Alpine Satellite Development 

Plan for the Proposed Greater 

Mooses Tooth 2 Development 

Project

Final Supplemental Environmental Impact 

Statement

Volume 4: Public Comments and BLM Response

Prepared by:

U.S. Department of the Interior 

Bureau of Land Management

Anchorage, AK

In cooperation with:

Native Village of Nuiqsut

U.S. Army Corps of Engineers

U.S. Environmental Protection Agency

U.S. DOI Fish and Wildlife Service

U.S. DOI Bureau of Ocean Energy Management

State of Alaska

North Slope Borough

Inupiat Community of the Arctic Slope

August 2018

Total Cost of Producing the EIS: $1.1 Million

Public Comment and BLM Response  Final Supplemental Environmental Impact Statement

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

1

PUBLIC COMMENTS AND BLM RESPONSES

This volume presents comments Bureau of Land Management (BLM) received on the Greater Mooses 

Tooth 2 (GMT2) Draft Supplemental Environmental Impact Statement (EIS). It also includes a 

description of the public comment process, how all comments were considered, and responses to all 

substantive comments.

GMT2 Supplemental EIS Comment Process

Public involvement is an important part of the NEPA process. The National Environmental Policy Act 

(NEPA) requires that all substantive comments received before reaching a decision must be considered to 

the extent feasible, and that agencies must respond to all substantive written comments submitted during 

the public comment period for an EIS (40 CFR 1503.4). Comments must be in writing (including paper or 

electronic format or a court reporter’s transcript taken at a formal hearing), substantive, and timely, in 

order to merit a written response.

Substantive comments do one or more of the following: 

• question, with reasonable basis, the accuracy of information in the EIS or EA. 

• question, with reasonable basis, the adequacy of, methodology for, or assumptions used for the 

environmental analysis. 

• present new information relevant to the analysis. 

• present reasonable alternatives other than those analyzed in the EIS or EA. 

• cause changes or revisions in one or more of the alternatives. 

Comments that are not considered substantive include the following. 

• comments in favor of or against the proposed action or alternatives without reasoning that meet 

the criteria listed above (such as “we disagree with Alternative A and believe the BLM should 

select Alternative C”). 

• comments that only agree or disagree with BLM policy or resource decisions without justification 

or supporting data that meet the criteria listed above (such as “more grazing should be 

permitted”). 

• comments that don’t pertain to the project area or the project (such as “the government should 

eliminate all dams,” when the project is about a grazing permit). 

• comments that take the form of vague, open-ended questions. 

The GMT2 Draft SEIS was made available for public review and a public comment period was 

announced with publication of a Notice of Availability in the Federal Register on March 23, 2018. The 

public comment period lasted for 55 days, closing on May 17, 2018. Public comments were accepted by 

mail, email, fax, hand-delivery at BLM’s office, and in-person at public meetings.

The BLM held public meetings during the comment period in North Slope communities, Anchorage, and 

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

communities to gather comments regarding potential impacts to subsistence use resulting from the 

alternatives considered in the SEIS. The public meetings in North Slope communities that were also

ANILCA §810 hearings are noted by asterisk. A list of the meetings and meeting dates are provided 

below. In order to capture all relevant comments, the entirety of the public meetings in North Slope 

communities were captured by a court reporter and reviewed for substantive comments.
Public Comment and BLM Response  Final Supplemental Environmental Impact Statement

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

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• Monday, April 9: Utqiaġvik *

• Tuesday, April 10: Atqasuk*

• Thursday, April 12: Anaktuvuk Pass *

• Monday, April 16: Anchorage

• Tuesday, April 17: Fairbanks

• Monday, April 30: Nuiqsut*

A total of 1,333 written communications were received, and 14 unique communications were derived 

from public meetings. Of the public meeting communications, four were the transcripts of the meetings, 

in which numerous community residents gave oral testimony. Of the written communications received, 

33 were considered unique communications, many of which were detailed multi-page letters. The vast 

majority of the email communications (1,240) were “canned” messages from members of the Alaska 

Industry Alliance who submitted a form letter developed specifically for this project.

All communications received as part of the public comment process were reviewed, individual comments 

that were considered substantive were parsed from the over-arching letter and entered into the comment 

analysis database and the Administrative Record. In total, 817 individual substantive comments were 

identified and entered into the database for a BLM response.

Consistent with federal regulations and BLM’s National Environmental Policy Act (NEPA) Handbook, 

BLM has drafted responses to substantive comments. Substantive comments were directed to BLM 

subject matter experts (SMEs) for consideration by resource category or section of the SEIS document. 

Responses were drafted to all such comments, and where appropriate, changes were made in the analysis 

in the Final SEIS. The majority of communications received have not received specific responses because 

they did not meet the definition of “substantive.” Many of these communications were expressions of 

personal preference that expressed the writers’ views on what management actions BLM should take. 

While these communications may have indicated why the writers advocated a certain course of action, 

they did not propose a new reasonable alternative or mitigation measure or present new information. 

Rather, the management action advocated was reflected in the existing alternatives or was within the 

range of the alternatives in the Draft SEIS, and the information provided was a part of the analysis 

considered by BLM in the Draft SEIS.

How to Read This Volume

BLM assigned a letter or public meeting comment number to every unique communication received

during the Draft public comment period. Table 4-1 lists all the substantive letters, public meeting

transcripts and verbal comments with the name of the individual or entity submitting the comments and 

the letter number/public meeting comment number assigned to them. Within each written communication 

or transcript, substantive comments were categorized and given a unique identifier. For example, the

North Slope Borough’s comment letter was assigned the letter number L86, and the first substantive 

comment from that letter was categorized as a comment on mitigation and assigned the communication 

number L86-1. Some letters were determined to be non-substantive in their entirety and are not included 

in this volume. Public meeting transcripts were assigned one public meeting number, and substantive 

comments within the transcript are identified by speaker and given a unique communication number in 

Table 4-2. Table 4-2 contains all substantive comments with BLM’s response and is organized by 

communication number. Complete transcripts of public meetings and copies of all substantive comment 

letters are available on BLM’s project website at: https://www.blm.gov/programs/planning-andnepa/plans-in-development/alaska/GMT2-SEIS
Public Comment and BLM Response  Final Supplemental Environmental Impact Statement

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

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Table 4-1: Substantive Comments and Identification Number

Letter or Public 

Meeting Number

Commenter Name

AKP1 Anaktuvuk Pass Public Meeting and Subsistence Hearing Transcript

ATQ1 Charles, Last Name Unknown

ATQ2 Ethel, Last Name Unknown

ATQ3 Atqasuk Public Meeting and Subsistence Hearing Transcript

L02 Anchorage Chamber of Commerce

L16 Michael Timmcke

L30 Sabin Center for Climate Change Law

L32 Resource Development Council

L42 Levi Frampton

L43 Lynden Transport

L44 Doyon, Limited

L51 Robert Meyer

L53 Scott Jepsen

L56 Joseph Marushack

L57 James Brodie

L58 Jon Schultz

L60 Frederick Herbert

L61 Kuukpik Corporation

L65 Hawk Consultants, LLC

L67 Alaska Trucking Association

L68 Barbara Fulmer

L70 Laborers' International Union of North America Local 341

L75 Robert Stinson

L76 EarthJustice

L77 Audubon Alaska

L78 Jerry Birch

L81 US Fish and Wildlife Service

L82 Conservation Lands Foundation

L83 Environmental Defense Fund, Institute for Policy Integrity, Natural Resources 

Defense Council, Sierra Club, Union of Concerned Scientists, Wilderness Society

L85 BP Exploration Alaska, Inc.

L86 North Slope Borough

L87 Arctic Slope Regional Corporation

L88 ConocoPhillips Alaska, Incorporated

L89 Wilderness Society, Alaska Wilderness League, Conservation Lands Foundation, 

Defenders of Wildlife, Northern Alaska Environmental Center, Sierra Club

L90 Native Village of Nuiqsut

L91 State of Alaska

L92 Environmental Protection Agency

NQT1 Mamie Pardue

NQT2 Frank Tukie, Sr

NQT3 Peter Kosbruk

NQT4 Dora Leavitt, Verbal Comments

NQT6 Dave Arnold

NQT7 Native Village of Nuiqsut Tribal Council, Verbal Comments

NQT8 Native Village of Nuiqsut Tribal Council, Verbal Comments

NQT9 Nuiqsut Public Meeting and Subsistence Hearing Transcript

UTQ1 Utqiagvik Public Meeting and Subsistence Hearing Transcript
Supplemental Environmental Impact Statement

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

4

Table 4-2: Substantive Comments and BLM Response

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

AKP1-11 Unidentified 

member of 

Anaktuvuk 

Pass

The major impact [from Alternative C is to [the 

bear cubs with] the helicopters that could land in a 

50 foot bank. Apparently that’s not going to be 

resolved. 

3.12 Mammals Helicopter traffic in general, unless it is low level and 

repetitive, is unlikely to have an impact on denning 

bears. Disruption from a helicopter landing near a bear 

den could impact the adult with consequences for a 

newborn cub. A female could potentially abandon a 

den, even with a cub inside, due to the disruption from 

a helicopter and associated human activity near a den. 

However, it is unlikely that helicopter traffic associated 

with GMT2 will disturb denning bears. An analysis of 

terrestrial maternal den sites estimated 95% of all dens 

between the Kavik River and Barrow were within 8 km 

(5 miles) of the coast (74 FR 56058). At the closest 

points, the Beaufort Sea coastline is 14.7 km (9.1 

miles) from the GMT-2 road and 26.9 km (16.7 miles) 

from the GMT-2 drill site. The nearest documented den 

record is more than 6.5 km (4.0 miles) north of GMT-2 

in the Fish Creek drainage and no dens have been 

documented within the GMT-2 Project Area.

AKP1-3 Unidentified 

resident of 

Anaktuvuk 

Pass

The [BLM] confronts the native peoples, after the 

fact that they have done things. The exploration, 

the biological and physical studies. You should 

already have that information before you come 

out here. I’m sure we have 30,000 pages from 

2004. 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

One purpose of preparing a supplemental EIS is to 

provide updated information that did not exist when the 

original EIS was written. The GMT2 SEIS updates the 

2004 EIS to include the most recent data regarding 

wildlife resources, subsistence use, and other issues 

identified as potentially impacted by the proposed 

action. 
Supplemental Environmental Impact Statement

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

5

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

AKP1-5 Unidentified 

member of 

Anaktuvuk 

Pass

Referring to Slide 11: I think GMT1 had air 

pollution, there was nothing in your impact 

statements on this. People are afraid for their lives 

on containments from CD1. They were asking for 

assistance from the State and CPAI, but nothing 

was done. It’s like these are capricious 

statements. Your modeling should be more than 

what this is right here. If you’re going to put 

peoples lives in peril from your drill rigs and 

platforms from the ground, you need to be aware 

of the air quality. You can’t say we’re sorry our 

work almost killed you, but we’re going to put that 

in our impact statement. 

3.5 Air Quality & 

Meteorology

BLM is aware of the air quality concerns in the 

community. The federal NEPA and State air permitting 

process is designed to prohibit any air quality impacts. 

As part of the Environmental Impact Analysis, the 

projected air quality impacts for GMT-2 sources have 

been assessed and been found to be minimal. 

Nonetheless, BLM is considering mitigation measures 

to guarantee continued air quality monitoring to 

alleviate concerns, see Section 4.2.3.2, Potential 

Mitigation Measures 1-11

AKP1-6 Unidentified 

member of 

Anaktuvuk 

Pass

Are you going to measure the air quality, [and] will 

it be an ongoing measurement?

3.5 Air Quality & 

Meteorology

Air quality monitoring is currently being done at the 

Nuiqsut Air Quality Monitoring Station and will continue. 

The data currently collected at the air monitoring site in 

Nuiqsut is property of CPAI. BLM is considering a 

requirement to expedite the timeframe for data review 

and dissemination of the Nuiqsut monitoring data in the 

GMT2 ROD, see Section 4.2.3 Atmospheric 

Environment, Potential Mitigation Measure 4.

AKP1-7 Unidentified 

resident of 

Anaktuvuk 

Pass

Some of those (chemical and air) agents you can't 

smell or detect until they are dead. I'm adamant 

about that. We can't have that happen again.

3.18 Public 

Health

Air pollutants that are harmful to human health, such as 

carbon monoxide, were evaluated for the GMT2 

Project. Results of the air quality modeling can be 

found in Section 4.2.3.

AKP1-8 Unidentified 

member of 

Anaktuvuk 

Pass

Evidently, the [air quality measuring station in 

Nuiqsut] was turned off. It should have measured 

some pollutants in the air and it didn’t. 

3.5 Air Quality & 

Meteorology

Thank you for the comment. The data from the Nuiqsut 

monitoring station was reviewed by EPA and others to 

determine the validity of the data, namely that a 

representative set of data were used. When the 

number of valid observations was below 60%, the data 

were removed from the analysis. In addition, the 

monitoring stations data used in the near-field and farfield modeling used three years of data to ensure 

proper and comprehensive monitoring data.
Supplemental Environmental Impact Statement

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

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Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

AKP1-9 Unidentified 

resident of 

Anaktuvuk 

Pass

We’ve had so many people dying of cancer all 

over the slope, maybe 6 people here. For the 

small community, that’s a big impact. I’m not 

saying it’s from there, it’s from the military activity. 

Radioactive testing, nuclear testing. I’m not 

comfortable with you saying these are so small 

they’re not showing up on your bar graph. But 

they could show up any where in the air. 

3.18 Public 

Health

Self-reported cancer prevalence in the NSB is 3.6 

percent, which is lower than statewide prevalence 

(2011-2013) (6.7 percent Alaska Native, 8.0 percent for 

all of Alaska). 

ATQ1-1 Charles The Inupiat land of Nuiqsut has been taken over 

by GMT1 and will also be impacted by GMT2 

even more so. The land is impacted by the oil 

companies and feel we the neighboring village is 

not happy for them to loose so much of their 

hunting grounds. I vote for the GMT2 project to be 

paused for the sake of our younger generations 

subsistence way of life.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

GMT2 was originally approved for development as CD7 in 2004 under the Alpine Satellite Development Plan 

EIS, as was GMT1 (as CD-6). As described in Section 

1.4 Purpose and Need for Federal Action, under federal 

statutes the BLM is required to issue the GMT2 permit 

for oil development in the NPR-A and cannot choose 

the No-Action alternative.

ATQ2-1 Ethel Concern built on hospitals, clinics, research of 

illnesses in villages, treatments, identify the 

illness, more science research on tundra, edible 

plants, soil, air pollution is already impacted, 

weather change, erosion, which is already in the 

EIS, concern of cancer disease, this will be like 

another addition of destruction? That is already 

happening with disaster, changes, sickness in 

fish, birds, whales, caribou, plants, will all the 

money in the world be able to fix, bring, built, 

make food, move the village, ALL the land is food. 

Because it's darkening the land, why these should 

be a different alternative? Slowly moving to 

kicking us all out, killing my grandchildren. Our 

people. This is in my Inupiaq way of writing. We 

may someday live again like our ancestors.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Thank you very much for your comment. We recognize 

the incredible resilience of the Inupiaq people in the 

face of all the changes associated with modern 

technology and industrial development. 

ATQ3-1 Paul Bodfish Comment that if a caribou herd comes by, 

Conoco Phillips could cease operations to reduce 

herd impacts.

4.2 Mitigation See Section 4.3.4 Mammals, Potential Mitigation 

Measure 2: Minimize Potential Ground Vehicle Traffic 

Disturbance of Caribou.
Supplemental Environmental Impact Statement

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

7

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

ATQ3-10 Paul Bodfish Comment that a marine mammal observer could 

be hired to monitor actual marine mammal 

numbers for impacted species.

3.12 Mammals Since impacts to marine mammals are unlikely due to 

distance and the low potential for a spill to reach the 

marine environment, and since marine mammal 

populations may be affected by a number of other 

factors, monitoring populations for this project would 

likely not yield valuable information.

ATQ3-11 Paul Bodfish Comment that an observer for caribou herd 

numbers who can communicate to the community 

where the animals are could be a valuable 

mitigation measure if populations are displaced.

4.2 Mitigation While use of an observer to communicate the presence 

and location of game species is not specifically 

addressed in the Federal Subsistence Hunting 

Regulations, taking wildlife with the aid of "radio 

communication," is prohibited. The BLM lacks the 

regulatory authority to create a program by which 

observers assist local hunters with locating the 

presence of game animals for harvest.

ATQ3-12 Fred Kanuarak Comment that caribou herds were southeast of 

Nuiqsut, during mosquito season. The numbers of 

herds in the area were different than what was 

observed in the past, and that the herds should 

have been closer to the coast at the time. 

Commenter surmised that either air traffic or 

hunters had changed the caribou migration 

patterns.

3.11 Caribou Thank you for your comment. The response of caribou 

to insects varies over the summer and behavior 

changes when Ostrid flies begin to pester the herds. 

ATQ3-13 Unidentified 

resident

Comment that chemicals coming from 

development could be getting into caribou, 

possibly in the lichens that the caribou feed on, 

and that the chemicals from caribou meat could 

cause cancer deaths in local communities.

3.11 Caribou This comment is not supported by the literature, nor do 

harvest surveys indicate that incidence of sick caribou 

harvested has increased. No text changes made. 

ATQ3-14 Paul Bodfish Comment that sick caribou are being found more 

frequently than 15 years ago.

3.11 Caribou Thank you for your comment. The BLM is not aware of 

any data pertaining to an abnormal number of sick 

caribou being found on the north slope. State and 

federal agencies will be monitoring the health of 

caribou on the north slope due to the recent 

confirmation of Mycoplasma ovipneumoniae detected 

from a single animal from the 40 mile caribou herd. 
Supplemental Environmental Impact Statement

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

8

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

ATQ3-16 Paul Bodfish Comment that sick caribou are found with lungs 

being attached to rib cages, or half a lung.

3.11 Caribou Thank you for your comment. The BLM is not aware of 

any data pertaining to an abnormal number of sick 

caribou being found on the north slope. State and 

federal agencies will be monitoring the health of 

caribou on the north slope due to the recent 

confirmation of Mycoplasma ovipneumoniae detected 

from a single animal from the 40 mile caribou herd. 

ATQ3-2 Fred Kanuarak Comment that information and numbers on swan 

populations in the Atqasuk presentation is not 

correct.

3.10 Birds Information on swan populations contained in the EIS 

has been reviewed for accuracy.

ATQ3-20 Paul Bodfish Comment that both BLM and Fish and Game staff 

flying in planes chase caribou away from herds 

due to flying at low altitudes.

3.11 Caribou Thank you for your comment. See comment response 

L89-68 regarding how BLM manages flight 

authorizations. 

ATQ3-21 Fred Kanuarak Comment that a plane flew 250 feet above a 

caribou herd and spooked them.

3.11 Caribou Thank you for your comments. See comment response 

L89-68 regarding how BLM manages flight 

authorizations. 

ATQ3-23 Paul Bodfish Comment that early rainfall is causing caribou to 

die off because they cannot dig through the snow 

due to ice crusting and snow being harder to find.

3.7 Climate 

Change

The GMT2 SEIS tiers to and incorporates by reference 

the analysis of climate change to caribou from the 2012 

NPR-A IAP EIS, including the effects of deep snow 

pack and icing events on caribou populations. 

ATQ3-24 Paul Bodfish Comment that there was recently a big die off of 

caribou due to an early rain freezing the snow.

3.7 Climate 

Change

See response to ATQ3-24
Supplemental Environmental Impact Statement

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

9

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

ATQ3-25 Fred Kanuarak Comment/question on how swan populations can 

be determined to be healthy when the overall 

population numbers in the area aren't known.

3.10 Birds The BLM follows a specific process to document visual 

resource inventory (VRI) and decisions for visual 

resource management (VRM). During the development 

of a land-use plan, the BLM conducts a visual 

resources inventory to identify the scenic qualities and 

sensitivity to change within the landscape. The landuse plan determines what the visual resource 

management objectives of the area will be. This 

means that while BLM recognizes that there may be 

high scenic values present, there could be a plan 

decision made that says that the area will be managed 

for other resource values. 

The proposed GMT2 project area is managed for 

Visual Resource Management Class IV objectives 

which allows for high modifications of the landscape. In 

the NPR-A the objectives allow for a built environment 

of constructed structures and linear features such as 

buildings, roads and pipelines that change or modify 

the landscape. GMT2 is 16-miles from Nuiqsut and 

should have a reduced visual contrast due to distance. 

ATQ3-26 Paul Bodfish Comment that snow geese populations have 

quadrupled in recent years.

3.10 Birds The area of greatest snow goose increase is on the 

Ikpikpuk River delta, outside of the GMT2 project area. 

Additional information on current snow goose 

population growth rates have been added to Chapter 3.

ATQ3-27 Paul Bodfish Comment that an observer for caribou herd 

numbers, placed between the road section and 

the drill side, would be a good mitigation measure. 

The observer could then tell the villagers where to 

go to harvest caribou.

4.2 Mitigation While use of an observer to communicate the presence 

and location of game species is not specifically 

addressed in the Federal Subsistence Hunting 

Regulations, taking wildlife with the aid of "radio 

communication" is prohibited under both Federal and 

State regulations. The BLM lacks the regulatory 

authority to create a program by which observers assist 

local hunters with locating the presence of game 

animals for harvest.
Supplemental Environmental Impact Statement

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

10

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

ATQ3-28 Paul Bodfish Comment that communities should be allowed to 

utilize the road system that will be built, to better 

connect villages to each other.

2.1 Proposed 

Action & 

Alternatives

The proposed GMT2 gravel road is intended to be 

available for use by the residents of Nuiqsut under a 

similar road access agreement currently in place for 

use of the GMT1 Access Road. At this time, Nuiqsut is 

the only community that is physically connected to the 

road due to the presence of the Kuukpik Spur Road. 

Should the BLM receive an application for additional 

gravel road(s), either industrial or municipal, to be 

constructed in the NPR-A that connect to other villages, 

it is assumed that the residents of those communities 

will be able to access and utilize the road. 

ATQ3-3 Fred Kanuarak Comment that air traffic disrupts caribou migration 

routes and hunting.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Impacts associated with Air Traffic are discussed in 

detail in Subsistence Section 4.4.5.5 Drilling and 

Operation.

ATQ3-4 Unidentified 

resident

Comment and question regarding the Porcupine 

herd changing migration routes to southwest 

routes due to development and if GMT2 will 

further impact their migration. 

3.11 Caribou The Porcupine Caribou Herd ranges well outside the 

project area and is thus not anticipated to be impacted 

by GMT2's cumulative impacts to caribou on the North 

Slope. No text changes made.

ATQ3-5 Fred Kanuarak Comment regarding confusion on how GMT2 

would have minor to negligible impacts on 

spectacled eiders when the birds nest close to 

each other.

3.10 Birds There are very few spectacled eiders nesting in the 

GMT2 project area. The statement that there would be 

a minor impact to the overall population of spectacled 

eiders is valid given the very low numbers expected in 

the project area. Consultation under section 7 of the 

endangered species act will be conducted in addition to 

BLMs analysis of the species.
Supplemental Environmental Impact Statement

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

11

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

ATQ3-6 Fred Kanuarak Comment that the air quality impacts outside of a 

300 kilometer circle are unknown.

3.5 Air Quality & 

Meteorology

The concentration of air pollutants typically decreases 

with distance from the emissions source. For example, 

the Q/D screening test used by the Federal Land 

Managers’ (FLMs) in the FLM Air Quality Related

Values Work Group (FLAG) 2010 guidance can be 

referred to. The Q/D screening test is evaluated by the 

sum of total SO2, NOx, PM10, and H2SO4 annual 

emissions in tons per year divided by the distance in 

kilometers between the source and the analysis area. 

As the distance between the source and the area is 

further apart the Q/D value is smaller. Q/D values 

below 10 are considered to have negligible impacts. 

During the maximum emissions year for GMT2 (Year 2 

for Alternative C (which is higher than Alternative A)), 

the Q/D is 1.3 for areas located 300 kilometers from the 

project area (Q=394 and D=300) and impacts are 

anticipated to be negligible.

ATQ3-8 Fred Kanuarak Comment that the health of locals has declined, 

possibly due to particulate matter.

3.5 Air Quality & 

Meteorology

Thank you for the comment. Potential impacts from 

particulate matter were evaluated as part of the GMT2 

Project and compared to the National Ambient Air 

Quality Standards and Alaska Ambient Air Quality 

Standards. The primary standards are set to provide 

public health protection and secondary standards are 

set to provide public welfare protection. Based on the 

analysis presented in the SEIS, the potential impacts 

from the proposed GMT2 Project are below the primary 

and secondary standards of the NAAQS/AAAQS for all 

pollutants including particulate matter.
Supplemental Environmental Impact Statement

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

12

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

ATQ3-9 Paul Bodfish Comment that in Barrow, a fill mixture of a foot 

and a half controls dust from the road, and could 

easily be graded. Resident comments that such a 

fill mixture could be considered for dust control on 

GMT2 roads. The fill is composed of all-natural 

ingredients that were mixed together. Resident 

comments that Harry Brower with the Barrow 

planning department could provide information on 

the fill used.

4.2 Mitigation See Section 4.2.3 Atmospheric Environment, Potential 

Mitigation Measure 1: Reduce fugitive dust generation. 

L02-4 Anchorage 

Chamber of 

Commerce

Information collected and provided since 

ConocoPhillips first started development in the 

Colville River Delta, with the Alpine field, shows 

that the subsistence lifestyle is thriving, and 

harvests are equal to or greater than before 

Alpine development. 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Text has been revised to include the assertion by 

ConocoPhillips and numerous commenters that the 

subsistence lifestyle is thriving. While it is true that 

subsistence harvests have remained steady since the 

Alpine development, community harvest amounts are 

not the only measure of the health of the subsistence 

lifestyle. Research conducted both before and after 

Alpine development provides evidence of the impacts 

of development, including Alpine, on subsistence users 

and activities. Reported impacts include increased time 

and effort involved in harvesting resources, discomfort 

in hunting areas due to the presence of industry, 

changes in or loss of hunting areas due to avoidance or 

displacement, and disruptions from developmentrelated traffic and noise. The continued harvest of 

subsistence resources despite these impacts is 

testament to the adaptability of subsistence harvesters 

in the face of change. To address the commenter and 

to provide a summary of existing levels of impacts on 

subsistence (including the acknowledgement that 

impacts have so far not affected overall harvests), 

SRB&A has added a section to the AE entitled “Existing 

Levels of Subsistence Impacts,” because these data 

should be considered as part of the baseline 

environment. The section briefly summarizes the 

baseline status of impacts affecting Nuiqsut 

subsistence based on the available data.
Supplemental Environmental Impact Statement

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

13

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L16-1 Michael 

Timmcke

Increased air traffic from a road less development 

stresses caribou herds while limited vehicle traffic 

seems to be unconcerning to wildlife. I also 

observed that wildlife used gravel pads and roads 

to rest and get relief from the unrelenting attach of 

mosquitos in the tundra. Possibly that is part of 

the reason the herd numbers continue to improve.

3.11 Caribou Thank you for your comment. Your observation of the 

response of caribou to roads could very well be correct, 

however, the time of year could be important with 

regard to caribou behavior and response to vehicle 

traffic. For example, during the insect season, caribou 

are distracted and more concerned with finding relief 

and less concerned about vehicle traffic. On the other 

hand, it is well documented that caribou do not tolerate 

road traffic and other disturbance during the calving 

season.

L30-01 Sabin Center 

for Climate 

Change Law

BLM should reconsider the assumptions 

underpinning its analysis of net GHG emissions 

generated under the proposed action and the no 

action alternative. We appreciate the fact that 

BLM has analyzed both direct and indirect 

emissions from the proposed action, including 

emissions from the transportation, refinement, 

and consumption of oil produced from the GMT2 

project. However, BLM has made a serious 

analytical error in comparing the total emissions 

from this action with those that would occur as a 

result of the use of other energy sources if the 

action is not approved. Specifically, BLM notes 

that its model for forecasting energy substitution 

“uses a projection of near constant demand [for oil 

and gas] over the next 40-70 years using the 

2016 AEO Reference Case, for which EIA does 

not assume any future changes in laws or policies 

other than what is incorporated in existing laws 

and policies.”2 This assumption does not comport 

with reality. 

3.7 Climate 

Change

The implications for oil and gas production in other 

countries relating to U.S. decisions about issuing 

leases are highly uncertain. In the substitution analysis 

based on MarketSim, the assumption is made that 

other oil producing countries will supply oil for U.S. 

import without additional restraints due to GHG-related 

policies in those countries. This might change in the 

future if other countries establish policies to achieve 

their GHG-related targets. Excluding the foreign oil and 

gas consumption is reasonable. First, the oil produced 

by GMT2 would be consumed domestically, therefore 

the substitution sources for GMT2 would also be 

consumed domestically. Second, oil consumption in 

each country is different, and BOEM does not have 

information related to which countries would consume 

less oil. This is important information since 

consumption patterns vary by country. For gas 

consumption, BOEM does not have information related 

to how changes in the U.S. market would affect other 

countries. Typically, any single project has a negligible 

impact on overall GHG globally. Geographical factors 

and time frame can also play an important role. In the 

short term, EIA tends to project continued demand. 

Here is the link to the BOEM GHG technical report: 

https://www.boem.gov/OCS-Report-BOEM-2016-065/
Supplemental Environmental Impact Statement

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

14

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L30-01

Continued

Sabin Center 

for Climate 

Change Law

The U.S. and almost every other country in the 

world have made a commitment to enact policies 

aimed at dramatically reducing greenhouse gas 

emissions in the coming decades, and this will 

inevitably involve a reduction in the utilization of 

and demand for fossil fuels.3 Thus it is nearly 

certain that there will be future changes in laws 

and policies aimed at reducing the consumption of 

oil and gas in the next 40-70 years. BLM explicitly 

recognizes that “[a]s countries, including the U.S., 

address climate change with individual policy 

targets, this assumption could no longer hold” and 

that “as new energy sources become more 

economically feasible, they could displace existing 

sources and/or alter the composition of energy 

supply.”4 BLM should therefore abandon this 

assumption as well as the analysis that depends 

on it. We recognize that there may not be a more 

accurate baseline that BLM can use to model 

potential energy substitutions and net emissions. 

If that is the case, BLM should explain that it 

cannot perform this analysis accurately due to 

uncertainties about future energy consumption 

patterns. This would be more prudent than 

presenting quantitative emission projections that 

are based on faulty assumptions, as those 

projections can mislead decision-makers and the 

public.

3.7 Climate 

Change

See above for BLM Response
Supplemental Environmental Impact Statement

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

15

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L30-02 Sabin Center 

for Climate 

Change Law

BLM should reconsider its significance 

determination (or lack thereof) with respect to 

GHG emissions from this project. BLM should 

use tools such as the social cost of carbon and 

EPA’s GHG equivalency calculator to evaluate the 

magnitude of the projected emissions and their 

corresponding impacts. BLM should also refer to 

the factors outlined in the NEPA regulations (40 

C.F.R. § 1508.27) to evaluate significance. When 

the projected emissions from this proposal are 

evaluated in light of the NEPA regulations and 

available analytical tools, it becomes clear that the 

emissions are significant by any reasonable 

standard. Despite finding that the project will 

generate relatively large quantities of CO2-e 

(whether measured as gross or net emissions), 

BLM does not issue findings with respect to 

whether these emissions represent a “significant 

impact” under NEPA. BLM also asserts that the 

“tools necessary to quantify climatic impacts of 

single projects are presently unavailable” and thus 

it cannot evaluate the magnitude of the GHG 

impacts that will occur as a result of this action.7 

There are several problems with BLM’s analysis 

of significance. First, the fact that the federal 

government has not established a specific 

significance threshold for GHG emissions does 

not prevent the agency from reaching its own 

determination as to whether those emissions 

qualify as a “significant impact” under NEPA (see 

letter for discussion, p. 3, fifth paragraph). It is 

also incorrect to say that “no single project or 

action contributes a significant amount of 

greenhouse gases when compared to global 

greenhouse gas emissions.”

3.7 Climate 

Change

Estimates of downstream greenhouse gas emissions 

are provided in the DSEIS to facilitate comparison of 

impacts associated with various alternatives and 

support analyses of cumulative impacts. The DSEIS 

indicates that emissions from anthropogenic activities 

such as production and combustion of fossil fuels do 

contribute to ongoing climate change processes, but 

existing models and tools are not sufficient to quantify 

specific impacts upon local resources. Climate change 

is by nature a cumulative global issue and no single 

action contributes an amount of greenhouse gases that 

can significantly impact global systems. Specific 

regulatory thresholds for greenhouse gas emissions 

have not been promulgated and there is no means to 

quantitatively assess impacts to local resources. It is 

recognized in the DEIS that there is inherent 

uncertainty in these estimates (from market influences 

and other factors).
Supplemental Environmental Impact Statement

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

16

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L30-02

Continued

Sabin Center 

for Climate 

Change Law

The concept of significance cannot be distilled 

down to a question of proportion – i.e., whether a 

project’s emissions are relatively small in 

comparison to global or even national totals. 

Rather, the NEPA regulations outline two 

overarching factors and a variety of 

considerations to be considered when assessing 

significance. The first factor is context (see letter 

for discussion - p.4 first paragraph). The second 

factor is intensity (see letter for discussion - p.4 

second paragraph, etc.). The other considerations 

relevant to the intensity question also weigh in 

favor of a positive significance determination for 

the emissions generated by the GMT2 project 

(see letter for discussion p.5). In light of all these 

factors, we urge BLM to revisit its analysis of 

significance and to issue a positive significance 

finding for this project.

3.7 Climate 

Change

See above for BLM Response
Supplemental Environmental Impact Statement

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

17

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L30-03 Sabin Center 

for Climate 

Change Law

BLM should elaborate on its analysis of climate 

change impacts on the project and its affected 

environment. BLM does not fully analyze how the 

changing conditions in the project area may affect 

the environmental outcomes of the project. For 

example, BLM notes that "[d]epending 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."17 But 

the analysis stops there. BLM does not consider 

what environmental outcomes may occur if it is 

necessary to remove water or excavate in 

swampy conditions. For example: could these 

excavation activities have adverse effects on 

endangered species or other environmental 

values in the area? For this reason, we 

recommend that BLM elaborate further on the 

implications that climate change may have for the 

environmental outcomes of the project.

3.7 Climate 

Change

The text quoted by the commenter is from Section 

3.2.4.3 Potential Climate Change Impacts in the Study 

Area, which is a description of current conditions within 

the affected environment that may be being affected by 

climate change, and not a description of impacts of the 

proposed project or alternatives. In this way, it is not an 

"analysis," but is simply a description of our 

understanding of conditions and their implications. The 

effects of gravel mining on various resources and 

species is discussed in those sections of Chapter 4 

Environmental Consequences. See for example, 

sections 4.3.3 Birds and 4.3.5 Threatened and 

Endangered Species for discussion of impacts from 

gravel mining, placement and climate change.

L32-1 Resource 

Development 

Council

BMP E-7(c) requires that a minimum separation 

distance of 500 feet between pipelines and roads 

be maintained to minimize disruption of caribou 

movement and subsistence use. However, 500-

foot separation of roads and pipelines may not be 

feasible in narrow land corridors between lakes 

and where pipelines and roads converge on a drill 

pad. For the GMT2 project, where it is not feasible 

to separate pipelines and roads, BLM should 

approve deviation from BMP-E-7(c) and instead 

employ supplemental mitigation measures such 

as speed limits and other design and operation 

measures that reduce impacts to subsistence 

resources. 

4.2 Mitigation Thank you for your comment. Section 2.2 of the SEIS 

describes the two deviations that are being requested 

by the applicant, and provides information regarding 

the rationale of the request. If the deviations are 

granted in the Record of Decision, the document will 

include text that explains the information considered in 

making the decision to allow a deviation to occur. 
Supplemental Environmental Impact Statement

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

18

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L42-6 Levi Frampton The proposed Alternate A includes a gravel road 

connecting existing infrastructure at GMT1. This 

gravel road assures a faster response in the 

unlikely event of an environmental or safety 

issues.

3.18 Public 

Health

Noted, further discussion in SEIS in Section 2.7, 

Alternative C: Roadless Access

L42-9 Levi Frampton Pipeline design standards and separation from 

the road were developed to ensure caribou 

movement is protected for subsistence hunting. 

The project has incorporated pull-outs on the 

gravel road to support safety and subsistence 

access on the GMT2 road.

3.18 Public 

Health

Noted, further discussion in SEIS in Section 2.7, 

Alternative C: Roadless Access, and Section 4.4.5, 

Subsistence

L43-2 Lynden It has been concluded that with proposed 

alternative A there will be fewest possible impacts 

to caribou migrations and historical substance 

hunting opportunities

3.11 Caribou Thank you for your comment. The impact analysis 

comparing Alt A and B with the roadless alternative C 

shows that the absence of impacts from roads would 

likely be offset by the increase from air traffic at the 

CD1/Alpine Processing Facility and GMT2 site. 

However, movements would likely be less restricted 

under the roadless alternative compared to other action 

alternatives.

L43-3 Lynden With Alternative A there would be a road providing 

necessary emergency response and lessor 

impact on the substance lifestyle by those 

residents of nearby community Nuiqsut.

3.18 Public 

Health

Noted, further discussion in SEIS in Section 2.7, 

Alternative C: Roadless Access, and Section 4.4.5, 

Subsistence

L44-3 Doyon, Limited Doyon notes that Alternative A consists of an 8.2 

mile long gravel road and pipeline, which will 

connect to GMT2 to existing infrastructure from 

Greater Mooses Tooth 1 (“GMT1”). The option for 

the road allows for emergency access and access 

in bad weather. The project has incorporated pullouts to support safety.

3.18 Public 

Health

Noted, further discussion in SEIS in Section 2.7, 

Alternative C: Roadless Access.
Supplemental Environmental Impact Statement

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

19

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L51-01 Robert Meyer Having reviewed the subject Draft EIS, I would 

like to point out that much of the fish data upon 

which the analysis is base is almost 20 years old. 

Considering the rapid warming of the Arctic much 

has changed since these data were collected. An 

exception is that some data on Grayling is current.

3.9 Fish A majority of the fish surveys were conducted in the 

project area between 2000-2009. These surveys are 

recent enough to be considered valid and provide 

adequate information to analyze and compare 

alternatives. 

L53-2 Scott Jepsen There are a number of areas I recommend the 

BLM focus on to improve the DSEIS. First, the 

description of the NPRA Impact Mitigation Fund 

on page 447 is misleading. The description of the 

program describes the grants as being “limited” to 

three categories. Although there are only three 

categories, those categories and the way they are 

interpreted and implemented provide a much 

wider scope than the DSEIS implies. A short 

perusal of the report issued by the State of Alaska 

every year regarding the grant program will 

support this observation. In addition, the DSEIS 

leaves the impression that the City of Nuiqsut is 

not eligible to receive grants and cannot manage 

the audits necessary to receive large grants (pg. 

176). In fact, the city has resolved its past audit 

issues and is eligible to receive grants. This 

section should be revised to reflect the current 

state of affairs for the city.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Text has been revised to update the City of Nuiqsut's

status and eligibility to receive grants from the State of 

Alaska in 2018. While the BLM cannot publish the 

entire annual report produced by the State of Alaska 

Department of Community and Economic 

Development, a range of Nuiqsut projects from the 

three categories that have been funded by these grants 

is included. 
Supplemental Environmental Impact Statement

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

20

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L53-3 Scott Jepsen The subsistence observations in the report do not 

appear to be based upon sound science. I draw 

this conclusion because of the use of 

hypotheticals (e.g., “If residents decrease use...”, 

pg. 423; “If harvests or the number of active 

participants in harvesting declines...”, pg. 424) to 

make adverse subsistence impact statements. 

The report should not be based upon 

hypotheticals, but rather actual data. The report 

also does not provide a balanced perspective 

regarding subsistence. It emphasizes negative 

comments and outcomes but does not give equal 

weight to the positive benefits the roads bring to 

subsistence hunters. For example, subsistence 

hunters have used the CD5 road to hunt. This has 

increased hunter success and made it easier to 

access caribou. In fact, this last winter several 

caribou were harvested between the GMT1 road 

and pipeline while the pipeline was under 

construction.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

The NEPA process is intended to help public officials 

make decisions that are based on understanding of 

environmental consequences, and take actions that 

protect, restore, and enhance the environment [40 CFR 

1500.1 (c)]. An EIS must identify the known and 

predicted effects that are related to issues identified 

that could be affected by a proposed action [40 CFR 

1500.4 (c), 40 CFR 1500.4(g), 40 CFR 1500.5(d), 40 

CFR 1502.16]. Federal Agencies are required to use all 

practicable means, consistent with the requirements of 

the Act and other essential considerations of national 

policy, to restore and enhance the quality of the human 

environment and avoid or minimize any possible 

adverse effects of their actions upon the quality of the 

human environment [40 CFR 1500.2(f)]. Inherently, 

NEPA analyses are statements about potential future 

outcomes, based on our understanding of effects that 

have already occurred, are currently occurring, our 

could occur, focusing on adverse effects in order to 

identify ways to address them. 

L53-4 Scott Jepsen Regarding additional mitigation measures, the 

265 mitigation measures and best practices that 

already apply to NPRA in combination with funds 

available to impacted villages from the NPRA 

Impact Mitigation Fund provide a substantial 

framework for protecting resources and mitigating 

impacts. BLM should not apply any additional 

mitigation measures.

4.2 Mitigation BLM NEPA Guidance and CEQ regulations for EIS 

analyses require that all relevant, reasonable mitigation 

measures that could improve the project are to be 

identified, even if they are outside the jurisdiction of the 

agency [40 CFR 1502.14(f), 40 CFR 1502.16(h)]. 

Following this requirement, the BLM included and 

analyzed several potential mitigation measures in the 

SEIS. The final suite of new mitigation measures 

applicable to the GMT2 Project will be determined in 

the ROD.
Supplemental Environmental Impact Statement

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

21

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L56-3 Joseph 

Marushack

The description of the NPRA Impact Mitigation 

Fund does not take into consideration a full 

spectrum of benefits and mitigation measures 

already in place. For instance, the draft SEIS 

leaves the impression that the City of Nuiqsut is 

not eligible to receive grants. In fact, the city is 

eligible to receive grants and the FEIS should 

reflect this.

4.2 Mitigation At the time of writing the Draft SEIS the BLM had been 

informed that the city was ineligible. This has changed, 

and text has been updated to reflect the fact that the 

city is eligible to receive grants from the State under 

this program.

L56-4 Joseph 

Marushack

The subsistence observations in the report do not 

appear to be based upon sound science. The 

report must rely on actual data, not speculative 

potential. The report does not provide a balanced 

perspective regarding subsistence. It emphasizes 

negative comments and outcomes but does not 

give equal weight to the positive benefits the 

roads bring to subsistence hunters.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

The NEPA process is intended to help public officials 

make decisions that are based on understanding of 

environmental consequences, and take actions that 

protect, restore, and enhance the environment [40 CFR 

1500.1 (c)]. An EIS must identify the known and 

predicted effects that are related to issues identified 

that could be affected by a proposed action [40 CFR 

1500.4 (c), 40 CFR 1500.4(g), 40 CFR 1500.5(d), 40 

CFR 1502.16]. Federal Agencies are required to use all 

practicable means, consistent with the requirements of 

the Act and other essential considerations of national 

policy, to restore and enhance the quality of the human 

environment and avoid or minimize any possible 

adverse effects of their actions upon the quality of the 

human environment [40 CFR 1500.2(f)]. Inherently, 

NEPA analyses are statements about potential future 

outcomes, based on our understanding of effects that 

have already occurred, are currently occurring, our 

could occur, focusing on adverse effects in order to 

identify ways to address them.
Supplemental Environmental Impact Statement

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

22

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L56-5 Joseph 

Marushack

Regarding additional mitigation measures, there 

exist over 200 mitigation measures and best 

practices that already apply to NPRA in 

combination with funds available to impacted 

villages from the NPRA Impact Mitigation Fund 

that provide a substantial framework for protecting 

resources and mitigating impacts. BLM should not 

apply any additional mitigation measures.

4.2 Mitigation BLM NEPA Guidance and CEQ regulations for EIS 

analyses require that all relevant, reasonable mitigation 

measures that could improve the project are to be 

identified, even if they are outside the jurisdiction of the 

agency [40 CFR 1502.14(f), 40 CFR 1502.16(h)]. 

Following this requirement, the BLM included and 

analyzed several potential mitigation measures in the 

SEIS. The final suite of new mitigation measures 

applicable to the GMT2 Project will be determined in 

the ROD.

L57-7 James Brodie The hundreds of mitigation measures and best 

practices required by BLM help ensure that 

environmental impacts are minimized. 

4.2 Mitigation BLM NEPA Guidance and CEQ regulations for EIS 

analyses require that all relevant, reasonable mitigation 

measures that could improve the project are to be 

identified, even if they are outside the jurisdiction of the 

agency [40 CFR 1502.14(f), 40 CFR 1502.16(h)]. 

Following this requirement, the BLM included and 

analyzed several potential mitigation measures in the 

SEIS. The final suite of new mitigation measures 

applicable to the GMT2 Project will be determined in 

the ROD.
Supplemental Environmental Impact Statement

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

23

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L58-2 Jon Schultz There are a number of areas I recommend the 

BLM focus on to improve the DSEIS. First, the 

description of the NPRA Impact Mitigation Fund 

on page 447 is misleading. The description of t he 

program describes the grants as being "limited" to 

three categories. In fact, the language describing 

the grant categories is so broad that there is 

practically no limitation on qualifying projects. A 

short perusal of the report issued by the State of 

Alaska every year regarding the grant program 

will support this observation. In addition, the 

DSEIS leaves the impression that the City of 

Nuiqsut is not eligible to receive grants and 

cannot manage the audits necessary to receive 

large grants (page 176). In fact, the city has 

resolved its past audit issues and is eligible to 

receive grants. This section should be revised to 

reflect the current state of affairs for the city. 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Text has been revised to update the City of Nuiqsut 

status and eligibility to receive grants from the State of 

Alaska in 2018. While the BLM cannot publish the 

entire annual report produced by the State of Alaska 

Department of Community and Economic 

Development, a range of Nuiqsut projects from the 

three categories that have been funded by these grants 

is included.
Supplemental Environmental Impact Statement

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

24

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L58-3 Jon Schultz The subsistence observations in the report do not 

appear to be based upon sound science. I draw 

this conclusion because of the use of 

hypotheticals (e.g., "If residents decrease use ... ", 

pg. 423; "If harvests or the number of active 

participants in harvesting declines ... ", pg. 424) to 

make adverse subsistence impact statements. 

The report should not be based upon 

hypotheticals, but rather actual data. The report 

also does not provide a balanced perspective 

regarding subsistence. It emphasizes negative 

comments and outcomes but does not give equal 

weight to the positive benefits the roads bring to 

subsistence hunters. For example, subsistence 

hunters have used the CDS road to hunt. This has 

increased hunter success and made it easier to 

access caribou. In fact, this last winter several 

caribou were harvested between the GMTl road 

and pipeline while the pipeline was under 

construction. 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

The NEPA process is intended to help public officials 

make decisions that are based on understanding of 

environmental consequences, and take actions that 

protect, restore, and enhance the environment [40 CFR 

1500.1 (c)]. An EIS must identify the known and 

predicted effects that are related to issues identified 

that could be affected by a proposed action [40 CFR 

1500.4 (c), 40 CFR 1500.4(g), 40 CFR 1500.5(d), 40 

CFR 1502.16]. Federal Agencies are required to use all 

practicable means, consistent with the requirements of 

the Act and other essential considerations of national 

policy, to restore and enhance the quality of the human 

environment and avoid or minimize any possible 

adverse effects of their actions upon the quality of the 

human environment [40 CFR 1500.2(f)]. Inherently, 

NEPA analyses are statements about potential future 

outcomes, based on our understanding of effects that 

have already occurred, are currently occurring, our 

could occur, focusing on adverse effects in order to 

identify ways to address them.

L58-4 Jon Schultz Regarding additional mitigation measures, the 

265 mitigation measures and best practices that 

already apply to NPRA in combination with funds 

available to impacted villages from the NPRA 

Impact Mitigation Fund provide a substantial 

framework for protecting resources and mitigating 

impacts. BLM should not apply any additional 

mitigation measures. 

4.2 Mitigation BLM NEPA Guidance and CEQ regulations for EIS 

analyses require that all relevant, reasonable mitigation 

measures that could improve the project are to be 

identified, even if they are outside the jurisdiction of the 

agency [40 CFR 1502.14(f), 40 CFR 1502.16(h)]. 

Following this requirement, the BLM included and 

analyzed several potential mitigation measures in the 

SEIS. The final suite of new mitigation measures 

applicable to the GMT2 Project will be determined in 

the ROD.
Supplemental Environmental Impact Statement

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

25

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L60-7 Frederick 

Herbert

Air quality exceeds ambient air quality standards 3.5 Air Quality & 

Meteorology

Based on the current background values from the 

Nuiqsut Monitoring Station from 2014 through 2016, 

current ambient air does not exceed national or state 

ambient air standards (Table 3.2-8 of SEIS). Analysis 

of the potential project impacts in the near-field and farfield for all analyzed pollutants and scenarios, the 

potential GMT2 Project impacts are less than their 

respective NAAQS/AAAQS (Section 4.2 of SEIS).

L60-9 Frederick 

Herbert

The hundreds of mitigation measures and best 

practices required by BLM help ensure that 

environmental impacts are minimized. 

4.2 Mitigation BLM NEPA Guidance and CEQ regulations for EIS 

analyses require that all relevant, reasonable mitigation 

measures that could improve the project are to be 

identified, even if they are outside the jurisdiction of the 

agency [40 CFR 1502.14(f), 40 CFR 1502.16(h)]. 

Following this requirement, the BLM included and 

analyzed several potential mitigation measures in the 

SEIS. The final suite of new mitigation measures 

applicable to the GMT2 Project will be determined in 

the ROD.
Supplemental Environmental Impact Statement

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

26

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L61-10 Kuukpik 

Corporation

The GMT2 DSEIS was spared the arbitrary page 

number limitation because it was already mostly 

drafted by the time Secretarial Order 3355 issued. 

12 But there has apparently been a large change 

in the Draft SEIS' analysis of long term warming in 

the Arctic. Kuukpik wants to address both the 

specific changes in the Draft SEIS, as well as 

express Kuukpik's concerns as to future NEPA 

processes. Based on announcements of recent 

discoveries it is abundantly clear that GMT2 is far 

from the last oil development project Nuiqsut will 

face in the next couple of years. And if the 

community can't rely on a thorough and detailed 

EIS document, it is likely to promote antidevelopment sentiment in Nuiqsut. If an EIS is not 

thorough, many people and organizations in 

Nuiqsut may decide that no development or 

delayed development is a lot safer than 

uninformed development.

3.7 Climate 

Change

CEQ regulations direct that: Agencies shall incorporate 

material into an environmental impact statement by 

reference when the effect will be to cut down on bulk 

without impeding agency and public review of the 

action. The incorporated material shall be cited in the 

statement and its content briefly described. No material 

may be incorporated by reference unless it is 

reasonably available for inspection by potentially 

interested parties within the time allowed for comment. 

(40 CFR 1502.21). The text provided in the GMT2 SEIS 

incorporates by reference and summarizes the text 

from the GMT1 SEIS and includes updated information 

where such information was available (i.e., minimum

sea ice extent). Our understanding of climate change 

and its effects on the Arctic are not significantly 

different than what is stated in the GMT1 SEIS. 

L61-100 Kuukpik 

Corporation

Page 522, Cumulative Impacts to Social Systems 

-Recreation, Future Impacts and Their 

Accumulation, Activities Not Associated with Oil 

and Gas Exploration and Development: The first 

passage states that "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." (emphasis added) 

This comment reflects a lack of understanding by 

the BLM, and possibly other entities: since public 

funds have been used for this planned road, it is 

almost certain that the road must be open to the 

public. This section is also out of date because, 

contrary to the suggestion in this section, the 

CD5-GMT1 road has already been built. 

3.17 Land Use Thank-you for your comment. Reworded section to 

reflect that vehicle access to Nuiqsut is restricted out of 

Deadhorse at the oil fields guard shacks and corrected 

CD5-GMT1 information.
Supplemental Environmental Impact Statement

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

27

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L61-101 Kuukpik 

Corporation

Page 526, Cumulative Impacts to Social Systems 

- Local Transportation, Future Impacts and Their 

Accumulation, Activities Not Associated with Oil 

and Gas Exploration and Development: The sole 

passage in this section states: "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." This 

statement is misleading, at best. The Colville 

River Access Road, when constructed, will only 

provide year-round vehicle access to one location 

on the Colville River. Although boats could then 

travel the river, this section suggests vehicle 

access would be much more extensive.

3.17 Land Use Revised wording in section: The addition of the Colville 

River Road Access would complete a road connection 

to the Colville River providing year-around vehicle 

access to fish and wildlife resources of the river and 

through river traffic its delta, as well as to estuarine and 

marine resources along the coast. 

