harvest levels 

change when infrastructure is established closer to town or in core hunting areas and it becomes more 

difficult for hunters to avoid development. Resource availability during construction of GMT2 may be 

affected by the factors described below.

It is highly unlikely that construction activities for Alternatives A and B would reduce the overall 

population levels of subsistence resources. Some members of the TCH may alter their movement patterns 

in response to a newly constructed road, but the road would likely not disrupt the overall integrity of the 

herd’s historic range. Altered movement patterns would likely be most noticeable if the leaders of the fall 

migration are disrupted, but it is difficult to predict these changes on the periphery of the herd’s range. 

Mechanisms of disturbance are not completely understood, but traditional knowledge asserts that 

disturbance of adult cows initiating and leading fall migration can disrupt traditional migration routes. 

Whether the presence of temporary infrastructure and activity associated with the construction period will 

disrupt lead cows to the extent that availability near Nuiqsut is impacted is unknown (see Section 4.3.4.1, 

Terrestrial Mammals). 

Under Alternatives A and B, direct impacts to subsistence resource availability from disturbance and 

temporary displacement could occur as a result of placement of elevated pipelines on vertical support 

members, placement of gravel fill (pad and access road), ice road construction, and concurrent 

construction and operation of winter ice roads and construction activities. Impacts from road traffic 

during construction would occur during the months of November to mid-April during ice road 

construction and operation, when the ice road will be used for gravel road construction and pipeline 

vertical support member installation. The second construction season would be similar in duration for ice 

road construction, pipeline, power line, and fiber optic line installations and facilities installation.
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Impacts to resource availability could also lead to increased risks, costs, time, and effort because 

harvesters would have to look elsewhere or spend more time and/or money in search of resources. (see 

Table 133 for baseline data on trip length). These impacts would have a more acute economic impact in 

Nuiqsut due to the high price of groceries (see Section 3.4.4.3, Economy – Local Economy – Community 

of Nuiqsut.Disturbance of subsistence resources is most likely to occur within key subsistence use areas 

during the two- to-three winter construction seasons when the area is most accessible to Nuiqsut residents

hunting overland. Impacts on resource availability related to noise, traffic, and infrastructure is an impact 

that has been frequently observed and reported by North Slope harvesters (SRB&A 2009b, 2017a). Even 

localized or limited changes in caribou distribution resulting from displacement can affect the availability 

of caribou to harvesters because of residents’ limited means to access caribou at different times of the year 

and the fact that caribou are not always available near Nuiqsut. Twenty-five percent of overland use areas 

for caribou are overlapped by the construction area of potential effect, and 91 percent of caribou 

harvesters reported using the construction area of potential effect to harvest caribou (see Table 136). 

Indirect effects to resource availability could occur in hunting areas accessed by boat within and outside

the construction area of potential effect due to deflection. Areas accessed by boat were excluded from the 

analysis of user access (see 4.4.5.1, Methodology); however, hunters utilizing boats may still be affected 

by changes in resource availability. Sixty-five percent of caribou hunting areas are accessed by boat in the 

summer, and many animals are harvested after they travel east through the area of potential effect (see 

Section 3.4.6.3, Overview of Subsistence Use Areas). Construction activity will be much lower during 

summer compared to the winter ice road and construction season, but work on the GMT2 Project will 

occur year round and deflection of animals is possible. 

Displacement of furbearers (wolves and wolverine) from the project area could affect Nuiqsut subsistence 

activities. These species could experience a short-term or long-term displacement due to construction 

activity, making these resources less available to hunters in traditional locations (see Section 4.3.4, 

Terrestrial Mammals). 

Hunting for wolves and wolverines is an important cultural activity for Nuiqsut. Residents engage in 

furbearer hunting in the wintertime, when few other subsistence activities are possible. Wolf and 

wolverine fur supports the making of art and clothing that can represent a critical source of income for 

hunters and sewers. 

Residents of Nuiqsut have pointed out the particular importance of the GMT2 area (previously known as 

CD7) for wolf and wolverine hunting since permitting for the ASDP began (BLM 2003). While recent 

caribou use area data show the GMT2 footprint on the periphery of Nuiqsut’s core caribou hunting area, 

wolf and wolverine use area data show high overlapping use areas throughout the GMT2 area. All wolf 

and wolverine hunters reported use areas in the project area, more than for any other resource. Residents 

have indicated that furbearers such as wolf and wolverine are particularly sensitive to development 

activities and noise (SRB&A 2009b, 2010a). It is possible that deflection of furbearers from the GMT2 

area, or direct overlap of normal trap lines, will cause hunters and trappers to travel farther looking for 

these resources. Because these activities occur during winter, traveling further in extreme cold presents 

additional risks for these hunters and trappers. 

Alternative C: Construction Phase

User Access

Impacts associated with construction activities related to the ice roads and gravel installation for pads, 

vertical support members, pipeline, power line, and fiber optic line placement to subsistence under 

Alternative C would be similar to Alternatives A and B. Additionally, Alternative C would have air access 

facilities consisting of a 5,000-foot gravel airstrip and parking aprons. The GMT2 drill pad would be 
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accessed via the 0.9-mile-long gravel airstrip access road from the 18.4-acre occupied structure pad. 

Alternative C would not include a GMT1–GMT2 Access Road. Increased traffic levels would occur on 

ice roads because year-round gravel road access would not be available during Year 2 construction. 

Under Alternative C, GMT2 facilities would be constructed over two or three construction seasons. In 

Year 1 of construction, vehicle traffic under Alternative C would be the most intense from January 

through April to support gravel hauling and construction of gravel pads, the airstrip access road, and the 

airstrip, and construction of the pipeline vertical support members. Ice road pre-packing and ice road 

construction would occur in November and December. In the Year 2 of construction, traffic between 

Alpine facilities and the GMT2 drill pad and occupied structure pad would occur on ice roads.

Air Traffic

Subsistence users and resources would experience increased levels of disturbance from air traffic during 

construction of GMT2 facilities under this alternative. No airstrip or camp would be available at GMT2 

during Project Year 1 and Project Year 2. Construction crews would stage out of Alpine-area camps. 

Fixed-wing flights to support construction crews during winter of Year 1 would land at CD1/Alpine 

Processing Facility. 

Impacts associated with air traffic are described below in the discussion of avoidance during the life of 

the project. A complete table of flight numbers is provided in Appendix B. Estimated flight numbers for 

Alternative C during the construction phase are:

• In Year 1 of GMT2 construction, there would be 647 new helicopter flights at GMT2 and 129 new 

fixed-wing flights into Alpine; and

• In Year 2 of GMT2 construction, there would be 413 new helicopter and 1,058 fixed-wing flights at 

GMT2 and 145 new fixed-wing flights at Alpine.

Avoidance

Avoidance during construction under Alternative C would be similar to Alternatives A and B. Because of 

winter GMT2 construction activities under Alternative C, subsistence hunters may avoid the GMT2 area, 

which could result in lost harvest opportunities for those hunters. Increased ice roads, traffic, and gravel 

hauling under Alternative C would likely result in high levels of avoidance in the winter. The lack of a 

gravel road being constructed in the area would reduce the physical barriers to access because hunters 

would not be concerned with problems crossing it.

Resource Availability

The geographic scope of the Terrestrial Mammals analysis contains the entire range of the Teshekpuk 

Caribou Herd (TCH). Impacts to subsistence are analyzed on a smaller scale and focus on the core 

subsistence use areas utilized by the community of Nuiqsut. This section discusses potential impacts in 

the core subsistence use areas. Construction of Alternative C would result in similar types of impacts to 

resource availability and would be similar in intensity to the impacts expected under Alternatives A and B. 

Seasonal construction of ice roads and construction of larger pads under Alternative C would result in 

different patterns of direct disturbance: there would be no gravel road constructed and thus linear 

disturbances or barriers to animal movement would be reduced, but the additional pad and airstrip at the 

drill site have a larger footprint and require more construction activity and gravel.

Summary of Construction Phase Potential Impacts on Subsistence

Construction, particularly of the gravel road under Alternatives A and B, is expected to impact user access 

to the area and could impede tundra travel (travel methods and travel routes) through the area. In addition 

to impediments to user access, gravel hauling and other traffic and construction activity would likely 
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result in localized displacement of subsistence resources and would likely cause hunters to avoid the area. 

Construction of GMT2 would include the direct loss of land used for subsistence purposes by permanent 

infrastructure, temporary infrastructure, and safety areas surrounding drill sites. Construction activities 

that could cause disturbance would last two to three winter construction seasons and two to three 

corresponding summer seasons. 

4.4.5.5 Drilling and Operation

Alternatives A and B: Drilling and Operation Phases

The 30-year drilling and operations phase of GMT2 under Alternatives A and B would result in permanent 

industrial infrastructure and associated activities that overlap with areas documented for multiple types of 

subsistence activities. Subsistence uses in the GMT2 Project area include large land mammals, furbearers 

and small land mammals, fish, migratory birds, ptarmigan, and vegetation. Impacts from drilling and 

operation, including impacts to hunter access, hunter avoidance, and reduced resource availability, are 

expected to last the life of the project, but impacts could last longer if GMT2 infrastructure is used for 

future projects. See Maps 2.5-1 and 2.6-1 for more detail on project infrastructure

User Access

Land overlain by the direct footprint of new permanent infrastructure would be removed from the 

subsistence use area during the 30-year GMT2 drilling and operations phase. Land overlain by wintertime 

(ice road and pad) infrastructure would be temporarily removed from the subsistence use area. Table 137

shows current subsistence use areas that are overlain by the drilling and operations area of potential 

effect. 

Table 137. Percent of Nuiqsut Harvesters using Drilling and Operation Area of Potential Effecta

Resource Category

Percent of Nuiqsut Hunters Utilizing 

GMT2 Area of Potential Effect a

Overland Use Areas Overlapped by

the GMT2 Area of Potential Effect

Wolverine 88% --

Wolf 87% --

Caribou 84% 13%

Burbot 7% --

Geese 67% --

Arctic cisco 70% --

Broad whitefish 4% --

Eiders 0% --

All Resources 100% 23%

Source: Stephen R. Braund and Associates (2010a, 2010b, 2011, 2012, 2013, 2014, 2015, 2016, 2017).

a Boat use areas covered by the area of potential effect are excluded. See 4.4.5.1, Methodology, for more information.

In addition to new permanent infrastructure, the drilling phase would include a 10-acre ice pad for each 

year of drilling. Access to the GMT2 drill site and surrounding safety area is restricted to authorized 

Alpine personnel during the entire construction and drilling and operation phase, residents needing access 

to an Alpine drill site for any reason must notify Alpine Security prior to departing Nuiqsut for clearance 

to access the drill site. discharge of firearmsis also prohibited in the 1,000-foot safety area around drill 

sites. 
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GMT2 Access Road

During the drilling and operations phase (30 years), the gravel road from GMT1 to GMT2 would be open 

to local use for access to subsistence areas. The GMT2 road would include three subsistence pullouts for 

temporary parking on the road and ramps to facilitate snow machine and four-wheeler access to the tundra

for overland travel. 

Residents see certain roads, especially the community’s currently planned Colville River Access Road, as 

valuable for facilitating access for hunters. During certain times of the year (e.g., spring, when rivers are 

not open, but travel by snowmachine is no longer possible), roads can be particularly important for 

access. Hunters who only have road vehicles or who are less active (e.g., have less time to go on longer 

hunting trips) also benefit from road access. The Colville River Access Road and the Kuukpik Spur Road 

are also valued for providing emergency evacuation routes. These factors are all considered in evaluating 

the overall potential impacts of roads, while this section focuses on the potential beneficial and negative 

impacts on subsistence of the proposed GMT1–GMT2 Access Road (referred to hereafter as the GMT2 

road). The location, design, and uses of the proposed GMT2 access road are different from the location, 

design, and uses of the Spur and the Colville River Access roads; these are the primary factors that would 

result in different effects.

For all subsistence resources, boating is the most common travel method, followed by snowmachine use 

and then foot travel (see Figure 18). For caribou harvest in particular, hunting by boat constitutes the 

travel method most utilized to access caribou subsistence use areas, followed by snowmachine use and 

then four wheeler use. Historical trends in travel method for caribou harvest are below in Table 138.

Table 138. Travel Method Used to Access Caribou Use Areas, SRB&A Caribou Subsistence Monitoring 

Reports

Travel Method Year 1

2008

Year 2

2009

Year 3

2010

Year 4

2011

Year 5

2012

Year 6

2013

Year 7

2014

Year 8

2015

Boat 74% 80% 74% 80% 74% 77% 70% 65%

Snowmachine 22% 9% 16% 12% 8% 10% 15% 8%

Four-wheeler 4% 9% 9% 9% 17% 11% 14% 18%

Truck 2% 2% < 1% 0% 1% 1% 1% 8%

Source: SRB&A, 2017a. 

The GMT2 road would be a private, industrial road; it is not designed or intended to be a public road 

(ConocoPhillips 2016). Temporary physical and legal restrictions would result from industrial traffic on 

the road, including movements of the drill rig and other equipment. Other relevant restrictions to 

subsistence access on the road would include:

• Subsistence hunters under the age of 18 would not be allowed to use the road unless accompanied 

by an adult. 

• Road users would be required to stop at all safety stations to receive travel advisories and show 

valid driver’s license and/or proof of Kuukpik authorization to access Kuukpik land. 

• Use designated parking areas or pullouts. Brief stops for subsistence purposes would be 

permitted. Any vehicle stopped on the roadway must leave their flashers on. If hunters intend to 

leave a vehicle unattended for more than a brief period, they are requested to advise the safety 

station before they depart. 

• Hunting from, but not on, the gravel roads is permitted. Hunters should use designated pullouts or 

vehicle parking areas where possible. The hunter must be off the driving surface of the gravel 
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road while shooting. The hunter must not shoot from the inside of a vehicle or shoot across any 

gravel road.

• ATVs (four-wheelers) and snowmachines on the gravel road would be required adhere to the 

same access rules as road vehicles (ConocoPhillips 2016).

Access to the GMT2 road by road (as opposed to reaching the GMT2 road via overland tundra travel on 

off road vehicles) would require hunters to comply with Kuukpik Corporation rules for the Kuukpik Spur 

Road. The Kuukpik Spur Road is also known as the Nuiqsut Spur Road, the Kuukpik Road, or simply the 

Spur Road and is owned and managed by the Kuukpik Corporation (the ANCSA native corporation for 

the community of Nuiqsut). The Kuukpik Spur Road is not part of the GMT2 development, and access to 

the Kuukpik Spur Road is considered here only in its ability to affect the utility of the GMT2 road for 

subsistence users. 

The Spur Road is a private road, surrounded by Kuukpik Corporation land, and use is by permission only: 

use is considered a privilege and not a right (Kuukpik 2016). Spur Road rules are largely the same as 

those for the GMT2 road with the following restrictions that may be relevant for subsistence hunters: 

• Everyone using the Spur Road (drivers and passengers of road and off-road vehicles) must have 

permission and sign the Waiver of Liability and Road Rules.

• ATVs (four-wheelers) must stay on the Spur Road; access to the tundra from the Spur Road by 

ATV is prohibited. Tundra damage caused by driving off the road surface will be reported to the 

North Slope Borough by Kuukpik and the driver will be responsible for such damage. 

• Travel by snowmachine on the Spur Road is allowed only after a sufficient new snowfall and 

before plowing of the Spur Road.

All rules and legal restrictions for use of the GMT2 road described above would apply for the duration of 

the operation phase. Kuukpik has discretion to change Spur Road rules, or rules applying to Kuukpik 

lands, at any time. Subsistence access to areas west of the community would increase after construction 

because some hunters would use the GMT2 road to reach the area and many would most likely continue 

to travel overland via off-road vehicles. Some Nuiqsut hunters would use the GMT2 road to scout for, 

harvest, and transport subsistence resources (primarily caribou but also geese in the spring). Hunters may 

use snowmachines or four-wheelers on the road from town, or they may load these off-road vehicles onto 

trucks or trailers, transport them onto the road, and then offload them for overland use. Hunters who have 

the appropriate vehicles and permission from the Kuukpik Corporation to use the Spur Road would likely 

benefit from this facilitated access. Hunters who lack appropriate vehicles or permission, or who choose 

not to use the road, would not benefit from it. 

The GMT2 road could also have some direct impacts to subsistence access by introducing physical 

barriers or obstructions to travel through the area by snowmachine or four-wheelers. These impacts could 

occur during summer, fall, or winter caribou hunting, winter furbearer hunting and trapping, and spring 

geese hunting. Nuiqsut residents have increasingly reported subsistence impacts related to human-made

structures in recent years. Impacts related to human-made structures were the second most commonly 

reported impact in 2014 (SRB&A 2016), before ramps had been constructed to cross the new CD5 road. 

Several hunters reported that human-made structures blocked access when traveling overland. Ramps 

were not in the initial design for the CD5 road; ramps were eventually constructed but were too steep and 

narrow for some travelers to use and sometimes difficult to locate or not in convenient locations. People 

traveling to check their Arctic Cisco nets on the Nigliq Channel, for example, reported that the CD5 road 

was too high and too steep, and that the ramps were not wide enough to accommodate a snowmachine 

towing a sled. One resident, attempting to reach his fishing site on Fish Creek, could not cross the new 
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CD5 road and said he would have had to go around CD5 to get there (SRB&A 2016 p. 107). In the first 

winter after its construction, several travelers tried and failed to cross the CD5 road, then went around the 

road on the Nigliq Channel side (under the bridge). In the spring, however, overflow on the river made 

that route too risky and travelers then backtracked to travel around CD5 to continue (Nukapigak 2014).

The GMT2 road would continue to act as an impediment to travel throughout the operation phase for 

snowmachine users traveling overland (not using the road). Users will likely be able to cross the road 

using the ramps during periods when the ramps are snow covered, but may have to reroute based on the 

location of the ramps.

It is likely that ramps newly constructed for the CD5–GMT1 Road and proposed for the GMT2 road will 

be better than those built for the CD5 road. Ramps for the GMT1 and proposed GMT2 roads were 

included in the road design and should be wider and less steep than the ramps that were added to the CD5 

road after construction. Concerns remain that with the new GMT1 road and the proposed GMT2 road, an 

inability to cross the road would effectively box people in if they were traveling overland in any westerly 

direction. The ramps would help mitigate this impact, but concerns remain that even with ramps, the 

traffic on the road, especially in times of reduced visibility, would make it difficult or dangerous to cross. 

Hazards commonly associated with roads in the area include heavy industrial traffic, fugitive dust in the 

summer, and ice fog exacerbated by emissions that impedes visibility in the winter. 

Data emerging from use of the new (2014) Kuukpik Spur Road indicate that some hunters are using it and 

some are avoiding it (SRB&A 2017a). In 2015, two individuals mentioned avoiding the newly 

constructed Spur Road area, while several individuals reported using the road, and a couple commented 

that the road was a benefit to community hunters (SRB&A 2017a). Use of the Spur Road was much 

heavier than use of the CD5 road (SRB&A 2017a). Residents have indicated that the Spur Road is 

substantially lower than the CD5 road and therefore it is easier for hunters to travel on and off the road to 

harvest caribou (as noted above, access to the tundra by four-wheeler from the Spur Road is prohibited). 

There are several reasons that data on the benefits of increased access provided by the Nuiqsut Spur Road 

should not be used to predict the impacts of the GMT2 road. Most data gathered on use of the Spur Road 

reflects use of it before there was any development west of it (i.e., the GMT1 road or proposed GMT2 

road), and the roads themselves are different in terms of design, location, and the type/frequency of 

vehicles utilizing the road.

The location, design, and uses of the GMT2 road may have the potential to deflect caribou to a greater 

extent, and with greater consequences, than the Spur Road. It is likely that construction and subsequent 

use of the larger industrial GMT2 road (with adjacent pipelines) located generally west of the Spur Road 

would deflect caribou that are migrating west to east towards the Spur Road. (See the discussion of 

Resource Availability with additional citations below). Concerns about this potential deflection have 

already been expressed by community residents (SRB&A 2017a). If caribou are deflected from crossing 

the GMT2 road, the current benefits of the Spur Road may be reduced. Hunters would likely respond by

increasing their use of the GMT2 road to access areas farther to the west of the community. This would 

involve longer trips and potential access issues.

The Spur Road is much lower compared to ground level than the newly constructed Alpine to CD5 and 

CD5 to GMT1 roads. The height of the conceptual GMT2 road will be approximately the same as the 

CD5–GMT1 Road, and the road height is the primary concern cited by Nuiqsut residents. Hunters have 

noted that the lower Spur Road is easy to cross and does not block caribou as has been observed at the 

new CD5 road (SRB&A 2017a). Gravel roads 4 feet or more in height create a visual barrier that can lead 

to delay or deflection of caribou movements (Wolfe et al. 2000), and the GMT2 road would be 

approximately 5 to 8 feet high. In addition to its height and location, the GMT2 road would be a large 

industrial road actively used by heavy equipment for several decades, whereas most industrial traffic is 

prohibited on the Spur Road. 
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The consequences of the Spur Road deflecting caribou are less impactful to hunters than deflection of 

caribou farther away from Nuiqsut would be. The Spur Road is very close to town, and any caribou 

deflected by the Spur Road likely remain close to town where people with limited resources depend on 

finding them. By contrast, the GMT2 road would be approximately 15 miles away from Nuiqsut and 

extend 14 miles into the edge of a high use fall migration corridor for Teshekpuk Caribou Herd. Caribou 

deflected by the GMT2 road may remain west of the GMT2 road and would require significantly more 

time and effort to harvest. (See the discussion of Resource Availability with citations below). 

Although still in draft form, the Year 9 report for the Nuiqsut Subsistence Caribou Monitoring Project 

documents use of the Spur Road, CD5 Road, and connected ice roads for caribou hunting, and Year 10 

data (forthcoming) show use of the newly constructed GMT1 road (see Section 3.4.6.4). Preliminary data 

from Year 10 of the monitoring study indicate a shift toward use of roads for subsistence, but also an 

increase in reported impacts associated with roads and road traffic. Methods for use of roads vary by 

hunter. 

While some respondents view the road as a benefit that provides access to caribou hunting grounds, 

others believe the road and/or road hunters are reducing the availability of caribou in traditional areas 

west of the community. Some individuals reported using the roads to spot caribou, while others use the 

roads as an access point for overland areas accessed by four-wheeler or snowmachine. Some indicate that 

they use the roads out of necessity because the caribou have been diverted away from areas closer to the 

community, either because of the roads themselves acting as barriers or due to the presence of hunters 

along the roads. Finally, a number of hunters have reported minimal or no use of roads for hunting, with 

some avoiding the roads altogether (SRB&A 2018). 

During a recent meeting of the Nuiqsut Caribou Panel, panel members reported impacts associated with 

developments to the west of the community, noting that caribou from the Teshekpuk Herd had approached 

the community in the fall/winter of 2017 but diverted back to the west because of the roads and activity in 

the area. Panel members stressed that the height and grade of the GMT1 road is too steep and results in 

difficulties for both caribou and hunters trying to cross the road.18

As noted above, several ramps along the proposed GMT2 road would allow crossing the elevated road 

from one side to the other and provide egress off the road and access back onto the road by four-wheelers 

and snow machines. Repeated passes in a single location by four-wheelers (or other wheeled vehicles) 

during non-frozen periods would likely result in trail braiding, breaking the tundra mat, ruts and 

channeling of water into vehicle tracks, and exposure of frozen soil with potential localized permafrost 

thawing and thermokarsting near the ramps (see Section 4.2.1.1, Physiography and Geomorphology/Soils 

and Permafrost.) Fugitive dust from roads can result in earlier snowmelt, and altered snow distribution 

patterns near roads can have major implications for ground temperatures (Walker, Raynolds et al. 2014). 

These factors could exacerbate thermokarsting near the road. 

These effects could eventually increase the risk and reduce the feasibility of overland access by fourwheeler in the area during the frozen period. Increasing injury rates and demand for search and rescue 

operations have been documented in arctic Canada (Clark, Ford et al. 2016). The subsistence use of fourwheelers, according to Ray Bane, “is a particularly complex and sensitive issue. Access to renewable 

natural resources is crucial to a subsistence based economy and lifestyle. However, such access must not 

degrade the environment and resource base for the sake of short-term convenience. Ultimately, this 

imperils the opportunity for future generations to continue a subsistence lifestyle,” (Bane 2000 p. 71-72).

 18 Preliminary data from Year 10 of the Nuiqsut Subsistence Caribou Monitoring Project (not published) was summarized for the 

Final Chapter 3 Affected Environment: Subsistence section of this SEIS. Please see (see Section 3.4.6.4).
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The GMT2 road would therefore initially facilitate subsistence access via four-wheeler, but that type of 

access could be restricted in overland areas near the road within the life of the project. It may become 

physically restricted due to rutting, subsidence, and thermokarst, and/or it could become legally restricted 

to prevent such damage. With appropriate ramp design, snowmachine users may not experience problems 

during the winter. However, the frozen period when overland travel by snowmachine is feasible is shorter 

than in the past and predicted to shorten in the future (Richter-Menge, Overland et al. 2017). Hunters 

traveling by snowmachine over snow-covered tundra in the spring may have problems using the ramps if 

the snow on and around them has melted away earlier than it has on the surrounding tundra (NVN 

2018b). Recent documentation of current impacts to subsistence activities in Alaska and a forecast model 

indicate a net reduction in the availability of subsistence resources over the next 30 years caused primarily 

by climate-related challenges in access, rather than changes in abundance or distribution of resources 

(Brinkman et al. 2016). 

The impacts described above may only affect some hunters and may change over time. Users who cannot 

or who chose not to use the road would have their access restricted throughout the drilling and operation 

phases. In the longer term, access to the tundra off the road may be restricted. Anticipated negative effects 

include direct overlap with a use area, impediments to overland access, hunter avoidance, hazards, dust, 

traffic, noise, emissions, ice fog, interference with scouting for caribou, localized deflection of caribou

and furbearers, and possible limited overland four-wheeler access in areas near ramps due to tundra 

damage and snowmachine access onto ramps due to early snowmelt on the gravel. 

Air Traffic

In preparing for development of Alpine, Nuiqsut residents and the Kuukpik Corporation perceived that 

industrial roads would result in the type of impacts that they wished most to avoid. Alpine was developed 

with a roadless design that was seen by many stakeholders as a significant evolution in reducing the 

footprint of development. Since the construction of those fields, disturbance from aircraft traffic has 

become the most commonly reported impact on subsistence activities (see Appendix K: Aircraft 

Disturbance Information). 

Under Alternatives A and B, fixed-wing aircraft would typically utilize the existing CD1/Alpine 

Processing Facility airstrip and helicopters would base out of CD1/Alpine Processing Facility. Flights 

would support personnel and equipment transport required for construction and the start of drilling. Under 

Alternatives A and B, personnel, equipment, and materials would be transported overland on snow trails, 

ice roads, and on the gravel GMT2 road, once it is constructed. Helicopter landings, to support 

environmental studies and ice road cleanup, would occur from May through September. 

Aircraft traffic results in unique and substantial impacts for Nuiqsut hunters. Impacts from infrastructure, 

road traffic, and drill pad noise, odors, and activity are impacts that hunters expect to occur near the actual 

site of development. These known impacts can be avoided if hunters choose to hunt elsewhere. In 

contrast, impacts from aircraft traffic are more difficult to forecast or avoid and can cause more acute 

stress and disruption to both animals and harvesters. 

Section 4.6.7, “Acoustical Environment” discusses existing natural and human-made noise in the GMT2 

Project area and potential impacts on noise-sensitive resources include wildlife, recreation, subsistence 

activities, and local residents and communities.

Aspects of air traffic disturbance considered in this analysis include:

• The frequency with which aircraft traffic is cited as a negative impact on subsistence uses on the 

North Slope. 

• The unique nature of helicopter noise associated with human disturbance, and 
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• The increasing amount of helicopter traffic in key Nuiqsut subsistence use areas and the amounts 

estimated to result under GMT2 Alternative A.

The traditional knowledge, hunter observations, and scientific data that indicate that aircraft noise disturbs 

animals are discussed below under “Resource Availability.”

Residents across the North Slope perceive aircraft traffic as a substantial impact on subsistence hunting. 

The Iñupiat Community of the Arctic Slope (the umbrella Tribal government of the North Slope Iñupiat) 

passed a resolution in 2014 requesting assistance from the BLM and all agencies and entities that 

participate in aviation on the North Slope “to alleviate the high air traffic, low flying aircraft, airplanes, 

and helicopter use from diverting the caribou migrations to our villages.” 

The community of Nuiqsut requested research on aircraft disturbance to corroborate this common 

complaint. An initial study collected summer sound- and noise-level data at 20 sites identified by the 

community near Nuiqsut, Fish Creek, and along the Colville River with a passive acoustic monitoring 

project in 2016 (Stinchcomb 2017). This research quantified human-caused noise attributable to aircraft 

activities at the sites:

“A total of 7,465 aircraft noise events were captured over 21-84 days of recording during 

peak caribou harvest season. Aircraft activity reached 11-15 overflights per day near Nuiqsut 

and the surrounding industrial complex, approximately six times greater than activity levels 

in undeveloped areas. Aircraft sound disturbance decreased incrementally with distance from 

human development. Aircraft traffic around developed environments compared to local 

operations at U.S. airports where the average population is 908 times larger than that of 

Nuiqsut,” (Stinchcomb 2017 p. 57). (Research methods and a map showing study site 

locations are included in Appendix C). 

At its 2016 Oil and Gas Forum, the North Slope Borough organized a session on “Reducing Impacts from 

North Slope Air Traffic.” The Oil and Gas Forumwas a high-level, three-day event held in Anchorage, and 

the air traffic forum was only one of eight breakout sessions. In his opening remarks in the session’s panel 

discussion, North Slope Borough Senior Wildlife Biologist Robert Suydam stated that aircraft conflicts 

with locals are a major concern in every village. Suydam noted that some people, out of extreme 

frustration, have threatened to shoot planes in the air, and the consequences could be tragic (North Slope 

Borough 2016).

North Slope subsistence users’ negative experiences with helicopter traffic are amplified by the 

widespread belief that their food security is impacted by it (see Appendix K: Aircraft Disturbance 

Information). Inupiaq hunters are not unique in their general reactions to helicopters, which are 

particularly annoying to many humans. Federal Aviation Administration research on this issue finds that 

helicopter noise is unique in several ways, including: 

• It is more noticeable than other types of noise.

• It often creates more annoyance in humans than fixed-wing aircraft noise, even when it is not as loud 

as fixed-wing noise.

• Some people regularly exposed to helicopter noise develop a substantially heightened reaction to it 

(even when the noise or incidents do not increase, and even compared to louder fixed-wing aircraft 

noise).

• A subset of the population is very sensitive to low-frequency noises in the range often created by 

helicopters and they are quite bothered and disturbed by this noise almost as soon as it crosses the 

threshold of audibility.
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• Community attitude is an important modifier of annoyance: when the party that generates the noise 

maintains very good community relations and convinces the community that everything possible that 

can be done is being done to reduce the noise, it creates less annoyance.

• People often feel that their privacy is being invaded when a helicopter flies low or hovers near them 

(Federal Aviation Administration 2004).

The Iñupiat Community of the Arctic Slope resolution, the summary of the 2016 North Slope Borough 

Oil and Gas Forum aviation disturbance session, and aviation recommendations made by the BLM NPRA Subsistence Advisory Panel, are included as Appendix K in this document. These sources establish that 

adverse impacts from aviation are experienced by residents of all North Slope communities. Aircraft 

traffic has been cited as justification for opposing research activities in both Point Lay and Wainwright in 

recent years, and there is an annual summertime spike in complaints from several NSB communities. To 

attempt to avoid conflict, thorough community consultation and engagement of local liaisons is standard 

practice for many aviation-based BLM-permitted activities in Atqasuk and Wainwright. 

The amount of aircraft activity in the Nuiqsut area far exceeds amounts in these other communities. As 

Stinchcomb’s research project found, aircraft noise in the Nuiqsut region is approximately equivalent to 

aircraft noise around an airport in a city the size of Anchorage (Stinchcomb 2017). The most commonly 

reported Alpine-related impact during the first 8 years of the Nuiqsut Caribou Subsistence Monitoring 

Project was associated with helicopter traffic. In Years 7 and 8, reports of helicopter traffic impacts 

decreased, and some harvesters attributed the decrease in impacts to construction of the Spur and CD5 

roads and resulting decrease in helicopter traffic associated with development. Helicopter traffic has 

actually increased, and residents continue to voice frustration that the roads have not eliminated air traffic 

in the Nuiqsut area. Harvesters have noted that helicopter and plane traffic tends to divert caribou or cause 

skittish behavior, resulting in reduced harvest opportunities (SRB&A 2009b). In comments and testimony 

on the GMT1 Supplemental EIS from North Slope residents, there was near-universal opposition to 

development options that include more airstrips due to the belief that roadless options result in increased 

air traffic19. 

The numbers of additional flights that will result from construction, drilling, and long-term operation of 

GMT2 under all alternatives are included in this document in Section 2.9, “Comparison of Alternatives,” 

Table 16

Considering only new helicopter flights that would occur in the GMT2 area during drilling and operation 

of the GMT2 Project, Alternatives A or B would result in 90 new helicopter flights per year during 6 years 

of drilling and subsequent 23 years of post-drilling operations. Over the lifetime of the GMT2 Project,

Alternatives A or B would result in 3,642 additional helicopter flights in the GMT2 area. See Section 

4.6.8.8, “Subsistence,” for information on cumulative flight numbers and anticipated impacts to 

subsistence. 

Discussion of the effects of air traffic on caribou is below under Resource Availability. Data available 

from North Slope hunters indicates that most hunters believe that helicopter traffic negatively affects 

caribou movement and harvest success (see Appendix K: Aircraft Disturbance Information and

(Stinchcomb 2017). Nuiqsut hunters continue to harvest caribou in regular numbers, thus these impacts to 

date are not affecting overall harvest success. However, the effort required to harvest resources and the 

experience of subsistence hunting is acutely disturbed by helicopter traffic. 

 19 In deliberations over GMT1 development and construction, many residents were under the impression that permanent roads 

would lead to an overall decrease in aircraft traffic than the area had previously experienced, not simply less of an increase than 

would result from roadless development.
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Assessing potential impacts of aircraft traffic associated with Alternatives A and B on subsistence uses in 

the Nuiqsut area, this analysis considers Inupiaq hunters’ traditional knowledge and observations, the 

consistent North Slope Borough-wide opposition to aircraft traffic during the caribou hunting season, 

research on aircraft noise effects on animals, and research on helicopter noise effects on humans. This 

body of evidence indicates that aircraft traffic disrupts subsistence hunting practices on several levels. The 

baseline amount of helicopter traffic in the Nuiqsut subsistence use area at present constitutes a 

significant impact to subsistence uses and the additional traffic resulting from Alternatives A or B would

exacerbate this impact substantially.

Avoidance

Avoidance as an impact to subsistence is mentioned above under the analysis of impacts during the 

construction phase (Section 4.4.5.4). That analysis notes that the avoidance effect would likely be more 

acute during construction (2-3 years) than it would be during drilling and operation. Avoidance as a 

general impact is discussed in more detail below, followed by analysis and stakeholder input on how 

GMT2 (under Alternatives A and B) could affect avoidance during the 30-32 year life of the project.

The shifting of subsistence use areas away from areas of development at a distance greater than the 

development footprint is well documented for the community of Nuiqsut (RFSUNY 1984; Impact 

Assessment, Inc. 1990; Pedersen et al. 2000; MMS 2007; SRB&A 2017a, 2017f). Subsistence harvesters 

often avoid areas of industrial construction due to discomfort about hunting near human or industrial 

activity. Pedersen et al. (2000) provide a detailed analysis of this impact, noting that harvest location 

information for Nuiqsut from 1993 and 1994 “provide support for the claim of displacement from 

traditional hunting areas.” The report notes that 80 percent of the community’s 1993 harvest came from 

areas more than 16 miles from any development, and a similar pattern was noted during the following 

year in North Slope Borough research. According to Minerals Management Service (2007), oil and gas 

development has to potential to divert subsistence users a distance of 5 miles to greater than 25 miles 

from facilities. 

The Alaska Department of Fish and Game Division of Subsistence 2015 comprehensive survey in 

Nuiqsut found that similar percentages of hunters were reporting impacts (not necessarily avoidance). 

When asked if Alpine-related activities in 2014 made caribou hunting more difficult and when asked for 

any additional comments, 57 percent of the households indicated adverse effects on their household’s 

2014 subsistence season attributed to surrounding development (Brown et al. 2016). 

Residents have explained that they are wary of hunting in the presence of human-made structures, even 

when caribou are present, due to fear of damaging infrastructure or company property. Nuiqsut hunters 

also explained that they feel forced out from traditional areas: many no longer use traditional areas near 

Alpine and CD5 and expect that the same effect will happen with GMT2. Nuiqsut hunters also noted that 

they have had to move hunting activities upriver to avoid development and that their hunting area is 

shrinking due to development (SRB&A 2017a, 2017f). 

Contamination or perceived contamination associated with the proposed project also could result in 

avoidance by subsistence users. The availability of subsistence resources depends not only on their

abundance in traditional use areas but on their health or quality (either actual or perceived). A main 

concern of North Slope subsistence users is the potential impacts on subsistence resources of 

contamination, including from air pollution, related to development (SRB&A 2009b, 2017f). 

Contamination or perceived contamination of subsistence resources could result in reduced availability of 

subsistence resources considered healthy enough for consumption. 

Summarizing the results of interviews with 215 active North Slope hunters regarding the impacts and 

benefits of oil and gas development, SRB&A (2009b) reported that 79 percent of active hunters in 

Nuiqsut cited personal experiences with difficulties in hunting related to oil and gas development, 
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including concerns related to physical and social barriers to hunting, increased effort required, and 

competition. 

SRB&A has included avoidance questions in the Nuiqsut Caribou Subsistence Monitoring Project since 

Year 6 (2013). From 2013 through 2016, when asked about places of avoidance, between 51 and 61 

percent of harvesters responded that there were places they no longer used or avoided. In just over onequarter of cases, those harvesters specifically identified the Alpine/Alpine Satellites areas; caribou 

harvesters also identified more general geographic locations in the vicinity of Alpine/Alpine Satellites, 

including Nigliq Channel, Colville Delta, and Tamayayak Channel, citing development-related reasons. 

For all responses related to avoidance, development-related causes were cited as the cause in nearly twothirds of observations (SRB&A 2018, Table 47 and Table 48). A preliminary review of the data collected 

in Year 10 of the monitoring study (data from 2017) shows an increase in reported avoidance, with nearly 

three quarters of active harvesters indicating that there are places that they no longer use or avoid. 

However, development causes were cited in a somewhat smaller percentage (approximately half) of 

observations.

Although there are yearly exceptions, over the 9 study years (2008–2016), the Nuiqsut Caribou 

Subsistence Monitoring Project (SRB&A 2018) has documented a general increase in the percentage of 

harvests in the area west of Nuiqsut and a general decrease in the percentage of harvests along the Nigliq 

Channel. This decrease in the percentage of harvests along the Nigliq Channel is likely caused by 

increased industrial activity in areas along the Nigliq Channel (SRB&A 2017f, page 28); the increase in 

the percentage of harvests west of the community likely reflects a shift of residents’ hunting patterns to 

avoid developed areas and, more recently, to take advantage of the Nuiqsut Spur Road.

Much of the research and conclusions related to harvester avoidance are based on pre-Alpine hunting 

patterns. While avoidance has continued to occur, and has been documented in the Caribou Subsistence 

Monitoring Project, it is important to note that as industry has moved closer to Nuiqsut, it has become 

more difficult for residents to avoid industry. Development of GMT2 would result in permanent 

infrastructure in the subsistence use area and increased helicopter traffic, which have historically resulted 

in increased avoidance. Avoidance may be less of an option as fewer areas without development are 

present and the avoidance effect may be decreased by the facilitated access provided by the GMT2 road, 

discussed in detail above. 

One Nuiqsut hunter, testifying publically on the proposed GMT2 project, noted that he did not like the 

term ‘hunter avoidance.’ “Because we are displaced by all that out there. [] It’s not so much avoidance as 

displaced,” (Taalak 2018).

The North Slope Borough commented that if such an impact was predicted for GMT1, “it seems that the 

impact of GMT2 would further displace hunters and be even more of a substantial restriction on 

subsistence uses,” (NSB 2018).

Kuukpik Corporation believes that avoidance of the footprint where GMT2 would be constructed and the 

couple of miles around it “that typically becomes effectively off-limits to subsistence users” would likely 

be one of the primary impacts of GMT2 (Kuukpik 2018). Kuukpik communicated that the other likely 

primary impact would be indirect impacts “that may result from constructing the project in an important 

migration corridor,” (discussed below under Resource Availability). 

Both of these impacts, according to Kuukpik, might be at least partially offset by the access to other areas 

that would be facilitated by the road to GMT2. “On the other hand, that same road may have real 

psychological impacts for a community that for years has felt-and become-increasingly surrounded by oil 

development. Much of the community views GMT2 as a significant contribution to that problem because 
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it will expand the network of roads farther west and south of town, further encircling (literally) the 

community with roads,” (Kuukpik 2018). 

Kuukpik does not believe that this “psychological burden” is immutable: the tangible benefits offered by 

increased access “could ultimately reduce many Nuiqsut residents’ traditional reluctance to use oil and 

gas infrastructure for subsistence purposes. [] That shift in attitude is, we believe, increasing as the 

Nuiqsut Spur Road continues to become an increasingly valuable asset for people looking to practice 

subsistence near the community,” (Kuukpik 2018).

Resource Availability

Impacts from drilling and operations on resource availability would primarily result from displacement 

(localized deflection) of subsistence resources away from areas where they are normally harvested by 

Nuiqsut hunters. Impacts related to resource availability related to noise, traffic, and infrastructure have 

been frequently observed and reported by North Slope Borough harvesters (SRB&A 2009b). Disturbance 

to and localized displacement of resources (caribou, furbearers, and waterfowl) could result from project 

infrastructure (habitat loss), road and aircraft traffic, odors, other industrial activity (i.e., pad and road

construction and well drilling), and from hunting pressure. 

The geographic scope of the Terrestrial Mammals analysis contains the entire range of the Teshekpuk 

Caribou Herd (TCH). Impacts to subsistence are analyzed on a smaller scale and focus on the core 

subsistence use areas utilized by the community of Nuiqsut. This section discusses potential impacts in 

the core subsistence use areas. Caribou migratory patterns relevant to the GMT2 project involve both the 

Teshekpuk Lake Caribou Herd (TCH) and, to a lesser extent, the Central Arctic Caribou Herd (CAH). 

Specifically relevant are the portions of animals from the TCH and CAH that are accessible to hunters 

from Nuiqsut during caribou hunting seasons. 

Annual TCH movement patterns are described in Section 3.3.4.1. In general, their distribution and 

movement patterns are driven by high quality forage availability prior to and during calving, and insect 

harassment during summer. At the onset of fall migration, some members of the TCH move east across 

the coastal plain and migrate south along the Colville River in the vicinity of Nuiqsut. The GMT2 Project 

area bisects this fall migration corridor. Some members of the TCH remain on the coastal plain through 

winter, which contributes to Nuiqsut hunters’ understanding that caribou can usually be found west of the 

Project area in the vicinity of Fish Creek.

The proposed GMT1-GMT2 road is on the eastern edge of the TCH range. Five percent of GPS-collared 

caribou crossed the proposed GMT2 road alignment during fall migration between 2005 and 2017 

(Lawhead et al. 2015, L. Parrett pers. comm.). Annual collared caribou crossing of the proposed GMT2 

road alignment ranges from 0% to 31%, and crossing rates are highly variable, low overall but persistent 

over time. While use of the migration corridor directly west of the Colville River is low when considered 

relative to the herd’s migratory movements as a whole, caribou utilizing migration routes on the eastern 

edge of the herd’s range are most easily accessible by Nuiqsut subsistence hunters. Thus, the small 

portion of the herd that use this eastern migration route is particularly important to the community. 

Localized displacement is possible, especially initially, and Nuiqsut is vulnerable to changes in TCH 

distribution.

The GMT2 project area is located at the western edge of the CAH range. The majority of the CAH 

remains east of the Colville River and calves primarily in the Colville East survey area (Map 3.3-10). 

CAH use of the NPR-A is low, the Alpine Satellite Development Plan Study Area does contain areas of 

high density utilization by the CAH, specifically during the mosquito and oestrid-fly seasons (Map 3.3-

10). In 2014, more CAH animals remained in the eastern portion of the Alpine Satellite Development Plan 

Study Area during midsummer than in other years since 2004 (see Section 3.3.3.1 for a detailed 
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description of the range of both herds). The Colville River Delta is in the peripheral range of both the 

Teshekpuk and Central Arctic herds, and Nuiqsut harvesters are particularly vulnerable to changes in the 

distribution and/or behavior of caribou in these herds

Drilling of 48 wells on the GMT2 pad is anticipated to occur over 7 years (years 3-10). Drilling activities 

may result in reduced caribou and furbearer availability. Studies show that caribou, especially cows with 

calves, generally avoid drilling sites, and those caribou that do approach drilling sites spend less time 

feeding and lying down (NRS 2003). Wolverines and wolves are sensitive to noise impacts, and activity 

associated with the drilling and operations phase of GMT2 may reduce availability of these resources in 

the area of potential effect (see Section 4.3.4.1 Terrestrial Mammals). 

Deflection of Resources by Loss of Habitat

Loss, alteration, and disturbance of habitat (including indirect habitat impacts outside the gravel footprint 

due to physical changes caused by gravel spray or dust deposition, snow drifting and piling, thermokarst, 

and altered hydrology) would result in reduced local availability of caribou and furbearers. A detailed 

discussion of these impacts is in Section 4.3.4.1 (Environmental Consequences: Terrestrial Mammals).

Habitat loss will not substantially reduce availability of caribou for subsistence harvest in the area of 

potential effect. 

Deflection of Resources by Infrastructure and Road and Air Traffic

A primary concern about the GMT2 road is that both the height of the road and the industrial traffic on it 

will deflect caribou from their local migration paths (BLM 2003, SRB&A 2017a). The analysis of 

potential impacts to caribou (§ 4.3.4.1) finds that road traffic supporting the GMT2 Project would most 

likely affect caribou of the TCH and possibly some animals from the CAH during the fall migration 

period because the GMT2 road extends about 14 miles into the edge of a high-use fall migration corridor 

for the TCH. This area is the eastern periphery of normal caribou migration paths in the eastern periphery 

of the TCH. In addition to traffic, the GMT2 road and drill site will present physical obstacles that may

deflect some caribou. Gravel roads 4 feet or more in height create a visual barrier that can lead to delay or 

deflection of caribou movements (Wolfe et al. 2000). Gravel roads associated with the proposed project 

would be a minimum of 5-feet thick (height above surrounding grade). Greater deflection of caribou 

would be anticipated during periods of migration that coincide with high use.

Local hunters frequently report deflection of caribou from industrial roads. In 2014, one respondent for 

the Stephen R. Braund and Associates Nuiqsut Caribou Subsistence Monitoring Project noted that traffic 

on the CD5 road had disrupted caribou migration paths (2016). In 2015, three project respondents noted 

that traffic on that road continued to disrupt caribou migration (SRB&A 2017a). The GMT2 road (and 

traffic and pipeline) could act as a barrier or deterrent to caribou as they travel through the area (from the 

west to areas closer to town). If the road has a tendency to prevent caribou from coming closer to town, 

then hunters who are not able to—or prefer not to—use the road to hunt from could be at a distinct 

disadvantage compared to hunters who have vehicles and use the road. 

Much of the general research on aircraft impacts on wildlife focuses on low-level military jets. However, 

the scientific evidence indicates that the short-term effects of aircraft on caribou behavior can negatively 

affect hunting success and harvest (Davis et al. 1985; Harrington and Veitch 1991; Luick et al. 1994; 

Maier et al. 1998; Wolfe et al. 2000; Vistnes and Nellemann 2007). A 2000 publication by Wolfe et al. 

reported that caribou response to aircraft is variable depending on the season, degree of habituation, type 

of aircraft, altitude, airspeed, weather conditions, frequency of overflights, and the sex and age 

composition of the caribou groups. The reaction was strongest during calving, calves being the most 

reactive, habituated caribou reacted less often, and caribou were more responsive to helicopter than to 

small fixed-wing overflights only at low (<100 m above ground level) altitudes. 
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Fullman et al. (2017) investigated the movement patterns of caribou in response to non-local sport 

hunting and environmental features in Noatak National Preserve, Alaska: a study initiated by a hypothesis 

that aircraft disturbance and associated hunting activity influenced caribou movements and migration. 

Local hunters in the area primarily access the area by boat while sport hunters typically use small, 

commercially operated transporter aircraft. The results of the study showed that caribou movements did 

not appear to be influenced by aircraft borne hunters at the movement scale they were able to address 

(caribou collar location every 8 hours), and that migratory movements were influenced more by 

environmental features. This finding tend to corroborate previous findings that responses to aircraft tend 

to be short-lived. However, findings from this research do not refute the potential that those short-lived 

responses can have impacts on subsistence hunters. 

The NPR-A Working Group’s General Principles for Development of Infrastructure in Northern Alaska 

(2014) notes, “Local and traditional knowledge and direct experience tell us that aircraft pose one of the 

greatest potential negative impacts to the success of subsistence hunters and that such flights can also 

impact caribou movements over the long-term.” A thorough discussion of the impacts of aviation on 

caribou movement and hunters, based on research in Nuiqsut, is included in the recent University of 

Alaska thesis (Stinchcomb 2017: Social-Ecological Soundscapes: Examining Aircraft-Harvester-Caribou 

Conflict in Arctic Alaska). Methods and study sites of that research are included in Appendix C. 

Data on caribou hunting activities collected during the Nuiqsut Caribou Subsistence Monitoring Project 

(SRB&A 2010a, 2011, 2012, 2013b, 2014, 2015, 2016, 2017a, 2018) display a shift in timing of caribou 

hunting activities in the GMT2 project area with a smaller percent of caribou use areas in the project area 

accessed during the winter months and a slightly higher percentage (30 percent) accessed in September. 

August overland caribou hunting activity in the project study area also increased during the study years 

for the caribou monitoring project (Figure 30) compared to the SRB&A (2010a) study years (Figure 29). 

Possible explanations for this shift include documentation of the use of four-wheelers by younger Nuiqsut 

hunters, an activity that occurs primarily during August and September. Another possible explanation 

could be more caribou being available in the project study area during August and September. In either 

case, the available data do not provide a definitive answer as to the reason for the shift. During Year 9 of 

the monitoring project, an increase in winter use of the project study area was evident, likely as a result of 

year-round access to roads (including ice roads) west of the community.

Aircraft activity in the larger GMT2 project study area could result in skittish and escapist behavior in 

caribou that makes harvesting them more difficult. Increased helicopter activity in overland areas west of 

town is expected to have a particularly large effect on harvesting activities because more hunters are 

harvesting caribou in that area during the helicopter season than have in the past. 

Drilling noise, industrial and human activity on the pad, and road and aircraft traffic in the GMT2 area are 

expected to exacerbate any deflection of resources that could result from the physical obstacles posed by 

the road and pad. 

Deflection of Caribou by Hunting Pressure

Caribou deflection may also occur because of increased hunter pressure from hunters whose ability to 

access the GMT2 project area, particularly overland areas west of town, would be facilitated by the road. 

Frequently cited Inupiaq traditional knowledge is that harvest or disturbance of lead animals during 

migration can divert or delay an entire herd, although the Iñupiat have strong cultural traditions and 

success discouraging this. Hunters who would use the road would likely have greater success than those 

who would not, particularly during fall because the road extends into the edge of the Teshekpuk Herd’s 

high-use fall migration corridor. Using the road would likely allow those hunters to reach the herd earlier, 

perhaps before other members travel further eastward and are accessible to river-based hunters. 
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Increased hunting pressure could exacerbate the localized deflection of animals that may already occur 

from drilling noise, aircraft traffic, the road itself, and industrial traffic and activities on the road and pad. 