L61-102 Kuukpik 

Corporation

Page 530, Cumulative Impacts to Social Systems 

- Subsistence, Future Impacts and Their 

Accumulation, Oil and Gas Development 

Activities: The discussion of Putu should be 

moved to the Colville River Unit and should note 

exploratory drilling was completed in 2018.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Text has been edited to move discussion of Putu to 

Colville River Unit.

L61-103 Kuukpik 

Corporation

Page 538, Cumulative Impacts to Social Systems 

- Environmental Justice, Future Impacts and Their 

Accumulation, Oil and Gas Exploration and 

Development Activities, Conclusion: There is no 

Alternative E. 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Text has been changed to indicate Alternative D.
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L61-104 Kuukpik 

Corporation

Appendix L 810 Analysis: Page 7, Evaluation of 

the Effect of Use, Occupancy, or Disposition on 

Subsistence Uses and Needs, Subsistence 

Resource Availability: Both Figure 3 (GMT2 

Construction Project Study Area, Caribou 

Subsistence Use Area) and Figure 4 (GMT2 

Drilling and Operation Project Study Area, 

Caribou Subsistence Use Area) show that the 

GMT2 pad and the GMT1-GMT2 access road are 

not in the highest caribou subsistence use areas. 

Also, Figure 4 has a hashmarked area which is 

not defined. Presumably, this marking was 

included to highlight the project study area for 

drilling and operation.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Maps were reviewed; the hatched area outlined in gray 

is "Project Area for Drilling and Operations" as 

indicated on the map. NEPA requires the BLM to 

evaluate the impacts of the entirety of a project, 

including areas of associated activities and connected 

actions. The project area is defined to include such 

connected areas as the ASRC gravel pit from which 

gravel will be derived and Alpine which is the 

origination point of most traffic to and from GMT2, to 

name just two examples.

L61-105 Kuukpik 

Corporation

Appendix L 810 Analysis: Page 10, Evaluation of 

the Effect of Use, Occupancy, or Disposition on 

Subsistence Uses and Needs, Access to 

Subsistence Resources, Access during 

construction: How was the footprint of the safety 

area (approximately 142 acres) calculated? Also, 

only a small portion of this footprint would be less 

than 5 miles from Nuiqsut, based on the planned 

ice road routes.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

The calculation for the safety areas was estimated 

based on maps provided by the applicant that are 

distributed with the GMT1 Road Access guidelines, 

which include red circles around drill pads and 

processing facilities. The actual amount of land 

included within these areas has been provided by the 

applicant and the text has been updated with accurate 

information. 
Supplemental Environmental Impact Statement

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L61-106 Kuukpik 

Corporation

Appendix L 810 Analysis: Page 11, Evaluation of 

the Effect of Use, Occupancy, or Disposition on 

Subsistence Uses and Needs, Access to 

Subsistence Resources, Access during 

construction: Figure 5 (Nuiqsut travel routes) is 

misleading since it does not distinguish between 

winter travel routes and summer travel routes.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Figure 3.4-22, introduced and explained in Chapter 3: 

Affected Environment and summarized in Appendix L, 

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. It is true that the figure does 

not distinguish between winter and summer routes. The 

map shows the data that exists regarding travel routes 

utilized by Nuiqsut residents. These are travel routes

for both subsistence and general traveling to locations 

such as to Utqiaġvik, Anaktuvuk Pass, or subsistence 

camps. However, the vast majority of them are travel to 

subsistence use areas and even those that are used for 

travel to other communities like Utqiaġvik or Anaktuvuk 

Pass are generally used for subsistence as well. 

L61-107 Kuukpik 

Corporation

Appendix L 810 Analysis: Page 12, Evaluation of 

the Availability of Other Lands: This passage 

explains that BLM "considered the possibility of 

moving the location of the GMT2 drill pad, but 

such an alternative would have moved the drill 

pad off Kuukpik-selected lands. This would have 

resulted in less revenue to the Kuukpik 

Corporation shareholders, and would have 

lessened the ability of those shareholders to 

adapt to the impacts of the GMT2 Project." BLM is 

both over-simplifying things and assuming facts 

that it doesn't know enough about. Moving the 

pad off Kuukpik-selected lands would not 

necessarily result in less revenue to Kuukpik. 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Text regarding Kuukpuk Corporation revenues has 

been removed. Kuukpik Corporation is encouraged to 

provide details on existing revenues and anticipated 

revenue sources so that the sections that should 

include this information (Economy, Sociocultural 

Systems, and ANILCA 810 evaluation of the availability 

of other lands) can be more accurate. 
Supplemental Environmental Impact Statement

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L61-108 Kuukpik 

Corporation

Appendix L 810 Analysis: Page 17, Evaluation 

and Findings for the Cumulative Case: The 

Nanushuk development is not planned to begin in 

2018.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Text has been changed to indicate that the Nanushuk 

project is currently under analysis through an EIS that 

is being prepared by the U.S. Army Corps of 

Engineers. Effective March 15, 2018, Oil Search 

Alaska, LLC has officially assumed the role of Operator 

for the Nanushuk development. The schedule for 

addressing public and agency comments on the Draft 

EIS, and completing the Final EIS is being extended, to 

allow the new operator time to communicate with 

various interested parties and stakeholders to assess 

possible additional opportunities to avoid and minimize 

impacts to the environment as a result of project 

activities, and develop responses to the outstanding 

project related Requests for Information (RFIs) from the 

U.S. Army Corps of Engineers. The former operator 

(Armstrong) expected the first development in the Pikka 

Unit to go online no later than 2022. 

L61-12 Kuukpik 

Corporation

The Final SEIS should identify and analyze 

mitigation measures that will be needed in order 

for GMT2 to adapt to a warming Arctic.

3.7 Climate 

Change

Any development in the NPR-A is currently subject to a 

extensive suite of best management practices (BMPs) 

pursuant to the IAP ROD, including BMPs for Facility 

Design and Construction. In addition, a potential 

mitigation measure specific to GMT2 has been 

proposed that includes the following requirement:

Equipment used to develop hydrocarbons must meet 

the following standards: Equipment must be designed 

in accordance with standard Arctic engineering 

practices for use in Arctic conditions; Design criteria 

must be based on conservative estimates.
Supplemental Environmental Impact Statement

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L61-14 Kuukpik 

Corporation

Kuukpik compared the GMT2 analysis of longterm climate issues with the similar analysis in the 

GMT1 Final SEIS. Instead of incorporating new 

and updated knowledge (both western and 

traditional) into this Draft SEIS, there is actually 

much less discussion of the trends Native people 

on the North Slope have observed over the past 

several decades or more. This includes things like 

changes in the annual migration timing of certain 

species (particularly whales), a shorter ice road 

season, reduction in sea ice, and increasingly 

unpredictable permafrost and hydrological events. 

Most of these issues aren't discussed in the Draft 

EIS with any particularity.

3.7 Climate 

Change

CEQ regulations direct that: Agencies shall incorporate 

material into an environmental impact statement by 

reference when the effect will be to cut down on bulk 

without impeding agency and public review of the 

action. The incorporated material shall be cited in the 

statement and its content briefly described. No material 

may be incorporated by reference unless it is 

reasonably available for inspection by potentially 

interested parties within the time allowed for comment. 

(40 CFR 1502.21). The text provided in the GMT2 SEIS 

incorporates by reference and summarizes the text 

from the GMT1 SEIS and includes updated information 

where such information was available (i.e., minimum 

sea ice extent). Our understanding of climate change 

and its effects on the Arctic are not significantly 

different than what is stated in the GMT1 SEIS. 

L61-15 Kuukpik 

Corporation

Worse, the bulk of information that's been omitted 

is the forward looking analysis that helps 

stakeholders understand how warming trends in 

the Arctic will impact the land and subsistence 

activities in the coming decades. That type of 

information is by far the most important to include 

in an EIS. Among the types of information and 

conclusions that were included in the GMT1 Final 

SEIS but not in the Draft GMT2 SEIS are the 

following: Changes in the Arctic marine 

environment are affecting the foundation of the 

food web in both terrestrial and marine 

ecosystems. (GMT l FSEIS, p. 119). Climate 

change has also been shown to have some 

impact in the NSB, including erosion problems, 

less reliable ice conditions, and higher risk to 

hunters and spring whalers.

3.7 Climate 

Change

CEQ regulations direct that: Agencies shall incorporate 

material into an environmental impact statement by 

reference when the effect will be to cut down on bulk 

without impeding agency and public review of the 

action. The incorporated material shall be cited in the 

statement and its content briefly described. No material 

may be incorporated by reference unless it is 

reasonably available for inspection by potentially 

interested parties within the time allowed for comment. 

(40 CFR 1502.21). The text provided in the GMT2 SEIS 

incorporates by reference and summarizes the text 

from the GMT1 SEIS and includes updated information 

where such information was available (i.e., most up to 

date information on minimum sea ice extent). Our 

understanding of climate change and its effects on the 

Arctic are not significantly different than what is stated 

in the GMT1 SEIS. 
Supplemental Environmental Impact Statement

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L61-15

Continued

Kuukpik 

Corporation

The NPR-A IAP (BLM 2012 p. 513) concludes 

that climate change will likely result in rapidly 

changing physical environmental and health 

conditions for the NSB population in the coming 

years. Climate change may affect both 

subsistence food availability and storage and may 

increase risks associated with subsistence 

activities, which in tum may lead to dietary and 

cultural change. Climate change can also affect 

water, sanitation, housing, transportation 

infrastructure, cultural continuity, community 

stress levels, the spread of infection, and even the 

types of diseases and infections to which the 

population is susceptible. (GMTl FSEIS, p. 211). 

Warming of the climate will have major impacts on 

the ecosystems of the North Slope and the project 

study area. The climate change scenario for the 

rest of this century suggests that climate will get 

warmer, with greater precipitation, but that longer, 

warmer summers will increase evapotranspiration 

so that there will actually be less moisture 

available to plants (Grimm et al. 2013). (GMTl 

FSEIS, p. 121). BLM (2012, § 4.8.7) concluded 

the cumulative effect of climate change is likely 

more pronounced on the North Slope than 

elsewhere in Alaska and may include an increase 

in particulate matter to the extent 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. Raynolds et al. 

(2014) found that climate change induced 

thermokarsting, lakeshore erosion, and changes 

to river bars and banks, has occurred across the 

Prudhoe Bay Oilfield and west of the field. (GMT1 

DSEIS, p. 528). 

3.7 Climate 

Change

See above for BLM Response
Supplemental Environmental Impact Statement

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L61-15

Continued

Kuukpik 

Corporation

People in Nuiqsut have observed many of these 

trends and are concerned about them. A failure to 

acknowledge their existence and the warming 

trend does not inspire confidence.

3.7 Climate 

Change

See above for BLM Response

L61-16 Kuukpik 

Corporation

The Draft appears to deliberately omit the most 

troubling information and concerns about warming 

trends in the Arctic that BLM identified just 3 years 

ago with GMT1. Instead, the Draft doesn't state 

many conclusions at all, instead jumping around 

between random facts, overly technical 

discussions of less important issues, and data 

that will help defend BLM in court from the 

argument that it arbitrarily failed to analyze 

climate change, but which don't contribute to or 

include any important conclusions about its 

impacts on subsistence, the ecosystem, or how to 

design the GMT2 project to be the LEDPA.

3.7 Climate 

Change

Although it is unclear what the subject of "overly 

technical discussion of less important issues" is 

referring to, the SEIS does tier to previous NEPA 

analysis, including the ASDP 2004, IAP 2012, and 

GMT1 2014. Following BLM guidance tiering is using 

the coverage of general matters in broader NEPA 

documents in subsequent, narrower NEPA documents 

(40 CFR 1508.28, 40 CFR 1502.20). This allows the 

tiered NEPA document to narrow the range of 

alternatives and concentrate solely on the issues not 

already addressed. Tiering is appropriate when the 

analysis for the proposed action will be a more sitespecific or project-specific refinement or extension of 

the existing NEPA document. The BLM has included 

more detailed information on subjects that were not 

previously covered in existing NEPA analysis. See 

also the response to L61-15.

L61-17 Kuukpik 

Corporation

Whether or not the Administration believes the

climate is warming slightly over time or not, the 

people of Nuiqsut have seen enough changes to 

be convinced that something is going on. Like 

them, Kuukpik frankly doesn't really care that 

much about what exactly is causing the warming 

trends we've seen over the years (because we're 

not really in a position to do anything about that) 

but we care profoundly about what these changes 

mean for the community, for subsistence, and for 

the infrastructure that is currently being built in 

this area.

3.7 Climate 

Change

Thank you for your comment. The BLM is also 

committed to understanding the effects of climate 

change in the NPR-A, and will continue to conduct 

research and monitoring to be able to respond to 

changing conditions through adaptive management.
Supplemental Environmental Impact Statement

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L61-18 Kuukpik 

Corporation

Previous NEPA documents have covered two 

aspects of how a project relates to climate 

change: "[I] How the Project could contribute to 

climate change through direct GHG emissions, 

and how mitigation measures could potentially 

reduce those emissions, [and 2] How regional 

climate change could have an impact on the 

Project, and how mitigation measures could 

potentially reduce those impacts.” But the GMT2 

Draft SEIS only discusses the first question in any 

detail, in fact going into great and unnecessary 

detail describing the (lack of) differences between 

the greenhouse gas emissions from each 

alternative. This misses the point because what 

really matters to Kuukpik, Nuiqsut and other 

stakeholders (including, we hope, the Corps of 

Engineers) is not how the project will affect 

climate change, but how a warming Arctic will 

affect the project, the project area, and the 

resources the EIS is supposed to be analyzing. 

That information is effectively absent from the 

GMT2 Draft EIS (save for some cursory mentions 

in the cumulative impacts section). Omitting this 

information is short-sighted because BLM and 

CPAI need to be planning now for what the North 

Slope is going to look like in 20 and 30 years. The 

Final EIS must consider long term warming trends

in the Arctic because the project needs to be 

designed to withstand them.

3.7 Climate 

Change

The impacts of climate change on the resources in the 

Arctic is analyzed in section 3.2.4, Climate Change. 

Regarding project infrastructure design, the project 

applicant has adjusted design standards over the years 

to ensure a conservative safety margin. One example 

of this is changing road thickness from an average 5-

foot thickness to a minimum 5-foot thickness. 
Supplemental Environmental Impact Statement

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L61-19 Kuukpik 

Corporation

A prime example is the evolving understanding of 

how gravel roads and pads may need to be 

designed to accommodate warming temperatures. 

Less than a year ago, the Corps of Engineers 

concluded in at least one instance that pads only 

35 miles away from GMT2 would need to be 

about 30-35% thicker than previously constructed 

(6.4 feet deep instead of the usual 5 feet) in order 

to prevent the pads from excessively and 

unevenly settling into the tundra, which could 

damage the structures and equipment on those 

pads. This is precisely the type of new information 

and updated analysis the GMT2 Supplemental 

EIS should include and prioritize. On-the-ground 

impacts caused by weakening permafrost are the 

very definition of information that wasn't fully 

known and understood when the ASDP EIS 

(which includes an early version ofGMT2) was 

completed in 2004. But instead of including real 

analysis and projections like those cited above, 

the Draft EIS (way back in the cumulative impacts 

section) treats the issue of whether 5 foot thick 

roads will be sufficient as a hypothetical question 

that doesn't need to be answered right now: "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. 

3.7 Climate 

Change

The regulatory division of the Army Corps of Engineers 

does not have any design considerations/requirements 

in regard to permafrost conditions. In general, the 

applicant is responsible for the engineering of their 

projects. The gravel depth for the Nanushuk project 

was proposed by the applicant and is not endorsed or 

required by the Corps. The BLM follows a similar model 

and defers to the applicant to design a project that will 

be resilient in the face of a changing climate. 

ConocoPhillips Alaska, Inc. designed GMT2 to 

withstand the harshest projected conditions with a 

margin of safety, which will account for changes in the 

climate over the life of the project.
Supplemental Environmental Impact Statement

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L61-19

Continued

Kuukpik 

Corporation

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 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." 

This last sentence, without benefit of any further 

analysis or information, is particularly elusive and 

frustrating in light of the Corps's recent conclusion 

for another facility, quoted above, that, yes, more 

than 5 feet of gravel will be needed to support 

structures-about one and half feet more to be 

exact. Is this the wave of the future? Perhaps. 

Probably nobody knows, but these are highly 

significant developments and the Draft SEIS 

doesn't really even address the question.

3.7 Climate 

Change

See above for BLM Response
Supplemental Environmental Impact Statement

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L61-20 Kuukpik 

Corporation

Recent experience suggests that projections 

about weakening permafrost could be accurate 

and that they could be affecting roads as well. 

Various oil companies have recently proposed to 

make existing roads thicker than five feet in 

Kuparuk. CP AI proposed one such effort {in the 

Kuparuk area) in part because it claims the roads 

are settling more and more unevenly as the 

permafrost has weakened. CPAI claims that the 

current thickness/height of some of those roads 

above the tundra is as little as one foot. Those 

roads were originally built to a minimum depth of 

5 feet-the same depth proposed for the GMT2 

Access Road. Whether CPAI's claims are 

accurate or not, the very fact that CPAI believes a 

warming trend is negatively impacting its existing 

roads confirms that the Final EIS needs to 

consider whether trends like this one are going to 

continue, and more importantly, help develop 

mitigation measures that will help GMT2 facilities

withstand those long term changes. The current 

best available data strongly suggests that the 

currently-proposed 5 foot thick GMT2 Access 

Road and pads may not be sufficient for the long 

term protection of the tundra and the stability of 

CPAI's facilities. That may very well mean that 5 

foot thick pads and roads are not the Least 

Environmentally Damaging Practicable 

Alternative. BLM, CPAI, and the Draft SEIS 

should at least address and consider whether it 

would be appropriate to construct thicker roads 

now rather than trying to solve these kinds of 

problems later when all the equipment is already 

in place and the oil is flowing.

3.7 Climate 

Change

Climate conditions over the life of the project are 

factored into the design and ConocoPhillips Alaska, 

Inc. has adjusted design standards over the years as 

design best practices have been identified. One 

example of this is changing road thickness from an 

average 5-foot thickness to a minimum 5-foot 

thickness. The roads in the Kuparuk unit that have 

been improved were improved to bring them up to the 

5-foot thickness minimum standard.
Supplemental Environmental Impact Statement

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L61-21 Kuukpik 

Corporation

In its present form, the Draft SEIS seems to 

largely ignore Nuiqsut's longer term traditional 

knowledge as well as the last several decades of 

more recent Kuukpikmiut experience with 

warming trends on the North Slope.

3.7 Climate 

Change

The text has been edited to include a section on 

climate change in the Cumulative Effects - Subsistence 

section (4.6.8.9) that describes recent scientific reports 

and Nuiqsut observations. Climate change is noted as 

a threat identified by residents of Nuiqsut in Section 

4.6.8.2 (Cumulative Effects - Sociocultural Systems): 

the text notes that several effects of climate change are 

particularly significant in the western Arctic and are 

likely to create significant social anxiety for the Iñupiat. 

The Cumulative Effects - Environmental Justice section 

(4.6.8.10) also notes that Inupiaq communities will bear 

a disproportionate burden of these effects. 

L61-22 Kuukpik 

Corporation

The discussion of socio-cultural issues in Nuiqsut 

is full of incorrect information, gossip, and 

opinions that are not relevant to this project. 

Kuukpik found it difficult to understand what BLM 

had in mind as a replacement when BLM 

announced that the GMT2 SEIS wouldn't use 

"impact criteria" to evaluate and describe impacts 

to important topics like subsistence and sociocultural systems. Although simple one word labels 

("minor," "major", etc.) can be difficult to apply in 

particular instances, such labels are intended to 

represent a meaningful conclusion that is the end 

product of a logical analysis of widely accepted 

facts. Properly applied, such an analysis and 

conclusions offer highly valuable information. 

Kuukpik disagreed with some of the application of

those criteria and the conclusions drawn in the 

GMT1 SEIS, for instance, but Kuukpik far prefers 

that impact criteria to the fuzzy, subjective, 

gossipy alternative that BLM presents in its stead 

in the Draft GMT2 SEIS.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

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 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. 
Supplemental Environmental Impact Statement

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L61-23 Kuukpik 

Corporation

What the BLM and the Draft SEIS offer in place of 

the usual analysis and conclusions using "impact 

criteria" is a fragmented, anecdotal and highly 

subjective discussion that seems like an effort to 

describe as many viewpoints and opinions as 

possible, but which ends up being far less 

informative and represents not so much an 

"analysis" as rumor mongering and gossiping. 

The change, at least as presented in the GMT2 

Draft SEIS, is misleading and unacceptable. This 

new approach includes extensive unscientific and 

unsupported opinion, much of it offered as though 

it represents a widely shared view in the 

community, when in fact no evidence is offered 

that it represents anything more than the opinion 

of the single interviewee or the author. Much of 

what factual information is offered is demonstrably 

wrong-see the extensive list of factual errors in 

the DSEIS in the Attachment to this comment 

letter. Dignifying and publicizing gossip may make 

for a more titillating text and more entertainment 

value, but it doesn't help anyone effectively 

evaluate the potential impacts of developing 

GMT2.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

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 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. 
Supplemental Environmental Impact Statement

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

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Comm # Commenter 

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L61-24 Kuukpik 

Corporation

BLM's choice of sources probably contributed to 

this problem significantly. The Draft SEIS draws 

heavily from Redmond and Thonsohn's The Next 

Horizon: A socio-cultural study of the impact of oil 

development on the Native community of Nuiqsut, 

Alaska (2016). But The Next Horizon is far from 

the type of scientific "study'' on which NEPA 

documents have relied on in past analyses of oil 

industry projects affecting Nuiqsut and the North 

Slope. It isn't an authoritative source-in fact, it isn't 

even a scientific publication. The authors of The 

Next Horizon are not sociologists, anthropologists, 

or academics, but lay people from a TV station in 

Denmark who came to Nuiqsut to film a TV 

documentary and subsequently generated The 

Next Horizon after the documentary was not 

completed. As film makers, their job is to find and 

tell a compelling and entertaining story, not to 

objectively and scientifically gather and analyze 

data. Put another way, a documentary film maker 

by definition is seeking a story that will attract an 

audience, versus a trained sociologist or biologist 

who is trying to objectively and accurately record 

and describe existing conditions. Quite simply, 

The Next Horizon is not the type of scientific 

report the NSB, the State. CPAI or the federal 

government would normally rely upon as part of a 

NEPA process. And yet the Draft SEIS 

unquestioningly treats it as though it were exactly 

that type of scientific study. That is simply 

incorrect and inappropriate usage of the source 

material. Kuukpik is not saying that it's a 

completely unacceptable source, but it does not 

have the same weight as either a scientific study 

or traditional knowledge.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

One purpose of preparing a supplemental EIS is to 

provide updated information that did not exist when the 

original EIS was written. BLM NEPA Guidance 

regarding information to be used as part of the analysis 

does not specify any minimum requirements. BLM 

NEPA handbook states "Data and other information 

used to describe existing conditions and trends may be 

obtained from other documents and summarized and 

incorporated by reference or otherwise appropriately 

referenced. You may also obtain data and other 

information from cooperating agency partners or other 

agencies, organizations, or individuals, as identified 

during scoping." The 2016 "Next Horizon" study was 

provided to BLM by the applicant as a source of recent 

socio-cultural information for Nuiqsut. The publication 

notes that it was commissioned and funded by the 

applicant for the Kuukpik Corporation.
Supplemental Environmental Impact Statement

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

41

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L61-24

Continued

Kuukpik 

Corporation

It's more akin to a detailed piece of journalism 

than it is a scientific study. That distinction-and 

the difference between actual facts reported in 

The Next Horizon, as opposed to interpretation or 

opinion-needs to be made abundantly clear in the 

SEIS if (or to the extent) BLM chooses to rely on 

this source.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

See above for BLM Response

L61-25 Kuukpik 

Corporation

In addition, though, The Next Horizon gets a lot of 

its facts wrong, and many of those inaccurate 

facts are carried over into the Draft SEIS. 

Certainly the extent of those inaccurate facts very 

much bears on the credibility of The Next Horizon. 

For example, the Draft SEIS repeats information 

from The Next Horizon about basic facts 

regarding Kuukpik's shareholders and internal 

governance that are flat out wrong and 

misleading, not to mention irrelevant to the GMT2 

project. The Draft SEIS incorporates The Next 

Horizon's statement (incorrectly citing one of 

Kuukpik's former Presidents, no less) that only 

one-third of Kuukpik's original shareholders are 

still alive. Actually, it's just the opposite: about 

one-third of Kuukpik's original shareholders have 

passed away and about two-thirds are alive. Nor 

are Board members elected by those with l00 

shares as The Next Horizon and Draft SEIS both 

state; all shares are eligible to vote for Kuukpik's 

directors.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

The text has been edited to include this information 

from Kuukpik. One purpose of preparing a 

supplemental EIS is to provide updated information that 

did not exist when the original EIS was written. BLM 

NEPA Guidance regarding information to be used as 

part of the analysis does not specify any minimum 

requirements. BLM NEPA handbook states "Data and 

other information used to describe existing conditions 

and trends may be obtained from other documents and 

summarized and incorporated by reference or 

otherwise appropriately referenced. You may also 

obtain data and other information from cooperating 

agency partners or other agencies, organizations, or 

individuals, as identified during scoping." The 2016 

"Next Horizon" study was provided to BLM by the 

applicant as a source of recent socio-cultural 

information for Nuiqsut. The publication notes that it 

was commissioned and funded by the applicant for the 

Kuukpik Corporation.
Supplemental Environmental Impact Statement

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

42

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L61-26 Kuukpik 

Corporation

For documentary film makers, weaknesses in 

human nature, dissension and divisiveness make 

a much better story than dry fact, but the Draft 

SEIS incorporates The Next Horizon's discussion 

of these topics without a hint of skepticism or 

question. For instance, the Draft SEIS portrays 

Nuiqsut residents as so little concerned with the 

fate of their community and culture that they 

wouldn't attend an agency or industry community 

meeting unless they receive a handout. Citing a 

highly offensive statement from The Next Horizon, 

the Draft suggests that residents care less about 

receiving information and voicing their concerns at 

public meetings than they do about enjoying a 

"sumptuous buffet and door prizes". This is as 

false as it is insulting. We can't recall if the 

authors of The Next Horizon even attended a 

public meeting, but they clearly weren't at one of 

the many, many meetings where people have sat 

hungry for hours just to make sure heard voices 

were heard. This unequivocal and patronizing 

statement that, absent a "sumptuous" buffet, "no 

public meeting is well attended" is a perfect 

example of the kind of emotional and inaccurate 

information that may be acceptable in TV studios, 

but has no place in an EIS. The fact that much of 

this "information" and these characterizations in 

the Draft SEIS are taken straight from The Next 

Horizon tells Kuukpik (and should tell BLM and 

the authors of the Draft SEIS) that The Next 

Horizon is not a valid scientific study and is not a 

source to rely on in this NEPA analysis. BLM 

should delete these paragraphs from the Final 

EIS, and should carefully consider whether there 

is any real value in relying on this publication at 

all.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

The DSEIS includes a detailed discussion of the 

problematic nature of development meetings but does 

not assert that residents are not concerned with the 

fate of their community. It describes, with numerous 

examples, how deeply concerned they are. The 

information used in the analysis was gathered from a 

variety of sources. Text has been revised to remove 

information perceived as insulting by the commenter. 

One purpose of preparing a supplemental EIS is to 

provide updated information that did not exist when the 

original EIS was written. BLM NEPA Guidance 

regarding information to be used as part of the analysis 

does not specify any minimum requirements. BLM 

NEPA handbook states "Data and other information 

used to describe existing conditions and trends may be 

obtained from other documents and summarized and 

incorporated by reference or otherwise appropriately 

referenced. You may also obtain data and other 

information from cooperating agency partners or other 

agencies, organizations, or individuals, as identified 

during scoping." The 2016 "Next Horizon" study was 

provided to BLM by the applicant as a source of recent 

socio-cultural information for Nuiqsut. The publication 

notes that it was commissioned and funded by the 

applicant for the Kuukpik Corporation.
Supplemental Environmental Impact Statement

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

43

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L61-27 Kuukpik 

Corporation

Kuukpik also objects to the descriptions of 

Nuiqsut and certain meetings-again taken 

primarily from The Next Horizon-that are 

unnecessary, untrue, and frankly insulting. The 

final paragraph of page 390 and first paragraph of 

page 39 l of the Draft SEIS attempt to describe, 

for some reason, why federal meetings are the 

"least popular", which the Draft concludes is 

because of the "lack of gifts and food" at such 

meetings. Not only is this patronizing, inaccurate 

(see, e.g., Footnote 34), and going far beyond 

prior BLM commentary on these issues, but its 

effect is to denigrate the residents of the 

community of Nuiqsut.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Meetings are recognized as a social impact for Nuiqsut. 

The descriptions of Nuiqsut meetings were not taken 

primarily from The Next Horizon. A recent master's 

thesis by an Inupiaq anthropology student (Stotts 2016) 

explored North Slope development meetings and 

analyzed why federal government meetings are more 

constrained, rigid, official, and culturally obtuse. One 

reason is the lack of gifts and food at federal 

government meetings, which are understood as 

standard compensation for time and effort. The BLM 

regrets that official policies prevent it from 

compensating meeting participants for their time and 

input. 

L61-28 Kuukpik 

Corporation

Under the guise of discussing the problem of 

some Nuiqsut residents' frustration with the pace 

of development, the Draft SEIS also proceeds to 

question the validity and credibility testimony from 

Nuiqsut residents and stakeholders, stating "On 

the North Slope, participants often believe that it 

is in their duty and best interest to describe 

impacts in the most dramatic manner possible in 

order to make [sic] their comments be 

considered." It is hard to see this as anything 

other than a broad grant of permission for public 

agencies to discount and disregard testimony 

from Nuiqsut residents and stakeholders. The fact 

that this comment comes from BLM instead of 

The Next Horizon is deeply troubling, and 

suggests BLM is falling into the same gossip and 

rumor mongering trap as The Next Horizon.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

The sociocultural systems section reports on a BLM 

effort to systematically record and analyze every single 

comment made by residents of Nuiqsut at public 

meetings on development. This is an effort to establish 

validity, trends, and credibility in regards to their 

testimony. The pace of development is repeatedly 

mentioned by residents as a concern; this impact is 

described in the analysis in several places and is not 

used as a guise to discount other reported impacts. 
Supplemental Environmental Impact Statement

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

44

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L61-29 Kuukpik 

Corporation

The discussion of possible differing views of 

GMT2 between shareholder and non

shareholders in Nuiqsut is another example of the 

problems caused by the Draft SEIS's 

unquestioning acceptance of statements in The 

Next Horizon and the undue attention the Draft 

SEIS gives to perceived dissension and "conflicts" 

within Nuiqsut. Much like The Next Horizonwhose producers must have believed (like every 

other Alaska-based "reality'' show) that focusing 

on conflict would make better TV-the Draft SEIS 

spends an inordinate amount of time describing 

strife in the community, as though that is the 

defining feature of the community for purposes of 

possible impacts from GMT2,16 and not nearly 

enough describing the far more defining aspects 

of the community and its culture that are in reality 

far more likely to be impacted by oil development 

than the conflicts The Next Horizon features so 

prominently. Nuiqsut and its vulnerabilities to oil 

development are so much more than the sort of 

near-civil war depicted in The Next Horizon and 

the Draft SEIS that the one-side descriptions in 

these documents are misleading rather than 

informative.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

The Final SEIS has replaced the citation from 

Redmond with other references and with verbatim

statements from Nuiqsut residents made at recent 

public meetings to provide a more accurate description 

of these concerns and is edited to clarify that they do 

not define the community. One purpose of preparing a 

supplemental EIS is to provide updated information that 

did not exist when the original EIS was written. BLM 

NEPA Guidance regarding information to be used as 

part of the analysis does not specify any minimum 

requirements. BLM NEPA handbook states "Data and 

other information used to describe existing conditions 

and trends may be obtained from other documents and 

summarized and incorporated by reference or 

otherwise appropriately referenced. You may also 

obtain data and other information from cooperating 

agency partners or other agencies, organizations, or 

individuals, as identified during scoping." The 2016 

"Next Horizon" study was provided to BLM by the 

applicant as a source of recent socio-cultural 

information for Nuiqsut. The publication notes that it 

was commissioned and funded by the applicant for the 

Kuukpik Corporation.
Supplemental Environmental Impact Statement

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

45

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L61-3 Kuukpik 

Corporation

Regardless of these new standards (NEPA page 

limits), it is patently unreasonable to ignore long 

term warming trends in the Arctic and the current 

and likely future effect of those trends on oil 

project designs and local Arctic communities. Any 

EIS document that refuses to acknowledge and 

analyze those changes is not only vulnerable to a 

legal challenge, it is ethically wrong, 

fundamentally flawed and of limited use to local 

stakeholders such as Kuukpik, our shareholders, 

and the residents of Nuiqsut.

3.7 Climate 

Change

In the GMT2 Supplemental EIS, the BLM tiers to and 

incorporates by reference previous NEPA analysis 

including the ASDP EIS (2004), the NPR-A IAP (2012) 

and the GMT1 SEIS (2014). CEQ regulations direct 

that: Agencies shall incorporate material into an 

environmental impact statement by reference when the 

effect will be to cut down on bulk without impeding 

agency and public review of the action. The 

incorporated material shall be cited in the statement 

and its content briefly described. No material may be 

incorporated by reference unless it is reasonably 

available for inspection by potentially interested parties 

within the time allowed for comment. (40 CFR 

1502.21). The text provided in the GMT2 SEIS 

incorporates by reference and summarizes the text 

from the GMT1 SEIS and includes updated information 

where such information was available (i.e., most up to 

date information on minimum sea ice extent). Our 

understanding of climate change and its effects on the 

Arctic are not significantly different than what is stated 

in the GMT1 SEIS. 
Supplemental Environmental Impact Statement

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

46

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L61-30 Kuukpik 

Corporation

It takes just a few facts to demonstrate that the 

possible impact of GMT2 on subsistence for 

Nuiqsut inevitably has a much greater bearing on 

virtually any resident's view of GMT2, shareholder 

or non-shareholder, than the information on which 

the Next Horizon and the Draft SEIS choose to 

focus. Consider that forty-four percent of the 

households in Nuiqsut share half or more of their 

subsistence harvest with other households, 

according to the Nuiqsut Profile subsection of the 

North Slope Borough's 2003 Economic Profile 

and Census Report. (p. 33) Thirty-six percent of 

Nuiqsut households substantially dependent on 

subsistence foods get half or more of their food 

through sharing by other households. Only 35 

percent of Nuiqsut households substantially 

dependent on subsistence foods got little or none 

of their subsistence foods through sharing. Only 

10 percent of the households in Nuiqsut would be 

unaffected by a decrease in sharing, and sharing 

is especially sensitive to harvest disruptions. 

While there are few general statements in the 

Draft SEIS on the importance of sharing 

subsistence resources, Kuukpik has not located 

anything like this level of detail of information in 

the text of the Draft SEIS-which is probably all 

that most users will read. The type of far more 

valuable and illustrative information on sharing 

that Kuukpik cites above is instead buried in two 

Appendices o the SEIS.40 This effectively omits 

that type of information for many users and makes 

the Draft SEIS affirmatively misleading.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

A more detailed discussion of the importance of sharing 

and participation has been provided in the Final SEIS. 

Statistics on participation and sharing (provided in 

Appendix F) have been updated to include data made 

available since the Draft SEIS was published, including: 

• 100 percent of households use subsistence food and 

over 90 percent attempt to harvest. 

• Community participation is highest for non-salmon 

fish (mainly broad whitefish), large land mammals 

(mainly caribou), and migratory birds. 

• 2014: 66 percent of Nuiqsut households participated 

in harvest of caribou (highest rate of harvest 

participation)

• 2016: 76 percent of Nuiqsut households participated 

in caribou hunting activities

• All available study years: 73 percent of Nuiqsut 

households attempt harvest of caribou 

Cultural Importance, measured quantitatively using 

data related to 2) sharing (percent of households 

receiving each resource).

• Sharing: between 70 and 92 percent of households 

receive caribou 

o 2014: 72 percent of households received caribou

o All available study years: 75 percent
Supplemental Environmental Impact Statement

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

47

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L61-31 Kuukpik 

Corporation

This sharing data is also far more illustrative of 

the community's concerns and attitudes as they 

relate to the possible impacts of GMT2 than the 

out-of-context disagreements on which The Next 

Horizon and then the Draft SEIS have chosen to 

focus. Consider, as well, the information in the 

first paragraph of this letter that approximately 90 

percent of the residents of Nuiqsut are 

shareholders in Kuukpik Corporation, are married 

to Kuukpik shareholders, or are descendants of 

Kuukpik shareholders (and will thus become 

shareholders of Kuukpik in the future through 

inheritance). With most housing in Nuiqsut 

consisting of three or more generations of a single 

family under a single roof due to Nuigsut's long 

term/long standing housing shortage, dividends to 

one generation support shareholders, their (often 

adult) children, and their grandchildren in the 

multi-generational households. Given the Inupiat 

cultural focus on sharing described and illustrated 

in the North Slope Borough statistics above, it is 

the Next Horizon and Draft SEIS focus on 

dissension and divisiveness and disagreement 

which is misleading and unrepresentative in 

describing the community of Nuigsut's view of the 

impacts of possible GMT2 development.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

One purpose of preparing a supplemental EIS is to 

provide updated information that did not exist when the 

original EIS was written. BLM NEPA Guidance 

regarding information to be used as part of the analysis 

does not specify any minimum requirements. BLM 

NEPA handbook states "Data and other information 

used to describe existing conditions and trends may be 

obtained from other documents and summarized and 

incorporated by reference or otherwise appropriately 

referenced. You may also obtain data and other 

information from cooperating agency partners or other 

agencies, organizations, or individuals, as identified 

during scoping." The 2016 "Next Horizon" study was 

provided to BLM by the applicant as a source of recent 

socio-cultural information for Nuiqsut. The publication 

notes that it was commissioned and funded by the 

applicant for the Kuukpik Corporation. A more detailed 

discussion of the importance of sharing and 

participation has been provided in the Final SEIS. 

Statistics on participation and sharing (provided in 

Appendix F) have been updated to include data made 

available since the Draft SEIS was published, including: 

• 100 percent of households use subsistence food and 

over 90 percent attempt to harvest. 

• Community participation is highest for non-salmon 

fish (mainly broad whitefish), large land mammals 

(mainly caribou), and migratory birds. 

• 2014: 66 percent of Nuiqsut households participated 

in harvest of caribou (highest rate of harvest 

participation)

• 2016: 76 percent of Nuiqsut households participated 

in caribou hunting activities
Supplemental Environmental Impact Statement

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

48

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L61-31

Continued

Kuukpik 

Corporation

See above for Comment 3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

• All available study years: 73 percent of Nuiqsut 

households attempt harvest of caribou 

Cultural Importance, measured quantitatively using 

data related to 2) sharing (percent of households 

receiving each resource).

• Sharing: between 70 and 92 percent of households 

receive caribou 

o 2014: 72 percent of households received caribou

o All available study years: 75 percent

L61-32 Kuukpik 

Corporation

A clear example of this gossip-based distortion in 

the Draft SEIS is the suggestion that possible 

differences in "land rental fees" rent paid to 

Kuukpik for portions of the GMT2 road in 

Alternative A vs. Alternative B might add to or 

detract from "multi-faceted conflict that the 

proposed GMT2 Project is causing in Nuiqsut "· 

This is nothing less than a suggestion that more 

rent to Kuukpik would exacerbate possible conflict 

between shareholders and nonshareholders in 

Nuiqsut. Let's get real. As discussed below, this is 

mere inaccurate conjecture. BLM doesn't know 

anything about rental payments Kuukpik receives. 

In fact, there is no difference in rent paid to 

Kuukpik if Alternative A were constructed vs. 

Alternative B. But even if there were such a 

difference, the idea that any rent paid to Kuukpik 

under one road-based Alternative vs. another, 

slightly different road-based Alternative would 

make any meaningful difference in dividends paid 

to shareholders is yet another overreaching and 

unsupported conjecture. It again illustrates the 

misleading and inaccurate focus of the Draft 

SEIS.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

BLM does not believe that the sociocultural systems 

analysis has a misleading and inaccurate focus: the 

analysis is drawn from numerous published sources 

and highlights the relative prevalence of concerns 

articulated by residents, whose comments have been 

recorded, transcribed, coded, and analyzed via 

numerous metrics. BLM mistakenly understood that 

Kuukpik would be able to charge surface rental fees for 

portions of infrastructure that would be constructed on 

Kuukpik Corporation land. Text has been revised to 

remove reference to surface use or rental payments to 

Kuukpik Corporation.
Supplemental Environmental Impact Statement

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

49

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L61-33 Kuukpik 

Corporation

The Draft SEIS' socio-cultural portrait manages to 

include descriptions of all kinds of such perceived 

rivalries, conflicts and infighting. Where is the 

detailed information on the far more critical 

aspects of the community that simultaneously 

make it vulnerable to oil development and also 

simultaneously provide some resilience? As the 

Alpine Satellite Development Project FEIS 

("ASDP FEIS") stated in 2005: “The sharing of 

subsistence foods is essential to the maintenance 

of family ties, kinship networks and community 

well being. 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.” his type of information is far 

more relevant to a discussion of the impacts of 

development of GMT2 on Nuiqsut than some 

conjectural and mistaken discussion about rents 

paid to Kuukpik or speculation on differences in 

attitude towards development between 

shareholders and non-shareholders. The entire 

community depends on subsistence, and impacts 

to subsistence are the primary concern of virtually 

all the Inupiat residents of Nuiqsut. As 

demonstrated above in the NSB's 2003 Economic 

Profile and Census Report data, those who do not 

subsistence hunt themselves get much of their 

daily food supply from sharing by the residents of 

Nuiqsut who are of an age and in good enough 

health that they do subsistence hunt.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

In response to efforts to tier to previous NEPA 

documents, important basic information such as this 

can be under-represented in supplemental analyses. 

The BLM agrees that this information on sharing and 

community participation is critical. The information was 

in the sections on subsistence and revised text includes 

this and updated data on the importance of the sharing 

network in Nuiqsut in the Final SEIS. A more detailed 

discussion of the importance of sharing and 

participation has been provided in the Final SEIS. 

Statistics on participation and sharing (provided in 

Appendix F) have been updated to include data made 

available since the Draft SEIS was published, including: 

• 100 percent of households use subsistence food and 

over 90 percent attempt to harvest. 

• Community participation is highest for non-salmon fish 

(mainly broad whitefish), large land mammals (mainly 

caribou), and migratory birds. 

• 2014: 66 percent of Nuiqsut households participated 

in harvest of caribou (highest rate of harvest 

participation)

• 2016: 76 percent of Nuiqsut households participated 

in caribou hunting activities

• All available study years: 73 percent of Nuiqsut 

households attempt harvest of caribou 

Cultural Importance, measured quantitatively using 

data related to 2) sharing (percent of households 

receiving each resource).

• Sharing: between 70 and 92 percent of households 

receive caribou 

o 2014: 72 percent of households received caribou 

o All available study years: 75 percent
Supplemental Environmental Impact Statement

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

50

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L61-34 Kuukpik 

Corporation

But equally important, what's the point of the Draft 

SEIS painting this particular picture of dissension 

and disagreement anyway? How, for example, is 

the history and process of trying to distribute 

Kuukpik shares to community members born after 

ANCSA was passed (which has not ever been 

discussed in any other North Slope NEPA 

documents that we are aware of) relevant to 

analyzing the potential impacts of GMT2? The 

Draft SEIS tries to make it relevant by concluding 

that there is "a degree of distrust due to this 

situation. The prospect of additional royalties 

accruing to Kuukpik Corporation from 

development of GMT2 could exacerbate this 

source of conflict." But this makes no sense 

whatsoever. As noted, over 90 percent of Nuiqsut 

residents are shareholders, are married to 

shareholders, or will inherit shares.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

The issue of potential concerns over perceived 

economic disparity between shareholders and nonshareholders was previously described in the SEIS for 

GMT1. BLM cannot disregard testimony from residents 

and BLM has been informed by some residents that 

this is a social and economic concern. BLM has edited 

the text in the Final SEIS to more accurately disclose 

that these are individual opinions that are not held by 

all residents. 
Supplemental Environmental Impact Statement

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

51

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L61-35 Kuukpik 

Corporation

This statement reflects even more ill-informed and 

misleading speculation. GMT2 royalties are not 

expected to be a particularly significant source of 

revenue for Kuukpik. The satellite reservoir that 

GMT2 would tap is largely located on lands not 

owned and that never will be owned by Kuukpik. If 

someone has told BLM that the prospect of GMT2 

royalties from a satellite oil field that is largely 

located on lands not owned by Kuukpik, not 

selected by Kuukpik, and that never will be owned 

by Kuukpik is weighing heavily on his or her 

opinion of whether or not GMT2 should be 

developed, that person is not only missing the 

forest for the trees in light of the sharing data on 

subsistence resources cited above, they are 

probably looking for a conflict that either doesn't 

exist or has little size or value. The Draft doesn't 

even conclude otherwise, merely stating that such 

revenues "could" matter to some people. Does 

that hypothetical concern really justify the Draft 

SEIS' speculative deep dive into Kuukpik's 

internal governance and some individual 

community members' opinion of it? In fact, does it 

serve any purpose other than to institutionalize 

and publicize someone's negative view of 

Kuukpik? Kuukpik thinks not, especially since this 

"issue" never featured in any other NEPA analysis 

by any public agency of any project on or near 

Kuukpik land or Nuiqsut.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

The economic and sociocultural systems sections of 

the Draft SEIS describe that Kuukpik has pursued 

benefits for all residents and represented the interests 

of the entire community with great success. The issue 

of some level of distrust (for some individuals) of the 

Kuukpik Corporation due to possible economic 

incentives to support development in general was 

disclosed in the 2015 GMT1 SEIS; this analysis also 

discloses it because BLM cannot disregard prevalent 

and repeated testimony from residents. BLM does not 

have specific information on nor does it speculate on 

Kuukpik's internal governance. The text has been 

edited to more accurately describe that Kuukpik reports 

that the corporation would most likely not be receiving 

significant royalties from production at GMT2. Kuukpik 

Corporation is encouraged to provide details on 

existing revenues and anticipated revenue sources so 

that the sections that should include this information 

(Economy, Sociocultural Systems, and ANILCA 810 

evaluation of the availability of other lands) can be 

more accurate. 
Supplemental Environmental Impact Statement

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

52

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L61-36 Kuukpik 

Corporation

In another area needing correction, Kuukpik was 

surprised to see the Draft SEIS suggesting that 

Kuukpik has already concluded that the 

sociocultural impacts from GMT2 will be 

"substantial". Kuukpik has not said that, and has 

not reached a final conclusion yet on the size and 

scope of the likely sociocultural impacts of GMT2. 

Kuukpik's GMT2 scoping letter (cited as the 

source for this claim) urged BLM to, among other 

things, carefully study the proposed GMT2 project 

and not simply rely on the 2004 Alpine EIS or the 

GMTl EIS. Kuukpik did point out that some 

impacts from Alpine have been greater than 

anticipated for a variety of reasons e.g., 

exceeding production expectations and the 

annual ice road that was not entirely anticipated). 

But the point of that information was to explain 

why the 2004 ASDP EIS is not a reliable predictor 

of GMT2's impacts, not to argue that all NEPA 

analyses under-estimate impacts on the 

community. Nor should the fact that Kuukpik has 

previously critiqued specific impact estimates be 

interpreted as an over-arching position that every 

oil project will, by definition, cause substantial 

negative impacts, or that BLM should start its 

analysis with that assumption in mind. BLM needs 

to eliminate the incorrect and speculative 

information from the socio-cultural impacts 

analysis and adequately discuss the critical 

subsistence issues described here.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Text has been revised to remove reference to 

Nukapigak and Kuukpik 2016 in Section 4.4.2.5.
Supplemental Environmental Impact Statement

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

53

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L61-37 Kuukpik 

Corporation

The Draft SEIS fails to adequately analyze the 

likely impacts the GMT2 Access Road would have 

on subsistence access and hunting patterns. 

Much like the more general conclusions 

discussed in the previous section, the Draft SEIS 

focuses heavily on potential negative impacts of 

the GMT2 Access Road without really evaluating 

its potential subsistence benefits. Some of the 

positive impacts are discussed below. But there 

are also negative impacts that the Draft SEIS 

does not identify or evaluate.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

The Draft SEIS discloses both potential benefits and 

potential negative impacts of the road and attempts to 

be succinct. Recent data on use of roads, gathered 

since the Draft SEIS was published, and verbatim 

testimony from hunters, has been included in the Final 

SEIS. 
Supplemental Environmental Impact Statement

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

54

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L61-38 Kuukpik 

Corporation

As to impacts not identified in the Draft SEIS, 

Kuukpik is gravely concerned that a new road 

extending farther west than any other permanent 

road in NPR-A could have the unintended 

consequence of encouraging more outsiders to try 

to drive street vehicles overland between Prudhoe 

Bay and Utqiagvik or Atqasuk, or to access or 

cross Kuukpik (and BLM) lands without benefit of 

ice roads or other accepted protection for the 

tundra and streams that these vehicles cross. 

This practice has increased significantly in the last 

couple of years, and Nuiqsut is beginning to see 

the impacts first hand as ill-prepared travelers get 

stuck on the tundra where Nuiqsut emergency 

personnel are often called to tow them out 

(leaving them unavailable to respond to 

emergencies). Several vehicles have been simply 

been abandoned after breaking down on a snow 

trail. The impacts of all this traffic have not been 

adequately analyzed in this or prior EIS efforts 

(even at current levels of traffic), but are only 

likely to increase if the GMT2 road is constructed. 

One of the drafts of the North Slope Borough's 

proposed 5 year plan to construct these snow 

trails suggested that users could hunt all along the 

trail-putting other North Slope residents and 

potentially members of the public from outside the 

North Slope into competition for subsistence 

resources on Nuiqsut's traditional subsistence 

range. This is one of Kuukpik's biggest concerns 

with the proposed road.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

These concerns of Kuukpik have been included in the 

Final SEIS. Kuukpik Corporation is encouraged to 

provide details on these impacts in order for the Final 

SEIS and future analyses to be accurate. The 

restrictions that should preclude access to both the 

Nuiqsut spur road and the oil field roads by outsiders 

are described in detail. The increasing demands on 

Nuiqsut Search and Rescue are also described. A 

potential new mitigation measure has been included in 

the Final SEIS that is responsive to this comment and 

to comments L87-4; L89-12 and 23; ATQ1-1; NQT9-45, 

57, 67, 71, and 72. Draft mitigation measure language 

(below) has been expanded to include these concerns.

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 

BLM encourages Nuiqsut to submit applications to the 

State of Alaska NPR-A Impact Mitigation Grant 

Program for funds for Search and Rescue.
Supplemental Environmental Impact Statement

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

55

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L61-39 Kuukpik 

Corporation

On the benefits side, such a road would create far 

easier access to new areas for Nuiqsut 

subsistence hunters. The Draft SEIS. however, 

makes no meaningful effort to analyze the scope 

of those potential benefits. Our scoping comments 

identified some specific questions that need to be 

addressed (even in estimate form) in order to 

flesh out the details of what building this road 

would mean for the community, which are set out 

in the accompanying footnote. But instead of 

answering those questions. the Draft SEIS begs 

off, substituting individual opinions and worst case 

hypotheticals for even a cursory analysis of data 

regarding subsistence practices and harvests 

since the completion of the Spur Road. 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

The Draft SEIS discloses both potential benefits and 

potential negative impacts of the road and attempts to 

be succinct. Recent data on use of roads, gathered 

since the Draft SEIS was published, and verbatim 

testimony from hunters, has been included in the Final 

SEIS. 
Supplemental Environmental Impact Statement

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

56

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L61-4 Kuukpik 

Corporation

Kuukpik and Nuiqsut depend on the NEPA 

process to provide an honest, unbiased analysis 

of the ways proposed oil and gas projects will 

impact our lands, our subsistence culture, and our 

future as a community. But this Draft SEIS doesn't 

do that because, among other things, it never 

confronts the reality that the Arctic climate is 

noticeably and rapidly warming. How can a 

document that so clearly conflicts with the 

experience of every community on the North 

Slope be accepted as credible and impartial? 

Worse, warming trends are already impacting the 

way that projects need to be designed. An oil 

industry project that doesn't factor warming trends 

into its design is highly likely to face real (and 

costly) problems later when the project has to be 

updated, expanded, or retro-fitted with design 

components that should have been identified 

during the NEPA process. Such omissions also 

mean that stakeholders (including the Corps in its 

effort to determine the Least Environmentally 

Damaging Practicable Alternative ("LEDPA") 

would not be getting an accurate description of 

potential impacts and consequences of the 

project.

3.7 Climate 

Change

In the GMT2 Supplemental EIS, the BLM tiers to and 

incorporates by reference previous NEPA analysis 

including the ASDP EIS (2004), the NPR-A IAP (2012) 

and the GMT1 SEIS (2014). CEQ regulations direct 

that: Agencies shall incorporate material into an 

environmental impact statement by reference when the 

effect will be to cut down on bulk without impeding 

agency and public review of the action. The 

incorporated material shall be cited in the statement 

and its content briefly described. No material may be 

incorporated by reference unless it is reasonably 

available for inspection by potentially interested parties 

within the time allowed for comment. (40 CFR 

1502.21). The text provided in the GMT2 SEIS 

incorporates by reference and summarizes the text 

from the GMT1 SEIS and includes updated information 

where such information was available (i.e., most up to 

date information on minimum sea ice extent). Our 

understanding of climate change and its effects on the 

Arctic are not significantly different than what is stated 

in the GMT1 SEIS. 

L61-40 Kuukpik 

Corporation

The issues described are legitimate, but the 

reasons cited in support of this conclusion are 

basically one side of a two-sided coin. "Direct 

overlap with a use area" for example, would apply 

to any development in Nuiqsut's subsistence 

range, and so isn't very helpful. Impacts to 

overland travel would be effectively limited to 

snowmachiners "not using the road, which is not a 

huge number of hunters now, and will be even 

fewer if the road is constructed since almost 

everyone wanting to access this area will take the 

road.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

The Draft SEIS discloses both potential benefits and 

potential negative impacts of the road and attempts to 

be succinct. Recent data on use of roads, gathered 

since the Draft SEIS was published, and verbatim 

testimony from hunters, has been included in the Final 

SEIS. 
Supplemental Environmental Impact Statement

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

57

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L61-41 Kuukpik 

Corporation

"Hunter avoidance" is a huge issue, and one that 

Kuukpik has described for years. But this 

sentence suggests that BLM has concluded that 

the road will cause more areas to be avoided ("by 

hunters who cannot or chose not to use the road") 

than to be made available and accessible (by 

those who use it). If that is BLM's conclusion, 

where is the calculation that supports it? Where 

are the estimates of current users of this area who 

will go elsewhere to avoid the road, so we can 

compare those estimates to new users who will 

use the road to access this and other areas to the 

west where they otherwise would not have gone? 

Where are the descriptions of the areas that will 

be more accessible if people can drive all the way 

to GMT2, so those can be compared to the areas 

close to the road, pipeline, and drill pad that will 

be avoided? The Draft doesn't contain any of that. 

So how can BLM conclude that the avoidance of 

the road and GMT2 facility will outweigh the 

improved access to other areas? Well, obviously 

BLM can make the conclusion because it did sobut the conclusion is wrong and needs to be 

corrected. In point of fact, the vast majority of 

adults and sub-adult licensed drivers in Nuiqsut 

have signed up to use the Nuiqsut Spur Road.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

The Draft SEIS discloses both potential benefits and 

potential negative impacts of the road and attempts to 

be succinct. Recent data on use of roads, gathered 

since the Draft SEIS was published, and verbatim 

testimony from hunters, has been included in the Final 

SEIS. The Draft SEIS did include updated discussions 

on avoidance, noting that 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.
Supplemental Environmental Impact Statement

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

58

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L61-42 Kuukpik 

Corporation

These impacts can and should also be mitigated 

significantly by including plenty of subsistence 

ramps along the GMT2 Access Road, and by 

designing those ramps to be long and wide 

enough to allow safe ingress and egress to and 

from the Road. The Draft doesn't seem to put 

much faith in that mitigation measure, but 

Kuukpik's experience is that they are quite 

effective for facilitating road crossings and use, 

and will only become more so as design features 

are improved and incorporated that make them 

safer and more effective for users. 

4.2 Mitigation Subsistence ramps in three locations are included as a 

design feature of Alternatives A and B. BLM is also 

considering a proposed mitigation measure that would 

allow input from the community on the ramp design to 

ensure they are effective (See Potential Mitigation 

Measure 7, Section 4.4.5.6.

L61-43 Kuukpik 

Corporation

The rest of the reasons supporting BLM's 

conclusion are a mix of speculation and a laundry 

list of negative impacts that are not actually 

associated with the road this paragraph is 

supposed analyze. There is no evidence 

supporting BLM's speculation that access to 

subsistence ramps will eventually be restricted ... 

due to tundra damage." Use of subsistence ramps 

has never been restricted at any other road to 

Kuukpik's knowledge. This isn't to say it's 

impossible to imagine a scenario where some 

usage rules would become necessary, but this is 

speculation.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

BLM is required to evaluate potential impacts that are 

reasonably likely to occur over the 30-32 year life of the 

project. Repeated passes in a single location 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. Over the course of 3 decades, it is 

reasonable to anticipate that these effects could 

eventually increase the risk and reduce the feasibility of 

overland access by four-wheeler in the area via the 

ramps. Evidence is provided by the numerous citations 

included in section 4.1.2.5. 
Supplemental Environmental Impact Statement

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

59

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L61-44 Kuukpik 

Corporation

The remaining laundry list is less speculative, to 

be sure, but simply lists impacts associated with 

developing GMT2 generally ("hazards, dust, road 

and aircraft traffic, noise, emissions, ice fog, and 

localized deflection of caribou and furbearers"). 

All of these are real issues, but not all of them are 

even related to the Access Road (e.g., aircraft 

traffic) or limited to Alternatives A and B. 

Moreover, it's not clear how the magnitude of 

these negative impacts would compare to the 

potential benefits from improvements in 

subsistence access created by the GMT2 Access 

Road. 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

The Draft SEIS discloses both potential benefits and 

potential negative impacts of the road and attempts to 

be succinct. Recent data on use of roads, gathered 

since the Draft SEIS was published, and verbatim 

testimony from hunters, has been included in the Final 

SEIS. 

L61-45 Kuukpik 

Corporation

The most obvious flaw in this part of the analysis 

is the failure to acknowledge and explore the 

developing information on how subsistence users 

are beginning to use roads around Nuiqsut and 

how they might use the GMT2 Access Road. 

Although the Draft acknowledges in a few 

sentences that access to the west "would 

increase" if a road is built to GMT2, it doesn't 

make any effort to quantify whether and how use 

would increase. This is in spite of recent studies 

by Stephen Braund & Associates that note the 

increase in hunting caribou through Spur Road 

access to the CP AI road system. The Draft 

should be describing in detail the areas that would 

be accessible by vehicle, how many "new" trips 

would be expected if road access was available, 

and whether those areas would be (or become) 

productive hunting areas. 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

The Draft SEIS discloses both potential benefits and 

potential negative impacts of the road and attempts to 

be succinct. Recent data on use of roads, gathered 

since the Draft SEIS was published, and verbatim 

testimony from hunters, has been included in the Final 

SEIS. 

L61-46 Kuukpik 

Corporation

GMT2 DSEIS, p. 111 ("Traffic is restricted on 

unfrozen ground in the NPR-A.") What restrictions 

is this referring to? 

3.7 Climate 

Change

The text is referring to NPR-A IAP ROD Best 

Management Practice C-2(a): Ground operations shall 

be allowed only when frost and snow cover are at 

sufficient depths to protect the tundra.
Supplemental Environmental Impact Statement

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

60

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L61-47 Kuukpik 

Corporation

Instead, the Draft focuses on access issues that 

are not important or which are overwhelmingly 

negative. The main section that should address 

the questions that Kuukpik posed above (and 

many more) ("User Access" and "GMT2 Access 

Road", pp. 430-434) instead first generalizes 

about the role of roads in general (opining that 

they are less important than rivers-except, 

apparently, the so-called "critical" Colville River 

Access Road), before moving on to describe 

various use restrictions that apply on the Spur 

Road and others that might apply to the GMT2 

Access Roads (several of which are not likely to 

be adopted and which are hardly important 

enough to consume a quarter of this discussion). 

This part of the discussion then concludes that 

"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. "

Much like the Draft's later conclusion that "some 

hunters are using [the Spur Road] and some are 

avoiding it," this cursory summation is misleading 

because it suggests that there about as many 

people who don't benefit from the Spur Road as 

those who do (i.e., "some hunters" in each camp). 

That's simply not true, since some 75-80 percent 

have such access, and the others can get that 

access without out-of-pocket cost. Vastly more 

subsistence users use the Spur Road than not. 

BLM's speculative conclusions to the contrary 

erroneously downplay the community-wide 

benefits of the Spur Road. 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

There are several reasons that preliminary data on the 

benefits of increased access provided by the Spur 

Road should not be used to predict the impacts of the 

GMT2 road. Data gathered by SRB&A that was 

available for the Draft SEIS on use of the Spur Road 

reflects hunter reports on uses of the Spur Road before 

there was any development northwest or west or of it 

(i.e., the GMT1 road or proposed GMT2 road), and the 

roads themselves are different. The Final SEIS 

includes the most recent data on the facilitated access 

provided by industry roads and it is used to more 

accurately predict the effects of the GMT2 road. The 

Draft SEIS discloses both potential benefits and 

potential negative impacts of the road and attempts to 

be succinct. Recent data on use of roads, gathered 

since the Draft SEIS was published, and verbatim 

testimony from hunters, has been included in the Final 

SEIS. 
Supplemental Environmental Impact Statement

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

61

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L61-48 Kuukpik 

Corporation

BLM justifies the decision not to go into detail on 

the benefits of the Spur Road and its connection 

to the Alpine Road system (and therefore to a 

GMT2 Access Road) on the basis that there isn't 

enough hard data yet to reach any firm 

conclusions about its impacts. That won't fly for a 

number of reasons. First of all, a lack of data 

didn't keep BLM from hypothesizing about other 

subsistence impacts. The fact that the Draft 

includes unsupported information critical of the 

Spur Road suggests that BLM is not applying the 

same standard to anecdotal information on 

potential impacts that "fit" with the Draft's 

seemingly negative perspective on Spur Roadenabled road use for subsistence purposes. If 

anecdotal information is enough to give BLM 

confidence to discuss perceived negative impacts 

of the Spur Road (and, by implication, a potential 

GMT2 Road), then the EIS should also include 

anecdotal information about the successes of the 

Spur Road, not stay silent until studies finish 

confirming what the people in Nuiqsut are seeing 

with their own eyes.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

The Draft SEIS discloses both potential benefits and 

potential negative impacts of the road and attempts to 

be succinct. Recent data on use of roads, gathered 

since the Draft SEIS was published, and verbatim 

testimony from hunters, has been included in the Final 

SEIS. 
Supplemental Environmental Impact Statement

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

62

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L61-48

Continued

Kuukpik 

Corporation

FOOTNOTE: An example is the Draft's statement 

that "While construction of the road is too recent 

to document changes in caribou movements via 

multi-year collar or harvest data, Nuiqsut hunters 

and Native Village of Nuiqsut (NVN) Tribal 

Council members reported reduced availability of 

caribou south of the CDS road (NVN Council 

Member, 2017)." GMT2 DSEIS, Appx. L, p. 251. 

In other words, even though there is no data to 

document a decrease in caribou resources in the 

Spur Road area, the Draft includes anecdotal 

information suggesting such a decrease is 

happening. Moreover, that statement is not 

consistent with our experiences last winter when 

caribou were abundantly present in the area south 

of the CDS road and west of the Spur Road.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

See above for BLM Response
Supplemental Environmental Impact Statement

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

63

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L61-49 Kuukpik 

Corporation

But critically, now that the Spur Road has been 

operational for a couple of years, there actually is 

some data to interpret. The latest information from 

SRB&A (from 2017) showed a shift in hunting 

patterns to areas accessible from the Spur Road, 

and to a lesser extent, the CD5 road. This 

evidence is certainly not conclusive, nor does it 

guarantee (by any means) that people will use the 

GMT2 Access Road. But it certainly supports the 

conclusion that Kuukpik has reached (based on 

the observations of its Board, their households 

and families) that the Spur Road is fast becoming 

a significant component of Nuiqsut subsistence 

practices. This makes sense from an economic 

perspective because the Spur Road gives people 

the option of hopping in their trucks and driving 

north from Nuiqsut on a safe gravel road to look 

for caribou. So far, the road (which is much 

narrower than most industry or public roads) has 

not proven to be a major impediment to caribou 

movement, so hunters have had great success 

finding game within sight of the road (on both 

sides). This is a major benefit because shorter 

trips on roads save time and money, and are 

much safer, which is especially important for 

younger families with young children and potential 

day care issues. When hunters don't find 

resources right along the Spur Road, they can 

either keep going (often west towards GMT1) or 

come back to the village and try again another 

time. Both are better options than existed prior to 

the Spur Road.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

The Draft SEIS discloses both potential benefits and 

potential negative impacts of the road and attempts to 

be succinct. Recent data on use of roads, gathered 

since the Draft SEIS was published, and verbatim 

testimony from hunters, has been included in the Final 

SEIS.
Supplemental Environmental Impact Statement

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

64

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L61-49

Continued

Kuukpik 

Corporation

This potential shift towards increasing road usage 

by subsistence hunters, in fact, is one of the most 

significant evolutions in the environment and

subsistence landscape since 2004, and it is one 

that the Final SEIS should therefore look at much 

more closely and strive to present a fair picture of. 

The decision to treat the impacts of the Spur 

Road as if they are simply unknown leaves this 

analysis woefully short on specific information that 

would allow us and BLM to evaluate the potential 

impacts of a road to GMT2.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

See above for BLM response
Supplemental Environmental Impact Statement

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

65

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L61-5 Kuukpik 

Corporation

There is another large problem with the Draft 

SEIS. NEPA also isn't the background for some 

reality TV show. Unfortunately, portions of the 

Draft seem to treat it that way by focusing on 

conflict and rivalries - real or perceived - that have 

no business being in an EIS. Relying heavily on a 

publication that was literally written by TV 

producers, not scientists or sociologists, the 

socio-cultural impacts analysis in particular seems 

to be an effort to describe and dramatize the 

entire social and emotional fabric of Nuiqsut. The 

result is a gossipy, subjective, and anecdotal 

description of individual and conflicting opinions 

on a wide range of issues, and speculation that 

lacks the kind of data and science that is normally 

the basis of such EIS evaluations. Instead of 

contributing to the EIS analysis, all this type of 

information does is institutionalize town gossip 

and perpetuate conflicts that Kuukpik and other 

community organizations would rather heal than 

stoke. That some of this information (particularly 

from The Next Horizon) is factually wrong and 

none of it is relevant to the potential impacts of 

constructing a development at GMT2 simply 

confirms that this socio-cultural analysis needs to 

be drastically revised. The Final SETS needs to 

pay more attention to substantive impacts, and 

less to gossip and innuendo that do not provide 

any meaningful insight into understanding the 

likely impacts of GMT2.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

One purpose of preparing a supplemental EIS is to 

provide updated information that did not exist when the 

original EIS was written. BLM NEPA Guidance 

regarding information to be used as part of the analysis 

does not specify any minimum requirements. BLM 

NEPA handbook states "Data and other information 

used to describe existing conditions and trends may be 

obtained from other documents and summarized and 

incorporated by reference or otherwise appropriately 

referenced. You may also obtain data and other 

information from cooperating agency partners or other 

agencies, organizations, or individuals, as identified 

during scoping." The 2016 "Next Horizon" study was 

provided to BLM by the applicant as a source of recent 

socio-cultural information for Nuiqsut. The publication 

notes that it was commissioned and funded by the 

applicant for the Kuukpik Corporation.
Supplemental Environmental Impact Statement

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

66

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L61-50 Kuukpik 

Corporation

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. And while the DSEIS correctly notes 

that there will be some modest economic benefits 

to the community due to 

Kuukpik and ASRC's interests in the oil to be 

produced at GMT2, most of those benefits will not 

be substantial, direct, or immediate enough to 

meaningfully impact those most affected by the 

development. BLM and others must therefore 

continue to promote and foster other ways to 

allow the Native community to share in some of 

the rewards from drilling at GMT2. 

FOOTNOTE: We therefore have to disagree with 

what seems to be the Draft SEIS's more optimistic 

view of the potential benefits that Kuukpik and 

ASRC shareholders will receive from this project, 

much less the idea that "the GMT2 project is 

partly driven by'' these entities. GMT2 DSEIS, p. 

459. Kuukpik owns a small over-riding royalty in 

some of the oil that will be produced at GMT2. 

That royalty interest does not give us any say 

over whether and how the project will be 

constructed or operated. ASRC's ownership 

interest is larger, but is also a passive one 

nonetheless. Neither of these corporations is 

"driving" the GMT2 project. So while the 

environmental justice analysis may be 

"particularly complex," it's not because this project 

is anything other than a typical "outsider-driven 

industrial activity." GMT2 DSEIS, p. 459.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

This input has been included in the economic and 

sociocultural systems section of the Final SEIS. 
Supplemental Environmental Impact Statement

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

67

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L61-51 Kuukpik 

Corporation

The Draft SEIS acknowledges in passing that the 

collapse of oil prices in 2015 has resulted in 

severe cuts in public funding (p. 169-70 and 176-

77), but fails to emphasize the extent to which 

these changes have impacted rural communities 

more than any other. Services that used to be 

funded or partially funded by the State are now 

gone or are being provided by other sources, like 

the local village corporations. These costs can 

easily offset some of the potential income a 

company like Kuukpik stands to receive from 

development on its land, even with oil prices rising 

(for now). Residents are also feeling the pain 

directly. Shareholder dividends have been cut 

along with those from the State Permanent Fund. 

Those dividends often make up a much larger 

percentage of household incomes in rural 

communities than they do elsewhere, so these 

losses hurt even more in places like Nuiqsut. 

3.16 Economy Section 3.4.4. notes that declining state revenues have 

resulted in cuts to public spending that have affected 

many Alaskans. Section 3.4.4.2 discusses reduction in 

dividends for ASRC. Section 3.4.4.3 discusses 

dividends from Kuukpik and ASRC focused on Nuiqsut. 

Without specific information on Kuukpik's profits and 

dividends, the BLM cannot accurately discuss the local 

impacts of the 2015 decline in oil prices. 

L61-52 Kuukpik 

Corporation

Kuukpik has talked for years about the need to try 

to mitigate these disproportionate impacts by 

positioning more locals to be able to obtain oilfield 

services jobs, particularly year round jobs that can 

truly impact an entire family and its standard of 

living. Kuukpik itself has created dozens of yearround and seasonal job for shareholders in 

Nuiqsut, Anchorage, and throughout the Alpine 

and Kuparuk oil fields.66 But subsistence needs 

and other barriers to entry have prevented many 

residents from obtaining or holding the most 

coveted jobs. Consequently, it remains critical for 

BLM to analyze and proliferate measures that can 

bring financial benefits to the community. We 

recognize, as the Draft emphasizes (repeatedly), 

that BLM doesn't have authority over certain 

aspects of the project that might advance that 

goal.

3.16 Economy Section 3.4.4.3 of the DEIS discusses the Nuiqsut cash 

economy including employment generally and related 

to oil and gas activities. Section 4.4.3.1 discusses 

employment impacts associated with construction of 

GMT2 including recognizing opportunities for Nuiqsut 

and other North Slope Borough communities. This 

analysis anticipates local employment impact to be 

similar to past projects. As noted in the comment, the 

BLM lacks authority related to hiring decisions made by 

the proponent and other affected businesses. However, 

the BLM does encourage that the local communities 

work with business to identify opportunities for increase 

workforce participation by local residents.
Supplemental Environmental Impact Statement

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

68

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L61-53 Kuukpik 

Corporation

One of our biggest concerns is the NPR-A 

Mitigation Fund situation. Despite professing no 

ability to influence the use of these funds, BLM 

describes the program fairly comprehensively. 

What it fails to mention is the depth of the

community's dissatisfaction with how that program 

has functioned towards Nuiqsut over the last 

several years. These funds are supposed to be 

prioritized and distributed to the communities 

most directly or severely impacted by oil and gas 

development. Frankly, that means the City of 

Nuiqsut should be at the head of the line every 

time. Nuiqsut lies in the heart of the most active 

(and growing) oil and gas fields on the North 

Slope. It is far and away the community most 

affected by oil development on the North Slope to 

date...

Considering the far lesser direct impacts which 

those communities have suffered and the 

staggering amount of revenue the Borough in 

particular receives from oil development, 69 BLM 

and the State need to make it a priority to 

distribute more of these funds to Nuiqsut. 

3.16 Economy Revised and incorporated updated information for 

section on "Local Economy: Community of Nuiqsut" 

and oil and gas operations impacts.

L61-54 Kuukpik 

Corporation

Instead, at least as of a year or so ago, the State 

had apparently put the City of Nuiqsut in a nearly 

impossible situation that has long prevented/is 

preventing it from actually receiving a more 

proportionate and appropriate share of NPR-A 

Impact Fund grants. Though Kuukpik has been 

told by City of Nuiqsut representatives that the 

information below from the Draft SEIS contains 

inaccuracies and that a correction is expected to 

be provided to BLM by the City... This information 

is over a year old and apparently some of it is 

outdated, so it needs to be 

corrected in the Final SEIS. 

3.16 Economy Revised and incorporated updated information for 

section on "Local Economy: Community of Nuiqsut" 

and operation impacts.
Supplemental Environmental Impact Statement

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

69

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L61-55 Kuukpik 

Corporation

The Draft SEIS suggests CPAI "evaluate" several 

potential mitigation measures that would reduce 

emissions further but which so far appear not to 

be part of the project. It's not clear whether these 

measures are just a suggestion, or something that 

CPAI is being required to study and implement if 

feasible, but Kuukpik believes the Final SEIS 

should analyze the most critical of these so that 

the responsible agencies (whether BLM or 

otherwise) can determine whether to impose 

stipulations that will prevent unnecessary 

degradation of air quality. These measures 

include at least the following (omitting some 

additional measures that are effectively legal 

requirements already, such as a leak detection 

program): 

1. Use of Tier 4 engines for ALL drilling activities 

until the rigs can be operated using high line 

power. The recent successful drilling with such 

generators at Putu 2 confirms that these low 

emission generators need to become the new 

operating standard on the North Slope.

2. implement high quality monitoring systems that 

can be monitored remotely. CPAI should make 

every effort to construct equipment and 

production monitoring systems that can be 

automated and monitored from GMTl (or 

wherever is feasible) so that the number of routine 

manned vehicle trips for monitoring purposes can 

be reduced. 

3. Onsite air quality monitoring at GMT2. CPA 

must conduct real time air quality monitoring at 

the GMT2 site, and have protocols in place for 

shutdown ( or "warm shutdown") when certain key 

threshold emissions are exceeded or about to be 

exceeded.

3.5 Air Quality & 

Meteorology

These mitigation measures were included in the Final 

SEIS for consideration as mitigation measures in the 

Record of Decision. Modeling was updated to assume 

a 35 mph speed limit. 
Supplemental Environmental Impact Statement

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

70

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L61-55

Continued

Kuukpik 

Corporation

4. Enforce a speed limit of 20 MPH on the 

Access Road and 5 MPH onsite. This measure is 

necessary because these speed limits were 

assumed for purposes of the AQM (p. 289). 

Because higher speeds would affect the 

calculation of fugitive dust and possibly other 

emissions, these speed limits must be observed. 

In short, given the community's extreme concern 

and sensitivity to air quality issues in the village, 

CPAI has every incentive to implement these 

practical mitigation measures (in addition to those 

that would be legally required anyway) in order to 

reduce the risks further and demonstrate to the 

community that it is willing to take the steps 

needed to help the community feel more 

comfortable with its operations in this area.

3.5 Air Quality & 

Meteorology

See above for BLM response

L61-56 Kuukpik 

Corporation

Page 2, Introduction: This section states that only 

exploration drilling has occurred in the GMT Unit. 

This information may be out of date. Kuukpik 

believes the first or possibly second development 

well is currently being drilled at GMT l.

1.1 Executive 

Summary & 

Introduction

The BLM reviewed and revised this section to make 

sure it is up to date. 

L61-57 Kuukpik 

Corporation

Page 12, Table 1.4-1, Key permits, approval, and 

other requirements for GMT2: This table does not 

list the DOI ANCSA Corporation Consultation 

Policy signed by Ken Salazar on August 10, 2012.

1.1 Executive 

Summary & 

Introduction

The BLM added the DOI Policy on consultation with 

ANCSA corporations to Table 1.4-1.

L61-58 Kuukpik

Corporation

Page 23, Table 2.1-1, Summary of changes in the 

GMT2 Project Over Time: This table refers to 

three 1.2 acre subsistence pullouts. This appears 

to conflict with Table 2.3-2 (pp. 29-30), which 

states that the total acreage for all three 

subsistence pullouts is 1.2 acres. Kuukpik 

believes Table 2.1-1 needs correction.

2.1 Proposed 

Action & 

Alternatives

Table updated to reflect 1.2 acres total for all three 

pullouts.
Supplemental Environmental Impact Statement

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

71

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L61-59 Kuukpik 

Corporation

Pages 34-35, Ice Roads: The last sentence in the 

first passage reads: .. The ice road length for 

GMT2 will be approximately three times longer 

than the ice road needed for CD3, which will 

result in a 20 percent decrease in the useable ice 

road season." How was this determined? The 

length of an ice road does not directly equate to 

the useable ice road season (though a warming 

climate does). BLM should more fully explain the 

conclusion that the GMT2 construction ice road 

season will be limited to about 80 days.

2.1 Proposed 

Action & 

Alternatives

Text has been revised to clarify assumptions regarding 

the length of the ice road season. "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."

L61-6 Kuukpik 

Corporation

From Kuukpik's perspective, the most important 

issues that need to be covered are, first, the 

potential impacts this project will have on 

subsistence activities and, second, the ways the 

project can provide offsetting benefits to those 

most affected: the residents of Nuiqsut.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

This input has been included in the economic and 

sociocultural systems section of the Final SEIS. 

L61-60 Kuukpik 

Corporation

Page 37, Water Use and Page 44, Roads, Ice 

Roads and Pads (Table 2.5-2): These passages 

indicate that a IO-acre ice pad (requiring 2.5 

million gallons of water) is planned under all 

alternatives. Why is this pad required since there 

will be a permanent gravel pad to support drilling 

operations? This is not how drilling at Alpine 

(including CDS and GMTl) is routinely conducted.

2.1 Proposed 

Action & 

Alternatives

Text has been revised to explain the purpose of the ice 

pad for the drilling period. CD3, CD5 and GMT1 have 

all used a similar setup to reduce the acreage of the 

permanent gravel pad.

L61-61 Kuukpik 

Corporation

Page 45, Vehicle Traffic: The table in this section 

states that 9,000 one way trips to or from GMT2 

will be needed for years 3-10. That's 4,500 round 

trips annually or 12.3 round trips per day. This 

seems a bit low in view of the drilling and 

production activities that would be occurring 

during this time frame. This comment also applies 

to Alternative B.

2.1 Proposed 

Action & 

Alternatives

The information presented in Table 2.5-3 regarding 

vehicle traffic for Alternative A represents the estimated 

number of vehicle trips based on the actual number of 

trips that occurred during these same phases of drilling 

and operations at similar locations, such as CD4.
Supplemental Environmental Impact Statement

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

72

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L61-62 Kuukpik 

Corporation

Page 45, Aircraft Traffic: This section states there 

will be between 5 and 15 flights per month for 

crew changes during construction. This estimate 

seems low since Alpine has these numbers of 

flights during non-construction season. If these 

are additional flights over the current baseline, the 

document should state that. 

2.1 Proposed 

Action & 

Alternatives

Text has been revised to clarify that the estimated 5-15 

fixed wing flights per month are additional, resulting 

from construction of GMT2.

L61-63 Kuukpik 

Corporation

Pages 46-47, Camps: There is no reference to the 

Arctic Wolf Camp (owned by Kuukpik) in Nuiqsut 

which is opened seasonally as needed. This 

section also describes the "Kuukpik Camp" as 

being located on Kuukpik's 10 acre pad, which is 

not correct. This comment also applies to 

Alternatives B and C.

2.1 Proposed 

Action & 

Alternatives

Edits have been made to the text to indicate that the 

Arctic Wolf Camp located in Nuiqsut is anticipated for 

use by the applicant during the ice road season, and 

what is referred to as the GMT2 Temporary 

Construction Camp located on the Kuukpik Pad near 

the confluence of the Kuukpik Spur Road and the CD5 

Road will be utilized year-round during construction.

L61-64 Kuukpik 

Corporation

Page 71, Alpine Spill History: How can 0.7 spills 

(of hazardous substances) due to human

factors be correct?

3.19 Hazardous 

Materials Spills

Table 3.1-1 presents the volume of substances spilled 

by cause, not the number of spills. There were 0.7 

gallons of hazardous substances spilled due to human 

factors over the time period evaluated. Added "gallons" 

after numbers in the table to clarify.

L61-65 Kuukpik 

Corporation

Page 116, Fish Species: Why isn't the ongoing 

ABR study of Arctic cisco included as part of

the industry conducted surveys, particularly since 

there is a later reference in this section to large 

numbers of Arctic cisco being captured in the 

lower Colville River?

3.9 Fish Text and references were added to include the Colville 

River fall fishery monitoring work.

L61-66 Kuukpik 

Corporation

Page 171, Regional Economy-North Slope 

Borough: ENI's Nikaitchuq project is not currently 

suspended as far as Kuukpik knows. There is no 

reference to Armstrong's Horseshoe exploration, 

which was reported (in the spring of2017) to be 

another large find in the Nanushuk formation.

3.16 Economy Revised text. Horseshoe is listed in the cumulative 

effects table and considered in the analysis. 
Supplemental Environmental Impact Statement

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

73

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L61-67 Kuukpik 

Corporation

Page 174, Local Economy-Community of Nuiqsut: 

Neither Kuukpik/Carlile nor Nanuq are

'Joint ventures" as stated here. Kuukpik/Carlile no 

longer exists. Nanuq is a wholly-owned

Kuukpik subsidiary, like Kuukpik Drilling, which is 

not listed. The information in the third

paragraph is also a bit outdated since it is from 

2015.

3.16 Economy Revised to update description of contracts. Added most 

recent employment information (2016) from Alaska 

Labor & Workforce Development.

L61-68 Kuukpik 

Corporation

Page 177, Land Use: The last sentence on this 

page needs revision and/or correction.

3.17 Land Use Reworded and recalculated acres and made correction.

L61-69 Kuukpik 

Corporation

Page 178-79, Local Transportation, Recreation, 

and Visual Resources: All of these sections

incorrectly refer to the City of Nuiqsut as the 

Native Village of Nuiqsut.

3.17 Land Use Corrected.

L61-7 Kuukpik 

Corporation

On subsistence, the primary impacts of GMT2 are 

likely to be ( l) avoidance of both the footprint 

where GMT2 would be constructed and the 

couple of miles around it that typically becomes 

effectively off-limits to subsistence users, and (2) 

indirect impacts that may result from constructing 

the project in an important migration corridor. Both 

of these impacts, however, may be 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 it will expand 

the network of roads farther west and south of 

town, further encircling (literally) the community 

with roads.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

This input has been included in the economic and 

sociocultural systems section of the Final SEIS. 
Supplemental Environmental Impact Statement

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

74

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L61-70 Kuukpik 

Corporation

Page 242, Physiography and 

Geomorphology/Soils and Permafrost -Drilling 

and Operation: The last two full passages on this 

page discuss impacts from subsistence users and 

four-wheelers. There is no discussion about 

industry off-road traffic in non-frozen conditions. 

Industry often uses Tuckers, rolligons, and other 

ADNR-approved summer tundra travel vehicles 

for a variety of purposes (e.g. study work, permit 

conditions, etc.). There should be a discussion of 

industry uses of tundra travel during non-frozen 

conditions and the potential impacts. The tundra 

damage near the ASRC Mine Site caused by 

rolligons several years ago is a prime example of 

the tundra impacts that can result from industry 

during non-frozen conditions.

3.2 Soils & 

Permafrost

Industry use of off road vehicles and machinery is 

limited to frozen conditions except for emergency 

response situations. use during non-frozen periods is 

likely to have long lasting effects on tundra including 

the potential for thermokarst due to the loss of 

insulation. This type of damage takes many decades 

or more to recover.

L61-71 Kuukpik 

Corporation

Page 260, Construction, Drilling and Operation: 

Cross-drainage culverts are typically 24 inches in 

diameter, not 48 as indicated here. Note that the 

source of the proposed 48 inch cross-drainage 

culverts was from 2004.

3.4 Water 

Resources

The sentence was modified to reflect the standard 24 

inch size.

L61-72 Kuukpik 

Corporation

Page 328, Fish -Construction, Ice Roads and 

Pads: CPAI should be required to conduct in

season monitoring at the Ublutuoch crossing if the 

ice road is constructed near the permanent 

bridge.

3.9 Fish The permanent bridge across the Ublutuoch River and 

the river reaches immediately upstream and 

downstream are not on BLM land, so the BLM cannot

require monitoring there.

L61-73 Kuukpik 

Corporation

Page 330, Fish, Table 4.3-6: The last line in this 

table for Alternative C states that diesel and 

mineral oil pipelines may be needed. Why is 

mineral oil needed at the drill site?

3.9 Fish See 2.7.3 Drill Pad and Support Facilities. Mineral oil is 

a component of the "muds make-up". Under a roadless 

alternative, mineral oil would be piped in rather than 

flown in. 

L61-74 Kuukpik 

Corporation

Page 332, Fish-Mitigation: Did CPAI conduct the 

hydrology and fish studies required by BMP E-14 

to determine the anticipated impacts of the 

proposed culverts at the stream crossing on the 

access road to GMT2?

3.9 Fish BMP E-14 does not apply to the M9925 outlet, as the 

"stream" at the road crossing is not channelized, but is 

a wetland/marsh. As such, BMP E-6 applies and 

requires that culverts placed in that section allow for 

natural drainage patterns and fish passage.
Supplemental Environmental Impact Statement

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

75

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L61-75 Kuukpik 

Corporation

Page 351, Terrestrial Mammals -Construction, 

Mortality or Injury: This section hypothesizes that 

increased use of the developed road system by 

local hunters under Alternatives A and B could 

increase "mortality of caribou, moose, muskoxen, 

or grizzly bears". This assertion should be deleted 

or acknowledge that instances of residents killing 

animals with vehicles is extremely rare. The 

likelihood that locals would hit moose, muskoxen 

or grizzly bears is even lower.

3.12 Mammals 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. Verbiage updated to be 

more clear. 

L61-76 Kuukpik 

Corporation

Page 353, Terrestrial Mammals -Drilling and 

Operation, Aircraft: This section states 

"Alternatives A and B would require 540 

helicopter flights (90/year) for drilling and 2070 

helicopter flights (90/year) for operations." Why 

are so many helicopter flights needed for drilling 

and operations for a road connected drill site?

2.1 Proposed 

Action & 

Alternatives

Helicopter flights during drilling and operations will 

support required monitoring and studies in the GMT2 

project area, and may be used for other activities such 

as placing spill response equipment. For analysis 

purposes, an additional 15 flights were included above 

the estimated amount in order to ensure potential 

impacts were adequately identified in Chapter 4.

L61-77 Kuukpik 

Corporation

Page 359, Marine Mammals: How was it 

concluded that spotted seals, bearded seals, and

beluga whales may occur in the project area?

3.12 Mammals The marine mammals identified in the document are 

species 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 in the project area.

L61-78 Kuukpik 

Corporation

Page 400, Table 4.4-4 Projected crude oil 

production: It should be noted that production 

from Pikka (Oil Search), Willow (CPAI), and 

Liberty (Hilcorp) and others (e.g., Nuna, Putu, 

Smith Bay, Horseshoe, Stony Hill, etc.) is not 

included in this table.

3.16 Economy Total Alaska North Slope production numbers were 

updated with the most current projections from the 

Alaska Department of Revenue.

L61-79 Kuukpik 

Corporation

Page 411, 4.4.3 Recreation -Construction: Who is 

the "one special recreation permittee

(wildlife and nature viewing) authorized to conduct 

activity in the GMT2 area"? Is he or she

aware of Kuukpik-owned and selected lands in 

the area?

3.17 Land Use We always inform our permittees that we only authorize 

lands that are managed by BLM and have no authority 

over non BLM Managed land. Permittees are also 

notified when there are such lands.
Supplemental Environmental Impact Statement

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

76

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L61-8 Kuukpik 

Corporation

Kuukpik doesn't think that psychological hurdle is 

immutable, however. Subsistence hunters are 

practical people. We believe the tangible benefits 

offered by increased access along the GMT2 road 

could ultimately reduce many Nuiqsut residents' 

traditional reluctance to use oil and gas 

infrastructure such as in-field roads 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. Recent caribou monitoring 

and harvest data confirm this trend. So it's not at 

all clear why the Draft SEIS isn't acknowledging 

those changes, and more importantly, trying to 

analyze and estimate how the changes will impact 

subsistence practices over time if and when 

additional roads are constructed. By treating 

those impacts as if they are completely unknown 

(and currently unknowable), the analysis is 

completely skewed because we cannot compare 

the potential negative impacts of the GMT2 

Access Road against the potential benefits-as far 

as one can tell from the Draft SEIS there basically 

are no benefits. This analysis must be updated in 

the Final SEIS and the real questions this road 

raises need to be answered.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

There are several reasons that preliminary data on the 

benefits of increased access provided by the Spur 

Road should not be used to predict the impacts of the 

GMT2 road. Data gathered by SRB&A that was 

available for the Draft SEIS on use of the Spur Road 

reflects hunter reports on uses of the Spur Road before 

there was any development northwest or west or of it 

(i.e., the GMT1 road or proposed GMT2 road), and the 

roads themselves are different. The Final SEIS 

includes the most recent data on the facilitated access 

provided by industry roads and it is used to more 

accurately predict the effects of the GMT2 road. The 

Draft SEIS discloses both potential benefits and 

potential negative impacts of the road and attempts to 

be succinct. Recent data on use of roads, gathered 

since the Draft SEIS was published, and verbatim 

testimony from hunters, has been included in the Final 

SEIS. 

L61-80 Kuukpik 

Corporation

Pages 431-432, Subsistence, Table 4.4-13: The 

table lists Years l to 8 but does not state which 

years the data represents. Also, the table shows a 

shift from use of boats and snowmachines to 

greater use of four wheelers and trucks. Knowing 

which years are portrayed may help explain this 

shift and, presumably, would confirm that it 

coincides with the increasing use of the Spur 

Road.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Text has been edited to add years to the table.
Supplemental Environmental Impact Statement

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

77

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L61-81 Kuukpik 

Corporation

Page 440, Subsistence -Drilling and Operation 

(Alternatives A and B), Resource Availability, 

Deflection of Resources by Infrastructure and 

Road and Air Traffic: This section suggests that 

subsistence users are increasingly accessing the 

GMT2 Project Study Area in September (and less 

in winter). Something seems amiss here. How did 

hunters access the GMT2 project area in 

September? Does the data show exactly what 

part of the GMT2 project area was accessed in 

September? There are no roads present, so 

vehicles weren't used. September is too early for 

snowmachine use. This info may be skewed by 

the definition of the GMT2 project area, which 

goes east past the ASRC mine site, includes 

portions of the Nigliq channel and portions of the 

Colville River. 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

NEPA requires the BLM to evaluate the impacts of the 

entirety of a project, including areas of associated 

activities and connected actions. The project area is 

defined to include such connected areas as the ASRC 

gravel pit from which gravel will be derived and Alpine 

which is the origination point of most traffic to and from 

GMT2, to name just two examples.
Supplemental Environmental Impact Statement

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

78

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L61-82 Kuukpik 

Corporation

Pages 445-446, Subsistence -Stipulations and 

Best Management Practices on Avoiding Conflict: 

There is an extensive write-up on the BLM 

Subsistence Advisory Panel. However, this entity 

has not met since November 2016. Also, there is 

no reference to the NPR-A Working Group. The 

suspension of advisory panel and working group 

meetings by Interior Secretary Zinke makes it 

unlikely that such groups will continue in the 

future.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

The NPR-A Working Group, established by the 2013 

NPR-A IAP ROD, is an advisory body established to 

provide input to BLM on implementation of the IAP, 

specifically on issues at a macro-level, such as leasing, 

land-use conflicts, adjustments of special area 

boundaries, etc. (see pg. 8-9 of IAP ROD). As such, 

the group is referred to in Chapter 4: Subsistence: 

Environmental Consequences under 1) the 

introduction, as an original source considered in 

analyzing the potential relevance of impacts that could 

be a result of GMT2 Project; 2) in 4.1.2.3 Impacts 

Common to All Alternatives: Rehabilitation of 

Infrastructure, where the group's assertion that 

decisions about whether and how to rehabilitate 

infrastructure should only be made through consultation 

with local communities is noted; 3) in 4.1.2.5: 

Operations and Drilling under Alternatives A and B: 

Deflection of Resources by Infrastructure and Road 

and Air Traffic, where the Working Group's "General 

Principles for Development of Infrastructure in Northern 

Alaska" (2014) is cited, (“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,”), and; 4) under Section 4.4.7.4. 

Environmental Justice - Mitigation. Neither the NPR-A 

Subsistence Advisory Panel (established in 1998) or 

the NPR-A Working Group has convened since the 

Dept. of Interior postponed advisory groups pending 

review in spring 2017. However, input received from 

both groups continues to be an important source in 

analyzing the effects of development and in formulating 

mitigation measures. 
Supplemental Environmental Impact Statement

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

79

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L61-83 Kuukpik 

Corporation

Pages 446-448, Mitigation: These passages 

discuss the State of Alaska NPR-A Impact 

Mitigation Program, the CPAI Subsistence 

Mitigation activities, and the GMTl Compensatory 

Mitigation Fund. There is no reference to the 

Regional Mitigation Strategy created via GMTl or 

to any similar mitigation fund related to GMT2.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Text revised to include discussion regarding the GMT1 

Compensatory Mitigation Fund and the Regional 

Mitigation Strategy.

L61-84 Kuukpik 

Corporation

Pages 449-452, Mitigation -Potential Mitigation 

Measures: These passages specify six potential 

mitigation measures which are: 1) GMT2 Road 

Right of Access Agreement; 2) Suspend NonEssential Helicopter Traffic During Peak Caribou 

Hunting Season; 3) Consultation Regarding 

Aircraft Communication Protocols; 4) Aircraft 

Monitoring Data Requirements; 5) Reduce Flights 

by Utilizing Unmanned Aerial Vehicles; and 6) 

Subsistence Monitoring Studies. Item 1 is 

effectively already in place. Item 2 may have 

some merit but CPA! doesn't do "joyriding" with 

helicopters due to costs. Item 3 is already in place 

via the KSOP. Item 4 is already required by the 

BLM via the permit stipulations imposed by the 

BLM in the NPR-A. Item 5 is worthwhile, but what 

has CPAI done on this same requirement, which 

was contained in the GMTI ROD? Item 6 may be 

worthwhile but may need some adjustments to 

really focus on and identify changes in 

subsistence activities. In summary, these 

proposals don't seem to be anything new or 

innovative.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

The proposed mitigation measures presented in the 

DSEIS comprise those measures from GMT1 that had 

merit in potentially being adopted for GMT2. One 

purpose of presenting impact analysis and proposed 

mitigation measures in a DSEIS is to disclose to the 

public possible negative effects of a proposed action 

and ways that these negative effects could be 

addressed, with the intent of soliciting additional 

information from the public, especially input on 

additional suggestions regarding additional potential 

mitigation measures. Local stakeholders with the 

greatest knowledge of the area and feasible mitigation 

measures are particularly encouraged to suggest 

mitigation measures that BLM could propose for the 

GMT2 ROD. 
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Comm # Commenter 

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Comments Comment 

Category Code

Comment Response

L61-85 Kuukpik 

Corporation

Pages 457-458, Public Health -Mitigation: There 

are three potential mitigation measures cited: 

1)GMT2 Industrial Disaster Response Plan for 

Nuiqsut; 2) Minimize Undue Idling of Vehicles; 

and 3) Public Health Monitoring. Item 1 is actually 

a NSB responsibility. Item 2 was already required 

for GMTI. Item 3 is already being worked by NVN, 

including an indoor air monitoring program. This 

potential measure calls for monitoring at a 

regional level. "Regional" is undefined. Again, 

these don't seem to be particularly new, 

innovative, or even additive since they are already 

required or underway.

3.18 Public 

Health

BLM is identifying all reasonable mitigation measures 

proposed during the public comment period in the Final 

SEIS for consideration in the ROD. Issues such as the 

ones identified in your comment may be used as 

justification for not adopting certain proposed mitigation 

measures. 

L61-86 Kuukpik 

Corporation

Pages 459-460, Environmental Justice: The third 

bullet stating Kuukpik receives "tax revenues" is 

plainly incorrect since Kuukpik is not a 

governmental entity.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Text has been corrected to indicate City of Nuiqsut.

L61-88 Kuukpik 

Corporation

Page 468, Cumulative Impacts -Methodology, 

Geographic Area of Relevant Past and 

Reasonably Foreseeable Actions: Map 4.6-1, 

depicting the geographic extent for the cumulative 

impacts analysis, lacks key information. The 

Caelus Nuna l drill site is shown, but the proposed 

Nuna 2 drill site is not. There is no hypothetical 

pipeline from Nanushuk to Kuparuk, but there is 

one depicted from Smith Bay to the Bear Tooth 

and from Cassin to GMTl (even though the latter 

are more speculative---or at least more remote in 

time-than the former). CO2 and CD3 are shown 

for Fiord West development.

5.1 Maps and 

GIS Data

Edits to the map have been made to reflect indicated 

changes. 
Supplemental Environmental Impact Statement

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

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Comm # Commenter 

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Comments Comment 

Category Code

Comment Response

L61-89 Kuukpik 

Corporation

Page 469, Cumulative Impacts, Table 4.6-1 

Summary of resource/issues time frame and 

geographic scope: What is the rationale for stating 

that oil, saltwater, and hazardous substance spills 

would continue until 2100? All other items in this 

table only go to 2050.

3.19 Hazardous 

Materials Spills

As described in Section 4.6.2, the time frame and 

geographic scope were defined for each 

resource/issue. For the Oil, Saltwater, and Hazardous 

Materials Spills, the time frame is defined as the 1940s 

(earlier than many of the other resources) to 2100 to 

account for previous activities that resulted in spills or 

releases within the defined geographic scope, and to 

address the persistence of some contaminants in the 

environment and the possibility of long-term cleanup 

activities.

L61-9 Kuukpik 

Corporation

The Final SEIS should meaningfully consider how 

the recent warming trends in the Arctic will impact 

GMT2 over the long term. Limiting the scope of a 

NEPA analysis undermines the integrity of the 

process and the conclusions reached in this Draft 

SEIS. As noted above, Kuukpik and Nuiqsut rely 

on the NEPA process and the EIS documents to 

take a "hard look" at oil industry projects and their

impacts. Kuukpik is very much concerned that 

recent internal Department of the Interior 

directives are going to substantially reduce the 

value of the NEPA process and its credibility in 

Nuiqsut in future years. Kuukpik and Nuiqsut rely 

on the NEPA process and the EIS documents to 

take a "hard look" at oil industry projects and their 

impacts. Kuukpik is very much concerned that 

recent internal Department of the Interior 

directives are going to substantially reduce the 

value of the NEPA process and its credibility in 

Nuiqsut in future years.

3.7 Climate 

Change

In the GMT2 Supplemental EIS, the BLM tiers to and 

incorporates by reference previous NEPA analysis 

including the ASDP EIS (2004), the NPR-A IAP (2012) 

and the GMT1 SEIS (2014). CEQ regulations direct 

that: Agencies shall incorporate material into an 

environmental impact statement by reference when the 

effect will be to cut down on bulk without impeding 

agency and public review of the action. The 

incorporated material shall be cited in the statement 

and its content briefly described. No material may be 

incorporated by reference unless it is reasonably 

available for inspection by potentially interested parties 

within the time allowed for comment. (40 CFR 

1502.21). The text provided in the GMT2 SEIS 

incorporates by reference and summarizes the text 

from the GMT1 SEIS and includes updated information 

where such information was available (i.e., most up to 

date information on minimum sea ice extent). Our 

understanding of climate change and its effects on the 

Arctic are not significantly different than what is stated 

in the GMT1 SEIS. 
Supplemental Environmental Impact Statement

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Comm # Commenter 

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Category Code

Comment Response

L61-90 Kuukpik 

Corporation

Pages 471-474, Cumulative Impacts, Table 4.6-2 

Past, Present and Reasonably Foreseeable 

Future Developments: Putu is shown as being in 

no unit, but in fact is part of the Colville River Unit. 

In the utilities section, it references a "pipeline" 

from CPFl to the power plant, but does not identify 

this as a gas pipeline or reference gas being 

provided to most Nuiqsut buildings and homes. 

Also, the Spur Road is stated as connecting 

Nuiqsut to the CD5 access road but states that 

this road is "Within Community''.

4.0 Cumulative 

Effects Projects 

and Methodology

The BLM corrected Table 4.6-2 as suggested. Spur 

road distance from Nuiqsut is 0 to 6 miles. 

L61-91 Kuukpik 

Corporation

Page 476, Cumulative Impacts -Cumulative 

Impacts to the Terrestrial Environment: This 

passage suggests that because the "future impact 

to the existing physiography, soil, permafrost 

regimes and to petroleum resources" cannot be 

accurately estimated at this time, the analysis 

does not include ANY future gravel footprint in the 

cumulative impacts analysis. The EIS should be 

making some effort to predict gravel use and 

footprints over the long term. It's also not clear 

how the data on the following pages "fits" with this 

analysis.

3.2 Soils & 

Permafrost

Text updated to provide an estimate of future gravel 

disturbance: 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. 
Supplemental Environmental Impact Statement

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L61-92 Kuukpik 

Corporation

Page 478, Cumulative Impacts -Future Impacts 

and their Accumulation, Oil and Gas Exploration 

and Development Activities: This section claims 

that ice roads are routinely "constructed between 

staging areas in the Kuparuk River Unit to 

locations within the NPR-A as far as the Utqiagvik 

(formerly Barrow) area." What is the source of this 

information? Kuukpik believes the western-most 

ice roads extended about 75 miles west of 

Nuiqsut (believed to be the Kokoda exploration 

wells drilled by CP AI in the 1990-2000 time 

frame), which is far from Utqiagvik. There have 

been many rolligon trails (mostly constructed 

annually) between Kuparuk and the Utqiagvik 

area, but these are very different from a usage 

and safety standpoint than ice roads.

3.4 Water 

Resources

The sentence was modified to reflect Smith Bay as the 

western-most ice road constructed to date.

L61-93 Kuukpik 

Corporation

Page 481, Cumulative Impacts -Cumulative 

Impacts to Air Quality, Table 4.6-3: Why does this 

table have a "no" for Evaluated in GMT2? This 

DSEIS does analyze the air impacts from GMT2. 

Perhaps this was copy and pasted from the GMTl 

EIS but not updated.

3.5 Air Quality & 

Meteorology

Table 4.6-3 indicates which sources are included as 

Reasonably Foreseeable Development (RFD) sources 

in the cumulative emissions inventory. GMT2 is not a 

RFD source in the cumulative inventory for the GMT2 

EIS, rather it is the project source. Similarly, GMT1 is 

not an RFD source in the cumulative inventory for the 

GMT1 EIS. This has been clarified in the SEIS.

L61-94 Kuukpik 

Corporation

Page 486, Cumulative Impacts to Biological 

Resources -Vegetation and Wetlands, Past and 

Present Impacts and Their Accumulation: The first 

passage describes "the recently built Nuiqsut 

Spur Road" as an impact from oil and gas 

activities, but the Spur Road is a community-led 

effort, the primary purpose of which is to facilitate 

subsistence and economic opportunities for 

Nuiqsut residents.

3.8 Vegetation 

and Wetlands

Sentence has been revised.
Supplemental Environmental Impact Statement

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

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Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L61-95 Kuukpik 

Corporation

Page 487, Cumulative Impacts to Biological 

Resources -Vegetation and Wetlands, Oil and 

Gas Development and Production: The reference 

to the Tofkat Unit is out of date since that unit no 

longer exists.

3.8 Vegetation 

and Wetlands

Reference to the Tofkat Unit has been deleted.

L61-96 Kuukpik 

Corporation

Page 498, Cumulative Impacts to Biological 

Resources -Terrestrial Mammals, Grizzly Bear, 

Fox, and Other Terrestrial Mammals, Contribution 

of the Alternatives to Cumulative Impacts: This 

passage claims that "The greatest threat 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." First, this comment casts a 

negative light on subsistence. Second, it isn't 

even consistent with the previous sentence 

stating that grizzly bears have been little affected 

by development on the North Slope. Third, it's not 

true. Kuukpik is aware of just one somewhat 

recent situation where a grizzly bear was killed (in 

the Prudhoe Bay area). This action is believed to 

have been taken by ADF&G reps. Oilfield 

operators generally don't kill grizzly bears. There 

are regulatory programs in place that discourage 

this practice and require implementation of other 

tactics (e.g., hazing, etc.) before lethally dealing 

with grizzly bears.

3.12 Mammals While greatest is relative to the other potential impacts, 

some could assume it to mean that it is a large and 

significant effect. The wording will be reviewed to 

ensure this is clear. Further below in the SEIS, see the 

statement "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)."

L61-97 Kuukpik 

Corporation

Page 516, Cumulative Impacts to Social Systems 

-Sociocultural Systems, Oil and Gas Development 

Actions: Qugruk is east of the community, not 

west, and is associated with Nanushuk.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Text has been corrected to include Qugruk with 

Nanushuk east of the Colville River.