Particularly because the Teshekpuk Herd does not need to cross the road to migrate to other areas, animals 

from the herd would likely be deflected to routes further west and south and away from areas closer to the 

Colville River and Nuiqsut, where they are traditionally harvested. Hunters who would not use the road 

would therefore be at a distinct disadvantage; this would be particularly true for hunters who do not own 

four-wheelers and who largely hunt caribou in the fall along rivers by boat. In effect, the road may create 

a situation where hunters feel forced to use it to ensure adequate harvests and, if they are not able to use 

it, they may be waiting for animals to migrate towards the Colville River with a road, traffic, and hunters 

on four-wheelers west of them potentially deflecting or delaying those animals. 

Deflection of Furbearers

Wolf and wolverine use area data show high overlapping use areas throughout the GMT2 area. One 

hundred percent of wolf and wolverine hunters reported use areas in the project area, more than any other 

resource. Residents have indicated that furbearers such as wolf and wolverine are particularly sensitive to 

development activities and noise (SRB&A 2009b, 2010a). Deflection of furbearers from the GMT2 area 

would likely cause hunters to travel farther looking for these resources. 

As noted above, hunting for wolves and wolverines is an important cultural and economic activity for 

Nuiqsut and one of the few subsistence activities feasible in the wintertime. Residents of Nuiqsut have 

pointed out the particular importance of the GMT2 area (then known as CD7) for wolf and wolverine 

hunting since permitting for the ASDP began (BLM 2003). 

Deflection of furbearers from the GMT2 area, or direct overlap of normal trap lines, will cause hunters 

and trappers to travel farther looking for these resources. Because these activities occur during winter, 

traveling further in extreme cold presents additional risks for these subsistence users. 

Community Participation

The potential decrease in or substantially altered nature of use of the GMT2 Project study area for 

subsistence purposes may reduce the opportunity to transmit traditional knowledge to younger 

generations about that traditional use area. The project could also alter hunting methods, not just use 

areas. If younger hunters become more accustomed to roadside hunting and less accustomed to longer 

trips on the land, this could potentially affect the Nuiqsut Cultural Landscape (Brown 1979) due to 

reduced use of an area and subsequent loss of knowledge of that area.

Alternative C: Drilling and Operations Phases

Alternative C is the limited access, year-round drilling GMT2 alternative under consideration. Under 

Alternative C, there would be pipelines but no gravel road connecting the GMT2 drill pad to GMT1 and 

the Alpine Field. Access to the GMT2 Project would be by aircraft and, during the winter, by annually

constructed ice roads. 

Alternative C would have a larger gravel footprint because a 47.3-acre airstrip and apron would be 

required. Alternative C would also require an occupied structure pad for material storage and personnel 

housing. A new mud plant and bulk cement facility would be required for year-round drilling because the 

existing plant at CD1/Alpine Processing Facility must remain in place to service drilling operations at the 

other satellites. On-site wastewater and solid waste treatment or management would be required in 

addition to numerous additional facilities (see Section 2.7.3). 

This alternative would result in greater amounts of water withdrawn to construct the ice roads (691 

million gallons over the life of the project as compared to 395 million gallons under Alternative A). 

Alternative C would also increase the amount of heavy industrial traffic during the winter. 
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User Access and Avoidance

After construction, to access the drill site by vehicle, a 7.0-mile ice road would be constructed each year 

from the GMT1 drill pad to GMT2. Hunter use patterns in this area during the winter months could be 

impacted by disturbance and displacement of resources during construction of the ice roads for operation. 

When drilling begins, ongoing vehicle traffic along the ice roads from GMT1 to GMT2 would be at levels 

greatly reduced from the two previous construction years. However, lack of permanent (year-round) 

gravel road access would increase the amount of industry traffic on the ice road needed to support drilling 

and operations, and this concentrated industrial traffic could deter subsistence uses. 

Under Alternative C, there would be no impacts to access from a high gravel road that is difficult to cross 

for subsistence users traveling overland by snowmachine or four-wheeler. There would be no year-round 

facilitated access via road vehicle to the surrounding subsistence use area because there would be no 

permanent road. If there were few barriers to using the ice road, residents would potentially benefit from 

use of the annual winter ice road to facilitate access to the area. Physical barriers to access under 

Alternative C would be limited to any restrictions on use of the ice road, areas where the pipeline is 

drifted with snow, the larger pad(s) and airstrip and the corresponding larger safety area (approximately 

920 acres) where access and discharge of firearms are prohibited by industry safety guidelines. 

Air Traffic

As described above, air traffic is the most frequently cited impact of development by Nuiqsut hunters. 

Alternative C would result in increased air traffic in the GMT2 Project area, and most importantly would 

result in larger, fixed-wing flights taking off and landing at GMT2 (whereas under Alternatives A and B 

all additional fixed-wing flights would continue to land at and take off from Alpine). A complete table of 

flight numbers is provided in Appendix B. Estimated flight numbers for Alternative C are:

• During drilling Years 4–10 and 23 years of operation, 143 new helicopter flights per year at GMT2

• During drilling Years 4–10, 1,210 new fixed-wing flights at GMT2

• During 23 years of operation, 270 new fixed-wing flights at GMT2

Subsistence users would experience increased levels of disturbance from air traffic during operation of 

GMT2 facilities under this alternative as compared to Alternatives A and B.

Avoidance 

The presence of the pipeline, the larger pad(s), the new airstrip, larger restricted safety area, increased 

aircraft traffic and increased human presence at the GMT2 site under Alternative C would likely 

contribute to hunter avoidance of the area. Factors that may decrease avoidance compared to Alternatives 

A and B include the lack of road traffic in the summer and fall and the associated road dust and human 

presence that hunters may prefer to avoid. Hunter avoidance may result in lost harvest opportunities and 

changing use patterns.

Resource Availability

Under Alternative C, there would be fewer physical barriers, particularly the high, linear infrastructure 

presented by a permanent gravel road, inhibiting caribou movement through the area. There would be 

increased aircraft traffic, which has the potential to disturb animal movements at least on a localized scale 

that makes harvesting them more difficult. On the seasonal ice roads, vehicle traffic disturbances could 

occur to wildlife and subsistence resources. Activity levels during winter use are greater than Alternatives 

A and B, and may be more distracting to Nuiqsut hunters who may continue to access the area using 

traditional overland methods, such as snowmachines, during the winter.
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Community Participation

The potential decrease in or substantially altered nature of use of the GMT2 Project study area for 

subsistence purposes may reduce the opportunity to transmit traditional knowledge to younger 

generations about that traditional use area. 

Alternative D: No Action (Construction, Drilling, and Operations) 

Under Alternative D, the no-action alternative, the GMT2 Project and associated infrastructure and 

activities would not be permitted. Therefore, no additional adverse effects or impacts to subsistence 

would be anticipated to occur under Alternative D. 

Lease Stipulations and Best Management Practices

Every record of decision for an NPR-A Integrated Activity Plan and/or EIS released since 1998 has 

established that exploration, development, and production of oil and gas resources will be conducted in a 

manner that prevents unreasonable conflicts between industry and subsistence activities (BLM 1998, 

2004, 2008, 2013, 2015). While recognizing that oil development has had and will continue to have 

impacts, BLM’s objectives are to protect subsistence uses and access to traditional subsistence hunting 

and fishing areas and minimize the impact of oil and gas activities on the air, land, water, fish, and 

wildlife. 

The magnitude of many of the impacts discussed in this section would likely be reduced through the 

continued application of previously established mitigation measures and the implementation of new 

mitigation measures. Best management practices and lease stipulations in the NPR-A seek to protect 

specific resources and subsistence practices with approaches that include:

• Establishing spatial buffer zones around facilities and infrastructure.

• Scheduling disruptive activities when there is the least potential for conflict with other users.

• Including community residents in project planning.

• Monitoring impacts on subsistence resources.

• Making efforts to minimize the interference of oil and gas exploration and development activities and 

structures with subsistence resources and users. 

The BLM recognizes that numerous impacts to subsistence are unavoidable and adverse: they are impacts 

that persist despite traditional mitigation measures. Helicopter traffic is the most commonly reported 

disturbance to subsistence in many surveys. However, BLM specialists have confirmed through 

computer-assisted analysis of public meeting transcripts (see Section 4.4.2), interviews, government-togovernment consultation with the Native Village of Nuiqsut tribal council, and literature reviews that the 

primary unavoidable adverse impact to subsistence for residents of Nuiqsut is the loss of traditionally 

used subsistence areas. 

Stipulations and Best Management Practices on Subsistence Species

Many of the protective measures established in previous NPR-A EIS records of decision are intended to 

minimize the surface impacts of oil and gas activities and to otherwise ensure the continued health of 

wildlife and subsistence resources. For a complete description of the measures under Alternative A that 

are designed to mitigate impacts to fish, see Section 4.3.2, “Fish.” Measures designed to protect birds are 

described in Section 4.3.3, “Birds,” and measures designed to protect marine mammals are described in 

Section 4.3.4, “Mammals.” Measures that are particularly relevant to subsistence species include:

• A-4 minimizes the impacts of contaminants on fish, wildlife, and the environment.
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• A-11 mandates the design and implementation of a study to monitor contaminants in subsistence 

foods for all permanent development. 

• Measures that would minimize disruption of caribou in the GMT2 Project study area include E-7, 

which dictates pipeline height at a minimum of 7 feet and a minimum distance of 500 feet between 

roads and pipelines and K-6, which establishes a buffer zone within 1 mile of the coast.

• To protect fish habitat, B-1 and B-2 regulate water withdrawals and C-2 to C-4 protect streams and 

prevent additional freeze down of deep-water pools.

• K-1 establishes a 3-mile setback along the lower Fish Creek, a 0.5-mile setback from Judy Creek, and 

a 0.5-mile setback from the Tinmiaqsigvik (Ublutuoch) River.

• E-10 minimizes the chances that migrating waterfowl will strike oil and gas facilities during low light 

conditions.

• K-2 prohibits permanent infrastructure within 0.25 mile of deep water lakes. 

Stipulations and Best Management Practices on Avoiding Conflict

Many protective measures are explicitly aimed at minimizing conflicts between subsistence users and oil 

and gas activities. Setbacks for development on subsistence rivers are an important measure to protect 

many traditionally used areas. These stipulations are intended to prohibit permanent oil and gas facilities 

(e.g., gravel pads, roads, and airstrips and pipelines) within the buffer zone. BMP H-2 is intended to 

prevent unreasonable conflict between subsistence activities and seismic exploration by mandating that an 

applicant for seismic exploration shall notify local search and rescue operations of current and recent 

seismic surveys and shall notify in writing all potentially affected cabin and camp users. BMP I-1 requires 

lessees to provide cultural orientation for all oil and gas workers to minimize cultural and resource 

conflicts with local inhabitants. Lease stipulation K-6, mentioned above as a measure to reduce impacts to 

caribou, is also designed to reduce conflict by implementing a setback of 1 mile from the coastline and by 

mandating the use of previously occupied sites for industrial development whenever possible. 

A measure that is particularly relevant to subsistence harvest patterns involved with the GMT2 Project is 

BMP E-1, which requires that all roads be designed to protect subsistence use and access to traditional 

hunting and fishing areas. Several subsistence users experienced significant access issues with the CD5 

road in recent years because the road was too high and too steep for hunters to cross with snowmachines 

or all-terrain vehicles. BMP E-1 is a particularly significant measure for the GMT2 Project because the 

road route (in Alternatives A and B) will transect several main travel routes between Nuiqsut and areas to 

the northwest, and subsistence access will have to be assured. One way that access would be provided 

under those alternatives would be via the GMT1–GMT2 Access Road itself (using the Kuukpik Spur 

Road to gain access to the CD-5 and GMT1 roads). However, the design of the road will have to allow for 

access by subsistence users who need to cross it or need to descend from and ascend onto the road. The 

construction of ramps concurrent with the construction of the road (under Alternatives A and B) should 

minimize this problem initially. However, the ramps will concentrate off-road vehicle use because they 

will be the only way on and off the elevated roadway. While snowmachine users may not experience 

problems during the winter, repeated passes by four wheelers during the spring snow thaw and in the 

summer months would likely result in trail braiding, breaking the tundra mat and exposing the frozen soil 

with potential localized permafrost thawing and thermokarsting near the ramps, making the area 

impassible. The four wheeler trails spoking away from the ramp areas would be susceptible to trail 

braiding from repeated vehicle passes until far enough away from the access ramp to disperse four 

wheeler use cross-country. Over time, hardening to allow continued use for subsistence access around the 

access ramps would possibly need to be considered.
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Related measures that reduce conflict over subsistence uses and access are E-2, E-3, E-6, and E-8, which 

maintain subsistence use and access to traditional subsistence fishing sites. H-3 prohibits hunting and 

trapping by lessee or permittee employees and contractors while those individuals are on work status.

Aircraft Traffic Mitigations

As described above and in Appendix K, disturbance from aircraft is one of the greatest impacts to 

subsistence users. The numbers of flights anticipated for GMT2 show that Alternatives A and B will result 

in a greater number of flights than are currently occurring in the area. Because disturbance from aircraft 

will increase under all GMT2 alternatives and cumulatively from other activities in the area, the BLM 

anticipates that concern over the inability to significantly reduce the number of flights will increase. 

BLM, industry, and other permitted aviation users must therefore increase efforts to reduce the number of 

flights needed and the disturbance those flights cause. 

By mandating minimum flight altitudes for industry and research, BMP F-1 mitigates the effects the lowflying aircraft on wildlife. This is effective when practicable and when obeyed; however, enforcement is 

not feasible. Furthermore, the BLM has no authority over private aircraft or aircraft used by projects that 

do not have BLM permits; these private aircraft have frequently been the source of reported impacts by 

hunters (SRB&A 2010b, 2011, 2012, 2013b, 2014, 2015, 2016, 2017a). BLM-chartered aircraft and 

aircraft use by BLM permittees accounts for a small percentage of the aircraft use in the NPR-A; 

therefore, the BLM is not able to effectively mitigate the wider problem. In the Nuiqsut area, a large 

percentage of flights are accounted for by ConocoPhillips, but the flights are necessary to meet required 

lease stipulations (e.g., ecological monitoring). The mitigation measures that the BLM has implemented 

in the past are not experienced as completely effective for the community of Nuiqsut because the aviation 

impacts are cumulative: there are comparable levels of aircraft traffic around Nuiqsut on non-federally 

managed land and on federally managed land where increasing development exploration activities have 

consistently required more aircraft traffic. 

As the GMT2 applicant and primary oil development company in the Nuiqsut area, ConocoPhillips 

management has made substantial efforts to mitigate these impacts by coordinating some helicopter-based 

studies with other regional oil development companies, by establishing dedicated ice road cleanup crews 

and modifying the ice road cleanup program to reduce helicopter flights, by implementing a daily call in 

service that allows people to listen to updates on aircraft activity, and by providing a weekly summary of 

helicopter activity that they share with stakeholders. The effectiveness of these measures and other new 

aviation mitigation measures will continue to be evaluated throughout the life of the project.

NPR-A Subsistence Advisory Panel

BMP H-1, which established the NPR-A Subsistence Advisory Panel in 1998, was designed to prevent 

unreasonable conflicts between subsistence uses and oil and gas development by requiring that, before 

submitting an application to BLM, a prospective lessee/permittee consult directly with affected 

communities to discuss the timing, location, and methods of their proposed activities. According to the 

BMP, oil companies must document consultation efforts as part of the plan of operation and must submit 

the plan of operations to the NPR-A Subsistence Advisory Panel for review and comment (sufficiently 

early to provide time for review by Subsistence Advisory Panel members and those members’ Native 

Tribal Governments and, if necessary, for government-to-government consultation between the BLM and 

the Tribal Government). Among other items, the operations plan must describe methods the applicant will 

use to monitor the effects of the activity on subsistence and must describe how the applicant will keep 

potentially affected individuals and communities up-to-date on the activities and locations of possible 

conflicts with subsistence users. 

Subsistence Advisory Panel meetings were public and were held in all NPR-A communities on a rotating 

basis from 1998-2016 (meetings are currently on hold). The Subsistence Advisory Panel meetings ensured
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that BLM management maintained regular communication and outreach with residents and that residents 

are notified of upcoming activities in their areas. BLM maintains a spreadsheet of the recommendations 

that the Subsistence Advisory Panel has made throughout the years and BLM responses to those 

recommendations. The BLM implemented nearly all the recommendations made by the Subsistence 

Advisory Panel that it had the authority to implement. In 2010, the Subsistence Advisory Panel expanded 

its purview to include reviewing science and research-based permitted projects. Since 2011, in response to 

a Subsistence Advisory Panel request, the BLM produces a spreadsheet of each permitted project in the 

NPR-A in a calendar year for distribution. The BLM produced transcripts of each meeting and a summary

of the presentations and concerns. The summaries (along with notices for meetings) were distributed to a

broad email list of about 250 North Slope residents. In summary, the Subsistence Advisory Panel was

effective at maintaining a minimum of dialogue, at assuring that many residents are aware of activities 

that are being permitted, and at familiarizing Subsistence Advisory Panel representatives with the NEPA

process. 

The effectiveness of the Subsistence Advisory Panel was limited by several factors that are shared by

most similar subsistence advisory boards, which have a long history on the North Slope. Residents have a 

hard time keeping the numerous boards straight and some tend to lump all of them (whether state, federal,

or regional) together. Some residents treat all public hearings as an opportunity to voice a wide range of

concerns, whether or not they are project-specific or matters for which the agency holding the meeting is 

responsible (RFSUNY 1984, BLM SAP 2016). Frustration is a persistent issue because a large percentage 

of the long-standing recommendations and concerns that the Subsistence Advisory Panel and residents 

have are matters that the BLM has no authority on which to act. 

The BLM was able to respond effectively to a long-standing community request by establishing a BLM 

Arctic District Office Utqiagvik (formerly Barrow) Field Station staffed by a local Inupiaq subsistence 

hunter. This position is currently held by a natural resource specialist. The natural resource specialist is 

able to communicate local concerns to BLM management and explain land management decisions and 

ongoing development permitting projects to local residents. They provide translation services at BLM 

North Slope meetings and has invaluable knowledge of the land and resources of the North Slope. They

have relations with most residents of the North Slope and have served on numerous government and 

subsistence panels throughout their career. A potential new mitigation measure that would establish a 

BLM office in Nuiqsut, which has been requested by residents, is described in Section 4.4.2.5. 

4.4.5.6 Mitigation

Existing Mitigation Fund Programs

In determining whether it is appropriate to consider compensatory mitigation for any impacts that are 

expected to persist after the adoption of measures that are aimed at avoiding or reducing such impacts, the

BLM will take into account other compensatory mitigation programs that are applicable to the project and 

project area, including the U.S. Army Corps of Engineers’ compensatory mitigation program under 

section 404 of the Clean Water Act and the State of Alaska’s NPR-A Impact Mitigation Grant Program 

funded from the State of Alaska’s 50 percent share of federal oil and gas revenues from NPR-A pursuant 

to 42 U.S.C.§6506a(l). Under the NPR-A Impact Mitigation Grant Program, the State uses its share of

NPR-A revenues to grant funds to communities in or near NPR-A to pay for projects that address residual 

impacts of oil and gas development in NPR-A to their communities per AS 37.05.530. To date, the State

has awarded over $140 million in funding for such projects. This amount is anticipated to increase 

substantially going forward as production of federal oil comes online. 
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State of Alaska NPR-A Impact Mitigation Program 

NPR-A revenues are paid to the U.S. Treasury, which then pays 50 percent of the revenues to the State of 

Alaska for the NPR-A Impact Mitigation Fund, managed by the State of Alaska Department of 

Commerce, Community and Economic Development. The NPR-A Impact Mitigation Grant Program is 

managed under Alaska Statute AS 37.05.530 which requires annual reports to the Alaska Legislature, 

including the history of the program and a list of all the grantees, projects, and amounts granted by the 

State since the program began receiving money in fiscal year 1983. The federal government has no ability 

to influence the management of the fund or State-run grant program. Activities that are eligible to receive 

NPR-A grant funding from the State are limited to three categories: (1) planning; (2) construction, 

maintenance, and operation of essential public facilities; and (3) other necessary public services provided 

by a municipality. Many subsistence projects are funded as “planning” or as “other necessary public 

services.” Fund levels change every year because they are based on lease sales and production royalties.

Priority is given to those communities most directly or severely impacted by oil and gas development. 

This has historically meant those communities located within the NPR-A (Utqiagvik, Atqasuk, Nuiqsut, 

Anaktuvuk Pass, and Wainwright). Because the North Slope Borough is an umbrella organization that has 

received and distributed a significant percentage of this grant money, all the North Slope Borough 

communities benefit, including Kaktovik, Point Lay, and Point Hope. Tribal governments are not 

municipalities and are not qualified to submit applications to the State of Alaska-administered NPR-A 

Impact Mitigation Grant Program. 

The State of Alaska Division of Community and Regional Affairs has an application selection committee 

made up of three people familiar with issues in NPR-A communities. This committee scores and ranks the 

proposals, and provides that list to its commissioner for a determination on which projects to fund. 

Examples of North Slope projects funded by NPR-A impact mitigation funds include: 

• Natural gas distribution system in Nuiqsut

• Renovation of community centers

• Gravel acquisition for Colville River Access Road

• Piuraagvik Recreation Center addition in Utqiaaigvik

• Village power plants/electrical distribution

• Police officers in villages

• Upgrades to search and rescue equipment

As described in Section 3.4.4, “Economy,” the City of Nuiqsut has had its award grants suspended in 

response to uncompleted audits for fiscal years 2012, 2013, and 2014. However, the City of Nuiqsut and 

the State have resolved past issues as indicated by disbursements of fiscal year 2017 grants and the 

substantial grant recommendation for fiscal year 2019. The City administrator indicated that “after a long 

period of NPR-A Impact Mitigation Program underfunding relative to the rapidly increasing impacts of 

oil and gas exploration and development within the Nuiqsut area, which had not allowed the City to grow 

its capacity to sufficiently address associated issues, the City has recently moved forward with a planning 

initiative to develop the administrative systems necessary to manage these impacts” (Arnold 2018).

ConocoPhillips estimates that, over the lifetimes of the two projects, royalties from GMT1 and GMT2 (if 

GMT2 is permitted and sanctioned) will result in an estimated $350 million available to the State of 

Alaska NPR-A Impact Mitigation Fund (ConocoPhillips 2016).
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ConocoPhillips Subsistence Mitigation

As part of the North Slope Borough’s permit for ConocoPhillips’s development of CD4, ConocoPhillips 

established a fund to mitigate subsistence impacts on local residents. The fund was managed by the North 

Slope Borough with assistance from representatives of the City of Nuiqsut, the Native Village of Nuiqsut,

and the Kuukpik Corporation. The North Slope Borough CD4 permit required annual payments of 

$50,000 for 10 years and the last payment was made in 2013 (ConocoPhillips 2014).

In 2008, as part of an agreement with the Kuukpik Corporation “to progress NPR-A activities including 

CD5 and GMT1,” ConocoPhillips agreed to make annual payments to a mitigation fund administered by 

a joint committee of the City of Nuiqsut, the Native Village of Nuiqsut, and Kuukpik Corporation of 

$50,000 per year per Alpine satellite pad in the NPR-A and for the Nigliq Channel bridge (ConocoPhillips 

2014). These funds are distributed in the form of fuel vouchers and household payments. ConocoPhillips 

reports that from 2017–2050, Kuukpik Subsistence Mitigation payments (including payments for CD5) 

will total $10.5 million (ConocoPhillips 2016). 

GMT1 Compensatory Mitigation Fund

With the 2015 record of decision permitting the GMT1 Project, the BLM required the permittee to 

contribute $8 million to the BLM to establish a compensatory mitigation fund to offset identified impacts. 

As established by the measure, ConocoPhillips contributed $1 million within 60 days of the record of 

decision being issued for the development and implementation of a landscape-level Regional Mitigation 

Strategy for the Northeastern NPR-A Region. The BLM has completed a Regional Mitigation Strategy for 

the NE NPR-A that is consistent with current DOI mitigation guidance. Two additional contributions 

totaling $7 million have been contributed to the fund itself ($3.5 million within 30 days after installation 

of first gravel and $3.5 million within 30 days of completion of road, pad, and pipeline). The Nuiqsut 

Trilateral Committee on GMT1 compensatory mitigation funds finalized an implementation plan for the 

first $3.5 million in early 2017 and ConocoPhillips contributed the first installment in February 2017. The 

Nuiqsut Trilateral Committee on GMT1 compensatory mitigation funds finalized an implementation plan 

for the second $3.5 million in June 2018 and ConocoPhillips processed this final disbursement in July 

2018. Because all mitigation actions established by the Nuiqsut Trilateral Committee on GMT1 funds 

have not yet been fully put into place, it is not possible to evaluate their effectiveness at mitigating 

impacts at this time.

Other Mitigation 

ConocoPhillips also pays property taxes to the North Slope Borough, which are used by the Borough to 

finance schools, public services, training programs, planning, and wildlife management. Based on the 

approach described in Section 4.4.4, “Economy,” it is estimated that the proposed GMT2 Project would 

generate total property tax revenue to the North Slope Borough of $209 million (in 2015 dollars) through 

2050. 

Both Kuukpik Corporation and Arctic Slope Regional Corporation would benefit economically from 

development of GMT2, and these earnings could result in continued or larger dividends paid to 

shareholders. As a regional Native Corporation, Arctic Slope Regional Corporation must, according to 

sections 7i and 7j of Alaska Native Claims Settlement Act, share a portion of the royalties it receives from 

the petroleum produced from lands where it has subsurface ownership with other Alaska Native Claims 

Settlement Act regional Native corporations. Thus, development of GMT2 would benefit all Alaska 

Natives to the extent that they benefit from financial earnings of their regional Alaska Native Claims 

Settlement Act corporations. 
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Suggested Mitigation Measures that the BLM Will Not Implement for GMT2

Federal agencies are not generally required to adopt mitigation. The standard the BLM must follow 

regarding what new potential mitigation measures must be considered and evaluated in an EIS is found in 

the BLM NEPA Handbook Q&A, number 19(b). This standard provides that all relevant and reasonable 

mitigation measures that could improve the project should be identified if they are within jurisdiction of 

the agency. If the BLM finds that a potential mitigation measure is not within BLM’s jurisdiction to 

implement, or should not be implemented for some other reason, the measure would not be adopted in the 

record of decisionfor the GMT2 project. The record of decision will contain a section in its appendix for 

“Potential Mitigation Measures Not Adopted,” which will document the BLM’s rationale for not adopting 

them. 

The primary mitigation measure supported by Nuiqsut hunters is to lower the height of the GMT2 Access 

Road. However, the design of the road is required to support industrial traffic with the smallest practicable 

footprint, which results in a high, steep-sided road. In addition, several feet of gravel are required to 

insulate the tundra and permafrost underneath the road to prevent settling. The BLM is establishing a new 

mitigation measure (see Potential Mitigation Measure 7, below) that will require industry to consult with 

residents on the location and design of the subsistence access ramps that would be constructed as part of 

the GMT2 road.

Another long-standing subsistence concern that the BLM has limited or no authority to act on is allowing 

people who have Native allotments in areas impacted by oil development to select new allotments in other 

areas. Such an action would require an Act of Congress; thus, the BLM has no jurisdiction to implement 

such a program.

Potential Mitigation Measures

In addition to the lease stipulations and best management practices that apply to all oil and gas activities 

in the NPR-A established by the NPR-A Integrated Activity Plan/EIS (BLM 2013), an extensive set of 

subsistence mitigation measures for the GMT1 project was established with the 2015 GMT1 Record of 

Decision. Similar mitigation measures are proposed for GMT2 and additional potential mitigation 

measures have been developed through consultation with stakeholders or proposed via input on the Draft 

SEIS for GMT2. 

Potential Mitigation Measure 1: GMT2 Road Right of Access Agreement 

Objective: Ensure that residents will have the right to use the GMT2 Access Road throughout the life of 

the project and ensure that residents are aware of the policies regarding use of project-associated roads for 

subsistence activities to reduce misunderstandings and ensure the safety of project workers and local 

residents using the roads. 

Requirement/Standard: The permittee will produce a clear and legally binding right of access 

agreement that 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 insure that this agreement is disseminated throughout the community. The permittee will 

also include a presentation on the agreement in its employee orientation, will ensure that sub-contractors 

have the agreement for their employee orientation, and will post the agreement on the road itself. The 

agreement 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.
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Potential Mitigation Measure 2: Suspend Non-essential Helicopter Traffic during Peak Caribou 

Hunting Season

Objective: To reduce the impacts of helicopter traffic on Nuiqsut caribou hunters.

Requirement/Standard: Via ongoing 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 1-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. The consultation results should be documented, distributed to the BLM and other 

stakeholders, and clearly identify actions to be implemented based on the consultation. 

• 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.

• Suspension dates can be revised every 3 years upon review of peak caribou season.

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.

Potential Mitigation Measure 3: Consultation Regarding Aircraft Communication Protocols

Objective: Ensure that current communication protocols related to 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.

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 and confirmation that existing minimum altitude requirements 

are adequate. The consultation results should be documented, distributed to the BLM and other 

stakeholders, and clearly identify actions to be implemented based on the consultation.

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.

Potential Mitigation Measure 4: Aircraft Monitoring Data Requirements

Objective: Monitor aircraft patterns and the impacts of aircraft associated with the GMT2 Project on 

subsistence hunting activities in the project area.

Requirement/Standard: Permittee will be responsible for funding and providing data to the BLM for a 

monitoring study of aircraft flight patterns and impacts related to aircraft traffic on subsistence activities. 

The permittee will provide the BLM with data from the monitoring study in a manner that facilitates 

meaningful analysis of activities and impacts.

The permittee will provide the BLM with clear and detailed quarterly flight reports that include the 

timing, flight path, and purpose of each flight in the project area. 
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The reports will highlight all flights that represent deviations from BLM’s best management practices and 

include explanations for any deviations. 

The permittee will provide data related to altitude of flights patterns. Noise data associated with altitudes 

will be cross-referenced to determine minimum altitudes for flights in the project area, to reduce impacts 

on wildlife and subsistence activities.

The aircraft monitoring plan will differentiate to the greatest degree practicable between the various 

purposes of flights (i.e., flights that are conducted for exploratory drilling operations, offshore pipeline 

baseline studies, and other scientific research broken down by species and researcher).

Reports will include statistical analyses on flight patterns, including how often actual flights and patterns 

deviate from the flight plan currently submitted to the BLM under existing BMP F-1.

Monitoring undertaken to provide baseline data or to monitor effectiveness of mitigation measures must 

meet the approval of the authorized officer. As the authorized officer deems it appropriate, the data 

collection process and product shall be consistent with standards established by BLM’s Assessment, 

Inventory, and Monitoring Program. 

Background, Potential Benefits, and Residual/Unavoidable Impacts: Improved monitoring and 

analysis of flights, flight purposes, and other flight patterns will assist the BLM to estimate the impacts of 

proposed actions or to formulate appropriate plans to reduce impacts. A monitoring study would provide a 

better understanding of how many aircraft are being used for different purposes, whether and how 

industry could reduce flights, and how aircraft and flight altitude affect subsistence activities and wildlife 

and in the project area. It is anticipated that such a monitoring plan will be significantly useful for the 

permittee and could direct the permittee to greater cost savings and efficiencies. It is anticipated that if 

aircraft traffic is not the reason for failed hunts, such a plan may be able to substantiate that. Data 

collected from this study will help the BLM to adapt management decisions to changing conditions and 

circumstances and make better decisions for future research studies and development projects in the NPRA.

Potential Mitigation Measure 5: 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). The permittee will consult with the authorized agency every 3 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 managed by the BLM in the Nuiqsut area, 

where much of the disturbance from aircraft occurs.
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Potential Mitigation Measure 6: Subsistence Monitoring Studies

Objective: Monitor the impacts of GMT2 development on subsistence patterns, harvests, and associated 

subsistence activities for the community of Nuiqsut.

Requirement/Standard: 

1). Initially (one time), the permittee will provide for an all-resources subsistence mapping study to 

document contemporary subsistence use patterns for Nuiqsut.

Potential Benefits and Residual/Unavoidable Impacts: The 2010 BOEM mapping study for all subsistence 

resources (SRB&A 2010a) has been valuable for this SEIS and several other North Slope analyses. The 

2010 mapping study is based on data collected 1995-2006, thus the data is 12 years old and might not 

reflect changes that have occurred since 2006 or reliably confirm continuity. The one time initial mapping 

study will include all resources. The decadal interim will provide a comprehensive overview of any 

changes in subsistence use patterns during a period of development expansion near the community. 

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 input from the community 

and will identify changes resulting from the proposed project including cumulative effects, and, 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 the Data Review and Information Dissemination mitigation measure (Section 

4.4.2.5). 

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 reports will be edited according to the NSB DWM peer review and the 

subsequent draft report will be provided simultaneously to the permittee and, when appropriate, to a local 

resource panel (e.g., the Nuiqsut Caribou Panel). The contractor will incorporate comments from both 

entities before releasing a final report. 

Potential Benefits and Residual/Unavoidable Impacts: 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.
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Potential Mitigation Measure 7: 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 hold a 

public workshop in Nuiqsut to gather input regarding the location and design of the three road pullouts 

and associated access ramps. Information from the workshop will be used by the permittee to ensure that 

the pullouts are properly located along the road to maximize access for subsistence users. 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.

Once the road pullouts and access ramps have been designed, the permittee will post the design for public 

comment for 30 days. Input derived from the public workshop and comment period will be provided to 

the BLM and the Kuukpik Subsistence Oversight Panel (KSOP). Concurrence from KSOP on final 

location and design of the pullouts and ramps shall be obtained by the permittee.

At least once a year 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. 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.

Potential Mitigation Measure 8: Subsistence User Monitoring and Adaptive Management

Objective: Prevent or minimize unreasonable conflicts between subsistence users and permitted activities 

associated with construction, operation, and production at the GMT2 development.

Requirement/Standard: Permittee will work with the Native Village of Nuiqsut, the Kuukpik 

Subsistence Oversight Panel, and local hunters to create a Subsistence User Monitoring Plan. The plan 

will include documentation of current issues facing subsistence users regarding resource abundance, 

limitations on access, and resource availability resulting from GMT2 and associated activities, and 

including other permitted activities being carried out by the permittee in the NPR-A (i.e., exploration 

drilling, data collection, etc.). The plan will specify a set of key indicators to be monitored through the life 

of the GMT2 development, as well mechanisms identified by subsistence hunters that can be used to 

prevent, reduce, alleviate, or correct adverse effects. The monitoring plan will provide a framework for 

Nuiqsut entities, the permittee, and the BLM to adaptively manage impacts to subsistence users resulting 

from the development. The process for developing the monitoring plan must be approved by the Kuukpik 

Subsistence Oversight Panel, and the final plan must be approved by the Nuiqsut trilateral entities (NVN, 

Kuukpik Corporation, and City of Nuiqsut). 

Potential Benefits and Residual/Unavoidable Impacts: Current subsistence monitoring in Nuiqsut 

focuses on the subsistence harvest, namely the scope and amount of resources being harvested through 

time, and only peripherally documents issues being experienced by the users themselves. Local residents 
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have expressed frustration at the pace of development, the lack of in-depth data regarding impacts, and 

the inadequacy of back-to-back NEPA analyses in effectively describing and minimizing risk. 

Establishing a monitoring plan and program now at the beginning of development activities in NPR-A 

will help inform future analyses and development decisions. Combining the monitoring plan with

adaptive management actions will afford local residents a measure of control over subsistence uses. 

Potential Mitigation Measure 9: Prohibit Airboats in Key Subsistence Use Areas*

Objective: To reduce noise and disturbance impacts from airboats on subsistence resources, users, and 

activities.

Requirement/Standard: Except in the case of emergencies, oil spill response training, mobilization and 

deployment of pre-staged spill response equipment, and mobilization and response during a spill event,

the permittee and its contractors will be prohibited from using airboats on rivers on BLM-managed lands 

in the Nuiqsut subsistence use area (for this measure, defined as a 50-mile-wide buffer around the 

community). Through consultation with local residents, the BLM may identify other key boating areas 

that should be avoided. The Authorized Officer and the permittee will coordinate to identify specific 

areas/rivers where oil spill response training and preparation activities would be permitted by the BLM. 

Potential Benefits and Residual/Unavoidable Impacts: Prohibiting the use of airboats in places where 

residents are actively traveling by boat to harvest subsistence resources will reduce potential disruptions 

to subsistence users and resources. The sudden and loud noise of airboats causes acute stress situations for 

subsistence users, particularly the elderly. Residual issues could arise if local subsistence use of airboats 

increased (there is currently one airboat, not in use, in Nuiqsut). The BLM would not have the authority to 

implement this measure on lands not managed by the BLM, and it is therefore unlikely that hunters and 

other subsistence users will experience complete respite from airboat disturbance if the measure is not 

adopted by the permittee for other lands.

Potential Mitigation Measure 10: 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 make the map available on the 

website developed to comply with Sociocultural potential mitigation measure #1 (if that measure is 

adopted as a BMP in the ROD for GMT2) 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). 

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, if adopted, would only apply 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 40 miles of Nuiqsut.

4.4.5.7 Summary and Comparison of Alternatives

Potential impacts from development of GMT2 should be considered in the context of the baseline of 

impacts on subsistence for Nuiqsut that began shortly after the community was resettled in 1973. The 

final section of Chapter 3: Affected Environment: Subsistence (Section 3.4.6.5) summarizes the various 
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sources of impacts on subsistence in Nuiqsut over time and provides an assessment of current levels of 

subsistence impacts. That section describes that oil and gas development has been the primary source of 

impacts reported by Nuiqsut residents (SRB&A 2009). Harvest amounts and community participation 

have remained stable; these are signs of the resiliency of the Nuiqsut people in the face of change and the 

availability of resources within the community’s harvesting area. However, sustained harvests may occur 

in spite of increased impacts on subsistence – harvest amounts do not provide information on the amount 

of effort (e.g., hours and distance) taken to harvest resources, the areas used to harvest resources, the 

quality of the resources harvested, or hunters’ experiences on the land.

Nuiqsut subsistence use areas have shifted away from the Prudhoe Bay/Kuparuk areas (areas which were 

at one time considered part of the community’s area of “intensive use” [Brown 1979]), and avoidance—

along with physical barriers and security restrictions—has been cited as a primary reason for this shift. 

Changes in use areas have occurred at a smaller scale since oil and gas development began in the Colville 

River Delta. Caribou use area data indicate decreased use of the Middle Colville Delta and the Nigliq 

Channel in recent years, and increased use of the area to the west of Nuiqsut, changes which have been 

attributed, at least in part, to hunter avoidance of industry. At the same time, use area data show increased 

use of industry related roads. While roads can benefit certain subsistence users by providing easier access 

to hunting areas, they can also cause a shift away from the use of traditional hunting grounds and can 

introduce new impacts such as user avoidance and barriers to hunters and wildlife. 

A preliminary review of the Year 10 (2017) data indicate that reported harvester impacts rose to within the 

range of previous years. Recent years have shown a decrease in helicopter traffic impact reports and an 

increase in impacts related to manmade structures (e.g., roads and pipelines). A preliminary review of 

Year 10 data indicates an increase in reports of manmade structure impacts and “other traffic” impacts 

(e.g., trucks) which are related to the recent construction and operation of the Spur, CD5, and GMT1 

roads. 

Indirect impacts include user avoidance and changes in resource availability. Between 51 and 61 percent 

of harvesters have reported that there are areas they no longer use or avoid and, in most cases, 

development infrastructure or activities were cited as the cause. The most recent data (see Section 3.4.6.5) 

indicates an increase in reported avoidance: a similar number (but smaller percentage) of observations 

attributed the avoidance to development causes. Ultimately, harvester avoidance can result in decreased 

feelings of connection with a traditional use area and loss of knowledge about that area over time.

Nuiqsut harvesters have reported changes in caribou migration, distribution, and behavior resulting from 

development infrastructure (e.g., pipelines and roads) and activity (e.g., air and road traffic). To 

compensate for decreased resource availability in their hunting areas, some respondents report taking 

more frequent or longer hunting trips or have changed the geographic focus of their hunting activities (see 

Section 3.4.6.5).

Preliminary data from 2017 monitoring indicate a shift toward use of roads for subsistence, but also an 

increase in reported impacts associated with roads and road traffic. While some respondents view the road 

as a benefit which provides access to caribou hunting grounds, others believe the road and/or road hunters 

are reducing the availability of caribou in traditional areas west of the community. Some respondents 

reported using the road out of necessity, because the caribou were not available closer to the community. 

Members of the Nuiqsut Caribou Panel have recently reported impacts associated with developments to 

the west of the community, noting that caribou from the Teshekpuk Herd had approached the community 

in the fall/winter of 2017, but diverted back to the west as a result of the roads and activity in the area. 

These Nuiqsut hunters reported that the height and grade of the GMT1 road is too steep, resulting in 

difficulties for both caribou and hunters trying to cross it. In addition, hunters reported that the ramps are 

placed too far apart and are too narrow and steep (see Section 3.4.6.5). (Please note proposed new 
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mitigation measure 7 described above in Section 4.4.5.6 that would require the applicant to consult with 

the community on the design and locations of the ramps.)

Under Alternatives A, B, and C, development of GMT2 would result in direct and indirect impacts to 

Nuiqsut’s subsistence uses. Temporary and permanent infrastructure and associated activities would affect 

subsistence areas that are predominantly used for caribou and furbearer hunting, but also for geese 

hunting and fishing (see Section 3.4.5 Table 55). 

The types of impacts (e.g., impacts to a subsistence use area, restrictions on user access, user avoidance, 

and reduced resource availability) are similar to those identified for the Alpine Satellite Development 

Project (BLM 2004) and for GMT1 (BLM 2014). Impacts are associated with a 2- to 3-year construction 

phase, 7 years of drilling, and 23 years of routine operations. Direct and indirect impacts are expected to 

last at least 32 years (the total life of the project) although development further west that includes use of 

the GMT2 Access Road and pipeline system would extend the timeframe and intensity of many impacts. 

The GMT2 Project would introduce industrial infrastructure and activity into subsistence use areas 

west/southwest of the community, reducing the area in which residents can hunt and fish without the 

presence of nearby industrial infrastructure. This would be considered a substantial loss of traditional 

lands by many residents. The GMT2 Project would also, as discussed under Environmental Justice 

(Section 4.4.7) and Economy (Section 4.4.3), develop resources partly owned by and result in profits to 

Inupiaq entities, which, in addition to other mitigation described above, will benefit residents and hunters 

but will not eliminate these impacts. It is recognized that for the subsistence lifestyle to be healthy, there 

must be continued harvests (material value) at continued levels of traditional land use and identification 

with traditional land use areas.

Primary impacts during construction under all alternatives include restricted subsistence access, reduced 

availability of subsistence resources, hunter avoidance, and hunter disturbance by road and aircraft traffic. 

Primary impacts under Alternatives A and B during drilling and operation include varying effects on 

subsistence access and hunting patterns due to the permanent GMT2 road and impacts to resource 

availability due to the likelihood that caribou and furbearers will be deflected from areas where they are 

normally harvested. The anticipated effect of the GMT2 Access Road is that facilitated access may offset 

many adverse impacts, including direct overlap with a use area, impediments to overland travel, hunter 

avoidance (by hunters who cannot or chose not to use the road), eventual reduced feasibility of overland 

access during the summer and fall by four wheeler in areas near ramps due to tundra damage, hazards, 

dust, road and aircraft traffic, noise, emissions, ice fog, and localized deflection of caribou and furbearers. 

Alternative C would not include facilitated access via a permanent road, would require a substantially 

larger footprint, and would require the annual construction of ice roads. Alternative C would also result in 

greater emissions and increased air traffic in hunting areas west of the community, including a new source 

of fixed-wing air traffic that did not exist before. No North Slope stakeholders support this development 

scenario.

These impacts are not anticipated to affect all hunters equally, and these impacts are expected to change 

over the life of the project. In terms of overall impacts to subsistence uses, Alternative A would likely 

have the fewest impacts. Under Alternative A, less gravel would be required for construction of GMT2 

than either Alternative B or C and the road would be shorter than under Alternative B. Compared to 

Alternative C, Alternatives A and B would not require annual construction of ice roads during operations, 

would involve smaller increases in aircraft traffic, and would facilitate hunter access by road to the 

project area. 
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Input received from key stakeholders on the Draft SEIS for GMT2 included various perspectives on the 

overall potential for GMT2 to impact subsistence uses for the community of Nuiqsut. 

The North Slope Borough supports the project due to its many benefits but expresses numerous concerns 

about impacts to Nuiqsut, including deflection of resources from the Fish Creek area, hunter avoidance of 

developed areas (whether caribou are present or not), and the height of the GMT2 road. The NSB believes 

that the SEIS should highlight that, “the small community of Nuiqsut will likely suffer significant adverse 

impacts to subsistence as a result of the GMT2 project and cumulative past, present, and future 

developments in the area.” [ ] “In addition, it must be acknowledged that Nuiqsut residents have 

expressed for many years their growing concerns regarding the scope and pace of industrial development 

as it has expanded nearer to the community and within traditional subsistence harvest areas. It follows 

that what must be a paramount goal of all proponents of the GMT2 development is the avoidance, 

minimization and mitigation of impacts to Nuiqsut through all reasonable means, working in a partnership 

that extends beyond this project and includes all area industry operators, all responsible federal, state, and 

local government land, wildlife management, and social service agencies, organizations with relevant 

expertise and the community itself,” (NSB 2018).

ConocoPhillips acknowledges the potential for impacts, notes that the company has a long history of 

working to mitigate such impacts, asserts that the subsistence lifestyle in Nuiqsut is thriving, and 

“advocates for a fact-based perspective that GMT2 is not reasonably expected to have a significant 

adverse impact on subsistence,” (ConocoPhillips 2018 Appendix C). ConocoPhillips maintains that 

hunters have shifted hunting patterns towards the west not to avoid developed areas: “Rather, hunters go 

west because they can,” (ibid). ConocoPhillips notes that roads are increasing access to the west, that an 

increasing percentage of caribou is being harvested by road vehicles, that access by roads will decrease 

tundra damage by ATV, and that “[h]arvest numbers are healthy and even the cumulative effects of 

development do not indicate major impacts or significant restrictions,” (ibid). ConocoPhillips notes that 

the data do not indicate that Nuiqsut hunters need more time to harvest caribou and that the overlap of the 

GMT2 project area does not mean loss of the subsistence use area (ibid). ConocoPhillips also maintains

that the magnitude of the tendency for hunters to avoid areas due to development is overstated, and notes 

that the numbers of hunters harvesting within 2.5 miles of infrastructure is increasing (ibid). 

The Nuiqsut tribal government (Native Village of Nuiqsut) comments included a request to delay 

permitting of GMT2 and noted that the council has “significant concerns about how the GTM2 project 

will further compromise subsistence practices within the community. The development of GMT2 will 

reduce our subsistence use area and permanently impact where and how we hunt. This project will further 

deter resources like caribou and wolverine from coming close to the community, and force hunters to 

travel further to avoid infrastructure and the associated activities of development,” (Native Village of 

Nuiqsut 2018).

Kuukpik Corporation’s input is described above in the discussion of avoidance under Alternatives A and

B (Section 4.4.5.5): hunter avoidance and impacts from construction in a caribou migration corridor will 

likely be the primary impacts, but they may be partially offset by facilitated access via the road. Kuukpik 

also maintains that the potential for impacts on subsistence, and in particular the potential for impacts to 

decrease the critically important sharing of subsistence foods in Nuiqsut, is likely the greatest concern for 

residents. Kuukpik is deeply concerned about increasing access to the road/ice road/snow trail system in 

the Nuiqsut area by travelers from other areas of the North Slope and the potential for the GMT2 road to 

encourage that, possibly resulting in tundra damage from stuck vehicles and competition for subsistence 

resources. Kuukpik maintains that benefits of improved subsistence access for Nuiqsut are proven by the 

widespread and successful subsistence use of the Spur Road, which allows shorter, safer hunting trips. 

Kuukpik believes that benefits will only outweigh impacts if Nuiqsut receives adequate financial benefits 

and mitigation (Kuukpik 2018). 
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Appendix L of this document includes the final determinations for the evaluation of potential impacts to 

subsistence uses and needs for each of the four alternatives considered in the GMT2 Supplemental EIS as 

required under Section 810(a) of Alaska National Interest Lands Conservation Act (ANILCA) for any

federal action on public lands. The Alaska National Interest Lands Conservation Act Section 810 

evaluation found that development of GMT2 under any of the action alternatives may significantly restrict 

subsistence uses for the community of Nuiqsut and the cumulative scenario may significantly restrict 

subsistence uses for the communities of Nuiqsut due to the potential for the infrastructure and activities to 

deflect caribou and furbearers from areas where they are traditionally harvested. The cumulative scenario 

(see section 4.6.8.9) evaluates potential impacts to subsistence from a broad range of reasonably 

foreseeable development projects and climate change. That analysis found possible significant restrictions 

to subsistence uses for the communities of Nuiqsut,, Anaktuvuk Pass, Utqiagvik, and Atqasuk. Because of

those findings, public subsistence hearings were held in the potentially affected communities. Input from 

subsistence hunters gathered during those hearings, any additional new data on subsistence in Nuiqsut 

collected in the interim, and the effects of existing and potential new mitigation were considered in the 

final Alaska National Interest Lands Conservation Act Section 810 analysis. 

4.4.6 Public Health

The initial Alpine Satellite Development Plan Environmental Impact Statement (BLM 2004), which this 

current analysis supplements, did not include a public health analysis. The NPR-A Integrated Activity 

Plan (BLM 2012, Section 4.3.21) did include a broad analysis of potential impacts to public health in 

North Slope Borough and Northwest Arctic Borough from potential future oil and gas development in the 

NPR-A. The following discussion of potential impacts to human health and community welfare 

associated with the proposed development of GMT2 incorporates recent data and, where data are 

available, focuses on potential direct and indirect impacts of nearby oil development on the community of 

Nuiqsut. A more detailed description is in Appendix G: Baseline Human Health Summary GMT2 Project.

4.4.6.1 General Impacts to Public Heath 

Impacts to public health related to nearby oil development could occur due to changes in diet and 

nutrition, environmental exposures, infectious disease, acculturative stress, economic impacts, and the 

capacity of local health care services. An influx of outside workers could increase exposure to 

communicable diseases, although the probability is low because oil field workers are segregated from the 

community, other outsiders regularly travel in and out of Nuiqsut, and Nuiqsut residents travel in and out 

of town. Because of nearby oil development, Nuiqsut has a seasonal road connection to the Dalton 

Highway that leads to noticeable increases in the trafficking and use of alcohol and drugs (Paskewitz 

2014). That seasonal road connection also facilitates road travel for medical purposes and provides a 

potential alternate evacuation route. 

Economic security substantially reduces chronic stress and Nuiqsut, because of oil development, has a 

more secure economic base than most Native Alaska villages. In 2014, the estimated median household 

income in the NSB was $74,609; for Alaska it was $71,829 and for Nuiqsut, $85,883 (Table 2, Appendix 

G). This number includes both Inupiaq and non-Inupiaq household income. Economic indicators 

demonstrate 3% of Nuiqsut residents live below the poverty limit (U.S. Census ACS, 2014). Data on 

household income and its potential to reduce chronic stress must be considered in light of the cost of 

living in Nuiqsut. For example, food costs are between 23 times as high as food costs in Anchorage 

(North Slope Borough, 2016).