L61-98 Kuukpik 

Corporation

Page 518, Cumulative Impacts to Social Systems 

-Economy, Past and Present Impacts and Their 

Accumulation: Kuukpik has no "ownership" in the 

Alpine Field.

3.16 Economy Text clarified to state that Kuukpik owns the surface 

land that CD2, 4 and 5 are built on and collects 

revenue from surface access agreements. 
Supplemental Environmental Impact Statement

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Comm # Commenter 

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Comments Comment 

Category Code

Comment Response

L61-99 Kuukpik 

Corporation

Page 519, Cumulative Impacts to Social Systems 

-Economy, Contribution of the Alternatives to 

Cumulative Impacts: The final paragraph appears 

to be a holdover from the GMT 1 Final SEIS that 

is not applicable to GMT2. See GMTI Final SEIS, 

p. 569. There is no Alternative D1. If this 

discussion were relevant, it would still be wrong 

because the Native Village of Nuiqsut would not 

receive increased economic benefits from use of 

the airport and hotel. Kuukpik owns the hotel, and 

no entity in Nuiqsut receives economic benefits 

from increased use of the airport.

3.16 Economy Paragraph deleted.

L65-5 Hawk 

Consultants 

LLC

The currently proposed GMT2 project (formerly 

CD7) is essentially the same as that approved for 

permitting in 2004 with changes that reduce the 

overall footprint. 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. Relocation of the 

drill site also mitigates the potential for impacts on 

peregrine falcons, an endangered species.

4.2 Mitigation Peregrine falcons were delisted on August 20, 1999 

and were removed from the Endangered Species List 

by the Department of the Interior. However, the BLM is 

required under the NPRPA, which guides management 

of the reserve, to protect the surface resources and 

wildlife located in the NPR-A to the maximum extent 

possible. To this end, the BLM encourages applicants 

to incorporate design elements into their proposals for 

activity that serve to minimize environmental impacts.

L65-6 Hawk 

Consultants 

LLC

Alternative C, the aircraft and roadless alternative, 

would not allow adequate access to emergency 

response resources and creates significant 

environmental and safety risk in the unlikely event 

of an issue. On bad weather days, there would be 

no access to GMT2.

3.18 Public 

Health

Noted, further discussion in SEIS in Section 2.7, 

Alternative C: Roadless Access and Section 4.5, 

Impacts of Oil, Saltwater and Hazardous Materials 

Spills.

L67-3 Alaska 

Trucking 

Association

As proposed in Alternative A, GMT2 will include a 

gravel road connection to existing infrastructure at 

GMT1 facilities. The road is necessary to insure 

that the operator can respond to the unlikely event 

of an environmental or safety issue in an 

adequate and timely manner.

3.18 Public 

Health

Noted, further discussion in SEIS in Section 2.7, 

Alternative C: Roadless Access and Section 4.5, 

Impacts of Oil, Saltwater and Hazardous Materials 

Spills.
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Comment Response

L68-2 Barbara 

Fullmer

One area that should be improved in the DSEIS is 

the basis described for the analysis of social 

systems impacts. The BLM has used prescribed 

criteria for evaluating impacts to physical 

characteristics and the biological environment, 

and it is important that the BLM also clearly 

explain the analysis of social systems impacts, 

including the methodology and criteria. The 

DSEIS (at Chapter 4.4 - Social Systems) does not 

describe impact criteria or identify impact levels 

for its analysis of cultural resources, socio-cultural 

systems, economic impacts, land use, 

subsistence, public health or environmental 

justice. While impact levels are not required under 

NEPA, the BLM should more clearly address the 

criteria for its evaluation. One way to do so is to 

apply the criteria and methodology in place for the 

ANILCA Section 810 analysis for assessing 

subsistence impacts, for the other social systems 

analyses, many of which are largely impacted by 

subsistence. Using the Section 810 criteria would 

allow the BLM to focus on facts and material 

issues to reach meaningful conclusions, while 

avoiding speculation, focus on issues that are 

only tangentially relevant, and a false precision in 

lieu of accuracy. 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

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 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. The 

ANILCA Section 810 criteria is specific to answering a 

single question: whether or not there may be a 

significant restriction to subsistence use, and our 

guidance is based on case law regarding that 

overriding factor. The NEPA requirement to take a 

"hard look" (also based on case law) goes beyond 

addressing a single question, and instead requires BLM 

to address a whole host of issues, including those 

identified during scoping, through consultation with 

stakeholders, and based on a review of relevant 

literature. In short, NEPA's hard look requires a more 

comprehensive analysis than that required pursuant to 

ANILCA Section 810.
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Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L68-3 Barbara 

Fullmer

Another area that should be improved is the 

analysis of potential impacts to subsistence 

(DSEIS at Section 4.4.5 and Appendix L). The 

analysis as currently presented emphasizes 

potential negative impacts on subsistence without 

consideration of positive impacts and results. For 

example, the DSEIS uses hypotheticals and then 

starts each with a negative stance (e.g., "If 

residents decrease use ... ", DSEIS at p. 423; "If 

harvests or the number of active participants in 

harvesting declines ... ", DSEIS at p. 424) to make 

adverse subsistence impact statements. Another 

unsupported negative emphasis is the subtle but 

pervasive repetition of allegedly detrimental

potential impacts that, in the end, are not 

supported by the facts. For example, the 

numerous references to concerns about deflection 

of caribou by roads are not supported by the 

many years of data available on North Slope 

caribou herds. A DSEIS (and the subsequent 

SEIS) should not be based upon hypotheticals, 

but on facts, and those facts should be broad 

enough to provide a balanced perspective 

regarding potential impacts to subsistence. And, 

in fact, there are positive impacts to subsistence 

from developments in this area, and they should 

be mentioned. There are Nuiqsut area 

subsistence reports that are not quoted in the 

DSEIS, which indicate that roads in this area have 

facilitated access to hunting areas and increased 

hunter success. For example, the CD-5 road is 

used for subsistence hunting with positive results 

(see, e.g., SRB&A Nuiqsut interview, November 

2014), and it has been reported that several 

caribou were taken by hunters using the GMT1 

road during the GMT1 pipeline construction 

season in 2018.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

The NEPA process is intended to help public officials 

make decisions that are based on understanding of 

environmental consequences, and take actions that 

protect, restore, and enhance the environment [40 CFR 

1500.1 (c)]. An EIS must identify the known and 

predicted effects that are related to issues identified 

that could be affected by a proposed action [40 CFR 

1500.4 (c), 40 CFR 1500.4(g), 40 CFR 1500.5(d), 40 

CFR 1502.16]. Federal Agencies are required to use all 

practicable means, consistent with the requirements of 

the Act and other essential considerations of national 

policy, to restore and enhance the quality of the human 

environment and avoid or minimize any possible 

adverse effects of their actions upon the quality of the 

human environment [40 CFR 1500.2(f)]. Inherently, 

NEPA analyses are statements about potential future 

outcomes, based on our understanding of effects that 

have already occurred, are currently occurring, our 

could occur, focusing on adverse effects in order to 

identify ways to address them. The Draft SEIS 

disclosed both potential benefits and potential negative 

impacts of the road and attempts to be succinct. 

Recent data on use of roads, gathered since the Draft 

SEIS was published, and verbatim testimony from 

hunters, has been included in the Final SEIS. The Draft 

SEIS did include updated discussions on avoidance, 

noting that 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.
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L68-3

Continued

Barbara 

Fullmer

By selecting and using only negatively focused 

references and sources, the DSEIS does not 

provide a balanced perspective regarding 

subsistence; instead, it emphasizes negative 

comments and outcomes without giving equal 

weight to the positive benefits the roads and other 

aspects of the development bring to subsistence 

hunters. A DSEIS should present a reasoned factbased approach and unbiased analyses. 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

See above for BLM response

L70-1 Laborers' 

International 

Union of North 

America Local 

341

Proposed Alternative A involves a gravel road 

between GMT2 and the current infrastructure at 

GMT1, which is critical to ensure that the operator 

can respond promptly in the unlikely event of an 

unanticipated issue at the site. 

4.2 Mitigation Section 4.5.5 of the SEIS discusses the benefits of 

having a gravel road connection in responding to any 

unforeseen issues.

L75-2 Robert Stinson Throughout the development of the DEIS, many 

improvements have been made to lessen the 

impacts on the environment including a relocated 

drilling site outside of the Colville River Special 

Area, and reducing the road and pipeline length, 

thereby reducing the amount of fill and associated 

impacts to wetlands. Relocation of the drilling pad 

also mitigates the potential impacts on waterfowl.

4.2 Mitigation The BLM is required under the NPRPA, which guides 

management of the reserve, to protect the surface 

resources and wildlife located in the NPR-A to the 

extent possible while remaining consistent with the oil 

and gas requirements of the Act. To this end, the BLM 

encourages applicants to incorporate design elements 

into their proposals for activity that serve to minimize 

environmental impacts.
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L76-01 EarthJustice The DSEIS does not adequately assess these 

impacts, nor does it account for the reasonably 

foreseeable impacts from development of the 

Willow prospect, which is only possible if the 

Bureau of Land Management (BLM) selects 

Alternative A or B for GMT-2. 

4.0 Cumulative 

Effects Projects 

and Methodology

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 project has independent utility from GMT2 

and is not considered a connected action under NEPA. 

The Willow find is sufficiently large that even in the 

absence of a road connection between GMT2 and 

GMT1, the Willow project could be developed 

roadlessly similar to the Alpine field. Deferral of a 

project authorization would be inconsistent with the 

directive in the Naval Petroleum Reserves Production 

Act to expeditiously carry out an oil and gas leasing 

program and the rights ConocoPhillips acquired with 

the subject leases to reasonably develop the oil and 

gas within those lease tracts.
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L76-02 EarthJustice Development of the Willow prospect is a 

reasonably foreseeable indirect effect of both 

Alternative A and Alternative B and therefore must 

be assessed in the GMT-2 SEIS. According to the 

DSEIS, “[d]evelopment and production at the 

Willow prospect requires GMT2 to be 

operational,”3 and “[s]pecifically, development of 

the Willow prospect is dependent on construction 

of GMT2 with a road.”4 Despite the admission 

that development and production at Willow cannot 

happen without GMT-2 and an associated road, 

BLM does not analyze Willow’s reasonably 

foreseeable effects. 

4.0 Cumulative 

Effects Projects 

and Methodology

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 project has independent utility from GMT2 

and is not considered a connected action under NEPA. 

The Willow find is sufficiently large that even in the 

absence of a road connection between GMT2 and 

GMT1, the Willow project could be developed 

roadlessly similar to the Alpine field. Deferral of a 

project authorization would be inconsistent with the 

directive in the Naval Petroleum Reserves Production 

Act to expeditiously carry out an oil and gas leasing 

program and the rights ConocoPhillips acquired with 

the subject leases to reasonably develop the oil and 

gas within those lease tracts.
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Comment Response

L76-03 EarthJustice Development and production at Willow is 

reasonably foreseeable if GMT-2 is developed 

with a road. The DSEIS states that Willow is 

estimated to contain 300 million barrels (mmbbl) 

of oil7—three times the GMT-2 estimate. In April, 

ConocoPhillips confirmed that recent exploration 

drilling “support the previously announced 

estimate of a recoverable resource potential of 

more than 300 million barrels of oil.”8 Given its 

resource potential and proximity to GMT-2, BLM 

cannot reasonably assume that Willow will not be 

developed. Thus, NEPA requires BLM to analyze 

those potential indirect and cumulative impacts of 

Willow that may be reasonably foreseen at this 

time. 

4.0 Cumulative 

Effects Projects 

and Methodology

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 project has independent utility from GMT2 

and is not considered a connected action under NEPA. 

The Willow find is sufficiently large that even in the 

absence of a road connection between GMT2 and 

GMT1, the Willow project could be developed 

roadlessly similar to the Alpine field. Deferral of a 

project authorization would be inconsistent with the 

directive in the Naval Petroleum Reserves Production 

Act to expeditiously carry out an oil and gas leasing 

program and the rights ConocoPhillips acquired with 

the subject leases to reasonably develop the oil and 

gas within those lease tracts.
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Alpine Satellite Development Plan for the Proposed Greater Mooses Tooth 2 Development Project

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Comm # Commenter 

Name

Comments Comment 

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L76-04 EarthJustice BLM’s failure to disclose and analyze impacts 

from Willow under Alternatives A and B falsely 

minimizes the impacts of those alternatives and 

makes them look less environmentally damaging 

than Alternative C (the roadless alternative). 

Given the size of the Willow find and its proximity 

to GMT-2, BLM must reasonably assume that 

Willow will affect most, if not all, of the same 

resources that GMT-2 affects, and that the 

impacts from Willow will be at least as significant 

as GMT-2 standing alone, and will be additive, 

cumulative, and synergistic to GMT-2’s impacts. 

4.0 Cumulative 

Effects Projects 

and Methodology

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 project has independent utility from GMT2 

and is not considered a connected action under NEPA. 

The Willow find is sufficiently large that even in the 

absence of a road connection between GMT2 and 

GMT1, the Willow project could be developed 

roadlessly similar to the Alpine field. Deferral of a 

project authorization would be inconsistent with the 

directive in the Naval Petroleum Reserves Production 

Act to expeditiously carry out an oil and gas leasing 

program and the rights ConocoPhillips acquired with 

the subject leases to reasonably develop the oil and 

gas within those lease tracts.
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L76-05 EarthJustice Although the DSEIS contains a reference to 

Willow in the cumulative impact section,6 BLM 

has not taken a hard look at the project’s 

foreseeable effects, nor does the DSEIS reflect 

the fact that the cumulative impacts of 

Alternatives A and B may be much more 

significant than Alternative C because Alternatives 

A and B will enable development of Willow. 

4.0 Cumulative 

Effects Projects 

and Methodology

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 project has independent utility from GMT2 

and is not considered a connected action under NEPA. 

The Willow find is sufficiently large that even in the 

absence of a road connection between GMT2 and 

GMT1, the Willow project could be developed 

roadlessly similar to the Alpine field. Deferral of a 

project authorization would be inconsistent with the 

directive in the Naval Petroleum Reserves Production 

Act to expeditiously carry out an oil and gas leasing 

program and the rights ConocoPhillips acquired with 

the subject leases to reasonably develop the oil and 

gas within those lease tracts.

L76-06 EarthJustice Finally, BLM’s analysis ignores the reasonably 

foreseeable greenhouse gas emissions from the 

Willow development that are an indirect effect of 

GMT-2. BLM cannot approve the GMT-2 Project 

based on the flawed analysis in the DSEIS. 

4.0 Cumulative 

Effects Projects 

and Methodology

Estimates of downstream greenhouse gas emissions 

are provided in the DSEIS to facilitate comparison of 

impacts associated with various alternatives and 

support analyses of cumulative impacts. The DSEIS 

indicates that emissions from anthropogenic activities 

such as production and combustion of fossil fuels do 

contribute to ongoing climate change processes, but 

existing models and tools are not sufficient to quantify 

specific impacts upon local resources. Climate change 

is by nature a cumulative global issue and no single 

action contributes an amount of greenhouse gases that 

can significantly impact global systems. Specific 

regulatory thresholds for greenhouse gas emissions 

have not been promulgated and there is no means to 

quantitatively assess major, moderate, or minor 

impacts to local resources. It is recognized in the DEIS 

that there is inherent uncertainty in these estimates 

(from market influences and other factors). 
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L76-07 EarthJustice First, BLM fails to account for foreign oil 

consumption, which leads it to assert that the 

GMT-2 action alternatives will result in only 

slightly higher greenhouse gas emissions than the 

No Action Alternative. Second, economic 

analyses show that near-total substitution for oil 

and gas production does not occur in the real 

world and is not a reasonable assumption. To the 

contrary, numerous studies show that every barrel 

of oil, and unit of gas, left undeveloped results in 

significant reductions in global oil and gas 

consumption with associated decreases in 

greenhouse gas pollution. Third, BLM’s DSEIS 

fails to adequately disclose that continued fossil 

fuel extraction from federal waters and lands is 

not compatible with the United States’ 

greenhouse gas commitments or with staying 

within a United States or global carbon budget 

necessary for avoiding the worst impacts of 

climate change.

3.7 Climate 

Change

The implications for oil and gas production in other 

countries relating to U.S. decisions about issuing 

leases are highly uncertain. In the substitution analysis 

based on MarketSim, the assumption is made that 

other oil producing countries will supply oil for U.S. 

import without additional restraints due to GHG-related 

policies in those countries. This might change in the 

future if other countries establish policies to achieve 

their GHG-related targets. Excluding the foreign oil and 

gas consumption is reasonable. First, the oil produced 

by GMT2 would be consumed domestically, therefore 

the substitution sources for GMT2 would also be 

consumed domestically. Second, oil consumption in 

each country is different, and BOEM does not have 

information related to which countries would consume 

less oil. This is important information since 

consumption patterns vary by country. For gas 

consumption, BOEM does not have information related 

to how changes in the U.S. market would affect other 

countries. Typically, any single project has a negligible 

impact on overall GHG globally. Geographical factors 

and time frame can also play an important role. In the 

short term, EIA tends to project continued demand. 

Here is the link to the BOEM GHG technical report: 

https://www.boem.gov/OCS-Report-BOEM-2016-065/
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L76-08 EarthJustice The court held that it was arbitrary for the agency 

to consider the economic benefits of the 

expansion without also assessing the climate 

consequences of the end use of coal using the 

Social Cost of Carbon protocol, described below. 

At the very least, the agency had to explain why it 

opted not to use the protocol.

3.7 Climate 

Change

Executive Order 13783 (Promoting Energy 

Independence and Economic Growth) issued in 2017, 

rescinded the policy requirement for federal agencies to 

consider the social cost of carbon in decision making. 

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.

L76-09 EarthJustice Applying SEI’s methodology to BLM’s production 

estimates for GMT-2 shows larger emissions 

reductions under the No Action Alternative. 

Foregoing the production of 100.2 mmbbl of oil at 

GMT-2 would lead to an approximate net 

reduction of 50 mmbbl in global oil consumption 

(i.e., around half of that amount would be 

replaced by increased oil production elsewhere in 

the world). Additionally, under SEI’s model, 

around 25 mmbbl of oil would be replaced by 

other oil substitutes such as biofuels or electricity 

(with an average carbon intensity of 85 percent of 

oil). Together these substitutions would lead to a 

net global reduction of greenhouse gas emissions 

of 11.5 million metric tons of CO2 under the No 

Action Alternative—more than five times larger 

than BLM’s estimate.

3.7 Climate 

Change

SEI's analysis is incompatible with the method used to 

calculate emissions from substituted sources. In order 

to calculate those emissions from a particular fuel, 

BOEM's Greenhouse Gas Lifecycle Model, uses the 

emissions expected from refineries as well as the 

emissions from consumption of fuels based on how 

those fuels would be consumed. For example, few 

countries use motor gasoline in as high a proportion to 

the rest of their oil use as the United States. This 

means other oil products are consumed at higher rates 

in those countries, however emissions rate differs 

based on type of oil product consumed. Without 

knowing each country's consumption pattern, and the 

refineries which supply those products (in the United 

States we use a national emissions factor for refineries) 

any assumption the model makes would reduce its 

accuracy. In order to compare the results of the No 

Action Alternative to the Action Alternatives, the same 

methodology must be used. 
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L76-10 EarthJustice Additionally, using BLM’s timeline for the 

production of GMT-2 oil from years 2020 to 2050,

66 we can apply the official social cost of carbon 

estimates to calculate the avoided social costs 

under the No Action Alternative. We find that 

these social costs range from $197 million to $1.9 

billion (2018 US$) depending on the choice of a 

discount rate.67 Given that the official social cost 

of carbon estimates are likely quite conservative, 

this indicates that the social costs of the GMT-2 

are comparable to BLM’s quantified economic 

benefits. 

3.7 Climate 

Change

Executive Order 13783 (Promoting Energy 

Independence and Economic Growth) issued in 2017, 

rescinded the policy requirement for federal agencies to 

consider the social cost of carbon in decision making. 

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.

L76-11 EarthJustice An accurate estimate of net carbon emissions 

resulting from the proposed action is a 

prerequisite for applying a social cost of carbon 

analysis. A complete and accurate assessment of 

the costs of GMT-2’s impacts on the climate is 

even more essential to a reasoned decision 

because BLM takes into account the potential 

economic benefits of the project. For example, it 

states that total royalties from GMT-2 would 

amount to approximately $1.45 billion; property 

tax revenue would be about $226 million; and 

$379 million in severance taxes.68 It is arbitrary 

for the agency to quantify certain economic 

benefits of GMT2 (and allude to others) without 

accurately disclosing the social cost of its likely 

carbon emissions.

3.7 Climate 

Change

Executive Order 13783 (Promoting Energy 

Independence and Economic Growth) issued in 2017, 

rescinded the policy requirement for federal agencies to 

consider the social cost of carbon in decision making. 

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.
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L76-12 EarthJustice BLM also fails to estimate black carbon emissions 

from GMT-2. GMT-2’s potential to affect the Arctic 

climate and melting sea ice is not limited to 

greenhouse gas emissions; black carbon also is a 

concern that BLM must address in its NEPA 

analysis.

3.5 Air Quality & 

Meteorology

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. Although black carbon emissions from the 

GMT2 Project are not explicitly quantified, black carbon 

is implicitly included as part of the GMT2 Project PM2.5 

emissions inventory used in the air quality impact 

analysis. 

Black carbon’s influence on arctic climate is complex 

and still an active area of research. Section 4.2.4 in the 

SEIS has been revised to include additional information 

about black carbon and its potential effects on climate 

based on available, peer-reviewed literature. The 

revised Section 4.2.4 in the SEIS describes known 

processes involving black carbon that can have 

warming or cooling effects on climate. Black carbon’s 

effects on climate depend on location and seasonality 

of emissions; associated co-emissions; atmospheric 

mixing state; and dominant meteorological, dynamical, 

and removal pathways. 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. As a result, it is 

not currently possible to quantitatively assess the effect 

of a Project’s black carbon emissions on global climate 

change. 
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L76-13 EarthJustice BLM fails to estimate GMT-2’s emissions of black 

carbon or identify potential mitigation measures 

when discussing air quality impacts and climate 

change. BLM must address this omission in its 

SEIS to give an accurate accounting of the 

project’s environmental impacts. 

3.7 Climate 

Change

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. Although black carbon emissions from the 

GMT2 Project are not explicitly quantified, black carbon 

is implicitly included as part of the GMT2 Project PM2.5 

emissions inventory used in the air quality impact 

analysis. 

Black carbon’s influence on arctic climate is complex 

and still an active area of research. Section 4.2.4 in the 

SEIS has been revised to include additional information 

about black carbon and its potential effects on climate 

based on available, peer-reviewed literature. The 

revised Section 4.2.4 in the SEIS describes known 

processes involving black carbon that can have 

warming or cooling effects on climate. Black carbon’s 

effects on climate depend on location and seasonality 

of emissions; associated co-emissions; atmospheric 

mixing state; and dominant meteorological, dynamical, 

and removal pathways. 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. As a result, it is 

not currently possible to quantitatively assess the effect 

of a Project’s black carbon emissions on global climate 

change. 
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L76-14 EarthJustice BLM asserts that the No Action Alternative would 

result in only 5 percent less greenhouse gas 

emissions than the action alternatives. Invoking 

market substitution, BLM claims that “the energy 

that would have been produced from the GMT2 

Project would be replaced by alternate energy 

sources.” However, by excluding one of the 

largest factors in its analysis (non-domestic oil 

consumption), BLM presents a misleading view of 

the impacts of its action. Artificially limiting its 

analysis and not fully reporting the findings of its 

own model allows BLM to irrationally conclude 

that increased oil production from GMT-2 would 

lead to only a negligible increase in emissions 

over the No Action Alternative. 

3.5 Air Quality & 

Meteorology

The implications for oil and gas production in other 

countries relating to U.S. decisions about issuing 

leases are highly uncertain. In the substitution analysis 

based on MarketSim, the assumption is made that 

other oil producing countries will supply oil for U.S. 

import without additional restraints due to GHG-related 

policies in those countries. This might change in the 

future if other countries establish policies to achieve 

their GHG-related targets. Excluding the foreign oil and 

gas markets is reasonable. Oil consumption in each 

country is different, and BOEM does not have 

information related to which countries would consume 

less oil. This is important information since 

consumption patterns vary by country. For gas 

consumption, BOEM does not have information related 

to how changes in the U.S. market would affect other 

countries. Typically, any single project has a negligible 

impact on overall GHG. Geographical factors and time 

frame can also play an important role. In the short term, 

EIA tends to project continued demand. Here is the link 

to the BOEM GHG technical report: 

https://www.boem.gov/OCS-Report-BOEM-2016-065/

L76-15 EarthJustice GMT-2, which would lead to oil production for 

many years into the future, would undermine the 

country’s—and the world’s—urgently needed 

implementation of its goals for moving swiftly 

away from dependence on carbon-based fuels. 

BLM’s analysis will have to ask a set of questions 

about how the choice to authorize GMT-2 relates 

to the overall carbon budget and to decisions 

about whether to pursue other fossil fuels in light 

of the reality that a vast majority of alreadydiscovered—much less undiscovered—fossil fuels 

must be left undeveloped. 

3.7 Climate 

Change

The BLM has prepared the Supplemental EIS to inform 

decision making related to a proposed project to 

construct a drill site, access road, pipelines, and 

ancillary facilities to develop and transport petroleum 

from the GMT2 production pad for shipment to market. 

Broader energy policy issues such as the Nation's 

ongoing use of fossil fuels or other types of energy 

sources are beyond the scope of the proposed project 

and are not included in the Supplemental EIS. The 

comment also refers to an overall carbon budget which 

does not exist given the decision by the United States 

to withdraw from the Paris Agreement in 2017.
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L76-16 EarthJustice BLM must analyze development of Willow as an 

indirect effect of Alternatives A and B in the GMT2 EIS because “development of the Willow 

prospect is dependent on construction of GMT2 

with a road.” One of the foreseeable 

consequences of the development of Willow, 

which is estimated to contain 300 mmbbl of 

economically recoverable oil, is additional 

greenhouse gas emissions. The DSEIS calculates 

the indirect greenhouse gas emissions of burning 

the 100 mmbbl of economically recoverable oil in 

GMT-2. But because development of an 

additional 300 mmbbl of oil is likely under GMT-2 

Alternatives A and B (the roaded alternatives), 

these alternatives must calculate the greenhouse 

gas emissions from burning 400 mmbbl and 

contrast those with Alternative C (the roadless 

alternative) and the No Action Alternative. BLM’s 

failure to include the significant increase in 

foreseeable indirect greenhouse gas emissions 

under Alternatives A and B skews the comparison 

of alternatives and makes Alternatives A and B 

look significantly less environmentally damaging 

than they are. 

3.5 Air Quality & 

Meteorology

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 project has independent utility from GMT2 

and is not considered a connected action under NEPA. 

The Willow find is sufficiently large that even in the 

absence of a road connection between GMT2 and 

GMT1, the Willow project could be developed 

roadlessly similar to the Alpine field. The direct and 

indirect impacts of Willow will be analyzed pursuant to 

NEPA as part of the Willow MDP EIS, which includes a 

central processing facility as part of the project 

proposal.
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L76-17 EarthJustice In scoping comments, commenters requested that 

BLM consider a seasonal drilling roadless 

alternative that would permit drilling only in the 

winter. BLM considered such a seasonal 

alternative in its final SEIS for the Greater Mooses 

Tooth 1 (GMT-1) development project. However, 

in the DSEIS for GMT-2, BLM eliminated the 

seasonal alternative from further study because it 

was not “economically viable” under either a $62 

per barrel and $123 per barrel price scenario. In 

order to comply with NEPA, BLM must consider 

the seasonal alternative because it is reasonable 

and would meet the purpose and need of the 

project. 

...

There is nothing in the purpose and need that 

would eliminate a seasonal alternative from 

consideration. Nor is there any explanation why 

an alternative that was considered reasonable 

under the same purpose and need for GMT-1 has 

become unreasonable for GMT-2.

2.1 Proposed 

Action & 

Alternatives

Section 1502.14 of NEPA and CEQ guidance requires 

the EIS to examine all reasonable alternatives to the 

proposal. In determining the scope of alternatives to be 

considered, the emphasis is on what is "reasonable" 

rather than on whether the proponent or applicant likes 

or is itself capable of carrying out a particular 

alternative. Reasonable alternatives include those that 

are practical or feasible from the technical and 

economic standpoint and using common sense, rather 

than simply desirable from the standpoint of the 

applicant. When proposed as part of the GMT1 SEIS, it 

was unknown if seasonal drilling was an economically 

feasible alternative until the analysis was completed. 

For the GMT2 SEIS, BLM has included the economic 

analyses used to screen out a roadless alternative with 

seasonal drilling as Appendix O. The initial analysis 

was done in November 2016, and a version with 

confidential information removed was provided in 

February 2017. 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 uneconomic. See 

Appendix O for more details. 
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L76-18 Earth justice Moreover, BLM has provided no explanation 

about what assumptions have gone into its 

economic viability analysis. Given that 

commenters specifically asked for a seasonal 

drilling alternative as a possible way to meet the 

defined project purpose of “protecting important 

surface resources,” BLM cannot reject such an 

alternative in one conclusory paragraph. Analysis 

of the seasonal drilling alternative is especially 

important because, as explained above, when 

BLM considers the full impacts of Alternatives A 

and B, those alternatives might not fulfill the 

purpose and need of the project to “protect[] 

important surface resources."

2.1 Proposed 

Action & 

Alternatives

BLM has included the economic analyses used to 

screen out a roadless alternative with seasonal drilling 

as Appendix O. The initial analysis was done in 

November 2016, and a version with confidential 

information removed was provided in February 2017. 

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 uneconomic. See Appendix O 

for more details.

L76-19 EarthJustice BLM’s discussion of social system (including 

subsistence and environmental justice) impacts is 

inconsistent with its analysis of other resources in 

the DSEIS. For all other resources, BLM applies 

impact levels that rate impacts as negligible, 

minor, moderate, or major. For social systems, 

however, BLM does not disclose where the 

impacts fall on this spectrum. BLM’s decision to 

disregard these impact levels for a resource for 

which the impacts will almost certainly be major 

serves to obfuscate the human impacts of GMT-2 

and mislead the public.

At the beginning of the Environmental 

Consequences section in the DSEIS, BLM 

explains its methodology for determining the 

impacts of GMT-2 on the various resources....The 

DSEIS then contains a table called “summary of 

impact levels for physical and biological 

resources” that rates impacts for each resource or 

issue except those categorized as social system 

resources. BLM does not explain why social 

system impacts are absent from this table. 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

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 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.
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L76-20 EarthJustice In the GMT-1 FSEIS, BLM applied a similar 

impact methodology and presented a similar table 

of impact levels. But for GMT-1, social system 

resources, including subsistence and 

environmental justice, were included in the table. 

Impacts to sociocultural systems, subsistence, 

and environmental justice were all rated as 

“major” in the GMT-1 FSEIS. BLM’s failure to 

apply the same methodology to social system 

resources in GMT-2, along with its failure to 

explain the omission, serves to obscure the 

severity of impacts to social system resources 

and presents an incomplete picture of the severity 

of impacts from GMT-2.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

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 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.

L76-21 EarthJustice As explained above, these impacts include the 

foreseeable indirect impacts of development of 

the Willow prospect under Alternatives A and B. 

Willow will occur in close proximity to GMT-2 and 

will affect the same subsistence resources as 

GMT-2, further harming the Nuiqsut community’s 

ability to participate in subsistence hunting and 

gathering. BLM has failed to fully account for and 

disclose the significant impacts to subsistence 

that will flow from GMT-2. 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

As a reasonably foreseeable future development the 

Willow Master Development Plan is covered in the 

cumulative effects analyses for all resources, including 

subsistence.
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L76-22 EarthJustice BLM must fully disclose the risks and 

environmental impacts of hydraulic fracturing 

(“fracking”) and other well stimulation to be used 

at the GMT-2 drilling project....BLM acknowledges 

that ConocoPhillips intends to use fracking to 

stimulate oil production, but the DSEIS is silent on 

the environmental effects of the practice. Fracking 

and acidizing cause environmental damages 

beyond those of conventional oil and gas 

development by producing water and air pollution, 

increasing the risk of earthquakes and oil spills, 

and prolonging the life of aging infrastructure and 

the production and consumption of fossil fuels. 

2.1 Proposed 

Action & 

Alternatives

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. As of July 2018, there have been no reports 

to AOGCC of increased seismicity on the North Slope 

or contamination of drinking water resulting from 

fracking operations. The spill risk associated with 

trucking fracking waste back to Alpine/CD1 for disposal 

is addressed in Section 4.5, Impacts of Oil, Saltwater 

and Hazardous Materials. GMT2 is a conventional 

sandstone formation, and will not require continuous 

hydraulic fracturing like unconventional shale 

formations in the lower 48.
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L76-23 EarthJustice Water contamination is a significant risk of 

fracking because of the hundreds of chemicals 

used in fracking fluid.

3.19 Hazardous 

Materials Spills

The Alaska Oil and Gas Conservation Commission 

(AOGCC) white paper on hydraulic fracturing in Alaska 

states "On the North Slope, Alaska’s most prolific oil 

and gas province, freshwater is 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 1000 to 2000 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 

addition, "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."

Updated Section 4.5 to include this information.

L76-24 EarthJustice Moreover, emissions from fracking have been 

found to pollute the air hundreds of miles 

downwind of operations.

3.5 Air Quality & 

Meteorology

Impacts associated with drilling and hydraulic fracturing 

operations were evaluated as part of the long-range air 

quality analyses for Alternatives A and C. Impacts were 

assessed at two sensitive areas (Arctic National 

Wildlife Refuge and Gates of the Arctic National Park 

and Preserve) which are located over 200 kilometers 

(125 miles) from the GMT2 Project Area. Maximum farfield impacts predicted for Alternative A at these two 

areas are reported in Tables 4.2-20 and 4.2-21, 

respectively, of the Draft SEIS. Maximum impacts 

predicted for Alternative C at these two areas are 

reported in Tables 4.2-29 and 4.2-30, respectively. The 

analysis demonstrates potential air quality impacts, 

including those from drilling and hydraulic fracturing 

activities, from the GMT2 Project are minimal.
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L76-25 EarthJustice Wastewater from well stimulation is injected 

underground, a disposal method that can result in 

leaks and contamination through the loss of well 

casing integrity. 

3.1 Geology and 

Physiography

No Class 1 disposal wells would be located at the 

GMT2 pad due to the lack of an acceptable disposal 

horizon . All Class 1 wastes would be transported 

offsite for disposal at CD1/Alpine Central Processing 

Facility, Prudhoe Bay drill site 4 grind and inject. This 

waste disposal wells are tightly regulated by the Alaska 

Oil and Gas Conservation Commission (AOGCC) for 

many reasons including to prevent damage to wellcasing. The sites are monitored and regulated by the 

EPA. 

L76-26 EarthJustice Risks to wetlands and water quality can arise from 

the storage and transport of well stimulation 

chemicals.

3.4 Water 

Resources

Agreed. This was mentioned in 2nd paragraph above 

4.2.2.4, Comparison of Alternatives.

L76-27 EarthJustice Chemicals that are being stored for fracking can 

also be susceptible to accidental spills and 

leaks... The site for GMT-2 is 99 percent 

wetlands, and it is subject to flooding, ice jams, 

and other severe weather that make the project 

vulnerable to spills and leaks.

3.19 Hazardous 

Materials Spills

Section 4.5 is updated to include a discussion of 

potential spills associated with fracking.

No changes to the text in response to the 2nd part of 

this comment. The GMT2 site is predominantly 

wetlands, and is subject to severe weather, as is the 

entire North Slope. The Conoco Phillips Oil Discharge 

Prevention and Contingency Plan for the Alpine Field 

and Satellites and Alpine Pipeline system provides a 

description of spill prevention and response strategies, 

and theoretical for spill responses for different weather 

conditions.

As stated in Section 3.2.2.1, page 80, "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. There are no additional new stream or river 

crossings proposed for the GMT2 Project, although 

smaller, seasonal flow drainages may be crossed."
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L76-28 EarthJustice The water withdrawal from lakes for the use in 

fracking must be evaluated... The substantial 

water withdrawals needed for fracking could 

cause fish mortality and low water levels in the 

project area, which could also harm birds such as 

the yellow-billed loon and spectacled eiders. The 

DSEIS has not adequately evaluated the volume, 

use, or environmental impacts of water use for 

fracking. 

3.4 Water 

Resources

Saltwater will be used for all hydraulic fracturing 

activities and will not result in impacts from water 

withdrawals from lakes.

L76-29 EarthJustice The water withdrawal from lakes for the use in 

fracking must be evaluated... The substantial 

water withdrawals needed for fracking could 

cause fish mortality and low water levels in the 

project area, which could also harm birds such as 

the yellow-billed loon and spectacled eiders. The 

DSEIS has not adequately evaluated the volume, 

use, or environmental impacts of water use for 

fracking. 

3.9 Fish Seawater would be hard-piped to GMT2 for use in 

hydraulic fracturing (HF) at approximately half the 

wells. There are no plans to utilize freshwater for HF. 

The Alaska Oil and Gas Conservation Commission 

regulates HF activities and those regulations can be 

found at 

http://doa.alaska.gov/ogc/regulations/regindex.html

L76-30 EarthJustice The water withdrawal from lakes for the use in 

fracking must be evaluated... The substantial 

water withdrawals needed for fracking could 

cause fish mortality and low water levels in the 

project area, which could also harm birds such as 

the yellow-billed loon and spectacled eiders. The 

DSEIS has not adequately evaluated the volume, 

use, or environmental impacts of water use for 

fracking. 

3.10 Birds Hydraulic fracturing for GMT2 will use seawater piped 

in from the Alpine facility. No water withdrawals from 

nearby freshwater lakes will occur for use in hydraulic 

fracturing. Section 2.4, Features Common to All 

Alternatives, has been updated with a detailed 

description of the hydraulic fracturing that will occur for 

the GMT2 Project.
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L76-31 EarthJustice Even if the earthquakes that fracking or related 

wastewater injection directly generates are small, 

fracking could be contributing to increased stress 

in faults that leaves those faults more susceptible 

to otherwise naturally triggered earthquakes of a 

greater magnitude. Alaska is seismically active, 

and the impacts on this seismicity on the project 

area need to be disclosed. 

3.1 Geology and 

Physiography

There is no evidence of induced seismicity from oil and 

gas activities on Alaska's North Slope. Concerns 

regarding hydraulic fracturing on the North Slope of 

Alaska appear to be based in the understanding of 

hydraulic fracturing activities in unconventional plays in 

the lower 48. Hydraulic Fracturing activities at GMT2 

will occur in conventional plays, meaning reservoirs 

have a well defined areal extent and are porous and 

permeable, which generally only require initial 

stimulation and far less volumes of fluid. All hydraulic 

fracturing activities are required to be reported to 

www.fracfocus.org, which includes well information and 

chemical disclosure. AOGCC regulations regarding 

hydraulic fracturing activities can be found at 

http://doa.alaska.gov/ogc/regulations.regindex.html.
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L76-32 EarthJustice BLM must analyze these serious hazards of 

fracking and well stimulation in its SEIS. It must 

also analyze the cumulative environmental, health 

and climate change impacts of well stimulation 

that is occurring across the North Slope.

4.0 Cumulative 

Effects Projects 

and Methodology

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. As of July 2018, there have been no reports 

to AOGCC of increased seismicity on the North Slope 

or contamination of drinking water resulting from 

fracking operations. The spill risk associated with 

trucking fracking waste back to Alpine/CD1 for disposal 

is addressed in Section 4.5, Impacts of Oil, Saltwater 

and Hazardous Materials. GMT2 is a conventional 

sandstone formation, and will not require continuous 

hydraulic fracturing like unconventional shale 

formations in the lower 48. GHG emissions from 

hydraulic fracturing were included in the quantitative 

estimate of GHG resulting from GMT2.
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L76-33 EarthJustice BLM must analyze these serious hazards of 

fracking and well stimulation in its SEIS. It must 

also analyze the cumulative environmental, health 

and climate change impacts of well stimulation 

that is occurring across the North Slope.

3.18 Public 

Health

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. As of July 2018, there have been no reports 

to AOGCC of increased seismicity on the North Slope 

or contamination of drinking water resulting from 

fracking operations. The spill risk associated with 

trucking fracking waste back to Alpine/CD1 for disposal 

is addressed in Section 4.5, Impacts of Oil, Saltwater 

and Hazardous Materials. GMT2 is a conventional 

sandstone formation, and will not require continuous 

hydraulic fracturing like unconventional shale 

formations in the lower 48. GHG emissions from 

hydraulic fracturing were included in the quantitative 

estimate of GHG resulting from GMT2.
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L76-34 EarthJustice BLM must analyze these serious hazards of 

fracking and well stimulation in its SEIS. It must 

also analyze the cumulative environmental, health 

and climate change impacts of well stimulation 

that is occurring across the North Slope.

3.7 Climate 

Change

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. As of July 2018, there have been no reports 

to AOGCC of increased seismicity on the North Slope 

or contamination of drinking water resulting from 

fracking operations. The spill risk associated with 

trucking fracking waste back to Alpine/CD1 for disposal 

is addressed in Section 4.5, Impacts of Oil, Saltwater 

and Hazardous Materials. GMT2 is a conventional 

sandstone formation, and will not require continuous 

hydraulic fracturing like unconventional shale 

formations in the lower 48. Text in Sections 2.4, 4.3 

and 4.5 have been updated to reflect this information.

L76-35 Earth justice BLM must consider alternatives that mitigate or 

avoid the effects of fracking on the human 

environment, including an alternative that 

prohibits fracking and acidization. 

2.1 Proposed 

Action & 

Alternatives

Acidizing will not occur at GMT2 wells because the 

source rock does not lack permeability that can be 

enhanced by acidizing . 

L76-36 Earth justice For the foregoing reasons, GMT-2, as proposed, 

threatens significant impacts to the climate and to 

biological and social resources. The DSEIS does 

not satisfy NEPA’s requirements to take a hard 

look at these significant impacts. We therefore 

request that BLM revise the DSEIS and solicit 

public comment on the revised draft before it 

considers finalizing the DSEIS and selecting an 

alternative. 

1.1 Executive 

Summary & 

Introduction

This is a supplemental EIS, supplementing the 2004 

Alpine Satellite Development Plan EIS to address new 

information and minor changes to the project proposal. 

The 2004 EIS addressed impacts to climate, biological, 

and social resources. Changes to the project proposal 

reduce impacts compared to those analyzed in the 

2004 Alpine EIS. 
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L77-1 Audubon 

Alaska

Explain deviations from Best Management 

Practices as described in the IAP 

The recommended lease stipulations and best 

management practices (BMPs) that appear in the 

IAP are important tools for maintaining the 

balanced approach as development takes place in 

the NPRA. The GMT2 project should adhere as 

closely as possible to the BMPs in the IAP. 

2.1 Proposed 

Action & 

Alternatives

The BLM regards the BMPs identified in the 2013 IAP 

ROD as extremely important requirements applicable to 

operation and development in the reserve. However, 

given that the IAP covers the entirety of the 23 million 

acre NPR-A, it was recognized by the BLM that in 

certain circumstances, operators may not be able to 

meet the requirements/specified in certain BMPs. It is 

for this reason that the ability for an applicant to request 

a deviation from BMPs as part of an authorization 

application is included within the IAP ROD. In 

proposing a deviation, the BLM must determine 

whether or not the objective of the BMP will be met 

before granting the deviation. The SEIS does not grant 

deviations to existing lease stipulations or best 

management practices, only a Record of Decision can 

grant a deviation. Instead, Section 2.2 of the SEIS 

describes the two deviations that are being requested 

by the applicant, and provides information regarding 

the rationale of the request. If the deviations are 

granted in the Record of Decision, the document will 

include text that explains the information considered in 

making the decision to allow a deviation to occur. 

L77-10 Audubon 

Alaska

The DEIS should also compare the cumulative 

impacts to caribou between the alternatives. The 

cumulative impacts section for caribou compares 

the direct impacts of roads and air traffic for 

caribou from the alternatives, but does not 

actually compare the cumulative impacts between 

the alternatives. This is an opportunity to discuss 

whether and how a road-based or roadless 

alternative may shape future development in the 

project area. If this type of discussion and 

analysis exists in prior planning documents, the 

agency should reference that material and apply 

those ideas to the current project. 

3.11 Caribou The DEIS acknowledges future leases and proposed oil 

development could expose a large number of the TCH 

caribou to exploration and development activities 

during most of the year. 
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L77-11 Audubon 

Alaska

Monitoring and public access to data

Audubon Alaska continues to advocate for greater 

public access to the data that underlie the 

agency’s analysis and conclusions for the 

Western Arctic, like those contained in this DEIS. 

For example, in the section on caribou in the 

Affected Environment Chapter, the agency relies 

heavily on data contained in industry reports 

which are not available to the public. The agency 

should consider offering shapefiles or 

geodatabases on their e-planning website in a 

similar manner to data made available that was 

used in developing the IAP. 

5.1 Maps and 

GIS Data

We understand the request for greater transparency of 

project data and thank you for noticing that our IAP 

website did make GIS data available to the public. GIS 

data for the NPRA IAP were created by BLM-Alaska 

and were, therefore, public information. Data for the 

GMT-2 project from Conoco was used with a data use 

agreement stating that the data are "the proprietary 

confidential property of Conoco Phillips Alaska Inc. to 

be used solely to create maps and diagrams of CPAI 

project areas." Data were, therefore, not distributed to 

the public.

L77-2 Audubon 

Alaska

The Draft EIS explains that BLM will grant 

deviations from Stipulation E-2 and BMP E-7(c), 

but does not connect the dots to explain why in 

this case these deviations are being granted. 

Instead, the agency references reasons for 

granting these deviations in the past for GMT1,1 

or simply states that the agency will grant the 

deviations. The DEIS does explain that the road 

for both Alternative A and Alternative B will be 

placed to protect the Fish Creek drainage area 

from a potential oil spill from the pipeline,3 but it’s 

not clear whether this rationale supports the 

placement of the road north of the pipeline, or if 

this rationale supports the granting of the BMP 

deviations. The agency should add explanation 

for why it grants the deviations for the areas 

indicated on Map 2.5-2 and Map 2.6-2.

2.1 Proposed 

Action & 

Alternatives

The SEIS does not grant deviations to existing lease 

stipulations or best management practices, only a 

Record of Decision can grant a deviation. Instead, 

Section 2.2 of the SEIS describes the two deviations 

that are being requested by the applicant, and provides 

information regarding the rationale of the request. If 

the deviations are granted in the Record of Decision, 

the document will include text that explains the 

information considered in making the decision to allow 

a deviation to occur. 
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L77-4 Audubon 

Alaska

The issue of predation on loons, however, merits 

more analysis and description in the DEIS. In the 

Affected Environment section, the DEIS explains 

that loons are vulnerable to nest predation by a 

number of avian predators including Golden 

Eagles, Bald Eagles, Short-eared Owls, Northern 

Harriers, Glaucous Gulls, Parasitic Jaegers, and 

Common Ravens. The DEIS also notes that the 

abundance of predators, including Common 

Ravens, have increased as infrastructure in 

Prudhoe Bay has increased. But in the section on 

Environmental Consequences, the analysis on the 

topic of predation on Yellow-billed Loons is a 

single statement that only mentions ravens 

specifically at the Alpine site. 

3.10 Birds Thank you for your comment. Information has been 

added in the yellow-billed loon sections of chapter 3 

and 4 to provide more information for the reader. 
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L77-5 Audubon 

Alaska

This short statement misses consideration of 

other avian predators that are mentioned earlier in 

the DEIS, and does not make clear the 

connection between observations and studies 

elsewhere and what could occur at GMT2. The 

increase of ravens in Prudhoe Bay is applicable to 

the GMT2 site and the cumulative effects 

analysis. Research on the connection between 

infrastructure and increased nest predation on

passerines and shorebirds is also applicable to 

analysis on this topic. Explaining the dynamics—

or pointing out the gaps in our understanding—of 

infrastructure causing or correlating with an 

increase in avian predation should be included in 

the sections analyzing impacts on Yellow-billed 

Loons in the area, as well as part of the 

cumulative impacts section. This topic is of 

particular interest for this project as development 

abuts the Colville River Special Area, an area 

where raptors nest in high densities. With 

abundant source populations so close to novel 

nesting and perching habitat, these areas could 

experience significantly more colonization than 

that observed in the Prudhoe Bay industrial 

complex. 

3.10 Birds Thank you for your comment. Research on the 

connection between infrastructure and increased nest 

predation on passerines and shorebirds (Liebezeit et al. 

2009) showed no effect of human infrastructure on nest 

survival for shorebirds as a group and that posteriori 

fine-scale analysis suggested that red phalaroped and 

red-necked phalaropes combined had lower 

productivity closer to infrastructure but no relationship 

was found for the 2 most abundant shorebirds in the 

study area. However evidence was found that risk of 

predation for passerine nests increased within 5 km of 

infrastructure. Text will be added to the passerine 

sections in chapter 3 and 4 to reflect this information.
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L77-7 Audubon 

Alaska

Cumulative impacts on caribou 

The cumulative impacts section for caribou in the 

DEIS should acknowledge the uncertainty in 

population-level impacts to caribou herds from oil 

and gas development. The cumulative impacts 

section concludes, “[o]verall, industry and agency 

actions on the North Slope are expected to have 

minor impacts to caribou herd productivity.” But in 

other sections the DEIS discusses data, 

observations, and trends that would tend to 

support a conclusion of uncertainty instead of a 

conclusion of cumulatively “minor” impacts in the 

overall development picture facing the North 

Slope of Alaska. The DEIS notes how the Central 

Arctic Herd has in fact responded to oil and gas 

development in Prudhoe Bay, but notes that 

research has yet to determine whether these 

impacts are reflected in population trends: 

"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. . . . 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."

3.11 Caribou This is a relevant comment pertaining to the uncertainty 

in population-level impacts to caribou herds from oil 

and gas development. The comment challenges the 

concluding statement that industry and agency actions 

on the North Slope are expected to have minor impacts 

to caribou herd productivity. The cumulative impacts 

from Willow would include: direct and indirect loss of 

habitat that could displace caribou from preferred 

habitats and result in long term changes is distribution

of the TCH. The cumulative impact section reflects this 

uncertainty in population level effects due to oil 

development. In addition the new Willow Project has 

been added to the cumulative impact section. 
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L77-8 Audubon 

Alaska

The DEIS should consider that the GMT2 project 

is one part of overall past and present oil 

infrastructure that could give rise to a level of 

development that causes caribou in the project 

area to respond with this type of behavior. 

Whether this in fact manifests in a populationlevel impact is not yet definitively known, but the 

agency’s conclusion on this matter should be one 

of uncertainty rather than an expectation of minor 

impacts. 

3.11 Caribou This is a relevant comment pertaining to the uncertainty 

in population-level impacts to caribou herds from oil 

and gas development. The comment challenges the 

concluding statement that industry and agency actions 

on the North Slope are expected to have minor impacts 

to caribou herd productivity. The cumulative impacts 

from Willow would include: direct and indirect loss of 

habitat that could displace caribou from preferred 

habitats and result in long term changes is distribution 

of the TCH. The cumulative impact section reflects this 

uncertainty in population level effects due to oil 

development. In addition the new Willow Project has 

been added to the cumulative impact section. 

L77-9 Audubon 

Alaska

The cumulative impacts section for caribou should 

also tie the discussion on the Central Arctic Herd 

response to infrastructure to population numbers 

for the Central Arctic Herd and the Teshekpuk 

Herd. In the same paragraph where the DEIS 

notes the pattern of displacement seen in the 

Central Arctic Herd, the agency mentions the 

Western Arctic Caribou Herd population numbers, 

but omits even any reference to current 

population numbers for the Teshekpuk and 

Central Arctic Herds. The agency should add 

reference to the population estimates and trends 

for these two herds, which overlap the project 

area. The agency should also offer analysis of a 

connection between the response pattern seen in 

the Central Arctic Herd and the trend and 

population status for the herds within the project 

area. We also note that a greater proportion of 

caribou are over-wintering in the NPRA, which 

has implications for winter road construction. This 

issue needs more discussion, and should be tied 

to the cumulative impacts analysis for caribou in 

the DEIS. 

3.11 Caribou Part 1. 2017 population estimates and trends for the 

TCH show an increase in population since 2015. 

Results from 2016 and 2017 populations estimates 

were not directly comparable but demographic metrics 

collected during this same period indicated the herd 

has probably remained relatively stable. (see update to 

3.3.4.1 Population dynamics from ADGF). The 

statement that "disturbance of caribou due to oil field 

development may adversely affect caribou populations, 

but these impacts are not readily apparent based on 

population trends." is still relevant. Part 2. An analysis 

of a connection between the response pattern seen in 

the Central Arctic Herd and trend and population status 

for the TCH based on data discussed in the Population 

Dynamics section show similar patterns of population 

increases and decreases since 1990, although the TCH 

population seems to have increased in recent years 

(since 2011) while the CAH has steadily decreased or 

remained stable. The CAH is currently about 26,000 

animals much less than a peak of 68,000 animals in 

2010. TCH is estimated at over 50,000 animals 

compared to a peak estimate of 68,000 caribou in 

2008. 
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L78-2 Alternative A will include a road connection to 

existing infrastructure at GMTl facilities. This 

would increase access to emergency response 

resources from both the human resource and 

environmental perspectives removing the weather 

factor involved with remote sites that are 

dependent on aircraft only. 

3.18 Public 

Health

Noted, further discussion in SEIS in Section 2.7, 

Alternative C: Roadless Access and Section 4.5, 

Impacts of Oil, Saltwater and Hazardous Materials 

Spills.

L81-1 US Fish And 

Wildlife Service

The DSEIS indicates the new cells mined for the 

GMT-2 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. As of 12-years post-construction 

approximately 80% of the overburden islands 

have disappeared and the channel cut islands 

and adjacent littoral area are beginning to 

subside. 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. The Service therefore suggests 

Phase 3 of the ASRC pit be mined without the 

intention of creating shallow habitats. Best 

Management Practices (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. 

4.2 Mitigation See Section 4.3.3 Birds, Potential Mitigation Measure 

3: Gravel Pit Rehabilitation.
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L81-10 US Fish And 

Wildlife Service

Cumulative Wetlands Impacts: Wetland impacts 

are assessed as the difference between the 

current wetland functional condition (baseline) 

and the anticipated functional condition after the 

wetland impact (USACE undated). The length of 

time after the impact when the wetland functional 

condition is assessed can have a substantial 

impact on the difference between before and after 

wetland function. Wetland type and latitude can 

also affect this “temporal” delay between baseline 

function and the reclaimed function. In addition, 

some wetland types never recover all their 

wetland functions after an impact (i.e., a 

permanent loss of function). The Service 

recommends the impacts analysis for wetlands 

include an assessment of the difference between 

baseline and post-impact wetland function, based 

on a defined length of recovery. Any functional 

loss after that period should be considered a 

permanent loss. Temporal loss (i.e., the time lag 

between the loss and replacement of wetland 

function) should also be considered. The Service 

recommends considering any temporary loss in 

wetland function after 10 to 15 growing seasons 

on the North Slope a permanent loss. 

3.8 Vegetation 

and Wetlands

Added: "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." in 

impacts section for Alt. A, B, and C. 
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L81-3 US Fish And 

Wildlife Service

Migratory Birds: Approximately 80 species of 

migratory birds are known to move through or 

nest within the vicinity of the proposed project. Of 

these, nine species (red-throated loon, yellowbilled loon, peregrine falcon, whimbrel, bar-tailed 

godwit, red knot, dunlin, buff-breasted sandpiper, 

and arctic tern) are considered to be Birds of 

Conservation Concern by the Service due to their 

small population size, population decline, and/or 

sensitivity to disturbance. Three species of birds, 

golden eagle, short-eared owl, and red knot are 

listed as sensitive species by the Bureau of Land 

Management (BLM) and may occur in the project 

area. 

3.10 Birds Thank you for your comment. This EIS lists the BLM 

sensitive species and provides information on those 

species

L81-4 US Fish And 

Wildlife Service

Fish: Eighteen freshwater, anadromous, and 

nearshore marine fish species are known to occur 

within the GMT-2 project area including Arctic 

grayling, broad whitefish, and least cisco. Of 

these, 8 species (arctic and least cisco, Dolly 

Varden, arctic grayling, broad and humpback 

whitefish, and pink and chum salmon) are 

considered to be important subsistence species 

for Nuiqsut. Essential Fish Habitat (EFH) has 

been established for pink and chum salmon in the 

lower Colville River. The Ublutuoch River and 

Fish Creek are used by most fish as migratory 

channels within the GMT-2 area, providing 

overwintering habitat and access to beaded 

streams and lakes during the summer. 

3.9 Fish Potential impacts to fish species ("trust resources" of 

the USFWS) are thoroughly analyzed for each 

alternative, with numerous BMPs included that are 

intended to mitigate each of those potential impacts.
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L81-6 US Fish And 

Wildlife Service

The Service listed the polar bear as a threatened 

species under the Endangered Species Act on 

May 15, 2008 (73 FR 28212). On October 29, 

2009, the Service proposed critical habitat for 

polar bears (74 FR 56058) and a final rule 

designating critical habitat was issued on 

December 7, 2010 (75 FR 76086). However, the 

U.S. District Court for the District of Alaska issued 

a decision to the Service on January 11, 2013 

which vacated and remanded the final rule on 

polar bear critical habitat in Alaska Oil and Gas 

Association et al. v. Salazar et al. (D. Alaska) 

(3:11-cv-00025-RRB). On February 29, 2016 the 

Ninth Circuit Court of Appeals upheld the final 

polar bear critical habitat rule on all points. The 

GMT-2 project area would occur within Unit 2, 

terrestrial denning habitat, of designated polar 

bear critical habitat (75 FR 76085).

3.13 Threatened 

and Endangered 

Species

Thank you for your comment. The polar bear section 

has been edited to make clear that part of the project 

study area is within polar bear critical habitat.

L81-6 US Fish And 

Wildlife Service

Wetlands and Vegetation: The Wetlands and 

Vegetation chapter of the DSEIS is 

comprehensive and is generally well written. The 

Service appreciates the development and 

inclusion of inundation and drying estimates as 

impacts from diverted sheetflow due to 

construction of GMT-2 infrastructure. Even with 2 

ft. diameter culverts placed approximately every 

1000 ft. along the road, upstream inundation 

estimates for Alternative A (preferred alternative) 

exceed 160 acres and downstream drying 

impacts exceed 70 acres. The alteration of 

sheetflow across the landscape as a result of 

long-linear structures, such as roads, has 

substantive impacts and may over time change 

vegetation and habitats through alteration and 

channelization of sheetflow through culverts. 

3.8 Vegetation 

and Wetlands

Added: "... however, change in vegetation over time is 

still possible due to alteration and channelization of 

sheet flow through culverts." in list of direct and indirect 

impacts. 
Supplemental Environmental Impact Statement

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L81-7 US Fish And 

Wildlife Service

Dust impacts from vehicles on the road also may 

impact vegetation on the downwind side of the 

road. According to the DSEIS however, these 

impacts likely do not exceed beyond 300 ft. from 

the road. This estimate is based on a study 

conducted in the 1970s along the haul road. The 

Service believes dust impacts exceed 300 ft. 

(based on field observations and measurements) 

and encourages the development of a 

comprehensive study to determine dust-related 

impacts associated with new developments in the 

NPR-A. The Service also supports the Proposed 

New Mitigation Measure 1: Alaska Natural 

Resources Conservation Service Level II Soil 

Survey to establish baseline conditions of soils 

within 1,000-meter radius of all planned gravel 

infrastructure in NPR-A. This study would 

establish baseline soil conditions and allow the 

BLM to monitor changes to the soil profile and 

vegetation as a result of dust resulting from 

industrial activity. 

3.8 Vegetation 

and Wetlands

The best available information indicates a 300 ft. zone 

of impact from dust. Therefore, that is the only 

information available to base effects upon. 
Supplemental Environmental Impact Statement

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L81-8 US Fish And 

Wildlife Service

Facility Lighting: As with any development project, 

unavoidable impacts to the area surrounding the 

GMT-2 development are likely to occur. However, 

the Service believes some of these impacts such 

as excessive light can be mitigated through the 

incorporation of specific design features and 

placement of the facilities. Lighted facilities (drill 

rigs and buildings) can cause episodic bird 

collisions with infrastructure, especially during 

migration and inclement weather. On the North 

Slope birds are especially vulnerable to collisions 

during fall (mostly westward) migration when 

ambient light is low and there are frequent periods 

of stormy weather and fog. Birds are attracted to 

the lights and become disoriented potentially 

colliding with buildings and drill rigs. To mitigate 

the collision risk, the Service recommends facility 

lighting be shielded from above thereby reducing 

reflectivity in clouds and fog. 

4.2 Mitigation See Section 4.3.3 Birds, Potential Mitigation Measure 

2: Facility Lighting.
Supplemental Environmental Impact Statement

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L81-9 US Fish And 

Wildlife Service

Invasive Weeds: The Service recommends 

implementing BMPs for minimizing the 

introduction and proliferation of invasive species, 

including thoroughly washing equipment to 

remove dirt and debris that might harbor invasive 

seeds before entering the jobsite, using weed-free 

fill, appropriately disposing of spoil and vegetation 

contaminated with invasive species, and 

revegetating with local native plant species. This 

is particularly important at sites adjacent to 

waterways where an introduced species could be 

easily transported downstream and spread 

throughout areas that would not otherwise be 

exposed to invasive species. River corridors 

provide an easy pathway for spreading invasive 

species throughout the otherwise inaccessible 

regions of Alaska. We also recommend on-theground personnel understand their role in 

preventing and controlling the introduction and 

spread of aquatic and terrestrial invasive species.

3.8 Vegetation 

and Wetlands

The following stipulation was included in the last 

Integrated Activity Plan for all development in NPRA. 

Alternative B-2 was chosen in the ROD, so this 

stipulation applies to GMT2. 

M-2 Best Management Practice. NOTE: This best 

management practice is applicable only to 

Alternative B-2. There would be no comparable 

provision for any of the other alternatives. Objective: 

Prevent the introduction, or spread, of non-native, 

invasive plant species in the NPR-A. 

Requirement/Standard: Certify that all equipment and 

vehicles (intended for use either off or on roads) are 

weed-free prior to transporting them into the NPR-A. 

Monitor annually along roads for non-native invasive 

species, and initiate effective weed control measures 

upon evidence of their introduction. Prior to operations 

in the NPR-A, submit a plan for the BLM’s approval, 

detailing the methods for cleaning equipment and 

vehicles, monitoring for weeds and weed control.
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Comment Response

L82-1 Conservation 

Lands 

Foundation

Statistics generated from GMT-1 Final SEIS and 

BLM lease sale data, and Braund & Associates 

1994-2003, as reported in Appendix G, Figure G1 of the Final Supplemental EIS for GMT1, 

suggest there are approximately 724,774 acres of 

leased lands within the NPR-A within Nuiqsut’s 

subsistence use area. Statistics generated from 

GMT-1 Final SEIS, BLM lease sale data, Alaska 

Department of Natural Resources data, and 

Bureau of Ocean Energy Management data, 

indicate that the total acreage of Nuiqsut 

subsistence area lands and waters that has been 

leased is much greater and includes 

approximately 3 million acres broken down as 

follows: 724,774 acres of NPR-A lands; 1,581,213 

acres of state onshore lands; 302,575 acres in 

federal off- shore waters, and 416,255 acres in 

State offshore waters. 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

The text has been edited to include this information in 

the Cumulative Effects: Subsistence section. 

L82-2 Conservation 

Lands 

Foundation

GMT-2 should not move forward until the BLM 

completes the RMS and offsets impacts resulting 

from the violation of the Fish Creek Setback. 

Instead, Conoco and BLM are pushing forward 

with permitting for GMT-2. The GMT-2 project 

would further extend the industrial footprint and 

road network by requiring an additional 8.1-mile 

gravel access road, a 14-acre gravel pad with 

capacity for 48 wells, an additional 8.6 miles of 

pipeline and more, while also serving as a 

building block for future development. This 

infrastructure represents a doubling of the size of 

GMT-1, which was already found to have major 

unavoidable and adverse impacts to subsistence 

access and resources for Alaska Native 

communities in the arctic. This is happening 

without the RMS.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

GMT2 was originally approved for development as CD7 in 2004 under the Alpine Satellite Development Plan 

EIS, as was GMT1 (as CD-6). As described in Section 

1.4 Purpose and Need for Federal Action, under federal 

statutes the BLM is required to issue the GMT2 permit 

for oil development in the NPR-A and cannot choose 

the No-Action alternative. Text is revised to include 

discussion regarding the GMT1 Compensatory 

Mitigation Fund and the Regional Mitigation Strategy.
Supplemental Environmental Impact Statement

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Comm # Commenter 

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Comment Response

L82-3 Conservation 

Lands 

Foundation

CLF staff recently attended the GMT-2 meeting in 

Nuiqsut. Members of the community proposed a 

no-action alternative until the impacts of GMT-1 

are fully realized. They noted that BLM was 

moving too quickly without fully analyzing the 

effects to human health and subsistence 

resources. Many expressed the need for a 

comprehensive plan. These are very reasonable 

requests and CLF strongly urges BLM to listen-to 

and follow through on the promises made to the 

Village of Nuiqsut. Specifically, BLM should delay 

further development until the agency: 1) fully 

studies the impacts to human health and 

subsistence of GMT-1 & GMT-2; and 2) finalize 

the RMS and mitigate for the harm caused by 

GMT-1 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

GMT2 was originally approved for development as CD7 in 2004 under the Alpine Satellite Development Plan 

EIS, as was GMT1 (as CD-6). As described in Section 

1.4 Purpose and Need for Federal Action, under federal 

statutes the BLM is required to issue the GMT2 permit 

for oil development in the NPR-A and cannot choose 

the No-Action alternative. Text is revised to include 

discussion regarding the GMT1 Compensatory 

Mitigation Fund and the Regional Mitigation Strategy.

L82-4 Conservation 

Lands 

Foundation

CLF staff recently attended the GMT-2 meeting in 

Nuiqsut. Members of the community proposed a 

no-action alternative until the impacts of GMT-1 

are fully realized. They noted that BLM was 

moving too quickly without fully analyzing the 

effects to human health and subsistence 

resources. Many expressed the need for a 

comprehensive plan. These are very reasonable 

requests and CLF strongly urges BLM to listen-to 

and follow through on the promises made to the 

Village of Nuiqsut. Specifically, BLM should delay 

further development until the agency: 1) fully 

studies the impacts to human health and 

subsistence of GMT-1 & GMT-2; and 2) finalize 

the RMS and mitigate for the harm caused by 

GMT-1.

3.18 Public 

Health

GMT2 was originally approved for development as CD7 in 2004 under the Alpine Satellite Development Plan 

EIS, as was GMT1 (as CD-6). As described in Section 

1.4 Purpose and Need for Federal Action, under federal 

statutes and the terms of the subject NPR-A leases the 

BLM is required to issue a permit allowing for develop 

of GMT2’s oil and gas, subject to reasonable regulation 

and cannot choose the No-Action alternative. The BLM 

is also required to process permit applications in a 

timely manner pursuant to Onshore Order 1. Text is 

revised to include discussion regarding the GMT1 

Compensatory Mitigation Fund and the Regional 

Mitigation Strategy.
Supplemental Environmental Impact Statement

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L83 Environmental 

Defense Fund, 

Institute for 

Policy Integrity, 

Natural 

Resources 

Defense 

Council, Sierra 

Club, Union of 

Concerned 

Scientists, and 

Wilderness 

Society

See Letter L83 3.7 Climate 

Change

Executive Order 13783 (Promoting Energy 

Independence and Economic Growth) issued in 2017, 

rescinded the policy requirement for federal agencies to 

consider the social cost of carbon in decision making. 

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.

L85-1 BP Exploration 

Alaska, Inc.

The Draft SEIS seeks to provide both qualitative 

and quantitative impacts from GHG emissions 

from the project. However, the document does not 

provide a context for the estimated GHG 

emissions from this relatively small project. While 

the DSEIS estimates that GHG emissions over 

the life of the project (30 years), the estimated 

direct GHG emissions (457,000 metric tons) are 

quite small on a national/global perspective. On 

an annual basis, these GHG emissions (16,000 

metric tpy) are equivalent to the GHG emissions 

from roughly 1,700 homes in the U.S. [US EPA 

GHG Equivalencies Calculator, 

https://www.epa.gov/energy/greenhouse-gasequivalencies-calculator]. As a point of reference, 

the U.S. builds roughly 900,000 to 1.4 million new 

homes annually. Thus, the direct GHG emissions 

from GMT2 represent only 0.2% of the emissions 

from new homes in the U.S. on an annual basis. 

This level of GHG emissions for the project 

therefore does not warrant significant further 

analysis in the SEIS.

3.7 Climate 

Change

It is not appropriate to evaluate emissions solely as a 

specific portion of national emissions. What matters is 

the difference between the Alternatives, not the 

difference between some of the Alternatives and other 

projects (like home building) which would not replace 

the proposed action. The climate change analysis has 

been updated between Draft and Final to include a 

comparison of the estimated oil production at GMT2 to 

oil produced on the North Slope, oil produced in the 

State of Alaska, and oil produced nationally. See 

section 4.2.4, Climate Change. 
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L85-2 BP Exploration 

Alaska, Inc.

As calculated in the DSEIS, the indirect GHG 

emissions are nearly 2 orders of magnitude 

greater than the direct GHG emissions (457,000 

metric tons vs. 43.18 million metric tons), and the 

indirect GHG emissions are mostly related to 

downstream refining and consumption of the oil 

produced from GMT2. Market forces drive these 

indirect emissions and oil refinery production and 

oil consumption will be produced regardless of the 

development of GMT2. The “No Action” 

alternative essentially verifies this; however, the 

assumptions and inputs used for the calculation of 

the indirect emissions (for both the Action and the 

No Action alternatives) have significant inherent 

uncertainties. Additionally, minor oil market 

influences (such as fuel efficiency policies, 

refinery outages, and/or global market stability) 

may greatly impact the levels of these indirect 

emissions. 

3.7 Climate 

Change

The BOEM Greenhouse Gas Lifecycle Model 

represents the best available information incorporating 

such market forces and was used in the GMT2 analysis 

for this reason. Uncertainties and assumptions of the 

modeling are spelled out in Appendix H. 

L85-3 BP Exploration 

Alaska, Inc.

The DSEIS does not fully quantify the benefits 

produced from the development of the project. 

The development of GMT2 provides additional oil 

for the continued operations of the Alpine 

production facility, which in turn provides oil for 

the continued operations of the Trans-Alaska 

Pipeline System (TAPS) and the greater Alaska 

North Slope. The Alpine facility also provides 

natural gas for home heating and power plant 

operations for the Village of Nuiqsut (as described 

in Section 4.4.2.1). This natural gas would likely 

not be available if Alpine operations were ended. 

3.16 Economy Extending the life of the Trans-Alaska Pipeline System 

is disclosed in 4.4.3.2. The benefits of access to natural 

gas for the community of Nuiqsut as a result of oil and 

gas development are mentioned in Section 4.4.7, 

Public Health. 
Supplemental Environmental Impact Statement

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L85-4 BP Exploration 

Alaska, Inc.

The environmental benefits of this natural gas are 

not evaluated in the DSEIS. As compared to the 

Village’s prior use of fuel oil, natural gas results in 

improved air quality, lower GHG emissions, and 

lower fuel spill risks. These beneficial 

environmental impacts from continued Alpine 

operations should be considered in the SEIS.

3.18 Public 

Health

An acknowledgement of the GMT2 Project's 

contribution to Nuiqsut's natural gas program has been 

added to Section 4.4.6.1

L85-5 BP Exploration 

Alaska, Inc.

The environmental benefits of this natural gas are 

not evaluated in the DSEIS. As compared to the 

Village’s prior use of fuel oil, natural gas results in 

improved air quality, lower GHG emissions, and 

lower fuel spill risks. These beneficial 

environmental impacts from continued Alpine 

operations should be considered in the SEIS.

3.5 Air Quality, 

Climate and 

Meteorology, Air 

Quality

The text of the SEIS has been updated in Section 

4.4.6.1 to acknowledge GMT2's contributions to natural 

gas energy in Nuiqsut. 

L85-6 BP Exploration 

Alaska, Inc.

The DSEIS should be updated to reflect current 

North Slope projected TAPS throughputs and 

assumptions for the economic impact analyses 

described in Section 4.4.3 (Table 4.4-4) (e.g. the 

Fall 2017 and Spring 2018 Revenue Forecast, 

and the EIA’s Annual Energy Outlook for 2017).

3.16 Economy Total Alaska North Slope production numbers were 

updated with the most current projections from the 

Alaska Department of Revenue.

L86-1 North Slope 

Borough

Nuiqsut's hunters are concerned that seismic 

exploration and helicopter activity drive caribou 

away. We request that aerial helicopter surveys 

be cut down to every other year to reduce air 

traffic.

4.2 Mitigation Two proposed mitigation measures described in 

Section 4.4.5 Subsistence address concerns about 

caribou during high activity. Potential Mitigation 

Measure 2: Suspend Non-essential Helicopter Traffic 

during Peak Caribou Season addresses a break of air 

activity during peak caribou hunting time. Potential 

Mitigation Measure 3: Consultation Regarding Aircraft 

Communication Protocols addresses communication 

protocols with Nuiqsut about flight patterns and 

frequency.
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L86-10 North Slope 

Borough

It is important to make the phrase "Proposed 

Study Area" clear and distinct to understanding 

overall risk analysis. BLM notes that risk analysis 

on all resources is related to the larger "Proposed 

Study Area" and not merely the "Proposed 

Permanent Infrastructure." An unclear distinction 

at the beginning of an EIS makes a significant 

difference when reading sentences, such as the 

following on page 332, Section 4.3.2.5 

Conclusion: "[g]iven the fairly low level of fish 

resources present in the immediate area between 

GMTl and GMT2, the intensity of effects would 

likely be 'low' and the duration would likely be 

'temporary."' 

2.1 Proposed 

Action & 

Alternatives

Additional text regarding the project study area has 

been added to the beginning of Chapters 3 and 4 in 

Sections 3.1.1 and 4.1.1 that will assist the reader in 

understanding the affected environment and 

environmental consequences of the alternatives.

L86-11 North Slope 

Borough

With an unclear distinction among areas, one 

might easily conclude that risk analysis is 

restricted to the area specified with its "fairly low 

level of fish resources" is the study area. This is 

not the case, of course. The "proposed study 

area" is most likely not an area with "fairly low 

level of fish resources." (See maps Fig. 3.4-7, Fig. 

3.4-13, -14, and -15 and for more evidence, see 

Map 3.3-2 indicating anadromous rivers and 

streams and identifying specific lakes designated 

as "Sensitive Fish Species Present," including 

ones near GMTl and GMT2. Map 3.3-4 also notes 

essential fish habitat within the "Project Study 

Area" as having king salmon and pink-chum 

salmon present. In 2009, the Tingmiaqsiugvik 

(Ublutuoch River) was found to have nine species 

present in June and July, including Arctic grayling, 

whitefishes (broad, least, humpback, and round) 

(Moulton, L. Fish populations in streams to be 

crossed by a proposed road to the GMT-1 well 

pad in Eastern NPR-A: 2009. Final report). 

3.9 Fish "fairly low level of fish resources" was removed from 

the text.
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L86-12 North Slope 

Borough

Additionally, much of the in-depth discussion and 

analysis produced for the GMTl SEIS applies as 

well to GMT2, since GMT2 is close to and 

associated with GMTl. However, discussions and 

analyses from the GMTl SEIS are not included or 

summarized in any detail in the GMT2 DSEIS 

and should be incorporated rather than simply 

cited. For instance, "Pedersen et al. (2000) 

provides the most detailed analysis of . . . impact, 

noting that harvest location information for 

Nuiqsut from 1993 and 1994 'provide support for 

the claim of displacement from traditional hunting 

areas."' If this was true for GMTl, then it seems 

that the impact of GMT2 would further displace 

hunters and be even more of a substantial 

restriction on subsistence uses. (page 435, 

Section 4.4.5.3 Impacts under Alternative A, in 

Alpine Satellite Development Plan GMTl 

Development Project Final Supplemental 

Environmental Impact Statement). 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Avoidance was discussed as an impact to subsistence 

both under the section on Construction (4.4.5.4) and 

under Drilling and Operation (4.4.5.5) in the Draft SEIS. 

The research noted in the comment was discussed 

under Construction. In the Final SEIS, the text has 

been edited and the detailed discussion of avoidance 

has been consolidated into section 4.4.5.5 (Drilling and 

Operation) to discuss possible impacts and 

countervailing impacts to avoidance of the GMT2 

project and access road during the life of the project. 

Input from key stakeholders on the potential magnitude 

of the avoidance effect has also been included in that 

section. 

L86-13 North Slope 

Borough

In Section 4.4.2.8, page 395, reference is made to 

new measures proposed to mitigate sociocultural 

impacts. The section also cites the measures 

discussed in Section 4.4.5.8 designed to mitigate 

subsistence impacts as also having the potential 

to address sociocultural impacts. No Section 

4.4.5.8 exists. The citation presumably should be 

to Section 4.4.5.6, titled Mitigation, beginning on 

page 446. In any event, BLM cannot implement 

and enforce many of the mitigation measures 

described in these sections. 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Text has been revised to correct section call-outs. BLM 

NEPA Guidance and CEQ regulations for EIS analyses 

require that all relevant, reasonable mitigation 

measures that could improve the project are to be 

identified, even if they are outside the jurisdiction of the 

agency [40 CFR 1502.14(f), 40 CFR 1502.16(h)]. 
Supplemental Environmental Impact Statement

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Comment Response

L86-14 North Slope 

Borough

In Section 4.4.2.8, page 395, reference is made to 

new measures proposed to mitigate sociocultural 

impacts. The section also cites the measures 

discussed in Section 4.4.5.8 designed to mitigate 

subsistence impacts as also having the potential 

to address sociocultural impacts. No Section 

4.4.5.8 exists. The citation presumably should be 

to Section 4.4.5.6, titled Mitigation, beginning on 

page 446. In any event, BLM cannot implement 

and enforce many of the mitigation measures 

described in these sections. 

4.2 Mitigation Text has been revised to correct section call-outs. BLM 

NEPA Guidance and CEQ regulations for EIS analyses 

require that all relevant, reasonable mitigation 

measures that could improve the project are to be 

identified, even if they are outside the jurisdiction of the 

agency [40 CFR 1502.14(f), 40 CFR 1502.16(h)]. 

L86-15 North Slope 

Borough

We would suggest adding an additional new 

mitigation measure under the listed measures 

"Provide Administrative and Technical Support" 

and "Provide Educational Support." Industry could 

be asked to fund a local science center 

associated with one of the other buildings 

suggested. The Borough has had great success 

over many years, with minimal available local 

resources and without dedicated facilities, 

conducting science within our 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. 

4.2 Mitigation The NSB recommendation has been added to the 

Potential Mitigation Measures discussed in Section 

4.4.2 Sociocultural Systems.

L86-17 North Slope 

Borough

Page iii, what are the major issues and focus of 

controversy? Para. 2: This section should include 

a description of the conclusions in the ANILCA 

810 analysis and cite Appendix L, including 

findings of major redistribution of resources and 

extensive interference of access. 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Reference to the ANILCA 810 evaluation has been 

added to the Executive Summary.

L86-18 North Slope 

Borough

Page 6, Secretarial Order 3352: Last sentence, 

define "DNA" in the list of acronyms.

1.1 Executive 

Summary & 

Introduction

Reference to DNA has been removed from the 

document; therefore, no addition was made to the list of 

acronym.
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Comments Comment 

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Comment Response

L86-19 North Slope 

Borough

Page 6, Secretarial Order 3355: Second 

sentence, define "RMP" in the list of acronyms. 

Third sentence define "NOI" in the list of 

acronyms. 

1.1 Executive 

Summary & 

Introduction

NOI and RMP have been added to the list of acronyms.

L86-2 North Slope 

Borough

Caribou may have difficultly crossing the elevated 

road to GMT2, especially in the winter when snow 

builds up alongside the road. Hunters have also 

complained of the difficulty of crossing these 

elevated industry roads. Industry maintains that 

these roads need to be high and steep to support 

industrial traffic. We ask that the BLM require 

developers to continue to work with local 

residents to modify standard road designs or 

identify other means to mitigate road-related 

impacts to tundra travel.

3.11 Caribou The concerns voiced by this comment are 

accommodated under "Subsistence consultation for 

permitted activities" on pg. 540 of the DSEIS. No text 

change made. 

L86-20 North Slope 

Borough

Page 7, Secretarial Order 3360: Second para, 

define "IM" in the list of acronyms. 

1.1 Executive 

Summary & 

Introduction

IM has been added to the list of acronyms.

L86-21 North Slope 

Borough

Page 15, Section 1.4.5, Para 2: " ... no 

appreciable changes in the physical, biological, or 

social resources ... since BLM (2004). This 

conclusion is inaccurate. The Teshekpuk Caribou 

Herd has declined by 13% between 2008 and 

2017 and the Central Arctic Caribou Herd 

declined by 37% between 2007 and 2017. We 

consider a 37% decline in a population an 

appreciable change. 

3.11 Caribou Thank you for your comment. To clarify the statement 

in Section 1.4.5 should state " other than natural cycles 

and perturbations, there are no appreciable changes in 

the physical, biological or social resources associated 

with the project study area since BLM (2004).
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L86-22 North Slope 

Borough

Page 74, Section 3.2.1.6 Paleontological 

Resources: "[t]he indirect impact analysis area is 

the project study area and lands beyond existing 

project facilities and proposed GMT2 Project." 

Clarification is necessary. Does this sentence 

imply that only "indirect impact" is analyzed 

beyond the "project facilities and proposed GMT2 

Project?" Within the "proposed study area" of> 

158,000 acres, will direct and indirect impacts be 

analyzed? 

3.14 Cultural and 

Paleontological 

Resources

Text has been revised to clarify that the project study 

area is the boundary for indirect effects, and the 

ground-disturbing footprint is used for direct effects. 
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L86-23 North Slope 

Borough

Page 116, Section 3.3.1.2 Invasive Plant Species 

Non-native. It states that the " .. higher-latitude 

regions which include the project area are 

considered to be invasion resistant [although the] 

common dandelion (Taraxacum ofjicinale) has 

been found north of the Brooks Range and there 

has been anecdotal observation of dandelion in 

the NPR-A (BLM 2012)." Two points: 1). This is 

not anecdotal evidence. This species as well as 

other species of dandelion grow as far north as 

Barrow, Alaska (Johnson 1995 and Borough staff 

observation). Most likely, the species is 

Taraxacum ceratophorum. Sometimes the plant is 

treated as a subspecies of T ofjicinale (subsp. 

ceratophorum ). The document must include this 

direct evidence of invasive plants existing farther 

north than the project area, and the project area 

should not be considered "invasion resistant." 2). 

Even within the GMT2 document itself, it states on 

p. 325, 4.3.1.6, Potential Impacts Due to Climate 

Change: "[a]s 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)." 

Johnson, Michele, M. Barrow Wildflower 

Sketchbook: Flowering Plants of Barrow, Alaska. 

North Slope Borough. 1995 ed. 18 pp. 

3.8 Vegetation 

and Wetlands

Deleted "anecdotal" and included reference (Johnson 

1995)
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L86-24 North Slope 

Borough

Page 116. While it is true that no "reports of 

waterweed (Elodea spp.) infestations in the Arctic 

or the NPR-A have been identified (Alaska 

Natural Heritage Program 2015)," in recent 

conferences and papers, experts conclude that " 

... the remoteness of Arctic and Subarctic systems 

such as Alaska is no longer a protective attribute 

against invasions, as transportation pathways 

now reach throughout these regions" (Carey et al. 

2016). See also Fig. 2 Panel C in this paper that 

indicates potential North Slope Borough risk 

areas: "[floatplane charter routes for companies 

with valid business licenses registered with the 

State of Alaska. These routes represent regularly 

traveled, high-traffic floatplane routes and are 

indicative of potential high-risk Elodea spp. 

transport routes should the invader arrive at a 

given route starting or ending location." Carey, 

Michael, Suresh A. Sethi, Sabrina J. Larsen , 

Cecil F. Rich. A primer on potential impacts, 

management priorities, and future directions for 

Elodea spp. in high latitude systems: learning 

from the Alaskan experience. Hydrobiologia 

(2016) 777:1-19 DOI 10.1007/s10750-016-2767-

x. 

3.8 Vegetation 

and Wetlands

This comment is supportive of what has been already 

written in this section of the document. Nothing to add.
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L86-25 North Slope 

Borough

Page 124, Para 2: This paragraph fails to 

describe the methods used to determine habitat 

selection and preference by focal birds and 

animals. The estimated density of focal birds per 

square kilometer in Tables 3.3-5 through Table 

3.3-12 and accompanying maps 3.3-7 through 

3.3-9 appear to be arbitrarily assigned to quintiles. 

It seems a better approach would be to delineate 

the quintiles by dividing the highest density of 

focal birds by five to assign each of the density 

categories- low density, medium low, medium, 

medium high, high. Better still would be to reduce 

the number of density categories to 3. In the case 

of Yellow-billed loons the difference between 

medium (0.12) and low density (0.02) loons per 

square kilometer does not seem biologically 

significant. 

3.10 Birds BLM used the 5 quintiles as they are what is used in 

the Fish and Wildlife Service reporting of their bird 

density contour data. If BLM changed the quintiles it 

would be very difficult to compare this EIS with past or 

future publications by the Fish and Wildlife Service. 

BLM used the Jenks optimization method, also called 

the Jenks natural breaks classification method, which is 

a data clustering method designed to determine the 

best arrangement of values into different classes. This 

is done by seeking to minimize each class’s average 

deviation from the class mean, while maximizing each 

class’s deviation from the means of the other groups. In 

other words, the method seeks to reduce the variance 

within classes and maximize the variance between 

classes. This method is applicable to these bird density 

datasets that have uneven (and not statistically 

standard) distributions because it does not create 

classes in even intervals, instead favoring class 

divisions that are visually interpretable. 

L86-26 North Slope 

Borough

Page 144, Population Dynamics, Paragraph 1: 

More recent results from a photocensus 

conducted in 2017 are available. The TCH and 

CAH population estimates were 56,250 and 

28,000, respectively. 

3.11 Caribou Thank you for your comment. The BLM has updated 

the section 3.3.4, Population Dynamics section to 

showing results of the 2017 photocensus for TCH and 

CAH . The BLM updated figure 3.3-3 and requested 

permission from ADGF to add a figure showing TCH 

abundance estimates.

L86-27 North Slope 

Borough

Page 145, Population Dynamics, Paragraph 2: 

Person et al. (2007) provides estimates of the rate 

of emigration from the TCH to be 0.07 ± 0.03. 

3.11 Caribou Thank your for your comment. The Person et al. 

(2007) reference providing estimates of the rate of 

emigration from the TCH will be added to the 

document. 
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L86-28 North Slope 

Borough

Page 146, Fox, Paragraph 1: Pamperin (2008) 

found that Arctic fox fitted with a satellite collar in 

Prudhoe Bay in late summer had a winter home 

range based on a 50% kernel distribution, of 23 

km-2• In comparison, Arctic fox collared in 

undeveloped regions of the NPR-A had a winter 

home range, 50% kernel distribution, of 10,050 

k.m-2• Lehner (2012) repeated this work and 

found similar differences in winter home ranges 

and attributed the difference to the availability of 

anthropogenic foods. He found that fox that 

remained in Prudhoe Bay had consumed 

anthropogenic foods whereas fox collared in 

NPR-A had not eaten anthropogenic foods based 

on isotopic signatures of tissues collected from 

collared fox in late winter. It is likely that GMT2 

will result in similar effects to Arctic fox behavior 

and diet. 

3.12 Mammals There is potential that the same results could occur 

around GMT-2 and nearby developments. A short 

summary of this paper has been added. 

L86-29 North Slope 

Borough

Page 150, Section 3.3.5.2 Spectacled Eider, 

Paragraphs 4 and 5: As previously described, the 

density index contours seem to be arbitrarily 

assigned. By definition, a quintile is 5 equal 

groups. Table 3.3-16 and associated maps 3.3-12 

are biologically irrelevant as it pertains to the 

study area because the difference between low 

(0.03) and medium low (0.1) density km-2 is both 

minimal and arbitrary. 

3.13 Threatened 

and Endangered 

Species

BLM used the 5 quintiles as they are what is used in 

the Fish and Wildlife Service reporting of their bird 

density contour data. If BLM changed the quintiles it 

would be very difficult to compare this EIS with past or 

future publications by the Fish and Wildlife Service. 

BLM used the Jenks optimization method, also called 

the Jenks natural breaks classification method, which is 

a data clustering method designed to determine the 

best arrangement of values into different classes. This 

is done by seeking to minimize each class’s average 

deviation from the class mean, while maximizing each 

class’s deviation from the means of the other groups. In 

other words, the method seeks to reduce the variance 

within classes and maximize the variance between 

classes. This method is applicable to these bird density 

datasets that have uneven (and not statistically 

standard) distributions because it does not create 

classes in even intervals, instead favoring class 

divisions that are visually interpretable. 
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L86-3 North Slope 

Borough

We need to continue to monitor and analyze the 

impacts of the GMTl project and road, and other 

development projects on caribou to make more 

informed decisions concerning the construction of 

roads in the area. Nuiqsut's residents feel that 

development is moving too quickly. The GMTl 

development has only just begun, and its impacts 

are not yet known. For this reason, we request 

BLM to require CPAI to continue monitoring the 

subsistence harvest of caribou. CPAI should 

continue funding the Nuiqsut Caribou Subsistence 

Household Harvest Surveys conducted by 

Stephen R. Braund and Associates, or another 

similar harvest survey. Furthermore, the Record 

of Decision should require this survey to continue 

every year to avoid gaps in the analysis. Analysis 

of this data will be essential in understanding the 

localized impacts of road development on 

subsistence. This data will be useful when 

evaluating whether or not to support the 

construction of a road to future developments, 

including any associated with the Willow 

Prospect.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

BLM has included potential mitigation measures to 

address continued monitoring of the caribou harvest 

and subsistence users' impacts, disturbance, and 

access. See Section 4.4.5 Subsistence, Potential 

Mitigation Measures 6 and 8. 

L86-30 North Slope 

Borough

Page 160 mentions "Point Utqiagvik (formerly 

Barrow) ... " While the city has been renamed, the 

point remains Point Barrow. 

3.0 Affected 

Environment

Thank you, text has been updated.

L86-31 North Slope 

Borough

Page 168, Section 3.4.1, Para 2: A more recent 

census was conducted by the North Slope 

Borough in 2014 and published in 2015. 

3.0 Affected 

Environment

Thank you, text has been updated.
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L86-32 North Slope 

Borough

Page 179, Section 3.4.5.3 Visual Resources: This 

section is ambiguous and inadequate in 

assessing the aesthetics of the "Proposed Study 

Area," especially considering that it emphasizes 

the more immediate area near GMT2 and GMTl 

and not the entire study area. Since all action 

alternatives will create new industrial 

development, these and previous developments 

are measureable cumulative effects resulting in 

cultural modifications in the study area. Some oil 

and gas infrastructure (including the facilities at 

Alpine), pipelines, and ice roads are visible from 

Nuiqsut and other portions of the proposed study 

area. To assess these specific proposed changes 

as well as the cumulative aesthetic effects on the 

study area, one should assess the horizon's 

unobstructed view (zero volume) to compare to 

obstructed view (X volume). One can then gauge 

the incremental impacts of past, present and 

provide estimates of reasonably foreseeable 

future actions that will obstruct the visual and 

aesthetic resources. Providing quantitative values 

should not be a burden. One tool that BLM could 

use is the US Army Corps OMBIL Regulatory 

Module (ORM), which is a central database 

deployed locally to each District. The BLM, like 

the ACOE certainly "values the importance of 

cumulative impacts analysis because it forces 

analysis outside of agency missions" ( quote from 

Army Corps of Engineers, Michael Salyer, Chief, 

North Branch Regulatory Division, DOI Arctic 

Cumulative Impacts Workshop FINAL REPORT 

Campbell Creek Science Center - Anchorage, 

Alaska April 12 -13, 2016). Please present the 

relevant documents for this project from OMBIL. 

3.17 Land Use The BLM follows a specific process to document visual 

resource inventory (VRI) and decisions for visual 

resource management (VRM). During the development 

of a land-use plan, the BLM conducts a visual 

resources inventory to identify the scenic qualities and 

sensitivity to change within the landscape. The landuse plan determines what the visual resource 

management objectives of the area will be. This 

means that while BLM recognizes that there may be 

high scenic values present, there could be a plan 

decision made that says that the area will be managed 

for other resource values. 
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L86-33 North Slope 

Borough

Page 180, Paragraph 2: "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." The delineation 

of a 2.5 mile buffer for direct impacts is 

unreasonable. The range of activities for the 

duration of all phases of GMT2 encompass will 

occur in a much larger area. See Figure 3.4.7 and 

Figures 1 and 2 in Appendix L. 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

NEPA requires the BLM to evaluate the impacts of the 

entirety of a project, including areas of associated 

activities and connected actions. The project area is 

defined to include such connected areas as the ASRC 

gravel pit from which gravel will be derived and Alpine 

which is the origination point of most traffic to and from 

GMT2, to name just two examples. See Section 4.4.5.1 

Methodology - GMT2 Areas of Potential Effects for 

Subsistence for a complete explanation of the project 

area including the 2.5 mile buffer. 

L86-34 North Slope 

Borough

Page 416, Evaluating Impacts to Subsistence: It 

should be explained why this section does not use 

similar impact criteria categories (intensity, 

duration, context, and geographic extent) and 

magnitudes as were used in Section 4.3 

Biological Environment and in the previous GMTl 

SEIS. 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

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 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. 
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L86-35 North Slope 

Borough

Page 423, Section 4.4.5.3 Impacts Common to All 

Action Alternatives, Spills: the paragraph does not 

address the potential impacts to subsistence 

associated with spill response activities, including 

any efforts to halt a spill in progress, mobilization 

and transport of response equipment and 

personnel, any hazing of wildlife, any capture and 

treatment of oiled wildlife, and any post-response 

construction or other activities necessary to

restore facilities to their full function. 

3.19 Hazardous 

Materials Spills

The Conoco Phillips Oil Discharge Prevention and 

Contingency Plan for the Alpine Field and Satellites 

and Alpine Pipeline system provides a description of 

spill response activities including mobilization and 

transportation of response equipment and personnel. In 

addition, any cleanup would follow procedures outlined 

in the ADEC Tundra Treatment Manual. These 

documents are described and referenced in Section 

2.4.10 (Features Common to All Alternatives - Spill 

Prevention and Response) and/or Section 4.5 Impacts 

of Oil, Saltwater, and Hazardous Materials Spills. 

No changes made to the text.

L86-36 North Slope 

Borough

Page 426, Air Traffic: here and wherever else air 

traffic is discussed in the document, use of the 

term "flight" should be clarified as to whether it is 

used to mean a round-trip or one-way transit, as 

each out and back transit, with some time spent at 

the project site, should be seen as a separate 

potentially impact-producing event. 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

All flights refer to a single take-off and landing, i.e., a 

helicopter that takes off from Alpine, lands along the 

GMT2 ice road route for stick picking in the summer, 

and transports the crew back to Alpine would be 

counted as two flights. Text will be updated to clarify 

this. 

L86-37 North Slope 

Borough

Page 436, at the top of the page, reference is 

made to the Borough's "annual Oil and Gas 

Forum." To clarify, the 2016 Forum was an 

extremely productive 3-day gathering, but similar 

events have only been held sporadically rather 

than annually. 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Removed the word annual from the description. 
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L86-38 North Slope 

Borough

Page 446, in discussing the creation and 

operation of the NPR-A Subsistence Advisory 

Panel as a mechanism to reduce conflicts 

between subsistence users and the oil and gas 

industry, BLM rightly notes that "[f]rustration 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 BLM has no 

authority on which to act." This is a critical 

observation, and must be properly acknowledged 

and addressed where relevant in various sections 

throughout the Final EIS. 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. 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

See section 4.4.2.1 Sociocultural Systems -Impacts 

Common to all Alternatives, Tensions Related to 

Permitting Processes for Development

L86-39 North Slope 

Borough

Page 447, the Piuraagvik Recreation Center 

addition is listed as an example of a Nuiqsut 

project funded by NPR-A impact mitigation funds 

when the Center is actually located in Utqiagvik 

(Barrow). It perhaps was intended that the 

bulleted section be introduced as "Examples of 

North Slope projects funded by NPR-A impact 

mitigation funds include:" 

4.2 Mitigation The sentence preceding the list of example grants 

indicates North Slope projects, not Nuiqsut. Text has 

been added to indicate the recreation center is located 

in Utqiagvik.
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L86-4 North Slope 

Borough

We have concerns over the air quality analysis in 

the DSEIS. It appears that air quality modeling 

scenarios did not account for concurrent 

construction activities. Construction has been 

constant in the vicinity of Nuiqsut since the 

development of Alpine, and construction activities 

are projected to continue into the foreseeable 

future. The analysis assumed that construction 

activities would be complete for Nanushuk and 

GMTl by the time GMT2 construction begins. We 

find this scenario unlikely. Furthermore, the 

background data used in modeling should include 

predicted cumulative impacts of future 

developments in the area, including Willow and 

Stoney Hill. BLM needs to remodel its air quality 

analysis to account for current and future 

construction activities and developments.

3.5 Air Quality & 

Meteorology

Thank you for the comment. Based on the timelines for 

the GMT1 and Nanushuk Projects, the construction 

phases are expected to be complete by the time the 

GMT2 Project begins construction. Therefore, the 

emissions from the operational phases were used for 

these cumulative sources in the models. It is important 

to note that the emissions from the operational phase 

of the Nanushuk Project, as presented in their EIS, are 

a magnitude larger than during the construction phase, 

therefore the emissions for that Project are 

conservatively included. Projects such as Willow and 

Stoney Hill do not meet the definition of foreseeable 

development as there is no clearly defined, proposed, 

or accepted scope of the projects.

For the far-field analysis, the air quality analysis 

assessed the impact of the worst-case (i.e., highest) 

emission years for each pollutant. The years 

considered included construction activities in addition to 

other activities during that year. Tables 4.2-20, 4.2-21, 

4.2-29, and 4.2-30 show that GMT2 project-only 

impacts are much lower than the National Ambient Air 

Quality Standards (NAAQS) for all pollutants and 

averaging periods at the sensitive Class II areas 

analyzed that are over 200 kilometers from the project 

area. Similarly, the GMT1 EIS showed that GMT1 

worst-case project-impacts were very small at these 

Class II areas. Emissions rates for the Nanushuk RFD 

sources are based on the modeled emissions rates 

presented in the 2017 Nanushuk draft SEIS AQIA. As 

discussed in Section 5.2 of the AQIA, the “modeled EU 

[emission unit] locations, physical parameters, and 

emission rates, respectively, of each modeled EU are 

based upon worst-case emission scenarios for the 

Construction and Drilling and Drilling and Operations 

scenarios, respectively.” Therefore, the cumulative 

GMT2 air quality analysis considers the worst-case 

impact for Nanushuk and GMT1 at these two Class II 

areas, and shows that impacts are lower than air 

quality standards.
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L86-40 North Slope 

Borough

Page 475, the brief discussion of potential 

overlapping impacts of the Liberty Development 

Project with GMT2 identifies as the only social 

impacts the "participation in multiple simultaneous 

NEPA processes." Reasonably foreseeable 

sociocultural impacts to the community of Nuiqsut 

certainly would extend beyond that only, and 

would also 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. 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

The text referred to is in Section 4.6.2.2 (Cumulative 

Impacts - Methodology - Past, Present, and 

Reasonably Foreseeable Future Actions), where the 

actions that are considered as cumulative are 

introduced. The analyses of sociocultural impacts 

(direct, indirect, and cumulative) includes details on the 

tensions related to multiple permitting processes and 

pace of development. The text in the cumulative 

analysis for subsistence (Section 4.6.8.9) has been 

edited to include this input from the NSB. 

L86-41 North Slope 

Borough

Page 476, Section 4.6.3 Cumulative Impacts to 

the Terrestrial Environment: "The GMT2 site, in 

combination with existing gravel footprints and 

footprints of developments in permitting total 

approximately 23,000 acres, which represents 0.5 

percent of the geographic extent of this analysis." 

The meaning of the sentence is unclear. Does it 

mean that the GMT2 site in combination with all 

other existing development would represent only 

0.5 percent in area of some considerably larger 

area? If so, what specific larger area, and what 

point is the statement attempting to make? 

3.1 Geology and 

Physiography

Text has been updated to remove this description. 

Updated text reads: 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.
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L86-42 North Slope 

Borough

Page 478, Section 4.6.4.2 Future Impacts and 

Their Accumulation: "The 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, p. 94)." The EIS 

should specify which lakes this comment is 

referring to and create a table to indicate 

cumulative yearly water removal in these lakes, 

even if removal is by more than one company. A 

yearly monitoring plan for ensuring re-charge and 

water quality should be initiated for these lakes. A 

time-to-recharge date should be maintained since 

climate change and fugitive dust can increase or 

decrease re-charge time. These comments are 

driven by the conditional language in the 

preceding paragraph that appears to be 

insinuating some difficulty in re-charge. 

3.4 Water 

Resources

To date, there have been no lakes used during winter 

drilling operations which have not re-charged the next 

season. It is agreed that problem lakes that do not recharge could be placed into a table under cumulative 

impacts in a future EIS. Generating a table of lakes 

which have been pumped multiple times may not be 

useful since many lakes are not pumped to the 

maximum withdrawal limits allowed.
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L86-43 North Slope 

Borough

Pages 478-79, Section 4.6.4.2 Future Impacts 

and Their Accumulation: "Dust deposition along 

roads can increase turbidity of adjacent water 

bodies. Snowdrifts along gravel and building 

structures can increase wintertime soil surface 

temperatures and result in increased thaw depths, 

Draft Supplemental Environmental Impact 

Statement Alpine Satellite Development Plan for 

the Proposed Greater Mooses Tooth 2 

Development Project 479 contributing to 

thermokarsting (BLM 2012, Section 4.8.7.4, page 

91)." This section is incomplete. Please note more 

recent documents and studies. For instance, 

Walker DA, Raynolds MK, Buchhom M, Peirce JL 

(eds.) (2014) Landscape and permafrost changes 

in the Prudhoe Bay Oilfield, Alaska. Alaska 

Geobotany Center Publication AGC 14-01, 84 pp. 

University of Alaska Fairbanks, Fairbanks, AK. 

Read especially the following chapters within this 

publication: 

• Supplementary information regarding calculation 

of impacts of oilfield development, North Slope, 

Alaska, by Kenneth J. Ambrosius

• Supplementary information regarding the 

Integrated Geoecological and Historical Change 

Mapping (IGHCM) method 33

3.2 Soils & 

Permafrost

Text revised to read: " Dust deposition along roads can 

increase turbidity of adjacent water bodies, increase 

the rate of thermokarst (Walker et al 2014) and affect 

the vegetation, soils and permafrost at distances of 600 

to 1000 meters from the road. These affects are most 

pronounced within 200 meters of the road and increase 

logarithmically as distance to the road decreases 

(Everett 1980, Myers-Smith et al 2006). Snowdrifts...."
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L86-44 North Slope 

Borough

Pages 478-79, Section 4.6.4.2 Future Impacts 

and Their Accumulation: "Dust deposition along 

roads can increase turbidity of adjacent water 

bodies. Snowdrifts along gravel and building 

structures can increase wintertime soil surface 

temperatures and result in increased thaw depths, 

Draft Supplemental Environmental Impact 

Statement Alpine Satellite Development Plan for 

the Proposed Greater Mooses Tooth 2 

Development Project 479 contributing to 

thermokarsting (BLM 2012, Section 4.8.7.4, page 

91)." This section is incomplete. Please note more 

recent documents and studies. For instance, 

Walker DA, Raynolds MK, Buchhom M, Peirce JL 

(eds.) (2014) Landscape and permafrost changes 

in the Prudhoe Bay Oilfield, Alaska. Alaska 

Geobotany Center Publication AGC 14-01, 84 pp. 

University of Alaska Fairbanks, Fairbanks, AK. 

Read especially the following chapters within this 

publication: 

• Supplementary information regarding calculation 

of impacts of oilfield development, North Slope, 

Alaska, by Kenneth J. Ambrosius

• Supplementary information regarding the 

Integrated Geoecological and Historical Change 

Mapping (IGHCM) method 33

3.7 Climate 

Change

Text updated. This reference was added under the 

climate change paragraph in the conclusions. 
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L86-45 North Slope 

Borough

Pages 478-79, Section 4.6.4.2 Future Impacts 

and Their Accumulation: "Dust deposition along 

roads can increase turbidity of adjacent water 

bodies. Snowdrifts along gravel and building 

structures can increase wintertime soil surface 

temperatures and result in increased thaw depths, 

Draft Supplemental Environmental Impact 

Statement Alpine Satellite Development Plan for 

the Proposed Greater Mooses Tooth 2 

Development Project 479 contributing to 

thermokarsting (BLM 2012, Section 4.8.7.4, page 

91)." This section is incomplete. Please note more 

recent documents and studies. For instance, 

Walker DA, Raynolds MK, Buchhom M, Peirce JL 

(eds.) (2014) Landscape and permafrost changes 

in the Prudhoe Bay Oilfield, Alaska. Alaska 

Geobotany Center Publication AGC 14-01, 84 pp. 

University of Alaska Fairbanks, Fairbanks, AK. 

Read especially the following chapters within this 

publication: 

• Supplementary information regarding calculation 

of impacts of oilfield development, North Slope, 

Alaska, by Kenneth J. Ambrosius

• Supplementary information regarding the 

Integrated Geoecological and Historical Change 

Mapping (IGHCM) method 33

3.4 Water 

Resources

This reference was added under the climate change 

paragraph in the conclusions.
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L86-46 North Slope 

Borough

With respect to the BLM statement on 

thermokarst above, note that not only manmade 

but also climate change and atmospheric 

temperature could increase thermokarst 

development. This point should incorporate new 

findings from the following: 

Walker, DA, Buchhom M, Kanevskiy M et al. 