Numerous concerns that are predominantly related to subsistence hunting and fishing and the loss of 

undeveloped traditional subsistence use areas are described in Section 4.4.5. Several of those potential 

impacts either directly affect or are indirectly connected to public health in Nuiqsut. An example is the 
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potential increased risk of injury and accidents while on the land due to some hunters’ tendency to avoid

developed areas.

Although, instances where hunters utilize roads and infrastructure may help facilitate access to 

subsistence resources and indirectly mitigate potential impacts from injury and accidents, further 

described in Section 4.4.5.3 “Summary of Subsistence Uses of the GMT2 Project Area.”

Social issues for Nuiqsut are described in Section 4.4.2, “Sociocultural Systems,” and further explored in 

the cumulative effects analysis for sociocultural systems, Section 4.6.10.2. Many of those issues either 

directly affect or are indirectly connected to overall public health in Nuiqsut.

The Alaska Department of Fish and Game in 2015 conducted a comprehensive harvest study in Nuiqsut 

and found that 12 percent of Nuiqsut households worried about having enough food at one or more times 

during 2014. When compared to statewide percentages, Nuiqsut had a higher percentage of food secure 

households (90 percent) and lower very food insecure households (2 percent), compared to 2014 

estimates for the entire state (88 percent food secure, 4 percent very food insecure). A summary of general 

public health impacts associated with oil and gas activities is listed below. These potential impacts would 

be common to all action alternatives.

• Localized activity may impact subsistence hunting. Nuiqsut hunters who already avoid large 

areas of traditional land to the northeast of the village could experience further limitation in 

their access to lands to the west of the village if oil and gas development occurs there. 

Avoidance of subsistence hunting areas may affect access to subsistence resources, which 

could affect dietary and nutritional outcomes (BLM 2012, page 345).

• Noise from air traffic and other sources could also create a nuisance around individuals’ 

camps and cabins, possibly reducing their use as a base for subsistence harvests. 

• Fixed oil and gas production sites, particularly those near villages or in areas of heavy 

subsistence use (e.g., near rivers) may lead to avoidance by hunters. In turn, this could 

increase travel times and costs for subsistence activities, and could potentially decrease 

harvests and increase risk of injury and accidents.

• Community infrastructure has had several upgrades, including water and sewer projects 

funded by the NSB, in addition to electrical utilities and telecommunications (ACOE Point 

Thomson EIS, 2013)

• Utilizing natural gas supplied by Conoco Phillips Alaska, Inc., reduces community use of 

diesel

• Revenue from oil and gas development to the North Slope Borough and village corporations 

will provide continued funding of existing health and social programs and the preservation of 

the current high level of direct and indirect employment. 

• The NPR-A Impact Grant Fund has made available revenues from NPR-A lease sales, rentals, 

bonuses and royalties on leases issued to North Slope communities, including Nuiqsut. It is 

estimated that $165 million has been administered through the NPR-A Impact Grant Fund 

since 1987. The payments are made to the North Slope Borough and other North Slope 

communities for projects that range from funding local caribou monitoring efforts, 

purchasing gravel to build roads near Nuiqsut, funding local government services, improving 

community infrastructure (water, sewer, telecommunications), funding youth, workforce 

development and cultural programs, and more (DCCED 2015). 
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• New jobs for North Slope and Nuiqsut residents in the oil and gas sector will increase with oil 

and gas exploration and development activities.

4.4.6.2 Air Quality 

Nuiqsut residents’ primary public health concern regarding the GMT2 Project is air quality. Regular air 

quality monitoring, air quality models that predict emission levels likely to result from development, and 

several investigations of pollution and associated public health in Nuiqsut, have not found any evidence 

that air pollution levels exceed air quality standards or are causing negative health effects in Nuiqsut. The 

Alaska Department of Health and Social Services investigated air pollution and respiratory illness in 

Nuiqsut in response to community concerns in 2003 and 2012. In both studies, health data were collected 

from inpatient and outpatient visits for respiratory illness. For the 2012 study, air pollution data were 

collected from the ConocoPhillips monitoring station and reviewed by the Alaska Department of Health 

and Social Services. Air pollution was not found to be associated with respiratory illness in these 

investigations (Alaska Department of Health and Social Services 2003, 2012). 

Air quality modeling was conducted to assess both project-level impacts of the GMT2 Project as well as 

cumulative air quality impacts resulting from development within a 50 kilometer radius of GMT2. The 

modeling assessed emissions of criteria pollutants and hazardous air pollutants. Section Section 3.4.7.1 

for a description of these terms.

Air quality modeling conducted for the GMT2 Project found that all action alternatives were below 

applicable air quality standards for all project phases. No adverse impacts to human health are expected as 

a result of air pollutants emitted from GMT2 or surrounding development. Five common air toxics are 

assessed as part of the GMT2 analysis,. Table 4.4-6 shows the maximum predicted cancer risk as a result 

of GMT2 and surrounding development is just over 1 in 100 million (1.2E-08). For complete results of air 

quality modeling, see Section 4.2.3.2, “Air Quality.”

4.4.6.3 Construction

The Arctic Slope Regional Corporation Mine site is the proposed gravel source for all alternatives. The 

Arctic Slope Regional Corporation Mine site is an existing commercial gravel source on the East Channel 

of the Colville River, approximately 6 miles southeast of CD4, 21.0 miles east of GMT2, and 4.5 miles 

east-northeast of Nuiqsut. During the construction phase of GMT1, blasting at the Arctic Slope Regional 

Corporation Mine site for GMT1 gravel occurred on a daily basis for 42 days in winter 2017, and similar 

occurrences are expected for the construction of GMT2. Local residents also raised health and safety 

concerns about the increased overall industrial activity associated with construction so close to the 

community, especially the large amount of heavy equipment traffic from the Arctic Slope Regional 

Corporation Mine site to the location of the road and pad construction (Native Village of Nuiqsut

Consultation 2017). Impacts from construction are concentrated during the ice road season, from January 

to early May, and impacts resulting from gravel extraction occur during the first winter of construction.

4.4.6.4 Drilling and Operations

A frequent public health concern raised by local residents associated with the drilling and operations 

phase, other than impacts to air quality, is the possibility of an industrial disaster, such as a blowout, a 

fire, or a large-scale spill. 

4.4.6.5 Comparison of Alternatives

The majority of the impacts discussed above would be relevant for all GMT2 action alternatives. These 

impacts are primarily applicable to the community of Nuiqsut, the closest community to the proposed 

GMT2 Project. These impacts are similar to the impacts discussed in detail in the recent Point Thomson 
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Project Final EIS (U.S. Army Corps of Engineers 2012) and the GMT1 Supplemental EIS (BLM 2014). 

The draft supplemental EIS findings for GMT2 are that development of GMT2 would have no 

measurable impacts to water and sanitation and infectious disease; no measurable impacts to specific 

health issues related to accidents and injuries; and increased access to health care and facilities.

Most impacts discussed above for GMT2 Alternatives A and B are relevant for Alternative C. Alternative 

C would result in greater overall emissions of air pollution, and it would result in more vehicle traffic near 

the community for the life of the project due to construction of annual ice roads. The risk of vehicle 

accidents on access roads would be reduced during summers under this roadless alternative, but it is likely 

that equivalent risks are associated with use of the ice roads during the winter season. The increased air 

emissions anticipated under Alternative C (Section 4.2.3.2, “Air Quality”) due to the presence of 

additional power generation onsite and increased flights to GMT2 could potentially lead to increased 

adverse impacts to public health; however, emissions of air pollutants are not expected to exceed any 

applicable standard. Public health in Nuiqsut is inherently connected to the continuation of subsistence 

hunting and high levels of community participation in subsistence activities. Potential impacts to 

subsistence are discussed in Section 4.4.5. 

No changes from current public health conditions would be expected to result from Alternative D because 

no action would take place under this alternative. Cumulative effects are discussed in Section 4.6.10.9.

4.4.6.6 Mitigation

BLM (2012, Section 4.3.21.5) outlined several potential mitigation measures to minimize potential 

adverse health impacts associated with the alternatives of that NPR-A leasing plan. Mitigation measures 

implemented with the 2013 NPR-A Integrated Activity Plan Record of Decision include contaminant 

monitoring of subsistence species, providing air quality data to the North Slope Borough and local 

communities in a timely manner, and actions to minimize the negative effects of an oil spill on public 

health.

The BLM considered and applied new mitigation measures for public health in the GMT1 Supplemental 

EIS (BLM 2015), and it is recommended that similar supplemental best management practices be 

applicable to GMT2. The BLM will determine whether to adopt the new potential mitigation measures in 

the record of decision. The new potential mitigation measures are discussed below.

Potential Mitigation Measure 1—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 ofthe Environmental Protection Agency through emission standards for 

engines and vehicles.

Potential Mitigation Measure 2—Public Health Monitoring

Objective: To understand the effects of oil and gas development-related changes to population health and 

increase community understanding of public health impacts.
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Requirement/Standard: The Human Health Baseline Summary (Appendix G) provides an overview of 

and helps establish the current health status of the communities within the North Slope Borough. Future 

human health baseline summaries can be created to make comparisons to baseline summaries over-time 

and as oil and gas development may advance within NPR-A. Future human health baseline studies may 

include health indicators and and should focus on health outcomes and/or health determinants that can be 

tied to GMT2 oil and gas activity. Where possible, indicators should include threshold levels and specific 

actions should be developed for when thresholds are surpassed. The State of Alaska Department of Health

and Social Services, the North Slope Borough, and the Alaska Native Tribal Health Consortium should be 

consulted in the identification of appropriate indicators, thresholds, and responsive actions.

Potential Benefits and Residual/Unavoidable Impacts: Future comparisons to the Human Health 

Baseline Summary (Appendix G) may expedite the detection of changes in population health caused by 

GMT2 development and associated oil and gas activity. Future human health baseline information may

inform on-going health monitoring activities to help further understand public health changes that may 

result from oil and gas development.

Potential Mitigation Measure 3—Water Quality Monitoring

Objective: Ensure that permitted activities do not create a human health risk through contamination of 

local drinking water sources.

Requirement/Standard: Permittee will work with the City of Nuiqsut to design and implement a water 

quality monitoring program at the fresh water drinking lake, and other lakes in the vicinity that could be 

used as a source of drinking water should the currently utilized lake fail or become contaminated. The 

monitoring program will consist of a monitoring plan, training for local residents so that they can carry 

out the monitoring themselves, and a water sampling program. 

Potential Benefits and Residual/Unavoidable Impacts: Monitoring the fresh water sources used for 

drinking water in Nuiqsut will provide information on contaminant levels, if present, which may have the 

potential to affect drinking water quality and human health. 

Potential Mitigation Measure 4-- 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: 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.

4.4.7 Environmental Justice

This analysis of impacts related to environmental justice considers if implementation of the proposed 

GMT2 alternatives would result in disproportionately high and adverse environmental effects to the 

community of Nuiqsut. The community of Nuiqsut, as discussed in Section 3.3.2.4, meets the 
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demographic characteristics to be qualified as a minority population, and requires evaluation for 

disproportionate impacts under environmental justice. 

Executive Order No. 12898 (February 1994), discussed in Section 3.4.7, directs federal agencies, to the 

greatest extent practicable and permitted by law, to achieve environmental justice by identifying and 

addressing disproportionately high and adverse human health or environmental effects of proposed 

federal actions on minority and low-income populations. The NEPA analysis of environmental justice is 

also informed by CEQ guidance, as follows:

“Under NEPA, the identification of a disproportionately high and adverse human health or environmental 

effect on a low income population, minority population, or Indian tribe does not preclude a proposed

agency action from going forward, nor does it necessarily compel a conclusion that a proposed action is 

environmentally unsatisfactory. Rather, the identification of such an effect should heighten agency 

attention to alternatives (including alternative sites), mitigation strategies, monitoring needs, and 

preferences expressed by the affected community or population.” – CEQ 1997, pg. 10. 

Federal agencies also are required to give affected communities opportunities to provide input into the 

environmental review process, including the identification of mitigation measures. The BLM has assured 

meaningful community representation in the process by holding public meetings, inviting the Native 

Village of Nuiqsut to participate as a cooperating agency on the GMT2 Supplemental EIS, and holding 

regular government-to-government consultation via teleconference with the Native Village council. The 

BLM has also consulted regularly with Nuiqsut’s Alaska Native Claims Settlement Act Native village 

corporation, Kuukpik, and their regional Native Corporation, the Arctic Slope Regional Corporation. 

Following Council of Environmental Quality guidance on evaluating environmental justice within NEPA 

(1997), the analysis should recognize if the question of whether agency action raises environmental 

justice issues is highly sensitive to the history or circumstances of a particular community or population

(CEQ 1997, pg. 8). The historical context within which environmental justice issues are considered for 

the Iñupiat of the North Slope is discussed in the 2012 NPR-A Integrated Activity Plan/EIS (Section 

4.4.5). Tiering from that discussion, the BLM recognizes the interrelated cultural, social, occupational, 

historical, or economic factors that are likely to amplify the natural and physical environmental effects of 

the GMT2 Project. Council of Environmental Quality guidance also directs the BLM to consider any 

multiple, or cumulative effects, to human health and the environment even if certain effects are not within 

the control or subject to the discretion of the agency (CEQ 1997, pg. 9).

The BLM therefore considered the following factors in determining whether the environmental effects of 

GMT2 will be disproportionately high and adverse: Whether there is or will be an impact on the natural 

environment that significantly and adversely affects Native residents of Nuiqsut. Such effects may include 

subsistence, ecological, cultural, human health, economic, or social impacts to Tribal members when 

those impacts are interrelated to impacts on the natural and physical environment.

The analysis of environmental justice in the context of the GMT2 Project is particularly complex. 

Standard environmental justice issues involve outsider-driven industrial activities that disproportionately 

affect minorities. The GMT2 Project would develop subsurface minerals that belong to the Alaska Native 

Claims Settlement Act regional Native Corporation, and the land where GMT2 would be constructed has 

been selected by the Alaska Native Claims Settlement Act village corporation for Nuiqsut (Kuukpik 

Corporation). This environmental justice analysis must consider that the GMT2 Project is partly driven by 

Inupiaq entities and Iñupiat would benefit economically as shareholders in their Native corporations. 

Alaska Native Claims Settlement Act corporations were established to promote development of their 

resources that benefits their shareholders. Analyses in this draft supplemental EIS for economy, 

sociocultural systems, and subsistence (Section 3.4.2, 3.4.3, 3.4.5, 4.4.2, 4.4.3, and 4.4.5) describe several 

ways that Inupiaq residents of Nuiqsut who hold dissimilar values and opinions and/or who are 
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economically disadvantaged would disproportionally experience negative impacts associated with 

development of GMT2. In particular, the democratically elected Tribal council for Nuiqsut (Native 

Village of Nuiqsut) has taken several steps to clarify that their own Alaska Native Claims Settlement Act

corporations do not necessarily speak for them on development issues. Federal agencies are required to 

consult with Alaska Native Claims Settlement Act corporations on the same basis as Tribes, but this does 

not diminish in any way the relationship and consultation obligations with Tribes. To the extent concerns 

differ between Tribes and Alaska Native Claims Settlement Act corporations, DOI gives due 

consideration to the right of sovereignty and self-governance of federally recognized Tribes. 

Effects to the minority community that have been identified in the preceding sections include:

• Employment opportunities.

• Royalties to Arctic Slope Regional Corporation and Kuukpik Corporation.

• Tax revenues to the North Slope Borough and the City of Nuiqsut.

• Increased State of Alaska NPR-A Impact Mitigation funds that eligible municipal governments 

can apply for. 

• Opposition by the democratically elected Tribal government (Native Village of Nuiqsut) to 

permitting GMT2 until GMT1 is complete and impacts analyzed. 

• Perceived inadequacy of compensation systems. 

• Distress associated with disruptions to the Nuiqsut cultural landscape. 

• Social conflict associated with income disparity. 

• Impacts to subsistence, including: 

o Project footprint’s direct and indirect impact to subsistence use areas.

o Disruption to subsistence hunting activities caused by aircraft traffic.

o Reduced access to and user avoidance of traditional subsistence use areas (this impact will likely 

be offset to some degree by the facilitated access that will be provided by the GMT2 road to 

previously difficult to reach hunting areas)

o Reduced value of traditional subsistence use areas.

o Potential disruption and deflection of subsistence resources (resource availability).

o Potential decreased community participation and transmission of knowledge.

4.4.7.1 Construction 

Construction crews would be housed at the Alpine Processing Facility, at commercial housing in Nuiqsut, 

or at a temporary camp at the drill site or on an ice pad. Construction at the site would not bisect any 

communities would not adversely affect access between communities. Because of the predominance of 

Alaska Natives in the North Slope Borough, minority individuals form “the broader community” of the 

area. Construction of the proposed project would not isolate minority or low-income individuals from the 

broader community.

Construction of the GMT2 Project is expected to increase employment opportunities for residents who 

take advantage of the local hire program sponsored by ConocoPhillips and its contractors. Local residents 

who work at the GMT2 facility would benefit from jobs and increased income. Although the number of 

jobs the GMT2 Project generates for local residents would not be known until after contracts are awarded 

and construction begins, it likely that positions for local residents would be available. However, based on 
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the history of past development projects on the North Slope, the construction of the GMT2 Project would 

likely have a minor impact on overall North Slope Borough resident employment. Nonresident workers 

who would leave the area between shifts will likely fill the majority of positions created by the project.

During construction, an increase in employment and in cash income from both employment and dividends 

to shareholders who live in the community would help local residents, especially those of working age, to 

stay in the area and maintain their culture and community characteristics. It is expected that residents will 

experience economic benefits through indirect effects of increased tax income for the North Slope 

Borough government. Section 4.4.3, “Economy” provides additional discussion of impacts to 

employment, income, and the North Slope Borough tax base.

Health impacts related to GMT2 construction are a primary concern for local residents and governing 

entities (Section 4.4.6.1). There would be limited interaction between workers at the site and the local 

community, thereby having minor impacts to food, nutrition, subsistence, and social determinants of 

health. Exposure to hazardous materials through emissions of air pollutants or spills of hazardous 

materials would be regulated for protection of human and environmental health. Issues associated with 

environmental security (fear of a blowout, lack of an evacuation plan, and air quality) are serious 

concerns for the Native Village of Nuiqsut Tribal government.

4.4.7.2 Drilling and Operation

The effects of drilling and operation of the GMT2 Project on the minority community of Nuiqsut would 

be less acutely impactful than those described above for construction, but would be of a much longer 

duration. Fewer workers would be employed to drill and maintain the wells than to construct the facility.

The 2012 North Slope Borough Baseline Community Health Analysis Report notes that a recent study 

examining air quality in Nuiqsut has not found evidence of [air] pollution at levels expected to have 

significant health effects (North Slope Borough 2012, page 98 and 184). That North Slope Borough

Report also notes that 24 percent of Iñupiat heads of household in Nuiqsut reported a shortage of 

subsistence food at some point during the year. This situation could be exacerbated if there was an 

adverse impact on the availability of subsistence resources due to GMT2 Project drilling and operation.

4.4.7.3 Comparison of Alternatives

The gravel access road constructed under Alternatives A and B could provide increased access for Nuiqsut 

residents to subsistence use areas. Disturbance from aircraft traffic has emerged as the most commonly 

reported impact on subsistence activities: this impact would increase under all action alternatives, but the 

increase would be greater under Alternative C. While the nature of impacts associated with aircraft traffic 

affects the relative intensity of other impacts (namely, roads), it does not affect the degree of intensity of 

other impacts. The GMT2 Access Road and the ease of general road access to the area will likely decrease 

the quality of the area (compared to no development), increase the local hunting pressure in the area, and 

could deflect caribou from areas closer to town. Potential access issues have been identified for 

subsistence hunters attempting to cross the existing CD5 and GMT1 roads. BLM mitigation measures 

require that road design will not impede access for subsistence activities. Although impacts to 

sociocultural systems and subsistence have been identified as likely to result from either Alternative A or 

B, the degree of intensity of these impacts is less under Alternatives A or B than it would be under 

Alternative C.

Alternative C, as described in Section 4.4.2, “Sociocultural Systems” and Section 4.4.5, “Subsistence”, 

would involve the most substantial environmental justice issues for Nuiqsut. This alternative would result 

in increased air traffic and associated noise directly over the residents’ subsistence hunting areas and 

would include a larger footprint for the project components, including an airstrip and a permanent camp at 

GMT2. There would not be a road linking GMT2 to the other Alpine Satellite facilities and Nuiqsut that 
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would facilitate residents’ access to subsistence use areas. Aircraft would be used approximately 9 months 

of the year (May through January) to access GMT2 from Alpine Processing Facility or Nuiqsut; ice roads 

would provide access approximately 3 months of the year (February through April). Noise impacts from 

aircraft operations between Alpine Processing Facility and GMT2 would disturb caribou and subsistence 

hunting activities. Landings and take-offs of large aircraft, combined with other activity at the GMT2 drill 

pad, could deflect caribou (most notably animals from the Teshekpuk Lake herd during its fall migration) 

from areas closer to town where they are traditionally harvested. Alternative C does not reflect the GMT2 

configuration that most members of the identified environmental justice population who have testified or 

submitted comments have preferred due to the impacts they experience. 

Alternative D, the no-action alternative, would result in none of the negative impacts to subsistence that 

are anticipated from the action alternatives. However, the no-action alternative would also result in none 

of the anticipated economic benefits of GMT2 Project. No additional impacts to the Nuiqsut cultural 

landscape would occur. The Native Village of Nuiqsut has expressed a preference for the no action 

alternative, and requested the BLM delay permitting of the GMT2 Project until GMT1 was built and its 

impacts could be evaluated. The BLM is required to issue a permit for the GMT2 development (see 

Section 2.8, No Action Alternative.)

Under all action alternatives, residents of the minority community of Nuiqsut could experience 

disproportionally high and adverse impacts as the result of negative impacts to sociocultural systems and 

disturbance to subsistence activities in highly valued, nearby traditional subsistence use areas. Resource 

availability could be impacted in the immediate vicinity of the project and caribou could be deflected 

away from areas closer to town. 

4.4.7.4 Mitigation

Prior planning documents covering the proposed project study area, described in BLM (2004, 2008b, 

2012, 2013, 2014), have provided opportunities for public involvement for low-income and minority 

populations. The BLM has carefully considered community views when developing and implementing 

mitigation strategies to reflect the needs and preferences of these populations, to the extent practicable. 

These planning documents have made some lands unavailable for oil and gas leasing, including a large 

portion of the coastal plain within the NPR-A used by Nuiqsut subsistence users. See Chapter 5 for 

consultation activities associated with this supplemental EIS.

These efforts also include ways to adapt management of these lands to better meet resource and use 

objectives, including adopting measures to protect subsistence resources, protect access to those 

resources, protect public health, and monitoring the activities of lessees/permittees to ensure compliance 

with requirements. The NPR-A Subsistence Advisory Panel (1998-2016) provided a forum for Tribal 

representatives to propose mitigations to the BLM, and the BLM conducts regular government-togovernment consultation with the Native Village of Nuiqsut council. The NPR-A Working Group (2013-

2016), made up of representatives of the North Slope local government, Native corporations, and Tribal 

entities, provided meaningful and regular input by local communities. Preferences expressed by the local 

community in past consultations with the BLM are as follows:

• Local residents should be consulted regarding local uses. This information and traditional 

knowledge should be incorporated into study plans before they are started.

• There should not be a pipeline towards Fish Creek; it is important for different types of fish in the 

fall, fall caribou hunting, and spring geese hunting. 

• Nuiqsut needs better coordination with industry.
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• The cumulative effects of oil and gas development need to be addressed and prioritized. There are 

too many meetings in the community, and this prevents residents from engaging on issues of 

importance to them. 

In the Alaska National Interest Lands Conservation Act Section 810 analysis documented in BLM 

(2004a, 2012), the BLM concluded that the authorized developments (Alternative F and B-2, respectively, 

both of which include the GMT2 Project) “include reasonable steps to minimize adverse impacts on 

subsistence uses and resources.”

Potential impacts to subsistence activities and resources are mitigated to the extent feasible by design and 

operational features included in Section 4.6 and the following protective measures of BLM (2013: A-4, A5, A-6, A-7, A-11, A-12, B-1, B-2, C-3, C-4, C-5, E-1, E-2, E-6, E-7, E-19, F-1, H-1, H-3, I-I, K-1, K-2, 

and M-1). Measures to protect the biological resources and human health have proven effective, measures 

in effect to date do not completely mitigate the social and cultural impacts of development or other 

aspects of technology, modernization, climate change, or cultural change. The effectiveness of lease 

stipulations and best management practices for subsistence is discussed in Section 4.4.5. Potential new 

mitigation measures for impacts to sociocultural systems are presented in Section 4.4.2.5, and potential 

new mitigation measures to address impacts to subsistence are presented in Section 4.4.5.6.

4.4.7.5 Conclusions

The analysis of impacts related to environmental justice considers if implementation of any of the 

proposed GMT2 Project alternatives would result in disproportionately high and adverse environmental 

effects to the minority community of Nuiqsut. The potentially affected resource in the environmental 

justice analysis is the community of Nuiqsut. It is understood that although the majority of residents are 

Inupiaq and thus Nuiqsut qualifies as an environmental justice population, there are sub-populations 

within this minority population that will likely experience the impacts of GMT2 differently than other 

sub-populations within the community. Lower economic status households and households that are more 

dependent on harvesting subsistence resources from impacted use areas will likely experience more 

intense impacts. However, some individuals and households will likely benefit from the facilitated access 

provided by the road.

The finding of the Alaska National Interest Lands Conservation Act Section 810 subsistence evaluation 

(Appendix L) for the proposed project under all action alternatives is that development of the GMT2 

Project may significant restrict subsistence uses for the community of Nuiqsut.

Under Alternatives A and B, the permanent access (after construction) to subsistence use areas is expected 

to have a long-term, moderately countervailing (beneficial) effect for many residents of Nuiqsut. The road 

is also expected to diminish the traditional value of the area due to loss of land, disturbance to and 

possible deflection of resources attributable to the stature of the road, road traffic, the presence of the 

pipeline, and increased local hunting pressure. Alternative B include a longer road, more gravel fill, and 

would would not include the same level of countervailing economic benefits that would occur under 

Alternative A. Alternative C would result in increased aircraft disturbance in the project study area and 

would not include the mixed effects of the road, therefore resulting in greater negative impacts to the 

community, including a higher degree of negative impacts to sociocultural systems. Impacts resulting 

from Alternative D are expected to include a lack of any of the economic benefits anticipated from GMT2 

Project, negligible additional negative impacts to sociocultural systems, and no additional impacts to 

subsistence use areas and activities.
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4.5 Impacts of Oil, Saltwater and Hazardous Materials Spills

This section summarizes the impacts that might result from releases of oil, saltwater, and hazardous 

substances associated with the proposed GMT2 Project. This analysis tiers to the information presented in 

the Alpine Satellite Development Plan EIS (BLM 2004, Section 4.3), the NPR-A Integrated Activity Plan 

EIS (BLM 2012, Section 4.2.2), and the Alpine Satellite Development Plan GMT1 Supplemental EIS

(BLM 2014, Section 4.5), and provides an updated analysis using the most current spill information from 

the Alaska Department of Environmental Conservation spills database of spills related to operation of the 

Alpine Field. This section also references the ConocoPhillips Alpine Field and Satellites and Alpine 

Pipeline System Oil Discharge Prevention and Contingency Plan (ODPCP), which is provided as 

Appendix P.

4.5.1 Background

The Alpine Satellite Development Plan EIS (BLM 2004 Section 4.3.3 and Section 4.3.4) provides a 

detailed analysis of the rate, behavior, and potential impacts of spills in a variety of spill scenarios. The 

type of material or product most likely to be spilled and the primary causes and source of spills were 

identified. Spills can occur from pipelines, storage tanks, production facilities and infrastructure, drilling 

rigs, and heavy equipment or vehicles. Impacts from spills vary based on what material was spilled, the 

size of the spill, and what time of year the spill occurred. Materials that could be spilled are categorized 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 waterbodies, 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. Non-crude 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, additives for hydraulic fracturing, 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 Conservation Tundra Treatment Guidelines 2010).

Resource-specific spill-related impact assessments and details on the factors affecting the fate and 

behavior of spills in the environment are provided in the Alpine Satellite Development Plan EIS (BLM 

2004, sections 3.1.2 and 4.3) and the NPR-A IAP/EIS (BLM 2012, Section 3.2.11) and are incorporated 

by reference. These documents evaluated the previous iteration of the GMT2 project, identified as CD7. 

The GMT2 project is similar to the previously analyzed CD7 project, with changes that reduce the overall 

impact. These changes include removing the drill site location from the Colville River Special Area and 

reducing the road and pipeline length.
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4.5.2 Spills History

To describe the impacts of spills, the following spill size categories the Alpine Satellite Development Plan 

EIS (BLM 2004) used the following spill size categories:

• Very small spills – less than 10 gallons (0.24 barrels)

• Small spills – 10 to 99 gallons (0.24 to 2.4 barrels)

• Medium spills – 100 to 999 gallons (2.4 to 24 barrels)

• Large spills – 1,000 to 100,000 gallons (24 to 2,400 barrels)

• Very large spills – greater than 100,000 gallons (2,400 barrels)

The NPR-A IAP EIS (BLM 2012) updated the data provided in the 2004 analysis, including the spill size 

classifications that were used. The size categories used in the NPR-A IAP EIS (BLM 2012) are:

• Small spills – less than 21,000 gallons (500 barrels)

• Large spills – 21,000 to 5,040,000 gallons (500 to 120,000 barrels)

• Very large spills – more than 5,040,000 gallons (120,000 barrels)

Both the 2004 and 2012 analyses found that the majority of spills have been less than 100 gallons, and 

were contained within secondary containment or on gravel pads and roads. Large spills were determined 

to have low probability.

4.5.2.1 North Slope Spills History

The Alaska Department of Environmental Conservation Summary of Oil and Hazardous Substance Spills 

by Subarea (October 2007) provides a detailed analysis of spills from 1995 to 2005. The analysis shows 

process water spills were 8 percent of the total number of spills, but 75 percent of the total volume. Crude 

oil spills were 12 percent of the total number of spills, and 5 percent of the total volume. Non-crude oil 

spills were 49 percent of the total number of spills, accounting for 7 percent of the total volume. 

Hazardous substance spills were 31 percent of the total number of spills, and 13 percent of the total 

volume. More than half (59 percent) of the spills were less than 10 gallons. Approximately 98 percent of 

the total volume released resulted from spills larger than 99 gallons. 

Data from the Alaska Department of Environmental Conservation Spills Database for spills related to oil 

development on the North Slope from 2012 to March 2017 was analyzed, and shows similar results to the 

1995 to 2005 data. From 2012 to March 2017, process water spills were 8 percent of the total number of 

spills, representing 41 percent of the total volume. Crude oil spills were 8 percent of the total number of 

spills, and 16 percent of the total volume. Non-crude oil spills were 53 percent of the total number of 

spills, and 15 percent of the total volume. Hazardous substance spills were 30 percent of the total number 

of spills, and 26 percent of the total volume. Spills of less than 10 gallons accounted for 68 percent of the 

total number of spills. Approximately 65 percent of the total volume released resulted from spills larger 

than 99 gallons.

Structural or mechanical issues, including corrosion, leaks, cracks, valve failures, or equipment failures, 

caused 75 percent of the spills, and human factors such as overfilling, unsecured cargo, or other human 

errors caused 15 percent of the spills.
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The ADEC Spills Database list three documented spills of greater than 100,000 gallons on the North 

Slope. In 1997, approximately 994,400 gallons of seawater was spilled in East Prudhoe Bay. (ADEC 

Spills Database).

In March of 2006, approximately 201,000 gallons of crude oil was spilled from the GC-2 Oil Transit 

Pipeline at the BP Exploration, Alaska (BPXA) Western Operating Area. The spill was a result of internal 

corrosion, which caused a 0.25-inch hole in the pipeline. The cleanup effort included removal of 64,596 

gallons of free flowing oil, 10,786 cubic yards of oil contaminated snow and soil, and 484 cubic yards of 

contaminated gravel. A survey of the site determined 1.93 acres of tundra and frozen lake were impacted 

by the spill. Soil sampling results confirm that site meets the clean-up criteria after the removal actions 

were completed, and the site was been backfilled and covered with transplanted tundra mats to 

rehabilitate the area. (ADEC Situations Reports, March 2008)

In December of 2006, approximately 255,152 gallons of produced water and 126 gallons of crude oil was 

spilled from GC-2 Tank 8511 at the BPXA Western Operating Area. The spill was caused by a mechanical 

failure involving the agitation jets used to suspend solids near the bottom of the tank. Misalignment of a 

jet caused a hole to erode through the bottom of the tank. While the tank was releasing produced water 

from the hole in the bottom of the tank, the crude oil was skimmed off through a drain line. Fresh water 

was pumped into the tank to give the oil greater retention time to increase the effectiveness of the 

skimming operation. When most of the oil was removed, the tank was allowed to drain. Vacuum trucks 

were used to remove the produced water and crude oil from secondary containment. The oil was returned 

to the pipeline and the produced water was re-injected into the formation. The spill was confined to the 

gravel pad secondary containment area. No impacts to tundra were identified. (ADEC Situations Reports, 

December 2007)

Other recent spills include the Repsol Q-2 pad gas and mud release in 2012, the Repsol Q-6 spill in 2013,

the BPXA H Pad Well 8 spill in 2014, and the BPXA Drill Site 2 pad release in 2017. The Repsol Q2 pad 

gas and mud release occurred on the Qugruk #2 pad on the Colville River Delta, approximately 18 miles 

northeast of Nuiqsut, on February 15, 2012. A Repsol contractor was drilling an exploratory well when 

the drill penetrated a shallow gas pocket at a depth of 2,523 feet, resulting in a gas kick. The gas drove 

drilling mud, down-hole materials, and water out of the well and through the gas diverter onto the ice pad 

and adjacent snow-covered tundra. The gas diverter is a pipe that extended approximately 75 feet from 

the drilling rig toward the south edge of the pad. Additional mud was pumped into the well in an attempt 

to control it, but that mud was also forced out by the gas. No oil was spilled during the release event.

An estimated 42,000 gallons of drilling muds were released during the blow out. The total impacted area 

is estimated at 23.75 acres. Spill responders used heavy equipment to remove the spilled material from the 

heaviest contaminated zones. Hand tools were used to recover drilling mud from areas of lighter 

contamination. An area of 16.75 acres of lightly-misted material was determined to be unrecoverable, and 

no cleanup occurred in this zone. Approximately 6,286 cubic yards of spilled material were removed from 

the snow-covered tundra and 2,402 cubic yards of down-hole material and 115,928 gallons of water-based 

drilling mud and freshwater from the steam units were recovered from the drilling pad during the initial 

response. (ADEC Situation Reports, 2012)

The Repsol Q-6 release occurred on the Qugruk #6 pad, approximately 18 miles northeast of Nuiqsut, in 

July of 2013, when a hose ruptured on a line between the well and a storage tank during a well flowback 

operation. The hose was under pressure when it failed, causing the fluids to spray out onto the pad and 

snow-covered tundra. Additional product was released into the lined secondary containment cell when the 

fluids in the storage tank drained back through the ruptured hose. An estimated 3,822 gallons of fluids (60

percent stimulation fluids, 35 percent diesel, and 5 percent crude oil) was released. The majority of the 

product was contained within the secondary containment area. Approximately 1.2 acres of snow-covered 

tundra and frozen lake were misted with fluids. Spill responders used shovels to remove the thin surface 
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crust of contaminated snow. Sample results show that the snow removal activities effectively removed the 

misted fluids, and the presence of snow and ice cover protected the underlying tundra and waterbodies

from the release. (ADEC Situation Report, 2013).

The BPXA H Pad Well 8 spill occurred in the BPXA west operating area in Prudhoe Bay. In April 2014, a 

pressurized line ruptured and natural gas, crude oil, and produced water were released. The spill was 

estimated to be 700 gallons of fluid, which sprayed an oily mist over approximately 33 acres of snowcovered tundra and 2 acres of gravel pad. Approximately 1,600 cubic yards of impacted snow was 

removed. Inspections during the summer of 2014 did not reveal any spill-related impacts to the tundra. 

Surface water sample results show that surface waterbodies were not impacted. (ADEC Situation Report 

2014).

The BPXA Drill Site 2 site occurred on the BPXA Drill Site 2 pad, Well 3, in the Greater Prudhoe Bay 

area. On April 14, 2017, BPXA employees discovered an uncontrolled gas and oil release from the top of 

the well house for Well 3, which is an oil and gas production well. The well was secured on April 19, by 

installing a mechanical plug in the well. The impacted area is limited to the DS2 gravel pad, and total size 

is less than 1.5 acres. (ADEC Situation Report, 2017)

4.5.2.2 Alpine Spills History

The Alaska Department of Environmental Conservation Spills Database lists 252 spills reported within 

the Alpine Oil Field for the entire operating period, from 1998 through March 2017. Total volume of 

spills for the operational period is approximately 15,975 gallons. Of the total volume spilled, 48 percent

was non-crude oil and 35 percent was process water. 

Spills prior to October 2013 at the Alpine facility are discussed in detail in the GMT1 EIS (BLM 2014, 

Section 3.1.3). There have been 62 reported spills from October 2013 to March 2017. The total volume of 

spills from this time frame is 4,103 gallons, including one spill of 3,000 gallons of diesel in December of 

2013 as a result of an overfill. All 3,000 gallons were contained in secondary containment. 

Of the total volume spilled during this time frame, non-crude oil spills accounted for 92 percent, process 

water spills were 7 percent, hazardous substances, were 2 percent, and crude oil was less than 1 percent. 

Spills of less than 10 gallons accounted for 74 percent of the total number of spills. Structural or 

mechanical issues caused 71 percent of the spills, and human factors caused 23 percent of the spills.

Of the 62 spills from October 2013 to March 2017, over half of the spills occurred in February (15 spills) 

and March (18 spills). There were eight spills reported in April, six in December, and three each in 

January, May, June, and September. August had two spills, and November had one. There were no 

reported spills in July or October.

The ConocoPhillips ODPCP for the Alpine Field and Satellites and Alpine Pipeline System (Appendix P)

provides a discharge history for oil spills greater than 55 gallons. The analysis shows that sources with the 

highest percentage of spill incidents are tanks (44%) and heavy equipment/mobile equipment/vehicles 

(18%). The largest percentage of spill volume was from tanks (46%), flange failure (14%), and heavy 

equipment/mobile equipment/vehicles (13%).

The ODPCP (Appendix P) includes a summary of oil spills to tundra and water at Alpine. There are 54 

spills listed, with a total volume released to tundra or water of 406 gallons. The four largest spills were 

252 gallons of diesel (May 1999), 35 gallons of hydraulic fluid (March 1999), 20 gallons of hydraulic 

fluid (February 1999), and 25 gallons of diesel (March 2015). These spills all occurred when there was 

snow on the ground, which was removed to recover the spilled materials. The remainder of the spills were 

less than 10 gallons.
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4.5.3 Construction

As described in the GMT1 Supplemental EIS (BLM 2014), 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. 

4.5.4 Drilling and Operation

• 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.

4.5.4.1 Hydraulic Fracturing

Hydraulic fracturing at GMT2 is described in Section 2.4.3. Hydraulic fracturing activities in Alaska are 

tightly regulated by the Alaska Oil and Gas Conservation Commission (AOGCC). The AOGCC 

regulations specifically require disclosure of the chemical composition and the anticipated volume of 

hydraulic fracturing fluids. For the GMT2 Project, impacts to freshwater are not a concern. In this 

part of Alaska, a thick layer of soil is underlain by permafrost – ground that remains frozen year 

round – so there is no liquid water, other than surface water, to a depth of 1,000 to 2,000 feet. Below 

the permafrost, only salt water is present, with very few exceptions. Regardless, wells on the North 

Slope are held to the same stringent statewide construction requirements. In over fifty years of oil 

and gas production, Alaska has yet to suffer a single documented instance of subsurface damage to an 

underground source of drinking water. As long as each well is properly constructed and its 

mechanical integrity is maintained, hydraulic fracturing should have no potential to damage any 

freshwater. (AOGCC 2015). The GMT2 Project will also pipe in seawater for use in hydraulic 

fracturing operations, so water withdrawal from freshwater lakes is not a concern for this project. 

All hydraulic fracturing activities are required to be reported to http://www.fracfocus.org, including well 

information and chemical disclosure. The wells at GMT2 that require hydraulic fracturing will only need 

initial stimulation. No acidizing is planned for the GMT2 wells. ConocoPhillips reported the following 

hydraulic fracturing fluid product components for well CD5-22 (FracFocus 2018), and the hydraulic 

fracking fluids used at GMT2 are assumed to be of similar composition:

• 1.2.4 Trimethylbenzene

• 2-bromo-2-nitro-1.3-propanediol

• Acrylate polymer

• Ammonium persulfate

• Borate salts

• Corundum

• Crystalline silica quartz

• Cured acrylic resin

• Ethanol

• Guar gum

• Heavy aromatic (petroleum) naphtha

• Mullite
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• Naphthalene

• Ethoxylated phenolic resin

• Poly (oxy-1,2-ethanediyl, alpha-(4-nonylphenyl-omega-hydroxy)-branched

• Potassium formate

• Potassium hydroxide

• Potassium metaborate

• Sodium carboxmethyl cellulose

• Sodium chloride

• Sodium glycollate

• Sodium hydroxide

• Sodium persulfate

• Sodium sulfate

Spills associated with hydraulic fracturing could occur during the fracking process or during 

transportation of used hydraulic fracturing fluids for disposal. The number of trucks needed for disposal 

of fluids from GMT2 hydraulic fracturing activities is generally no more than 30 per well (ConocoPhillips

personal communication, 2018).

4.5.4.2 Blowout Response

As required by ADEC 18 AAC 75, the blowout contingency plan establishes notification procedures, 

presents decision-based guidelines for managing a well control incident, and provides emergency 

response, source control equipment, and logistics information. The blowout contingency plan is 

supplemental to the area ODPCP (Appendix P), which provides details on oil spill prevention and 

response for various spill scenarios, including a well blowout.

Well Capping 

Well capping is effective for onshore wells. The purpose of capping a well, to control a blowout, is to stop 

or redirect the flow of hydrocarbons by means of placing a very strong valve on the wellhead. This is 

done in order to buy time for the engineers to kill and permanently seal the well. In addition to well 

capping, plans and provisions for a relief well are also incorporated into a response. 

Once initial notifications are made and response objectives are established under the Incident Command 

System (typically within the first 24 to 48 hours of an incident), the anticipated general time frame for 

major actions to perform well capping is as follows:

• Mobilize heavy equipment, personnel, and materials (from North Slope locations): 1-5 days

• Mobilize well control contractor personnel and specialized equipment: 1-5 days

• Situation and site assessment; establish Safety Plan and Well Capping Plan: 2-5 days

• Equipment staging, determine approach paths, prepare heavy equipment with heat shielding, rig 

up Athey wagons and fire pumps, test equipment, apply fire suppression, begin debris removal, 

continually assess situation, (initiate relief well planning): 6-10 days

• Cut off BOP stack with abrasive jet cutter, excavate at wellhead, prepare casing for new wellhead 

or capping stack, install new wellhead (if required), prepare and deploy capping stack, activate 

rams and/or place on divert, kill well: 10-15 days
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Due to the unpredictable nature of well blowouts, and environmental conditions which can limit the 

effectiveness of personnel and equipment, this timeline is intended for illustration and planning, and 

represents the best-case scenario.

Relief Well Drilling

Well capping is typically effective for well source control; however, in the event of an uncontrolled well 

emergency, plans and operations for drilling a relief well would be made simultaneous with those for well 

capping. Drilling a relief well in support of a well control response at GMT2 during summer months 

(generally May through October) primarily would require construction of a gravel pad and mobilization 

of a drill rig and related facilities (e.g., mud and cement plants). A gravel pad sized at a minimum of 

300 feet by 380 feet would be required to support the rig and drilling operations; gravel would be 

scavenged from nearby gravel pads and roads or possibly mined from local gravel resources. 

Approximately 600,000 cubic feet of gravel would be needed to construct the gravel pad. Alternatively, a 

well pad could be constructed using rig mats placed on leveled tundra surface; approximately 1,800 rig 

mats, double layered for stability, would be required. Siting of the relief well pad would be made at the 

time of the incident, taking into consideration current wind and weather conditions, blowout severity, and 

distance from the heel of the blowout wellbore, as well as other environmental or regulatory factors such 

as mandatory setbacks. Proximity to the gravel road structure would allow unrestricted access and reduce 

tundra damage; however, it is assumed tundra travel would be approved by governing agencies as an 

element of the response.

Spill Scenario Modeling

A hypothetical spill of an uncontrolled well blowout is described in the current Alpine ODPCP (Appendix 

P). The Response Planning Standard (RPS) for the spill scenario is 150,000 barrels, or 10,000 barrels of 

oil per day for a duration of 15 days. The well blowout scenario is modeled for ConocoPhillips’s CD5 pad 

in both summer (August) and winter (February) conditions. Modeling for a well blow out at CD5 pad 

presents a worst case scenario, and the potential impacts would be similar for GMT2.

ADEC regulations governing the ODPCP (Appendix P) (18 AAC 75) require modeling to show where 

dispersed oil would be most likely to fall within the environment (trajectory analysis). This involves 

consideration of prevailing wind direction (wind direction is taken from the nearest available wind 

monitoring station). For the proposed GMT2 Project the nearest wind monitoring station is in Nuiqsut. 

The RPS scenario in the Alpine ODPCP (Appendix P) describes a hypothetical well blowout at 

ConocoPhillips’s CD5 pad. The plume dispersion model is from SL Ross, which projects that the oil takes 

the form of an aerial plume extending from the well in the direction of predominant winds. Using wind 

data derived from the Nuiqsut Air Quality Monitoring Program, the predominant winds in the summer are 

from the ENE 40% of the time, and the NE, E, and W 20% of the time each. The predominant winds in 

the winter are from the NE 50% of the time, from the ENE 30% of the time, and from the E 20% of the 

time. Therefore; the hypothetical blowout would discharge 30,000 barrels to the WSW, SW, W, and E of 

the CD5 pad in the summer or SW, WSW, and W in the winter. For this scenario, the model predicts the 

following plume dimensions:

• Approximately 70 percent of the discharged oil falls within 430 feet downwind of the well. At 

that distance, the plume is about 90 feet wide.

• Approximately 80 percent of the discharged oil falls within 1,275 feet downwind of the well. At 

that distance, the plume is about 235 feet wide.

• Approximately 90 percent of the discharged oil falls within 8,885 feet (1.7 miles) downwind of 

the well. At that distance, the plume is about 1,355 feet wide. 
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• According to the SL Ross model, 10 percent of discharged oil is in the form of droplets so small 

(50 micrometers or less) that they do not fall to the ground.

For this scenario, approximately 70 percent (105,000 barrels) of the discharged oil falls on the CD5 pad. 

Not all oil falling on the pad is retained by gravel. If not recovered, discharged oil accumulates in lowlying areas and eventually flows off the pad. Approximately 30,000 barrels of oil falls beyond the pad. An 

estimated 4,300 barrels enters open water. The average thickness of the oil deposited on water surfaces is 

0.10 inch.

4.5.5 Waste Disposal 

Drilling fluids, produced waters, and other wastes associated with the exploration, development, or 

production of crude oil and natural gas are solid wastes that are not hazardous waste in accordance with 

40 CFR §261.4(b)(5). Any other hazardous waste generated at the facility is subject to the hazardous 

waste regulations under Sections 3001 through 3019 of the Resource Conservation and Recovery Act 

(RCRA) (42 USC 3251 et seq.). 

In the event of a spill there may be a need for temporary storage of oil, oily waste, and debris recovered 

during a spill cleanup. The spill location or other logistical concerns may require the use of small, 

portable containers that can be mobilized via truck or aircraft to the nearest disposal facility.

Numerous options are available at North Slope facilities for the recycling of recovered hydrocarbons. 

Injection well disposal of Class I fluids is available at the Alpine Development and at Pad 3 in the 

Prudhoe Bay Unit, and would be included in the Alternatives D1 and D2 infrastructure. Injection well 

disposal of Class II solids is available at the Grind and Inject Facility in Prudhoe Bay Unit, and Class II 

wells for liquids disposal in Alpine and Kuparuk. If materials need to be transported off the North Slope, 

truck, and/or air transportation would be arranged.

4.5.6 Comparison of Alternatives

In general, the potential impacts due to spills of oil, saltwater, or other hazardous materials as described 

earlier in this section are similar for each action alternative. Alternative A (described in Sections 2.4 and 

2.5) and Alternative B (described in Sections 2.4 and 2.6) include a drill pad, gravel access road, and 

pipelines, with differing road and pipeline alignments. The pipelines follow the proposed road alignments, 

allowing easy year-round access for monitoring and repair. Spill response equipment would be staged as 

described in Section 2.4.10, and the access road would allow rapid response from the medial, fire, and 

spill response personnel from CD1/Alpine Processing Facility. 

Alternative C (described in Sections 2.4 and 2.7) includes a drill pad, an occupied pad, an airstrip and 

associated facilities, a local access road, and pipelines. There is no gravel access road from GMT1 to 

GMT2 or the rest of the Alpine Field development area. Access would be by aircraft and ice road (winter 

only). A 2-inch diesel pipeline and additional bulk storage tanks would be required for this alternative, 

which increases the opportunity for spills to occur. Pipeline inspections would be conducted by road 

during the ice road season, and by aircraft during the rest of the year. The lack of road access under this 

alternative would complicate spill response, as discussed in Section 2.4.10 and Section 2.7.8. The limited 

access to emergency response resources under Alternative C, particularly during bad weather, creates 

environmental and safety risks.

Alternative D is the no action alternative. Under this alternative, there would be no impacts from spills of 

oil, process water, or hazardous substances.
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4.5.7 Mitigation

Several best management practices (best management practices) have been developed to minimize 

impacts from spills in the Alpine Satellite Development Plan EIS (BLM 2004, Section 4.3), the NPR-A 

Integrated Activity Plan EIS (BLM 2012, Section 4.2.2), and the Alpine Satellite Development Plan 

GMT1 Supplemental EIS (BLM 2014, Section 4.5). The GMT1 Record of Decision (BLM 2015) 

included supplemental BMPs A-3 and A-4, which were modified to include additional requirements for 

secondary containment, warm storage or deicing of response equipment, and having response equipment 

designated to arctic conditions. See Section 4.7 for additional discussion of best management practices.

Spill prevention and response, training requirements, fuel and chemical storage, and waste handling and 

disposal are discussed in Sections 2.4.10, 2.4.11, and 2.4.12. These were developed in accordance with 

State and federal regulations and industry standards. A list of the State of Alaska environmental protection 

statutes and BLM best management practices and regulations can be found in Appendix J. ConocoPhillips 

also maintains a current Oil Discharge Prevention and Contingency Plan with the Alaska Department of 

Environmental Conservation for the Alpine Facility that will be updated to include GMT2. In addition to 

the design measures and existing BMPs incorporated by the applicant to handle solid waste associated 

with the project, the BLM received suggestions during the DSEIS public comment period from 

stakeholders for additional potential mitigation measures that address solid waste and hazardous 

materials.

4.5.7.1 Potential Mitigation Measure 1 —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. 

4.5.7.2 Potential Mitigation Measure 2 —Leak Detection and Leak Shut Down 

Requirements 

Objective: Reduce pipeline leaks and protect human health and safety.

Requirement/Standard: Meet the requirements of 18 AAC 75.055 for the pipeline carrying crude oil 

from GMT2 to GMT 1, including using external leak detection for prompt identification of leaks, daily 

flow verification, weekly visual surveillance, and demonstrated ability to stop flow within one hour of 

detection. 
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Potential Benefits and Residual/Unavoidable Impacts: The pipeline carrying crude oil from GMT2 to 

GMT1 is a flow line regulated under 18 AAC 75.047. Although it does not meet the definition of a crude 

oil transmission pipeline because it also carries gas and produced water, complying with the 18 AAC 

75.005 requirements for crude oil transmission pipelines will ensure early detection and response to any 

leaks. This will minimize impacts to human health and the environment from pipeline leaks.