(2015) lrifrastructure-Thermokarst-SoilVegetation 

Interactions at Lake Colleen Site A, Prudhoe Bay, 

Alaska. Alaska Geobotany Center Data Report 

AGC 15-01, 92 pp. Institute of Arctic Biology, 

University of Alaska Fairbanks, Fairbanks, AK. 

3.2 Soils & 

Permafrost

More information on how cumulative development 

impacts will interact synergistically with climate change 

can be found in Section 4.6.3, Terrestrial Environment. 

Text has been updated with the proposed reference. 
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L86-47 North Slope 

Borough

Finally, regarding dust and fugitive dust, the 

DSEIS does not adequately address dust under 

its Contribution of the Alternatives to Cumulative 

Impacts (pp. 479-481). The DSEIS notes in only 

the most general (and therefore vague) terms that 

increasing climate change and fugitive dust could 

lead to drying out of shallow lakes, watersheds ... 

(p. 481). However, the DSEIS should directly 

reference, discuss, and incorporate the work of 

Walker, DA, Buchhom M, Kanevskiy M et al. 

(2015) lnfrastructure-Thermokarst-SoilVegetation 

Interactions at Lake Colleen Site A, Prudhoe Bay, 

Alaska. Alaska Geobotany Center Data Report 

AGC 15-01, 92 pp. Institute of Arctic Biology, 

University of Alaska Fairbanks, Fairbanks, AK. In 

their chapter entitled "Effects of development on 

permafrost and tundra along the Spine Road at 

Prudhoe Bay, Alaska," it was noted that 50m off 

road, "[ c ]lear surface mineral horizons up to 18 

cm thick occur near the south west side of the 

road and up to 10 cm thick on the northeast side. 

The mineral surface horizons decrease in 

thickness away from the road, but even at 200 m 

from the road the underlying organic material 

have a gray color indicating leached dust." Road 

dust that accumulates on top of the moss layer 

causes centimeters of mineral horizons to develop 

and changes the plant environment leading to 

reduction in mosses, lichens, and small forbs. In 

terms of mitigation and restoration, monitoring 

and reporting, these effects (not observed until 20 

or more years later) might have to be considered 

40 years (or more) later. This is also an example 

of cumulative and indirect effects that should be 

accounted for within the "Proposed Study Area." 

3.5 Air Quality & 

Meteorology

Text in Section 4.6.3 Cumulative Impacts to the Water 

Resources has been revised to read: "Dust deposition 

along roads can increase turbidity of adjacent water 

bodies, increase the rate of thermokarst (Walker et al 

2014) and affect the vegetation, soils and permafrost 

at distances of 600 to 1000 meters from the road. 

These affects are most pronounced within 200 meters 

of the road and increase logarithmically as distance to 

the road decreases (Everett 1980, Myers-Smith et al 

2006). Snowdrifts...."
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L86-48 North Slope 

Borough

Map 4.6-1 is intended to be a "Cumulative Effects 

Analysis Map. " However, it does not show 

potential and past overlap of study areas. For 

reasonably foreseeable projects, please add a 

mean size boundary for gas and oil development 

projects on the North Slope. This would allow one 

to get a sense of past, present, and future overlap 

of areas. See Alaska Daily News 16 April 201 8 

for a map that list North Slope Oil and Gas 

Activity. While this map delineates general 

activity, it does not locate the community of 

Nuiqsut. 

3.0 Affected 

Environment

We acknowledge that it seems like adding boundaries 

for past and potential projects to highlight overlap 

would be relatively straightforward. Unfortunately, 

projects are permitted by different administrative 

entities, permit documents are often done by 

contractors, and some project areas are considered 

proprietary and confidential. We do not have the 

information to add a mean size boundary for oil and 

gas developments and could not gather all the different 

study areas to add to the cumulative effects map.

L86-49 North Slope 

Borough

In terms of monitoring cumulative effects, see 

Martha K. Raynolds, et al., Cumulative 

geoecological effects of 62 years of infrastructure 

and climate change in ice-rich permafrost 

landscapes, Prudhoe Bay Oilfield, Alaska, in 

Global Change Biology, 2014, Volume 20, Issue 

4, pp. 1211-122 4. While some changes may take 

place decades after development, these very long 

term changes are now understood as reasonably 

foreseeable. See Sect. 3: Supplementary 

information regarding calculation of impacts of 

oilfield development, North Slope, Alaska, by 

Kenneth J. Ambrosiusin 

http://www.geobotany.uaf.edu/library/pubs/Walker

DA2014_agc14-01.pdf. 

3.7 Climate 

Change

Additional text has been added to the discussion of 

Climate Change in Chapter 3 that summarizes the 

article indicated in the comment. The cumulative 

effects described in the article were considered in 

applicable sections in Chapter 4 (e.g., vegetation, 

hydrology, and socio-cultural).

L86-5 North Slope 

Borough

We urge BLM to require the permittee to allow the 

community of Nuiqsut access to the GMT2 road. 

CP AI should allow hunting from the GMT2 road 

and produce concise policies regarding the use of 

its roads concerning hunting.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

BLM has included a potential mitigation measure 

requiring a road access agreement by ConocoPhillips 

for the community of Nuiqsut that specifies the rules for 

utilizing the road and guarantees continued access.
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L86-50 North Slope 

Borough

Page 490, Section 4.6. 7 .2, 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 and in some 

scenarios, could be synergistic. Because of the 

highly migratory life history of many Arctic fish 

species, if enough local impacts on fish occurred 

in the various oil and gas areas near GMT2, these 

impacts could accumulate and result in a decline 

in productivity for fish populations at a regional 

scale." The "conclusion " is not a conclusion, but a 

conditional statement in the form of "would be ... if 

... could ... " The conditional "conclusion" is that 

"impacts could accumulate and result in a decline 

in productivity for fish populations at a regional 

scale." Does this imply potential population-level 

effects? It is not analyzed thoroughly enough to 

conclude high, medium, or low impact. The above 

statement also begs for an answer concerning " ... 

if enough local impacts on fish occurred ... ". How 

many is "enough?" 

3.9 Fish The text was changed to be more direct and definitive.
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L86-51 North Slope 

Borough

Page 490, Section 4.6.7.2 Paragraph 2: The 

number of gravel and ice roads in the region may 

cause a decline in fish productivity and its 

populations at a regional scale. It is strongly 

recommended that studies on fish habitat, 

movement and population biology be conducted 

before, during and after the duration of the GMT2 

project. Especially for the main subsistence 

species: Arctic Cisco, Burbot and Broad 

Whitefish. 

3.9 Fish Movement studies in the project area have been 

conducted for Arctic grayling, burbot, and broad 

whitefish (Morris 2003; Heim et al. 2014, 2015). While 

specific patterns of these species may differ, one 

commonality is that many individuals make seasonal 

movements between lakes, small streams, and rivers. 

As such, BMPs aim to maintain natural hydrologic 

regimes and thus water body connectivity so that these 

patterns are not disrupted. Long-term monitoring of the 

fall Colville fishery and focused work on Arctic cisco 

has lead to an understanding of juvenile fish transport 

from the Mackenzie River (where they all originate), 

several years of habitat use primarily along the coast 

and in the Colville delta, and a return spawning run to 

the Mackenzie - patterns that would not be impacted by 

the GMT2 project.

L86-54 North Slope 

Borough

Page 516, Contribution of the Alternatives to 

Cumulative Impacts, last paragraph, first 

sentence: " ... residents of Nuiqsut will have 

facilitated to subsistence areas .... " Though the 

sentence is obviously missing something, its 

meaning is clear. It should also be noted that, 

alternatively, some hunters will voluntarily avoid 

the road because it is a nontraditional route. 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Text has been revised to correct sentence.
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L86-56 North Slope 

Borough

Page 51 7, despite the frank discussion of 

potential impacts that precedes it, the last 

sentence on this page somewhat vaguely 

concludes that, "[ a]ppropriate 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 nonoil and 

gas activities." 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 performancebased 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. 

4.2 Mitigation The BLM manages the NPR-A pursuant to the 

requirements of the NPRPA of 1976 and the DOI 

Appropriations Act FY 1981 implemented at 43 CFR 

2360, and 43 CFR 3130. The NPRPA and these 

regulations require the BLM to conduct an oil and gas 

leasing program within the NPR-A, specify that the 

intent of the leasing program is oil and gas 

development leading to production, and gives the 

Secretary authority to protect surface resources to the 

extent consistent with the oil and gas requirements of 

the NPRPA. Other applicable laws, such as Section 

810 of ANILCA and NEPA, assist the BLM in carrying 

out these responsibilities. The BLM is limited in our 

ability to carry out requests or actions that are contrary 

to the requirements of existing federal law. Once 

issued, oil and gas leases provide a right of 

development, subject to reasonable regulation. We 

encourage local and regional stakeholders to utilize the 

avenues afforded them through State and Municipal 

law, and through the federal political process to identify 

and implement solutions.

L86-6 North Slope 

Borough

BLM and CPAI should also consider: suspending 

helicopter flights around select rivers for month 

long periods during peak caribou hunting season; 

and implementing mitigation measures for road 

dust including speed limits, a dust control plan, 

increased remote monitoring of facilities to reduce 

traffic and the watering of roads; and constructing 

a warm storage building to house vehicles, 

minimizing the need to idle vehicles for long 

periods of time.

4.2 Mitigation See Section 4.4.5 Subsistence, Potential Mitigation 

Measure 2: Suspend Non-essential Helicopter Traffic 

during Peak Caribou Hunting Season; Section 4.3.4 

Mammals, Potential Mitigation Measure 2: Minimize 

Potential Ground Vehicle Traffic Disturbance of 

Caribou; and Section 4.4.6 Public Health, Potential 

Mitigation Measure 2: Minimize Undue Idling of all 

Vehicles.
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L86-60 North Slope 

Borough

Again, these are among the most significant 

findings of the DSEIS. Given their scope and 

severity, they demand more than vague general 

assurances that "appropriate mitigation and 

performance-based lease stipulations and best 

management practices" will reduce significant 

long-term adverse cumulative impacts. 

4.2 Mitigation The BLM manages the NPR-A pursuant to the 

requirements of the NPRPA of 1976 and the DOI 

Appropriations Act FY 1981 implemented at 43 CFR 

2360, and 43 CFR 3130. The NPRPA and these 

regulations require the BLM to conduct an oil and gas 

leasing program within the NPR-A, specify that the 

intent of the leasing program is oil and gas 

development leading to production, and gives the 

Secretary authority to protect surface resources to the 

extent consistent with the oil and gas requirements of 

the NPRPA. Other applicable laws, such as Section 

810 of ANILCA and NEPA, assist the BLM in carrying 

out these responsibilities. The BLM is limited in our 

ability to carry out requests or actions that are contrary 

to the requirements of existing federal law. Once 

issued, oil and gas leases provide a right of 

development, subject to reasonable regulation. We 

encourage local and regional stakeholders to utilize the 

avenues afforded them through State and Municipal 

law, and through the federal political process to identify 

and implement solutions.
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L86-61 North Slope 

Borough

On Map 3.3-4, Oil Creek is not indicated. In the 

past, it has been a creek from Oil Lake to Crea 

Creek. If it no longer exists, then its absence may 

be an example of drying as noted on pages 480-

481, Section 4.6.4.3 Conclusion: "BLM (2012, 

Section 4.8.7) concluded that climate change may 

increase particulate matter (fugitive dust, 

byproducts of combustion, and evaporation of 

hydrocarbons) to the extent shallow lakes and 

ponds dry up Draft Supplemental Environmental 

Impact Statement Alpine Satellite Development 

Plan for the Proposed Greater Mooses Tooth 2 

Development Project 481 or become 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." 

3.7 Climate 

Change

Oil Creek flows from Oil Lake to the Ublutuoch, not 

Crea Creek. See map 3.3-4 from the GMT1 SEIS (it is 

the drainage just to the west of CD5).

Also, it is not drying, but is healthy and flowing, having 

been gauged since 2009, with data through 2016 

posted to: http://www.fishcreekwatershed.org/data.html

L86-62 North Slope 

Borough

Appendix B, Aircraft Flights for Alternative A 

through D: These tables provide information on 

the number of flights associated with CD/ APF 

and GMT2 but do not provide information on the 

origin of those flights. Are any flights expected to 

utilize the runway at Nuiqsut? 

2.1 Proposed 

Action & 

Alternatives

No flights are expected to use the runway in Nuiqsut. 

Appendix B has been updated with footnotes explaining 

the origin and destination of the flights listed. 

L86-63 North Slope 

Borough

Appendix D: Appendix D does little to clarify the 

methods used to determine density index 

contours. The section titled "Cross reference for 

habitat and vegetation types" needs some text to 

describe the table and how habitat and vegetation 

types are related. 

3.8 Vegetation 

and Wetlands

Section deleted.

L86-64 North Slope 

Borough

Appendix L, ANILCA Sect. 810 Subsistence 

Analysis, Findings with respect to Alternative A 

Page 10, Paragraph 4: Hunters should receive 

fuel vouchers to compensate for the longer travel 

distances to access subsistence resources during 

construction phase. 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

BLM has included the use of fuel vouchers as a 

potential mitigation measure under Section 4.4.2 

Sociocultural System; however, the BLM lacks the 

regulatory authority to require the applicant to provide 

funding to local residents in this manner. 
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L86-65 North Slope 

Borough

Page 13 Paragraph 2 states: "given the 

importance of caribou availability, uncertainties 

regarding the extent and duration of altered 

caribou availability preclude a finding that the 

effects of Alternative A will not cause a major 

redistribution of caribou and thus will not 

significantly restrict subsistence uses for Nuiqsut 

hunters." Given this dire conclusion, it is strongly 

recommended that studies on caribou distribution, 

migrations and habitat be conducted before, 

during and after the duration of the GMT2 project. 

Between the cumulative effects on fish and 

caribou, the residents of Nuiqsut can have their 

subsistence resource availability significantly 

reduced or eliminated for several years, especially 

in the case of an oil spill (Page 18 Appendix L 

Para 4). Oil spill simulation models should be 

developed and run for this area, in order to better 

assess the risks and consequences of an oil spill, 

especially if it reaches the Colville River Delta. 

3.11 Caribou BLM has included potential mitigation measures 

including Subsistence Harvest Monitoring Studies, and 

Subsistence User Monitoring and Adaptive 

Management.
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L86-65 North Slope 

Borough

Page 13 Paragraph 2 states: "given the 

importance of caribou availability, uncertainties 

regarding the extent and duration of altered 

caribou availability preclude a finding that the 

effects of Alternative A will not cause a major 

redistribution of caribou and thus will not 

significantly restrict subsistence uses for Nuiqsut 

hunters." Given this dire conclusion, it is strongly 

recommended that studies on caribou distribution, 

migrations and habitat be conducted before, 

during and after the duration of the GMT2 project. 

Between the cumulative effects on fish and 

caribou, the residents of Nuiqsut can have their 

subsistence resource availability significantly 

reduced or eliminated for several years, especially 

in the case of an oil spill (Page 18 Appendix L 

Para 4). Oil spill simulation models should be 

developed and run for this area, in order to better 

assess the risks and consequences of an oil spill, 

especially if it reaches the Colville River Delta. 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

BLM has included potential mitigation measures to 

address continued monitoring of the caribou harvest 

and subsistence users' impacts, disturbance, and 

access. See Section 4.4.5 Subsistence, Potential 

Mitigation Measures 6 and 8. 
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L86-66 North Slope 

Borough

Page 13 Paragraph 2 states: "given the 

importance of caribou availability, uncertainties 

regarding the extent and duration of altered 

caribou availability preclude a finding that the 

effects of Alternative A will not cause a major 

redistribution of caribou and thus will not 

significantly restrict subsistence uses for Nuiqsut 

hunters." Given this dire conclusion, it is strongly 

recommended that studies on caribou distribution, 

migrations and habitat be conducted before, 

during and after the duration of the GMT2 project. 

Between the cumulative effects on fish and 

caribou, the residents of Nuiqsut can have their 

subsistence resource availability significantly 

reduced or eliminated for several years, especially 

in the case of an oil spill (Page 18 Appendix L 

Para 4). Oil spill simulation models should be 

developed and run for this area, in order to better 

assess the risks and consequences of an oil spill, 

especially if it reaches the Colville River Delta. 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

BLM has included potential mitigation measures to 

address continued monitoring of the caribou harvest 

and subsistence users' impacts, disturbance, and 

access. See Section 4.4.5 Subsistence, Potential 

Mitigation Measures 6 and 8. 
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L86-7 North Slope 

Borough

The DSEIS contains no summary that indicates 

significant findings. After reading Vol. 1, one could 

easily conclude that subsistence resources are 

not at risk. However, the ANILCA 810 analysis in 

Appendix L finds that there is a potential 

"substantial restriction of subsistence uses." Both 

points should have been presented early in a 

summary statement, especially because a 

common practice among reviewers is to focus on 

chapters that are of most interest. BLM has noted 

and advocated this practice in public meetings to 

help readers get through large EIS (> 600 page) 

documents when only a short comment period 

has been provided. One could easily miss and 

misunderstand the overall findings of significance 

because Appendix L is not tied to typical 

biological studies that emphasize resource 

population-level effects. 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

A statement regarding the ANILC 810 evaluation and 

findings has been added to the Executive Summary at 

the front of the document.
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L86-8 North Slope 

Borough

Among the central conclusions that must be 

highlighted in the final EIS is 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. These impacts 

must be called out in some clear manner, so that 

they are easily recognized by all readers. 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. 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Language describing the primary impacts to 

subsistence is now included in both the introduction to 

the Subsistence Section (4.1.2) and in the conclusion 

(4.1.2.7). 
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L86-9 North Slope 

Borough

There is a problem in consistency in referring to 

the "proposed study area" versus smaller, multiple 

sub-sets of areas. Page 69, Section 3.1.1 Project 

Study Area, states: "[t]he study area extends 

approximately 2.5 miles in radius from proposed 

project facilities and encompasses 158,480 

acres." Clarification is necessary with this 

statement. First, while the phrase "study area 

extends approximately 2.5 miles in radius from 

proposed project facilities" is clear, that area 

would encompass - 12,560 acres, not > 158,000 

acres. Table 2.3-2 (pp. 29-30) even provides a 

summary of major project components for each 

action alternative. Part of the preceding sentence 

is the table legend 2.3-2 itself. Nowhere in this 

table is the complete "study area" of> 158,000 

acres indicated. In fact, part of the phrase "study 

area" is used seemingly indiscriminately on maps 

and in the text to designate at times the larger 

area, at times the "proposed permanent 

infrastructure" area, and at times other smaller 

areas. To remedy this, a clearer understanding of 

the study area is provided on page 4, Appendix L: 

"[t]he GMT2 construction project area 

encompasses 158,480 acres (Figure 1) and 

project (sic) 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 CDSGMTl access road, the GMTl drill site northwest of 

Nuiqsut, and the proposed GMT1-GMT2 access 

road and GMT2 drill site west of Nuiqsut" (p. 4, 

Appendix L). 

2.1 Proposed 

Action & 

Alternatives

Additional text regarding the project study area has 

been added to the beginning of Chapters 3 and 4 in 

Sections 3.1.1 and 4.1.1 that will assist the reader in 

understanding the environmental consequences of the 

alternatives.
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L87-10 Arctic Slope 

Regional 

Corporation

BLM goes further to state that subsistence users 

who utilize the GMT2 Road will “disadvantage” 

(SEIS, pg. 440 and 441) users who choose not to. 

This type of assumption creates wedges and 

friction in the Native community which provides no 

value to the analysis of the proposed project. BLM 

notes that subsistence users have traditionally 

and culturally managed how we hunt so as to not 

disrupt other hunters, ensure successful hunts by 

all, and share subsistence resources in the 

community and across the North Slope (SEIS, pg. 

441).

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

The statement referred to in the comment is a partial 

reading of the sentence which begins "If the road has a 

tendency to prevent caribou from coming closer to 

town, then..." BLM will revise the "will" that is at issue 

to "could" in order to match the assertion that the 

statement is a future possibility.

L87-11 Arctic Slope 

Regional 

Corporation

ASRC finds it confusing how BLM has 

characterized movement and deflection of 

Caribou with respect to the Red Dog Mine and the 

Teshekpuk Caribou Herd (SEIS, pg. 350).

3.11 Caribou Thank you for your comment. Point number 3 on page 

350 of the DSEIS discusses caribou responses to the 

Red Dog Mine road. A study by Wilson et al. (2016) 

was provided as one example of how caribou 

responded to a newly-constructed road. The authors 

point out that annual variability of responses to the Red 

Dog Mine road was high and cautioned that caribou 

behavior is very context -dependent (i.e. exacerbated 

or mitigated by environmental variables, herddependent, or individual-dependent). The BLM used 

this example to offer insight in to the potential impacts 

of the proposed GMT1-GMT2 Access Road, 

Alternatives A and B. One of the points form Wilson 

(2016) is that predicting a caribou herd's response to a 

newly constructed road is largely speculative because 

of the variables associated with behavior. Nonetheless 

the impacts associated with roads require disclosure. 

Some of the impacts may include potential obstruction 

due to snow accumulation, disturbance from traffic, 

access and related impacts from subsistence hunting. 

Cumulatively, the roaded alternative will expedite 

development in the NPRA compared to the constraints 

on industry from Alt. C. and the potential of 

incremental increase in development. 
Supplemental Environmental Impact Statement

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165

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L87-12 Arctic Slope 

Regional 

Corporation

As ASRC raised in both our scoping comments 

and during consultation, BLM should consider 

how the GMT2 Road will provide additional 

access to over‐land subsistence areas for hunters 

who may not have the means or access to boats 

to hunt via the Colville River, where the majority of 

subsistence hunting occurs. ASRC is concerned 

why this likely outcome is noted only once and not 

carried through in BLM’s analysis (SEIS, pg. 432). 

Recent studies from Stephan R. Braund 

assessing the Spur Road also support the trend 

towards an increase in overland hunting (which 

can be more economical) since the Spur Road 

was finished (SEIS, pg. 431).

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

This positive impact is described under the analysis for 

Alternatives A and B, both of which include a road 

connection between GMT1 and GMT2 (the section is 

entitled GMT2 Access Road). It is not carried forward 

under the Alternative C or D analysis because those 

alternatives do not include a road between GMT1 and 

GMT2.

L87-13 Arctic Slope 

Regional 

Corporation

In several areas BLM states that the “eventual 

restriction” of subsistence users on the GMT2 

Road is possible due to tundra damage (SEIS, pg. 

434 and 452). It is unclear to ASRC why BLM has 

included this in their analysis and how the GMT2 

Road could possibly be restricted to subsistence 

users. The local people have made clear their 

preference that the GMT2 Road remain a private 

road to eliminate outside hunter competition in the 

area, while the operator has clearly committed 

that local people will be allowed access to the 

GMT2 Road for subsistence purposes and even 

designed subsistence pull‐outs and ramps for 

ease of access. It is unclear if BLM is proposing 

that BLM may in the future legally restrict local 

access of the GMT2 Road to mitigate tundra 

damage. If BLM plans to legally limit access, BLM 

should be transparent in their intention or 

otherwise remove this language from the SEIS as 

it is unnecessary and not supported by ASRC. 

Some of the GMT2 Road will traverse Native‐

owned land and BLM should not assume authority 

over access to Native‐owned land.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Text and references have been added to clarify the 

intent of the discussion regarding how tundra damage 

can physically restrict travelers, and to provide 

additional information regarding existing BMPs or 

regulations that do not allow tundra damage by BLM or 

other agencies with regulatory authority.
Supplemental Environmental Impact Statement

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

166

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L87-14 Arctic Slope 

Regional 

Corporation

BLM’s analysis does not include the likely 

scenario that over‐land hunting in the GMT2 area 

may increase as a result of GMT2 Road. As a 

result of the additional access provided by the 

GMT2 Road, the “avoidance affect” BLM notes in 

their analysis may be reduced or eliminated. This 

countervailing impact is currently overlooked in 

BLM’s analysis but is worth noting as a likely 

outcome of the GMT2 Road.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

BLM states "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 likely continue to travel overland 

via the off-road vehicles."

L87-15 Arctic Slope 

Regional 

Corporation

While BLM describes in one area how 

subsistence access to areas west of the 

community would increase because of the GMT2 

Road (SEIS, pg. 432), this assessment is not 

carried through BLM’s analysis and remains 

mostly unaddressed. ASRC is disappointed BLM 

did not fully assess this benefit as additional road 

access and connectivity is desired and supported 

by nearly every community on the North Slope 

and the sociocultural benefits of this additional 

infrastructure have been seen in Nuiqsut and 

Utqiaġvik. In Utqiaġvik, the Barrow Gas Field 

Road east of the community provides a further 

jumping off point for subsistence users. This has 

become a highly used road for subsistence 

purposes and has provided convenient access to 

an otherwise low‐use area. The Nuiqsut Spur 

Road, road to CD5, and now GMT1 also are 

examples of how road connectivity serves 

subsistence users and provides a direct benefit of 

expanding the range of subsistence. The 

proposed Colville River Access Road planned by 

Native Village of Nuiqsut, is also a good example 

of how additional road connectivity provides a 

direct benefit to subsistence users in the 

community. These roads were championed locally 

and can provide a good analogue to the GMT2 

road.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

This positive impact is described under the analysis for 

Alternatives A and B, both of which include a road 

connection between GMT1 and GMT2 (the section is 

entitled GMT2 Access Road). It is not carried forward 

under the Alternative C or D analysis because those 

alternatives do not include a road between GMT1 and 

GMT2.
Supplemental Environmental Impact Statement

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

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Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L87-16 Arctic Slope 

Regional 

Corporation

BLM should note in their analysis that access 

provided by the GMT2 Road may lessen the 

avoidance affect, or perhaps provide a benefit by 

creating additional throughways to other 

subsistence areas which would in turn benefit 

subsistence users and expand traditional hunting 

areas near GMT2.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

BLM states "Under Alternatives A and B, the avoidance 

effect may be decreased by facilitated access provided 

by the GMT2 road." 

L87-17 Arctic Slope 

Regional 

Corporation

Through our consultation, ASRC was made aware 

that BLM’s Impact Criteria was removed from the 

Draft SEIS because there was growing concern 

internally within BLM and Department of Interior 

that the Impact Criteria was highly subjective and 

tended towards an outcome of major impacts to 

subsistence. BLM has made several comments 

that they have had difficulty coming up with 

objective criteria to evaluate subsistence and that 

this is not required under NEPA. ASRC 

recommends that BLM adhere to their NEPA 

requirements with respect to their subsistence 

criteria. As an alternative, BLM should use the 

ANILCA 810 Criteria to evaluate impacts to 

subsistence.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

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 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. The 

ANILCA Section 810 criteria is specific to answering a 

single question: whether or not there may be a 

significant restriction to subsistence use, and our 

guidance is based on case law regarding that specific 

factor. The NEPA requirement to take a "hard look" 

(also based on case law) goes beyond addressing a 

single question, and instead requires BLM to address a 

whole host of issues, including those identified during 

scoping, through consultation with stakeholders, and 

based on a review of relevant literature. In short, 

NEPA's hard look requires a more comprehensive 

analysis than that required pursuant to ANILCA 

Section 810.
Supplemental Environmental Impact Statement

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168

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L87-18 Arctic Slope 

Regional 

Corporation

ASRC especially encourages ConocoPhillips to 

evaluate the slope of subsistence ramps, height of 

the GMT2 Road, and work with local subsistence 

hunters on continually evaluating impacts to 

subsistence users and subsistence resources 

from the Alpine development, GMT1, and GMT2. 

Through this collaboration, local subsistence 

hunters can express their concerns directly to the 

operator and the operator can directly address 

concerns whenever appropriate. ASRC supports 

this level of coordination and looks forward to 

participating in future engagements.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

BLM has included a potential mitigation measure 

requiring ConocoPhillips to work with the community of 

Nuiqsut to identify the location and design specification 

for the access ramps and pull outs along the GMT2 

road. See Section 4.4.6, Potential Mitigation Measure 7

L87-19 Arctic Slope 

Regional 

Corporation

ASRC recommends that BLM’s closely examine 

their description of the ASRC Gravel Pit and 

impacts associated with its use. ASRC was 

shocked by the level of attention the gravel pit 

received in the SEIS as it is not the proposed 

action, is already a permitted activity, and was 

never mentioned as a concern during ASRC’s 

regular consultation with BLM. Throughout the 

SEIS, BLM uses different maps to show the area 

to be mined which leads to confusion. Some of 

the maps reflect the permitted area of 300 acres 

while others show the mine area of approximately 

23 acres. The inconsistencies in the various maps 

have already led to confusion in public meetings 

and should be standardized in the Final SEIS.

2.1 Proposed 

Action & 

Alternatives

Use of gravel from the ASRC Gravel Pit as part of the 

project proposal makes gravel mining at the pit a 

connected action as defined by 40 CFR 1508.25 (a), 

and the BLM must demonstrate that we have 

considered the connected action in the NEPA 

document. According to the BLM NEPA Handbook, if 

the connected action (either Federal or non-Federal) 

and its effects can be prevented by BLM decisionmaking, then the effects of the action are properly 

considered indirect effects of the BLM action and must 

be analyzed as effects of the BLM action [(40 CFR 

1508.25(c); H-1790-1 Section 6.5.2.1 Connected 

Actions]. The maps and description of the mine site 

have been reviewed and edited to provide a consistent 

description of the use of the mine site associated with 

the GMT2 project. 

L87-2 Arctic Slope 

Regional 

Corporation

Although ASRC notes ConocoPhillips's efforts to 

proactively address subsistence impacts through 

monetary means, project design features, 

mitigation measures and other mechanism, valid 

concerns remain from local stakeholders on the 

cumulative impact and pace of local resource 

development on the subsistence lifestyle of the 

local people.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

BLM discusses the pace of development in Section 

4.4.2 Sociocultural Systems - Pace.
Supplemental Environmental Impact Statement

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169

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L87-20 Arctic Slope 

Regional 

Corporation

The ASRC Gravel Pit is permitted by the United 

States Army Corps of Engineers (Corps), a 

cooperating agency on the SEIS. The ASRC 

gravel mine site has been permitted and 

thoroughly analyzed by the Corps, State of Alaska 

Department of Fish & Game, North Slope 

Borough, and other authorizing agencies since 

the mid‐1990s. ASRC’s disagrees with the degree 

of impacts BLM has attributed to the gravel pit 

and the subjective language used to describe 

assumed sociocultural impacts associated with 

activity at the gravel pit (SEIS, pg. 383). This is 

the eighth take from gravel pit that has been 

permitted at this site since 1996.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

One purpose of preparing a supplemental EIS is to 

provide updated information that did not exist when the 

original EIS was written. The BLM has added citations 

to the section describing concerns related to gravel 

mining to provide the source of the concerns that have 

been raised to the BLM from residents within the 

community regarding recent mining activity. 

L87-21 Arctic Slope 

Regional 

Corporation

BLM should refine their analysis of the gravel pit, 

focus their NEPA analysis on the proposed 

activity, and consult with the Corps and ASRC on 

how to accurately describe the gravel pit.

2.1 Proposed 

Action & 

Alternatives

The BLM has obtained information from the US Army 

Corps of Engineers regarding the NEPA analysis and 

permit that has been issued for mining in the ASRC 

gravel pit. Use of gravel from the ASRC Gravel Pit as 

part of the project proposal makes gravel mining at the 

pit a connected action as defined by 40 CFR 1508.25 

(a), and the BLM must demonstrate that we have 

considered the connected action in the NEPA 

document. According to the BLM NEPA Handbook, if 

the connected action (either Federal or non-Federal) 

and its effects can be prevented by BLM decisionmaking, then the effects of the action are properly 

considered indirect effects of the BLM action and must 

be analyzed as effects of the BLM action [(40 CFR 

1508.25(c); H-1790-1 Section 6.5.2.1 Connected 

Actions]. The maps and description of the mine site 

have been reviewed and edited to provide a consistent 

description of the use of the mine site associated with 

the GMT2 project. 
Supplemental Environmental Impact Statement

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

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Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L87-22 Arctic Slope 

Regional 

Corporation

ASRC disagrees with the inclusion of the blasting 

study in the SEIS as it is not a proper analogue, 

doesn’t reflect current blasting practices and 

technologies, and provides no actual analytical 

value; we request that this be removed from the 

SEIS (SEIS, pg. 102)

3.6 Acoustical 

Environment

In the absence of site-specific noise data for blasting 

operations at the mine, we used published blast data 

from the Pääkkönen (1991) study as a reasonable 

proxy. But we also noted the importance of acquiring 

accurate on-site data for levels of blast noise near 

Nuiqsut as a means of determining the need for 

mitigation measures.

L87-23 Arctic Slope 

Regional 

Corporation

The language describing the mine as “unnerving” 

should either be cited with a source or removed 

as again, as it is not representative and does not 

provide any analytical value (SEIS, pg. 383). BLM 

also raises concerns over damage to heating or 

plumbing infrastructure. ASRC has investigated 

these concerns along with the Corps, North Slope 

Borough, and the operator and found that many of 

the impacts to local infrastructure are due to 

ground settling. This is well documented in the 

2014 report, Climate Change in Nuiqsut in 

Alaska1, issued by the Alaska Native Health 

Tribal Consortium in coordination with the North 

Slope Borough and the Native Village of Nuiqsut. 

ASRC encourages BLM to utilize this resource as 

a reference rather than incorrectly attributing 

these concerns to the gravel pit.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

One purpose of preparing a supplemental EIS is to 

provide updated information that did not exist when the 

original EIS was written. The BLM has added citations 

to the section describing concerns related to gravel 

mining to provide the source of the concerns that have 

been raised to the BLM from residents within the 

community regarding recent mining activity. 

L87-24 Arctic Slope 

Regional 

Corporation

BLM raises concerns over potential dust impacts 

from blasting and references a presentation from 

the U.S. Office of Surface and Mining created out 

of Denver, Colorado addressing blasting at coal 

mines in Wyoming. This citation has no bearing to 

the GMT2 project or its ancillary activities, and the 

presentation clearly states “this module is not 

intended to stand alone”. BLM should remove this 

citation and clarify their analysis.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

One purpose of preparing a supplemental EIS is to 

provide updated information that did not exist when the 

original EIS was written. The BLM has added citations 

to the section describing concerns related to gravel 

mining to provide the source of the concerns that have 

been raised to the BLM from residents within the 

community regarding recent mining activity. 
Supplemental Environmental Impact Statement

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

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Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L87-25 Arctic Slope 

Regional 

Corporation

Under the gravel permitting, the gravel pit has 

already gone through a NEPA process which BLM 

should tier from and consult with ASRC and the 

Corps on the many mitigation measures already 

incorporated into operations at the pit that 

address many of the concerns mentioned in the 

SEIS.

2.1 Proposed 

Action & 

Alternatives

The BLM has obtained information from the US Army 

Corps of Engineers regarding the NEPA analysis and 

permit that has been issued for mining in the ASRC 

gravel pit. Use of gravel from the ASRC Gravel Pit as 

part of the project proposal makes gravel mining at the 

pit a connected action as defined by 40 CFR 1508.25 

(a), and the BLM must demonstrate that we have 

considered the connected action in the NEPA 

document. According to the BLM NEPA Handbook, if 

the connected action (either Federal or non-Federal) 

and its effects can be prevented by BLM decisionmaking, then the effects of the action are properly 

considered indirect effects of the BLM action and must 

be analyzed as effects of the BLM action [(40 CFR 

1508.25(c); H-1790-1 Section 6.5.2.1 Connected 

Actions]. The maps and description of the mine site 

have been reviewed and edited to provide a consistent 

description of the use of the mine site associated with 

the GMT2 project. 

L87-26 Arctic Slope 

Regional 

Corporation

To address Air Quality concerns, ASRC 

recommends a table in the SEIS comparing the 

Nuiqsut air quality with air quality data from 

Fairbanks, Prudhoe Bay, Barrow, and Anchorage.

3.5 Air Quality & 

Meteorology

Thank you for the comment. In order to address the 

comment, we evaluated each of the suggested 

locations. The Anchorage and Fairbanks locations are 

over 600 kilometers away and would therefore not be a 

useful comparison to address concerns. The air quality 

data at Prudhoe Bay is impacted by nearby portable 

and mobile sources as described in the GMT1 AQIA for 

exclusion of background monitoring data at Deadhorse 

and A Pad. Therefore, these datasets are also not a 

useful comparison to address air quality concerns. The 

monitoring station at Barrow is not an EPA monitoring 

station and is instead observed and maintained by 

NOAA's Earth System Research Laboratory (ESRL). At 

this time, that monitoring station only records carbon 

monoxide and ozone. The incomplete dataset would 

not be useful for comparison to Nuiqsut's suite of data 

including NO2 and PM.
Supplemental Environmental Impact Statement

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Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L87-27 Arctic Slope 

Regional 

Corporation

To address Air Quality concerns, ASRC 

recommends the BLM should revise Slide 15 in 

the public meeting presentation to show values

3.5 Air Quality & 

Meteorology

Comment does not relate to the analysis in the SEIS.

L87-29 Arctic Slope 

Regional 

Corporation

To address Air Quality concerns, ASRC 

recommends BLM obtain from Alaska Department 

of Environment Conservation an inclusive and 

thorough list of air quality mitigation measures 

and design features that will be applied to the 

GMT2 project

3.5 Air Quality & 

Meteorology

See Appendix J for a description of State of Alaska 

regulations regarding air quality. 

L87-3 Arctic Slope 

Regional 

Corporation

In a recent public meeting in Nuiqsut for the 

GMT2 SEIS, concerns were voiced that the slope 

of subsistence access ramps were problematic for 

fully‐loaded sleds and that the planned height of 

the road may be problematic. ASRC encourages 

Conoco to work closely with local hunters to 

address these concerns and, where possible, 

reduce the slope of the subsistence ramps and 

height of the road to an acceptable level. ASRC is 

pleased that Conoco increased the number of 

subsistence pull outs since this project was 

originally proposed and their commitment to work 

with the community to address impacts to 

subsistence and subsistence users.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

BLM has included a potential mitigation measure 

requiring ConocoPhillips to work with the community of 

Nuiqsut to identify the location and design specification 

for the access ramps and pull outs along the GMT2 

road. See Section 4.4.6, Potential Mitigation Measure 7
Supplemental Environmental Impact Statement

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

173

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L87-30 Arctic Slope 

Regional 

Corporation

BLM correctly notes the burdensome permitting 

process creates sociocultural impacts on the 

community of Nuiqsut. ASRC has raised this 

impact to BLM several times. To alleviate this 

impact on the community, ASRC urges BLM to 

host the required, mandatory meetings in the 

community of Nuiqsut or when requested by the 

Native Village of Nuiqsut or Kuukpik Corporation. 

ASRC encourages BLM to maintain alignment 

with ANILCA with respect to public meetings and 

adhere to the input from Kuukpik and the Native 

Village of Nuiqsut on ways to minimize BLM’s 

permitting footprint in the community which has 

caused unnecessary anxiety and exhaustion.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

BLM will continue to host meetings within the 

community at the request of the Native Village of 

Nuiqsut and/or the Kuukpik Corporation, and will strive 

to combine those meetings with other requirements as 

possible so as to minimize the negative effects of these 

meetings to the community. However, we are also 

required through statute and regulation to hold other 

meetings or hearings, and it may not be possible to 

apply measures that could alleviate the associated 

stress and anxiety. BLM is highly conscious of the 

burden of permitting and our regulatory requirements, 

and where we have the ability to effect change to 

reduce these burdens we will do so.

L87-31 Arctic Slope 

Regional 

Corporation

Regional benefits from the NPR‐A Impact Fund 

which allocates funds to the municipal 

governments of the NPR‐A communities should 

be fully considered in BLM’s analysis. The NPR‐A 

Impact Fund has provided benefits to the local 

communities as a direct result of development 

within NPR‐A, and will be further stimulated by 

GMT‐2. Evidence of this positive impact can be 

seen with the gas pipeline in Nuiqsut, which was 

funded by the NPR‐A Impact Fund.

4.2 Mitigation The NPR-A Impact Mitigation Fund administered by the 

State of Alaska is described in detail in Section 4.4.5 

Subsistence.

L87-32 Arctic Slope 

Regional 

Corporation

Despite the documented, regional economic 

benefits of resource development for the local 

people, ASRC was disappointed by BLM’s 

multiple references to the “economic disparity” 

attributed to the GMT2 Project. ASRC objects to 

this characterization and encourages BLM to 

approach topics of community affairs with great 

sensitivity and only when absolutely necessary.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Through the NEPA process, the BLM has been 

presented information from local residents regarding 

economic disparity within the community (see NUI 

Public Meeting Transcript as a recent example), and it 

continues to be a topic of concern. 
Supplemental Environmental Impact Statement

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Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L87-33 Arctic Slope 

Regional 

Corporation

As BLM points out, Kuukpik Corporation is not 

open to “after‐births” despite multiple proposals to 

expand their shares. However, as the regional 

ANC, ASRC shareholders include “after‐births” 

and the Nuiqsut residents who are not Kuukpik 

shareholders are likely ASRC shareholders who 

still receive ASRC’s dividends and benefit 

financially from GMT2. BLM should not 

characterized the descendants of our 

shareholders as “after‐births”, this offensive 

language should be removed from the SEIS.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

BLM does not use the phrase "after-births." The 

footnote referenced states that "...subsequent 

generation's of Alaska Natives, commonly referred to 

as "afterborns"..." This is the terminology used in 

Village Journey: The Report of the Alaska Native 

Review Commission by Thomas Berger,1985 and is 

referred to in numerous ANCSA reports and citations. 

L87-34 Arctic Slope 

Regional 

Corporation

BLM should remove references to the City of 

Nuiqsut’s eligibility to receive funds from the 

NPRA Impact Grant Fund. BLM’s comments are 

inaccurate and inappropriate. ASRC encouraged 

BLM to make these changes and to take great 

sensitivity when discussing affairs and economic 

disparity.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

BLM has revised these sections.

L87-35 Arctic Slope 

Regional 

Corporation

In general, ASRC recommends that BLM be 

sensitive when discussing Native ownership, 

economic standing, and community affairs within 

the SEIS. ASRC concern is that BLM may 

inaccurately state certain items and may cause 

wedges between different community entities and 

members. Of these inaccuracies, ASRC notes 

that BLM has mischaracterized ASRC as the 

“largest private landowner in Alaska. Most of 

ASRC’s lands are rich in subsurface oil, gas, and 

base metals” (SEIS, pg. 173). ASRC finds this 

statement to be inaccurate and irrelevant to 

include in the SEIS. ASRC is not the largest 

private landowner in Alaska, but on the North 

Slope. Of landowners on the North Slope, BLM is 

likely the largest landowner, with known resource 

rich lands like the NPRA.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

BLM has removed the sentence regarding ASRC as 

the largest private landowner.
Supplemental Environmental Impact Statement

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Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L87-4 Arctic Slope 

Regional 

Corporation

Another concern raised at the public meeting in 

Nuiqsut was the timing of the GMT2 decision 

making prior to understanding the impacts from 

the recent GMT1 development. Specifically, 

ASRC notes that local hunters are wary of 

impacts to subsistence from GMT1 that may not 

be fully realized prior to the GMT2 Record of 

Decision. With respect to this concern, ASRC 

recommends that ConocoPhillips work directly 

with Nuiqsut Trilateral Group, local hunter, and 

the NPRA Working Group to closely examine any 

impacts from GMT1 and proactively address 

these with respect to GMT2.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

BLM has included a potential mitigation measure for 

the applicant to conduct monitoring of subsistence uses 

aimed at understanding the impacts of GMT1 and 

GMT2, in order to further minimize impacts through 

adaptive management.

L87-5 Arctic Slope 

Regional 

Corporation

The working relationship between hunters and 

industry does not end with BLM’s NEPA’s 

permitting process but should be maintained 

throughout life of GMT2. To this end, ASRC 

recommends that Conoco engage hunters directly 

and together closely examine how lessons 

learned from GMT1 can inform the development 

of GMT2 outside and beyond the permitting 

process.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

BLM has included a potential mitigation measure for 

the applicant to conduct monitoring of subsistence uses 

aimed at understanding the impacts of GMT1 and 

GMT2, in order to further minimize impacts through 

adaptive management.
Supplemental Environmental Impact Statement

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

176

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L87-6 Arctic Slope 

Regional 

Corporation

Throughout the SEIS, ASRC has several 

concerns for how subsistence and subsistence 

impacts are currently described and the 

inconsistencies in BLM’s analysis that would 

benefit from some additional clarity. First, there 

are several places in the SEIS where the area of 

GMT2 is referred generally as a “high‐use” (SEIS, 

pg. 419) subsistence area for caribou but in other 

instances it is described as “on the periphery of 

Nuiqsut’s core caribou hunting area” (SEIS, pg. 

428, 420, 426‐ 427). Given these very basic 

inconsistencies in BLM’s analysis, it becomes 

very challenging for the reader to distinguish the 

significance of the GMT2 area and the actual 

impacts of the additive GMT2 infrastructure to 

subsistence.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

The statement referred to on page 419 under Summary 

of Nuiqsut Subsistence Uses regarding the GMT2 

Project Area is for all subsistence resources, not only 

caribou. 

L87-7 Arctic Slope 

Regional 

Corporation

Furbearers are mentioned multiple times in the 

SEIS and ANILCA 810 Analysis as a significant 

subsistence resource in the GMT2 area with high 

overlapping areas for hunting (SEIS, pg. 428 and 

441). However, at other points in the SEIS it is 

noted that furbearers are “uncommon” in the 

GMT2 area (SEIS, pg. 146). ASRC is concerned 

these inconsistencies at best are confusing to the 

reader and decision‐maker, and, at worst, may be 

misleading regarding potential impacts to 

furbearers as it relates to GMT2 and subsistence.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

The wildlife section has been updated to include recent 

data regarding wolverine populations. However, the 

subsistence section draws from data from subsistence 

harvesters, and the Terrestrial Mammals section from 

data regarding wildlife populations or population density 

that may not be comparable due to a general lack of 

information for these species. 
Supplemental Environmental Impact Statement

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

177

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L87-8 Arctic Slope 

Regional 

Corporation

Impacts to subsistence are generally very broadly 

described to the extent that in some places it is 

not clear to the reader which subsistence 

resource BLM is analyzing (SEIS, pg. 427 and 

428) or how seasonality of subsistence hunting of 

that resource and actual activity at GMT2 (i.e., 

construction occurring in the winter and not during 

peak subsistence hunting [SEIS, pg. 424, 427, 

428]) is taken into consideration or even noted in 

BLM’s analysis. ASRC is concerned that this 

gross generalization tends towards a conclusion 

of significant impacts that isn’t well understood by 

BLM, stakeholders, or the reader. By generalizing 

impacts to all subsistence resource unilaterally, 

BLM fails to conduct a meaningful or clear 

analysis to aid valuable stakeholders and 

eventually the decision‐maker in determining 

impacts from the GMT2 project. BLM should avoid 

oversimplifying the subsistence practices of the 

local people or the subsistence resources in order 

to produce an outcome of significant impacts. 

Rather, ASRC recommends BLM carefully review 

these inconsistencies and make the necessary 

changes to provide a more clear analysis of

subsistence and subsistence impacts.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

The text has been revised to provide clarity regarding 

the subsistence resources being referred to, and the 

seasonality of the impact. We believe the text was 

shortened in an attempt to tier to existing analyses, and 

this may be leading to confusion. 
Supplemental Environmental Impact Statement

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

178

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L87-9 Arctic Slope 

Regional 

Corporation

ASRC is concerned with BLM’s language 

assessing how subsistence users who choose to 

utilize the GMT2 Road would create an impact to 

subsistence users who chose not to use the road 

for subsistence (SEIS, pg. 433 and 441). ASRC 

feels this commentary is inappropriate, outside 

the scope of NEPA, and an attempt to normalize 

an idea that subsistence users are impacting 

other subsistence users. We find this type of 

reasoning worrisome and inappropriate for BLM to 

analyze subsistence in this fashion. Our concern 

is that subsistence is becoming the source of the 

impact, rather than the project BLM is required to 

analyze.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

NEPA requires the BLM to evaluate the direct and 

indirect impacts of a proposed action. The concern 

cited by the commenter is an example of an indirect 

impact that could result due to the presence of a gravel 

road. 

L88-01 ConocoPhillips 

Alaska, Inc.

Update to Tables 3.3-1, 4.3-2, and 4.3-3. See 

Attachment B-1, B-2 and B-3 of L88, 

ConocoPhillips comment letter

3.8 Vegetation 

and Wetlands

Tables 3.3-1, 4.3-2, and 4.3-3 have been updated. 

L88-02 ConocoPhillips 

Alaska, Inc.

on page 89, there is a reference to Table 3.2-9 in 

this paragraph that should be a reference to Table 

3.2-8. See ConocoPhillips comment letter 

Attachment A. 

3.8 Vegetation 

and Wetlands

Reference has been corrected.

L88-03 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment A. 

On page 113, There is a slight difference in 

wetlands mapping between the ConocoPhillips 

USACE 404 permit application and the SEIS 

because the BLM used different wetlands 

mapping than CPAI provided in the USACE 

Individual Permit Application. This should be 

noted. 

3.8 Vegetation 

and Wetlands

The slight difference has been corrected with the new 

tables.
Supplemental Environmental Impact Statement

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

179

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L88-04 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment A. 

The hydrologic regime is missing from the NWI 

code for “Seral Herbs” and the assigned NWI 

code is PSS1 which is typically assigned to 

wetlands dominated by scrub-shrub vegetation 

types. Recommend considering “PEM1” NWI 

code which is typically assigned to wetlands 

dominated by herbaceous vegetation types, and 

assigning a hydrologic regime code based on 

aerial imagery interpretation or a description of 

plant species composition and occurrence on the 

landscape. “Seral Herbs” is also missing from 

Appendix D - Classification and Description of 

Vegetation and Wildlife Habitat Types submitted 

as part of the DSEIS. Descriptions for Coastal 

Complex, Elymus Meadow, Halophytic Grass Wet 

Meadow, Halophytic Willow-Graminoid Dwarf 

Shrub Tundra, Open Low Willow-Sedge Shrub 

Tundra, or Wet Sedge-Willow Tundra, all of which 

are listed in Table 3.3-1, are also missing from 

Appendix D. Many of these vegetation types are 

missing from Tables 4.3-2 and 4.3-3 as well. 

Recommend verifying that descriptions for all 

vegetation types referenced in the tables are 

included in Appendix D and checking the 

consistency of vegetation types listed in Chapters 

3 and 4 tables. 

3.8 Vegetation 

and Wetlands

Error for Seral Herbs has been corrected in the 

updated Table 3.3-1. Error of omission of 7 vegetation 

types in Tables 4.3-2 and 4.3-3 has been corrected in 

the updated tables. 

Descriptions of Coastal Complex, Elymus Meadow, 

Halophytic Grass Wet Meadow, Halophytic WillowGraminoid Dwarf Shrub Tundra will be added by Writer 

Editor. 

Still looking for descriptions of:

Seral Herbs

Open Low Willow-Sedge Shrub Tundra

Wet Sedge-Willow Tundra

L88-05 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment A. 

NWI code of Human Modified Barrens should be 

"Upland" instead of N/A since this vegetation type 

characterizes areas where gravel fill has been 

placed, as indicated in the table footnotes. 

3.8 Vegetation 

and Wetlands

Correction has been made in the updated Table 3.3-1.
Supplemental Environmental Impact Statement

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

180

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L88-06 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment 

A. Recommend revising first sentence "Areas not 

classified as water bodies or wetlands are 

considered uplands or Natural Barrens". The NWI 

codes assigned to Natural Barrens in Table 3.3-1 

includes E2US3P, which would be considered a 

water body. 

3.8 Vegetation 

and Wetlands

Corrected to say: " Areas not classified as water bodies 

or wetlands occupy just over 3 percent of the project 

area as shown in Table 3.3-1."

L88-07 ConocoPhillips

Alaska, Inc.

See ConocoPhillips comment letter Attachment A. 

Figure 3.3-3: Caption should say "111 

surveys....2001-2016". It appears the source for 

this graphic is Prichard et al 2017 Figure 5.

3.12 Mammals The figure caption has been updated.

L88-08 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment A. 

Mistake - "...(Johnson square kilometer et al. 

2005; Lawhead 2014b). That square kilometer 

part in the citation is a mistake. 

3.12 Mammals Thank you for noting this error.

L88-09 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment A. 

In paragraph 4 on page 170, it states there are 

approximately 250 Kuukpik shareholders while on 

page 174, paragraph 4, it states there are 325. 

3.16 Economy Updated information regarding the approximate number 

of current shareholders was obtained from Kuukpik 

Corporation, and the section has been revised.

L88-10 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment A. 

Section 3.4.4.2 This section erroneously states 

the Ooguruk and Nikaitchuq developments are 

suspended. Both are in production. 

3.16 Economy Revised text.

L88-100 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment B0. A more recent version of this figure would show 

Conoco's 2016 additions to the NPRA survey 

area.

BLM has the 2016 report with the survey area 

extended to the west; this should be used.

3.12 Mammals The figure has been updated.
Supplemental Environmental Impact Statement

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

181

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L88-101 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment B0. Please update Tables 3.3-1, 4.3-2, and 4.3-3 

with new Tables 3.3-1, 4.3-2, and 4.3-3 included 

below. The numbers are only slightly different in 

each new table but updated to reflect more recent 

analyses that were unavailable when the Modified 

NEPA Analysis Document (MNAD) was prepared 

and submitted to BLM in March 2016 and for 

consistency with the GMT2 404 application for 

wetlands fill. We also note that the existing tables 

3.3-1, 4.3-2, and 4.3-3 in the DSEIS are internally 

inconsistent so believe it best to update them. For 

reference, the acreages in the tables have been 

revised using the vegetation type detail from 

Jorgenson, et al. (2004) and Wells, et al. (2014), 

and the latest project footprints for each action 

alternative as follows:

- Alternative A footprint – submitted to BLM on 26 

May 2017

- Alternative B footprint – submitted to BLM on 9 

June 2017

- Alternative C footprint – submitted to BLM on 7

December 2016 (as Alternative D1); the 

appropriate citations are:

Jorgenson, M.T., J.E. Roth, M. Emers, W. Davis, 

E.R. Pullman, and G.J. Frost. 2004. An Ecological 

Land Survey in the Northeast Planning Area of 

the National Petroleum Reserve-Alaska. 2003: 

Addendum to the 2002 Report. Prepared by ABR, 

Inc. - Environmental Research & Services (ABR,

Inc.). Prepared for ConocoPhillips Alaska, Inc. 

and Anadarko Petroleum Corporation.

Wells, A.F., M.W. Macander, C.S. Swingley, T.C. 

Cater, T. Christopherson, A.N. Cade, T.C. 

Morgan, and W.F. St. Lawrence. 2014. 2013 

Habitat Monitoring and Assessment CD5 

Development Project. ABR, Inc. Fairbanks, AK, 

and Polar Alpine, Inc. Berkeley, CA.

3.8 Vegetation 

and Wetlands

Updated tables inserted into the document and 

outdated tables were removed. 
Supplemental Environmental Impact Statement

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

182

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L88-102 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment B0. As depicted in red on the below graphic labeled 

Sheet 23 of 33, the messenger cable may be 

attached to the sides of the horizontal support

members rather than suspended beneath them.

2.1 Proposed 

Action & 

Alternatives

Updated Sheet 23 of 33 has been added to Appendix 

A: Permit Drawings Package.

L88-103 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment B0. Attachment D contains updated inundation 

analyses for Alternatives A & B. Tables 4.2-4 and 

4.2-5 of the DSEIS use information from the

MNAD Alternative A analysis prior to the change 

in the way the road enters the GMT2 pad. These 

should be updated to reflect the new road 

alignment. The Alternative B values should also 

be updated in order to be consistent with the 

updated Alternative A method. The\ text on the 

bottom of page 255 and top of 256 should also be 

adjusted to account for the additional 

conservatism built into the analysis: The historical 

gage data indicated typical duration of snowmelt 

runoff is seven days, with peak flow conditions 

occurring approximately 3.5 days after the start of 

runoff. It is assumed that the duration of snowmelt 

runoff at the USGS gage is representative of 

conditions along the proposed GMT2 Alternative 

A alignment. To provide a conservative estimate 

for this analysis, the duration of snowmelt runoff 

was condensed to a five-day period with peak 

flow conditions occurring 2.5 days after the start 

of runoff. (page 1 of Alternative A update in 

Attachment D)

3.4 Water 

Resources

Edits were made to Tables 4.2-4 to 4.2-7 and all 

referrals to this table and the snowmelt runoff periods.
Supplemental Environmental Impact Statement

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

183

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L88-104 ConocoPhillips 

Alaska, Inc.

BLM Should Explain Its Method for Assessing 

Impacts to Social Systems Elements. BLM used 

prescribed criteria for evaluating impacts to 

physical characteristics and the biological

environment and, accordingly, it would be helpful 

for BLM to clarify its analytical approach to the 

assessment of potential impacts to social systems 

elements. This is true regardless of whether BLM 

chooses to adopt different criteria for the social 

systems assessments or to adopt no criteria at all. 

In either case, it is important that BLM clearly 

explain (i) why it is using a different approach for 

its analyses of social systems impacts, and (ii) the 

supporting rationale for the methodology used by 

BLM to evaluate social systems impacts.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

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 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.

L88-105 ConocoPhillips 

Alaska, Inc.

BLM Should Explain Its Method for Assessing 

Impacts to Social Systems Elements. BLM used 

prescribed criteria for evaluating impacts to 

physical characteristics and the biological

environment and, accordingly, it would be helpful 

for BLM to clarify its analytical approach to the 

assessment of potential impacts to social systems 

elements. This is true regardless of whether BLM 

chooses to adopt different criteria for the social 

systems assessments or to adopt no criteria at all. 

In either case, it is important that BLM clearly 

explain (i) why it is using a different approach for 

its analyses of social systems impacts, and (ii) the 

supporting rationale for the methodology used by 

BLM to evaluate social systems impacts.

3.18 Public 

Health

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 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. 
Supplemental Environmental Impact Statement

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

184

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L88-106 ConocoPhillips 

Alaska, Inc.

BLM Should Explain Its Method for Assessing 

Impacts to Social Systems Elements. BLM used 

prescribed criteria for evaluating impacts to 

physical characteristics and the biological

environment and, accordingly, it would be helpful 

for BLM to clarify its analytical approach to the 

assessment of potential impacts to social systems 

elements. This is true regardless of whether BLM 

chooses to adopt different criteria for the social 

systems assessments or to adopt no criteria at all. 

In either case, it is important that BLM clearly 

explain (i) why it is using a different approach for 

its analyses of social systems impacts, and (ii) the 

supporting rationale for the methodology used by 

BLM to evaluate social systems impacts.

3.16 Economy 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 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. 

L88-107 ConocoPhillips 

Alaska, Inc.

BLM Should Explain Its Method for Assessing 

Impacts to Social Systems Elements. BLM used 

prescribed criteria for evaluating impacts to 

physical characteristics and the biological

environment and, accordingly, it would be helpful 

for BLM to clarify its analytical approach to the 

assessment of potential impacts to social systems 

elements. This is true regardless of whether BLM 

chooses to adopt different criteria for the social 

systems assessments or to adopt no criteria at all. 

In either case, it is important that BLM clearly 

explain (i) why it is using a different approach for 

its analyses of social systems impacts, and (ii) the 

supporting rationale for the methodology used by 

BLM to evaluate social systems impacts.

3.14 Cultural and 

Paleontological 

Resources

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 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. 
Supplemental Environmental Impact Statement

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

185

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L88-108 ConocoPhillips 

Alaska, Inc.

CPAI recommends that BLM adopt the criteria of 

the Alaska National Interest Lands Conservation 

Act (ANILCA) Section 810 analysis, described in 

Appendix L, as the criteria for assessing 

subsistence impacts, and also the other social 

systems for which the impacts are largely 

determined by subsistence. In our view, this 

would allow for adherence to the legally 

prescribed analysis for subsistence while also 

allowing for consideration of the other factors that 

BLM has included in its analysis. It would also 

allow BLM to draw meaningful conclusions that 

are not so detailed that they convey a false 

precision. The analysis should be consistent with 

the Section 810 subsistence analysis, and focus 

on facts and material issues while avoiding 

speculation and tangential issues. If BLM adopts 

this approach (or any other approach), it should 

explain the basis for it and why BLM is using an 

approach that is different than the criteria 

assessment used to address impacts to physical 

characteristics and the biological environment. 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

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 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. The 

ANILCA Section 810 criteria is specific to answering a 

single question: whether or not there may be a 

significant restriction to subsistence use, and our 

guidance is based on case law regarding that 

overriding factor. The NEPA requirement to take a 

"hard look" (also based on case law) goes beyond 

addressing a single question, and instead requires BLM 

to address a whole host of issues, including those 

identified during scoping, through consultation with 

stakeholders, and based on a review of relevant 

literature. In short, NEPA's hard look requires a more 

comprehensive analysis than that required pursuant to 

ANILCA Section 810.

L88-109 ConocoPhillips 

Alaska, Inc.

The DSEIS states at page 431 that “[b]rief stops 

for subsistence purposes would be permitted at 

designated pullouts or parking areas.” (Emphasis 

added.) By adding the word “brief,” the DSEIS 

minimizes the fact that CPAI has designed the 

road with pullouts for Nuiqsut residents to use for 

subsistence, with no prescribed time limit on their 

use. This type of negative characterization 

appears throughout the subsistence analysis. 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

This language was taken from the concise one-page 

guidelines that accompany the GMT1 Road Access 

Agreement (see bullet seven) prepared by 

ConocoPhillips. It was assumed that the rules that are 

applicable to the GMT1 Road and other industrial roads 

in the Alpine area would be consistent with those to be 

applied to the GMT2 Road.
Supplemental Environmental Impact Statement

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

186

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L88-11 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment A. 

The statement, “Nuiqsut, like all other North Slope 

Borough communities, does not qualify as 

economically distressed” is no longer correct. The 

Denali Commission 2017 report lists Anaktuvuk 

Pass and Point Hope as economically distressed. 

3.16 Economy Revised text to incorporate results of more recent 

report.

L88-110 ConocoPhillips 

Alaska, Inc.

The idea of caribou deflection pervades the entire 

subsistence analysis. See, e.g., DSEIS, p. 428 

(“[E]effects of resources availability could occur . . 

. due to deflection.”); see also DSEIS, pp. 439, 

443; App. L, p. 8. By raising the issue repeatedly 

as a concern, the DSEIS conveys a sense of 

negative impact that is out of proportion to the 

available data. The data, as discussed in 

Attachment C, support the conclusion that caribou 

are being harvested closer to Nuiqsut and closer 

to roads than before, so current roads do not 

appear to be significantly impairing caribou 

harvest generally, and there is no reason to think 

the GMT2 road would have a greater impact.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Text has been revised to include data from year 9 of 

the Nuiqsut Caribou Monitoring Study which includes 

additional information regarding use of the road for 

subsistence harvesting. Deflection of resources, 

including caribou, is one of the most frequent concerns 

raised by local residents regarding oil industry and 

associated activities. This section has been carefully 

reviewed to ensure the text is consistent with 

comments received as part of the review of the draft 

SEIS, and duplicative or speculative text without 

supporting information has been revised.

L88-111 ConocoPhillips 

Alaska, Inc.

The DSEIS analysis also tends to present 

speculation as known negative impacts that are 

attributable to GMT2. For example, the DSEIS 

states: “If residents decrease the use of the 

project area, the opportunity to transmit traditional 

knowledge about the area would diminish and 

could eventually be lost to younger generations. . 

. . Any changes to residents’ ability . . . to 

harvest resources in traditional places at the 

appropriate times . . . could have long-term or 

permanent effects on culture[.]”20 That sounds 

ominous, but it is pure speculation and not an 

analysis of the reasonably anticipated impacts of 

the GMT2 project.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

This section has been carefully reviewed to ensure the 

text is consistent with comments received as part of the 

review of the draft SEIS, and duplicative or speculative 

text without supporting information has been revised.
Supplemental Environmental Impact Statement

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

187

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L88-112 ConocoPhillips 

Alaska, Inc.

The DSEIS does not, however, include 

countervailing information, such as the following 

quote from the subsistence reports: [At the] end of 

July or August, I went out with the four-wheeler 

five or six or seven or eight times, around these 

lakes here. Let’s see, all around over here is 

where we went. This area here all the way to CD5 

here ... from CD5 I traveled to here [to the west], 

around this area right here. Right around this way. 

I get some caribou at CD5. I tried at CD5 but 

there was quite a few caribou – like 10 to 15. The 

people that were working there, they keep seeing 

a lot. My nephew was telling me they were seeing 

caribou around that area ... I can’t remember, 

practically every day or every other day. Yeah, 

late August to September I probably went like 

every other day [by four-wheeler]. Yeah, June, 

July, August by Honda.... Yeah, they were pretty 

much in that whole area, they still go to that area 

even though CD5 is there. They are all over that 

area, they have still been seeing them in that 

area. (SRB&A Nuiqsut Interview November 2014)[

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Many direct quotations in the DSEIS text were removed 

in order to be consistent with new NEPA requirements 

regarding brevity of analysis. The text was revised to 

include relevant quotations, such as this, to help 

explain the context of identified positive and negative 

impacts.
Supplemental Environmental Impact Statement

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

188

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L88-113 ConocoPhillips 

Alaska, Inc.

The DSEIS simply ignores some of the most 

important harvest data, which provide strong 

evidence that subsistence is healthy in Nuiqsut 

and can reasonably be expected to remain 

healthy even with the construction and operation 

of GMT2. As described in more detail with 

supporting data in Attachment C, subsistence 

harvests of the most important resources are 

stable or increasing for Nuiqsut residents. This is 

relevant, objective, scientifically documented 

information from an independent third party. It 

should be an important part of the subsistence 

analysis, but instead it is treated dismissively with 

the statements that harvest data are “not the only 

measure of health of the subsistence lifetyle”21 

and “not always reflective of changes in the 

subsistence lifestyle.”22 Neither of these 

statements address the fact that there are 

objective, relevant, independent subsistence data 

that are not presented in the DSEIS and that 

counter some of the statements that are included 

in the DSEIS. 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

A new section entitled "Existing Levels of Impacts on 

Subsistence Uses" has been included in Chapter 3, 

Section 3.4.6 Subsistence that discusses subsistence 

harvest data. 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.

L88-114 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment C. 

CPAI urges BLM to incorporate the information 

presented in this Section III.B of the comment 

letter, and the more technical information in 

Attachment C, into the Section 4.4.5 analysis of 

subsistence impacts in the FSEIS. In light of what 

appear to be competing viewpoints regarding the 

scope and magnitude of the impacts (both 

negative and positive) associated with 

development in the NPR-A generally, and for the 

GMT2 project in particular, BLM should ensure 

that both viewpoints are presented in the FSEIS. 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Many direct quotations in the DSEIS text were removed 

in order to be consistent with new NEPA requirements 

regarding brevity of analysis. The text was revised to 

include relevant quotations, such as this, to help 

explain the context of identified positive and negative 

impacts.
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Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L88-115 ConocoPhillips 

Alaska, Inc.

The DSEIS discusses the potential for caribou 

deflection specifically due to road height.23 The 

GMT2 road is proposed to be five feet high with 

2:1 side slopes. The photo below shows caribou 

climbing a slope that is 38 feet high, over a 

distance of 91 feet, with a slope of 2.4:1, which is 

similar to the GMT2 road and about seven times 

as high. This photo was taken during the summer 

of 2017 at Mine Site E on the border between the 

Kuparuk River Unit and the Milne Point Unit. 

Oilfield facilities are visible in the upper left corner 

of the photo. While the DSEIS reports instances 

in which individuals have expressed concern 

about deflection, the photo indicates that caribou 

have no trouble climbing a steep embankment, 

even one they cannot see over. 

3.11 Caribou The text referenced on pg. 428 does not specify "road 

height" as the cause of deflection, but rather mentions 

deflection generally. The DSEIS, as written, accurately 

describes public concerns regarding road features and 

caribou movements.
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Name

Comments Comment 

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Comment Response

L88-116 ConocoPhillips 

Alaska, Inc.

The DSEIS also presents other concerns about 

the road, not specific to road height, such as the 

assertion that local hunters “frequently report 

deflection of caribou from industrial roads.”24 The 

DSEIS fails to include evidence supporting the 

view that caribou grow habituated to roads 

relatively easily, and roads provide useful access 

to hunting opportunities. The following testimony 

from reports available to BLM should have been 

included in the DSEIS: In contrast, several 

respondents expressed the view that the road will 

not negatively affect the caribou, and even 

thought that it could be advantageous for hunters. 

One respondent observed that caribou have 

grown accustomed to past development projects 

and activities, while another pointed out that the 

road will make hunting access easier. 

Just on CD5, it is a brand new road. I don’t think 

there would be any impact [from] the road. All 

these here, the CDs, I never did hunt in the 

area... We observed the caribou are kind of 

getting used to all the activity up here. They don’t 

mind it, when they migrate they go through all of 

that. They don’t even run away from the choppers 

anymore. (SRB&A Nuiqsut Interview November 

2014) 

I believe [I'll keep hunting on the Spur Road] 

because it’s a prominent road. It’s pretty bumpy 

on the tundra and this makes it easier. It’s pretty 

safe, I believe, since they made the road wider. 

(SRB&A Nuiqsut Interview January 2015)[25] 

CPAI recommends that BLM include this positive 

testimony in the final SEIS to provide a more 

balanced analysis of the potential impact of roads. 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Many direct quotations in the DSEIS text were removed 

in order to be consistent with new NEPA requirements 

regarding brevity of analysis. The text was revised to 

include relevant quotations, such as this, to help 

explain the context of identified positive and negative 

impacts.
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Name

Comments Comment 

Category Code

Comment Response

L88-117 ConocoPhillips 

Alaska, Inc.

The DSEIS emphasizes that hunters avoid 

hunting near infrastructure, causing a negative 

impact on subsistence.26 This position is 

incorrectly supported by the assertion that “72 

percent of respondents” made “observations of 

avoidance” in 2015.27 The study cited in support 

of this number first asks hunters if they avoided 

areas where they previously hunted, and then 

asks why. 28 But the 72 percent number applies 

only to the subset of observations from hunters 

who reported avoiding an area at all, which in 

2015 was 58 percent and in the draft 2016 report 

is 51 percent. Thus, the number of observations 

of avoidance of development is even less than 58 

percent of respondents in 2015 and 51 percent of 

respondents in 2016. It should be noted in the 

Stephen R. Braund & Associates (SRB&A) 

presentation given to the NSB (Attachment H) that 

the percent of observations on the cause of 

avoidance dropped from 72 percent to 53 percent 

in Year 9. This data is indicative that fewer than 

50 percent of hunters report avoiding an area due 

to development. The result of BLM’s use of the 72 

percent figure is a serious misrepresentation of 

the data, and an incorrect conclusion about the 

magnitude of infrastructure avoidance. This 

misrepresentation is magnified by the fact that the 

numbers of hunters harvesting within 2.5 miles of 

infrastructure is increasing. 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Text has been revised to clarify the data from SRB&A. 
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Comm # Commenter 

Name

Comments Comment 

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Comment Response

L88-118 ConocoPhillips 

Alaska, Inc.

The DSEIS asserts than an “industry-established 

safety area would be delineated and restricted to 

authorized use during construction (2-3 years), 

thereby restricting access to this area by 

subsistence users during that time. The footprint 

of that safety area would be approximately 142 

acres. It is within close proximity (<5 miles) of the 

community.”29 Since the GMT2 pad is 16 miles 

from Nuiqsut, it is entirely unclear what area is 

being described here. In any case, the only 

safety restrictions during construction are on 

shooting across or towards ice roads and pad. 

Travel on the ice and gravel roads is available as 

soon as they are complete and ready for use. Ice 

roads are typically open by February 1st each 

year and the gravel road is open by October in the 

year it is constructed. 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Text has been revised to clarify information regarding 

the safety area, and unavailability of the gravel road 

during construction.

L88-119 ConocoPhillips 

Alaska, Inc.

another example of the errors contained in the 

subsistence analysis is the incorrect assertion that 

“[a]authorized subsistence hunters would be 

permitted to use the GMT1-GMT2 access 

road.”30 That statement lays a foundation for a 

later conclusion that the road would pose a legal 

barrier to access to subsistence resources. But 

CPAI does not authorize some users and withhold 

authorization from others. Residents of Nuiqsut 

are allowed to use the road, subject only to basic 

coordination rules that provide for safety of all 

users. There is no authorization program, 

requirement, or restriction. 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

The text has been revised to remove the word 

authorized and to clarify that subsistence users are 

permitted to use the road subject to basic coordination 

and safety rules.

L88-12 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment A. 

On page 200, Reference to map 3.3-1 should be 

3.1-1

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Map reference has been corrected.
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Name

Comments Comment 

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Comment Response

L88-120 ConocoPhillips 

Alaska, Inc.

The Section 4.4.5 analysis does not adequately 

distinguish between impacts that might be caused 

in the future by the GMT2 project, and impacts 

that may be happening already for other reasons. 

This is partly because the GMT2 “project area,” as 

described and analyzed in the DSEIS, is 

expansive. It includes CD1/ACF, the City of 

Nuiqsut, all areas that might be used under any of 

the potential alternatives (even though only one 

will actually be selected), and a 2.5-mile wide 

buffer on every side of every area.31 By 

comparison, the actual road, pad, and pipeline 

that will be constructed for GMT2 is a fraction of 

the defined project area. Even though pipelines 

will extend from CD5 to ACF, they will be laid 

alongside existing pipelines on existing support 

members, and thus present no new infrastructure 

footprint in this area. These details are not clearly 

explained in the current analysis. Overbroad use 

of the project area definition was a defect in the 

subsistence analysis in BLM 2014, and it should 

be corrected here, not perpetuated.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

NEPA requires the BLM to evaluate the impacts of the 

entirety of a project, including areas of associated 

activities and connected actions. The project area is 

defined to include such connected areas as the ASRC 

gravel pit from which gravel will be derived and Alpine 

which is the origination point of most traffic to and from 

GMT2, to name just two examples. See Section 4.4.5.1 

Methodology - GMT2 Areas of Potential Effects for 

Subsistence for a complete explanation of the project 

area including the 2.5 mile buffer.
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Comments Comment 

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Comment Response

L88-121 ConocoPhillips 

Alaska, Inc.

The subsistence analysis relies heavily on 

observations of the degree to which subsistence 

activities overlap with the project area, as it has 

been expansively defined in the DSEIS. For 

example, the DSEIS states that “[t]he GMT2 

Project study area overlaps with many of 

Nuiqsut’s most concentrated subsistence use 

areas,”32 “[t]he GMT2 project area would overlap 

27% of subsistence use areas for all resources 

during the construction phase and would overlap 

23% of overland subsistence use areas for all 

resources during the drilling and operations 

phase,”33 and “374 caribou use areas . . . 

overlapped use areas within the project study 

area.”34 Such observations, however, do not 

accurately reflect the actual impacts of the GMT2 

project because many of the areas in which 

subsistence activities overlap with the project area 

contain infrastructure that is already constructed 

and not part of the GMT2 project. Indeed, much of 

the infrastructure in the project area has been in 

place for nearly 20 years. Whether or not GMT2 is 

constructed, the City of Nuiqsut, the Alpine 

facilities, the ASRC gravel mine, and the annual 

ice roads, all of which are located in the GMT2 

project area as defined by BLM, will continue to 

exist. So, repeating that the GMT2 project area 

overlaps with subsistence use areas is not helpful 

in understanding the potential impacts of the 

GMT2 project on subsistence. 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

NEPA requires the BLM to evaluate the impacts of the 

entirety of a project, including areas of associated 

activities and connected actions. The project area is 

defined to include such connected areas as the ASRC 

gravel pit from which gravel will be derived and Alpine 

which is the origination point of most traffic to and from 

GMT2, to name just two examples. See Section 4.4.5.1 

Methodology - GMT2 Areas of Potential Effects for 

Subsistence for a complete explanation of the project 

area including the 2.5 mile buffer.
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Comment Response

L88-122 ConocoPhillips 

Alaska, Inc.

The analysis in Section 4.4.5 of the DSEIS should 

focus on the key aspects of the GMT2 project, 

especially the construction and use of the new 

road and pad, and any potential subsistencerelated impacts associated with those aspects. 

Appropriate delineation between project-specific

impacts and baseline or cumulative impact 

information will result in a more analytically 

correct, and accurate, subsistence analysis. 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

BLM has reviewed the sociocultural impacts section, 

and has revised text to ensure that those aspects of the 

discussion that should be included in the cumulative 

section are addressed there, and not in the direct or 

indirect impacts resulting from the proposed action and 

alternatives.
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Name

Comments Comment 

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Comment Response

L88-123 ConocoPhillips 

Alaska, Inc.

The DSEIS analyzes “User Access,”35 the “GMT2 

Access Road,”36 and “Avoidance”37 as 

independent variables, all of which are focused on 

the notion of access to subsistence resources. 

The effect of analyzing these closely-related 

categories distinctly is to magnify the impression 

of potential subsistence impacts associated with 

the avoidance of infrastructure, including roads. 

The DSEIS discusses various types of restrictions 

on access at length, such as the notion that 

access is restricted when the road is being 

constructed: “During [construction], access onto 

or via the road would be physically and legally 

restricted.”38 This discussion ignores the fact that 

CPAI is committed to making this road, some of 

which is on private lands owned by Kuukpik 

Corporation, available to residents of Nuiqsut and 

therefore useful for subsistence. The DSEIS 

characterizes the open-access road, which is 

subject only to basic coordination requirements to 

ensure the safety of both industrial and residential 

users, as a barrier to subsistence.39 However, a 

rig will be moved to GMT2 before drilling 

commences, and moved offsite months or years 

later—this cannot reasonably be characterized as 

a “legal restriction” on access to subsistence 

resources. A typical rig move may intermittently 

occupy the road over one to two days and 

includes periods of time when traffic may pass. 

Very few other uses of the road would restrict use 

of the road for subsistence. More detailed 

discussion about coordinated use of the road

during phases of project construction and 

operation is set forth in Attachment C. 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Text has been revised to include information from 

Conoco to clarify extent of potential access issues due 

to industrial activity. 
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Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L88-124 ConocoPhillips 

Alaska, Inc.

The DSEIS acknowledges that the GMT2 ramps 

“likely” will be better, but relates that “concerns 

remain.”42 CPAI submits that the improved 

design has substantially addressed the concerns, 

and the subsistence pullouts and access ramps 

make year-round access to this area more 

reliable, more convenient, and less timeconsuming. 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

This section has been carefully reviewed to ensure the 

text is consistent with comments received as part of the 

review of the draft SEIS, and duplicative or speculative 

text without supporting information will be revised.

L88-125 ConocoPhillips 

Alaska, Inc.

In Appendix L of the DSEIS, the factors are not 

described using the same words as in the BLM 

guidance. The most significant deviation is that in 

the DSEIS’s statement addressing limitations on 

access references only “increased competition for 

the resources” and does not reference physical 

and legal barriers (as directed by the BLM 

guidance).44 This deviation is not explained, and 

we recommend that the BLM guidance be stated 

accurately and followed by BLM. 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

The text has been revised to more clearly address the 

factors required by BLM guidance. 
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Comment Response

L88-126 ConocoPhillips 

Alaska, Inc.

CPAI recommends that BLM clearly articulate the 

ANILCA Section 810 factors in Section 4.4.5 and 

how they are used in both Section 4.4.5 and 

Appendix L to define the level of impact. We also 

recommend that BLM include a summary to 

characterize the level of impact. In our view, the 

Section 810 distinction between actions that 

“would significantly restrict subsistence uses” and 

those that would not is a sound way to summarize 

the analysis, as long as the summary is 

adequately explained. 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

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 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. The 

ANILCA Section 810 criteria is specific to answering a 

single question: whether or not there may be a 

significant restriction to subsistence use, and our 

guidance is based on case law regarding that 

overriding factor. The NEPA requirement to take a 

"hard look" (also based on case law) goes beyond 

addressing a single question, and instead requires BLM 

to address a whole host of issues, including those 

identified during scoping, through consultation with 

stakeholders, and based on a review of relevant 

literature. In short, NEPA's hard look requires a more 

comprehensive analysis than that required pursuant to 

ANILCA Section 810.
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Comments Comment 

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Comment Response

L88-127 ConocoPhillips 

Alaska, Inc.

Attachment C includes data that should be 

included in subsistence analysis. The information

supports the following points:

• The GMT2 project is not expected to decrease 

the abundance or availability of harvestable 

subsistence resources.

• Harvest levels are healthy, and GMT2 is not 

expected to cause a decrease in harvest.

• Time required for caribou harvest is not 

increasing, and GMT2 is not expected to cause 

an increase in time required.

• Overlap of subsistence use areas and the 

expansively defined GMT2 project area does 

not mean that a significant loss of subsistence 

use area will occur.

• The GMT2 road will not pose a significant 

physical or legal barrier to subsistence. 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

BLM appreciates your comment, and has included it 

and the information cited in Appendix C in our analysis. 

L88-128 ConocoPhillips 

Alaska, Inc.

The DSEIS section addressing sociocultural 

impacts also does not correctly distinguish 

between (i) the direct and indirect effects of the 

GMT2 project and (ii) cumulative impacts. Instead 

the DSEIS conflates these impact categories, 

which results in the improper attribution of some 

cumulative impacts to the GMT2 project itself. For 

example, in Section 4.4.2.1, Impacts Common to 

All Alternatives, the DSEIS states, “the [annual ice 

road that connects Nuiqsut to the Dalton Highway] 

facilitates the importation of alcohol and other 

drugs to Nuiqsut and other North Slope 

communities.”45 Since the annual ice road exists 

and will continue to exist with or without GMT2, 

the impact of the road is not a GMT2 impact. 

Other examples include the DSEIS’s discussions 

about economic disparity,46 the pace of 

development,47 and the frequency and nature of 

meetings related to permitting.48 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

BLM has reviewed the sociocultural impacts section, 

and has revised text to ensure that those aspects of the 

discussion that should be included in the cumulative 

section are addressed there, and not in the direct or 

indirect impacts resulting from the proposed action and 

alternatives.
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Comments Comment 

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Comment Response

L88-129 ConocoPhillips 

Alaska, Inc.

As an initial matter, the DSEIS substantively 

addresses the key elements for analyzing the 

potential climate change-related effects of the 

GMT2 project. However, it would be helpful for 

Section 4.2.4 to include an introductory section 

that provides an overview of the relevant issues 

and the approach and methodologies used by 

BLM to evaluate potential climate change-related 

effects. An example of one such introduction can 

be found in Section 3.26 of the recently issued 

final EIS for the Donlin Gold Project.49 

3.7 Climate 

Change

The Donlin EIS includes a description of how climate 

change will impact the resources of the project area, 

which can be found in the GMT2 Final SEIS in Section 

3.2.4, Climate Change. A description of the 

methodology used to evaluate the alternatives' 

contributions to climate change can be found in Section 

4.2.4.1, Methodology.

L88-13 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment A. 

The statement, “The percentage of adults 

reporting very good to excellent health was lower 

in Nuiqsut (39 percent) than it was statewide (56 

percent)” is misleading. The statement should 

note that 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%). This is from North 

Slope Borough (2012). 

3.18 Public 

Health

NSB 2012 citation and information added to 3.4.7.1
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Comment Response

L88-130 ConocoPhillips 

Alaska, Inc.

The DSEIS reasonably uses the amount of 

downstream GHG emissions as a proxy for the 

potential indirect effects of the project.50 CPAI 

recommends that, as a precaution, BLM include a 

more detailed explanation of the significance (if 

any) of the additional 2.14 mmt produced by the 

action alternatives compared to the no-action 

alternative.51 Such an explanation could address 

the context in which the production of 2.14 mmt is 

relevant, such as how it compares to overall 

carbon production from the State of Alaska.52 

The additional 2.14 mmt of CO2e that the action 

alternatives produce over the 30-year life of the 

project, compared to the no-action alternative, 

represents roughly 0.23% of the industrial CO2e 

emissions for the entire State of Alaska over 30 

years (anthropogenic and non-transportation 

sources). It also represents only 0.001% of the 

national GHG emissions and 0.0003% of the 

global GHG emissions.53 Consequently, the 

additional 2.14 mmt of CO2e produced by the 

action alternatives, compared to the no-action 

alternative, is, at most, negligible.

3.7 Climate 

Change

The text of the SEIS has been updated to include a 

comparison of GMT2 to regional, statewide and 

national production estimates through GMT2's peak 

production (2027). See section 4.2.4, Climate Change. 
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L88-131 ConocoPhillips 

Alaska, Inc.

Accordingly, as a precautionary matter, CPAI 

provides the following comments for BLM’s 

consideration and potential inclusion in the FSEIS 

regarding the MarketSim analysis: 

• MarketSim creates predictions by utilizing data 

produced by a modified version of the Energy 

Information Administration’s (EIA) National 

Energy Modeling System (NEMS) Annual 

Energy Outlook (AEO). The MarketSim model’s 

strong reliance on the peer-reviewed NEMS 

AEO model supports BLM’s choice to use the 

MarketSim model.

• We suggest that BLM consider running the 

MarketSim model with the NEMS AEO 2017 

projections, rather than the 2016 projections. 

BLM should also clarify the information 

presented in Appendix H, which references the 

2015 MarketSim model, rather than the 2017 

MarketSim model.

• Projected production from the GMT2 project is 

already taken into account in both the BOEMmodified AEO 2016 and EIA’s AEO 2017 and, 

accordingly, BLM’s evaluation of the action 

alternatives essentially double-counts the 

assumed production from GMT2. Nevertheless, 

the modeled results do not appear sensitive to 

this issue because Alaska represents only a 

small portion of the global energy market 

(approximately 0.5% on a daily basis), and the 

modeled results are more sensitive to the 

relative simulated changes in demand rather 

than baseline estimates.

3.7 Climate 

Change

Bullet 1 -Thank you for your comment. BLM is in the 

process of modifying the MarketSim for their own 

purposes which will allow for additional analyses like 

this one, tailored for the onshore, and expanded to 

include coal. 

Bullet 2 - Updated for 2018 AEO 

Bullet 3 - BLM received a comment on the application 

of BOEM’s MarketSim to the BLM data as the baseline 

AEO data in the MarketSim assumes new onshore 

leasing the model would already occur 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 leasing from 

2019 forward. As such, any double counting of the 

additional onshore production is accounted for by the 

underestimation of new offshore oil and gas leasing. 

Bullet 4 -The limitations of static emissions is 

addressed in Appendix H (see Assumption 2 in Section 

7 Key Assumptions). 

Bullet 5 - Oil is a global commodity and the impact of 

any one particular project is limited. 
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L88-131

Continued

ConocoPhillips 

Alaska, Inc.

• The emission factors considered in the 

MarketSim model are high-level resource-wide 

estimates based on current or recent operating 

conditions, markets, and technologies. 

Therefore, those emission factors do not 

account for improving control technologies and 

equipment or changing energy mix, policies, and 

use over time, which will change the carbon 

intensity of the production and consumption of 

those resources. Because these changes will 

likely make activities less carbon intensive over 

time, the MarketSim model may overestimate 

the indirect GHG emissions from the GMT2

• Generally, the record should reflect that the 

MarketSim model’s conclusions are not 

particularly sensitive to assumptions given that 

Alaska represents a very small portion of the 

global energy market and that the GMT2 project 

would represent an even smaller fraction of the 

global energy market as it would only amount to 

approximately 5% of Alaska oil production.

3.7 Climate 

Change

See above BLM response

L88-132 ConocoPhillips 

Alaska, Inc.

We recommend that the GMT2 SEIS expressly 

incorporate the climate change-related analyses 

in the IAP EIS by reference, including Appendix 

C. 

3.7 Climate 

Change

The Draft Supplemental EIS provides a summary of 

previous analyses included in prior documents. The full 

context of analyses in such documents is being 

incorporated by reference into the Draft Supplemental 

EIA. Incorporation by reference is used to ensure 

relevant information and analyses is disclosed and 

considered for decision making, but without duplicating 

content.
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Comment Response

L88-133 ConocoPhillips 

Alaska, Inc.

Additionally, although the DSEIS addresses the 

effects of climate change on the project study 

area, an evaluation of the potential effects of 

climate change on the project features, such as 

the planned infrastructure, is not readily apparent. 

We request that the FSEIS include a clear 

discussion of these potential effects. Finally, the 

FSEIS should address potential climate changerelated effects in its discussions of the potential 

effects of the project on specific resources and in 

the cumulative impacts section. The Donlin Gold 

Project FSEIS referenced above provides a good 

example of this approach. 

3.7 Climate 

Change

See Section 3.2.4, Climate Change. 

L88-134 ConocoPhillips 

Alaska, Inc.

Table 4.1-2 on page 238 of the DSEIS is a 

summary of impact levels for physical and 

biological resources. The climate change impacts 

are summarized as “N/A, see Section 4.2.4.” We 

urge BLM to either follow impact criteria of 

Section 4.1.2 using the levels identified in Section 

4.1.3, and conclude that the climate change 

impacts are, as the best available information 

demonstrates, “negligible”; or expressly adopt and 

explain other criteria and impacts levels that are 

suitable for climate change analysis, and use 

those terms. While we do not see this as a 

substantive issue, we believe that failure to apply 

the stated criteria and make conclusions in terms 

of the adopted terminology creates at least a 

superficial discrepancy that might be incorrectly 

portrayed as a faulty analysis. 

3.7 Climate 

Change

The BLM found that the use of GMT2 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. 

Therefore, impact criteria has been removed in the 

Final SEIS for all resources.
Supplemental Environmental Impact Statement

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Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L88-135 ConocoPhillips 

Alaska, Inc.

BLM should similarly reconsider the rating for 

atmospheric environment in Table 4.1-2, or 

explain the rating in Sections 4.1.2-4.1.3. The 

same summary table, Table 4.1-2, summarizes 

the impacts for air quality (in the row for 

Atmospheric Environment) as “not significant.” 

CPAI agrees with that conclusion, but we are 

concerned that it creates confusion and could be 

a basis for objection to the analysis because “not 

significant” is not an impact level presented in 

Sections 4.1.2 and 4.1.3, where the framework for 

impact criteria and impacts levels are discussed. 

This discrepancy can be fixed by either changing 

the terminology to conform to Section 4.1.3 (e.g., 

find that the impacts are “negligible”) or adding 

the terms “not significant” to Section 4.1.3 and 

explaining the basis for it in Section 4.1.2. This 

issue is about consistent terminology and clear 

expression of analysis, not substantive 

conclusions. 

3.5 Air Quality & 

Meteorology

Based on other comments received, the impact criteria 

has been removed from the SEIS. All impacts are 

described and quantified as a percent of existing 

standards.

L88-136 ConocoPhillips 

Alaska, Inc.

Yellow-billed loons were at one point a candidate 

species for listing under the Endangered Species 

Act (ESA). Listing was found to be “not warranted” 

in 2014. In the DSEIS, BLM includes yellow-billed 

loons in the Chapter 3 description of the affected 

environment, specifically in Section 3.3.3.7, but 

not the Chapter 4 analysis of environmental 

consequences. While yellow-billed loons would 

not seem to fall within the scope of Section 4.3.5 

on ESA-listed species, for the purpose of 

completeness and clarity CPAI recommends that 

BLM address yellow-billed loons expressly, as a 

“special status species” in the Section 4.3.3 

discussion of impacts on birds. We are confident 

the GMT2 project poses no substantial risk to 

yellow-billed loons, and believe the FSEIS should

be clear on that point. 

3.10 Birds Thank you for your comment. Chapter 4 of the bird 

section does not specifically call out individual bird 

species but treats the potential consequences as 

covering all bird species. A paragraph has been added 

in Chapter 4 discussing the importance of nest site 

selection to yellow-billed loons and calls the species 

out as being of conservation concern.
Supplemental Environmental Impact Statement

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Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L88-137 ConocoPhillips 

Alaska, Inc.

The analysis of impacts on Steller’s eiders and 

polar bears in Section 4.3.5 appears to use 

different criteria for the two different species. 

BLM’s analyses and conclusions are wellreasoned and supported, but for purposes of 

ensuring a thorough analysis, we recommend that 

BLM explain the criteria used in the analyses, 

including an explanation of the reason why 

different criteria were used, if that is the case. 

This is primarily a matter of documentation rather 

than substance. 

3.13 Threatened 

and Endangered 

Species

Thank you for your comment. There was no analysis of 

impacts on Steller's eiders in section 4.3.5 as they are 

considered extremely unlikely to be found in the project 

study area. There is a difference in the criteria used 

between spectacled eiders and polar bears and that 

difference follows the same criteria as in GMT-1

L88-138 ConocoPhillips 

Alaska, Inc.

None of those stated uses of a soil survey has an 

apparent purpose for the GMT2 project. And the 

data on vegetation, landforms, and hydrology 

already exist in the form of the ITU mapping that 

has been performed to date for this area. CPAI 

estimates that this proposed requirement would 

add $100-$300 thousand in costs to GMT2, while 

providing no discernible benefit. Most significantly, 

from a project planning perspective, the proposed 

mitigation measures introduce a very real risk of 

delaying the project by a year. Assuming the 

survey must be conducted before laying gravel, 

which appears to be a sound assumption, a 

survey could not be performed in time after the 

ROD is issued. Since CPAI plans to begin laying 

gravel in January 2019, a soil survey requirement, 

which appears to serve no particular purpose, 

poses a serious risk of unnecessarily delaying the 

project for a year, with significant economic 

impacts. CPAI urges BLM to eliminate this 

proposed mitigation measure from further 

consideration. 

3.2 Soils &

Permafrost

The soil survey is required to assess long term impacts 

of the development. The impacts would include 

changes in active layer depth due to the development 

as well as impacts of dust on vegetation and active 

layer. This will help address changes due to increasing 

temperatures and to assign impacts of the development 

as separate impacts from the climate change impacts. 

This data will help inform future decisions and designs 

for arctic operations. Conducting the soil survey during 

the first summer after gravel placement would be 

acceptable to the BLM. 
Supplemental Environmental Impact Statement

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Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L88-14 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment A. 

In the second paragraph under Asthma, there is a 

reference to a 2003 study but this study has no 

citation. 

3.18 Public 

Health

Omitted from 3.4.7.1, no citation

L88-140 ConocoPhillips 

Alaska, Inc.

Proposed mitigation measures 2, 4, and 5 on 

DSEIS pages 449 to 451 are unnecessary. See 

ConocoPhillips Comment Letter, pages 19-20. 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

CEQ NEPA regulations and BLM's NEPA guidance 

requires that : In an EIS, all “relevant, reasonable 

mitigation measures that could improve the project are 

to be identified,” (see Question 19b, CEQ, Forty Most 

Asked Questions Concerning CEQ's NEPA 

Regulations, March 23, 1981).

L88-141 ConocoPhillips 

Alaska, Inc.

The impact finding for Atmospheric Environment 

was “not significant” because conservative 

modeling shows the GMT2 project will not 

threaten any health-based ambient air quality 

standards. Decades of ambient air quality 

measurements amply demonstrate this, and 

technological improvements in oilfield equipment 

will continue driving the impacts down. These 

realities obviate the need to impose new air 

quality requirements such as those listed under 

Best Management Practices and Best Available 

Control Technology on pages 289 and 290 of the 

DSEIS. 

3.5 Air Quality & 

Meteorology

All reasonable mitigation measures were included in 

the Final SEIS for consideration in the Record of 

Decision. 
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Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L88-142 ConocoPhillips 

Alaska, Inc.

Section 4.7 of the DSEIS, “Mitigation Measures 

and Monitoring,” does not include discussion of 

compensatory mitigation under the Clean Water 

Act Section 404 permitting program administered 

by the Department of the Army, Corps of 

Engineers. CPAI’s permit application, available 

online in the Corps’ Alaska District website, 

contains CPAI’s proposal to restore a degraded 

stream and road crossing in Nuiqsut, or to 

preserve threatened wetlands in the region, as 

mitigation for the wetlands impacts of the GMT2 

gravel fill. Ultimately, mitigation will be determined 

by the Corps, but the Corps’ process and current 

proposals should be acknowledged in the FSEIS 

to ensure a more comprehensive accounting of 

GMT2-specific project mitigation measures. 

4.2 Mitigation The applicant-proposed GMT2 Development Project 

Wetlands Mitigation Plan is included in the Final SEIS 

as Appendix R.
Supplemental Environmental Impact Statement

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Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L88-143 ConocoPhillips 

Alaska, Inc.

The NPR-A Impact Mitigation Grant Program is 

inaccurately described on pages 447 to 448 of the 

DSEIS, and BLM should fix the errors in the final 

document because the program is a very 

important part of the context in which NPR-A 

development must be considered and evaluated. 

The NPR-A Impact Mitigation Grant fund is 

inaccurately described as a State of Alaska 

program, not subject to federal influence, and 

extended to only “limited” categories of grants. 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Federal Legislation 42 U.S.C. Chapter 78, Sections 

6501-6508 directs the federal government to provide a 

percentage of revenue from the NPR-A to the State of 

Alaska. Specifically, Section 6506a, or former 6508, of 

the federal statute requires that 50 percent of the 

money received by the federal government from the 

“sales, rentals, bonuses, and royalties on leases 

issued...” be paid to the State of Alaska. In accordance 

with Section 6506a, or former 42 U.S.C. 6508, 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: Provided further, that in the 

allocation of such funds, the State shall give priority to 

use by subdivisions of the State most directly or 

severely impacted by development of oil and gas 

leased under this section.” The State of Alaska NPR-A 

Impact Mitigation Program is solely governed by the 

Alaska legislature, under state code AS 37.05.530 (a) 

and (b), and is a grant program managed and 

administered by the State of Alaska Department of 

Commerce, Community and Economic Development. 

L88-144 ConocoPhillips 

Alaska, Inc.

The DSEIS, at pages 175 and 176, inaccurately 

suggests that the City of Nuiqsut is not eligible for 

grants under the NPR-A Impact Mitigation Grant 

program. The grant database maintained by the 

Alaska Department of Commerce, Community, 

and Economic Development (DCCED) shows that 

the City of Nuiqsut was awarded grants every 

year from 2005 to 2017 with the exception of 

fiscal years 2015 and 2018. The two grants for FY 

2017 are still active and they have received 

$260,134 out of the total awarded of $410,000. 

These grants provide significant support for the 

City of Nuiqsut. 

3.16 Economy Revised and incorporated updated information for 

Section on "Local Economy: Community of Nuiqsut"
Supplemental Environmental Impact Statement

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Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L88-145 ConocoPhillips 

Alaska, Inc.

The DSEIS does not fully describe existing 

mitigation measures. The GMT2 administrative 

record should reflect all existing mitigation 

measures, however, because the existing 

measures provide a strong foundation for the 

conclusion that it is not necessary or even helpful 

to add additional layers of mitigation on top of 

what has been required, agreed, or volunteered in 

the past. 

4.2 Mitigation Existing mitigation including the NPR-A IAP ROD 

BMPs and Alpine Satellite Development Plan ROD 

requirements are included by reference. In addition, all 

existing mitigation that serve to reduce impacts are 

identified and discussed for each resource in Chapter 

4: Environmental Consequences. Mitigation required 

by other agencies is discussed in Section 4.4.5 

Subsistence. BLM NEPA Guidance and CEQ 

regulations for EIS analyses require that all relevant, 

reasonable mitigation measures that could improve the 

project are to be identified, even if they are outside the 

jurisdiction of the agency [40 CFR 1502.14(f), 40 CFR 

1502.16(h)]. Following this requirement, the BLM 

included and analyzed several new potential mitigation 

measures in the SEIS that are not already covered by 

existing mitigation. The final suite of new mitigation 

measures applicable to the GMT2 Project will be 

determined in the ROD.

L88-146 ConocoPhillips 

Alaska, Inc.

Although the DSEIS was complete at the time it 

was prepared, there is new information about the 

potential Willow development that should be 

included in the cumulative impacts analysis in the 

FSEIS for GMT2.

4.0 Cumulative 

Effects Projects 

and Methodology

Updated information about Willow was added to Table 

4.6-2 Past, Present and Reasonable Foreseeable 

Future Developments. 

L88-147 ConocoPhillips 

Alaska, Inc.

Under the circumstances, it bears stating here 

that GMT2 and the Willow development project 

each have independent utility and, accordingly, 

are not “connected actions.”

4.0 Cumulative 

Effects Projects 

and Methodology

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 project has independent utility from GMT2 

and is not considered a connected action under NEPA. 

The Willow find is sufficiently large that even in the 

absence of a road connection between GMT2 and 

GMT1, the Willow project could be developed 

roadlessly similar to the Alpine field. 
Supplemental Environmental Impact Statement

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Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L88-148 ConocoPhillips 

Alaska, Inc.

In 2018, CPAI not only appraised the potential 

Willow development, but also drilled exploration 

wells at West Willow, Putu, and Stony Hill. Each 

of the exploration wells encountered oil and 

verified the. potential of the play.71 This recent 

information should be incorporated into the 

FSEIS. 

4.0 Cumulative 

Effects Projects 

and Methodology

The FEIS was updated to incorporate this recent 

information. 

L88-15 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment A. 

The statement, “recent research into the 

transportation of pollution nanoparticles (not 

regulated by EPA) from oil and gas activities in 

Prudhoe Bay (Kolesar et al. 2017) indicates that 

there are potentially forms of pollution that are not 

currently monitored in Nuiqsut” is inappropriate 

and should be removed. There are neither 

standards for “nanoparticles” nor reference 

methods to monitor them. The unsupported 

implication this statement conveys is that there 

are unmonitored pollutants in the village impacting 

health; there is no support whatsoever for this. 

Finally, inclusion of statements like this opens up 

the analysis to any class of matter, whether 

recognized as pollution or not.

3.18 Public 

Health

Omitted.

L88-16 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment A. 

In the second paragraph under Food Security, 

there is a reference to Table ##. There should be 

a number, of course, but we also could not locate 

that table. 

3.18 Public 

Health

Corrected: The SEIS now references Table 5 from 

Appendix G

L88-17 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment A. 

Incorrect reference to waste being injected into a 

Ukpeagvik Inupiat Corporation facility; UIC stands 

for Underground Injection Control well. 

3.4 Water 

Resources

Correction was made as suggested
Supplemental Environmental Impact Statement

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

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Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L88-18 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment A. 

The footnote beneath each of these tables is 

confusing and lacks context. We recommend it 

either be explained better in the paragraphs 

referencing the tables or that it be removed 

altogether. 

3.5 Air Quality & 

Meteorology

Based on the reviewer's comment, the note below each 

of the referenced tables has been removed. The 

clarification these notes intended to give is explained in 

detail in the AQIA.
Supplemental Environmental Impact Statement

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Name

Comments Comment 

Category Code

Comment Response

L88-19 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment A. 

BLM lists a number of “Best Management 

Practices” and “Best Available Control 

Technology” measures meant to minimize air 

emissions. ConocoPhillips’ project design will 

employ many of these but the document must be 

clear that these cannot be considered 

requirements. For example, the project’s base 

design is to operate the drill site on grid power but 

there will be times when that power is unavailable 

so the flexibility for on-site power generation must 

be maintained. Related to fugitive dust control, 

ConocoPhillips will employ speed limits but 20 

mph, as suggested by the DSEIS, is too low to be 

practicable. In a transmittal to BLM in November 

2017, ConocoPhillips identified 35 mph as a 

speed control measure that represents best 

management practice. In addition, watering will be 

employed during the months when fugitive dust 

from roads may be an issue (June-September). It 

is unnecessary to translate modeling assumptions 

into requirements or limits as the modeling was 

conservative and real-time ambient air 

measurements show that fugitive dust is not an 

issue around North Slope roads. For leak 

detection and repair and the items under “Best 

Available Control Technology”, ConocoPhillips will 

comply with EPA’s New Source Performance 

Standards which do impose stringent control 

technologies. Finally, no new ambient air 

monitoring requirements should be imposed as 

the ambient air quality is adequately measured at 

Nuiqsut and CD5. 

3.5 Air Quality & 

Meteorology

All reasonable mitigation measures proposed by BLM 

subject matter experts or members of the public were 

included in the Final SEIS for consideration in the 

Record of Decision. 
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Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L88-20 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment A. 

Correction - gravel depth of 5 feet is required to 

keep active layer "frozen" all-year. Frozen 

materials resist compression. In addition, this 

section should mention that temporary trenching 

(about 400 square feet) will be required to allow 

the power and fiber optic cables to cross the 

existing gravel access roads. 

3.8 Vegetation 

and Wetlands

Text updated to add information about trenching. 

L88-21 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment A. 

BLM considers the GMT2 project impacts for 

gravel mining as the entire Phase 3 expansion of 

the ASRC pit (465.3 acres), while the GMT2 

project will only utilize ~35 acres of the total 

Phase 3 expansion. BLM must confine the 

assessment to just the 35 acres of the total 

expansion. 

3.8 Vegetation 

and Wetlands

Text has been revised to reflect 35 acres.

L88-22 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment A. 

Inappropriate literature citation: The paper cited -

Felix and Raynolds 1989 - refers entirely to 

seismic trails in ANWR from 1984 and 1985. The 

results in that paper do not apply to seasonal ice 

infrastructure considering the methods used today 

are different. 

3.8 Vegetation 

and Wetlands

Citation to Felix and Reynolds 1989 "Landscape 

function and Disturbance in Arctic Tundra" has been 

corrected. Replaced Yokel with Guyer et. el 2005 full 

citations found under 4.1.1 conclusion

L88-23 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment A. 

"Drilling activities would not have specific impacts 

to wetlands and vegetation different than those 

discussed for construction." Since construction 

would involve impact from gravel fill while drilling 

activities would not, this is a confusing statement. 

Drilling impacts on vegetation and wetlands 

would, in fact, be negligible. 