4.5.7.3 Potential Mitigation Measure 3: Fuel Storage (new subparagraph to BMP A-4)

Objective: Minimize the impact of contaminants on fish, wildlife, and the environment, including 

wetlands, marshes, and marine waters, as a result of fuel, crude oil, and other liquid chemical spills. 

Protect subsistence resources and subsistence activities. Protect public health and safety.

Requirement/Standard: Fuel and hazardous material storage containers with a capacity greater than 660 

gallons must use impermeable lining and diking capable of containing 110 percent of the containers’ 

capacity. Vinyl liners, with foam dikes and a capacity of 25 gallons, must be placed under all valves or 

connections to fuel tanks when located outside of secondary containment. 

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 l providing secondary containment for storage containers greater than 660 gallons and using 

liners for protection outside of secondary containment. 

4.5.7.4 Potential Mitigation Measure 4: 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.

4.5.7.5 Potential Mitigation Measure 5: Facility Equipment and Design Criteria (new 

subparagraph to BMP A-3)

Objective: Minimize pollution by ensuring adequate facility design criteria and system integrity.

Requirement/Standard: Equipment used to develop hydrocarbons must meet the following standards:

a. Equipment must be designed in accordance with standard Arctic engineering practices for use in 

Arctic conditions;

b. Design criteria must be based on conservative estimates (as determined by the authorizing 

officer). 
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Potential Benefits and Residual/Unavoidable Impacts: System integrity is essential for spill 

prevention, but not all integrity requirements are within the scope of Oil Spill Contingency Planning. 

Potential benefits of these added measures above current protections include additional protection for 

vegetation, wetlands, and other surface resources by ensuring facility design and system integrity are 

suitable to harsh Arctic environmental conditions. 

4.5.7.6 Potential Mitigation Measure 6: Leak Detection Criteria (new subparagraph to 

BMP E-4) 

Objective: Implement leak detection systems for GMT1 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.

4.5.7.7 Potential Mitigation Measure 7—GMT2 Industrial Disaster Response Plan for 

Nuiqsut 

Objective: To minimize the direct effects to the community of Nuiqsut resulting from large-scale health 

and safety incidents at GMT2 or associated facilities. 

Requirement/Standard: An emergency contingency plan and associated evacuation plan specific to 

responding to an industrial disaster in close proximity to the community of Nuiqsut should be created to 

identify the appropriate response by the community to a variety of health and safety events that could 

occur at the GMT2 Project. The North Slope Borough should be consulted and the City of Nuiqsut, 

Native Village of Nuiqsut, and Kuukpik Corporation should be directly involved in the creation of both 

plans. Ideally, the plan would be created in consultation with other industrial operators in the Nuiqsut 

vicinity, so that it is applicable for any potential industrial disaster within a 50-mile radius of the 

community. 

Potential Benefits and Residual/Unavoidable Impacts: The emergency contingency plan and 

associated evacuation plan will be a resource to be utilized by the community of Nuiqsut should a largescale industrial health and safety event occur.

4.5.7.8 Potential Mitigation Measure 8—Creation of Emergency Respite Zone

Objective: Protect health of sensitive populations, such as the children and the elderly, in the event of an 

industrial disaster.

Requirement/Standard: Install air filters in schools and public buildings. Use HEPA filters for PM 

impacts and carbon filters for VOC impacts.

Potential Benefits and Residual/Unavoidable Impacts: Children and the elderly are the most sensitive 

populations impacted by air pollution. These sensitive groups spend many hours in public buildings and 

schools. Utilizing air filtration systems will reduce incursions of outside air pollution into buildings and 

create respite zones that can be used by the entire community.
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4.5.8 Conclusions

The direct impacts of oil, process water, and hazardous substance spills are similar under the three action 

alternatives. 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 to a pad area or containment 

and resulted in minor impacts with low intensity, short duration, and limited extent (GMT1 SIES, BLM, 

2014).

4.6 Cumulative Impacts

The cumulative impact analysis considers impacts of a proposed action and its alternatives that may not 

be consequential when considered individually, but when combined with impacts of other actions, may be 

consequential (Council on Environmental Quality 1997b). As defined by Council on Environmental 

Quality regulations (40 CFR 1508.7 and 1508.25[a][2]), a cumulative impact is: 

...the impact on the environment which results from the incremental impact of the action when 

added to other past, present, and reasonably foreseeable future actions regardless of what agency 

(Federal or non-Federal) or person undertakes such other actions. Cumulative impacts can result 

from individually minor but collectively significant actions taking place over a period of time.

The purpose of this cumulative impacts analysis is to determine if the impacts of the actions considered in 

this supplemental EIS, together with other past, present, and reasonably foreseeable future actions, have 

the potential to interact or accumulate over time and space, either through repetition or combined with 

other impacts, and under what circumstances and to what degree they might accumulate. 

4.6.1 Background

The cumulative impacts analyses described in BLM (2004, Section 4.G, pages 1233–1333), BLM (2008, 

Section 4.7, pages 4-631–4-929), BLM (2012, Section 4.8, pages 1–296), and Point Thomson EIS (U.S. 

Army Corps of Engineers 2012, Section 4.2, page 4-2) provide a broad cumulative impacts analysis of 

existing and potential oil and gas-related activities on the North Slope. The cumulative impacts analyses 

for this supplemental EIS begins by reviewing the cumulative impacts summary and conclusions in BLM 

(2004) and BLM (2012), followed by an identification and evaluation of changes (e.g., new actions, new 

data) relevant to analysis of cumulative impacts of developing the proposed GMT2 Project. 

4.6.2 Methodology

This cumulative impacts analysis follows the methodology outlined in BLM (2014) and tiers to two 

previous analyses, although the overall scope of the analysis and project area are narrower. The analysis 

of cumulative impacts follows guidance provided in Considering Cumulative Effects under the National 

Environmental Policy Act (Council on Environmental Quality 1997b). The supplemental EIS will identify 

and describe actions—past, present, and future—that may impact the elements of the environment, 

including people, that may be impacted by the proposed project. These include not only the proposed 

project, but also actions undertaken by others within and outside the project study area. The supplemental

EIS also provides the geographic and temporal scope of the analysis and addresses additive, synergistic, 

and countervailing impacts among the cumulative impacts. 

This analysis involves the following steps:

• Define the time frame and geographic scope for each resource/issue analyzed in this supplemental

EIS.

• Identify past present and future actions within the geographic area.

• Characterize response to changes and evaluate cause-and-effect relationships.
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• Determine the magnitude of cumulative impacts from current conditions and if any thresholds of 

significance would be exceeded.

In this supplemental EIS, both the time period and geographic scope of the cumulative impacts analysis 

vary according to the resource/activity under consideration. Generally, the appropriate timeframe for 

cumulative impacts analysis spans from the 1970s through 2050 (through the duration of the proposed 

project). Geographic scope generally encompasses the Harrison Bay and Lower Colville River 

watersheds. Specific timeframe and geographic scope restrictions are located in Section 4.6.2.

• Time Frame for Relevant Past and Reasonably Foreseeable Future Actions: While relevant past 

projects date back to the 1940s, the general timeframe used in this cumulative impacts analysis 

reflects more recent oil and gas activities. Unless otherwise specified, the general timeframe ranges 

from the 1970s through the duration of the proposed project until roughly 2050. Projections of 

projects beyond this time frame (or 30 to 35 years) become speculative. Resource-specific time 

frames are presented in Table 140. 

• Geographic Area of Relevant Past and Reasonably Foreseeable Future Actions: 

o Unless otherwise specified, the geographic extent for the cumulative impacts analysis is 

limited to the Harrison Bay and the Lower Colville River Watersheds (see Map 4.6-1.). 

o Resource-specific geographic areas are presented in Sections 4.6.4, 4.6.9, and 4.6.10.

• Impact Evaluation: Unless specified otherwise, the magnitude (intensity), duration, context, and 

geographic extent described in Sections 4.2 and 4.3 are used for determining the cumulative impact 

analysis of each respective resource/activity. The analysis also considers the interaction among the 

impacts of the proposed action with the impacts of various past, present, and reasonably foreseeable 

future actions as described below:

o Additive; the impacts of actions add together to make up the cumulative impact.

o Countervailing; the impacts balance or mitigate the impacts of other actions.

o Synergistic; the impact of the actions together is greater than the sum of their individual 

impacts.

Impacts from past, present, and reasonably foreseeable future actions within these timeframes and 

geographic areas were combined with those from GMT2 to determine if a threshold of significance would 

be exceeded. The BLM considers mitigation and monitoring requirements to determine if these 

supplemental protective measures would avoid or minimize impacts. 

Facilities with very small footprints such as the U.S. Geological Survey Fish Creek Meteorological 

Station located approximately 2.3 miles northwest of the GMT1 pad are expected to have a negligible 

contribution to cumulative impacts and are not included in the cumulative impacts analysis. Likewise, 

activities that have the potential to adversely impact paleontological and cultural resources are required to 

have professional inventories and reports filed with the appropriate agencies prior to starting the proposed 

action, including potential gravel sources, cross-country winter travel routes, ice road and ice pad 

locations, and temporary summer camps. These requirements provide assurances that adverse impacts to 

paleontological and cultural resources will be minimized, if not eliminated. Accordingly, paleontological 

and cultural resources are not discussed further.

Table 139 describes the time frame, geographic scope, and direct and indirect impacts of the proposed 

development.
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Table 139. Summary of resource/issues time frame and geographic scope

Resource or Issue

Time Frame (through duration of 

proposed project Geographic Scope

Terrestrial Environment 1970s through 2050 Harrison Bay and Lower Colville River 

(from Umiat north) Watersheds

Aquatic Environment 1940s through 2050 Harrison Bay and Lower Colville River 

(from Umiat north) Watersheds

Soil Resources 1970s through 2050 Harrison Bay and Lower Colville River 

(from Umiat north) Watersheds

Atmospheric Environment 1970s through 2050 Nuiqsut area to North Slope

Noise Intermittent from

1970s through 2050

The range of impact from noise depends 

on the source and atmospheric 

conditions; certain sources under certain 

conditions can be heard as far as 20 

miles away; the geographic area for noise 

was set at 20 miles from the Arctic Slope 

Regional Corporation gravel pit and the 

Alpine Central Processing Facility airstrip

Vegetation and Wetlands 1970s through 2050 Harrison Bay and Lower Colville River 

(from Umiat north) Watersheds

Fish and Fish Habitat 1970s through 2050 Harrison Bay and Lower Colville River 

(from Umiat north) Watersheds

Birds 1970s through 2050 Species dependent, but would include 

distribution area of birds being analyzed

Terrestrial Mammals 

(caribou)

1970s through 2050 Species dependent, but would include 

distribution area of animals being 

analyzed

Marine Mammals 1970s through 2050 Beaufort Sea from Cape Halkett to Milne 

Point

Threatened and 

Endangered Species

1970s through 2050 Species dependent, but would include 

distribution area of animals being 

analyzed

Sociocultural Systems 1970s through 2050 North Slope communities, particularly 

Nuiqsut

Public Health 1970s through 2050 North Slope communities, particularly 

Nuiqsut

Economy 1970s through 2050 North Slope Borough and Arctic Slope 

Regional Corporation

Subsistence 1970s through 2050 Primarily the Nuiqsut Subsistence Use 

Area

Environmental Justice 1970s through 2050 Nuiqsut

Land Use and Ownership 2013 through 2050 (2013 Integrated 

Activity Plan/EIS is base year)

Harrison Bay and Lower Colville River 

(from Umiat north) Watersheds

Recreation 1970s through 2050 Harrison Bay and Lower Colville River 

(from Umiat north) Watersheds

Visual Resources 1970s through 2050 Viewshed near development area

Transportation Systems 1970s through 2050 Harrison Bay and Lower Colville River 

(from Umiat north) watersheds and Umiat 

Road between Dalton Highway and Umiat

Oil, Saltwater and 

Hazardous Materials Spills

1940s through 2100 Harrison Bay and Lower Colville River 

(from Umiat north) Watersheds, and 

coastal regions
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4.6.2.1 Assumptions

Key assumptions used for the cumulative impacts analysis in this supplemental EIS are:

• Development of the oil and gas resources of the GMT Unit is consistent with the Secretary of the 

Interior's most recent decisions to offer federal oil and gas leases in the NPR-A.

• As a stand-alone production facility in the GMT Unit, cumulative impacts from GMT2, including 

abandonment and final reclamation, would extend 30 to 50 years. Development and production at the 

Willow prospect (located in the adjacent Bear Tooth Unit) would utilize infrastructure at GMT2 such 

as a road (if permitted) and pipeline vertical support members and would extend the period of some 

cumulative impacts at GMT2 for an additional period to coincide with abandonment and final 

reclamation at the conceptual Willow Development. 

• The BLM has approved a substantial number of winter exploration wells in the area known as the 

GMT Unit. Newly-identified and economically recoverable oil resources resulting from these or other 

future drilling projects in the GMT Unit may further extend the cumulative impacts of GMT2 based 

on BLM policy to minimize the number of permanent facilities such as gravel roads and elevated 

pipeline systems to the maximum extent practicable.

• Approval of a permit to drill at GMT2 would likely result in the transfer of selected land within the 

GMT2 Project area to the Kuukpik Corporation. Conveyance of surface ownership would also result 

in the transfer of associated mineral resources to Arctic Slope Regional Corporation. 

• Alternatives A, B, and C would meet the purpose and need identified in Section 1.3.

• Alternative D would not meet the purposes and need identified in Section 1.3.

• Alternative D would deny the production of economically viable oil resources in the GMT Unit that 

are 8 to 16 miles from existing oil production and transportation facilities connected to the TransAlaska Pipeline System in the Prudhoe Bay area. Prohibiting a project in the GMT Unit that 

otherwise appears to meet the requirements contained in federal oil and gas leases, as amended in 

2008, and the requirements of BLM (2013), may result in industry uncertainty and concern that 

proposed developments meeting the requirements of the lease and land use plans would be denied. 

This uncertainty could reduce industry interest in development on federally managed lands in the 

NPR-A.

4.6.2.2 Past, Present and Reasonably Foreseeable Future Actions

Table 140 summarizes projects to be considered in the cumulative impacts analysis within the Harrison 

Bay and Lower Colville River Watersheds for a period extending to about the year 2050. A discussion of 

activities outside the Harrison Bay and Lower Colville River Watersheds that may contribute to 

cumulative impacts follows the table.
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Table 140. Past, Present and Reasonably Foreseeable Future Developments 

Category

Production 

Unit/General 

Location Project/Activity Description

Past, Present, 

or Future 

Project a? 

Approximate 

straight-line 

distance to 

Nuiqsut (miles)

Oil and Gas 

Exploration 

and 

Development

Colville River 

Unit

Alpine (CD1, 

CD2)

Exploratory wells first drilled in 1994. CD1 pad developed and 

produced first oil in 2000. Alpine development includes a central 

processing facility, an airstrip and 3 miles of gravel road. Total 

surface development 97 acres. Two drill pads with approximately 

140 wells, connected to Kuparuk pipeline system by 34 miles of 

pipeline.

Present 8

Qannik Expansion of CD2 Drill Pad. 18 wells were added in 2007 –

routine infill drilling ongoing. 

Future 8

Fjord (CD3) Drill pad with airstrip built 2005-2006. CD3 is not connected to 

other infrastructure via road and builds a yearly ice road. 

Present 14

Nanuq (CD4) Existing drill pad with road built in 2005-2006. Present 5

Alpine West 

(CD5)

Drill pad constructed in 2014, currently in drilling phase. 6 miles of 

road and four bridges. Connected by pipeline to Alpine Facility. 

Future 8

Fjord West 

(CD2, CD3, 

CD5)

This reservoir will be accessed from CD2, CD3, and CD5, with 

drilling expected to begin from CD2 in Q1 2020. Up to 32 wells will 

be added to CD2 via a 5.8 acre gravel pad expansion -- routine 

infill drilling. 

Future 8 (from CD2)

Greater 

Mooses 

Tooth Unit

GMT1 (CD6) 12 acre drill pad, 33 wells to be drilled from 2019-2022. Project 

includes a 7.6 mile road from CD5 to GMT1 drill pad. 

Present/Future 12

Rendezvous Exploratory wells -- discovery wells for GMT2 development. Drilled 

in 2000. 

Past 16
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Category

Production 

Unit/General 

Location Project/Activity Description

Past, Present, 

or Future 

Project a?

Approximate 

straight-line 

distance to 

Nuiqsut 

(miles)

Oil and Gas 

Exploration 

and 

Development

Kuparuk 

River Unit

Meltwater Exploratory well that became drill site 2P in 2001, currently has 15 

wells drilled.

Present 17

Palm (Drill Site 

3S) 

Exploratory well that became drill site 3S in 2002, now in production. Present/Future 23

Tarn Exploratory wells that became drill sites 2L and 2N in 1998, now in 

production. 

Present 17

Kuparuk 3 central processing facilities, a seawater treatment plant, 47 11-acre 

drill pads with over 1,150 wells. Approximately 520 acres of surface 

development. Originally built from 1979-1981, production is ongoing 

and more development is planned. 

Present/Future 28 (from CPF2)

Tabasco This reservoir is being accessed from drill site 2T, which started 

production in 1998. Currently producing. 

Present 25

Shark Tooth 

(Drill Site 2S)

New gravel pad with up to 24 wells, new powerlines and pipeline, and 

14 new wells drilled on existing pad. Construction began in 2014, 

facility currently in production.

Present 20

West Sak/NE 

West Sak

Drill site 1H expanded by 9 acres to accommodate 18 additional wells.

Drilling will commence in Q3 2017, and will last approximately 1.5 

years -- routine infill drilling. 

Present/Future 35

Bear Tooth 

Unit

Tinmiaq/Willow 2 exploratory wells in 2016, 3 exploratory wells in 2018. May do 

additional appraisal wells in 2019. The development plans proposed 

by ConocoPhillips include a central processing facility and up to four 

satellite drill pads, gravel road connections between pads, a new 

airstrip, a potential new gravel mine and temporary infrastructure for a 

sealift operation. Estimated 400M to 750M barrel oil find.b 

Present/Future 27

Cassin 2 exploratory wells drilled in 2013. Currently being evaluated for 

development potential. 

Present/Future 29

Pikka Unit

Qugruk Three existing exploration wells drilled in 2013. Present 18

Nanushuk EIS is currently under development by the USACE, estimated 

construction date is unknown. Proposed project includes 3 drill pads 

with 78 wells, 1 operations pad and CPF. Project includes 25 miles of 

gravel road and 4 pads, totaling 288 acres of gravel fill. Estimated 

project life 30 years. 

Future 12
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Category

Production 

Unit/General 

Location Project/Activity Description

Past, Present, 

or Future 

Project a? 

Approximate 

straight-line 

distance to 

Nuiqsut 

(miles)

Oil and Gas 

Exploration 

and 

Development

Ooguruk Unit

Oooguruk 6-acre gravel island with 40 wells constructed in 2007-2008, ongoing 

development drilling. Project connected to onshore infrastructure via 

subsea flowline bundle connected to onshore tie in pad connected to 

Kuparuk. Estimated project life 30 years (2038).

Present/Future 26

Ooguruk Unit

Nuna Planned onshore well pads that will tie into Kuparuk infrastructure. 

Two well pads are planned, one has been constructed. Project will 

have associated roads and pipelines. Start date 2018 or later. 

Future 22

Placer Unit Placer 3 exploration wells drilled in 2016, unspecified future development 

plans.

Present/Future 17

Southern 

Miluveach 

Unit

Mustang Exploratory well, plans to develop on hold pending additional 

investors. Mustang will include up to 11 production wells, 20 reinjection wells, and an operations camp. Start date TBD, company 

looking for investors.

Present/Future 17

Nikaitchuq 

Unit

Eni Nikaitchuq Two drill pads with 52 planned wells. One pad onshore at Oliktok Point 

and one pad on 11 acre artificial gravel island (Spy Island) pads 

connected by a 3.8-mile underwater pipe bundle. Construction began 

in 2008, 23 wells have been drilled to date. Project currently in 

production with further drilling planned in 2017. Estimated project life 

30 years (2041).

Present/Future 36

No Unit Pipeline from 

Smith Bay

Potential pipeline route to cross impact zone, unknown project start 

date.

Future

No Unit Stony Hill Exploratory well drilled in 2018, located approximately 7.5 miles SSW 

of Nuiqsut.

Present 7.5

Colville River 

Unit

Putu Exploratory wells located in the vicinity of Nuiqsut, drilled in 2018. Present 5

No Unit West Willow Exploratory well drilled in 2018. Present 36

No Unit Horseshoe Exploratory wells drilled in 2017, unspecified plans to develop 

resources.

Present/Future 12

Various 

Locations

Seismic 

Exploration 

Seismic surveys will occur in multiple locations within the cumulative 

effects area boundary.

Future N/A
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Category

Production 

Unit/General 

Location Project/Activity Description

Past, Present, 

or Future 

Project a?

Approximate 

straight-line 

distance to 

Nuiqsut 

(miles)

Transportation

Community 

of Nuiqsut

Colville River 

Access Road

Proposed gravel road from water source lake to Colville River. Road 

permitted in 2016.

Future Within 

Community

Nuiqsut Airport Single runway airport with 4,589 ft x 100 ft gravel runway, built in 1983. 

Proposed extension and paving of runway under consideration, no 

start date identified.

Present/Future Within 

Community

Intra-village 

roads

Gravel road system located within Nuiqsut, including access to landfill 

and water source lake, totaling approximately 10 miles.

Present Within 

Community

Community 

of Nuiqsut

Nuiqsut Spur 

Road

Existing gravel road from Nuiqsut to CD5 Access Road built in 2014. Present 0 to 6

Gravel Mines Vicinity of 

Nuiqsut

ASRC Mine Site Active gravel mine with planned expansion. Expansion proposing 300+ 

additional acres of mining beginning in 2018 is currently under 

consideration at USACE.

Present/Future 4.5

Willow gravel 

mine.

Gravel mine to support Willow project. Future 6

Utilities

Community 

of Nuiqsut

Nuiqsut City 

Powerplant and 

Natural Gas 

Pipeline

Pipeline from Alpine CPF to community of Nuiqsut built in 2009, 

includes six generators. Upgrades to include installation of equipment 

for removal of hydrogen sulfide from the gas stream.

Present Within 

Community

Community 

of Nuiqsut

Nuiqsut Landfill Built in 1986 with 4 cells, the landfill currently operates with 3 cells. 

The landfill facility includes a salvage area, burn cage, septic 

tank/honey bucket lagoon, and a used drum storage area.

Present Within 

Community

a Past = a project that is no longer in operation, but whose impacts are still felt in the environment and will overlap in time and space with the impacts of GMT2. Present = a project that 

is currently in operation, whose impacts will overlap with GMT2. Future = a reasonably foreseeable future project, defined as a project for which there is an existing proposal, a project 

currently in the NEPA process, or a project to which a commitment of resources (such as funding) has been made. 

b The BLM received a request from ConocoPhillips Alaska, Inc., to conduct a Master Development Plan EIS to evaluate the Willow development in May 2018. The most current 

information from that request letter has been incorporated into the cumulative effects analysis. Although the Willow development would use GMT2 and Alpine infrastructure to the 

maximum extent possible, this prospect has independent utility from GMT2, and thus, is not a connected action under NEPA. The Willow prospect is sufficiently large that even in the 

absence of a road connection between GMT2 and GMT1, Willow could be developed roadlessly, similar to the Alpine field.
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Other Activities That May Contribute to Cumulative Impacts

In addition to projects that are physically located in the Lower Colville River and Harrison Bay 

watersheds, there are several projects whose impacts may overlap with GMT2 that are located outside this 

geographic area. 

Liberty Project

The proposed Liberty Oil and Gas Development Project is currently in the NEPA process and is being 

analyzed by the Bureau of Ocean Energy Management. Liberty is located approximately 20 miles east of 

Prudhoe Bay and inland of the Beaufort Sea’s barrier islands. The Liberty Project will have overlapping 

impacts with the GMT2 Project in three areas: social impacts to the community of Nuiqsut due to 

participation in multiple simultaneous NEPA processes, overlapping impacts to overall subsistence uses, 

and greenhouse gas emissions contributing to global climate change.

Alaska Stand Alone Pipeline

The Alaska Stand Alone Pipeline project is a proposed natural gas pipeline that would follow the TransAlaska Pipeline System from the gas conditioning facility in Prudhoe Bay south to a connection with the 

existing ENSTAR natural gas pipeline system in the Matanuska-Susitna Borough. The physical impacts 

of the conceptual Alaska Stand Alone Pipeline Project are unlikely to overlap with GMT2 (with the 

exception of greenhouse gas emissions contributing to global climate change), but the social impacts 

associated with the community of Nuiqsut’s participation in a parallel NEPA process will overlap and be 

additive to the impacts of the GMT2 NEPA process.

Projects Not Considered in the Cumulative Effects Analysis

Leasing Program for the Coastal Plain of the Arctic National Wildlife Refuge

Title II of the Tax Cuts and Jobs Act of 2017 (Tax Act), directs the Secretary of the Interior, acting 

through the Bureau of Land Management, to establish and administer a competitive oil and gas program 

for the leasing, development, production and transportation of oil and gas in and from the Coastal Plain of 

the Arctic National Wildlife Refuge (Tax Act section 20001(b)(2)(A)). The Tax Act amended the Alaska 

National Interest Lands Conservation Act section 303(2), which established the Arctic National Wildlife 

Refuge, by adding an additional purpose to “provide for an oil and gas program on the Coastal Plain.” Oil 

and gas leasing in the Coastal Plain of the Arctic National Wildlife Refuge is reasonably foreseeable; 

however, its impacts will not overlap geographically with the projected impacts of the GMT2 Project. The 

leasing plan has therefore not been considered in the evaluation of cumulative impacts.

Alaska Strategic Transportation and Resources (ASTAR)

The State of Alaska’s Arctic Strategic Transportation and Resources (ASTAR) project seeks to identify 

regional infrastructure needs in the Arctic. The goal is to develop a strategic plan that prioritizes 

community needs and then identifies infrastructure opportunities that offer the highest cumulative benefit 

and which best enhance quality of life in the region. ASTAR is still in the early stages, scoping has not 

occurred and no specific projects are reasonably foreseeable at this time. The ASTAR strategic plan has 

therefore not been considered in the evaluation of cumulative impacts. 

4.6.3 Cumulative Impacts to the Terrestrial Environment

The evaluations in this section describe the direct and indirect effects of gravel fill and gravel mining on 

cumulative effects evaluations from past, present and reasonably foreseeable future projects for 
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physiography, soil, and permafrost (Section 4.2.1). As noted above in Section 4.6.2, impacts to 

paleontological resources are not expected to occur and as a result are not discussed further. 

Additive cumulative effects have occurred from some 40 years of construction activity in the area 

(including the Native Village of Nuiqsut); maintenance and abandonment of military sites along the coast; 

development, use, and abandonment of Legacy Wells in the NPR-A; and, oil and gas development at 

Kuparuk, Alpine, and Umiat (including gravel footprint from extraction and construction and winter 

exploration activity). Future impacts could include pipelines and infrastructure to support oil development 

off the coast of Alaska as well as reasonably foreseeable future projects in the NPR-A. Cumulatively 

(including the Native Village of Nuiqsut, Military Development, Legacy Wells, Kuparuk, Alpine, Umiat, 

Umiat Road and Pipeline.), the footprint is approximately 10,200 acres. 

The cumulative impacts from the proposed project to the physiography, soil, and permafrost of the area 

would be directly related to the construction materials needed for production of oil from the GMT2 site. 

Gravel would be mined from the existing Arctic Slope Regional Corporation Mine site, which would 

result in an incremental cumulative impact as the mine site is expanded to meet the gravel demand for the 

GMT2 Project. Demand for gravel for future developments may utilize the undeveloped Clover potential 

gravel source; however, no project that is currently under construction or reasonably foreseeable will 

utilize gravel from the Clover source.

The GMT2 site, in combination with existing gravel footprints and footprints of GMT1, and CD5 pads 

would represent present disturbance. Additional footprints from Willow, including a central processing 

facility, development pads, and gravel from a prospective source cannot be quantified at this time.

Developments in permitting total approximately 23,000 acres, which represents 0.5 percent of the 

geographic extent of this analysis. An analysis of the current and known future projects indicates that the 

impacts of each development run about 0.26 to 0.27 percent of the project area. The potential for future 

impact to the existing physiography, soil, permafrost regimes and to petroleum resources are recognized 

and at this time are expected to be less than 0.3 percent of each development area in the future as well; 

therefore, potential future impacts are expected to be similar to the approximately 23,000 acres described 

above. the impact from potential remediation/reclamation of former Military Sites and Legacy Wells 

cannot be quantified at this time and would have a countervailing impact due to uncertainty of federal 

funding availability and the relative priority and timing of site cleanup, when compared to similar sites 

across the North Slope and Alaska.

The duration of the impacts ranges is short-term (1 to several years) if the vegetation is disturbed and up 

to several decades if the soils are destroyed. Incremental impacts of the proposed project would be small 

(approximately 2 to 3 percent) when compared to past, present, and future development. While soils and 

permafrost impacts are additive, the total and incremental amount of disturbed area is small compared to 

the total resource within the North Slope region and is not considered to be cumulatively significant 

(BLM 2004, Section 4G.5.3). The short-term impacts are expected to diminish after a few years, with the 

long-term impact estimated to be about 3 percent of the original footprint regardless of the alternative 

(BLM 2012, Section 4.8.7.3). The long-term impact resulting from the fugitive dust that roads and pads 

may contribute to the increased rate of permafrost degradation, which may adversely affect the stability of 

the gravel fills overtime. Effects would be localized, long-term, and potentially major. More gravel and 

reconstruction may be necessary over the life of project. The decrease in albedo may cause higher 

temperatures and increase thaw rates.

If global climate change persists, the cumulative effects to soil from oil and gas development, and non-oil 

and gas development, on the North Slope could be greater than predicted. If the climate warms, the 

permafrost will thaw to an increased depth each season, which will cause varying degrees of impacts on 

subsidence, soil moisture, and vegetation. Since there is great depth of the permafrost on the North Slope 

it would take several decades of warming at the predicted rate before it would transition into 
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discontinuous permafrost. However, if the permafrost continues to warm, its ability to support structures 

would diminish, which could affect development on the North Slope. Thicker gravel may be needed to 

support structures, and abandoned work pads and roads could become unusable as they are cut up by deep 

polygonal troughs over thawing ice wedges, or by other thermokarst degradation (BLM 2012, Section

4.8.7.3). 

Overall cumulative impacts to the physiography, soil, permafrost, and geology resources would be minor, 

site specific, and long-term. Projects near proposed new access would have an additive effect. Cumulative 

impacts to petroleum resources would be major due to depletion, although primarily limited to the GMT 

Unit. Alternative D would not have any disturbance to physiography, soil, permafrost, and geology.

Reasonably foreseeable future development would increase the direct footprint of gravel fill and gravel 

mining for all projects (oil and gas and non-oil and gas); these impacts would likely be concentrated along 

the coast between the Canning River and westward into the NPR-A. The north-south Dalton Highway and 

Trans-Alaska Pipeline System also supports oil and gas development on the North Slope by providing 

direct access to the rest of Alaska and other markets. A natural gas pipeline system would be located in the 

vicinity of both the Dalton Highway and Trans-Alaska Pipeline System. Overall impacts to the landscape 

would be minor, site specific, and long lasting, depending on the relationship of a reasonably foreseeable 

future development for projects near existing or proposed new access.

The proposed action is consistent with the provisions of the federal oil and gas leases in the project area, 

and the land use plan approved in BLM (2013). Overall, the direct and indirect impacts to physiography, 

and geology, other than petroleum and gravel resources, are predicted to be of moderate intensity and 

long-term in duration, but of local extent. Because the resources are common, the overall direct and 

indirect impacts are characterized as minor for all action alternatives. The cumulative effect of Alternative 

D would incur no incremental impacts to gravel or other geologic resources. Petroleum resource impacts 

would be major across the action alternatives.

4.6.4 Cumulative Impacts to Water Resources

Cumulative impacts to water resources and water quality from oil and gas exploration, development, and 

production in the NPR-A and across the North Slope would result from: (1) thermokarst from damaged 

vegetation and streambanks; (2) water withdrawals from lakes; (3) disruption of natural flows by roads, 

pads, and river crossing structures; (4) gravel mining; and (5) spills. Cumulative impacts to water 

resources in the project area are discussed more fully in BLM (2004a, Section 4G.5.6 and Section 4G.5.7)

and BLM (2012, Section 4.8.7.4).

4.6.4.1 Past and Present Impacts and Their Accumulation

Approximately 2,500 acres of direct land surface disturbance from non-oil and gas activities have 

impacted waterbodies and drainage patterns (BLM 2012, 4.7.8.4). Scientific excavations; temporary tent 

camps; overland moves by transport vehicles; aircraft landings, and use of gravel strips; boats; use of offhighway vehicles such as four-wheel vehicles and snowmachines; hazardous material or debris removal;

legacy well plugging; and small fuel spills; all have the potential to impact water resources and quality. 

These impacts are usually localized and result in short-term impacts for up to a few years. Large amounts 

of debris were left on the North Slope from exploration and military activities from 1940 to 1970 that 

impacted water quality, but cleanup efforts since the 1970s have removed some of the remaining debris.

Through 2011, oil and gas activities have caused approximately 18,400 acres of direct impacts to lands on 

the North Slope, and indirect impacts to water resources may have occurred on another 18,400 acres. 

These impacts to water resources are likely to persist for several decades or more. Water withdrawals are 

required for all oil field operations. Permit regulations have maintained water quality and quantity in lakes 

as natural recharge processes have been sufficient to recharge the lakes each year.
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Through 2011, over 9,500 acres of gravel pads and roads were constructed in association with oil-field 

development on the North Slope. Inadequate design and placement of structures, culverts, or bridges have 

caused impoundments, streambank erosion, scour, and sedimentation at stream crossings. This has altered 

natural sediment transport and deposition, creating scour holes or channel bars. Several spills have 

occurred on the North Slope, but their impacts have been minor and have likely not accumulated. Effects 

of discharges from offshore facilities and subsurface injection of drilling wastes are largely unknown, but 

likely have had little cumulative effect on water quality on the North Slope.

4.6.4.2 Future Impacts and Their Accumulation

Activities Not Associated With Oil and Gas Exploration and Development

BLM (2004a; 2012) concluded non-oil and gas activities such as construction of roads and pads at 

villages could impact waterbodies and drainage patterns, but would be minor due to the slow growth (2

percent annually) of the communities. Water to support the cleanup of abandoned military sites and 

Legacy Wells would likely come from the same lakes used originally. None of these water supply lakes 

are associated with the construction and operations of the GMT2 Project or with other reasonably 

foreseeable demand for water in the Nuiqsut area.

A large amount of debris was left on the North Slope from Legacy Well exploration and military activities 

from 1940 to 1970 that impacted water quality, but on-going cleanup efforts since the 1970s have 

removed some of the remaining debris. The BLM has assessed the condition of the U.S. Geological 

Survey Legacy Wells and embarked on a program to plug and abandon those wells that pose risks.

Between 2002 and 2013, the BLM had plugged 18 of 19 wells identified to pose a potential risk to the 

environment. A detailed assessment of the Legacy Wells was made in 2013 and identified 50 additional 

wells needing remediation. This assessment can be found in the BLM National Petroleum Reserve in 

Alaska: 2013 Legacy Wells Summary Report (BLM 2013b). These and other remediation and reclamation 

projects in the Harrison Bay and Lower Colville River Watersheds would have a cumulative, long-term, 

countervailing, and local impact to water quality.

Oil and Gas Exploration and Development Activities

BLM (2012) analyzed potential cumulative impacts on water resources and water quality from oil and gas 

development in the Beaufort Sea offshore leases, construction of a commercial gas pipeline, and 

unconventional oil and gas development east of the NPR-A. Large discoveries of oil in the Chukchi or 

Beaufort Seas offshore could make additional developments in the northern NPR-A more economically 

feasible, resulting synergistically in even more impacts in the NPR-A. In general, all action alternatives, 

present and reasonably foreseeable future projects, such as Willow, have the potential for long-term 

cumulative impacts to local water resources resulting from the placement of new infrastructure. During 

most winters, ice roads are constructed between staging areas in the Kuparuk River Unit to locations 

within the NPR-A as far west as Smith Bay. Water needed for construction of CD5 was available and has 

been permitted. Generally, oil and gas development in the project area will have impacts on local water 

resources from sedimentation, water withdrawal, and altered drainage patterns. As described in BLM 

(2014), impacts to water resources from GMT1 will include localized impacts such as increased 

inundation levels and impacts from the Tinmiaqsigvik (Ublutuoch River) bridge. Improper siting of 

gravel mine sites could result in changes to the configuration of stream channels, stream flow hydraulics 

or lake dynamics, erosion and sedimentation. Gravel removal for roads and pads has resulted in over 

6,400 acres of surface impacts through 2011, with 4,550 acres rehabilitated by conversion into functional 

habitat for plants and animals and possible fish habitat (BLM 2012, Section 4.8.7.4, page 91). The 

Ublutuoch and/or Clover Mine site will be required as development moves west and greater distances 
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from the Arctic Slope Regional Corporation Mine site near Nuiqsut. Gravel mining for oil and gas 

development is projected to account for a total of 10,950 acres by the year 2100 (Table 140).

BLM (2012) determined that some lakes were being pumped annually along primary transportation routes 

until development commenced. If lakes do not fully recharge or have water quality changes, future 

withdrawals may be conditional upon permit stipulations. It is possible that if water is drawn from a 

majority of lakes in a concentrated area, this could affect the surface flow regime of an area (BLM 2012, 

Section 4.8.7.4, page 94). Long-term pumping of lakes adjacent to the Willow development for drinking 

water will also require water quantity and quality monitoring similar to those lakes near Alpine.

Seismic and overland travel (including non-oil and gas activities) could result in thermokarst erosion with 

associated increases in turbidity of adjacent waterbodies. BLM (2004a) determined that construction of 

gravel roads and pads, road crossing structures and removal of gravel from riverine pools could affect 

water flow and result in subsequent melting of permafrost (thermokarst) and induce changes to stream 

morphology (BLM 2004a, Section 4G.5.6).

Dust deposition along roads can contribute to more extensive thermokarst in areas adjacent to roads and 

gravel pads (Walker et al. 2014) and increase turbidity of adjacent waterbodies. Snowdrifts along gravel 

and building structures can increase wintertime soil surface temperatures and result in increased thaw 

depths, contributing to thermokarsting (BLM 2012, Section 4.8.7.4, page 91). These impacts would be 

considered additive, but local, long-term, and minor in effect.

Inadequate design and placement of structures, culverts, or bridges and unbreached or slotted ice bridges 

could cause impoundments, streambank erosion, and scour and sedimentation at stream crossings, thereby 

altering natural sediment transport and deposition, and creating scour holes or channel bars. Up to 1,106 

miles of roadways are projected for maximum development within the NPR-A (BLM 2012). A total of 

55,895 acres of direct impacts are projected to occur through 2100 (Table 140). To date, very little 

abandonment of large-scale projects (except for single exploration or development wells) has occurred 

anywhere on the North Slope. However, abandonment of gravel pads and roads, as well as pipelines, 

would most likely only have a temporary impact on local aquatic habitats. Removal of problematic stream 

crossing structures would contribute to positive cumulative impacts on water resources by allowing for a 

return to the previous hydrological regime.

Spills from GMT2 and other oil and gas developments on marine or estuarine waters or along streams 

draining into such waterbodies could impact those waters (Section 4.5). The extent of such contamination 

would be related to the size, nature, and timing of the spill. Because spill frequency and volume are 

expected to be low, the cumulative impact from oil spills is not considered to be an additive cumulative 

impact. If a large (500- to 900-barrels) spill were to occur during the ice-covered season, the impacts 

would be minor. If it were to happen during the open-water or broken-ice seasons, hydrocarbons 

dispersed in the shallow estuarine water column could exceed acute-toxic criteria during the initial spill 

period, but would be short-term and localized (BLM 2004a, Section 4G.5.7). Spills have occurred on the 

North Slope, but their impacts have been minor and have not accumulated.

Contribution of the Alternatives to Cumulative Impacts

Cumulative impacts to water resources tend to be proportional to the amount of area impacted by 

infrastructure, with modifications due to specific activities and locations. Cumulative impacts to water 

resources from gravel roads and pads and gravel mines would generally be proportional to the number of 

acres developed in a nature that disrupts the hydrologic regime.

On a watershed level, cumulative water resource impacts are related to alterations in the drainage pattern, 

and to a lesser degree stream flow. GMT2 would have similar, though potentially fewer impacts, than 
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GMT1, which would be additive (BLM 2014, Section 4.6.5). Alternatives A and B have a greater 

potential for cumulative impacts to drainage patterns due to the long linear gravel access road installation.

BLM (2004a) analyzed the potential cumulative impacts of the project to water resources and water 

quality (BLM 2004a, Section 4G.5.6–4G.5.7). It predicted that no cumulative impact to North Slope 

water supplies from withdrawal of water for construction and operation would occur because the annual 

yield (runoff and refill of lakes) is many times greater than the amount withdrawn.

Erosion, sedimentation, and stream flow are impacts to water quality that may be sustained to a lesser 

extent, as a result of road construction, stream crossings, and culverts. Sustained periods of these impacts 

are not expected to have significant cumulative impacts on a watershed level under any of the action 

alternatives. These impacts would be additive to other reasonably foreseeable future projects impacts that 

may be developed.

The primary change in project components of Alternative C with potential to alter the degree of 

cumulative hydrological impacts is the reduction in the total length of new roads, and the construction of 

an airstrip. Despite the elimination of the GMT1–GMT2 Access Road which parallels the pipeline, the 

new gravel footprint is larger than Alternatives A and B due to the addition of the airstrip and occupied 

structure pad, and the increase in pad size to support a remote, self-sufficient camp and drilling operation. 

The gravel footprint of the 5,000-foot airstrip under Alternative C is expected to have minor impacts to 

the localized drainage pattern.

The 5,000-foot airstrip and associated GMT2 pad and occupied structure pad under Alternative C would 

not cross any major drainages or streams. To minimize surface water ponding adjacent to the gravel 

embankments, the gravel surface may need to be contoured to direct surface water runoff (from 

precipitation and snow melt) to the down-gradient edges of the pad. The width of the pads and airstrip are 

too large to traverse with culverts. If ponds develop, runoff may need to be routed along the edges of the 

airstrip and pads. Over the compacted gravel surface there will be less infiltration of precipitation which 

may reduce the recharge of shallow groundwater in the immediate area. However, this impact will be 

localized and of low intensity.

Water withdrawal from lakes to support construction of ice roads and activities would be temporary under 

Alternatives A and B, and is not expected to result in cumulative impact to water resources. Naturally 

occurring seasonal water recharge occurs at a rate sufficient to offset withdrawal volumes if best 

management practices and state permit requirements are adhered to as directed. Cumulative impacts to 

water withdrawal sources and recharge functions are not expected.

Alternative C would require significantly more water withdrawal from local lakes to support summer and 

winter drilling during the non-winter months when ice road access to Alpine Processing Facility would 

not be possible. Under Alternative C there are more ice road miles during the construction phase, and also 

a need for annual ice roads during the operation phase (production). Therefore, impacts of ice roads under 

Alternative C would be greater and of longer duration compared to the other action alternatives. If 

reasonably foreseeable future roadless projects were developed, similar impacts would be additive. The 

impacts to rivers and drainage basins under Alternative C would be less than those for the other action 

alternatives.

In comparison to the other action alternatives during the operation period, Alternative C could result in 

higher spill risk due to increased activity with aircraft operations and year-round living accommodations. 

Overall, it is expected that the combination of lakes in the vicinity of Nuiqsut will continue to meet 

demand for existing and reasonably foreseeable future demand for water to construct ice roads and pads, 

exploration drilling and for GMT2, as well as for potable water supply. Further, it is expected that existing 

mitigation requirements (e.g., BLM best management practices and stipulations and State and North 
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Slope Borough permitting conditions) will avoid or minimize impacts to fish and fish habitat due to water 

withdrawal. Alternative D (no action) would result in no change from the current baseline conditions.

4.6.4.3 Conclusion

Impacts to water resources and water quality from GMT2 would be additive to past, present, and 

reasonably foreseeable future action impacts on the North Slope. The majority of the impacts would result 

from oil and gas development activities, with construction of roads, permanent pads, stream-crossing 

structures, and water use from lakes during the winter months being the major contributors. These 

impacts tend to be proportional to the amount of area impacted by infrastructure, with modifications due 

to specific activities and locations. All of these activities involve construction of infrastructure that would 

affect water quality through dust, impoundments, changes in natural drainage patterns, snow drifting, and 

oil, seawater or produced water spills. These impacts would be long-term and would accumulate. Because 

of the abundance of water resources on the North Slope, the overall cumulative impact to water resources 

on the North Slope and in the NPR-A would probably be small in magnitude and most impacts would be 

local in nature. Alternative D (no action) would result in no change from the current baseline conditions.

Climate change may increase particulate matter (fugitive dust, byproducts of combustion, and evaporation 

of hydrocarbons) to the extent shallow lakes and ponds dry up or become smaller, watersheds would 

experience a change to drier soils (BLM 2012), and contribute to increased thermokarsting as ice-rich 

permafrost becomes unstable with increases in ambient surface temperatures, resulting in more abundant 

small points, greater microrelief, and more active lakeshore erosion (Walker et al. 2014).

4.6.5 Cumulative Impacts to Air Quality

A cumulative air quality assessment should account for air emissions from nearby existing sources and 

reasonably foreseeable developments that are not yet built, and therefore are not included in the 

background ambient air quality data. A cumulative impacts analysis was performed to assess the impact 

on air quality and air quality related values at the sensitive Class II areas from the proposed GMT2 

Project as well as existing and reasonably foreseeable development sources. The sources evaluated in the 

cumulative impacts analysis for the prior GMT1 study (BLM 2013) and this GMT2 supplemental EIS are 

presented in Table 141. As shown in Table 141, GMT2 is not an RFD source in the cumulative emissions 

inventory when evaluating cumulative impacts of GMT2 in combination with RFD sources as this would 

double count the emissions from GMT2.
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Table 141. Reasonably foreseeable development sources included in GMT1 and GMT2 cumulative impacts 

analysis

Reasonably Foreseeable Development Source Evaluated in GMT1? Evaluated in GMT2?

ConocoPhillips GMT1 No Yes

ConocoPhillips GMT2 Yes No

Shell Discoverer Camden Bay Yes No

Eni Nikaitchuq Development Yes Yes

TDX Deadhorse Power Plant Yes Yes

Pioneer Oooguruk Development Yes Yes

Brooks Range Petroleum North Shore Yes No

ConocoPhillips Alpine CD5 Yes Yes

ExxonMobil Point Thomson Facility Yes Yes

Brooks Range Petroleum Mustang Yes Yes

BPXA Liberty Yes Yes

Nanushuk Pad (proposed) No Yes

Nanushuk Drill Site 2 (proposed) No Yes

Nanushuk Drill Site 3 (proposed) No Yes

Nanushuk Operations Center (proposed) No Yes

The cumulative impacts analysis was performed using a tiering (scaling) approach based on the GMT1 

far-field modeling data and results and the GMT2 supplemental EIS emissions. The difference in the 

magnitude of emissions presented for each pollutant from GMT2 and reasonably foreseeable development 

sources, between the GMT1 study and now, was used along with the results from the GMT1 far-field 

modeling to estimate GMT2 and cumulative far-field impacts by scaling the GMT1 results by the ratio of 

the cumulative emissions in the GMT2 and GMT1 studies. Results from the tiering were then compared 

with the regulatory standards and air quality-related value thresholds relevant to this project. 

The total emission rates for each pollutant were compared and a ratio (R) was calculated using the 

following equation: Ratio (R) = (total emissions from all sources in GMT2 study) divided by (total 

emissions from all sources in GMT1 modeling). Because NOx and SO2 emissions also contribute to PM 

formation, the tiering ratio for daily PM10 was determined using the sum (“Q”) of daily PM10, hourly NOX

and hourly SO2 emissions. A similar approach was used for the PM2.5 scaling ratio. Additional information 

on the cumulative scaling analysis performed may be found in the GMT2 far-field air quality impacts 

analysis (Ramboll Environ and Kleinfelder 2017).

Table 142 presents the ratios calculated and used for the tiering analysis for each pollutant and the 

emission rates used to calculate the ratio. The Q value shown here equals the sum of hourly NOx, hourly 

SO2, and daily PM10, all in units of grams per second.

Table 142. Tiering analysis calculated ratios

Emission 

Source

NOx

Hourly 

Emission 

Rate 

(g/sec)

NOx

Annual 

Emission 

Rate 

(g/sec)

SO2

Hourly 

Emission 

Rate 

(g/sec)

SO2

Annual 

Emission 

Rate 

(g/sec)

PM10

Daily 

Tiering 

Value 

(g/sec)

PM2.5 

Daily 

Tiering 

Value 

(g/sec)

PM2.5

Annual 

Tiering 

Value 

(g/sec)

Q Value 

(g/sec)

GMT1 243.41 243.41 14.55 14.55 14.77 13.96 13.96 272.73

GMT2 219.49 217.76 24.96 21.46 37.30 33.41 11.26 281.75

Ratio (R) 0.90 0.89 1.72 1.48 2.53 2.39 0.81 1.03
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The maximum predicted impacts from the cumulative far-field modeling performed for GMT1 and 

existing and reasonably foreseeable development sources identified in that study (AECOM 2014) were 

scaled using the ratio (R) values presented in Table 142 to predict maximum impacts from the proposed 

GMT2 Project plus existing and reasonably foreseeable development sources. For example, 1-hour NO2

maximum predicted impacts from the GMT1 far-field modeling (72 μg/m3, from Table 3-1 in AECOM 

2014) was multiplied by the NO2 hourly emission rate ratio of 0.90 to obtain a maximum predicted impact 

of 65 μg/m3 for 1-hour NO2 for the GMT2 far-field modeling. 

Results of the tiering analysis are presented in Table 143 and Table 144 for the Arctic National Wildlife 

Refuge and Gates of the Arctic National Park and Preserve, respectively, and demonstrate that cumulative 

impacts from GMT2 and existing reasonably foreseeable development sources will not adversely impact 

air quality at the two sensitive Class II areas. There are no exceedances of the Class II prevention of 

significant deterioration increments or National Ambient Air Quality Standards and Alaska Ambient Air 

Quality Standards for either sensitive Class II area.

Table 143. Cumulative air quality impacts at Alaska National Wildlife Refuge

Pollutant

Averaging 

Period

Maximum 

Predicted 

Impact 

(μg/m3)

Class II 

Increment 

(μg/m3)

Over 

Increment?

Ambient 

Background 

(μg/m3)

Total 

Concentration 

(μg/m3)

NAAQS/ 

AAAQS 

(μg/m3)

Over 

NAAQS/ 

AAAQS?

NO2 1-hour 65 -- -- 41.9 106.9 188 No

NO2 Annual 0.21 25 No 3.8 4.0 100 No

SO2 1-hour 2.9 -- -- 5.9 8.8 196 No

SO2 3-hour 1.7 512 No 6.2 7.9 1,300 No

SO2 24-hour 0.62 91 No 4.8 5.4 365 No

SO2 Annual 0.024 20 No 0.003 0.027 80 No

PM10 24-hour 2.38 30 No 45.2 47.6 150 No

PM2.5 24-hour 2.30 9 No 7.3 9.6 35 No

PM2.5 Annual 0.123 4 No 2.1 2.2 12 No

Table 144. Cumulative air quality impacts at Gates of the Arctic

Pollutant

Averaging 

Period

Maximum 

Predicted 

Impact 

(μg/m3)

Class II 

Increment 

(μg/m3)

Over 

Increment?

Ambient 

Background 

(μg/m3)

Total 

Concentration 

(μg/m3)

NAAQS/ 

AAAQS 

(μg/m3)

Over 

NAAQS/ 

AAAQS?

NO2 1-hour 0.38 -- -- 41.9 42.3 188 No

NO2 Annual 0.0021 25 No 3.8 3.8 100 No

SO2 1-hour 0.12 -- -- 5.9 6.0 196 No

SO2 3-hour 0.10 512 No 6.2 6.3 1,300 No

SO2 24-hour 0.051 91 No 4.8 4.9 365 No

SO2 Annual 0.0015 20 No 0.003 0.005 80 No

PM10 24-hour 0.38 30 No 45.2 45.6 150 No

PM2.5 24-hour 0.38 9 No 7.3 7.7 35 No

PM2.5 Annual 0.020 4 No 2.1 2.1 12 No

The Q tiering ratio was used to scale the visibility impacts from the GMT1 far-field cumulative analysis 

to get an approximate measure of the GMT2 cumulative visibility impacts. The scaled 98th percentile Δdv 

for each year is presented in Table 145. Cumulative visibility impacts are small.
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Table 145. Cumulative visibility impacts

Class II Area

98th Percentile 

Δdv 2007

98th Percentile 

Δdv 2008

98th Percentile 

Δdv 2009

Arctic National Wildlife Refuge 4.35 3.85 4.66

Gates of the Arctic National Park and Preserve 0.77 0.70 1.05

The hourly NOx and SO2 emission tiering ratios were used to scale the GMT1 far-field cumulative 

deposition impacts. The results of the scaling for cumulative nitrogen and sulfur deposition impacts are 

presented in Table 146. The estimated impacts for nitrogen deposition from the GMT2 Project and 

reasonably foreseeable development sources combined are well below the range of critical loads for 

deposition shown in Table 27. The estimated cumulative impacts for nitrogen deposition including the 

existing (measured) nitrogen deposition of 0.94 kg/ha-yr at Gates of the Arctic National Park and Preserve 

shown in Table 27 are also below the range of critical loads.

Table 146. Cumulative deposition impacts

Class II Area Pollutant

Averaging 

Period

Maximum Impact 

Due to Project 

Reasonably 

Foreseeable 

Development

Sources

(kg/ha-yr)

Critical 

Load Range

(kg/ha-yr)

Below/

Within/

Above 

Range?

Arctic National Wildlife Refuge Nitrogen Annual 0.025 1–3 Be

Gates of the Arctic National 

Park and Preserve

Nitrogen Annual 0.004 1–3 Belo

Arctic National Wildlife Refuge Sulfur Annual 0.006 - -

Gates of the Arctic National 

Park and Preserve

Sulfur Annual 0.001 - -

4.6.5.1 Summary of Cumulative Air Quality Impacts

Potential cumulative air quality impacts from GMT2 and nearby existing sources plus reasonably 

foreseeable development sources that are not yet built, and therefore, not included in the background 

ambient air quality data were evaluated. The cumulative impact analysis tiered off of the GMT1 

cumulative analysis using the ratio of emissions between GMT2 study cumulative emissions to GMT1 

study cumulative emissions. Changes in cumulative emissions between GMT2 and GMT1 are due to 

differences in project emissions, updates to existing source emissions, and changes in anticipated 

reasonably foreseeable development emissions. The potential cumulative impact of GMT2 plus existing 

and reasonably foreseeable development source emissions are estimated to be less than the National 

Ambient Air Quality Standards and Alaska Ambient Air Quality Standards and other available evaluation 

thresholds.

4.6.6 Cumulative Impacts of Noise

Cumulative impacts of noise on the acoustical environment, wildlife, and people in the project area are 

attributable to operation of motorized vehicles, boats, and aircraft; use of mechanical equipment; use of 

firearms; and mine blasting. These noise sources and associated impacts result from activities associated 

with oil and gas exploration and development, as well as from a range of activities not associated with oil 

and gas development.
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4.6.6.1 Past and Present Impacts and Their Accumulation

Unlike many of the resources and impact issues considered in this supplemental EIS, data characterizing 

past and present noise levels in the GMT2 Project area and across the North Slope are relatively lacking. 

The 2016 PAM study (Stinchcomb and Brinkman, unpublished data; see Section 3.2.3.3 and Appendix C) 

focused on aircraft noise, included only four sites in the project area, and was of short duration. Three 

sites in the project area were among the four sites overall where noise sources other than aircraft 

contributed to recorded noise levels. This is to be expected, given the study site locations in proximity to 

existing development activities. But this result also indicates that in most of the study area beyond the 

GMT2 Project area, aircraft noise was the dominant form of noise. Aircraft noise was especially common 

at three of the sites in the project area (the fourth site was monitored only for 5 days), with median and 

maximum numbers of daily aircraft noise events among the highest found in the entire study with the 

exception of Umiat. 

4.6.6.2 Future Impacts and Their Accumulation

Activities Not Associated With Oil and Gas Exploration and Development

Future construction and operation of transportation infrastructure and planned expansion of the Arctic 

Slope Regional Corporation gravel mine are foreseeable future actions that will generate noise and 

contribute to the overall accumulation of noise impacts in and around the GMT2 Project area. These 

activities are not associated directly with oil and gas exploration and development, although they may be 

affected by them. 

Oil and Gas Exploration and Development Activities

Foreseeable future oil and gas exploration and development activities on the North Slope will contribute 

to the accumulation of noise impacts in the region. Operation of motorized vehicles and aircraft for 

transportation of personnel and material; operation of motorized equipment for aspects of exploration, 

development, and production; and oil-and-gas-related mine operations will contribute to greater 

geographic extent, frequency of occurrence, and overall accumulation of noise impacts. 

Contribution of the Alternatives to Cumulative Impacts

For the action alternatives, impacts from noise on the acoustical environment are addressed in Section

4.2.3.3. Noise impacts resulting from these alternatives generally would be proportional to their relative 

gravel requirements (noise attributable to gravel mining), gravel footprints (noise attributable to 

infrastructure construction), numbers of vehicle trips and miles, and numbers of aircraft flights. On a 

project-level basis, overall noise impacts are considered to be moderate for all action alternatives, with 

reasonably foreseeable impacts of Alternatives A and B less than the foreseeable impacts of Alternative C 

due to the greater level of aircraft activity under Alternative C. The various types and levels of noise 

resulting from GMT2 would contribute to the greater geographic extent, frequency of occurrence, and 

overall accumulation of noise impacts in the project area and in the North Slope region as a whole. 

4.6.6.3 Conclusion

Impacts to the acoustical environment and noise-sensitive wildlife and people from GMT2 would be 

additive to noise impacts of past, present, and other foreseeable future actions. As with project-level 

impacts, overall cumulative impacts of noise generally are expected to be proportional to the geographic 

extent and frequency of occurrence of noise generated by motorized vehicles, aircraft, and equipment, but 

also are contingent on context. Cumulative impacts on the acoustical environment due to noise from past, 

current, and foreseeable future actions are regional in extent, of high intensity, and of temporary or 

interim duration. But even if temporary or interim in terms of the acoustical environment, noise impacts 
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on wildlife and human receptors are important or unique in context where they occur and impact 

residential communities such as Nuiqsut and concentrated or dispersed subsistence-use areas (see Section

4.6.8.8 and related sections). 

4.6.7 Cumulative Impacts to Biological Resources

4.6.7.1 Vegetation and Wetlands

Approximately 99 percent of the terrestrial vegetation within the project area is classified as wetlands (see 

Section 3.3.1) and impacts to vegetation and wetlands would result from construction, operations, and 

abandonment/rehabilitation of sites. The cumulative impacts to vegetation and wetlands include the direct 

loss of land cover due to placing gravel fill on the tundra and by mining gravel, and indirect loss or 

alteration of land cover as a result of modification of surface drainage patterns, gravel spray and dust 

(extending outward up to 300 feet from the facility footprint). Cumulative impacts to vegetation and 

wetlands are discussed more fully in BLM (2004a, 2012).

Past and Present Impacts and Their Accumulation

BLM (2012) summarized past and present direct and indirect impacts of non-oil and gas and oil and gasrelated activities on wetlands and vegetation. Approximately 2,500 acres of direct impacts and 4,630 acres 

of indirect impacts to vegetation and wetlands from non-oil and gas activities (primarily communities) 

persist on the North Slope today (BLM 2012). Oil and gas activities have caused approximately 18,400 

acres of direct impacts to vegetation, including wetlands, that persist today, and about the same acreage of 

indirect impacts (BLM 2012). These include the recently built Nuiqsut Spur Road, which connects the 

village of Nuiqsut to the all-weather road system of the Alpine development and its satellites. Whether 

impacts are associated with non-oil and gas residential, commercial or military development, or oil and 

gas activities, these impacts to vegetation are additive to future impacts and would be likely to persist for 

several decades or more (BLM 2012). However, the rate at which vegetation and wetlands are disturbed 

by development has slowed substantially in recent years due to advances in technology and a slowing of 

oil field development on the North Slope (BLM 2012).

Future Impacts and Their Accumulation

Activities Not Associated With Oil and Gas Exploration and Development

The primary impact to vegetation and wetlands associated with non-oil and gas reasonably foreseeable 

future projects are the permanent loss of vegetation and wetlands through the placement of gravel to 

support infrastructure and transportation systems such as roads, and impacts from gravel mining. The 

proposed Colville River Access Road and the community of Nuiqsut are within the GMT2 Project area 

and the Harrison Bay/Lower Colville River Watershed, and thus any construction in these locations would 

have additive impacts to vegetation and wetlands.

Oil and Gas Exploration and Development Activities

Seismic and Exploration Drilling Activities: Impacts from seismic and exploration drilling activities in 

the past have typically been from damage to the vegetative mat or the underlying soils from tracked 

vehicles or sleds on skids cutting into hummocks, or from dozer operators making tight turns or dropping 

the blade too deeply into the snow. Use of newer technologies, such as vehicles that apply less pressure to 

the ground or best management practices like restricting travel to periods when there is adequate snow 

and frost cover to protect vegetation, have reduced the level of impacts to vegetation and soil. Impacts 

from future seismic and exploration drilling activities are not likely to accumulate and become additive to 

past effects (BLM 2012). Vegetation recovery studies have shown that most impacts to vegetation from 
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seismic and exploration drilling activities should be minor and short-term (National Research Council

2003).

North Slope exploration drilling is not typically authorized for gravel road or pad development, so no 

future impacts associated with gravel infrastructure are expected from exploration drilling activities.

Oil and Gas Development and Production: The primary impact to vegetation and wetlands associated 

with the proposed project and other reasonably foreseeable future projects is the permanent loss of 

vegetation and wetlands through the placement of gravel to support infrastructure (pads) and 

transportation systems (roads). The total future direct and indirect impacts to wetlands and floodplains on 

the North Slope would be the sum of impacts from the gravel footprint, excavation of material sites, and 

construction of elevated and buried pipelines. The loss of vegetation and wetlands resulting from the 

development of GMT2 and reasonably foreseeable future projects would also affect the wildlife and 

fisheries resources that rely on this habitat.

Future development and production could occur on the North Slope in the NPR-A, the Beaufort and 

Chukchi Seas, and onshore between the NPR-A and the Arctic National Wildlife Refuge. New 

development, especially for economically marginal oil fields, would most likely occur near existing fields 

so that infrastructure systems could be shared (BLM 2012). Specific reasonably foreseeable future

projects include development in the Greater Mooses Tooth, Bear Tooth, Colville River, and Pikka Units. 

These potential projects, along with established activities, recent developments, and recently permitted 

activities noted in Table 140, Past, Present and Reasonably Foreseeable Future Developments, are all 

within the Harrison Bay and Lower Colville River Watersheds and would have additive impacts to 

vegetation and wetlands in that area. One offshore prospect in Smith Bay would likely require an onshore 

pipeline and possibly a road that would also impact this area. 

Although the increase in the area disturbed by oil and gas development has slowed dramatically in recent 

years, BLM (2012) estimated that an additional 6,300 acres could be covered by gravel or impacted by 

gravel mines east of the NPR-A between 2012 and 2100. Approximately 38,000 acres of vegetation may 

be indirectly affected by dust, changes in hydrology, and thermokarst (BLM 2012).

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, roads, and airstrips 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.

Abandonment: Increased oil and gas development and production on the North Slope would also result 

in an increased need for removal of infrastructure and rehabilitation of vegetation upon completion of 

operations. Removal of aboveground facilities, pipelines, and power poles would have a minor impact on 

vegetation. Roads and pads would remain unaffected if they are maintained, but if maintenance is 

discontinued, thaw subsidence in ice-rich areas would result in settling of the gravel structures into 

thermokarst troughs. Removal of roads and pads would accelerate thaw subsidence, but would also 

accelerate the reclamation process. Removal of gravel fill has recently been accomplished in wetlands and 

preliminary studies suggest that a wetland mosaic of vegetation can be restored (BLM 2012).

If global climate change persists, the cumulative effects to wetlands and floodplains from oil and gas and 

non-oil and gas development on the North Slope could be greater than predicted. Continued climate 
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change would eventually lead to shifts in the composition and distribution of Arctic tundra vegetation and 

wetlands. Permafrost would thaw to increased depths, causing varying degrees of impacts on subsidence, 

soil moisture, and vegetation. The potential for many shallow streams, ponds, and wetlands in the Arctic 

to dry out under a warming climate is increased by the loss of permafrost. Such impacts of climate change 

could accumulate with changes in soil thermal regimes that might occur as a result of past and future nonoil and gas and oil and gas activities in and near the NPR-A, potentially leading to synergistic impacts to 

vegetation (BLM 2012).

Contribution of the Alternatives to Cumulative Impacts

Section 4.3.1 discusses the direct impacts due to the footprint of Alternatives A, B, and C. BLM (2004a) 

described the potential cumulative impacts to wetlands and vegetation to be minor. The incremental 

contribution to cumulative impacts from GMT2 would also be minor, unless a large oil spill was to occur. 

Impacts to North Slope vegetation communities from oil field abandonment activities would result in a 

small, temporary contribution to cumulative impacts followed by a recovery over the long-term. The 

affected area would be a small fraction of the total North Slope acreage, so the benefit would be relatively 

small. It is not expected that synergistic impacts (whether beneficial or adverse) to vegetation would 

occur as a result of developing additional acres. The potential cumulative impacts to vegetation and 

wetlands of the proposed project are within the range of those analyzed by the BLM in 2004.

The vegetation and wetlands impacts of the action alternatives are within the range (i.e., minor and 

localized) of cumulative impacts of oil and gas activities analyzed earlier (BLM 2012). Non-oil and gas 

development together with oil and gas activities would occupy less than 1,400 acres within the largely 

undeveloped 4.3-million-acre area comprising the Harrison Bay and Lower Colville River Watersheds. 

Future impacts to vegetation both inside and outside of the NPR-A would be additive to the impacts to 

vegetation that have accumulated in the past and persist today. In the context of the entire North Slope, 

however, these cumulative impacts would be relatively minor. Alternative D (no action) would result in 

no change from the current baseline conditions.

Conclusion

Overall, the direct, indirect, and cumulative impacts to vegetation and wetlands associated with the 

proposed GMT2 and completion of other reasonably foreseeable future projects are expected to be within 

the potential cumulative impacts to wetlands and vegetation described in the Alpine Satellite 

Development Plan EIS (BLM 2004a) and to be of moderate intensity and long-term duration. Alternative 

D (no action) would result in no change from the current baseline conditions.

4.6.7.2 Fish and Fish Habitat

Past and Present Impacts and Their Accumulation

Activities Not Associated With Oil and Gas 

Impacts on fish to date from most North Slope non-oil and gas activities, such as developing villages, 

recreation, hunting, research, waste removal and remediation projects, and winter overland supply 

operations have been minor and localized. Impacts on fish from military Distant Early Warning-Line 

stations that initially accumulated along the coast have been recovering since abandonment (BLM 2012, 

Section 4.8.7.7).

Oil and Gas Exploration

Impacts to fish from seismic activities and exploration over the last several decades should have largely 

been local, acute, and short-lived. Explosive-based seismic surveys and exploration that included 
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construction of gravel infrastructure have been replaced by Vibroseis-based surveys and winter 

exploration that utilizes temporary ice infrastructure, which have fewer potential repercussions on the 

environment. Aquatic habitats and local fish communities that were temporarily impacted in the past have 

likely recovered (BLM 2012, Section 4.8.7.7).

Oil and Gas Development and Production

Some aspects of North Slope oil and gas development and production have caused impacts on fish that 

have accumulated, while impacts on fish from other aspects have not persisted. Impacts from gravel pads 

and roads as well as causeways have accumulated by impeding fish movements and significantly altering 

fish habitat by changing physical and chemical conditions. Year-round freshwater use for domestic 

facilities, seawater use for waterflooding, and oil spills have all effected fish in ephemeral ways that have 

not likely accumulated (BLM 2012, Section 4.8.7.7).

Future Impacts and Their Accumulation

Activities Not Associated With Oil and Gas 

Non-oil and gas activities that will take place in the NPR-A and adjacent lands related to village 

development; recreation, hunting, and research and associated small camp, watercraft, and floatplane use; 

waste removal and remediation projects; and winter overland supply operations will probably increase in 

the future. However, in most cases, minor impacts on fish would be localized and brief and would not 

accumulate (BLM 2012, Section 4.8.7.7).

Construction of new gravel roads provides improved access to subsistence harvest of fish from waters that 

were previously remote. Improved access carries a risk that small populations of slow growing fish may 

be overharvested. Although this is possible, it is unlikely that substantially increased harvest levels would 

go unnoticed or unchecked. Accordingly, there is still a risk of overharvesting local populations of fish.

Oil and Gas Exploration

It is expected that future seismic surveys and exploration drilling operations will continue using current 

technologies. Based on evidence that these current techniques effectively mitigate impacts on fish, the 

localized impacts that could occur would not be expected to accumulate. Onshore, this includes winter 

vibroseis surveys and exploration drilling in the Willow region or other targeted areas to the east of 

GMT2. For marine activities, airgun-based seismic activities and exploratory drilling in the Beaufort Sea 

could impact coastal marine fish as well as anadromous fish from the NPR-A, primarily due to 

disturbance. Nearshore operations would potentially impact more fish than offshore operations since 

many fish species tend to concentrate along the coast during much of the open-water season. Overall, 

impacts on fish from seismic activities and exploration in these other areas would not likely accumulate 

(BLM 2012, Section 4.8.7.7).

Oil and Gas Development and Production

The elements of onshore North Slope oil and gas development and production most likely to contribute to 

future impacts on fish that could accumulate include permanent infrastructure (e.g., roads, pads, pipelines, 

and causeways) and gravel mining necessary to build the infrastructure. The gravel infrastructure (roads, 

pads, airstrips) and associated gravel mining associated with oil and gas development and production 

have caused impacts on fish that have accumulated by impeding fish movements and significantly altering 

the physical and chemical conditions of fish habitat. Oil and gas development and production in the 

Willow region to the east of the NPR-A, or in the Beaufort Sea, would require additional facilities and 

infrastructure that would be additive to impacts from GMT2 development. Collectively, these cumulative 

impacts from onshore and marine oil and gas development and production could reduce the size and 
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structure of fish populations, diminish individual fish condition, and shift local fish community 

composition and species distribution (BLM 2012, Section 4.8.7.7).

Impacts on fish from North Slope oil spills on land thus far have not accumulated because the spills have 

been small and cleanup and rehabilitation efforts have generally been successful. Regardless, given the 

magnitude of development scenarios, this situation could change, with the probability of spills entering 

aquatic habitats increasing. Also, as pipelines age and degrade, spills would probably be more frequent 

and impacts on fish could be additive. Impacts on fish from even small individual spills in streams and 

lakes could accumulate over time (BLM 2012, Section 4.8.7.7).

Oil and Gas Facility Abandonment

Except for the abandonment of isolated individual exploration or development wells, to date, very little 

abandonment has occurred anywhere on the North Slope. However, abandonment of gravel pads and 

roads, as well as pipelines, would most likely only have a temporary impact on local aquatic habitats 

provided that the abandonment includes removal and restoration of any problematic stream crossing 

structures. The process of removal, restoration, and abandonment would contribute to positive cumulative 

impacts on fish by allowing fish to reach habitats that were previously made inaccessible by development. 

Contribution of the Alternatives to Cumulative Impacts

In general, the greater the amount of infrastructure, the higher the expected incidents of impacts to fish 

and fish habitats. As such, the highest anticipated impacts would occur under Alternatives A and B, 

followed by Alternatives C. Overall impacts under Alternatives A and B are anticipated to be similar, as 

they only vary slightly in routing and infrastructure extent. The reduction of roads in Alternative C would 

avoid many of the potential disruptions to fish and fish habitats under the other action alternatives, 

although annual ice roads would be required for the life of the project. Potential impacts from oil pipeline 

spills would be similar under Alternatives A, B, and C. Alternative D (no action) would result in no 

change from the current baseline conditions. 

Conclusion

The direct, indirect, and cumulative impacts to fish and fish habitat associated with the proposed GMT2 

Project and other regional oil and gas activities (Map 4.6-1) would be additive. However, the potential 

impacts most likely to occur to fish from the GMT2 project would be localized, seasonal, and effect a 

relatively low number of individual fish. As such, it is not likely to contribute to changes in local or 

regional fish population characteristics. 

4.6.7.3 Birds

As noted in Section 4.3.3, all action alternatives associated with the proposed GMT2 Project have the 

potential, via direct and indirect impacts, to affect birds, bird behavior, and their nesting, brood-rearing, 

foraging, and molting habitats through habitat loss, alteration, and disturbance. Mechanisms may include 

physical changes resulting in loss of habitat, displacement from habitats altered by vehicle noise, dust 

deposition, and thermokarst, attraction to habitats altered by thermokarst and early green-up adjacent to 

gravel infrastructure, or disturbance from increased aircraft noise or visual stimuli. Cumulative impacts to 

birds are discussed more fully in BLM (2004, 2012).

Past and Present Impacts and Their Accumulation

BLM (2004, 2012) found that the additive impacts of past, present, and reasonably foreseeable future

activities are not expected to cause pervasive cumulative impacts, including impacts from synergistic 

effects to bird populations on the North Slope.
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Activities Not Associated With Oil and Gas Exploration and Development

Impacts to birds from most North Slope non-oil and gas activities such as subsistence activities (including 

hunting, fishing, berry picking, etc.), recreational use, activities associated with scientific surveys and 

research camps, village expansion, clean-up of old oil and gas exploration sites, and activities associated 

with government actions (e.g., clean-up of abandoned well sites) have been minor and localized (BLM 

2012). Approximately 2,500 acres of habitat have been directly impacted by non-oil and gas development 

on the North Slope and those impacts are additive to future impacts and would be likely to persist for 

several decades or more in the absence of an active reclamation program (BLM 2012).

Oil and Gas Exploration and Development Activities

Overall, direct mortality impacts due to collisions with vehicles, aircraft, buildings, pipelines, powerlines 

and communications towers were estimated to occur only at very low levels in the North Slope oilfields 

during present and future developments. The National Research Council (2003) concluded that reduced 

productivity was the most substantial cumulative impact to bird populations due to oil and gas 

development activities, and that determination was based on decreased productivity due to increased 

levels of predators attracted to the development area. The National Research Council (2003) review 

focused on the Prudhoe Bay Oilfield, with most studies conducted through the mid 1990s when the 

landfill and dumpsters were accessible by gulls, ravens, bears and foxes. Since the late 1990s, the landfill 

has been fenced to exclude bears, and animal proof dumpsters have been installed throughout North Slope 

oilfields (BLM 2004).

More recently, a 4-year avian study on the Arctic Coastal Plain further corroborated this concept with 

evidence of increased predation risk for passerine nests within 5 kilometers of oil field infrastructure 

(Liebezeit et al. 2009). When the relationship was tested by individual avian species individually, not all 

species (notably semipalmated and pectoral sandpipers) exhibited the same findings (Liebezeit et al. 

2009). The inconsistent results among species may have been due to variability in survey year, conditions, 

or sites. The following recommendation was provided for gaining a better understanding of this notable 

potential cumulative impact to avian species, “We recommend targeted management actions to minimize 

anthropogenic effects and suggest new research needed on this issue as expanding development is 

planned for the Arctic Coastal Plain of Alaska. In particular, we recommend research on demography of 

key predators and their importance with respect to nest survival, and experimental studies that better 

address challenges posed by high natural variability” (Liebezeit et al. 2009).

Future Impacts and Their Accumulation

Activities Not Associated With Oil and Gas Exploration and Development

The primary impact to birds associated with non-oil and gas reasonably foreseeable future projects is the 

permanent loss of habitat through the placement of gravel to support infrastructure and transportation 

systems such as roads, and impacts from gravel mining. Increased harvests resulting from increased 

access to remote areas via new roads, especially from subsistence hunting, are characterized as a notable 

cumulative impacts factor in the Alpine Satellite Development Plan area. Subsistence harvest within the 

Alpine Satellite Development Plan area would affect approximately 2,800 birds and eggs, compared to an 

estimated 950 nesting waterbirds and ptarmigan affected by habitat loss, alteration, and disturbance 

caused by reasonably foreseeable future development within the plan area (BLM 2004). BLM (2012) 

analyzed potential cumulative impacts across the North Slope to non-special status bird species occurring 

in the NPR-A, and impacts on birds from non-oil and gas activities that are part of BLM operations or 

authorizations were not expected to accumulate.
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Oil and Gas Exploration and Development Activities

Seismic and Exploration Drilling Activities. Impacts to birds from seismic and exploration drilling 

activities in the past have typically been related to damage to the vegetation. Use of newer technologies 

have reduced the level of impacts to vegetation and soil, and thus, to bird populations using these 

resources. Vegetation recovery studies have shown that most impacts to vegetation, and thus, to birds, 

from seismic and exploration drilling activities should be minor and short-term (Section 4.3.1, 

“Vegetation and Wetlands” (National Research Council 2003). North Slope exploration drilling is not 

typically authorized for gravel road or pad development, so no future impacts associated with gravel 

infrastructure are expected from exploration drilling activities. Impacts from future seismic and 

exploration drilling activities are not likely to accumulate and become additive to past effects (BLM 

2012).

Oil and Gas Development and Production. The primary impacts to birds associated with the proposed 

project and other reasonably foreseeable future projects is the permanent loss of habitat through the 

placement of gravel to support infrastructure (pads) and transportation systems (roads) and the 

disturbance of birds due to noise from drilling and associated activities. The loss of habitat resulting from 

the development of GMT2 and reasonably foreseeable future projects would affect the bird resources that 

rely on these habitats.

Future development and oil production could occur on the North Slope in the NPR-A, the Beaufort and 

Chukchi Seas, and onshore between the NPR-A and the Arctic National Wildlife Refuge. New 

development, especially for economically marginal oil fields, would most likely occur near existing fields 

so that infrastructure systems could be shared (BLM 2012). Specific reasonably foreseeable future

projects include development in the Greater Mooses Tooth, Bear Tooth, Colville River, Kuparuk River, 

Ooguruk, Pikka and Tofkat Units. These potential projects, along with established activities, recent 

developments, and recently permitted activities noted in Table 140, Past, Present and Reasonably 

Foreseeable Future Developments, are all within the Harrison Bay and Lower Colville River Watersheds 

and would have additive impacts to birds in that area. 

More information has recently been acquired with the submission to the BLM of a master plan for the 

Willow Development. The Willow Master Development Plan (MDP) is a proposed project similar in scale 

to the original Alpine Development Plan. The Willow MDP addresses an inter-related series of 

infrastructure components that could be constructed over an approximately 10-year period including up to 

five drill sites, a central processing facility, an infrastructure pad, gravel access roads, an airstrip, module 

delivery via sealift barges, pipelines, and a gravel mine. These components would be primarily in the 

Beartooth Unit, located about 7 miles west of the GMT2 well site, with supporting infrastructure in the 

Greater Mooses Tooth Unit, and on un-unitized lands within the NPR-A, Kuukpik Corporation Lands and 

State of Alaska land and waters. 

The cumulative impacts to [birds and their habitats] from Willow, according to the MDP, would be the 

loss of habitat through placement of gravel to support the infrastructure and transportation system, 

including an estimated 37 miles of new gravel access roads and over 100 miles of new pipelines. The total 

new surface disturbance due to the placement of gravel fill is estimated to be 410 acres. 

Although direct habitat loss from cumulative oil and gas development on the North Slope would affect 

only a small proportion of the total area, indirect habitat loss, or functional loss, could result from longterm displacement of birds from the vicinity of oil and gas activities and could involve a much larger area. 

Future offshore or nearshore development of leases in the Beaufort Sea could expose birds to additional 

habitat loss and disturbance related to oil and gas development through onshore facilities to support 

offshore/nearshore leases.
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Spills of crude oil and other substances associated with reasonably foreseeable future projects could affect 

birds on the North Slope. Cumulative effects would depend on the type, number, size, location, and 

timing of spills, and the type and effectiveness of the oil spill response and the species exposed to the 

spill. 

If global climate change persists, the cumulative effects to birds from oil and gas and non-oil and gas 

development on the North Slope could be greater than predicted due to larger than currently expected 

changes to bird habitat. Continued climate change would eventually lead to shifts in the composition and 

distribution of Arctic tundra vegetation and wetlands, which would affect birds in both positively and 

negatively. Permafrost would thaw to increased depths, causing varying degrees of impacts on 

subsidence, soil moisture, and vegetation. The potential for many shallow streams, ponds, and wetlands in 

the Arctic to dry out under a warming climate is increased by the loss of permafrost. Such impacts of 

climate change could accumulate with changes in soil thermal regimes that might occur as a result of past 

and future non-oil and gas and oil and gas activities in and near the NPR-A, potentially leading to

synergistic impacts to birds (BLM 2012).

BLM (2012) analyzed potential cumulative impacts across the North Slope to non-special status bird 

species occurring in the NPR-A and found that cumulative impacts on bird productivity and abundance 

are likely to be long-term and could result in adverse impacts on productivity of some species of birds. 

The BLM expects that the impacts of facilities and activities for future projects on bird populations, 

though additive, would be substantially less than those of past projects because of the smaller total area 

needed for future projects due to advances in technology.

Contribution of the Alternatives to Cumulative Impacts

All future impacts will be additive to the impacts to birds and bird habitat that have accumulated in the 

past and persist today, but in the context of the entire North Slope west of the Canning River, these 

cumulative impacts are expected to be relatively small. The 2012 Integrated Activity Plan/EIS found that 

if current rates of development continue into the future, about 3,750 additional acres of bird habitat would 

be lost through the construction of pads, roads, and airstrips through the year 2100, and 750 acres by 

gravel mines. About 27,000 additional acres would be indirectly affected by dust, changes in hydrology, 

and thermokarst through 2100. 

Section 4.3.2 discusses, in depth, the impacts to birds from Alternatives A, B, and C. Direct impacts to 

bird habitats from gravel placement would be greater for Alternative C than Alternatives A and B. 

Impacts associated with disturbance to birds from vehicle traffic would be greatest under Alternative A or 

B, due to the distance vehicles would have to travel. Alternative C would have no gravel access road 

traffic. 

Potential impacts to birds from aircraft under Alternative C is greater than Alternatives A or B due to the 

requirement to use aircraft to access the GMT2 drill pad when ice roads are not feasible (roughly 9

months of the year). The air traffic at the GMT2 facility under Alternative C would be additional to the 

existing activity in the Alpine Central Processing Facility and Nuiqsut airspaces, and would continue for 

the long-term while additional flights required under Alternatives A and B would drop considerably after 

construction is completed. 

Alternatives A and B would have annual ice roads constructed in Years 1–3 to allow for construction of 

gravel infrastructure. Post-construction of gravel infrastructure there would be no ice roads needed for 

these two alternatives. Alternative C requires annual ice roads to be constructed for the life of the project. 

Few birds are present in the area during ice road season; however, re-use of ice annual road routes and ice 

pad locations could damage tundra, resulting in potential long-term impact to potential high value bird 

habitats.
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Potential impacts to birds from mortality and predation due to Alternatives A and B would be higher than 

for Alternative C, because the absence of a gravel road would negate the probability of mortality due to 

vehicle traffic and fewer culverts in gravel structures would create fewer potential sites for predators to 

exploit. 

Potential impacts from oil pipeline spills would be similar under Alternatives A, B, and C. Alternative D 

(no action) would result in no change from the current baseline conditions. 

Conclusion

The combination of impacts to birds from the proposed project coupled with impacts from reasonably 

foreseeable future projects in would be additive, long-term, and localized, or perhaps regional, depending 

on the type of access to the reasonably foreseeable future (roaded or not roaded). However, in the context 

of the North Slope west of the Canning River, these cumulative impacts would be relatively small (BLM 

2012) and would be dependent upon reasonably foreseeable future project locations relative to bird 

populations and their preferred habitat.

Further development in the cumulative impacts evaluation area may also impact birds through a 

cumulative reduction in habitat and an increase in disturbance. These impacts are not expected to cause 

pervasive cumulative impacts, because the impacts of the currently proposed and reasonably foreseeable 

future projects on bird populations, though additive, would be less than those of past projects due to 

smaller project areas (by comparison) and the large extent of existing habitat in the area of evaluation. 

The contribution from the proposed project is expected to be negligible with respect to the cumulative 

impacts evaluation area, and would be decreased from that approved in the 2004 Alpine Satellite 

Development Plan Record of Decision due to the reduced footprint of the proposed project.

Direct impacts to birds associated with the proposed project are expected to be localized and minor in 

nature with no adverse impacts expected at the population level. Overall, it is anticipated that less than 1

percent of the total high value bird habitat in the project study area would be impacted, directly or 

indirectly, by any single action alternative.

If climate change over the next several decades were to result in substantial changes in weather patterns, 

vegetation types and distribution, and insect abundance, habitat disturbance impacts from oil and gas 

activities could be exacerbated additively and perhaps synergistically, and extend beyond the life of the 

oil and gas fields. Changes in vegetation as a result of climate change would directly impact the amount 

and types of habitat available to tundra nesting birds. Such impacts of climate change could accumulate 

with any changes in soil thermal regimes that might occur as a result of past and future non-oil and gas 

and oil and gas activities in and near the NPR-A, potentially leading to synergistic impacts to bird habitat 

(BLM 2012).

Oil spills would not significantly add to cumulative impacts, except for an unlikely to very unlikely large 

spill to aquatic habitats.

The combination of impacts from the proposed project, coupled with impacts from other reasonably 

foreseeable future projects would be additive, long-term, and localized. The overall cumulative impact to 

birds for the Harrison Bay and Lower Colville River Watersheds, and other reasonably foreseeable future

projects is considered to be minor.

Alternative D would not have any incremental cumulative impacts to birds.
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4.6.7.4 Terrestrial Mammals

Caribou

Both the Teshekpuk Caribou Herd and the Central Arctic Herd use the GMT2 Project area for 

winter/summer forage during one or more seasons each year, and at very low densities for calving in June. 

The project area is part of a high use corridor for fall migration by the Teshekpuk Caribou Herd, and 

overall it tends to be used more year-round by the Teshekpuk Caribou Herd than the Central Arctic Herd. 

Although the footprint of facilities is a good indicator of potential impact to caribou, the activity 

occurring at the production pad, road, and airfields produces different impacts to caribou.

Cumulative impacts on caribou as a result of habitat loss and disturbance to animals are discussed in 

general terms under impacts on terrestrial habitats. Caribou may be affected by temporary ice roads and 

pads, and by disturbance caused by development construction and operations, especially during migration 

and calving periods. Cumulative impacts to terrestrial mammals are discussed more fully in BLM (2004a,

2012).

Past and Present Impacts and Their Accumulation

Approximately 2,500 acres of habitat have been directly impacted by non-oil and gas development on the 

North Slope, and those impacts continue to persist. Oil and gas activity between the Colville and Canning 

Rivers, where hundreds of miles of gravel roads cross a large portion of the Central Arctic Herd calving 

range in a 500-square-mile area, has caused an additional habitat loss or alteration of over 17,000 acres 

that persist today. Since most of these impacts are associated with ongoing residential or non-oil and gas 

commercial development, and oil and gas activities, these impacts to habitat are additive to future impacts 

and would be likely to persist for several decades or more in the absence of an active reclamation program 

(BLM 2012).

Oil and gas development has altered the distribution of female Central Arctic Herd caribou during the 

calving season and interfered with caribou movements between inland feeding areas and coastal insect 

relief areas. Female caribou may experience lower parturition rates when in close proximity to oil field 

development. It has also been suggested that declines in Central Arctic Herd caribou productivity in the 

early 1990s may have been the result of additive impacts of oil field development and high insect activity, 

although populations of Teshekpuk Caribou Herd and Central Arctic Herd caribou have increased 

between the mid-1970s and 2008. Thus, disturbance of caribou due to oil field development may 

adversely affect caribou populations, but these impacts are not readily apparent based on population 

trends. The Western Arctic Herd, whose range does not overlap the current oil fields and whose insectrelief habitat is not on the coastal plain, increased in numbers until about 2003. Since then, population 

estimates show a decline (Alaska Department of Fish and Game 2016).

Future Impacts and Their Accumulation

Activities Not Associated With Oil and Gas Exploration and Development. As described in BLM 

(2004a), cumulative impacts on caribou from road traffic would be expected to involve short-term 

displacement, especially during calving when maternal caribou avoid areas within 2.5 miles (4 

kilometers) of roads. Displacement from roads outside the calving season would not be expected to have a 

measurable effect on herd abundance or large-scale patterns of distribution (BLM 2004a).

Non-oil and gas activities on the North Slope would continue to disturb mammals and cause the loss of 

minor amounts of their habitat. Distant Early Warning-Line stations and other military sites, villages, 

airstrips, and other non-oil and gas infrastructure are likely to persist into the indefinite future. 

Furthermore, villages are likely to increase in size causing the loss of additional habitat. The amount of 

area that would be disturbed by new development on the North Slope in villages and other public 
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facilities is projected to increase to approximately 3,600 acres by 2050 and then level off for the 

remainder of the 21st century (BLM 2012).

Oil and Gas Exploration and Development Activities. Based on past seismic activity on the North 

Slope, BLM (2012) assumed continuation of the recent experience of three to four seismic crews active in 

NPR-A each winter. Since that assumption was made, however, there have been only one to two crews 

per winter. Exploration sites with gravel pads, disturbed areas around these pads, exploration airstrips, and 

gravel exploration roads have been replaced in recent years by ice roads, ice airstrips, and ice drilling 

pads to reduce the costs and environmental effects of exploration. Both disturbance and habitat loss 

impacts from ice roads and pads are short-term and are not expected to accumulate. Only a small amount 

of habitat is likely to be affected long-term by exploration activities (i.e., seismic) (BLM 2012).

BLM (2012) estimated that oil and gas development in the Chukchi and Beaufort Seas, construction of a 

road between Umiat and the Dalton Highway, and construction of a commercial gas pipeline and 

unconventional oil and gas development east of the NPR-A, could cause direct, terrestrial impacts on up 

to 6,300 acres of terrestrial habitat and indirect impacts on 38,000 acres (Section 4.6.5.1). At this point in 

time, the Umiat Road project has been withdrawn from permitting consideration and is no longer 

considered a reasonably foreseeable future. Additionally, the Chukchi Sea is considerably outside the 

GMT2 cumulative impacts analysis area and exploration of offshore leases in the Chukchi Sea has been 

halted, at least temporarily. More recently, a new potential development in the very-nearshore Smith Bay, 

could result in a pipeline and possible road going through or around core Teshekpuk Caribou Herd habitat 

in the Teshekpuk Lake area.

Although direct habitat loss from cumulative oil and gas development on the North Slope would affect 

only a small proportion of the total area, indirect habitat loss, or functional loss, could result from longterm displacement of wildlife from the vicinity of oil and gas activities and could involve a much larger 

area. Future gas and both conventional and unconventional oil exploration and development between the 

Colville and Canning Rivers, in addition to a commercial gas pipeline, would increase the amount of 

activity within the Central Arctic Herd caribou range. Future offshore or nearshore development of leases 

in the Beaufort Sea could expose Teshekpuk Caribou Herd and Central Arctic Herd caribou to additional 

activities related to oil and gas development (through onshore facilities to support offshore/nearshore 

leases). Future leases in the NPR-A could expose a large number of the Teshekpuk Caribou Herd caribou 

to exploration and development activities on their summer and winter grounds, and during migration. 

Caribou from the Western Arctic Herd would also be exposed to development activities in their summer 

range.

The Willow MDP is a proposed project similar in scale to the original Alpine Development Plan. The 

Willow MDP addresses an inter-related series of infrastructure components that could be constructed over 

an approximately 10-year period including up to five drill sites, a central processing facility, an 

infrastructure pad, gravel access roads, an airstrip, module delivery via sealift barges, pipelines, and a 

gravel mine. These components would be primarily in the Beartooth Unit, located about 7 miles west of 

the GMT2 project area, with supporting infrastructure in the Greater Mooses Tooth Unit, and on ununitized lands within the NPR-A, Kuukpik Corporation Lands and State of Alaska land and waters. 

The cumulative impacts to caribou and their habitats from Willow would be the loss of habitat through 

placement of gravel to support the infrastructure and transportation system, including an estimated 37 

miles of new gravel access roads. The estimated total surface disturbance includes 410 acres for roads and 

pads, and 75 acres for Willow Central Facility and airstrip, and over 100 miles of new pipelines. 

The TCH use the GMT2 project area throughout most of the year including spring and fall migration 

routes. Disturbance activities associated with Willow could displace caribou from these habitats and 

interfere with movement patterns. Expected disturbances due to Willow that could impact caribou within 

the GMT2 plan area include: noise, roads, yearlong vehicle traffic, aircraft traffic, construction activities, 
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mining gravel, winter ice roads and pads construction, and module transport. Depending on the type of 

activity the displacement could be short term but impacts from ground and air traffic could displace 

caribou in the GMT2 project area over the long term if development continues to expand into the NPR-A.

Proposed development could alter distribution of female caribou on the eastern portion of their calving 

area (Cameron et al. 2005), and new gravel access roads and pipelines could fragment some seasonal 

habitats and interfere with caribou movements (Cameron et al. 1995) during spring, and fall in the GMT2 

planning area The loss of habitats resulting from the development of GMT2 and reasonably foreseeable 

future exploration and development activities would affect primarily the TCH whose range is west of the 

Colville River. The CAH and WAH could be affected to a lesser degree. 

Construction of a gas pipeline would have short-term effects on wintering caribou if caribou are present 

during construction. This could affect both the Central Arctic Herd and Teshekpuk Caribou Herd. If 

buried, the pipeline would have no further disturbance effects except for brief periods of maintenance. It 

is anticipated that these effects would be minor and would not accumulate. A much greater impact would 

be effects from the gas development that such a pipeline would make possible (BLM 2012) within the 

NPR-A, and to the east.

Spills associated with reasonably foreseeable future projects could affect caribou on the North Slope. 

Cumulative effects would depend on the type, number, size, location, and timing of spills, and the type 

and effectiveness of the oil spill response. Potential oil spills from both offshore and onshore oil activities 

would be likely to have a small effect on caribou because comparatively low numbers of animals would 

be expected to be disturbed or contaminated, or to ingest contaminated food sources.

Abandoned gravel pads and roads could provide some benefits as insect-relief sites for caribou. The 

ultimate fate of the gravel pads and roads would not be known until closer to the end of a field’s 

production life. Permitting agencies could require that gravel be removed and the tundra revegetated. If 

other uses are determined to be preferable, regulatory agencies could allow permittees to leave gravel 

pads in place, either revegetated or not.

Contribution of the Alternatives to Cumulative Impacts

Impacts associated with vehicle traffic would be greatest under GMT2 Alternative A or B, due to the 

increased distance vehicles would have to travel. Alternative C would have no gravel access road traffic, 

but the absence of impacts from roads would likely be offset by the increase in impacts from air traffic at 

CD1/Alpine Processing Facility and GMT2 site. The use of aircraft at airports that are 16 to 21 miles 

apart (GMT2, Nuiqsut and CD1) under Alternative C is expected to have the greatest overall impact to 

caribou.

In addition to direct and indirect impacts to caribou from the GMT2 Project, the addition of the GMT1–

GMT2 Access Road under Alternative A or B could add increased hunting pressure to caribou herds due 

to increased road access west of existing development. Alternative D (no action) would result in no 

change from the current baseline conditions.

Conclusion

Overall, industry and agency actions on the North Slope are expected to have minor impacts to caribou 

herd productivity. Determining the overall cumulative impacts on herd abundance is difficult to predict. 

Displacement of caribou from the periphery of core calving area would be expected but this impact may 

have only a minor effect on the TCH population. The area between the Colville and Canning Rivers 

represents much of the range of the Central Arctic Herd. In some winters, this area is also important 

habitat for part of the Teshekpuk Caribou Herd. 
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Cumulative impacts from development and exploration in NE NPR-A on caribou habitats are within the 

range of cumulative impacts from oil and gas activities considered by BLM (2004a, 2012), which 

estimated there would be direct or indirect impacts on 44,000 acres of caribou habitat by 2100 (BLM 

2012). Caribou movements, particularly during spring and fall migrations, could be interrupted by vehicle 

traffic. The contribution from all action alternatives of the GMT2 Project is expected to be minor, and 

synergistic effects at the herd level would not be anticipated. Alternative D (no action) would result in no 

change from the current baseline condition.

Impacts to all mammalian populations from the combined impacts of vegetation change (from both 

human activities and climate change) and climate change induced weather patterns could prove to be 

synergistic rather than additive.

Grizzly Bear, Fox, and Other Terrestrial Mammals

Impacts under the proposed project’s action alternatives are expected to be higher during the construction 

phase. Construction of the project action alternatives would result in long-term, direct and indirect habitat 

loss due to gravel extraction and the placement of gravel for roads, pads, and, under Alternative C, an 

airstrip. Once construction is completed, the drilling and operation phase would affect terrestrial 

mammals and their habitats in the medium term through altered survival or productivity, habitat 

alteration, disturbance, potential for vehicle collision, and mortality for human safety. The cumulative 

impacts to grizzly bears, foxes, and other terrestrial mammals would be additive when considering the 

proposed project and all other reasonably foreseeable future projects. Cumulative impacts to terrestrial 

mammals are discussed more fully in BLM (2004a, 2012).

Past and Present Impacts and Their Accumulation

As reported by BLM, approximately 2,500 acres of habitat have been directly impacted by non-oil and 

gas development on the North Slope and those impacts continue to persist. Oil and gas activities have 

caused an additional habitat loss or alteration of over 17,000 acres that persist today. Since most of these 

impacts are associated with ongoing residential and non-oil and gas commercial development, or oil and 

gas activities, these impacts to habitat are additive to future impacts and would be likely to persist for 

several decades or more in the absence of an active reclamation program (BLM 2012).

Grizzly bears, foxes, and other terrestrial mammals have been little affected—some may even have 

benefited—from development on the North Slope. Subsistence and recreational hunting pressure has 

likely increased from historic levels due to increases in human populations and better access to the North 

Slope. Still, based on subsistence harvest surveys, subsistence harvest of mammals has been relatively 

stable since the early 1990s. Based on population trends of game mammals on the North Slope, neither 

hunting nor other human activities appear to be adversely affecting mammal populations (BLM 2012).

Future Impacts and Their Accumulation

BLM (2012) analyzed potential cumulative impacts across the North Slope to mammals occurring in the 

NPR-A. Some impacts that could prove to be synergistic rather than additive are the combined impacts of 

vegetation change (from both human activities and climate change), climate change induced weather 

patterns on the productivity of all mammalian populations, and predation. Mammalian populations have 

inherent levels of resilience, through behavioral flexibility and movement, to change in different factors 

affecting survival and productivity. Development of oil and gas in the NPR-A, alone or in combination 

with similar development elsewhere on the North Slope or offshore, could result in a decrease in this level 

of resilience. For some species, the magnitude of decrease may be adequate to result in negative 

population level responses.
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Activities Not Associated With Oil and Gas Exploration and Development. Non-oil and gas activities 

on the North Slope would continue to disturb mammals and cause the loss of minor amounts of mammal 

habitat. Distant Early Warning-Line and other military sites, villages, airstrips, and other non-oil and gas 

infrastructure are likely to persist into the indefinite future. Furthermore, villages are likely to increase in 

size causing the loss of additional habitat. The amount of area that would be disturbed by new 

development on the North Slope in villages and other public facilities is projected to double to 

approximately 3,600 acres by 2050 and then level off for the remainder of the 21st century (BLM 2012).

Oil and Gas Exploration and Development Activities. BLM (2004a) found that oil development on the 

North Slope would likely result in increased abundance of Arctic foxes near development areas, which 

may present a rabies health hazard to humans in the oilfield areas. The attraction of grizzly bears to 

human refuse may lead to the loss of bears as the result of interactions with humans, which could lead to 

an eventual decline in bear abundance near development areas. The cumulative impacts on muskoxen, 

moose, wolves, wolverines, and small mammals from oil and gas development on the North Slope would 

be local and short-term, within 1 to 2 miles of exploration or development facilities, and with no adverse 

impacts on populations (BLM 2004a, Section 4G.6.4.1).

Spills associated with reasonably foreseeable future projects could affect terrestrial mammals on the 

North Slope. Cumulative effects would depend on the type, number, size, location, and timing of spills, 

the type and effectiveness of the oil spill response, and the species exposed to the spill. Potential oil spills 

from both offshore and onshore oil activities would be likely to have a small effect on terrestrial mammals 

because comparatively low numbers of animals would be expected to be disturbed or contaminated, or to 

ingest contaminated food sources.

Abandoned gravel pads and roads could provide some benefits as burrowing habitat for species such as 

foxes and ground squirrels. The ultimate fate of the gravel pads and roads would not be known until 

closer to the end of the production field life. Permitting agencies could require that gravel be removed and 

the tundra revegetated. If other uses are determined by the permitting agencies to be preferable, the 

agencies could allow the permittee to leave the gravel pads in place, either revegetated or not revegetated.

Contribution of the Alternatives to Cumulative Impacts

Impacts to grizzly bears, foxes, and other terrestrial mammals for the action alternatives are presented in 

Section 4.2.1. Alternatives A, B, C would have similar, minor, impacts to terrestrial mammals, with 

impacts due to habitat loss and alteration expected to be of low intensity, long-term duration, and limited 

extent. The affected resources are rated common because grizzly bear, foxes, and other terrestrial 

mammals are considered usual or ordinary in the region, not depleted in the locality, and not protected by 

legislation.

Some mammal populations (e.g., fox and grizzly bear) have been little affected by development on the 

North Slope. The greatest increase of mortality to grizzly bears may be increased hunter access under 

Alternative A or B, as well as a potential increase in mortality in the defense of life and property at the 

GMT2 site. However, population-level effects should be negligible. Fox populations may increase, but 

mitigation measures should minimize any potential expansion of fox populations in the GMT2 Project 

area. Alternative D (no action) would result in no change from the current baseline conditions.

Conclusion

The cumulative impacts to grizzly bears, foxes, and other terrestrial mammals would be additive when 

considering other reasonably foreseeable future projects. Alternative D (no action) would result in no 

change from the current baseline conditions. If climate change over the next several decades were to 

result in widespread changes in vegetation composition and insect abundance, disturbance effects of oil 

and gas activities to terrestrial mammals could be exacerbated and could extend beyond the life of the oil 
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and gas fields. If these cumulative effects were to result in reductions in caribou populations, there could 

also be a reduction in the abundance of predators such as wolves, bears, and wolverines. Other impacts 

that could prove to be synergistic rather than additive are the combined effects of vegetation change (from 

both human activities and climate change), climate change induced weather patterns on productivity and 

predation.

The implementation of new mitigation measures in conjunction with lease stipulations and best 

management practices required for the protection of terrestrial mammal resources under all alternatives 

could reduce the cumulative effect to terrestrial mammals from oil and gas, and non-oil and gas activities.

4.6.7.5 Marine Mammals

Marine mammals are not expected to occur within the GMT2 Project area, or north along the coastline of 

Harrison Bay. The waters along the coast are either out of their geographic range or too shallow for most 

species to use during limited migrations through the area. Of the 10 marine mammal species initially 

considered, it was determined that 6 are not expected to occur in the project area (Section 3.3.4), and are 

not further evaluated. The four exceptions are: polar bear, covered under Section 4.3.5; and, spotted seal, 

bearded seal, and the beluga whale that are covered under Section 4.3.4.1. Cumulative impacts to marine 

mammals are discussed more fully in BLM (2004a, 2012) and are expected to be negligible.

4.6.7.6 Threatened and Endangered Species

Cumulative impacts to threatened and endangered species are described in BLM (2004, 2012). The types 

of potential impacts to threatened and endangered species under the GMT2 Project are similar to that of 

other birds and mammals, and include habitat loss and alteration, disturbance and displacement, mortality, 

obstruction of movement, and predation. Sections 4.3.3, “Birds,” and 4.3.4.2, “Marine Mammals,”

provide discussion of potential impacts to birds and marine mammals in general.

The threatened and endangered species that have been reported to occur, or have occurred, in or near the 

GMT2 Project area are Steller’s eider, spectacled eider, and polar bear. Potential impacts to these species 

from project elements and activities vary among the different action alternatives during construction, 

drilling, and operations (i.e., production). Discussion of potential impacts, and comparison of alternatives 

is presented below.

Steller’s Eider and Spectacled Eider

Steller’s Eider

Section 3.3.3 discusses the distribution, population, and habitat associations of Steller’s eider. Nest 

searches in the Colville River delta, Kuparuk River Unit, and northeast NPR-A over approximately 25 

years have found no nests or indications of breeding by Steller’s eiders (Johnson et al. 2013). In a similar 

time period, only a few sightings of individuals have been recorded (Johnson et al. 2013; Seiser and 

Johnson 2014). Therefore, there is a low probability for their future presence in the future at the project 

study area (Johnson et al. 2013). There is no designated critical habitat for this species on the North 

Slope. The overall cumulative impact to Steller’s eiders for the Harrison Bay and Lower Colville River 

Watersheds for the proposed project and other reasonably foreseeable future projects is considered to be 

negligible. There would be no impacts under the no-action alternative. Cumulative impacts to threatened 

and endangered (or special status species) are discussed more fully in BLM (2004, 2012).

Spectacled Eider

Section 3.3.3 discusses the distribution, population, and habitat associations of the spectacled eider. There 

is no designated critical habitat for the spectacled eider on the North Slope. Multi- year surveys show the 
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spectacled eider is present in the project study area, with the species occurring in high concentrations on 

the Colville River Delta and north of the Native Village of Nuiqsut. Habitats utilized by the spectacled 

eider adjoin the conceptual location of the road, production pad, and pipeline system of the proposed 

GMT2 Project. The spectacled eider could be impacted by the proposed project under all action 

alternatives as a result of habitat loss and alteration, disturbance and displacement, obstruction of 

movement, various sources of mortality (e.g., vehicle collisions, nest predation), or spills. The spectacled 

eider could be directly impacted ( in a very minor way) by the proposed project under Alternative A as a 

result of habitat loss. There would be no impacts under the no-action alternative. Cumulative impacts to 

threatened and endangered (or special status species) are discussed more fully in BLM (2004, 2012).

Past and Present Impacts and Their Accumulation

Activities Not Associated With Oil and Gas Exploration and Development. Approximately 2,500 

acres of habitat on the North Slope have been directly impacted by non-oil and gas development, and 

those impacts continue to persist. Oil and gas activities have caused an additional habitat loss or alteration 

of over 17,000 acres that persist today. Although only a small portion of this area would have been used 

by threatened and endangered species, much of it has occurred along the coastline and near Utqiagvik 

(formerly Barrow), areas where spectacled and Steller’s eiders are often found. These impacts are additive 

to future impacts and would likely persist for several decades or more in the absence of an active 

reclamation program.

Oil and Gas Exploration and Development Activities. Direct and indirect impacts from disturbance of 

many different types are difficult to measure, but are likely accumulating as the number of developments 

and the amount of developed area increase. New oil and gas developments have reduced their footprint 

size and the corresponding direct impacts have been reduced. However, these new developments often 

rely on aircraft support for transportation of personnel and equipment potentially increasing disturbance

to feeding, nesting, staging and molting birds. The impacts of predators on threatened and endangered 

species populations may be waning as industry reduces the amount of predator-attracting garbage in the 

fields. Habitat loss and disturbance can add incrementally to the impacts of development on threatened 

and endangered species (BLM 2012).

Whether past impacts to threatened and endangered species populations from habitat loss or disturbance 

are associated with non-oil and gas residential and commercial development, or oil and gas activities, 

these impacts are additive to any potential future impacts (BLM 2012).

Future Impacts and Their Accumulation

Activities Not Associated With Oil and Gas Exploration and Development. Non-oil and gas activities 

are expected to continue in the future resulting in the loss of small amounts of habitat and disturbance to 

threatened and endangered species. In some cases, loss of habitat from these activities would be 

temporary, lasting only a season or a few years.

However, habitat loss and disturbance associated with military facilities, villages, airstrips, and other nonoil and gas infrastructure are likely to persist into the indefinite future. Villages are likely to increase in 

size, causing the loss of additional habitat and increase disturbance, and may increase the predation rate of 

spectacled and Steller’s eiders and nests in the vicinity of the human expansion. The amount of area that 

would be disturbed by new development on the North Slope in villages and other public facilities is 

projected to double to approximately 3,600 acres by 2050 and then level off for the remainder of the 21st

century. It is currently illegal to use lead shot while hunting waterfowl, although lead shot is allowed for 

hunting upland species. Illegal use of lead shot for hunting waterfowl, or legal use of lead shot for hunting 

upland species near waterfowl habitats, could contribute to the impacts of lead poisoning on eider 

populations. Programs are currently underway by the USFWS and the North Slope Borough to inform 
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hunters of harvest closures on these species in an effort to decrease this source of mortality. However, 

lead shot appears to persist in the environment and any additional lead shot would be additive to past 

amounts, incrementally increasing the chance of exposure to eiders and further reducing survival.

Oil and Gas Exploration and Development Activities. BLM (2012) analyzed potential cumulative 

impacts across the North Slope to spectacled and Steller’s eiders occurring in the NPR-A. Development 

activities that could contribute to cumulative impacts to spectacled and Steller’s eiders and their habitat 

on the North Slope include onshore oil and gas development by federal, state, and Native entities; federal 

and state offshore oil and gas development (including the construction of onshore infrastructure); oil and 

gas transportation, including commercial gas pipelines; and road construction. All of these activities 

involve construction of infrastructure that would directly destroy habitat (although it is unknown if high 

quality eider habitat will be directly impacted by these projects) within the immediate footprint of the 

project and indirectly affect potential habitats for eiders through disturbance, predation, dust, flooding, 

changes in natural drainage patterns, thermokarst, snow drifting, and oil and chemical spills. The potential 

loss of habitat resulting from the development of the proposed project and reasonably foreseeable future

projects could affect the threatened and endangered bird resources that rely on these habitats. 

Development in the northern portion of the NPR-A could have a synergistic effect on spectacled eiders 

using the Colville River delta by the need for increased infrastructure or air or ground traffic in the delta 

to transport oil and gas, or corresponding supplies and equipment, to or from the NPR-A.

The primary impacts to threatened and endangered birds associated with the proposed project and other 

reasonably foreseeable future projects is that future development and oil production could occur on the 

North Slope in the NPR-A, the Beaufort and Chukchi seas, and onshore between the NPR-A and the 

Arctic National Wildlife Refuge. New development, especially for economically marginal oil fields, 

would most likely occur near existing fields so that infrastructure systems could be shared (BLM 2012). 

Specific reasonably foreseeable future projects include development in the Greater Mooses Tooth, Bear 

Tooth, Colville River, Kuparuk River, Ooguruk, Pikka and Tofkat Units. These potential projects, along 

with established activities, recent developments, and recently permitted activities noted in Table 4.6-2, 

Past, Present and Reasonably Foreseeable Future Developments are all within the Harrison Bay and 

Lower Colville River Watersheds and would have additive impacts to threatened and endangered birds in 

that area. 

More information has recently been acquired with the submission to BLM of a master plan for the Willow 

Development. The Willow Master Development Plan (MDP) is a proposed project similar in scale to the 

original Alpine Development Plan. The Willow MDP addresses an inter-related series of infrastructure 

components that could be constructed over an approximately 10-year period including up to five drill 

sites, a central processing facility, an infrastructure pad, gravel access roads, an airstrip, module delivery 

via sealift barges, pipelines, and a gravel mine. These components would be primarily in the Beartooth 

Unit, located about 7 miles west of the GMT2 well site, with supporting infrastructure in the Greater 

Mooses Tooth Unit, and on un-unitized lands within the NPR-A, Kuukpik Corporation Lands and State of 

Alaska land and waters. 

The cumulative impacts to [spectacled eiders and their habitats] from Willow, according to the MDP, 

would be the loss of habitat through placement of gravel to support the infrastructure and transportation 

system, including an estimated 37 miles of new gravel access roads and over 100 miles of new pipelines. 

The total new surface disturbance due to the placement of gravel fill is estimated to be 410 acres.

Although direct habitat loss from cumulative oil and gas development on the North Slope would affect 

only a small proportion of the total area, indirect habitat loss, or functional loss, could result from longterm displacement of threatened and endangered birds from the vicinity of oil and gas activities and could 

involve a much larger area. Future offshore or nearshore development of leases in the Beaufort Sea could 
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expose birds to additional habitat loss and disturbance related to oil and gas development through onshore 

facilities to support offshore/nearshore leases.

Spills of crude oil and other substances associated with reasonably foreseeable future projects could affect 

threatened and endangered birds on the North Slope. Cumulative effects would depend on the type, 

number, size, location, and timing of spills, and the type and effectiveness of the oil spill response and the 

species exposed to the spill. 

If global climate change persists, the cumulative effects to threatened and endangered birds from oil and 

gas and non-oil and gas development on the North Slope could be greater than predicted due to larger 

than currently expected changes to bird habitat. Continued climate change would eventually lead to shifts 

in the composition and distribution of Arctic tundra vegetation and wetlands, which would affect birds in 

both positively and negatively. Permafrost would thaw to increased depths, causing varying degrees of 

impacts on subsidence, soil moisture, and vegetation. The potential for many shallow streams, ponds, and 

wetlands in the Arctic to dry out under a warming climate is increased by the loss of permafrost. Such 

impacts of climate change could accumulate with changes in soil thermal regimes that might occur as a 

result of past and future non-oil and gas and oil and gas activities in and near the NPR-A, potentially 

leading to synergistic impacts to threatened and endangered birds (BLM 2012).

Contribution of the Alternatives to Cumulative Impacts

BLM (2004) found that the incremental contribution of the Alpine Field to the cumulative impacts on 

spectacled and Steller’s eiders on the Arctic Coastal Plain was likely to be limited to occasional 

disturbance from aircraft overflights resulting in temporary, nonlethal impacts. Disturbance of some 

individual eiders as a result of both onshore and offshore oil and gas operations would likely be 

unavoidable over the long-term. The impacts from typical activities associated with cumulative 

exploration and development of oil and gas prospects on the North Slope and adjacent marine areas may 

include small declines in local nesting or loss of small numbers of spectacled eiders (and potentially 

Steller’s eiders). These impacts would occur through changes in survival and productivity, predation 

pressure enhanced by human activities, and collisions with structures and vehicles. Increased human 

access via new roads and highways may result in locally severe increases in subsistence hunting 

pressures. Alternatively, subsistence hunting may decrease if hunters choose to avoid developed areas. 

The cumulative activities discussed above may cause localized impacts within the Colville River delta but 

are unlikely to cause significant cumulative population impacts (BLM 2004).

Section 4.3.3 discusses, in depth, the impacts to threatened and endangered bird species from Alternatives 

A, B, and C. Direct impacts to habitats used by threatened and endangered bird species from gravel 

placement would only occur under Alternative A. Under all alternatives, no significant impact to the 

spectacled eider population is expected due to the low population density in the vicinity of the proposed 

facilities. 

Alternatives A and B would have annual ice roads constructed in Years 1–3 to allow for construction of 

gravel infrastructure. Post-construction of gravel infrastructure there would be no ice roads needed for 

these two alternatives. Alternative C requires annual ice roads to be constructed for the life of the project. 

No threatened and endangered birds are present in the area during ice road season; however, re-use of ice 

annual road routes and ice pad locations could damage tundra, resulting in potential long-term impact to 

potential high value threatened and endangered bird habitats.

Impacts associated with disturbance to threatened and endangered birds from vehicle traffic would be 

greatest under Alternative A or B, due to the distance vehicles would have to travel. Alternative C would 

have no gravel access road traffic. 
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Potential impacts to threatened and endangered birds from aircraft under Alternative C is greater than 

Alternatives A or B due to the requirement to use aircraft to access the GMT2 drill pad when ice roads are 

not feasible (roughly nine months of the year). The air traffic at the GMT2 facility under Alternative C 

would be additional to the existing activity in the Alpine Central Processing Facility and Nuiqsut 

airspaces, and would continue for the long term,while additional flights required under Alternatives A 

and B would drop considerably after construction is completed. The impacts (disturbance and 

displacement) associated with aircraft traffic would be greatest for Alternative C as compared to 

Alternatives A and B.

Potential impacts to threatened and endangered birds from mortality and predation due to Alternatives A 

and B would be higher than for Alternative C, because the absence of a gravel road would negate the 

probability of mortality due to vehicle traffic and fewer culverts in gravel structures would create fewer 

potential sites for predators exploit. Under Alternatives A and B the construction of a road system could 

improve access for subsistence hunting of birds. The impacts associated with mortality from traffic and 

predators for all alternatives are expected to be of long-term duration and of local extent.

Potential impacts from oil pipeline spills would be similar under Alternatives A, B, and C. Alternative D 

(no action) would result in no change from the current baseline conditions. 

Conclusion

In the context of the North Slope west of the Canning River, the combination of impacts to threatened and 

endangered birds from the proposed project coupled with impacts from reasonably foreseeable future 

projects the cumulative impacts would be relatively small (BLM 2012) and would be dependent upon 

reasonably foreseeable future project locations relative to eider populations and their preferred habitat and 

on the type of access to the reasonably foreseeable future (roaded or not roaded). Further development in 

the cumulative impacts evaluation area may also impact spectacled and Steller’s eiders through a 

cumulative reduction in habitat and an increase in disturbance. These impacts are not expected to cause 

pervasive cumulative impacts, as the impacts of the currently proposed and reasonably foreseeable future

projects on spectacled and Steller’s eider population, though additive, would be less than those of past 

projects due to smaller project areas (by comparison) and the large extent of existing habitat in the area of 

evaluation. The contribution from the proposed project is expected to be negligible with respect to the 

cumulative impacts evaluation area, and would be decreased from that approved in the 2004 Alpine 

Satellite Development Plan Record of Decision due to the reduced footprint of the proposed project.

If climate change over the next several decades were to result in substantial changes in weather patterns, 

vegetation types and distribution, and insect abundance, habitat disturbance impacts from oil and gas 

activities could be exacerbated additively and perhaps synergistically, and extend beyond the life of the 

oil and gas fields. Changes in vegetation as a result of climate change would directly impact the amount 

and types of habitat available to threatened and endangered birds. Such impacts of climate change could 

accumulate with any changes in soil thermal regimes that might occur as a result of past and future nonoil and gas and oil and gas activities in and near the NPR-A, potentially leading to synergistic impacts to 

bird habitat (BLM 2012).

Oil spills would not significantly add to cumulative impacts, except for an unlikely to very unlikely large 

spill to aquatic habitats.

The combination of impacts from the proposed project, coupled with impacts from other reasonably 

foreseeable future projects would be additive, long-term, and localized. The overall cumulative impact to 

threatened and endangered birds for the Harrison Bay and Lower Colville River Watersheds, and other 

reasonably foreseeable future projects is considered to be minor.
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Alternative D would not have any incremental cumulative impacts to threatened and endangered birds.

Polar Bear

Section 3.3.5 discusses the distribution of the polar bear, a wide-ranging animal that can be found along 

the coastline of the entire North Slope. Maternal polar bear dens are documented along the mouth of the 

Colville River delta, but have not been documented inside the project study area (BLM 2012, Map 3.3.8-

6). There is designated critical habitat for this threatened species on the North Slope. The three habitat 

units of that critical habitat include sea ice habitat extending east from the international dateline to 

Canada, barrier islands along Alaska’s coast within the range of the polar bear, and terrestrial denning 

habitat extending 5 miles inland from the coast from Utqiagvik (formerly Barrow) to the Kavik River and 

20 miles inland from the Kavik River to Canada. Potential polar bear denning habitat, sightings, and den 

locations in relation to the proposed GMT2 Project area are shown in Map 3.3-11. The nearest den 

locations reported are more than 2 miles from infrastructure associated with the proposed GMT2 Project 

(Durner 2010) (Map 3.3-11). Within the project study area a section of the GMT2 road system is within 

the area designated critical for denning and additional portions of the project study area are within the 

area designated critical for feeding. In the GMT1 Biological Opinion, USFWS noted that while polar 

bears may be present in the GMT1 Action Area, they are expected to occur infrequently, with the highest 

numbers occurring in the portion of the action area closest to the coast (USFWS 2014a). The GMT2 

Action Area would be even further inland. Polar bears are likely to be impacted in similar ways to 

terrestrial mammals. Cumulative impacts to marine mammals and threatened and endangered (or special 

status species) are discussed more fully in BLM (2004, 2012).

Past and Present Impacts and Their Accumulation

Prior to the 20th century, both the Chukchi/Bering and Southern Beaufort sea polar bear populations 

probably existed near carrying capacity (Allen and Angliss 2010). Once harvest by non-Natives became 

common in the 1960s, the size of the Southern Beaufort Sea population declined substantially (Amstrup 

et al. 1986; Amstrup 1995). Since passage of the Marine Mammal Protection Act in 1972, both the 

southern Beaufort and Chukchi/Bering sea populations seem to have increased (Allen and Angliss 2010). 

However, polar bears have since been listed as threatened rangewide because of climate change-related 

threats to the species’ sea ice habitat (BLM 2012).

Changes in sea ice conditions can have cascading effects that increase the magnitude of impacts from 

other sources of impact. For example, thinning ice and a greater extent of marginal ice stability in the fall 

may already be leading to reduced sea ice denning, and a corresponding increase in denning on land, in 

Southern Beaufort Sea bears (Fischbach et al. 2007). This in turn increases the probability of disturbance 

to denning bears from human activities. The chances of bear-human encounters in coastal villages and 

industrial areas also increases with a greater proportion of the Southern Beaufort Sea or Chukchi/Bering 

sea populations coming on land during the fall open-water period, or as the amount of time individual 

bears spend on land increases (BLM 2012).

Future Impacts and Their Accumulation

Activities Not Associated With Oil and Gas Exploration and Development. BLM (2012) described 

potential cumulative impacts to polar bears from non-oil and gas activities that would result from harvest 

(subsistence, handicrafts, and recreation), other sources of direct mortality, research, pollution and 

contaminants, and coastal development. These activities and impacts are described below and are 

summarized from the BLM (2012, Section 4.8.7.11).

The primary concern for polar bears on the North Slope is loss of sea ice. The potential for an oil spill 

remains a potential threat to polar bears at the local population level, and this threat may increase with 

increased shipping traffic in the Arctic. While most other threats are either being managed or are not 
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currently thought to be significant threats to polar bear populations, each could become significant in 

combination with future effects of climate change and the resultant loss of sea ice.

Hunting by non-Natives has been prohibited since 1973 although Alaska Natives living in coastal 

communities can hunt polar bears for subsistence and the making of handicrafts. The Southern Beaufort 

Sea population is currently considered depleted (Allen and Angliss 2010), and harvest quotas are set by 

the Inuvialuit-Iñupiaq Council. The harvest level for the Chukchi/Bering Sea population is not limited at 

this time; while the Alaska Native harvest from this population is reported to have declined recently, the 

portion of harvest that occurs in Russia is not well quantified (Allen and Angliss 2010).

Polar bears are occasionally killed during defense of life and property (Brower et al. 2002). Other 

relatively rare sources of mortality include predation by other polar bears, injury during fights or attacks 

among polar bears for reproductive advantage (Swenson et al. 1997), and injury received during play 

bouts (Taylor et al. 1985). Polar bears may also occasionally sustain serious injury while hunting, which 

can lead to death (Stirling et al. 2008).

There are several on-going research programs studying polar bears that may cause short-term adverse 

impacts to individual polar bears observed in surveys or targeted in capture efforts and may also 

incidentally disturb other bears nearby.

Persistent organic pollutants and the heavy metal mercury are known to have accumulated in individuals 

of the Southern Beaufort Sea and Chukchi/Bering Sea populations of polar bears, although adverse 

impacts have not been demonstrated for individual bears nor are the contaminants thought to have 

population-level impacts. However, contaminant body burdens, in combination with other factors such as 

loss of sea ice habitat and decreased prey availability, could ultimately contribute to adverse impacts in 

the health or productivity of individual polar bears.

The BLM estimates that approximately 1,800 acres have been occupied by community development in 

six Alaska North Slope villages through 2008, with much of the development associated with these 

villages occurring along the coast. Fourteen Distant Early Warning-Line sites were constructed along the 

coast of the North Slope in the 1950s, ranging in size from 150 to 2,835 acres. Beginning in the 1990s 

some of these sites have been remediated and restored, while others were converted to National Weather 

Service stations. Coastal development since 1900 has likely increased disturbance impacts to bears and 

increased human-bear encounters, but there is no evidence that this has significantly affected polar bear 

populations. If land-based denning by polar bears increases with declines in sea ice, future coastal 

development may make potential polar bear denning habitat prone to disturbance or unavailable.

Oil and Gas Exploration and Development Activities. Cumulative impacts to polar bears from 

activities across the North Slope were fully considered in BLM (2012). Oil and gas development in the 

Chukchi and Beaufort seas has the greatest potential to lead to additive impacts for polar bears. Even 

small spills that could not be completely remediated could accumulate over time and could include direct 

fouling of polar bears, their prey, or their habitat. These spills could foul ice and shorelines, so the 

continued risk of direct exposure remains, as does the risk of long-term contamination of both marine and 

terrestrial habitats (BLM 2012). Other proposed activities with the most potential to affect polar bears in 

the NPR-A include oil and gas exploration, aircraft and watercraft traffic, and winter overland travel. 

These activities could affect polar bears by causing direct mortality from defense of human life, 

accidental oil spills, altering polar bear behavior, physiology, or movements; or disturbing or destroying 

snow dens, which could cause impacts to cubs at critical life stages, resulting in mortality (BLM 2012).

Based on past seismic activity on the North Slope, BLM (2012) assumed continuation of the recent 

experience of three to four seismic crews active in NPR-A each winter. Since that assumption was made, 

however, there have been only one to two crews per winter. Exploration sites with gravel pads, disturbed 
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areas around these pads, exploration airstrips, and gravel exploration roads have been replaced in recent 

years by ice roads, ice airstrips, and ice drilling pads to reduce the costs and environmental effects of 

exploration. Both disturbance and denning habitat loss impacts from ice roads and pads are short-term and 

are not expected to accumulate. Only a small amount of potential denning habitat is likely to be affected 

long-term by exploration activities (BLM 2012).

Future development and oil production could occur on the North Slope in the NPR-A, the Beaufort and 

Chukchi seas, and onshore between the NPR-A and the Arctic National Wildlife Refuge. New 

development, especially for economically marginal oil fields, would most likely occur near existing fields 

so that infrastructure systems could be shared (BLM 2012). Specific reasonably foreseeable future

projects include development in the Greater Mooses Tooth, Bear Tooth, Colville River, Kuparuk River, 

Ooguruk, Pikka and Tofkat Units. These potential projects, along with established activities, recent 

developments, and recently permitted activities noted in Table 4.6-2, Past, Present and Reasonably 

Foreseeable Future Developments, are all within the Harrison Bay and Lower Colville River Watersheds. 

Some of these reasonably foreseeable future projects fall within the critical habitat area for terrestrial 

denning habitat, which extends 5 miles inland from the coast from Utqiagvik (formerly Barrow) to the 

Kavik River potentially affecting denning habitat and decreases denning success.

More information has recently been acquired with the submission to BLM of a master plan for the Willow 

Development. The Willow Master Development Plan (MDP) is a proposed project similar in scale to the 

original Alpine Development Plan. The Willow MDP addresses an inter-related series of infrastructure 

components that could be constructed over an approximately 10-year period including up to five drill 

sites, a central processing facility, an infrastructure pad, gravel access roads, an airstrip, module delivery 

via sealift barges, pipelines, and a gravel mine. These components would be primarily in the Beartooth 

Unit, located about 7 miles west of the GMT2 well site, with supporting infrastructure in the Greater 

Mooses Tooth Unit, and on un-unitized lands within the NPR-A, Kuukpik Corporation Lands and State of 

Alaska land and waters. 

The cumulative impacts to [polar bears and their habitats] from Willow would include the loss of habitat 

through placement of gravel to support the infrastructure and transportation system, including an 

estimated 37 miles of new gravel access roads, temporary development in State of Alaska waters over 

100 miles of new pipelines and all the disturbance issues associated with the GMT-2 development. 

Although direct habitat loss from cumulative oil and gas development on the North Slope would affect 

only a small proportion of the total area, indirect habitat loss, or functional loss, could result from longterm displacement of polar bears from the vicinity of oil and gas activities and could involve a much 

larger area. Future offshore or nearshore development of leases in the Beaufort Sea could expose polar 

bears to additional habitat loss and disturbance related to oil and gas development through onshore 

facilities to support offshore/nearshore leases.

If global climate change persists, the cumulative effects to polar bears from oil and gas and non-oil and 

gas development on the North Slope could be greater than predicted due to larger than currently expected 

changes to their habitat. Such impacts could accumulate with changes in thinning of ice and greater extent 

of marginal ice stability in fall that might occur as a result of past and future non-oil and gas and oil and 

gas activities in and near the NPR-A, potentially leading to synergistic impacts to polar bears (BLM 

2012).

The proposed project represents an additive cumulative effect with respect to polar bears. 
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Contribution of the Alternatives to Cumulative Impacts

Under the action alternatives, polar bears may be drawn or attracted to human activity associated with the 

proposed project resulting in incidental or intentional harassment. Under Alternatives A, and B which add 

permanent gravel roads, there is an increased risk of collision with vehicles. These alternatives also 

increase the local transportation network, thus allowing easier access for subsistence hunters. Alternative 

C would have no gravel access road traffic, but the absence of impacts from roads would likely be offset 

by the increase in impacts from air traffic at the GMT2 site. The potential mortality impacts to polar bears 

resulting from all the action alternatives are expected to be minor. Alternative D would have no negative 

impacts to polar bears.

Conclusion

Oil and gas activities may result in disturbance to individual polar bears and may prevent some polar 

bears from using small portions of habitat. In particular, some polar bear denning habitat has likely been 

altered or made unavailable as a result of construction and human activity. The amount and effect is 

unknown, but likely minimal, since the majority of historic dens were offshore and most land dens were 

to the east of major development (Amstrup and Gardner 1994). The main land-based polar bear travel 

corridor (within 1 mile of the coast) and nearshore area have been fragmented to some extent; but the 

effect has likely been minimal. This minimal effect can be attributed to the small amount of development 

that has occurred related to total area, and the ability of polar bears to cross human-made routes, including 

roads and causeways.

Whereas industry activities have had some impacts on individual polar bears, there is no evidence these 

impacts have resulted in changes to polar bear populations (BLM 2012, Section 4.8.7.11). While other 

threats are managed or are not currently thought to be significant threats to polar bear populations, each 

could become significant in combination with future effects of climate change and the resultant loss of sea 

ice. Changes in the extent and timing of sea ice are expected to have a significant impact on polar bears 

through alteration of their distribution, nutritional status, reproductive success, and ultimately their 

abundance.

When evaluating the currently proposed project in conjunction climate change and other reasonably 

foreseeable future projects, these projects could have an additive cumulative effect with respect to polar 

bears. Further development may encroach on polar bear denning habitats and the placement of additional 

infrastructure would increase disturbances, the potential for encounters, and obstruction to movement. 

Offshore development and development of onshore support facilities would have cumulative additive 

impacts to polar bears and their habitats. This impact would be anticipated to be long-term, localized, and 

depending on the species and location would range in intensity.

Bowhead Whale and Ringed Seal

Two species of marine mammals listed under the Endangered Species Act are present in the Beaufort Sea: 

the bowhead whale (endangered) and the ringed seal (threatened). All but the CD5 pad, a short section of 

pipeline system from GMT1, and a short section of pipeline system from CD5 to CD1 are further than 5 

miles from the coast. This infrastructure would not likely impact these species.

Cumulative impacts to bowhead whales, and ringed seals are most likely to occur as a result of 

subsistence hunting, vessel transportation, air transportation, commercial fishing, spills or other 

discharges to the marine environment, dredging, coastal development, and climate change (BLM 2012, 

Section 4.8.7.11). Cumulative impacts to marine mammals and threatened and endangered (or special 

status species) are discussed more fully in BLM (2004, 2012).
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Past and Present Impacts and Their Accumulation

For Bering-Chukchi-Beaufort seas bowhead whales, the most dramatic population level impacts were 

associated with commercial whaling that occurred from 1849 to 1915 (Bockstoce and Botkin 1983). In 

fact, all circumpolar bowhead populations are still recovering to varying degrees from commercial 

whaling today (Zeh et al. 1993; BLM 2012, Section 4.8.7.11).

More recently, climate change and increasing human activities (particularly with regard to oil and gas 

activities) may be having large impacts on these species. For bowheads, some information is available on 

how individual animals respond to oil and gas activities but the observations are short-term and provide 

little usable data for longer-term impacts on individuals or the population. Bowheads seem to be highly 

sensitive to low levels of anthropogenic sounds and deflect away from those sounds or change their 

behavior. Ringed seals seem to be quite tolerant of anthropogenic activities. Little is known about other 

species (BLM 2012).

Although some information exists on how individual animals respond to anthropogenic sounds, it is not

known how those impacts accumulate. Most bowhead whales annually return to Beaufort Sea to feed, and 

much information exists on how individual animals respond to anthropogenic sounds (Richardson et al. 

1995). One such response is that migrating bowhead whales have avoided areas of specific human 

activities ranging from 1 to 2 kilometers to over 20 kilometers (Richardson 1999, 2008). 

Bering/Chukchi/Beaufort sea bowheads do not seem to have habituated to industrial activities. If impacts 

were countervailing or do not accumulate over years, cumulative impacts or past and present activities 

may have been minimal to date (BLM 2012).

Hunting and commercial fishing are the two primary factors that have affected bowhead whales in the 

past and continue today, while ringed seals are thought to have been relatively unaffected by 

anthropogenic sources. While commercial fishing, vessel strikes, and subsistence take have removed 

individuals from the bowhead population and possibly affected population growth rates, the impact is 

minimal and has not altered a strong population growth trend (George et al. 2004; BLM 2012).

Noise and disturbance associated with offshore seismic and drilling activities, and boat and barge traffic,

have affected bowhead whales, causing deflection and behavioral changes (Richardson et al. 1995). A 

large body of literature exists about the sensitivity of bowhead whales to industrial sounds and activities 

(see National Research Council 2003); however, it is not known how impacts from these stressors 

accumulate. Bowhead populations have been increasing for at least 3 decades despite oil and gas 

activities. It is possible, though, that the population could have increased more rapidly in the absence of 

industrial activities. It appears that ringed seals are relatively insensitive to some disturbance impacts 

from oil and gas activities such as vessel traffic, offshore seismic and drilling activities but studies have 

not been completed to assess with confidence whether long-term persistent changes in behavior exist that 

could lead to reduced fitness and population changes. Other impacts from oil and gas activities such as 

vessel discharge, introduction of new biota, oil spills, and changes in prey distribution or abundance have 

a high probability of negatively impacting seals (BLM 2012).

Future Impacts and Their Accumulation

Activities Not Associated With Oil and Gas Exploration and Development. Non-oil and gas activities 

could also contribute to cumulative impacts on bowhead whales and ringed seals. Principle impacts 

include: shipping, commercial fishing, subsistence hunting, tourism, and climate change. Although a few 

individuals would likely be injured or killed, non- oil and gas activities are not expected to have much 

impact on the bowhead whale or seal population, and bowhead whale populations have increased steadily 

under current management (George et al. 2004; Zeh and Punt 2005). However, if major commercial 

shipping routes become established in the Arctic, ship strikes of bowheads and other shipping-related 

impacts may occur at higher rates (e.g., oil spills, debris, bilge water) (Reeves et al. 2012; BLM 2012).
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A presumably small number of bowhead whales could be injured or killed as a result of entanglement in 

fishing gear or collisions with ships (Reeves et al. 2012). Fishing would compete for seal prey items and 

over time may produce population level impacts due to decreased body conditions of seals from 

nutritional stress. It is expected that subsistence harvesters would continue to harvest bowhead whales and 

that traditional seal harvest will continue (BLM 2012).

Past and present activities associated with the operation and rehabilitation of Distant Early Warning-Line 

and similar military sites, tourism, and scientific research can cause impacts to bowhead whales and 

ringed seals and result in disturbance, deflections, and masking of whale and seal sounds. These 

disturbances can be expected to continue or possibly increase in the future (BLM 2012).

It is likely that reduced sea ice and climate changes could result in increased commercial shipping traffic 

and increased commercial fishing. These activities could result in an increase in vessel collisions for 

bowheads resulting in additional injury and mortality (BLM 2012).

Increased fishing effort in areas currently used by bowheads and ice seals would likely result in an 

increased rate of encounters with fishing gear, greater entanglement rates, and subsequent injury, loss of 

fitness, and mortality. Ringed seals would experience an increased competition for food resources, which 

could affect overall body condition and recruitment into the population (BLM 2012).

Oil and Gas Exploration and Development Activities. The potential impacts of future oil and gas 

development on the North Slope to special status marine mammals was analyzed in BLM (2012). If a 

large oil spill were to occur as a result of (1) development and production associated with any past, 

present, or reasonably foreseeable future development project on the North Slope or in the Beaufort or 

Chukchi seas, or (2) grounding of a large commercial vessel, some bowhead whales and ringed seals 

would likely be impacted. However, most whales directly exposed to spilled oil would likely experience 

temporary, nonlethal impacts from skin contact with oil, inhalation of hydrocarbon vapors, ingestion of 

oil- contaminated prey, baleen fouling, reduction in food resources, or temporary displacement from some 

feeding areas. A few individuals could be killed if they were to experience prolonged exposure to freshlyspilled oil. Reproductive impacts are also possible. Impacts to seal species would depend on a number of 

factors such as the amount and duration of exposure, and proportion of oiled prey consumed. Reduction in 

food resources would be more detrimental to seal species due to their life history characteristics when 

compared to long-lived bowhead whales with large stored energy supplies. Oil spill cleanup activities 

(e.g., vessel and aircraft traffic) could displace some bowhead whales, should those activities coincide 

with the fall migration.

If there were increased offshore exploration and development activities, the potential for cumulative 

impacts to marine mammals by noise or other activities would increase. Whale species most likely to 

experience cumulative impacts include gray whales. Increases in ice-free periods and ice retreat may be 

accompanied by a northward shift in commercial fisheries and shipping traffic, potentially increasing 

rates of disturbance, entrapment, entanglement, and vessel strikes. Offshore oil and gas exploration and 

development, should it occur in areas occupied by whales, would result in disturbance impacts and may 

impact foraging success, possibly to the extent that fitness is reduced. Contribution of impacts from 

onshore NPR-A activity to the overall cumulative impacts to special status marine mammals will likely be 

relatively small (BLM 2012). While specific effects of climate change and ocean acidification on 

bowhead whales and ringed seals are uncertain, ice seals, in particular, may experience loss of habitat and 

changes in prey distribution and availability. Impacts of the currently proposed project are within the 

range of impacts analyzed in BLM (2012).

Of the reasonably foreseeable future projects, development of offshore prospects and onshore support 

infrastructure would have the greatest potential impact to these species based on the location of these 

projects. The impacts would be additive to those of GMT2 and future onshore development in the NPR-
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A. A full evaluation of how potential offshore development and associated onshore support infrastructure 

could impact these three species is outside of the scope of this document.

Contribution of the Alternatives to Cumulative Impacts

Under all of the action alternatives for the proposed GMT2 Project, the impact to bowhead whales and 

ringed seals is considered negligible based on the project location relative to these species. Alternative D 

would have no incremental impact due to the lack of development.

Conclusion

In the Arctic, industrial sounds and other disturbances have displaced whales from preferred habitats; 

these impacts can be difficult to quantify and to determine if they accumulate. In addition to noise and 

disturbance from existing oil development, seals and bowhead whales could be affected by future offshore 

development in the Beaufort and Chukchi Seas.

The probability of a spill reaching marine waters under the proposed project is very low. In the event of a 

spill reaching marine waters, the spill would need to reach waters of greater depth well offshore from the 

coastline to coincide with the seasonal preference of these three species for an impact to occur. An oil 

spill could affect marine mammals in offshore or coastal areas, with the impacts depending on the 

location and amount of oil spilled and time of year. The impacts of future habitat alteration associated 

with gravel island construction, platforms, or other structures related to oil development would likely be 

minor.

The presence of small amounts of hazardous materials, including hydrocarbons and previously used 

insecticides, would likely have minor impacts on marine mammals.

The BLM (2004) found that the overall cumulative impacts of the proposed development and other past, 

present, and reasonably foreseeable future activities would be minor. Impacts were expected to be the 

potential loss of up to several hundred seals and walruses, and probably less than 10 gray whales. 

Cumulative noise and disturbance in the Beaufort Sea and on the North Slope are expected to briefly and 

locally disturb or displace a few seals and gray whales (BLM 2004).

4.6.8 Cumulative Impacts to Social Systems

4.6.8.1 Cultural Resources

Cumulative impacts to cultural resources could occur in the project area as a result of additive direct 

impacts such as those that occur from ground-disturbing activities such as gravel excavation, road 

construction, installation of vertical support members for pipelines and powerlines, and other ground 

disturbance in proximity to project components. Other activities and events that could cause direct 

impacts to cultural resources include damage caused by equipment during the construction, drilling, and 

operation phases of the project, and unanticipated incidents such as blowouts, spills, or fires and 

subsequent cleanup activities. There may also be adverse impacts to undiscovered cultural resources due 

to erosion and gullying resulting from development projects. Cumulative indirect effects typically occur 

from bringing more people into the region increasing the potential for disruption, destruction, or 

unauthorized collecting or looting of cultural resources. 

Cumulative impacts to cultural resources could also occur from direct and indirect impacts in the project 

area including removal, trampling, or dislocation of cultural resources and culturally sensitive areas by 

personnel and visitors, complete or partial destruction of a site from erosion, melting permafrost, 

vibrations, or other landscape changes caused by GMT2 Project components; and the loss of traditional 

meaning or importance of a resource or loss of cultural association with a resource.
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Past and present actions and events that have potentially affected cultural resources in the project area 

include historic and continued exploration and extraction of oil reserves, development of military sites for 

communications, scientific research and surveys, and recreation and tourism activities. Because of the 

potential existence of unidentified cultural resources, it is difficult to quantify the extent to which past and 

present activities have impacted cultural resources. While some cultural resources in these areas have 

undoubtedly been damaged, destroyed, or buried under gravel, most of these impacts have occurred 

outside the NPR-A (BLM 2012). However, the potential for cumulative impacts increases with increased 

ground-disturbing activities associated with construction, drilling, and operations and bringing more 

people into the region.

As noted by BLM (2012), from a cumulative perspective, more cultural sites have been disturbed and 

cultural material removed from the region as the result of scientific studies than have been destroyed or 

removed through unauthorized collection resulting from oil and gas exploration and development or other 

construction-related activities. While the scientific value and significance of the material that was 

obtained through scientific work is known, the value and significance of material lost through 

unauthorized collection or destruction will never be known. This is the greatest potential cumulative 

impact to cultural resources (BLM 2014).

New development, research, or other activities that may result from the proposed GMT2 Project increase 

the likelihood of future identification, disruption, or destruction of cultural resources. Therefore, the 

action alternatives, in combination with other oil and gas exploration or extraction, or any other proposed 

development in the GMT2 vicinity, have the potential to create cumulative effects on cultural resources. 

These include: destruction or possible disturbance of unidentified cultural resources via increased gravel 

mining, or other ground-disturbing activities; added noise or visual effects; fragmentation of some 

culturally important areas through reduction in access and changes in local resource availability, and 

increased access to other areas containing sensitive cultural sites. To reduce these impacts, measures can 

be taken to protect those resources that have been identified. While unidentified sites are susceptible to 

adverse effects in direct correlation to the extent of ground disturbance, number of construction activities, 

and people in the region, the GMT2 has a low likelihood of impacting unidentified resources because of 

the relatively low number of cultural resources documented in nearby areas.

Cumulative effects to known cultural resources are similar across the GMT2 alternatives, except for 

Alternative D which would have no incremental adverse cumulative effect to cultural resources in the 

region. Cumulative impacts to cultural resources would be low because (1) there are no historic 

properties, Alaska Heritage Resources Survey sites or Traditional Land Use Inventory sites within the 

GMT2 direct area of potential effect; (2) only three sites (Traditional Land Use Inventory HAR078, 

Traditional Land Use Inventory HAR079, and Traditional Land Use Inventory HAR103) are within the 

limits of the indirect area of potential effect; (3) of those sites within the indirect area of potential effect, 

temporary access, frozen conditions, and poor surface visibility will likely help protect these resources; 

and (4) impacts to the viewsheds and soundscapes of the two sites outside the 2.5-mile indirect impact 

boundary and within the 5-mile sound and viewshed boundary will be temporary. 

Impacts to the travel routes identified as circulation and land use features of the area identified in Nuiqsut 

Paisanich as the Nuiqsut Cultural Landscape would result in a detectable alteration, but these effects 

would be mitigated to some degree by proposed access points being provided by ConocoPhillips as part 

of the proposed action. Because of the generally unpredictable location and context of cultural resources, 

the magnitude of cumulative impact the resources is difficult to estimate. However, it is expected that if 

current procedures for survey and inventory before exploration and development activities continue, the 

impact to the resource would be minimal. Due to the variety of circumstances surrounding the location 

and character of cultural resources, the significance of potential future cumulative impacts to historic 

properties, Alaska Heritage Resources Survey sites, and Traditional Land Use Inventory sites is difficult 
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to assess; however, if the protections that are currently in place carry forward, then the cumulative 

impacts in the region would be expected to be minor.

Summary and Comparison of Alternatives

Impacts to cultural resources are similar across the action alternatives. There are no historic properties, 

Alaska Heritage Resources Survey sites, or Traditional Land Use Inventory sites known from the direct 

area of potential effect of Alternatives A, B, or C. 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 

for all alternatives, and these would experience a small degree of minor, local, temporary noise and visual 

impacts. Routes utilized by Nuiqsut residents to travel north and west of the community to Teshekpuk 

Lake, Smith Bay, Admiralty Bay and Utqiagvik (formerly Barrow), have been identified as features of the 

area identified as the Nuiqsut Cultural Landscape. Effects to these common elements of the cultural 

landscape from Alternatives A and B gravel road, ice road, and pipeline construction and maintenance, or 

Alternative C pipeline and ice-road construction and maintenance, could be mitigated in the same manner 

across alternatives by constructing and operating this infrastructure in a manner that allows local residents 

to cross the road/pipeline and continue to utilize these routes. No adverse effects or impacts to cultural 

resources are anticipated under Alternative D.

Overall, the current analysis resulted in a determination of “No Historic Properties Affected” (36 CFR 

800.4[d][1]) under Section 106 of the National Historic Preservation Act; and a NEPA finding of minor 

impacts to cultural resources. No known Alaska Heritage Resources Survey sites, Traditional Land Use 

Inventory sites, or historic properties are within the direct effects area of potential effect, and impacts to 

the three sites in the indirect area of potential effect are expected to be negligible. The low visual and low, 

temporary noise impacts to the two sites at the far northwestern boundary of the buffer area would not 

affect cultural or physical integrity of the sites, or alter their character, nature, or feeling in terms of 

NRHP criteria or NEPA considerations. Effects to the travel routes north and west of Nuiqsut proposed as 

features of the area identified as the Nuiqsut Cultural Landscape could be mitigated by constructing and 

operating the GMT2 Access Road and pipeline in a manner than enables Nuiqsut residents to continue to 

travel along these routes.

4.6.8.2 Sociocultural Systems

Overall impacts associated with the GMT2 Project and past, present, and reasonably foreseeable 

development to the sociocultural characteristics of North Slope communities other than Nuiqsut would 

occur. Those impacts are expected to be primarily economic and beneficial, because GMT2 would result 

in a substantially larger amount of money in the state-administered NPR-A Impact Fund. Development of 

GMT2 under Alternatives A and B would most likely increase the feasibility of the current State of Alaska 

proposal to construct a permanent road from Nuiqsut to Utqiagvik, and development of such a road would 

likely make other development prospects more feasible. (The proposed road is not considered a 

reasonably foreseeable future at the time of writing). It is not expected that impacts resulting from GMT2 

would be greater than those caused by technology, previous development, or climate change. Cumulative 

impacts to sociocultural systems are discussed in BLM (2004, Section 4G.7.1) and BLM (2012, Section

4.8.7.14). The analysis of the direct and indirect consequences of the GMT2 Project on sociocultural 

systems within the community of Nuiqsut found that all alternatives would likely have substantial, albeit 

varying, impacts. Nuiqsut would be likely to experience significant impacts to sociocultural systems 

because of the GMT2 Project and other past, present, and reasonably foreseeable exploration and 

development projects in the area. 

The cumulative impacts of past, current, and reasonably foreseeable future actions on subsistence are 

discussed below in Section 4.6.10.8, “Subsistence.” Subsistence activities are critical to maintaining 
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social ties within Inupiaq communities; substantial disruption to traditional hunting, harvesting, 

processing, distributing, and consuming Native food will also have impacts on social organization in the 

community.

Past and Present Impacts and Their Accumulation

Although North Slope Iñupiat have experienced the impacts of development on their social organization 

since their initial contact with non-Inupiaq explorers in the early 19th century, the cumulative impacts 

analysis is limited to events that have occurred since 1970. The cumulative impacts of oil and gas 

development on sociocultural patterns over the last 40 years are hard to establish with precision. There is 

evidence that North Slope systems have experienced both positive and negative ongoing, additive, and 

synergistic cumulative impacts from oil and gas activities. Today, the North Slope Borough receives 

approximately 98 percent of its tax revenues from oil and gas development, thus development has a 

substantial economic effect: no North Slope Borough community is considered an economically 

threatened community. 

Stresses on North Slope sociocultural systems include residents’ inability to access traditional use areas, 

threats to subsistence resources, concerns about public health, decreased spiritual connection with the 

land, tensions associated with participating in multiple permitting processes for development and 

associated public meetings, and inter- and intra-community conflict. Long-term stresses result in greater 

impacts to sociocultural systems. Ongoing sociocultural impacts that are directly related to nearby oil 

development are expected to be substantially more intense in Nuiqsut than in other North Slope Borough

communities. In other North Slope Borough communities, it is anticipated that the economic benefits that 

will accrue from GMT2 in combination with other past, present, and reasonably foreseeable future actions 

will outweigh any negative impacts these communities will experience. Depending on an individual or 

family’s particular value system and economic situation, the negative sociocultural impacts associated 

with development are likely to continue to match or outweigh the benefits of development in Nuiqsut. 

Future Impacts and Their Accumulation

Activities Not Associated with Oil and Gas Exploration and Development

Non-oil and gas activities on the North Slope since the 1970s with associated substantial sociocultural 

impacts include, but are not limited to, the passage of Alaska Native Claims Settlement Act, the formation 

of the North Slope Borough, the passage of Alaska National Interest Lands Conservation Act, and the 

transferal of the management of the NPR-A from the Navy to the BLM. Many of the prominent Boroughwide sociocultural issues are discussed in North Slope Borough Economic Profile and Census Reports 

and North Slope Borough Comprehensive Plans, which are periodically produced for each community 

and the Borough as a whole. The Economic Profile and Census Reports focus on changing dependency 

ratios (a concern because the dynamics of the North Slope population has increasing percentage of school 

age children and elders but fewer working age residents), housing (overcrowding and outmigration are 

issues in all communities), income, training and education, use of the Inupiaq language, health, and 

subsistence (North Slope Borough and CRA North Slope Borough, prepared by Circumpolar Research 

Associates Shepro [2016]).

For the comprehensive plans, each community identifies its top strengths, weaknesses, opportunities, and 

threats, which effectively illustrate many of the primary sociocultural issues. Responses from Nuiqsut’s 

Draft 2015 (North Slope Borough Planning 2015) comprehensive plan are:

Strengths:

• Unity of residents to work together to thrive as a community 
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• Leadership abilities and dedication by residents to participate in governance and protection of the 

health of residents and the environment

• Year-round, seasonal availability of subsistence resources of fish, whale, moose, caribou, seals, and 

berries

• Community commitment to the protection of subsistence hunting and lifestyle now and for 

generations to come

• Elder knowledge and the sharing of that knowledge with youth 

• The enduring family tree—each person knowing who they are in relation to other extended family 

members and valuing that connection

• Community gatherings

• Natural gas-generated electricity/inexpensive energy

• Education system 

• Job opportunities in the oil and gas industry for motivated people whose subsistence duties do not 

conflict with industry work schedules

• Water and sewer services 

• Whaling as a community effort 

Weaknesses: 

• Restricted access to traditional hunting grounds by nearby industry 

• Concern that air pollution from oil industry potentially contributes to asthma and respiratory 

infections in villagers, particularly young children

• Individual’s low motivation for jobs and career training, particularly for jobs in the oil and gas 

industry/inability of industry to cope with employee’s subsistence duties and schedules

• Need gravel for village public and private residents’ use, particularly for repair of damage due to road 

subsidence and driveway wear 

• Need new housing to relieve severe overcrowding

• Need a day care center to facilitate parents working/current proposed center is small/no outdoor play 

yard/who will run it? 

• Desire to eradicate drugs and alcohol use and abuse 

• High cost of living, particularly costly food and gas 

• Communication between elders and youth needs improvement 

• High drop-out rate by high school students/still needs improvement 

• Lack of understanding of how Borough funds are allocated between the villages and Utqiagvik 

(formerly Barrow) coupled with a desire to have a more equitable distribution of resources 

• Need local decision making on how Borough resources are allocated, rather than “top down” 

decisions 

• Helicopter activity within the subsistence area “spooks” the caribou and alters their migration patterns 

away from the village

• Need to extend water/sewer service to all residences 

• Septic tanks freeze due to lack of, or failure of, heat tracers 

• Need a washateria 

• Borough needs to hold contractors accountable for quality design, materials, and construction work 

(poor quality heating, sewers, and housing systems are examples)

• The village needs health assessments of its residents as a baseline as well as regular monitoring 

• Need apartment buildings 

• Need housing for all income levels, including working families whose income is above Department of 

Housing and Urban Development low-income criteria

• Need activities for kids

• Need year-round monitoring of spur road activities, particularly with regard to oil spills and damage 

to the adjacent environment by worker traffic
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• Need parking at Prudhoe for residents’ vehicles coming in on the ice road 

• Need to bring back DARE officers to the school 

• Need a school bus driver 

• Taguiugmiullu Nunamiullu Housing Authority housing construction jobs go to out of town people and 

not to local residents

• A need to provide indoor recreation for youth and adults 

Opportunities:

• Dredge the silted Puutu Channel to provide improved boat access to the Colville River and to produce 

gravel for village use 

• Build new Arctic climate energy-efficient homes in the south side of town

• Operate job training and offer a broader spectrum of educational opportunities 

• Operate a day care center

• Provide improved access to the Colville/Kuukpik River

• Provide cultural and recreational activities for youth and adults

• Improve interaction between elders and youth in the school

• Stand up against state and federal permitting agencies to prevent sport/trophy hunters within the 

village subsistence area 

• Stand up to state and federal permitting agencies to require mitigation for commercial and industrial 

development to assure the least possible impact to the community’s way of life 

• Establish a cost-effective dust control system 

• Provide a road to the Cross Island area to bring whale meat and muktuk to the village instead of 

flying it in and to bring whaling supplies to the island 

• Provide roads, power, water, sewer, and other utilities to shareholder lots to build new homes

• Native Village of Nuiqsut to get federal funds and knowledge to build new housing, similar to the 

housing in the Native Village of Utqiagvik (formerly Barrow)

• Provide boat and trailer access to the river

• Provide a shared system of boat trailers and trucks to haul boats to the river (for households who do 

not have those vehicles) 

• Improve runway with paving and other elements to assure emergency medical evacuations, if needed 

• Avoid multiple landing strips and air traffic by industry, which disturb subsistence resources and 

hunters, by having Nuiqsut airport serve as a regional airport

• Provide public parking at Prudhoe 

• Provide a natural gas filling station

Threats:

• Expensive gas/diesel fuel and resulting expensive food and airfare

• Alcohol, drugs, and smoking use and abuse 

• Climate change and its effects—stream bank erosion, subsidence, change in timing of subsistence 

wildlife, hazardous ice travel 

• Air pollution due to industry discharges (including from flaring gas) into the prevailing winds 

towards the village

• Reduced access to subsistence resources due to area oil and gas activities

• Oil and gas development too close to the village with the potential for an oil spill on water and land as 

well as greater air pollution

• Helicopter activity spooking the caribou and changing their migration routes out of reach of residents

• Off-shore oil and gas exploration could disrupt, disturb, or damage Cross Island whaling resources 

• Taguiugmiullu Nunamiullu Housing Authority housing construction jobs go to out of town people and 

not to local residents

• Contractors do not train and hire local residents and this becomes an endless cycle
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• The Borough “freeze” on the sale of gravel for private lots and driveways cause Fire and Health 

emergency personnel to be unable to access people in need 

• Since Alpine development, Borough Capital Improvement Program funds do not come to Nuiqsut any 

more 

• On the east side of the river oil companies will be building roads and residents will have to go 

through numerous “check points” to pass these roads to access subsistence resources 

• Oil company roads are too high for snow machines to pass and access to subsistence resources is 

blocked

• Sport hunters scare away caribou, particularly the vanguard herd 

• State and federal agencies limiting subsistence harvest (quotas and bans) resulting in uncertainty 

about the ability to hunt in the future

• Loss of State revenues result in worsening of enforcement of permits for environmental protection 

• Airport “hub”/expansion to accommodate large planes for industry may change the character of the 

village

Oil and Gas Exploration and Development Actions

The Greater Mooses Tooth Unit is located within the jurisdictions of several entities that have varying 

authorities on oil and gas development activities on lands within the unit. Entities include the BLM for 

federally managed land within the NPR-A (including both BLM-managed surface and subsurface, and 

land that has been selected by the Kuukpik Corporation but not yet conveyed), the North Slope Borough, 

the Kuukpik Corporation as a surface land owner, and Arctic Slope Regional Corporation as the owner of 

the subsurface rights under Kuukpik Corporation land. The GMT2 and other reasonably foreseeable 

future activities on the North Slope do not change the scope of authorities of these institutions, but may 

change where said authorities are applied if land and subsurface ownership are transferred to the two 

Native corporations. Cumulative impacts to sociocultural systems in Nuiqsut include tension between, on 

the one hand, all Nuiqsut entities and, on the other, all North Slope regional entities. For example, nearly 

every single village Tribe, corporation, and city on the North Slope has joined with the Voice of the Arctic 

Iñupiat, a non-profit organization for local advocacy and engagement on state, federal and international 

forums addressing Arctic issues, but none of the three Nuiqsut entities has joined the organization. 

With oil development in close proximity to Nuiqsut increasing in the future, cumulative sociocultural 

impacts directly related to it (including many described as direct and indirect impacts of GMT2 in Section

4.4.2 and listed above by the community as weaknesses and threats) are likely to increase. Any impacts to 

subsistence have strongly associated impacts to social bonds and community cohesion and resilience. 

Oil and gas-related reasonably foreseeable future activities that could affect social organizations on the 

North Slope include offshore oil and gas development activities, including the Liberty Project, the draft 

EIS for which identifies major potential impacts to Nuiqsut subsistence whaling at Cross Island. The 

already substantial tensions related to the permitting processes for Liberty will be exacerbated by the 

currently proposed federal plans to sell leases and quickly approve permit applications for all offshore 

drilling in the Arctic. 

Various and significant concerns about expanded offshore oil development will be additive with the 

numerous concerns over GMT2 and the cumulative effects of the reasonably foreseeable future oil 

development projects on land near Nuiqsut (see Section 4.6.10.8, “Subsistence,” below, for a complete list 

of current and reasonably foreseeable future oil exploration and development within 40 miles of Nuiqsut). 

The potential for additional development to the west of the community (Cassin, Willow), south of the 

community (Stony Hill, Horseshoe), and east of the community (Putu, Nanushuk, Qugruk), when 

considered with Alpine and the Alpine Satellites to the north/northwest and near-solid expanse of 

development from Kuparuk to Point Thompson on the east, has many Nuiqsut residents feeling 
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overwhelmed. It should be noted that many felt overwhelmed by the amount of development in close 

proximity to Nuiqsut years before many of these new reasonably foreseeable futures were considered. 

The North Slope Borough’s input on the cumulative impacts to sociocultural systems for Nuiqsut 

includes: 

Nuiqsut residents, more so than residents of other North Slope communities, and perhaps more so 

than any other Alaskan residents, have lived with a decades-long, ever-increasing, near constant 

level of frustration and apprehension as expanding oil and gas facilities and operations have 

impinged upon their traditional onshore and offshore subsistence harvest areas. The 

psychological toll of perpetually having to cope with increasing threats to the nutritional and 

cultural well-being of the community must be significant and should not be ignored in the EIS 

analysis (NSB 2018). 

[ ]

Despite the positive impacts of that development, the long lists of community weaknesses and 

threats identified by Nuiqsut residents illustrates a significant undercurrent of discontent over the 

relative apportionment between communities of the tangible benefits of the oil development that 

has expanded close to their town and within traditional harvest areas, over rising concerns and 

disagreement regarding any negative health impacts of that development, and over long-term 

food and cultural insecurity as further industrial expansion is projected. As noted in our general 

comments above, proponents of continued development within the vicinity of Nuiqsut must work 

together and with other interested stakeholders to avoid, minimize and mitigate impacts to the 

already-impacted community (NSB 2018).

The incremental construction of development-related infrastructure throughout the community of 

Nuiqsut’s traditional hunting and harvesting areas will likely result in the erosion of identify or cultural 

connection with those lands. This impact has already occurred with traditional use areas or camps within 

existing development areas that are no longer accessible to local residents.

The possibility of a major oil spill in the marine environment and its impacts on bowhead whales, other 

marine mammals, and fish are residents’ greatest concern associated with offshore oil and gas activity. 

Offshore development in the Beaufort Sea may require onshore processing facilities and would require 

onshore pipelines. 

These and other stresses accumulate because they interact and are repeated with each new lease sale, EIS, 

development proposal, and facility expansion. Income from royalties, taxes, and jobs, generated by oil 

and gas activity and available to residents of the North Slope, would be anticipated to offset many 

sociocultural concerns. Dominance by industrial infrastructure over the majority of the Nuiqsut cultural 

landscape would not be effectively offset by these economic benefits.

Contribution of the Alternatives to Cumulative Impacts

With the Nuiqsut Spur GMT1 roads and upcoming completion of the Colville River Access Road, 

residents of Nuiqsut will have facilitated access to subsistence areas and might be able to commute to 

work in the Alpine Field20. Under Alternatives A and B, these benefits would expand to the GMT2 site for 

employment and area for hunting. Concerns that development of the GMT Unit will deflect caribou and 

 20“ The majority of positions in the oil field typically require employees to stay on site during the entirety of their shifts. 

Commuting would not likely occur daily, but for these 2-3 weeks shifts.
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adversely impact Nuiqsut’s ability to harvest caribou remain. “It should also be noted that some hunters 

will voluntarily avoid the road because it is a non-traditional route” (NSB 2018).

The cumulative impacts of the past, present, and reasonably foreseeable future activities on economic 

organization are tied closely to cumulative impacts on subsistence. The community of Nuiqsut 

participates in a mixed subsistence-market economy. The increasing presence of development activities in 

and around the community may disrupt the economic organization of the community through changes in 

subsistence activities and participation in the cash economy. If subsistence activities or resources are 

disrupted to the extent that overall harvests of subsistence resources decline, then residents may begin to 

rely more heavily on wage employment and participate less in traditional subsistence activities. Research 

by Native Alaskan individuals and institutions has found that high levels of participation in subsistence 

and the accompanying celebration of the native way of life are the most promising efforts to decrease 

depression and suicide rates (Peter et al. 2016). 

As discussed in Sections 4.4.2, “Sociocultural Systems” and 4.4.5, “Subsistence,” disruption to Nuiqsut 

will be substantial under all action alternatives but would be particularly negative under Alternative C. 

Alternative C would preclude residents from commuting to work at GMT2 and would not provide 

facilitated access to the area for hunting. 

Alternative C would also result in a greater annual influx of outside workers to construct the additional 

ice roads that would be necessary. 

In terms of overall impacts, Alternatives A and B would have the least substantial impacts because they 

require smaller increases in regional air traffic and would have the largest footprint with a particularly 

active drill site, camp, and airstrip. 

Conclusion 

The GMT2 Project, in addition to past, present, and reasonably foreseeable future activities on the North 

Slope, is not expected to result in substantial changes to population or employment levels for the 

community of Nuiqsut. Increasing development activities on the North Slope, particularly those that occur 

in areas accessible from the community of Nuiqsut by road, may result in more residents obtaining 

employment in the oil and gas industry. 

As discussed in BLM (2012, Section 4.8.7.13–4.8.7.14), several effects of climate change are particularly 

significant in the western Arctic. These effects are exacerbating erosion rates and migration schedules for 

subsistence resources. A decreasing ability of residents to harvest resources at the appropriate times would 

be likely to create significant social anxiety for the Iñupiat. 

BLM (2012) found that the overall extent of expected cumulative impacts on sociocultural systems would 

vary depending on the alternative selected, but that no scenario was expected to result in overall impacts 

that would be more substantial than those caused by technology, other aspects of modernization, and 

climate change. The current supplemental EIS sociocultural systems analysis is focused on Nuiqsut and 

the potential impacts of GMT2. It finds that all the action alternatives are likely to result in a mixture of 

sociocultural benefits and adverse impacts. None of the numerous adverse impacts is considered 

significant in and of itself. Taken as a whole, the degree and intensity of the wide range of impacts are 

much more substantial. In the context of rapidly increasing development in close proximity to the 

community, those already substantial sociocultural impacts will likely be synergistic with similar impacts 

resulting from other projects. There would substantially higher degrees of negative sociocultural impacts 

associated with Alternative C. 
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Appropriate mitigation and performance-based lease stipulations and best management practices should 

reduce the cumulative effect to sociocultural systems in Nuiqsut from oil and gas activities, and non-oil 

and gas activities.

The North Slope Borough notes that the “BLM, lease holders and potential developers must acknowledge 

that continued industrial expansion in close proximity to Nuiqsut and within its traditional harvest areas 

cannot occur indefinitely. At some point, and perhaps this is that point, the cumulative impacts will be 

greater than the community can reasonably be expected to absorb. All possible measures must therefore 

be taken moving forward to collaborate with Nuiqsut as decisions regarding this project and future 

management of the area are made. Rather than simply relying on "appropriate mitigation and 

performance-based lease stipulations and best management practices," we suggest that it is time to 

develop new strategies that would provide for the long-term viability of Nuiqsut as a subsistence-based 

community, with its residents maintaining their health and cultural well-being” (NSB 2018).

4.6.8.3 Economy

BLM (2004) describes cumulative impacts to the economy as potential gains in direct employment, which 

would include additive jobs in petroleum exploration, development, and production, and oil spill cleanup 

activities (BLM 2004, Section 4G.7.2.1). Cumulative impacts are projected to generate additive 

employment and personal income increases for local, North Slope Borough, and state residents. 

Table 141 contains information concerning past, present and possible future oil and gas development in 

the cumulative analysis area. Overall cumulative economic impacts resulting from increased development 

on the North Slope would have benefits at state, regional, and local levels. Cumulative impacts to the 

economy are discussed more fully in BLM (2004, Section 4G.7.2; BLM 2012, Section 4.8.7.20). 

Past and Present Impacts and their Accumulation

The North Slope Borough has transformed to a mixed cash-subsistence economy. Particularly in the last 

40 years, residents have both benefited and grown accustomed to the result of modern capital 

development on the North Slope. In addition to the petroleum industry, the North Slope Borough has 

become a dominant economic organization on the North Slope. The North Slope Borough taxes the oil 

and gas facilities and uses the revenues to provide education and a wide array of other public services 

within its boundaries. Property taxes on oil and gas infrastructure provided over 82 percent of the total 

revenues received by the North Slope Borough in 2009 (BLM 2012, Section 4.8.7.20). 

Kuukpik Corporation collects revenues from their land ownership in several of the Alpine satellites (CD2, 

4 and 5) and enters into surface access agreements for use of Kuukpik land. Kuukpik Corporation owns 

surface lands within the project area, and Arctic Slope Regional Corporation owns the subsurface 

minerals. Development in the Alpine Field benefit these entities and royalties to Arctic Slope Regional 

Corporation from production of these fields would generate revenues for the corporation and its 

shareholders. Seventy percent of these petroleum royalties would be shared with the other Alaska Native 

regional corporations in accordance with section 7(i) of Alaska Native Claims Settlement Act.

Future Impacts and Their Accumulation

Activities Not Associated With Oil and Gas Exploration and Development

Continued recreational, research, and other activities are expected to largely follow historic economic 

patterns. Growth and development associated with villages and military sites are also expected to 

continue (BLM 2012, Section 4.8.7.20). 
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Oil and Gas Exploration and Development Activities

Events that would affect the economy of the North Slope Borough and the State of Alaska result from 

existing and future onshore and offshore oil and gas leasing and development, possibly assisted by the 

potential construction of a natural gas pipeline. Oil and gas exploration and development would occur on 

existing leases on State- and Native-owned lands east of the NPR-A, federal and Native-owned leases in 

the NPR-A, and federal and state leases in the Beaufort and Chukchi Seas. Future oil and gas lease sales 

with subsequent exploration and development may occur in the NPR-A, Chukchi Sea, Beaufort Sea, and 

lands east and west of the NPR-A. Construction of a natural gas pipeline is required to take North Slope 

gas to market, and would be important to the local and state economy. Economic impacts to the State, 

borough, and local economies are within the range analyzed in BLM (2012, Section 4.8.7.20). 

Kuukpik and Arctic Slope Regional Corporation might derive revenues from other reasonably foreseeable 

future oil and gas activities in the area as mentioned, and Arctic Slope Regional Corporation finances are 

affected by the oilfield services it provides. Proximity of NPR-A communities, particularly Nuiqsut, to 

development in and near the NPR-A might provide opportunities to those communities. Community 

businesses could provide goods and services, and residents might obtain work associated with

development activities. 

Revenues from exploration and development of oil and gas resources in the NPR-A and elsewhere on the 

North Slope have added economic stability to local communities. The cumulative economic impacts also 

apply at the local community level. Although smaller scale, the economic ramifications could result in an 

increase in employment, income and revenue that is long-term, but localized. Since communities in the 

NPR-A receive revenue from oil and gas through land ownerships used by industry, distribution of special 

funds unique to the NPR-A, and appropriations for a variety of services from the State government the 

economic impact could be substantial. There are a number of jobs in Nuiqsut that are technically North 

Slope Borough jobs but are paid for with NPR-A Impact funds from the State's share of revenues 

collected from federal development. Continuing or expanding those opportunities are dependent on NPRA royalty revenues. 

Contribution of the Alternatives to Cumulative Impacts

Production of oil from the GMT2 would, for a substantial period into the future, be a source of revenue to 

the North Slope Borough, which in turn, becomes part of the source of allocations to local communities. 

Production of oil resources from the GMT Unit under the cumulative case would be one of the sources of 

oil and tax revenues that would go to the North Slope Borough. For the purposes of this analysis, it is 

assumed that Alternatives A, B, and C would generate similar tax revenues. Alternative D would provide 

no additional revenue to the North Slope Borough since there would be no production from this project. 

Impacts to the State economy are based on the assumption that there are commercial quantities of 

recoverable oil and gas in the GMT Unit that would be extracted at the GMT1 and GMT2 sites. GMT2 

and GMT1 would go on line at different times; phased construction and production would extend the 

overall economic effect of the revenue stream to the State from the GMT Unit over time. The cumulative 

effect of production and a pipeline system to CD5 would have a beneficial effect on other undiscovered 

oil and gas resources in the GMT Unit by having road access into the GMT Unit under Alternatives A and 

B.

Conclusion

Overall cumulative economic impacts resulting from increased development on the North Slope would 

have benefits at state, regional, and local levels. 

Climate change could negatively affect the North Slope economy. Five of the 8 North Slope Borough 

communities are coastal, and Nuiqsut is located in the Colville River Delta, approximately 35 miles from 
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the Beaufort Sea. Violent storms, particularly those that occur during times of the year when there is no 

shore fast ice, and an increase in mean sea level may result in damage to infrastructure. Utqiagvik, for 

example, experiences frequent and severe coastal storms resulting in flooding and erosion that threaten 

public health and safety and over $1 billion of critical infrastructure.

4.6.8.4 Land Use

Cumulative impacts to land use from oil and gas exploration, development, and production in the NPR-A 

and across the North Slope will result in development of previously undisturbed areas and will change the 

character of land use. Cumulative impacts to land use in the project area are discussed more fully in BLM 

(2004a, Section 4G.7.6; 2014, Section 4.6.10.4).

Past and Present Impacts and Their Accumulation

Table 140 contains information concerning past, present and possible future oil and gas development. 

Lack of access in the NPR-A limits uses of these lands. The plan area considered in the Alpine Satellite 

Development Plan EIS (BLM 2004a), which includes GMT2, accounts for 890,000 acres of the 4.3-

million-acre plan area (or 21 percent). Of this, the Alpine Field Development accounts for approximately 

100 acres, and the Native Village of Nuiqsut accounts for 5,900 acres of development. The Nuiqsut Spur 

Road was constructed on Kuukpik Corporation lands and allows year-round access to the Alpine 

development area for increased subsistence use of the area, and increased employment opportunities for 

the Nuiqsut community. The remaining land is undeveloped, outside of subsistence-related camps and 

cabins and the Helmerick’s property in the northeast part of the Colville River Delta. North Slope Alaska 

Natives, particularly those in Nuiqsut, use the Alpine Satellite Development Plan Plan Area for 

subsistence hunting and gathering. Oil exploration and scientific research activities also occur in various 

locations.

Future Impacts and Their Accumulation

Activities Not Associated With Oil and Gas Exploration and Development

Future activities have the potential to impact land use including several non-oil and gas-related activities. 

Anticipated non-oil and gas activities include archaeological and paleontological excavations, scientific 

studies, recreational use, overland moves by transport vehicles, reclamation of former military or legacy 

well sites, expansion of existing communities, or the construction of new roadways. All of these activities 

would impact existing land use to some extent. Changes from additional future activities could be either 

positive or negative depending on location, ownership, and current uses.

Oil and Gas Exploration and Development Activities

The GMT Unit is located within the jurisdictions of several entities, which have varying authorities and 

perspectives on oil and gas development activities on lands within the unit. These include the BLM for 

federally managed land in the NPR-A (including land that has been selected by Kuukpik Corporation but 

not yet conveyed), the North Slope Borough, Kuukpik Corporation as a surface land owner, and Arctic 

Slope Regional Corporation as the owner of the subsurface rights under Kuukpik Corporation land and as 

a surface land owner. The GMT1, proposed GMT2 Project, and other reasonably foreseeable future

development activities on the North Slope do not change the scope of authorities of these institutions, but 

may change where said authorities are applied if land and subsurface federal ownerships are transferred to 

the two Native corporations. The combination of GMT1, the proposed GMT2 Project, and the proposed 

Bear Tooth Unit Development would not change existing land use of federally managed land in the NPRA, reflecting a Department of the Interior decision to issue oil and gas leases with an implied expectation 

by the lease holder that environmentally responsible development of discovered commercially 

recoverable oil and gas resources would be approved. The CD5–GMT1 Road involves an area selected by 
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the Kuukpik Corporation. Land owned by the Kuukpik Corporation is designated for a mixed use, which 

includes oil and gas production facility operations associated with Alpine. Until these lands are conveyed, 

The BLM manages all selected land in the same manner as federally managed land in the NPR-A. 

Overall, the cumulative impact to land use by construction of GMT1, Bear Tooth Unit Development, and 

the GMT2 under any of the action alternatives is not expected to change the land uses now in place (BLM 

2014, Section 4.6.10.4). Generally, the cumulative impacts of these developments would be similar and 

would not change existing land use.

The 2004 Alpine Satellite Development Plan EIS stated that additive cumulative impacts on land use, 

habitats, and subsistence on the North Slope would be expected to occur from current and future 

development and operation of energy, transportation, and utility facilities. BLM (2014) stated that the 

combination of GMT1 and the conceptual GMT2 Project would not change existing land use of federally 

managed land in the NPR-A. The continued development of previously undisturbed areas on the North 

Slope will change the character of land use and cause increases in noise and disturbance. Both documents 

(BLM 2004, 2014) found that most of the cumulative impacts from future development were expected to 

be localized to the development facilities.

Other reasonably foreseeable future projects considered in this document (i.e., Colville River Unit 

Drilling Expansion, Willow Exploration, Kuparuk River Unit Future Development, Ooguruk Unit 

Development, Pikka Unit Development, Seismic Exploration, Community of Nuiqsut facilities, and the 

continued use of the Arctic Slope Regional Corporation Mine site) would have an additive impact with 

respect to land use to the extent that development associated with reasonably foreseeable future projects 

may extend into areas which have not been set aside for oil and gas development.

Contribution of the Alternatives to Cumulative Impacts

Alternatives A and B were cited and designed to comply with all relevant lease stipulations, as well as 

most of BLM (2013a) best management practices governing surface uses. Alternative C may not have an 

adverse cumulative impact to the overall land ownership on the North Slope since land ownership is fixed 

by federal law. However, the location of unfilled land entitlements for the State and to Native 

corporations may move to other valid existing selections by the Kuukpik Corporation and Arctic Slope 

Regional Corporation within NPR-A. Selected land associated with GMT2 may not transfer from federal 

to private ownership because it is reasonable to conclude that most of these selections were based on 

prospective oil and gas development. The extent that existing valid selections by the Kuukpik Corporation 

and Arctic Slope Regional Corporation would or would not continue to patent is beyond the scope of this 

document.

Conclusion

Other related cumulative impacts to land use are discussed under Section 4.6.8.9, “Subsistence” and 

Section 4.6.8.5, “Recreation.”

4.6.8.5 Recreation

Cumulative impacts to recreation from oil and gas exploration, development, and production in the NPRA and across the North Slope would result from construction and operation of facilities and roadways 

resulting in decreased solitude and primitiveness and possible increased access to recreational 

opportunities. Cumulative impacts to recreation are discussed more fully in BLM (2004a, Section 4G.7.7; 

2012, Section 4.8.7.16).

Public recreational facilities in the GMT2 Project area are nonexistent and recreational opportunities in 

this area are a function of the natural setting. Primitive unconfined recreational opportunities (e.g.,

backpacking, sightseeing, and hunting) are possible, but access is limited due to the remote nature of the 
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area. Public recreation in the area is of low intensity and primarily limited to non-local visitors who float 

the Colville River between Umiat and Nuiqsut. 

Past and Present Impacts and Their Accumulation

BLM (2012, 2014) considered the effects of past and present non-oil and gas and oil and gas- related 

activities and their accumulation on recreation resources (BLM 2012, Section 4.8.7.16; BLM 2014,

Section 4.6.10.5) as described below.

Non-oil and gas activities would have minimal temporary or short-term impacts to recreation resources 

within the NPR-A. Temporary structures such as tents, vehicles such as Rolligons, and noise from 

generators, aircraft, human presence, and associated activities could have some minimal seasonal impacts 

on the setting, experiences, and desired beneficial outcome from use of public land. All of these identified 

non-oil and gas activities are transitory and seasonal, thus limiting the likelihood of recreationists 

encountering them in any given location.

The previous and current growth of communities around and within the GMT2 Project area may have a 

negligible impact on recreation resources through competition for resources on public lands. The past use 

of lands for military development and the adjacent active and inactive Air Force radar sites, do not take 

away from recreation opportunities.

Some past oil and gas exploration activity resulted in gravel pads and runways that remain today and can 

be beneficial for recreationists. Past oil and gas activities, including legacy wells, have left drums and 

other debris that would impact a recreationist for the duration that the items are visible.

Overall, the impacts to recreation resources and use from past and present activities are considered 

negligible. Past activities have left some mark on the land that can detract from the recreation experience 

however, evidence of past use is scattered and localized.

Future Impacts and Their Accumulation

Future impacts to recreation and recreational resources are anticipated from both non-oil and gas and oil 

and gas activities. Impacts could be both positive and negative.

Activities Not Associated With Oil and Gas Exploration and Development

After reclamation has taken place on past military development sites and legacy well locations, there may 

be remaining gravel runways and pads that could be used to access sites and to camp, which could benefit 

recreationists and other activities such as research. Nevertheless, this could lead to competition among 

user groups for this resource (BLM 2012, Section 4.8.7.16). Development of the Colville River Access 

Road could provide easier access for recreationalists in the GMT2 Project area if the road is open to the 

public. Future impacts could be both positive and negative.

Oil and Gas Exploration and Development Activities

The BLM considered impacts to recreation across the North Slope that may result from future oil and gas 

and related activities. Reasonably foreseeable future projects would have an additive cumulative impact 

on recreation resources in the NPR-A (BLM 2012, Section 4.8.7.16; BLM 2014, Section 4.6.10.5) it is 

assumed that impacts in the GMT2 Project area would be similar.

Of the proposed and reasonably foreseeable future projects, depending on the alternative selected, the 

CD5–GMT1 Road has potential to impact recreational opportunities in the cumulative impacts evaluation 

area, but any impact would be negligible (BLM 2014, Section 4.4.4.3). The construction of the CD5–

GMT1 Road would allow additional access to the project area, but could only be used by the local 
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population for subsistence activities. Thus, the potential impact to recreation overall is considered to be 

negligible.

Contribution of the Alternatives to Cumulative Impacts

Impacts to recreation during drilling and operations are considered to be minimal due to the lack of access 

and limited extent. Under Alternatives A and B, the construction of a new gravel road may increase 

recreational access to a larger area than is currently accessible via roadway. However, because road use 

would be limited to industrial traffic and travel by local residents, impacts to recreation are likely to be 

minimal. Alternative C would not provide additional opportunity for public access because a road would 

not be constructed and travel in and out of the associated airstrip would be limited to industry. Alternative 

D (no action) would result in no change from the current baseline conditions.

Conclusion

BLM (2004a) predicted that short-term impacts, such as green trails and disturbance from noise and other 

activities, would not accumulate. Impacts from long-term or permanent facilities such as roads, pipelines, 

and gravel pads would accumulate and would result in the long-term loss of solitude, quietude, 

naturalness, or primitive/unconfined recreation, and wilderness-type values. These impacts could be 

locally adverse (BLM 2004a, Section 4G.7.7). Alternative D (no action) would result in no change from 

the current baseline conditions.

As the climate warms in future years, the timing and location of recreation activities could change. For 

instance if wildlife distribution changes then both wildlife viewers and hunters would correspondently 

change the location that they recreate. Cumulatively there would be more activity, more human presence, 

increased noise, increased aircraft use, change in location of recreation activities, and correspondingly 

greater impacts on the setting, experiences, and desired beneficial outcome from use of public land. Also 

in the future as the climate gets warmer, the timing and location of recreation activities could change. The 

impacts to recreation associated with the proposed project are within the range of impacts considered by 

BLM (2012, Section 4.8.7.16).

4.6.8.6 Wilderness

The region of context for considering cumulative effects is the area of land from the Willow prospect area 

going east to Deadhorse containing the villages of Nuiqsut, Umiat, GMT1 and GMT2 Project areas. 

Continued development of oil and gas, and public utilities and infrastructure, over the next 50 to 100 

years could cause the entire project area to lose its wilderness characteristics as a result of dissecting the 

area into parcels smaller than 5,000 acres, or by reducing naturalness within the area significantly. Flat 

topography allows long sight distances where above ground structures and elevated roads or pads could 

be seen easily, thus reducing naturalness throughout the region. Best management practices could help to 

reduce visibility of disturbance and structures, potentially enlarging the size of interspersed lands 

maintaining wilderness characteristics.

4.6.8.7 Visual Resources

Cumulative impacts to visual resources from oil and gas exploration, development, and production in the 

NPR-A and across the North Slope would result from increased development resulting in changes to the 

character elements of form, line, color, and texture of the natural landscape. Cumulative impacts to visual 

resources in the project area are discussed more fully in BLM (2004a, Section 4G.7.8; BLM 2012, 

Section 4.8.7.19).

BLM (2012, Map 2-5) identifies the visual resources in the GMT2 Project area as being managed as a 

Class IV resource. The overall cumulative impact to visual resources in the area by production facilities, 
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elevated pipeline system, gravel road, and airports would be high (obvious disturbances to visual 

resources).

Past and Present Impacts and Their Accumulation

Past and present non-oil and gas-related activities, including archeological collection efforts, field camps, 

survey work, scientific research, recreation activities, film permits, and overland moves, are seasonal and 

generally limited with respect to size or scale, and therefore the casual observer has been minimally 

impacted. Landscape modifications from previous and current growth of communities around and within 

the NPR-A, the past use of lands for military development, and inactive Air Force Radar Sites have 

impacted visual resources or scenic quality, by creating a contrast to the landscape character elements of 

form, line, color, and texture of a primarily horizontal natural landscape. The colors of structures and 

equipment associated with non-oil and gas activities contrast with the white color of the snow-covered 

landscape and the various hues of greens and browns. 

Cabins and camp structures associated with subsistence activities can be found throughout the North 

Slope. These structures are usually isolated single-story small plywood cabins that produce some contrast 

with the surrounding landforms, but on a very local scale, along lakes, rivers, and creeks (BLM 2012, 

Section 4.8.7.19). The Nuiqsut Spur Road has changed the characteristic of the landscape and increased 

the local transportation network, allowing traffic to move between Nuiqsut and the Alpine Field.

Airstrips are located within the NPR-A, villages, oil and gas fields, and at Deadhorse. While the profile of 

an airstrip is low, landform changes are introduced by brown colors in predominantly green vegetation 

and more regular lines than the surrounding irregular vegetation (BLM 2012, Section 4.8.7.19). 

Winter overland moves, such as overland transportation of fuel and supplies to villages, and previous 

seismic activity can leave long lasting impacts to vegetation. The contrast has been minimal from ground 

view and almost nonexistent from more than a few hundred feet away. After 8 to 9 nine years, the 

evidence of use would be minimal (BLM 2012, Section 4.8.7.19).

Oil and gas activity prior to the 1998 lease sale left remnants (drums and other debris) of use on the 

landscape. As funding becomes available, the BLM has been plugging old wells, cleaning sites, and 

removing debris. However, debris not located at old well sites are scattered in the NPR-A. As the BLM 

encounters these items, GPS points are taken so that debris eventually may be able to be removed. The 

debris is a contrast to the landscape character elements of line, form, color, and texture of the landscape. 

Oil and gas activity since the 1999 lease sale has included requirements that leaseholders reclaim an area 

once they have completed their activity on the land. Some wells have been capped for future re-entry. 

However, they only occupy a minimal space on the landscape, approximately an imprint of 6 by 6 feet 

(BLM 2012, Section 4.8.7.19).

Future Impacts and Their Accumulation

Activities Not Associated With Oil and Gas Exploration and Development

Activities not associated with oil and gas exploration are anticipated to continue as they have in the past 

and associated impacts are expected to be similar to current impacts described above.

Of the non-oil and gas reasonably foreseeable future projects, the Colville River Access Road has the 

greatest potential cumulative impacts. The proposed Colville River Access Road would permanently 

change the characteristic of the landscape, introduce public access into a currently non-easily accessible 

area and increase the overall noise level. 
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Oil and Gas Exploration and Development Activities

BLM (2012) concludes the cumulative effect of oil and gas development on the visual resources of the 

North Slope generally would be limited to the foreground-middle ground zone of the viewer (BLM 2012, 

page 135). The GMT1 development, Arctic Slope Regional Corporation Mine site expansion, and the 

Bear Tooth Unit development, and reasonably foreseeable future projects are likely to have the greatest 

potential cumulative impacts. The GMT and Bear Tooth Unit developments would add facilities and 

structures (roads, airstrips, drill rigs) that would have a moderate impact to visual resources resulting in 

noticeable disturbances. The Arctic Slope Regional Corporation Mine site expansion would add a 

permanent impact to visual resources, but it would only slightly increase the impact of the current mine 

site on visual resources and would be minor. The proposed Pikka development would add facilities and 

structures that would have a moderate impact with noticeable disturbance to the visual resources northeast 

of Nuiqsut.

Contribution of the Alternatives to Cumulative Impacts

BLM (2004a) considered cumulative impacts to visual resources from the proposed Alpine development. 

Short-term impacts such as green trails would not accumulate, and would naturally recover. Impacts from 

long-term or permanent facilities such as roads, pipelines, gravel pads, and pits would accumulate and 

would result in the loss of scenic quality. Long-term impacts from future development with a possible life 

span of over 30 years would affect the visual resources for the North Slope. These impacts would be 

expected to be greatest within a 0.5-mile radius of each developed site. Pipelines could be elevated above 

ground level. Except during construction and repair of pipelines, there would be no associated on-theground activity. Therefore, long-term impacts to visual resources from pipelines would be expected to be 

minimal beyond approximately 0.5 mile (BLM 2004a, Section 4G.7.8).

Oil and gas activities, including the alternatives associated with the GMT2 Project, would result in 

changes to the existing undeveloped nature of the project area. During the construction phase, the primary 

negative impact to visual resources from the alternatives for GMT2 would result from the presence of 

drill rigs in the project area. During drilling and operations, pad facilities and communication towers 

would introduce a strong contrast to the natural landscape. The addition of gravel roads, pads, and airports 

as well as above-grade pipelines and bridges would also alter the existing visual landscape.

With all of the GMT2 action alternatives, there would be a cumulative adverse impact on visual resources 

within approximately 5 miles of proposed permanent facilities. Alternative C would eliminate the visual 

impact of a gravel road to the GMT2 pad in Alternative A and B, but would include an elevated pipeline. 

This would be counterbalanced by the establishment of a new airport and instrumentation. The impacts of 

new facilities would change the existing visual resources associated with the GMT2 Project. For new 

facilities, there would be noticeable impacts to visual resources that would be long-term in duration and 

likely to be visible up to 2.5 miles from the facilities. New facilities constructed adjacent to existing 

facilities or added to existing vertical support members would not change the existing visual character 

associated with existing oil and gas facilities. All three of the action alternatives are consistent with VRM 

Class IV land management objectives and would impact the visual resources moderately. Alternative D 

(no action) would result in no change from the current baseline conditions.

Conclusion

The overall cumulative impact to visual resources from production facilities, an elevated pipeline system, 

gravel roads, and airports would be high and result in an obvious disturbance. The GMT2 Project area is 

one characterized as low relief with very low vegetation cover, suggesting the cumulative effect to visual 

resources could extend over a mile on a clear day. Lights at permanent facilities would also be seen from 

a distance of several miles during winter (BLM 2014, Section 4.6.10.6). Alternative D (no action) would 

result in no change from the current baseline conditions.
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As development expands across the North Slope, primarily into areas where no infrastructure currently 

exists, so would the extent of impacts on visual resources. Climate change could affect visual resource 

values by altering the current conditions of color, vegetation, land formation, adjacent scenery, and the 

presence of water. The proposed project and reasonably foreseeable future projects, in conjunction with 

the GMT1 Project and the range of alternatives for the proposed GMT2, would have an additive 

cumulative negative impact, which would permanently alter the existing visual resources.

Although best management practices, lease stipulations, and mitigation measures would help blend 

structures and permanent facilities into their surroundings, the overall cumulative impact to visual 

resources in the immediate area of production facilities, elevated pipeline, gravel roads, and airports 

would be high and result in obvious changes to visual resources. The cumulative impacts from the 

currently proposed project are within the range analyzed in BLM (2012).

The implementation of lease stipulations and best management practices, required for the protection of 

visual resources under all alternatives, should reduce the cumulative effect to visual resources from oil 

and gas, and non-oil and gas activities.

4.6.8.8 Local Transportation

Cumulative impacts to local transportation from oil and gas exploration, development, and production in 

the NPR-A and across the North Slope would vary depending on whether new developments link into 

existing road systems or rely on roadless construction and are supported by air transportation. The 

cumulative impacts of new local transportation facilities in the Nuiqsut area would be intense and longterm and would have both localized and regional benefits. Cumulative impacts to local transportation in 

the project area are discussed more fully in BLM (2004a, Section 4G.7.9).

Past and Present Impacts and Their Accumulation

The GMT2 Project area has undergone significant changes with respect to local transportation since the 

1970s. The community of Nuiqsut was reestablished in 1973, and soon after, Trans-Alaska Pipeline 

System was built and production at Prudhoe Bay began. The reestablishment of the community, 

construction of the Nuiqsut Spur Road, and oil development in Prudhoe Bay and the GMT2 Project area

have included the development and construction of roads, airports and other supporting infrastructure in 

the previously undeveloped area. 

Future Impacts and Their Accumulation

Activities Not Associated With Oil and Gas Exploration and Development

The addition of the Colville River Road Access would complete a road connection providing year-around 

vehicle access to fish and wildlife resources along the Colville River and its delta, as well as to estuarine 

and marine resources along the coast. The cumulative impacts of new local transportation facilities in 

Nuiqsut area would be intense and long-term, and would have both localized and regional benefits.

Oil and Gas Exploration and Development Activities

The 2004 Alpine Satellite Development Plan Final EIS found that the proposed Alpine Field 

development, along with continued oil and gas development throughout the North Slope, would result in 

substantial increases in both road and air traffic levels, particularly on the central oil and gas 

transportation infrastructure in the Prudhoe Bay area. However, most of the transportation infrastructure 

on the North Slope is restricted to industry and local resident use, and operated well below capacity. 

Despite the substantial increase in activity levels, the existing infrastructure, combined with the proposed 

roads and airstrips serving remote facilities, was expected to be sufficient to accommodate these increased 
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demands for air and overland transportation. Therefore, BLM (2004a) did not anticipate any adverse 

cumulative impacts on transportation resources on the North Slope (BLM 2004a, Section 4G.7.9.1). The 

transportation impacts considered there are consistent with those for the currently proposed project.

The GMT1 project is increasing the transportation network from CD5 to GMT1 through the construction 

of the CD5-GMT1 gravel road. The 2014, the BLM found that the cumulative impacts of new 

transportation facilities would be intense and long-term, and would have both localized and regional 

benefits.

The cumulative impacts from Alternatives A and B would be similar to the GMT1 project impacts. The 

proposed road will provide year-around access to the GMT2 facility, although access on this road system 

will be limited to the local community. Other reasonably foreseeable future projects, such as the Pikka 

Unit and Bear Tooth Unit Developments, could have a synergistic cumulative effect to the extent that new 

offshore and onshore developments connect to project infrastructure expanding the local transportation 

network and providing access to subsistence resources.

Contribution of the Alternatives to Cumulative Impacts

All of the action alternatives would increase access to the general area around GMT2. The overall 

increase in permanent road access, under Alternatives A and B may be beneficial to future discoveries of 

commercially recoverable oil and gas resources in the GMT Unit depending on the location of the oil and 

gas resource. Having a gravel road system is likely beneficial to residents of Nuiqsut seeking access to 

traditional subsistence areas now limited to travel by off-road vehicle/snowmachine. Conversely, 

improved year around access may adversely impact the ability to harvest subsistence resources in the 

immediate area of the road and other facilities. 

Alternative C would increase air transportation in the Nuiqsut area, but would not likely provide any 

beneficial improvements for local residents. Alternatives A and B will link GMT2 to GMT1 and the 

proposed gravel road infrastructure of the Alpine Unit. Minor impacts to local transportation are expected, 

as most construction would take place on industry-constructed ice roads with no public impacts. These 

alternatives would have a minor impact over an interim duration (during construction only) on a regional 

basis. Alternative C would not include a road connection to GMT2 and would require construction of a 

new airport at the GMT2 pad. Alternative C would result in a large increase in aircraft traffic, which 

would occur for the entire duration of the proposed project. As such, Alternative C would have a moderate 

impact for a long duration on a regional basis. Alternative D (no action) would result in no change from 

the current baseline conditions.

Conclusion

The cumulative effect of GMT2 would be focused on the construction of an industrial gravel road system 

in an area currently roadless. For the GMT2 Project, impacts to local transportation would occur during 

both the construction and operation phase. In general, impacts to local transportation range from minor to 

moderate on an interim to long-term basis. Cumulative impacts could be either positive or negative based 

on the selected alternative.

The cumulative impacts of these new transportation facilities, as they provide opportunities for other 

reasonably foreseeable future projects to occur in the project area, would be intense and long-term, and 

would have both localized and regional benefits. Alternative D (no action) would result in no change from 

the current baseline conditions.

Potential impacts to transportation are mitigated by design, and operational features described in Section 

4.7. Adherence to lease stipulations and best management practices of BLM (2013a) will reduce the 

impacts and total area of disturbance; these include E-1, E-5, and F-1.
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4.6.8.9 Subsistence

Cumulative impacts would be direct and indirect impacts to subsistence use areas due to the construction 

of infrastructure leading to physically restricted access, and reduced access due to avoidance of 

infrastructure, air and ground traffic, security concerns, and resource availability. Cumulative impacts 

would likely include localized deflection or more broadly altered migration routes of caribou. Cumulative 

impacts to subsistence have been discussed in BLM (2004, Section 4G.7.3; 2012, Section 4.8.7.13; and 

2014 Section 4.6.10.8).

These previous analyses concluded that the cumulative impacts of current and reasonably foreseeable 

actions would likely be substantial and would restrict access. The 2014 analysis of the direct and indirect 

impacts of GMT1 concluded that the effects of that project in and of itself would likely be significant. The 

GMT1 road, pad, and pipelines were constructed (Year 1 of construction) in winter 2016–2017.

Past and Present Impacts and Their Accumulation

The community of Nuiqsut was reestablished in 1973. Soon after, the Trans-Alaska Pipeline System was 

built and production began at Prudhoe Bay, approximately 63 miles east of Nuiqsut. Since that time, oil 

and gas development has expanded both east and west, resulting in infrastructure and activities in 

traditional subsistence use areas that have effectively displaced subsistence camping, hunting, and fishing 

activities. The community of Nuiqsut’s traditional use area previously extended to the Prudhoe Bay area 

and several residents have native allotments along the coast between Nuiqsut and Prudhoe. 

Other activities, including primarily social change (globalization), modern transportation methods, the 

economy of the NSB and Nuiqsut, effects of climate change and, to a lesser degree, scientific research 

activities, have substantially affected Nuiqsut’s subsistence uses. 

Future Impacts and Their Accumulation

Activities Not Associated with Oil and Gas Exploration and Development

Future activities not associated with oil and gas exploration, production, and development, could have 

cumulative impacts on subsistence uses. One reasonably foreseeable project is the Colville River Access 

Road, which would facilitate residents’ access to the main channel of the Colville River. A potential 

impact of this road is that it could create a hunting corridor. Such changes have been documented in other 

rural communities where roads have been introduced, as described in BLM (2012, Section 4.8.7.13). In 

the case of the Colville River Access Road, facilitated access to hunting areas is an express purpose of the 

road. 

The impacts of increased street vehicle accessibility and use throughout the Kuukpikmiut’s traditional 

range by non-residents during the winter and shoulder months who are trying to travel between 

Deadhorse and communities to the west (primarily Utqiagvik but also Atqasuk) is a growing concern for 

Nuiqsut. The use of four-wheelers and other wheeled vehicles for subsistence can damage habitat and 

impact subsistence access to popular hunting areas: if trails become so damaged that they are rendered 

impassable, hunters may be prevented from traveling to an area or they may cause further damage by 

making new trails. With the exception of localized areas of concentrated use near oil field road ramps, 

these impacts to the tundra and subsistence access are not anticipated to exceed changes to the Arctic 

Coastal Plain that are anticipated to occur due to climate change.

Climate Change

BLM (2012, Section 4.8.7) concluded that the cumulative effects of climate change is likely more 

pronounced on the North Slope than elsewhere in Alaska and may include an increase in particulate 
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matter to the extend shallow lakes and ponds dry up or are smaller, watersheds would experience a 

change to drier soils, and thermokarsting may increase as ice-rich permafrost becomes unstable with 

increases in ambient surface temperatures. Lakeshore and coastal erosion, and changes to river bars and 

banks, has occurred across the Prudhoe Bay oilfield and west of the field. 

The effects of anticipated warming of the climate regime in the Arctic could significantly affect 

subsistence harvests and uses if warming trends continue as predicted (Arctic Climate Impact Assessment 

2004). The reduction, regulation, and/or loss of subsistence resources or reduced ability to access 

subsistence resources at appropriate times (Brinkman et al. 2016) would have severe impacts on the 

subsistence way of life for residents of NPR-A communities. If permafrost loss increases as predicted, 

there could be synergistic cumulative impacts on infrastructure, travel, landforms, sea ice, river 

navigability, habitat, availability of fresh water, and availability of terrestrial mammals, marine mammals, 

waterfowl and fish. These synergistic effects could necessitate relocating communities or their population, 

shifting the population to places with better subsistence hunting, and causing a loss or dispersal of 

community (National Research Council 2003; Arctic Climate Impact Assessment 2004).

According to the 2017 National Oceanic and Atmospheric Administration Arctic Report Card (RichterMenge, Overland et al. 2017), despite relatively cool recent summers, “there are many strong signals that 

continue to indicate that the Arctic environmental system has reached a ‘new normal’” characterized by 

Arctic air temperatures that are warming at double the rate of the global temperature increase. There are 

long-term losses in the extent and thickness of sea ice cover and warming sea surface and permafrost 

temperatures. Arctic tundra is experiencing increased greening and record permafrost warming. “The 

unprecedented rate and global reach of Arctic change disproportionally affect the people of northern 

communities, further pressing the need to prepare for and adapt to the new Arctic,” (ibid, p. 3). 

Nuiqsut community members have reported early spring thaws, shorter and warmer cold spells in winter, 

and abnormal wind patterns (Brubaker, Bell et al. 2014). Average monthly temperatures are expected to 

increase with the largest increases in the winter, precipitation is expected to increase significantly during 

summer, and there is an increased risk of some types of extreme weather. Residents have reported a 

longer boating season and a shorter season for ice travel, including difficulties traveling over ice to 

hunting locations. Shallow conditions throughout the river system are also reported which can interfere 

with travel, cause damage to engines, create hazards, and are raising concerns about fish migration (ibid, 

p. 20). Increased erosion effects sediment load, turbidity, and fish habitat. “Changes to the Colville River 

and its tributaries have implications for safe travel, subsistence, food security, and drinking water safety 

related to species that can carry waterborne pathogens,” (Brubaker, Bell et al. 2014 p. 21). Nuiqsut 

residents have also reported that climate change is threatening their food security because the ice cellars 

in which they store their meat are melting. 

Oil and Gas Exploration and Development Activities

Existing and currently proposed oil exploration and development projects within 40 miles of Nuiqsut 

include:

• The Kuparuk River Unit to the east:

o Three central processing facilities, seawater treatment plant, 47 11-acre pads with over 1,150 

wells, approximately 520 acres of surface development. Constructed 1979–1981, production 

is ongoing and more is planned. 

o Tabasco, accessed from drill site 2T, since 1998, 25 miles from Nuiqsut.

o Tarn/Drill sites 2L and 2N 1998, 17 miles from Nuiqsut.

o Meltwater/Drill Site 2P since 2001, 15 wells, 17 miles from Nuiqsut.
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o Palm/Drill Site 3S since 2002, 23 miles from Nuiqsut.

o Shark Tooth/Drill Site 2S, new gravel pad with up to 24 wells, new power lines and pipeline 

and 14 new wells drilled on existing pad, construction began 2014, currently in production, 

20 miles from Nuiqsut.

o West Sak/NE West Sak/Drill Site 1H expanded by 9 acres for 18 additional wells, drilling in 

third quarter of 2017, 35 miles from Nuiqsut.

• The Oooguruk Unit:

o Oooguruk, 6-acre gravel island with 40 wells, constructed 2007–2008, ongoing development 

drilling, 26 miles from Nuiqsut.

o Nuna, 2 onshore production pads, one constructed, associated roads and pipelines, 22 miles 

from Nuiqsut.

• The Placer Unit, 3 exploration wells drilled 2016, unspecified future development plans, 17 miles 

from Nuiqsut.

• The Southern Miluveach Unit/Mustang, exploratory well (development on hold), would include up to 

11 production wells, 20 re-injection wells, and operations camp, 17 miles from Nuiqsut. 

• The Nikaitchuq Unit/Eni Nikaitchuq, 2 drills pads, 52 planned wells. One pad onshore at Oliktok 

Point, one pad on an 11-acre artificial gravel island (Spy Island). Construction began 2008, 23 wells 

drilled to date, in production with further drilling planned 2017. 36 miles from Nuiqsut. 

• The Pikka Unit:

o Nanushuk, 3 drill pads with 78 wells, 1 operations pad and central processing facility, 25 

miles of gravel road, 288 acres of gravel fill, 12 miles from Nuiqsut.

o Qugruk, 3 exploratory wells drilled 2013, 18 miles from Nuiqsut. 

• Colville Delta Unit:

o Alpine CD1, CD2, central processing facility, airstrip, 3 miles gravel road, total surface 

development 97 acres, since 2000. Two drill pads with approximately 140 wells, connected to 

Kuparuk via 34-mile pipeline, 8 miles from Nuiqsut.

o Qannik, expansion of CD2 Drill Pad, 18 wells added 2007, 8 miles from Nuiqsut.

o Expansion of CD2 Drill Pad Winter scheduled for winter 2018, 42 wells will be added, 8 

miles from Nuiqsut

o Fjord/CD3, drill pad with airstrip, since 2006, 14 miles from Nuiqsut.

o Nanuq/CD4, drill pad with road since 2006, 5 miles from Nuiqsut.

o Fjord West/CD2, CD3, CD5 (reservoir accessed from 3 pads). 

o CD5 road, bridge, and pad constructed 2013-14, approximately 7 miles from Nuiqsut.

o Putu, exploratory well, exploration drilling occurred winter 2018-2019, approximately 5 

miles east of Nuiqsut.

• Greater Mooses Tooth Unit:

o GMT1, previously CD6, 12-acre pad, 33 wells will be drilled 2019-2022, 7.6 mile road from 

CD5, 12 miles from Nuiqsut. 

o Rendezvous exploratory wells, discovery wells for GMT2 drilled in 2000, 16 miles from 

Nuiqsut.
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o Willow/Tingmiaq, 2 exploratory wells drilled 2016, 3 exploratory wells drilled in winter 

2017-18, and possible appraisal wells in 2019.Estimated 300 million barrels of oil, 27 miles 

from Nuiqsut. Notice of Intent for Willow Master Development Plan is anticipated summer 

2018 and development is anticipated to begin in 2021.

• Bear Tooth Unit: 

o Cassein, 2 exploratory wells drilled in 2013, currently being evaluated for development 

potential. 

• Stony Hill (no unit), exploratory well drilled 2018, 7.5 miles SSW of Nuiqsut.

• Horseshoe (no unit), exploratory well drilled in 2017, unspecified plans for development, 12 miles 

from Nuiqsut.

• Arctic Slope Regional Corporation Gravel Mine, active with planned 300+ acre expansion beginning 

2018, 4.5 miles from Nuiqsut.

• Seismic exploration surveys will occur in multiple locations within 40 miles of Nuiqsut, including 

winter 2018–2019 with northern boundary of the survey block approximately 10 miles south of 

Nuiqsut.

The North Slope Borough maintains that the cumulative impacts of the Liberty Development Project

would “include a potentially reduced bowhead whale harvest paired with an ongoing constriction of 

previously utilized onshore traditional subsistence harvest areas and transportation routes, associated food 

security, impacts to sharing networks, added economic costs of longer and more distant hunting trips, 

extended time away from families and jobs and amplified community-wide stress” (NSB 2018).

Recently leased acreage within and near the NPR-A indicates the likely future progression of oil 

exploration and development on the western and southern sides of Nuiqsut. ConocoPhillips acquired an 

additional 594,972 acres in the NPR-A in the 2016 BLM lease sale and 142,280 acres of land on the east 

(non-NPR-A) side of the Colville River. Figure 42 below depicts acres leased in the NPR-A only. 
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Figure 42. ConocoPhillips’ leases in the NPR-A

The Willow MDP is a proposed project similar in scale to the original Alpine and Alpine Satellites 

Development Plan. The Willow MDP addresses an inter-related series of infrastructure components that 

could be constructed over an approximately 10-year period, including up to 5 drill sites, a central 

processing facility, an infrastructure pad, gravel access roads, an airstrip, module delivery via sealift 

barges via a temporary gravel island near Atigaru Point, pipelines, and a gravel mine. These components 

would be primarily in the Beartooth Unit, located about 7 miles west of the GMT2 well site, with 

supporting infrastructure in the Greater Mooses Tooth Unit, and on un-unitized lands within the NPR-A, 

Kuukpik Corporation Lands and State of Alaska land and waters.
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The cumulative impacts to caribou and their habitats from Willow would be the loss of habitat through 

placement of gravel to support the infrastructure and transportation system, including an estimated 37 

miles of new gravel access roads and over 100 miles of new pipelines. The total new surface disturbance 

due to the placement of gravel fill is estimated to be 410 acres for roads and pads, and 75 acres for the 

Willow Central Facility and airstrip. The location of many of the infrastructure components would be 

within the migration corridor of the Teshekpuk Caribou Herd. 

These activities, in combination with development of GMT2, are likely to increase problems between 

subsistence users and oil and gas activities. “The expansion of oil and gas development into traditional 

Nuiqsut lands has led to conflicts with traditional subsistence activities and a feeling among some 

residents that, as one individual put it, they are living in a ‘human corral’.” (SRB&A 2017f, page 12). 

Additional developments such as Willow would cause synergistic cumulative disturbances to subsistence

use areas and could contribute to localized deflection of caribou and other large land mammals from the 

area. The combination of these activities would result in the community of Nuiqsut being effectively 

surrounded by development. This will most likely pose difficulties for those hunters who prefer to avoid 

oil and gas infrastructure altogether. As noted above, the shifting of Nuiqsut subsistence use areas away 

from oil and gas infrastructure has been documented (Pedersen 1979; Research Foundation of the State 

University of New York 1984; Impact Assessment, Inc. 1990; Pedersen et al. 2000; SRB&A 2014; 

Nukapigak and Kuukpik Corporation 2016). Much of the research and conclusions related to harvester 

avoidance are based on pre-Alpine hunting patterns. While avoidance has continued to occur, and has 

been documented in the Caribou Subsistence Monitoring Project, it is important to note that as industry 

has moved closer to Nuiqsut, it has become more difficult for residents to avoid industry. Future research 

will reveal how harvesters respond when infrastructure is established closer to town or in their core 

hunting areas. Avoidance may be less of an option as fewer areas without development are present.

Although the area referred does not conform to the cumulative effects areas established for this analysis, a 

comment submitted on the Draft SEIS noted that statistics generated from the GMT1 Final SEIS and 

BLM lease sale data suggest that there are approximately 724,774 acres of leased lands within the NPR-A 

that are within Nuiqsut’s subsistence use area. Statistics generated from those sources, AK DNR data, and 

BOEM data, indicated that the total acreage of Nuiqsut subsistence area lands and waters that has been 

leased includes approximately 3 million acres (724,774 acres in the NPR-A, 1,581,213 acres of State of 

Alaska land, 302,575 acres in federal offshore waters, and 416,255 in State of Alaska offshore waters)

(Conservation Lands Foundation 2018).The GMT2 Project would contribute to those changes. 

Subsistence use of the GMT2 Access Road after its 2 to 3 year construction phase would likely present a 

countervailing impact in that it would facilitate access via road vehicle to the GMT2 area, although 

adverse impacts associated with the road are anticipated. 

Contribution of the Alternatives to Cumulative Impacts

Under Alternatives A, B, and C, Nuiqsut residents would experience direct impacts to subsistence use 

areas, particularly those used for caribou and furbearers (wolf and wolverine) but also for geese and fish. 

Direct impacts on the subsistence use area would be most intense during the 2 to 3 year construction 

period for all action alternatives, but particularly under Alternatives A and B because those alternatives 

would involve construction of linear components (i.e., permanent gravel road) that could physically block 

access to subsistence users until it is complete. During drilling and operation, direct impacts would be 

lowest during the summer months because many of the subsistence activities that occur in the GMT2 area 

peak in the late fall through early spring. User access would not be physically restricted by the pipelines 

except in areas of high snow drifting. User access will be facilitated for users who have permission and 

choose to travel on the GMT2 Access Road after construction. Tundra travel should not be physically 

blocked by the road because ramps will be constructed to facilitate crossing; however, hunters may have 

to travel farther or reroute in order to find or access a nearby ramp. User avoidance is expected to be the 
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primary impact related to user access because Nuiqsut hunters may avoid the GMT2 area due to 

disturbance from air and road traffic and drill pad activities and perceived or real reduced availability of 

resources. Subsistence use of the GMT2 Access Road may partly offset some of the possible negative 

impacts related to deflection of caribou and other resources and reduced resource availability. 

The cumulative impacts of Alternatives A and B would be similar because both of these alternatives could 

lead to future expansion of oil and gas exploration and development in other areas on the west side of the 

Colville River. Expansion would result in increased impacts on Nuiqsut subsistence use areas and could 

potentially introduce oil and gas development into areas used by other North Slope communities (i.e., 

Utqiagvik, Atqasuk). A continued shifting of Nuiqsut hunting to areas south along the Colville and its 

tributaries could affect Anaktuvuk Pass. Nuiqsut hunters’ use of the permanent road built under these 

alternatives and roads that would likely be built for any additional development projects on the west side 

of the Colville may partly offset some of the negative impacts. 

Alternative C would be less likely to facilitate westward oil and gas development. However, Alternative C 

would result in greater aircraft traffic in the GMT2 area, a larger direct impact due to the larger pad(s), 

and would not provide the potentially offsetting benefit of subsistence use of a permanent gravel road. 

In terms of overall subsistence impacts, Alternatives A and B would likely have fewer than Alternative C 

because these alternatives would result in a smaller increase in aircraft traffic and would include a road 

that subsistence hunters can use. Alternative C would result in greater impacts to subsistence because of 

the increased air traffic and no offsetting benefit of a road. For Alternatives A and B, high-intensity 

impacts to subsistence would be greatest during the 2 to 3 year construction period; impacts would be 

partly offset but not eliminated by facilitated access during drilling and operation. For Alternative C, 

impacts would likely be intense during construction and would continue to have high negative impacts to 

subsistence during drilling and operation due to larger pad(s), larger increases in air traffic, and lack of 

road access. 

BLM (2004) found that additive impacts that could affect subsistence resources include potential oil 

spills, seismic noise, road and air traffic disturbance, and disturbance from construction activities 

associated with ice roads, production facilities, pipelines, gravel mining, and supply efforts. Based on 

potential cumulative, long-term displacement and/or functional habitat loss, habitat available for caribou 

may be reduced, unavailable, or undesirable for use. Changes in population distribution due to the 

presence of oil field facilities or activities may affect availability for subsistence harvest in traditional 

subsistence use areas. Overall, impacts to subsistence harvest and use may have synergistic impact with 

community health, welfare, and social structure. To the extent that subsistence hunting success is reduced 

in traditional use areas near Nuiqsut, hunters may need to travel further, to unfamiliar areas, or make more 

frequent trips to harvest sufficient resources in order to meet community needs. This could result in 

greater time spent away from the community for some and competition for resources with other 

communities. The changes in subsistence patterns may result in stress within households, family groups, 

and the community.

Conclusion

Overall, the GMT2 Project in addition to other current and reasonably foreseeable activities could 

increase the severity of existing impacts on Nuiqsut subsistence uses in addition to introducing impacts on 

subsistence uses for other North Slope communities. These impacts include continued hunter avoidance 

of industrial areas, continued disturbance of hunters and wildlife from increased air and road traffic, 

reduced access to or loss of subsistence use areas, and reduced availability of subsistence resources in 

development areas. In addition, if displacement of subsistence resources occurs in Nuiqsut subsistence 

use areas, hunters may travel farther west to access hunting grounds, increasing the potential for 
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competition between hunters from different communities. These impacts could result in increased 

investments in time, money, fuel, and equipment and potentially affect hunting success. 

The GMT2 Project would introduce industrial infrastructure and activity into subsistence use areas 

west/southwest of the community, reducing the area in which residents can hunt and fish without the 

presence of nearby industrial infrastructure to only the area south of town. As oil and gas activities occur 

over a larger area and affect a greater portion of subsistence use areas, North Slope subsistence users may 

alter their harvesting patterns. This could potentially result in a loss of opportunities to harvest subsistence 

resources in traditional use areas. This loss of opportunity could have impacts on future generations, 

because harvesters will no longer be able to teach future generations about subsistence uses in traditional 

harvesting areas. 

The implementation of Lease Stipulations, best management practices, and potential new mitigation 

measures required for the protection of subsistence resources under all alternatives should reduce the 

cumulative effect to subsistence resources from oil and gas and non-oil and gas activities in the planning 

area.

4.6.8.10 Public Health

Impacts to public health under the GMT2 action alternatives include: no impacts to water and sanitation 

and infectious disease; low impacts to specific health issues related to accidents and injuries; food, 

nutrition, and subsistence; and non-communicable chronic diseases; medium impacts as a result of 

exposure to hazardous materials (i.e., air quality emissions) and social determinants of health (i.e., 

depression, anxiety and resulting social ills); and high positive impacts to public health as a result of 

increased access to health care and facilities. Potential contributing factors to negative health under the 

proposed project could include hunters and animals being diverted, noise from increased air traffic, 

increased travel time and costs for subsistence, and poor air quality episodes. Cumulative impacts to 

public health are discussed more fully in BLM (2012, Section 4.8.7.21).

Past and Present Impacts and Their Accumulation

The 2012 Integrated Activity Plan/EIS public health cumulative effects analysis (BLM 2012, Section

4.8.7.21) described both positive and negative health impacts for North Slope residents due to changes 

that have occurred in the last 50 to 100 years, as well as reasonably foreseeable future actions such as oil 

and gas exploration and development, scientific research activities, mining projects, military 

developments and activities, transportation plans, community development projects, and recreation and 

tourism activities. As stated in the analysis, rapid modernization has led to significant changes in diet, 

housing, employment, and traditional culture. This has led to positive health changes including an 

increase in life expectancy, a decrease in infant mortality and infectious disease rates, improved health 

care services, public health programs, and municipal health infrastructure such as sanitation and water 

treatment facilities. 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 dysfunction. 

The pattern of oil and gas development that has taken place in and near the NPR-A, combined with the 

area’s unique culture and geography, has led to the creation of certain health concerns that are of 

particular importance. These health concerns represent areas of vulnerability whereby further oil and gasrelated development may have a disproportionate impact on health and safety, and include: injury and 

trauma, which may be linked to the adaptation by hunters to travel further away from development to 

conduct subsistence activities; increases in social pathologies such as alcohol and drug misuse, social 

dysfunction and violence, in part due to increased opportunities to import alcohol and drugs; and health 

disparities due to the uneven distribution of the rewards and risks of development. 
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Future Impacts and Their Accumulation

Activities Not Associated With Oil and Gas Exploration and Development

Future non-oil and gas activities that could impact public health include scientific research activities, 

mining projects, military developments and activities, transportation plans, community development 

projects, and recreation and tourism activities. The common components of these future actions that are 

most likely to drive public health and safety outcomes were evaluated in BLM (2012, Section 4.8.7.21): 

potential growth in population in the communities in the project study area; in-migration of workers, 

visitors, or temporary residents not originally from the area; economic changes at the level of both 

individual residents and the Native corporations; changes in the level or success of subsistence activities; 

changes to public infrastructure; potential exposure to environmental contaminants; changes in access to 

or use of the land; continued acculturation of the Iñupiat people and alteration of sociocultural traditions. 

As the reasonably foreseeable future actions continue the path and progress of development seen in the 

past, it can be expected that the changes in public health and safety outcomes will follow the same trends 

that have been observed in recent years as described above. 

Nearby Pending Development

Impacts to human health associated with the Willow, Nanushuk, and Liberty Development Projects would 

be similar to those under the range of action alternatives for the GMT2 Project, specifically those impacts 

that could be attributed to changes in subsistence harvest and availability of resources, and social and 

cultural impacts that lead to greater overall stress and anxiety for community residents. Development of 

Nanushuk and Liberty would have additional negative impacts with respect to public health. The 

additional Nanushuk development to the east would likely have an additive impact with respect to 

diverting animals and hunters away from infrastructure, and an increased amount of air emissions 

(including from the Nanushuk processing facility) and potential for spills. Further, the increased gravel 

required to construct Nanushuk is currently proposed to come from the Arctic Slope Regional Corporation

Mine site, resulting in increasing noise and stress from blasting, and potentially affecting air quality due 

to fugitive dust. Personnel needed during the construction phase could also be an additive strain on 

existing medical care and emergency services. Potential impacts from the Liberty Project center around 

impacts to subsistence whaling and sea mammal hunting by the community of Nuiqsut. Currently, 

Nuiqsut harvests resources from the land, rivers, and lakes, and the ocean when they are available. Much 

like any predominantly subsistence community, subsistence users can adapt to small changes in one 

resource (such as fish), by harvesting more of another (such as caribou). However, should one resource be 

majorly disproportionately affected, such as failing to harvest any bowhead whale, in conjunction with a 

poor fish or caribou harvest, there would be synergistic impacts to subsistence. As with the GMT2 

Project, these impacts would be greatest during the construction phase and would be reduced once 

operations are underway. The greatest potential impact during the operational period of either project 

would be the potential for a large-scale oil spill or other catastrophic industrial disaster. 

Oil and Gas Exploration and Foreseeable Development Activities 

The pattern of development and modernization that has taken place in and near NPR-A combined with the 

area’s unique culture and geography has led to the creation of certain health areas that are of particular 

importance. These areas include injury and trauma, social pathologies such as alcohol and drug misuse, 

social dysfunction and violence, and health disparities within the population.

New development tying into existing infrastructure to the west of the NPR-A could exacerbate some of 

these impacts. The potential extension of seasonal or permanent roads into the northeast of the NPR-A 

might compound issues of conflict and smuggling in Nuiqsut and other North Slope Borough 

communities. Air and water quality across the region are currently good. Local impacts due to site-
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specific activity are possible, but will depend on the characteristics of individual site plans and the 

presence of exposed villages or camps. More widespread development will result in a greater number of 

individuals on the land or in camps being exposed to local air, and possibly water, exposures. Any road or 

pipeline that is proposed in a primarily east-to-west linear route, such as one from the Smith Bay area to 

existing infrastructure, will be of primary concerns in terms of the availability of Teshekpuk Lake 

Caribou. Likewise, additional exploration leading to future development within the Greater Mooses Tooth 

Unit (i.e., Willow Discovery) will have the potential to further displace caribou away from Nuiqsut, 

resulting in indirect negative health effects.

Additional public health and safety considerations include the potential for offshore oil and gas 

exploration, development and production. A ramp-up of offshore development may lead to potentially 

substantive changes in public health outcomes via three pathways: (1) the displacement of marine 

mammals and the subsequent reduction of success and safety of subsistence marine hunting; (2) the 

potential for contamination and the fear of contamination through oil spills or routine discharge; and (3) 

substantially increased economic returns to the North Slope Borough, village corporations and individuals 

with resulting positive and negative health impacts and disparities (BLM 2012, Section 4.8.7.21). The 

direct and indirect employment resulting from oil and gas exploration and development combined with 

the government and Native corporation revenues are all major contributors to the positive health changes 

in the North Slope Borough over the last few decades. 

Contribution of the Alternatives to Cumulative Impacts

Under all of the action alternatives, an increase in workers could impact the local community with respect 

to availability of medical care and emergency services. Impacts under all of the action alternatives are 

expected to be similar, with a few notable exceptions, discussed below. Alternative C, which does not 

include the construction of a GMT1–GMT2 Access Road, would have the least impact of any of the 

action alternatives in terms of potential impacts related to perception of food contamination and 

avoidance of infrastructure at subsistence sites. Alternative C would cause none of the impacts associated 

with the presences of a road (dust, emissions, noise, accidents) between GMT1–GMT2, but would 

increase the traffic, emissions, noise, and other public health issues associated with annual ice road 

construction and would have comparable impacts resulting from gravel extraction as the Arctic Slope 

Regional Corporation Mine site. Due to the lack of a year-round access road, Alternative C would have 

greater impacts on public health concerns related to environmental security (e.g., oil spill response, 

evacuation routes, air pollution). Alternative D (no action) would result in no change from the current 

baseline conditions.

Conclusion

When evaluating the currently proposed project in conjunction with the conceptual Nanushuk, Liberty,

and other reasonably foreseeable future projects, these projects could have an additive cumulative effect, 

generating potentially substantive changes, with respect to public health as described above and in BLM 

(2012, Section 4.8.7.21). The community of Nuiqsut will be most impacted by the proposed and 

conceptual projects and affected by other reasonably foreseeable future projects in the area. The 

cumulative impacts of increased development to the east, west, and north of Nuiqsut; exploration of the 

Greater Mooses Tooth Unit, Bear Tooth Unit, and on Kuukpik Corporation and State of Alaska lands may 

have synergistic effects with respect to disturbance of animals. This may result in changes to traditional 

hunting grounds and may require further energy (time and travel costs) to reach these resources. Other 

reasonably foreseeable future developments are not likely to have a direct impact on the availability of 

local emergency services.

Uncertainty over the impact of climate change on subsistence resources and related traditional lifestyles 

and culture is a cause of concern among Iñupiat hunters and community members. Climate change may 
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also result in increased injury and trauma, as unusual or unpredictable weather, water, snow and ice 

conditions make travel more hazardous and people may travel greater distances to find marine or land 

mammals or edible plants.

4.6.8.11 Environmental Justice

The analysis of impacts related to environmental justice considers if implementation of one of the 

proposed alternatives would result in disproportionately high and adverse environmental effects to the 

minority community of Nuiqsut. Environmental justice analyses weigh the benefits of a proposed project 

(e.g., increased economic activity or access) on the minority community, which may offset the adverse 

environmental effects from construction, drilling, or operation. The potentially affected resource in the 

environmental justice analysis is the community of Nuiqsut. The duration of effects under all the action 

alternatives would be long-term.

Effects to subsistence comprise direct effects to the Iñupiat, a recognized minority population and the 

primary subsistence harvesters on the North Slope. Impacts from GMT2 to human health and well-being, 

social systems, and cultural values of the Iñupiat would cumulatively lead to disproportionate effects on 

this minority population.

Cumulative impacts to environmental justice are discussed more fully in BLM (2004, Section 4G.7.4;

BLM 2012, Section 4.8.7.15; and BLM 2014, Section 4.6.10.10).

Past and Present Effects and Their Accumulation

Sustained contact with Euro-Americans and oil exploration and development conducted by the federal 

government and industry have directly impacted the habitat use and behavior of subsistence species and 

resulted in additive impacts on subsistence resources, harvest patterns, and users. In addition, 

development associated with villages on the North Slope has impacted subsistence resources. These 

activities cumulatively resulted in the loss of approximately 2,500 acres of habitat for subsistence species. 

These effects have disrupted subsistence livelihoods and account for some of the social problems seen in 

Iñupiaq villages today. The economic benefits that North Slope Borough communities have accrued due 

to oil revenues have greatly helped to ameliorate social problems, although dependence on an 

undiversified economy based on the extraction of natural resources creates other anxieties. Climate 

change impacts to date have caused social anxiety and climate change is increasingly understood as an 

environmental justice issue (BLM 2012, Section 4.8.7.15).

Future Effects and Their Accumulation

Activities Not Associated With Oil and Gas Exploration and Development

Non-oil and gas activities on the North Slope, including archaeological and paleontological digs, camps 

and aircraft traffic associated with scientific studies, recreational use, and overland moves by transport 

vehicles, would continue to disturb Iñupiaq subsistence resources and cause users to avoid hunting in 

such areas while these activities are underway. Contaminated sites that persist can have long-term effects 

that constitute environmental justice issues. The BLM anticipates that several existing military sites will 

undergo remediation efforts in the next decade. Cleanup projects could potentially have short-term effects 

(a “plume” created by clean-up activities) that could include a temporary increased potential for 

contamination of subsistence species, particularly fish, in the area around the cleanup site (BLM 2012, 

Section 4.8.7.15).

Military sites, villages, airstrips, and other non-oil and gas infrastructure are likely to persist into the 

indefinite future. The amount of area that would be disturbed by new development on the North Slope in 

villages and other public facilities is projected to double to approximately 3,600 acres by 2050 and then 
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level off for the remainder of the 21st century. However, a housing shortage and out-migration from North 

Slope villages is a concern in the North Slope Borough. The effects of climate change are expected to 

become more significant in the future and it is likely that Iñupiaq communities will bear a 

disproportionate burden of those effects (BLM 2012, Section 4.8.7.15).

Oil and Gas Exploration and Development Activities 

BLM (2012) evaluated the cumulative impacts of oil and gas activities to environmental justice in the 

NPR-A. That evaluation considered impacts associated with the then-proposed Umiat Road/Pipeline, 

offshore development in the Chukchi and Beaufort Seas, commercial oil and gas pipelines, and 

conventional oil and gas exploration and development. BLM (2014) considered cumulative impacts more 

specific to the community of Nuiqsut, as does this analysis. 

Disturbance of caribou and other subsistence resources caused by additional development would 

accumulate with impacts from existing disturbances. Oil and gas activities near the project area have 

already deterred subsistence hunters from using traditional hunting, fishing, and camping sites. Continued 

expansion of activity and infrastructure near the project area will increase the area considered less 

desirable by resource users, could deflect or divert important subsistence resources from their normal 

routes, and require users to travel further to harvest subsistence foods at a greater cost in terms of time, 

fuel, wear and tear on equipment and people, and lost wages

Impacts to Nuiqsut’s subsistence resources and use areas from future oil and gas activities are expected to 

be additive with respect to impacts from other past, present, and future non-oil and gas activities and past 

and present oil and gas activities. The number and proximity of current and reasonably foreseeable future

oil exploration and development projects within 40 miles of Nuiqsut (listed in the cumulative effects to 

subsistence analysis above, Section 4.6.10.8) is substantially greater now than it has been for previous 

cumulative effects analyses. These projects in the Nuiqsut region will increase the total level of 

disturbance and the amount of subsistence use areas impacted by oil and gas development. 

Contribution of the Alternatives to Cumulative Effects

The cumulative impacts of Alternatives A and B would be similar, in that each of these alternatives could 

lead to future expansion of oil and gas exploration to the west of the Colville River. Specifically, 

development of the Willow prospect is dependent on construction of GMT2 with a road. Expansion 

further to the west of the Colville River would result in increased impacts on Nuiqsut subsistence use 

areas, particularly those along Fish Creek, and could potentially introduce oil and gas development into 

areas used by other North Slope communities such as Utqiagvik (formerly Barrow) and Atqasuk. A

possible difference in the economic and thus sociocultural impact of Alternative B is that the road would 

not be located on Kuukpik Corporation land, thus the corporation might not receive as much in surface 

use rental payments21. Economic benefits of oil development are the primary countervailing impact for 

residents of the North Slope and Nuiqsut. 

Alternative C, the roadless alternative, would be less likely to facilitate westward oil and gas 

development. However, this alternative would create a greater increase in aircraft traffic in areas used by 

Nuiqsut subsistence users. In Nuiqsut, disturbance from helicopter traffic is the most frequently reported 

impact associated with oil and gas development (Stephen R. Braund and Associates 2017a); Alternative C 

would contribute a greater amount to the cumulative impacts of helicopter traffic. 

Overall, impacts to the minority community resulting from GMT2 Alternatives A, B, and C are expected 

to be long-term. Under Alternatives A and B, the improved permanent access to subsistence use areas is 

expected to have a long-term, offsetting effect for many residents of Nuiqsut while diminishing the value 

 21 The BLM has no detailed information on Kuukpik’s revenue and potential future revenue sources.
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of the area for others. Alternative C would result in greater increases of aircraft noise in the project study 

area and would not include the mixed effects of the road.

Conclusion

The finding of the Alaska National Interest Lands Conservation Act Section 810 analysis for the proposed 

project under all action alternatives is that development of the GMT2 Project may significant restrict 

subsistence use for the community of Nuiqsut due to the potential for the project to result in localized 

deflection of caribou from areas where they are traditionally harvested.

BLM (2004, 2013, 2014) found that development as contemplated in the cumulative case could cause 

long-term displacement and/or functional loss of habitat to caribou over the life of the proposed 

development. This could result in a significant impact on this important subsistence resource. Impacts 

would be considered as having disproportionately high adverse effects on Alaska Natives. Access to 

subsistence-hunting areas and subsistence resources, and the use of subsistence resources, could change if 

oil development were to reduce the availability of resources or alter their distribution patterns. Potential 

spill impacts would also have disproportionately high adverse effects on Alaskan Natives (BLM 2004, 

Section 4G.7.4). 

Climate change can be understood as an environmental justice issue and the Iñupiaq of the North Slope 

are disproportionately impacted by it both by the fact that climate changes effects are more pronounced in 

the western Arctic and by the fact that Iñupiaq subsistence activities are particularly dependent on ice, 

wind, and permafrost conditions. Climate change is perceived as causing changes to the environment of 

the North Slope is affecting subsistence users’ ability to access subsistence resources at appropriate times 

(Brinkman et al. 2016). The reduction of sea ice has exacerbated coastal erosion, the weather has become 

less predictable, the shore ice in spring is less stable for whaling, fall travel for caribou is hampered by a 

late and unreliable freeze up, spring hunting for geese is hampered by an early breakup, ice cellars 

provide less reliable food storage. All of these issues create significant concerns for many Iñupiat because 

they are perceived as factors that cannot be controlled and that are threatening their way of life. 

In evaluating GMT2 and other current and reasonably foreseeable future activities, the cumulative 

impacts to the community of Nuiqsut would likely be additive to the extent that other current and 

reasonably foreseeable future developments within the cumulative effects evaluation area could deflect or 

divert subsistence resources further away from the community. The development of other reasonably 

foreseeable future projects would also increase the footprint of development into currently undeveloped 

areas, which would have further reaching effects. Reasonably foreseeable future projects, outside of the 

GMT2 Project, would not be countervailing because they are not connected to the local transportation 

network.

Overall, the GMT2 Project in addition to other current and reasonably foreseeable future activities will 

increase the severity of existing impacts on Nuiqsut. Most relevantly, the proposed Nanushuk project on 

the east side of the community could result in major impacts to subsistence because of impacts to caribou 

hunting areas, according to the Corps of Engineers’ Draft EIS (U.S. Army Corps of Engineers 2017). As 

oil and gas development activities occur over a larger area and/or in closer proximity to Nuiqsut, direct 

effects to the Inupiaq residents of Nuiqsut will likely be significant and have long-term effects. 

Alternative D would likely have incremental adverse cumulative economic impacts to environmental 

justice on the North Slope.

The implementation of lease stipulations, best management practices, and other mitigation outlined in the 

records of decision for the 2013 NPR-A Integrated Activity Plan/EIS (BLM 2013) and the 2014 GMT1 

Supplemental EIS (BLM 2014), designed to ensure the continued health of subsistence resources and 

wildlife, in addition to Lease Stipulation H-1, required for the protection of environmental justice under 
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all alternatives, should reduce the cumulative effect to environmental justice from oil and gas activities 

and non-oil and gas activities in the planning area.

4.6.9 Cumulative Impacts of Oil, Saltwater and Hazardous Materials 

Spills

This section tiers to the GMT1 Supplemental EIS (BLM 2014, Section 4.6.11) and the NPR-A Integrated 

Activity Plan EIS (BLM 2012, Sections 4.8 and 4.12). Section 4.5 of this document describes the 

potential impacts of spills associated with the GMT2 Project. The BLM selected the time frame from 

1940s through 2100 for evaluating cumulative impacts of spills (Table 139) to capture all projects whose 

impacts have the potential to overlap with the impacts of GMT2.

The majority of spills on the North Slope have been less than 100 gallons, primarily occurring within 

secondary containment or onto gravel pads or roads. A review of the Alaska Department of Environmental 

Conservation spills database shows that the total number of spills reported on the North Slope has 

decreased from a maximum number of 581 reported spills in 2006 to a minimum of 311 reported spills in 

2016.

Spills from non-oil and gas activities, as well as some types of oil and gas exploration activities, are 

expected to be relatively small fuel spills associated with construction activities or vehicle use. Drilling 

and operation activities have the potential for a very large oil spill. The NPR-A Integrated Activity Plan 

EIS (BLM 2012) Section 4.12 discusses low-probability, very large oil spills, and includes historic 

incidents and modeled frequencies. Depending on the timing, size, and resource, a very large oil spill can 

result in serious long-term consequences.

Future development and production could occur on the North Slope in the NPR-A, the Chukchi and 

Beaufort Seas, and onshore between the NPR-A and Arctic National wildlife Refuge. New development 

would most likely occur near existing fields so infrastructure systems could be shared (BLM 2012, 

Section 4.8). Reasonably foreseeable future projects identified in Table 140 are within the Harrison Bay 

and Lower Coleville River watersheds. The risk of spills in these locations would be additive.

Cumulative impacts from each of the GMT2 action alternatives are similar. Alternatives A and B have a 

road located near the pipeline, allowing better access for surveillance and monitoring of the pipeline and 

for rapid emergency and spill response actions. Alternative C would rely on aircraft access for pipeline 

surveillance and monitoring, and emergency and spill response.

Small spills of less than 100 gallons are inevitable events that have the potential to occur at any time.

Spills resulting from development of GMT2 will add to the number of spills annually from the oil 

industry and other reasonably foreseeable future developments on the North Slope. Implementing best 

management practices and spill prevention and response planning, and performing regular maintenance 

and monitoring can reduce the potential for a large spill to occur.

4.7 Mitigation Measures and Monitoring

NEPA regulations (40 CFR 1508.20) define mitigation as avoiding, minimizing, rectifying, reducing over 

time, or compensating for impacts of a proposed action. For actions on federally managed land in the 

NPR-A, the BLM has developed a series of protective measures to mitigate potential impacts. These are 

defined and evaluated as part of the Integrated Activity Plan/EIS process, and adopted in the record of 

decision. Records of decision and permits may include additional mitigation, and mitigation may also be 

incorporated into project design (Council on Environmental Quality 2011, page 5). State of Alaska 

regulatory standards and permits also have requirements designed to protect environmental health and 
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serve to mitigate the impacts of development; however, the BLM does not have the authority to enforce or 

modify these regulatory requirements. 

The USACE regulations implementing Section 404 of the CWA and Section 10 of the RHA are defined in 

Title 33 Code of Federal Regulations (CFR) Parts 320–332. Additionally, as part of the public interest 

review, and in accordance with 33 CFR 320.4(b)(4)), the District is also required to review actions in 

accordance with regulations developed by USEPA under Section 404(b)(1) of the CWA (hereafter 

identified as the 404(b)(1) guidelines). Any requirement for compensatory wetland mitigation will be 

determined by the Corps in accordance with these regulations and existing Alaska District guidance.

In analyzing the GMT2 Project, protective measures required by the BLM for activities in the NPR-A, 

mitigating requirements of BLM (2004a), and mitigation incorporated by ConocoPhillips into Alpine 

Satellite Development Plan project design and practices are considered for their effectiveness in avoiding 

or reducing potential environmental impacts.

Due to the timeframe from exploration to development, the GMT2 Project has been subject to various 

BLM requirements, as summarized below:

• The BLM approval for permitting the Alpine Satellite Development Plan (including GMT2) included 

prescriptive lease stipulations adopted by the 1998 Northeast NPR-A Integrated Activity Plan/EIS 

Record of Decision, as well as other project-specific measures to mitigate potential impacts of 

development (2004 Alpine Satellite Development Plan Record of Decision).

• In 2008, in adopting a new Integrated Activity Plan for the Northeast NPR-A, the BLM adopted two 

types of performance-based protective measures analogous to those that had been adopted in the 

Northeast NPR-A (BLM 2008): lease stipulations and required operating procedures. The analysis 

included a comparison of the 1998 stipulations and the 2008 lease stipulations and required operating 

procedures (BLM 2008, Section 2.7, Tables 2-2 and 2-3). ConocoPhillips updated GMT2 lease 

obligations to comply with the 2008 lease stipulations.

• The 2008 performance-based lease stipulations and required operating procedures differ from the 

1998 prescriptive stipulations in two general ways. The 2008 lease stipulations and required operating 

procedures: (1) reduced replication of other laws and regulations; and (2) provided more utility and 

effectiveness in accommodating the variation and complexity associated with North Slope activities, 

as well as greater ability to adapt management as new information becomes available and 

construction/operations methods improve. By focusing on results, the performance-based measures 

provide the BLM with greater flexibility achieving resource protection objectives (BLM 2008, 

Section 2.3.5);

• In 2013, the BLM adopted an Integrated Activity Plan for all lands and waters administered by the 

BLM in the NPR-A. BLM (2013) supersedes BLM (2004a) and BLM (2012, Section 1.6.1). The two 

types of protective measures were maintained, and although the term best management practice

replaced the term required operating procedure, the definition was retained. 22

The Record of Decision (2013) for the NPR-A establishes performance-based stipulations and best 

management practices, which apply to oil and gas and, in some cases, to non-oil and gas activities within 

 22 Required Operating Procedure: Mitigation developed through the BLM planning process/NEPA process that is not attached to 

the oil and gas lease but is required, implemented, and enforced at the operational level for all authorized (not just oil and gas) 

activities in the planning area (BLM 2008a, NE NPR-A Supplemental Integrated Activity Plan Record of Decision, page 35). 

Best Management Practice (BMP): Mitigation developed through the BLM planning process/NEPA process that is not attached 

to the oil and gas lease but is required, implemented, and enforced at the operational level for all authorized (not just oil and gas) 

activities in the planning area (2013 NPR-A Integrated Activity Plan Record of Decision, page 39).
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the NPR-A and requires studies and monitoring. The following is a summary of these best management 

practices, which can be found in Appendix J:

• Waste Prevention, Handling, Disposal, Spills, and Public Safety 

o Eleven measures include, for example, requirements for waste management, spill prevention 

and response, and HazMat emergency contingency plans; air quality monitoring; and 

monitoring for potential contamination of subsistence foods.

• Water Use for Permitted Activities 

o Limits water withdrawal from streams and lakes to protect fish and other wildlife.

• Winter Overland Moves and Seismic Work

o Regulates winter travel to protect the soil, vegetation, streams, and denning bears.

• Oil and Gas Exploratory Drilling 

o Prohibits exploratory drilling in rivers, streams, and fishbearing lakes and construction of 

permanent facilities (gravel pads) for exploratory drilling.

• Facility Design and Construction 

o Twenty measures include, for example, requirements that permanent facilities minimize 

footprint; remain 500 feet from waterbodies except for crossings; allow fish passage, caribou 

movement, and subsistence user access (e.g., 7-foot-high pipeline and 500-foot road/pipeline 

separation); and USFWS-designed threatened or endangered species protections.

• Use of Aircraft for Permitted Activities 

o Requires a plan to minimize impacts to subsistence users and establishes seasonal minimum 

flight altitudes over raptor nest habitat and caribou calving, insect relief, and winter areas.

• Oil and Gas Field Abandonment 

o Requires that all oil and gas infrastructure “be reclaimed to ensure eventual restoration of 

ecosystem function.”

• Subsistence Consultation for Permitted Activities 

o Requires lessees/permittees consult with subsistence communities on their proposed 

activities, submit a plan to show how their activities will prevent unreasonable conflicts with 

subsistence activities, monitor for impacts to subsistence use, and constrain employees from 

engaging in recreational hunting and fishing at the work-site. In addition, seismic operations 

are to avoid subsistence cabins.

• Orientation Programs Associated with Permitted Activities 

o Requires personnel receive orientation on range of North Slope issues, including protecting 

resources, subsistence, and local lifestyles and laws.

• Endangered Species Act-Section 7 Consultation Process 

o Alerts lessees that the BLM may recommend modifications to exploration and development 

proposals to avoid impacts to species currently listed under the Endangered Species Act or 

that could lead to an Endangered Species Act listing and that the BLM will not approve any 

activity until it completes any necessary Endangered Species Act consultations.

• Summer Vehicle Tundra Access 
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o Establishes requirements (studies of impacts of specific vehicles to be used and resource 

surveys) of applicants for approval of vehicle use on the tundra during summer.

For the GMT2 Project, the 2013 best management practices will be in effect, but no changes to the current 

lease stipulations—from the 2008 NE NPR-A EIS—will occur without further evaluation and discussion 

with the BLM. Certain 2008 lease stipulations (D1, D-2, E-2, E-3, G-1, K-1, and K-2) applicable to this 

project present essentially the same level of protection as the 2013 best management practices. In 2013, 

the 2008 Stipulation E-17 was dropped in deference to required operating procedure E-11; however, due 

to project location, Stipulation 17 is not applicable to GMT2. To BLM’s knowledge, these stipulations 

and best management practices are not inconsistent with each other. To the extent any are found to be 

inconsistent, the 2008 lease stipulations would control.

4.8 Unavoidable Adverse Impacts

Adverse impacts from oil and gas activities, resulting from construction, operation, and abandonment of 

the proposed project and alternatives were described in BLM (2004, Section 4H.1) and in BLM (2012, 

Section 4.9). Many adverse impacts could be lessened by mitigation, but would not be completely 

eliminated or reduced to negligible levels. Some are short-term impacts, while others may be long-term 

impacts. These have been described for each resource in Sections 4.2 through 4.5. Depending on the 

preferred alternative and adopted mitigation, these impacts potentially include:

• Loss of soil productivity and sand and gravel resources largely from construction of roads and pads 

and gravel mine development;

• Loss of petroleum resources;

• Change in surface drainage due to construction of roads and pads;

• Increased air emissions, including fugitive dust, pollutants, and greenhouse gases;

• Loss of wetlands and associated functions largely from construction of roads and pads and gravel 

mine development;

• Loss or fragmentation of wildlife habitat;

• Continued change in access to and availability of subsistence resources; and

• Increased risk of spills.

To assist with abandonment and reclamation, the BLM has a bonding process in place for leases which 

are issued within NPR-A. The bond is held by the BLM, and certifies that the company will cover the full 

cost of reclamation. This bond provides monetary assurance to the BLM that the company will reclaim 

the pads, wells, and any associated surface disturbance to the standards of the BLM authorized officer. 

This is determined at the time of reclamation, thus allowing the BLM to take an adaptive management 

approach. Upon abandonment, the BLM will consider current data, technologies available, and the current 

resource situation in its determinations on specific reclamation. Additionally, the BLM retains the ability 

to increase the bond amount at any time during the lease based on a recalculation of liability (i.e., 

increased number of wells, or a history of non-compliance with BLM’s operational standards).

4.9 Relationship Between Local Short-Term Uses and Long-Term 

Productivity

The short-term uses of the study area for hydrocarbon development and production activities versus the 

maintenance and enhancement of potential long-term productivity of environmental resources of the area 

were discussed in BLM (2004, Section 4H.2) and in BLM (2012, Section 4.10). In this supplemental EIS, 
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“short-term” refers to the duration of hydrocarbon development and production activities at GMT2; 

“long-term” refers to an unspecified period beyond hydrocarbon production at GMT2. Long-term 

productivity is the capability of the land to provide natural resources indefinitely. 

The proposed GMT2 Project is consistent with terms of federal oil and gas lease AA-081800. 

Hydrocarbons developed from the GMT Unit would help offset declines in production from the Alaska 

North Slope and maintain throughput of the Alpine Sales Pipeline and ultimately, the Trans-Alaska 

Pipeline System. Hydrocarbon production would help meet the U.S. domestic energy demand. At some 

future date, the GMT2 Project will be abandoned, and elements of lost productivity may be restored.

4.10 Irreversible and Irretrievable Commitments of Resources

Irreversible and irretrievable commitments of resources were described in Section 4H.3 of the Alpine 

Satellite Development Plan EIS (BLM 2004) and in BLM (2012, Section 4.11). An irreversible or 

irretrievable commitment of resources refers to the consumption, commitment, or loss of resources due to 

project development. These distinctions refer primarily to non-renewable resources. No irreversible or 

irretrievable impacts are expected on air quality, water quality, or noise. Depending on the final 

abandonment plan, irreversible and irretrievable commitments of gravel resources, vegetation, bird 

habitat, and visual resources may be reduced. Lease Stipulation G-1 includes requirements for site 

restoration at abandonment. There would be some irreversible or irretrievable commitments of resources. 

These include:

• Removal of hydrocarbons from the reservoir;

• Energy consumption associated with construction and operation of the project;

• Ground disturbance/change resulting from gravel removal;

• Surface water consumption for drilling and other industrial purposes with wastewater disposal via 

underground injection;

• Loss or change in vegetation and wetlands where gravel is placed, regardless of whether it is removed 

at abandonment;

• Increased access to resources of the NPR-A; and

• Loss or change in subsistence use of the area, depending on final abandonment plans.
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Chapter 5. Consultation and Coordination

Exploration and potential development at the GMT2 site have been subject to various NEPA analyses in 

the past, involving a wide array of stakeholders. This chapter summarizes the public and agency outreach 

the BLM has engaged in as it has developed the supplemental EIS, including keeping the public and other 

federal, state and local agencies informed of the process and offering opportunities for the public and 

agencies ask questions and provide input. The section also identifies the individuals who prepared the 

supplemental EIS.

Early in the process, the BLM conducted public scoping to identify the range of issues and alternatives to 

address in the draft supplemental EIS, as described in Section 1.5. 

In addition to the consultation described below, BLM Alaska sought input from the local community in a 

variety of ways, including the NPR-A Subsistence Advisory Panel, NPR-A Working Group, and regular 

contact and outreach by the BLM Arctic District Office. The Subsistence Advisory Panel, established in 

1998, is comprised of seven representatives from North Slope Tribal governments and the North Slope 

Borough. The panel makes recommendations to the BLM on how to mitigate issues, concerns, and 

possible impacts to subsistence resources or harvesting due to oil and gas activities. The Subsistence 

Advisory Panel held its most recent meeting in November 2016 in Nuiqsut, which included an update on 

the GMT2 Project. The NPR-A Working Group, established by BLM (2013), held its last meeting in April 

2017, which also included an update on the GMT2 Supplemental EIS. The Working Group’s purpose is to 

consult directly with the BLM on large-scale land management decisions in the NPR-A, including oil and 

gas leasing. At the end of April 2017, all meetings of advisory groups were postponed at the direction of 

the Secretary of the Interior. As of August 2018, the NPR-A Working Group and NPR-A Subsistence 

Advisory Panel meetings had not resumed. Additional public outreach will take place as the project 

moves through its permitting phases.

5.1 Supplemental EIS Consultation and Coordination

5.1.1 Coordination and Consultation with Local, State, and Federal 

Agencies

The BLM consulted and coordinated with various stakeholders in setting the scope of analysis and 

alternatives for the supplemental EIS. Collaboration with the cooperating agencies greatly informed the 

range of the alternatives and the issues analyzed in the draft supplemental EIS. The BLM also worked 

closely with its Air Quality MOU Technical Working Group, which provided feedback on air quality 

modeling and the subsequent Air Quality Impact Analysis, and reviewed the air quality impacts language 

for Chapter 4 of the supplemental EIS. 

Development of the supplemental EIS involved consultation and coordination with the following 

government agencies:

• U.S. Army Corps of Engineers;

• U.S. Environmental Protection Agency;

• U.S. Fish and Wildlife Service;

• U.S. Bureau of Ocean Energy Management Office of Environmental Programs;

• U.S. National Park Service;

• U.S. Forest Service;

• Alaska Department of Natural Resources;

• Alaska Department of Environmental Conservation;

• North Slope Borough Department of Iñupiat History, Language, and Culture
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• North Slope Borough Department of Law

• North Slope Borough Planning Department; and,

• Native Village of Nuiqsut.

5.1.2 Tribal Consultation 

The BLM initiated the government-to-government consultation process as required by Presidential 

Executive Memorandums dated April 29, 1994, and November 5, 2009, and Department of the Interior 

Policy on Consultation with Alaska Native Claims Settlement Act Corporations, with letters sent on 

August 1, 2016, to the following Tribes and Alaska Native Claims Settlement Act corporations whose 

members could be affected by the proposed development of GMT2: 

• Native Village of Nuiqsut;

• Iñupiat Community of the Arctic Slope;

• Kuukpik Corporation; and

• Arctic Slope Regional Corporation.

Government-to-government consultation meetings were held on a monthly basis with the Native Village 

of Nuiqsut. Kuukpik Corporation and the Arctic Slope Regional Corporation also engaged in regular 

consultation with BLM Alaska during the NEPA process. 

5.1.3 ConocoPhillips Coordination 

In addition to the public outreach required as part of the NEPA process, ConocoPhillips has an extensive 

stakeholder engagement program to inform local communities, including residents of Nuiqsut, of 

proposed development activities. ConocoPhillips consults regularly with residents of Nuiqsut, including 

representatives of Kuukpik Corporation, Kuukpik Subsistence Oversight Panel, and the Native Village of 

Nuiqsut to obtain feedback on proposed activities.

5.2 List of Preparers

This supplemental EIS was prepared by the BLM and their contractors Kleinfelder and Ramboll-Environ, 

with input from all of the cooperating agencies, the Air Quality Technical Working Group, and technical 

editing and document management from the Forest Service’s Enterprise Team. BLM employees are listed 

with their office. Technical input was provided by ConocoPhillips. In addition, numerous employees of 

the cooperating agencies reviewed portions the supplemental EIS and provided constructive suggestions 

for improvement. Following is a list of Department of the Interior team members involved in the 

preparation of this supplemental EIS.

Name and Agency

Bart Brashers (Ramboll-Environ)

Cindy Hamfler (BLM Arctic District Office)

Craig Nicholls (BLM National Operations Center)

Dave Yokel (BLM Arctic District Office)

David Maxwell (BLM National Operations Center)

Debbie Nigro (BLM Arctic District Office)

Donna Wixon (BLM Arctic District Office)

Dustin Collins (Kleinfelder)

Eric Geisler (BLM Alaska State Office)

Eric Wolvovsky (Bureau of Ocean Energy Management)

Erin Julianus (BLM Central Yukon Field Office)

Greg Larson (BLM Uncompahgre Field Office)
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Joe Keeney (BLM Arctic District Office)

Josh Sidon (BLM National Operations Center)

K. Melody Debenham (BLM Arctic District Office)

Kaitlin Meszaros (Kleinfelder)

Karen Laubenstein (BLM Alaska State Office)

Kim Mincer (BLM Alaska State Office)

Krish Vijayaraghavan (Ramboll-Environ)

Liz Sears (Stephen R. Braund and Associates)

Maple Taylor (Forest Service-Enterprise Team)

Margaret Donegan-Ryan (Ramboll-Environ)

Mark Miller (BLM Alaska State Office)

Matthew Weber (University of Maryland)

Matthew Whitman (BLM Arctic District Office)

N. Shelly Jones (BLM Arctic District Office)

Paul Lawrence (Stephen R. Braund and Associates)

Rebecca Moore (BLM Washington Office)

Richard Kemnitz (BLM Arctic District Office)

Sara Longan (BLM Alaska State Office)

Sarah LaMarr (BLM Arctic District Office)

Sarah Peters Coffman (Bureau of Ocean Energy Management)

Sarah Yoder (Alaska Department of Health and Social Services)

Serena Sweet (BLM Alaska State Office)

Stacey Fritz (BLM Arctic District Office)

Stacie McIntosh (BLM Arctic District Office)

Stephanie Rice (BLM Alaska State Office)

Stephen R. Braund (Stephen R. Braund and Associates)

Thomas St. Clair (BLM Arctic District Office)

Vanessa Rathbun (BLM Alaska State Office)

William Anderson (Bureau of Ocean Energy Management)

Zachary Lyons (BLM Alaska State Office)
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Chapter 6. References

ABR Inc. Environmental Research & Services and PND Inc., Consulting Engineers. 2004. Ecological 

Restoration of the Clover A Mine Site, Alpine Satellite Development Project, Alaska. 

Unpublished report prepared for ConocoPhillips Alaska, Inc., Anchorage, AK.

ABR Inc. Environmental Research & Services. 2011. Integrated-terrain-unit mapping for baseline 

environmental studies associated with the Alpine, Tarn, Meltwater, Palm (DS3D), West Sak 

Development Area (DS-1J, DS-1K, DS-1P), NPRA, and Kuparuk Project Developments. Last 

updates 2011. Prepared for ConocoPhillips Alaska, Inc., Anchorage, AK.

ABR Inc. Environmental Research & Services. 2015. Fall 2014 subsistence fishery monitoring on the 

Colville River. Prepared for ConocoPhillips Alaska, Inc., Anchorage, AK.

Advisory Council on Historic Preservation (ACHP). 2012. Traditional cultural landscapes in the Section 

106 review process. Washington, D.C.

AECOM. 2013. ConocoPhillips Alaska, Inc. Greater Mooses Tooth 1 Air Quality Impact Analysis. Report 

submitted to ConocoPhillips Company, Anchorage, AK. October 2013. Available online at: 

https://eplanning.blm.gov/epl-front-office/projects/nepa/37035/49803/54251/2013-10-

18_GMT1_Air_Quality_Impact_Analysis_Conoco_Phillips_AK_Inc.pdf (Accessed June 2018).

AECOM. 2014. ConocoPhillips Alaska, Inc. Greater Mooses Tooth 1 Alternative A revised RFD source 

far-field air quality impact analysis. Report submitted to ConocoPhillips Alaska, Inc., Anchorage, 

AK. April.

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