3.8 Vegetation 

and Wetlands

Paragraph has been rewritten.

L88-24 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment A. 

Recommend revising first sentence by deleting 

"(100 meters)". One hundred meters are equal to 

328 feet rather than 300 feet. 

3.8 Vegetation 

and Wetlands

Edit has been made to read 328 feet (100 meters)
Supplemental Environmental Impact Statement

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Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L88-25 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment A. 

This section states that Alternative A would 

directly impact 77.9 acres of vegetation. The total 

impact to vegetation by Alternative A is 78.1 acres

(77.9 to waters of the US and 0.2 to uplands).

3.8 Vegetation 

and Wetlands

Paragraph has been rewritten.

L88-26 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment A. 

"All areas of direct and indirect impacts from 

Alternative A are within potential wetlands" is 

incorrect. 0.2 acres of direct and 2.4-acres 

Indirect impacts occur in non-Jurisdictional 

uplands.

3.8 Vegetation 

and Wetlands

Paragraph has been rewritten.

L88-27 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment A. 

Recommend revising third sentence to reference 

Alternative B, not Alternative A.

3.8 Vegetation 

and Wetlands

Corrected.

L88-28 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment A. 

BLM restates that the GMT2 project would impact 

the entire ASRC Pit Expansion. Evaluation 

should only be for the ~35 acres of GMT2 portion 

of ASRC Pit 

3.8 Vegetation 

and Wetlands

Agree, edits have be made.

L88-29 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment A 

"Under all action alternatives, gravel placement 

would cover between 0.0 and 74.4 acres of each 

of five vegetation/wetland types." The range 

according to Table 4.3-2 is 0 to 92 acres 

3.8 Vegetation 

and Wetlands

Corrected to indicate 92.0 acres

L88-30 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment A. 

"These results may be additive, although at least 

one study as suggested otherwise (Yokel et al 

2007)." BLM offers no other citation to suggest 

that they are additive, and the Yokel paper 

indicates that year after year ice structures aren't 

additive. As such, the statement departs from 

available evidence and should be corrected. 

3.8 Vegetation 

and Wetlands

The sentence has been deleted from the document.
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Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L88-31 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment A. 

A list of the Applicant provided design features 

and activities intended to minimize impacts from 

the project should be included in the DSEIS and 

referenced in Section 4.3.1. These minimization 

measures are contained in the USACE 404 permit 

application and include maximized use of existing 

infrastructure such as VSMs and the use of ice 

pads for wintertime drilling activities. 

3.8 Vegetation 

and Wetlands

Added paragraphs from 404 permit application to 

mitigation section 4.1.1.5

L88-32 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment A. 

In the Potential column, "Exposure of bare 

substrate and decreased vigor of associated 

vegetation around water sources if complete 

recharge does not occur", and "Changes in 

chemical composition of tundra by discharges of 

treated domestic wastewater..." are not discussed 

in Chapter 4. The text should contain a discussion 

of these potential impacts if they are to be 

included in the table. 

3.8 Vegetation 

and Wetlands

Agree, edits have be made.

L88-33 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment A. 

Recommend deleting the last two sentences or 

provide an analysis of impacts to “edge-effects” to 

provide context for the reader. 

3.8 Vegetation 

and Wetlands

Sentences have been deleted as indicated.

L88-34 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment A. 

When listing BMPs, BLM should write out the 

entire BMP because, in some cases (such as 

BMP B-1), exceptions are allowed. As worded, 

the abbreviated BMPs in the DSEIS can be 

interpreted as more restrictive than the underlying 

full text of the BMP in the IAP. 

3.9 Fish Text updated to direct the reader to full descriptions of 

the BMP's and explain that deviations can be granted. 
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Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L88-35 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment A. 

The USGS recently released a study of greater 

white-fronted geese and nesting productivity 

during industrial cleanup of the Pt. Lonely site 

which found that birds are not as disturbed by 

DC6 and helicopter activity as this paragraph 

indicates. They hunkered down versus leaving the 

nest, thus not affecting productivity. 

https://www.alaskapublic.org/2018/02/28/whatcan-geese-teach-us-about-the-future-of-arcticdevelopment/. 

3.10 Birds Thank you for your comment. Text has been added in 

chapter 4 of the bird section to include the Meixell and 

Flint 2017 study results.

L88-36 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment A. 

Last sentence of paragraph "...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." As 

mentioned above, Yokel et al (2007) states that 

year after year ice structures are NOT additive. 

3.10 Birds Thank you for your comment. Text has been added in 

chapter 4 comparison of alternative section within the 

bird section to include this information.

L88-37 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment A. 

Inappropriate literature citation: Tyler (1991) was 

a study of Svalbard reindeer wherein snowmobile 

drivers were instructed to intentionally search out 

groups of reindeer. Upon spotting them, reindeer 

groups were intentionally provoked by driving one 

snowmobile slowly (20km/hr) until reaching the 

spot where the animals had been - dropping 

sticks along the way when the caribou showed 

any visible reaction, then again when any member 

of the caribou group showed unease or alarm, 

and again when the group fled. These distances 

were measured and analyzed. This study isn’t 

analogous to what occurs in the oil field –

snowmachines are used infrequently and typically 

only in the beginning of the winter season and are 

not intentionally driven towards mammals. 

3.11 Caribou Thank you for your comment. Tyler (1991) conducted 

a study of reindeer to quantify distances in which 

reindeer groups exhibit certain behaviors to 

approaching vehicles. This study is relevant to the 

SEIS with regards to the potential of increased hunting 

pressure from new gravel roads. Even though 

snowmobiles are used infrequently in the oil field, 

hunters commonly use all terrain vehicles to access 

hunting areas. The expected disturbance to caribou, 

whether from a snowmobile or all terrain vehicle would 

be similar. 
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Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L88-38 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment A. 

A Table 4.4-1 is referenced but no such table 

could be located in the DSEIS.

3.14 Cultural and 

Paleontological 

Resources

This was a typo where the in text reference to the table 

was not linked to the table it was referencing. This has 

been fixed.

L88-39 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment A. 

We believe it important to add to this 

transportation benefits discussion the fact that 

ConocoPhillips allows Nuiqsut residents to park 

vehicles at Oliktok Point which is connected to the 

road system. Thus, during summer months, 

people can use boat transportation to get to 

Oliktok Point and have access to the Dalton 

Highway and urban centers during that period as 

well. 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Text has been added to add the beneficial use of 

Oliktok Point by Nuiqsut residents due to permission 

from ConocoPhillips. 

L88-40 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment A. 

References to Kuukpik Corporations lack of 

support for exploratory drilling at the Putu 1 well 

should be updated because Kuukpik ultimately did 

support the drilling at Putu 1. 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Text been revised regarding support of the Kuukpik 

Corporation to drill the Putu well. 

L88-41 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment A. 

The listing of Potential New Mitigation Measures, 

measures the BLM "lacks the authority to require 

implementation of", should be removed from the 

document. 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

CEQ NEPA regulations and BLM's NEPA guidance 

requires that : In an EIS, all “relevant, reasonable 

mitigation measures that could improve the project are 

to be identified,” even if they are outside the jurisdiction 

of the agency (see Question 19b, CEQ, Forty Most 

Asked Questions Concerning CEQ's NEPA 

Regulations, March 23, 1981).

L88-42 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment A. 

Reference to GMT1 should be changed to GMT2. 

GMT1 is already rezoned.

3.17 Land Use Corrected.

L88-43 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment A. 

In the first paragraph under Comparison of 

Alternatives there is a reference to “Arctic Slope 

Regional Corporation-selected” land. Should this 

read Kuukpik-selected land instead? 

3.17 Land Use Corrected.
Supplemental Environmental Impact Statement

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

219

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L88-44 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment A. 

Detailing this review process is unnecessary and 

confusing. ConocoPhillips commissions work to 

produce scientific information among many 

contractors, including others who contributed to 

the DSEIS (e.g., ambient air quality data), but 

those data review processes aren’t detailed. We 

are not sure why it is in this case and believe the 

information should be removed. 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

A complete explanation of the methodology for the 

Nuiqsut Caribou Subsistence Monitoring Reports was 

requested by internal DOI reviewers of the preliminary 

Draft SEIS. The review process is a critical aspect of 

any study's methodology. Other stakeholders have also 

commented on it, and BLM has added language to the 

mitigation measure that requires continued monitoring 

of subsistence harvests (established with GMT1 ROD 

and carried over for GMT2) to clarify that BLM and 

Nuiqsut stakeholders will approve of the methodology 

of the monitoring studies. 

L88-45 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment A. 

Mistake - In the first sentence Figure 3.4-6 is 

cited, but reference should be to Figure 3.4-7

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Figure reference has been corrected.

L88-46 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment A. 

Reference to table 2.9-1 should be 2.9-3

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Table reference has been corrected.

L88-47 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment A. 

First sentence "The amount of aircraft activity in 

the Nuiqsut area far exceeds amounts in other 

communities." We believe a statement this 

declarative requires a citation. 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

The text states "The amount of aircraft activity in the 

Nuiqsut area far exceeds amounts in these other 

communities" (emphasis added), and is comparing 

Nuiqsut to three other communities on the North Slope. 

Citation has been added to reference BLM's permitted 

activities spreadsheet that is posted online and details 

aircraft use in the NPR-A. 

L88-48 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment A. 

Last bullet- 270 new fixed-wing flights is the 

annual number. Text should be added to make 

this clear. 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Text has been revised to include 270 annual fixed 

wings flights to the Air Traffic discussion.
Supplemental Environmental Impact Statement

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

220

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L88-49 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment A. 

Under Stipulations and Best Management 

Practices on Avoiding Conflict, there is a 

reference to an Integrated Activity Plan best 

management practice (BMP) regarding setbacks. 

The reference states, “these stipulations are 

intended to prohibit permanent oil and gas 

facilities...within the buffer zone.” This language 

does not reflect the full text of the referenced BMP 

(K-1) which allows for a process to approve 

essential pipeline and road crossings through the 

setbacks. The language should be updated to 

capture the full text of the BMP. 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Text has been revised to include the full text of the 

BMP.

L88-50 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment A. 

This misleading statement is in the text: “In the 

past few years, relatively minor blowouts have 

occurred at oil exploration and development sites 

on the North Slope, including one fairly close to 

Nuiqsut.” The text should be modified to hew 

more closely to the fact that there has been one 

blowout at an exploration site that we are aware 

of in the history of Western North Slope oil and 

gas industry operations.

3.18 Public 

Health

Addressed: text edited to "In 2012, one minor blowout 

occurred at an oil exploration site on the North Slope, 

approximately 18 miles northeast of Nuiqsut."
Supplemental Environmental Impact Statement

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

221

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L88-51 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment A. 

The DSEIS text includes this statement: “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. An 

example of this occurred during the spring of 2015 

when high water on the Colville River during 

break-up threatened development sites in the 

Colville Delta, resulting in the temporary 

evacuation of staff from the CD4 satellite site to 

the Alpine Central Processing Facility.” The 

example cited is not an example of an industrial 

disaster. The CD4 road was overtopped and the 

crew on the pad needed to get to CD5 so they 

could perform work onsite at CD5. They were thus 

merely relocated to the Alpine camp to effect this.

3.18 Public 

Health

Reference to topover is omitted.

L88-52 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment A. 

The Kuukpik pad should also be listed as a 

location where construction crews will be housed.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Text has been revised to include Kuukpik Pad.

L88-53 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment A. 

There is no reference for "Alaska Clean Seas 

2015", cited on page 56. This should refer to the 

Alaska Clean Seas Technical Manual. 

6.1 References Reference has been added.

L88-54 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment A. 

Page 483 Section 4.5.2.2 refers to the 

"ConocoPhillips Oil Discharge Prevention and 

Contingency Plan for the Alpine Development 

Area (ConocoPhillips 2013). There is not a 

reference provided for this citation.

6.1 References This reference has been updated to reflect the most 

recent plan "ConocoPhillips Alpine Field and Satellites 

and Alpine Pipeline System Oil Discharge Prevention 

and Contingency Plan (ODPCP)" (ConocoPhillips 

2018).
Supplemental Environmental Impact Statement

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

222

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L88-55 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment A. 

The reference "ConocoPhillips 2014d" does not 

seem to appear in the document.

6.1 References Reference has been deleted.

L88-56 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment A. 

We could not locate a Map 4.3-1 which is 

referenced at the top of page 315 of Volume 1

5.1 Maps and 

GIS Data

Omission of the map from the DEIS was an oversight. 

Thank you for alerting us that the map was missing, it is 

included in the FEIS.

L88-57 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment A. 

Under “Otter/CASA Flights into CD1/APF” there 

appears to be a numerical error. Construction 

(Year 1-2) flights should be 1,981. “Total Flights” 

for this row should be 3,112.

2.1 Proposed 

Action & 

Alternatives

Accepted, changed in document.

L88-58 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment A. 

The entries on this table do not appear consistent 

with the entries in Appendix b so should be 

checked. 

2.1 Proposed 

Action & 

Alternatives

Accepted, changed in document.

L88-59 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment A. 

Drilling for Alternative C is listed to begin in May 

of year 2 with first oil expected at the end of year 

two. To be consistent with section 2.4.1 and Table 

2-9.1, this should state drilling will begin in May of 

year 3 with first oil expected at the end of year 3. 

Delete references to 2020. 

2.1 Proposed 

Action & 

Alternatives

Accepted, changed in document.

L88-60 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment A. 

Drilling for Alternative C is listed to begin in May 

of year 2 with first oil expected at the end of year 

two. To be consistent with section 2.4.1 and Table 

2-9.1, this should state drilling will begin in May of 

year 3 with first oil expected at the end of year 3. 

Delete references to 2020. 

2.1 Proposed 

Action & 

Alternatives

Accepted, changed in document.

L88-61 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment A. 

should say "construction, fixed-wing aircraft 

trips..."

2.1 Proposed 

Action & 

Alternatives

Accepted, changed in document.
Supplemental Environmental Impact Statement

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

223

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L88-62 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment A. 

Clarify that “Year 1-2” refers to Nov of Year 1 

through Oct of Year 2. 

Clarify that “Year 2-3” refers to Nov of year 2 

through Dec of year 3 (a 14-month period) Clarify 

that “Drilling (Years 4-10)” represents Jan of Year 

4 through April of Year 10. 

Clarify that “Annual Operations/Post Drilling” 

represents May of year 10 through Dec of year 

32. This information, with the monthly totals, will 

allow reader to understand the calculations, 

otherwise, the calculations are very confusing. 

2.1 Proposed 

Action & 

Alternatives

Accepted, changed in document.

L88-63 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment A. 

should say "construction, fixed-wing aircraft trips 

are limited to between 5 and 15...

2.1 Proposed 

Action & 

Alternatives

Accepted, changed in document.

L88-64 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment A. 

The 2-acre operations ice pad to be constructed 

each year until the end of the 30-year design life 

of the project, as described in the Section 404 

permit application, is not described in description 

of ice roads and pads for Alternative A. Water use 

to support ice pad construction is included in the 

water use tables provided in Appendix B. 

Recommend clarifying use of 2-acre operations 

ice pad for all action alternatives. See MNAD, 

March 2016, Appendix C. 

2.1 Proposed 

Action & 

Alternatives

Accepted, changed in document.

L88-65 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment A. 

“Construction is expected to take 2 years...” 

should be changed to “Construction will take 

either two or three years...” 

2.1 Proposed 

Action & 

Alternatives

Accepted, changed in document.
Supplemental Environmental Impact Statement

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

224

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L88-66 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment A. 

The pipeline-road crossing for pipelines is not 

"underground", which implies the pipeline is 

buried below-grade. 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. 

2.1 Proposed 

Action & 

Alternatives

Text now reads "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."

L88-67 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment A. 

Alaska Clean Seas provides spill response 

training to the North Slope Spill Response Team 

weekly, not just "annually"; weekly is significantly 

more frequent than "annual". 

2.1 Proposed 

Action & 

Alternatives

Accepted, changed in document.

L88-68 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment A. 

Incorrect regulatory reference: an oil discharge 

prevention and contingency plan complies with 

State of Alaska requirements in AS 46.04.030(b) 

[not "46.04.030(10)(A)", which is a non-existent 

regulation]. 

2.1 Proposed 

Action & 

Alternatives

Accepted, changed in document.

L88-69 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment A. 

Gravel for GMT1 came from a 25-acre parcel in 

phase 3 of the ASRC mine site. It was permitted 

for 45. 

2.1 Proposed 

Action & 

Alternatives

Accepted, changed in document.

L88-70 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment A. 

Ice roads will be used to support every year of 

construction, whether two years or three years. 

This section should make that clear. 

2.1 Proposed 

Action & 

Alternatives

Accepted, changed in document.
Supplemental Environmental Impact Statement

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

225

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L88-71 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment A. 

We appreciate that BLM included both 

construction schedules in these sections (twoyear construction schedule and three-year 

construction schedule). We request that the 

schedules be presented as options that, at the 

discretion of ConocoPhillips, are available as a 

result of the analyses performed in the DSEIS. To 

this end, we also request that the resource impact 

analyses include reference to each schedule and 

that, where they exist, differing impacts because 

of construction schedule (whether two-year or 

three-year) be disclosed. 

2.1 Proposed 

Action & 

Alternatives

Text has been added to those resource sections where 

a potential effect difference due to the 2- or 3-year 

schedule could occur. 

L88-72 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment A. 

"extended-reach drilling is still not technically 

feasible for the GMT2 Project." This appears to be 

a holdover from the GMT1 DSEIS. Since COPA is 

now building an extendable reach drilling (ERD) 

rig, this is not an entirely accurate statement. ERD 

is still evolving and allows reaching more from 

single pad but ERD would not be used to 

determine pad location. 

2.1 Proposed 

Action & 

Alternatives

Text was reviewed and updated to provide clarification 

with regard to the alternative that was eliminated from 

further review due to the technical infeasibility of 

extended reach drilling.

L88-73 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment A. 

There are three 0.4 acre pull-outs for a total of 1.2 

acres. Table 2.1-1 incorrectly states there are 

three 1.2 acre pull-outs in the column titled “2015 

GMT2 Project Proposed by ConocoPhillips”. 

2.1 Proposed 

Action & 

Alternatives

Accepted, changed in document.

L88-74 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment A. 

No off-lease disposal of produced water will be 

sought. Produced water is injected back into 

reservoirs for secondary recovery, not into 

disposal wells. 

1.1 Executive 

Summary & 

Introduction

Reference to off-lease disposal of produced water has 

been removed.
Supplemental Environmental Impact Statement

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

226

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L88-75 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment A. 

the term should be "spill prevention, control, and 

countermeasure plan" ("control" not 

"containment") and the regulations have been 

amended to apply to "oil storage containers with 

capacity 55 gallons or greater for facilities with 

over 1,320 gallons in aggregate oil storage 

container capacity". Reference to "660 gallons" is 

outdated and the requirement applies to all 

petroleum hydrocarbons (oils) not just fuel. 

1.1 Executive 

Summary & 

Introduction

Text has been revised to update regulatory language.

L88-76 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment A. 

Mineral Leasing Act...there is no ROW required 

for GMT2

1.1 Executive 

Summary & 

Introduction

Text has been revised to remove reference to a MLA 

Right-of-Way.

L88-77 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment A. 

"National"...misspelled word. Should be "notional 

participation areas". Also, there are no notional 

PA's noted on Map 1.1-1 

1.1 Executive 

Summary & 

Introduction

Text has been revised to "notional." The legend in Map 

1.1-1 for the FEIS will be updated and incorporate 

notional participation areas to be consistent with text in 

the document.

L88-78 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment A. 

AA-081798 is the GMT1 lease location, not 

GMT2. GMT2 pad is on AA-081800. This is 

evident on Map 1.1-1. 

1.1 Executive 

Summary & 

Introduction

Reference to the lease on which GMT2 is located has 

been corrected.

L88-79 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips Attachment B. Update Sheet 

22 of Appendix A

2.1 Proposed 

Action & 

Alternatives

Accepted, changed in document.

L88-80 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment C, 

Additional Subsistence Information

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Text has been revised to include information from 

Attachment C of ConocoPhillips Comment Letter.

L88-81 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment D, 

Updated Alt A and B Inundation Analysis

3.4 Water 

Resources

Edits were made to Tables 4.2-4 to 4.2-7 and all 

referrals to this table and the snowmelt runoff periods.

L88-85 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment F, 

NPR-A Impact Mitigation Program Annual Report

3.16 Economy Revised to reflect changing conditions since the 

development of the draft SEIS
Supplemental Environmental Impact Statement

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227

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L88-86 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment B0. Map 1.1-1 update to include new unit 

boundaries

5.1 Maps and 

GIS Data

Map 1.1-1 was updated for the FEIS to include recent 

boundary changes to the Greater Mooses Tooth Oil & 

Gas Unit.

L88-87 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment B0. third line - remove "In the GMT Unit" and 

replace with "For the GMT2 Project” since 

development

drilling is occurring at the GMT1 pad.

1.1 Executive 

Summary & 

Introduction

The text has been revised as suggested.

L88-88 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment B0. Alternative A & B designs have been updated. 

The latest design now includes a sand handling 

module.

2.1 Proposed 

Action & 

Alternatives

Accepted, changed in document.

L88-89 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment B0. Chemical storage with containment and truck 

loading will be included at GMT1 & GMT2 

(document shows only GMT1) 

2.1 Proposed 

Action & 

Alternatives

Accepted, changed in document.

L88-90 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment B0. The exact number of VSMs will be established 

based on final road alignment so it is more 

accurate to state “800 to 1,000 vertical support 

members will be required between GMT1 and 

GMT2, depending on final road alignment,...” 

rather than just 800. 

2.1 Proposed 

Action & 

Alternatives

Accepted, changed in document.

L88-91 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment B0. The latest design now includes a sand handling 

module. 

Chemical and weathered crude storage with 

containment and truck loading will be included at 

GMT1 & GMT2 (document shows only GMT1) 

2.1 Proposed 

Action & 

Alternatives

Accepted, changed in document.

L88-92 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment B0. 4th bullet: 6" miscible injection should be 8". 

Also, later in the sentence, it will connect to an 8" 

gas line (not 6"). 

2.1 Proposed 

Action & 

Alternatives

Accepted, changed in document.
Supplemental Environmental Impact Statement

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

228

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L88-93 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment B0. First sentence: the state approved oil discharge 

prevention and contingency plan was re-approved 

by the state for another 5 years, approved 

February 16, 2018. The title was updated to 

"Alpine Field and Satellites and Alpine Pipeline 

System Oil Discharge Prevention and 

Contingency Plan". 

2.1 Proposed 

Action & 

Alternatives

Accepted, changed in document.

L88-94 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment B0. Second sentence: Please include weathered 

crude in the list of fluids that may be stored on site 

at GMT2. Weathered crude may be used to 

freeze-protect the wells. 

2.1 Proposed 

Action & 

Alternatives

Accepted, changed in document.

L88-95 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment B0. The state approved oil discharge prevention 

and contingency plan was re-approved by the 

state for another 5 years, approved February 16, 

2018. The title was updated to "Alpine Field and 

Satellites and Alpine Pipeline System Oil 

Discharge Prevention and Contingency Plan". 

The word should be "Countermeasure", without 

an "s" at the end. 

2.1 Proposed 

Action & 

Alternatives

Accepted, changed in document.

L88-96 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment B0. The second two bullets in this section related to 

camps should be replaced with: Nuiqsut Hotel -

The Project will utilize existing beds at the 

commercial hotel as available to support the 

project.

Kuukpik Pad Camp –It would supply 370 -456 

beds for 120 days to support winter construction 

work (Year 1 to Year 3) and 175 beds for 245 

days to support summer activities in Year 1 to 

Year 3. 

2.1 Proposed 

Action & 

Alternatives

Accepted, changed in document.
Supplemental Environmental Impact Statement

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

229

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L88-97 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment B0. Lodging Requirements, Construction: update 

as described above.

2.1 Proposed 

Action & 

Alternatives

Accepted, changed in document.

L88-98 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment B0. The 2017 photocensus results are now 

available for all arctic herds and this should be 

cited as all of the

herds saw a growth in numbers.

3.11 Caribou Thank you for your comment. The BLM has updated 

the section 3.3.4, Population Dynamics section to 

showing results of the 2017 photocensus for TCH and 

CAH . The BLM updated figure 3.3-3 and requested 

permission from ADGF to add a figure showing TCH 

abundance estimates.

L88-99 ConocoPhillips 

Alaska, Inc.

See ConocoPhillips comment letter Attachment B0. The Alpine Field and Satellites and Alpine 

Pipeline System Oil Discharge Prevention and 

Contingency Plan was re-approved by the state 

on February 16, 2018. The re-approved plan has 

updated spill summary information.

3.19 Hazardous 

Materials Spills

Updated document name in text.
Supplemental Environmental Impact Statement

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Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L89-1 Wilderness 

Society, et.al.

BLM has failed to adequately analyze and 

quantify the potential impacts to subsistence and 

sociocultural systems. The dSEIS fails to include 

impact criteria and overall rankings that show the 

level of impact by alternative for the social system 

impacts, including impacts to subsistence. BLM 

provides no explanation for the arbitrary absence 

of impact criteria or analysis of the level of 

impacts by alternative for social impacts, which is 

concerning for several reasons.*2 As an initial 

matter, BLM has already developed specific 

impact criteria for nearly every social systems 

resource, and these criteria were well-vetted and 

subject to public comment in the GMT1 Final 

SEIS.*3 Given the similarities between GMT1 and 

GMT2, and the close timeframes for drafting the 

EIS’s, there is seemingly no reason that BLM 

should refuse to use these specific and relevant 

impact criteria in the dSEIS. 

*2The dSEIS makes statements which are, in fact, 

contrary to the approach BLM adopts in the social 

systems impacts analysis. “A resource specific 

description of the impact criteria is included in 

each section of this chapter.” Alpine Satellite 

Development Plan for the Proposed Greater 

Mooses Tooth 2 Development Project: Draft 

Supplemental Environmental Impact Statement 

235 (2018) [hereinafter GMT2 Draft SEIS] 

(emphasis added). BLM entirely fails to explain its 

reasoning for abandoning this resource-specific 

approach for an approach that favors no impact 

determinations whatsoever. 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

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 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.
Supplemental Environmental Impact Statement

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

231

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L89-1

Continued

Wilderness 

Society, et.al.

*3 See GMT1 Final EIS, Table 4.4-1 [Cultural 

Resources]; Table 4.4-3 [Economy]; Table 4.4-8 

[Land Use and Ownership]; Table 4.4-10 [Local 

Transportation]; Table 4.4-11 [Recreation]; Table 

4.4-12 [Visual Resources]; Table 4.4-13 

[Subsistence]. 

Further, BLM does not even apply the “general” 

impact criteria described in the GMT2 dSEIS 

Sections 4.1.2 and 4.1.3 to its conclusions for 

social system impacts. Absent resource- specific 

criteria, BLM should have referred to these 

sections to characterize what constitutes a 

significant impact for each resource. BLM’s failure 

to characterize impacts for social systems

makes it difficult to compare impacts between 

alternatives or synthesize information in a manner 

that is easy for the public to understand. It is 

particularly troubling that the analysis of impacts 

to social systems was singled out for such vague 

treatment in the dSEIS, given the proximity of the 

GMT2 project to the community of Nuiqsut. 

Impacts to subsistence, cultural resources, health, 

and the economy, are of the highest importance 

and interest to community members and other 

stakeholders. It is critical that BLM provide a 

meaningful analysis, conclusions for the levels of 

impacts, and a comparison between alternatives 

for social systems.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

See above for BLM response
Supplemental Environmental Impact Statement

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

232

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L89-10 Wilderness 

Society, et.al.

The mapping and other information included as 

part of the Section 810 analysis is also based on 

outdated information about subsistence use 

areas. The GMT2 project is laid out on top of 

subsistence data from 1995–2006. Elsewhere in 

the dSEIS, BLM states that “[f]uture research will 

reveal how harvesters respond when 

infrastructure is established closer to town or in 

their core hunting areas” and provides that 

“[a]voidance may be less of an option as fewer 

areas without development are present.” BLM 

already has information from existing studies and 

from the community showing that subsistence 

users have had to shift their activities in light of 

existing developments. It is not acceptable for 

BLM to state that avoidance problems will 

decrease in the future since the community will 

have no choice other than to hunt and fish around 

the infrastructure if they are surrounded by it. The 

Section 810 mapping and BLM’s overall analysis 

fail to account for shifts that have occurred to 

Nuiqsut’s subsistence use areas over time in light 

of development activities and infrastructure. As a 

result, these maps and BLM’s analysis do not 

adequately take into consideration how traditional 

subsistence use areas have been lost and how 

the GMT-2 project is likely to further deprive the

community of access to traditional subsistence 

use areas. 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

The Draft SEIS discloses both potential benefits and 

potential negative impacts of infrastructure and 

attempts to be succinct. Recent data on use of roads, 

gathered since the Draft SEIS was published, and 

verbatim testimony from hunters, has been included in 

the Final SEIS. The Draft SEIS did include updated 

discussions on avoidance, noting that 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. 
Supplemental Environmental Impact Statement

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

233

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L89-11 Wilderness 

Society, et.al.

BLM states in its assessment of the potential 

mitigation measures that federal agencies are not 

generally required to adopt mitigation measures. 

The dSEIS also states that BLM lacks the ability 

to eliminate negative sociocultural impacts for 

Nuiqsut residents through mitigation. However, 

BLM has broad authority to impose mitigation 

measures, including the authority to require 

compensatory mitigation, to address the impacts 

from this project. BLM also has an obligation 

under Section 810 of ANILCA to take reasonable 

steps to minimize and address the potential 

impacts to subsistence from the project. 

Moreover, the U.S. Army Corps of Engineers 

(“Corps”), as a cooperating agency, will use this 

SEIS to base its analysis for its Clean Water Act 

404 process. The Corps has broad mitigation 

authority under 404, and the dSEIS should 

consider a suite of mitigation measures which 

may be implemented as part of this process. 

BLM’s responsibilities in the Reserve include the 

protection of the Reserve’s exceptional ecological 

and other values. BLM has broad authority to use 

mitigation tools to protect the subsistence and 

other surface values in the Reserve, including 

ecological values.

4.2 Mitigation BLM NEPA Guidance and CEQ regulations for EIS 

analyses require that all relevant, reasonable mitigation 

measures that could improve the project are to be 

identified, even if they are outside the jurisdiction of the 

agency [40 CFR 1502.14(f), 40 CFR 1502.16(h)]. The 

Supplemental EIS analyzes a broad range of potential 

new mitigation measures, including some that are 

compensatory in nature and some that are outside the 

jurisdiction of BLM to adopt. However, the decision to 

adopt mitigation is not required, and is at the discretion 

of the decision-maker. The record of decision will 

determine which if any potential new mitigation 

measures to adopt, including those that may be 

compensatory in nature. BLM Instructional 

Memorandum 2018-093 Compensatory Mitigation 

issued July 24, 2018 supersedes all previous policies 

regarding compensatory mitigation, and generally 

precludes the BLM from requiring compensatory 

mitigation from public land users. 
Supplemental Environmental Impact Statement

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

234

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L89-12 Wilderness 

Society, et.al.

BLM should not authorize GMT-2 until after the 

completion of the Regional Mitigation Strategy 

(RMS) and until BLM has a better understanding 

of the potential cumulative and other impacts of 

development in the region.

The RMS is intended to serve as a roadmap for 

mitigating impacts from both GMT1 and future 

projects in the northeastern region of the Reserve 

— including GMT2. BLM has not finalized the 

RMS. The RMS will help inform the locations 

where mitigation actions could take place in the 

northeastern region of the NPR-A and is intended 

to develop potential mitigation measures to better 

address the unmitigated and substantial impacts 

to subsistence, sociocultural systems, and other 

values. This may include decisions about areas 

that need additional protections or how to more 

effectively mitigate against the impacts from 

developments like GMT2.

...BLM has yet to determine how it will adequately 

address and mitigate against the serious impacts 

of development on subsistence and other values. 

BLM should respect the wishes of the Native 

Village of Nuiqsut and postpone authorizing 

GMT2 until the potential impacts and the 

effectiveness of any mitigation measures to 

address those impacts are better understood. 

4.2 Mitigation The Regional Mitigation Strategy pursuant to 

Supplemental BMP 1 in the Greater Mooses Tooth One 

Record of Decision has been completed. However, in 

the interim, many of the policies under which the RMS 

was envisioned and authorized have been rescinded, 

including BLM's Mitigation Handbook and Manual. BLM 

NEPA Guidance and CEQ regulations for EIS analyses 

require that all relevant, reasonable mitigation 

measures that could improve the project are to be 

identified, even if they are outside the jurisdiction of the 

agency [40 CFR 1502.14(f), 40 CFR 1502.16(h)]. The 

Supplemental EIS analyzes a broad range of potential 

new mitigation measures, including some that are 

compensatory in nature and some that are outside the 

jurisdiction of BLM to adopt. However, the decision to 

adopt mitigation is not required, and is at the discretion 

of the decision-maker. The record of decision will 

determine which if any potential new mitigation 

measures to adopt, including those that may be 

compensatory in nature. BLM Instructional 

Memorandum 2018-093 Compensatory Mitigation 

issued July 24, 2018 supersedes all previous policies 

regarding compensatory mitigation, and generally 

precludes the BLM from requiring compensatory 

mitigation from public land users. 
Supplemental Environmental Impact Statement

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

235

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L89-12

Continued

Wilderness 

Society, et.al.

This includes holding off on making any additional 

authorizations in the NPR-A until after the 

completion of a robust mitigation plan to address 

those impacts. In addition to its broader mitigation 

obligations, BLM is also required to take 

reasonable steps under ANILCA to address the 

impacts to subsistence; without an adequate 

analysis of the potential steps and options for 

addressing those impacts, BLM will not meet this 

obligation under ANILCA. BLM needs to finalize 

the RMS prior to making a decision on GMT2 so 

there is a plan in place to address impacts to 

subsistence and other values. 

4.2 Mitigation See above BLM response

L89-13 Wilderness 

Society, et.al.

The mitigation measures that are discussed in the 

dSEIS do not go far enough to address the 

significant impacts to subsistence users and the 

community of Nuiqsut. Given that impacts to 

subsistence and sociocultural systems are one of 

the most significant impacts likely to stem from 

this project and other developments in the region, 

the dSEIS proposes shockingly little in the way of 

mitigation measures or analysis of potential 

measures to address such impacts. There is no 

indication that the proposed avoidance and 

minimization measures will be sufficient to 

address or offset those impacts. Monitoring 

studies, while important, are unlikely to result in 

on-the-ground changes to the project or mitigation 

measures without more (e.g., clear adaptive 

management provisions that will actually lead to 

changes or necessary adjustments to the project).

4.2 Mitigation BLM NEPA Guidance and CEQ regulations for EIS 

analyses require that all relevant, reasonable mitigation 

measures that could improve the project are to be 

identified, even if they are outside the jurisdiction of the 

agency [40 CFR 1502.14(f), 40 CFR 1502.16(h)]. The 

Supplemental EIS analyzes a broad range of potential 

new mitigation measures, including some that are 

compensatory in nature and some that are outside the 

jurisdiction of BLM to adopt. However, the decision to 

adopt mitigation is not required, and is at the discretion 

of the decision-maker. The record of decision will 

determine which if any potential new mitigation 

measures to adopt, including those that may be 

compensatory in nature. BLM Instructional 

Memorandum 2018-093 Compensatory Mitigation 

issued July 24, 2018 supersedes all previous policies 

regarding compensatory mitigation, and generally 

precludes the BLM from requiring compensatory 

mitigation from public land users.
Supplemental Environmental Impact Statement

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

236

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L89-13

Continued

Wilderness 

Society, et.al.

Even where the dSEIS states there will be 

mitigation measures, such as the pullouts and 

access ramps, it is unclear whether they have 

been sited or designed in a way that is culturally 

appropriate or will actually address the adverse 

impacts to subsistence users. BLM notes that 

mitigation measures like the ramps will only 

“likely” be designed in a way that fixes some of 

the access problems that occurred in the context 

of the CD-5 road. This is insufficient. If BLM is 

going to rely on and incorporate such measures 

into the project for the benefit of the community, it 

should ensure that they are designed and sited in 

a way that incorporates feedback from the 

community. BLM should also address the safety 

concerns associated with use of such access 

points by community members to ensure 

crossings provide safe and effective access 

points. 

BLM should also consider requiring compensatory 

mitigation for this project, relying on its broad 

authority under the NPRPA and FLPMA. In the 

GMT1 context, BLM required compensatory 

mitigation from ConocoPhillips because the 

existing avoidance and minimization measures 

were insufficient to address the subsistence and 

sociocultural impacts from the project. The 

existing avoidance and minimization measures for 

GMT2 are similarly not going to be adequate to 

fully address the anticipated impacts to 

subsistence and sociocultural systems from this 

project. 

4.2 Mitigation See above BLM response
Supplemental Environmental Impact Statement

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

237

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L89-14 Wilderness 

Society, et.al.

There are a number of foreseeable developments 

and decisions that could further exacerbate the 

cumulative impacts to the region that BLM failed 

to consider in the dSEIS. BLM failed to include a 

potential full-field development scenario as part of 

the dSEIS. BLM’s current development scenario 

in the dSEIS and Map 4.6-1 only accounts for a 

limited range of activities and developments and 

does not adequately encompass the full range of 

developments that are likely to occur in the region 

under a full-field development scenario. As a 

result, BLM has failed to fully address and 

account for the full range of significant, cumulative 

impacts. BLM needs to account for the wide range 

of foreseeable projects and developments that will 

potentially occur in the region in the foreseeable 

future. 

BLM’s full-field development scenario and 

cumulative impacts assessment should also 

account for the release of the U.S. Geological 

Survey’s (USGS) updated estimates of oil and 

gas resources in the Reserve. USGS updated its 

estimate of the mean undiscovered, technically 

recoverable onshore resources, revising the 

estimate from 1.5 billion barrels of oil in 2010 up 

to 8.7 billion barrels of oil.

4.0 Cumulative 

Effects Projects 

and Methodology

GMT2 was originally approved for development as CD7 in 2004 under the Alpine Satellite Development Plan 

EIS. The purpose of the SEIS is to supplement the 

2004 analysis and to include new information relevant 

to environmental concerns that have bearing on the 

proposed action or its effects. The GMT2 SEIS tiers to 

and incorporates by reference previous NEPA analysis 

including the full-field development scenarios analyses 

found in the ASDP EIS (2004), and the cumulative 

effects analysis in the NPR-A IAP (2012) and GMT1 

SEIS (2014). 
Supplemental Environmental Impact Statement

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

238

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L89-15 Wilderness 

Society, et.al.

BLM has failed to account for and assess the 

potential cumulative impacts from activities on 

newly leased acreage in the NPRA. At the 2016 

lease sale, ConocoPhillips acquired an additional 

594,972 acres in the Reserve — nearly doubling 

the 895,000 total acres already leased in the 

Reserve. A significant portion of this new acreage 

is within the Teshekpuk Lake Special Area, and 

will push development activities even closer to the 

most sensitive areas around Teshekpuk Lake. In 

a state area wide lease sale held the same day, 

ConocoPhillips also acquired 142,280 acres of 

land just outside the Reserve on the edge of the 

Colville River Special Area. All of this newly 

acquired acreage is in the vicinity of 

ConocoPhillips’ existing developments and 

acreage around Nuiqsut and extends out from the 

existing lease areas. It is reasonably foreseeable 

that there will not only be additional exploration 

activities on these lease tracts, but that there will 

potentially be development and production pads 

that move forward in these areas as well. BLM 

should account for these potential developments 

and activities in its assessment of the cumulative 

impacts analysis and its assessment of a potential 

full-field development scenario. These areas are 

located to the south and southwest of Nuiqsut, so 

any activities and developments in this region are 

likely to further exacerbate the impacts to 

subsistence and other resources already being 

experienced by the community. These 

developments will effectively encircle the 

community of Nuiqsut with oil activities and 

infrastructure and choke the community out of the 

remaining subsistence use areas west and south 

of the community that are currently free of oil 

infrastructure. 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Section 4.6.8 Cumulative Impacts to Social Systems, 

Sub-section 4.6.8.9 Subsistence includes a long list of 

existing and currently proposed oil exploration and 

development projects within 40 miles of Nuiqsut. Text 

has been revised to include the reasonably foreseeable 

future development at Willow. The SEIS discloses the 

anticipated over-arching impacts of additional 

exploration and development and attempts to be 

succinct. 
Supplemental Environmental Impact Statement

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

239

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L89-16 Wilderness 

Society, et.al.

BLM also identified that it plans to revise the IAP. 

Secretarial Order 3352 called for the potential 

revision to the IAP. The dSEIS states, “Current 

anticipated direction is that BLM Alaska will issue 

a [determination of NEPA adequacy] based on an 

alternative analyzed but not implemented in the 

2012 Final IAP/EIS.” Despite this 

acknowledgement, BLM never assesses the 

cumulative effects or potential ramifications from 

reopening the IAP and opening additional areas to 

development. The primary target of any such 

effort would potentially be the Teshekpuk Lake

Special Area. The Teshekpuk Lake Special Area 

was first established in 1977 and is an area of 

international conservation importance. The 2013 

IAP safeguards much of the Teshekpuk Lake 

Special Area from leasing and non-subsistence 

permanent infrastructure because of its high 

conservation and subsistence values. The 

Teshekpuk Lake Special Area includes important 

calving and insect-relief areas for the Teshekpuk 

Caribou Herd, an important subsistence resource. 

It supports a variety of fish, including lake trout, 

whitefish, Bering cisco, and rainbow smelt, among 

other species. It also contains globally important 

habitat for waterbird and shorebird breeding, 

molting, staging, and migration. Any efforts to 

expand industrial activity into these areas would 

have far-reaching direct, indirect, and cumulative 

impacts across the region. Despite the fact that 

BLM identified in the GMT2 dSEIS that a revision 

to the IAP is foreseeable, BLM has completely 

failed to consider the potentially huge 

ramifications such a decision is likely to have on 

the entire region. 

4.0 Cumulative 

Effects Projects 

and Methodology

While SO 3352 did require the ASLM to submit a 

schedule to effectuate a revision of the NPR-A IAP, it is 

uncertain whether or not a revision will occur. The 

GMT2 SEIS tiers to and incorporates by reference 

previous NEPA analysis including the ASDP EIS 

(2004), NPR-A IAP (2012) and GMT1 SEIS (2014). 

Leasing within the TLSA was analyzed in detail under 

Alternative D in the 2012 NPR-A IAP Final EIS. 
Supplemental Environmental Impact Statement

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

240

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L89-17 Wilderness

Society, et.al.

BLM has also failed to adequately account for the 

full scope of the Willow project and its potential 

direct, indirect, and cumulative impacts to 

subsistence and other resources in the region. 

The dSEIS contains outdated information about 

the scope and potential plans for the Willow 

project. The dSEIS describes the Willow project 

as “2 exploratory wells in 2016, 4 exploratory 

wells planned for 2018 and may do additional 

appraisal wells in 2019. Unspecified development 

plans, including whether or not to have a 

production facility. Estimated 300M barrel oil find.” 

ConocoPhillips has stated that it anticipates that 

the Willow development will produce 100,000 

barrels per day and anticipates starting production 

in 2023. Willow is likely to be another Alpine-sized 

development in the region and is likely to require 

a new stand-alone oil processing facility. BLM has 

failed to account for the significant size of this 

project and the far-reaching impacts such a 

project is likely to have on subsistence and other 

resources in the region, particularly since 

ConocoPhillips is likely to propose connecting any 

infrastructure back to the existing GMT and Alpine 

developments. BLM needs to fully account for this 

development in the assessment of the cumulative 

impacts of GMT2. 

Relatedly, BLM failed to analyze a new central 

processing facility (CPF), which will be necessary 

for any future projects within the GMT Unit or 

beyond. The Alpine Satellites field was 

constructed and has been maintained under the 

premise that the Alpine CPF would process oil 

resources produced from the Alpine field, which 

includes GMT-2. 

4.0 Cumulative 

Effects Projects 

and Methodology

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 project has independent utility from GMT2 

and is not considered a connected action under NEPA. 

The Willow find is sufficiently large that even in the 

absence of a road connection between GMT2 and 

GMT1, the Willow project could be developed 

roadlessly similar to the Alpine field. The direct and 

indirect impacts of Willow will be analyzed pursuant to 

NEPA as part of the Willow MDP EIS, which includes a 

central processing facility as part of the project 

proposal.
Supplemental Environmental Impact Statement

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

241

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L89-17

Continued

Wilderness 

Society, et.al.

However, no other sites were intended to be 

developed by relying on CPF’s capacity, because 

of their distance and Alpine CPF’s limited 

processing capacity. Future development beyond 

GMT-2, therefore, will require construction of a 

new CPF. The original Alpine facility was planned 

as a 97-acre surface development that included 

stand-alone processing facilities, and an airstrip. 

Building a new CPF further west will require vast 

amounts of gravel to construct a large pad to 

house the myriad infrastructure needed to 

process oil and gas resources. A new CPF will 

bring with it a new airstrip, longer gravel roads, 

more ice roads, changing traffic patterns, and will 

greatly impact noise, air quality, water, wildlife, 

and the community of Nuiqsut. The failure of the 

dSEIS to analyze a new CPF as part of the 

reasonably foreseeable future development 

scenario is unacceptable.

4.0 Cumulative 

Effects Projects 

and Methodology

See above BLM response
Supplemental Environmental Impact Statement

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

242

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L89-18 Wilderness 

Society, et.al.

The dSEIS also fails to account for the full range 

of impacts from the studies and other activities 

likely to occur from ConocoPhillips trying to permit 

and bring additional developments online, 

particularly with regard to the number of flights 

and other activities likely to disturb wildlife and 

further limit subsistence activities. For example, 

ConocoPhillips recently applied for a five-year 

authorization to conduct summer work in the 

Reserve in the Greater Mooses Tooth, Bear 

Tooth, and Colville Units, Nuiqsut, Inigok, and 

surrounding areas. In this permit application, 

ConocoPhillips predicts that they will conduct 

7,844 helicopter takeoffs and landings in the 

summer of 2018 alone. This is an unbelievable 

number of flights, none of which has been 

accounted for in the dSEIS. Helicopter traffic is 

one of the most commonly reported disturbances 

to subsistence hunting and is a significant 

concern for the community of Nuiqsut. This makes 

it even more important for BLM to fully assess the 

total number of flights occurring in the region. The 

application also states that personnel will be 

housed in both Alpine and Nuiqsut, which means 

more traffic in and out of Nuiqsut, and increasing 

the interaction between the community and 

industrial workers. The dSEIS fails to account for 

the cumulative number of flights and level of 

industrial activity likely to occur from the large 

number of developments occurring across the 

region. 

4.0 Cumulative 

Effects Projects 

and Methodology

GMT2 was originally approved for development as CD7 in 2004 under the Alpine Satellite Development Plan 

EIS. The purpose of the SEIS is to supplement the 

2004 analysis and to include new information relevant 

to environmental concerns that have bearing on the 

proposed action or its effects. The GMT2 SEIS tiers to 

and incorporates by reference previous NEPA analysis 

including the cumulative effects analysis in the ASDP 

EIS (2004), NPR-A IAP (2012) and GMT1 SEIS (2014). 

The estimated number of flights for the 5-year 

authorization requested by CPAI in the summer of 2018 

were analyzed in in both the IAP and GMT1. CPAI 

reports the total combined numbers in association with 

the summer activities authorization pursuant to the ESA 

consultation requirements in determining level of take.
Supplemental Environmental Impact Statement

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

243

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L89-19 Wilderness 

Society, et.al.

The dSEIS references outdated information 

regarding Putu, Stony Hill, and ConocoPhillips’ 

plans to develop additional production pads in the 

Colville River Unit. The dSEIS only references the 

delayed exploratory activities at Putu and notes

that there will potentially be a 32-well and 5.8-acre 

expansion of CD-2.73 ConocoPhillips has already 

completed its exploration activities at Putu and 

Stony Hill and has stated that the company is 

planning to turn those prospects into tieback 

developments. Putu is only around two miles 

away from the community of Nuiqsut, which would 

make this the closest oil and gas infrastructure to 

the community to date. This will have serious 

cumulative impacts on the community of Nuiqsut 

and other resources in the region that have not 

been adequately assessed in the dSEIS. 

4.0 Cumulative 

Effects Projects 

and Methodology

Text has been revised to reflect updated information 

regarding recently-drilled exploration wells within the 

cumulative effects analysis geographic area. GMT2 

was originally approved for development as CD-7 in 

2004 under the Alpine Satellite Development Plan EIS. 

The purpose of the SEIS is to supplement the 2004 

analysis and to include new information relevant to 

environmental concerns that have bearing on the 

proposed action or its effects. The GMT2 SEIS tiers to 

and incorporates by reference previous NEPA analysis 

including the cumulative effects analysis from ASDP 

EIS (2004), NPR-A IAP (2012) and GMT1 SEIS (2014). 

L89-2 Wilderness 

Society, et.al.

Table 4.1-2 provides a helpful summary of the 

level of impacts for each

resource considered in the dSEIS except social 

systems. BLM must include impact criteria and

accurately determine level of impact by alternative 

for social system impacts, and include a

similar summary in Table 4.1-2.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

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 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. 
Supplemental Environmental Impact Statement

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

244

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L89-20 Wilderness 

Society, et.al.

BLM did not analyze impacts from the proposed 

Arctic Strategic Transportation and Resources 

(ASTAR) project. As currently proposed by the 

State of Alaska, ASTAR plans to construct a 

series of interconnected gravel roads or rights-ofway spanning portions of the North Slope 

Borough, predominantly between villages and 

Prudhoe Bay, with most of the focus on 

connecting the Colville Delta to Barrow. The 

construction of this proposed project would 

directly impact Nuiqsut and the broader 

geographic area impacted by GMT1, and would 

likely lead to increased development of oil and 

gas sites in the western NPR-A. Moreover, this 

proposed project would cause synergistic impacts 

on subsistence, environmental justice, and 

sociocultural systems due to increased road 

access to NPR-A villages, particularly Nuiqsut. 

These impacts must be analyzed as cumulative 

effects. 

4.0 Cumulative 

Effects Projects 

and Methodology

ASTAR is in the early stages of planning. No specific 

projects are reasonably foreseeable at this time. A 

discussion of ASTAR was added to section 4.2.2.2 
Supplemental Environmental Impact Statement

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

245

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L89-21 Wilderness 

Society, et.al.

The dSEIS also fails to address the full range of 

cumulative impacts from the Smith Bay 

development. The dSEIS only accounts for a 

potential pipeline from the Smith Bay 

development, without accounting for the potential 

impacts of an actual development at Smith Bay. 

Caelus Energy announced a large discovery of 

roughly 1.8 to 2.4 billion barrels of oil in Smith Bay 

in 2016. Caelus’ proposed development would 

require extensive infrastructure and industrial 

activity in and around the ecologically rich Smith 

Bay, which is located at the western edge of the 

Teshekpuk Lake Special Area. The area around 

Teshekpuk Lake supports the highest density of 

shorebirds in the circumpolar Arctic. More than a 

dozen of the National Audubon Society’s Alaska 

WatchList species nest, molt, or rest near 

Teshekpuk Lake, including threatened spectacled 

eiders, Steller’s eiders, yellow-billed loons, dunlins 

and American golden-plovers. The region also 

provides important habitat for the Teshekpuk Lake 

Caribou Herd. Development in this region could 

place additional pressure on the Teshekpuk herd, 

further exacerbating the impacts to the herd and 

subsistence users occurring as a result of the 

GMT2 and other developments at the 

northeastern edge of the Reserve. Oil 

development of this scale could potentially have 

huge impacts on the Reserve’s wildlife, the 

surrounding marine habitat, and the traditional 

subsistence practices of local residents. The 

dSEIS should account for the full scope of 

potential cumulative impacts from Caelus’ 

development and not just the potential for a 

pipeline. 

4.0 Cumulative 

Effects Projects 

and Methodology

The FEIS defines the geographic area of relevant past 

and reasonably foreseeable future actions as limited to 

Harrison Bay and Lower Colville River watersheds. 

Smith Bay is outside of the cumulative effects analysis 

area thus it is not included in the cumulative effects 

analysis. The potential pipeline from Smith Bay crosses 

the analysis area and is included. 
Supplemental Environmental Impact Statement

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

246

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L89-22 Wilderness 

Society, et.al.

BLM has not considered a reasonable range of 

alternatives to the proposed project. BLM ruled 

out use of a seasonal roadless alternative for 

economic purposes. However, BLM has failed to 

consider other alternatives that would minimize 

the potential use of the road. For example, BLM 

should consider a roaded alternative that would 

limit industrial activities during times of the year 

when particularly sensitive subsistence use 

activities (e.g., caribou hunting) are likely to occur 

in the vicinity of the project. 

2.1 Proposed 

Action & 

Alternatives

Section 5.3 of the BLM NEPA Handbook and CEQ 

regulations describe the conditions under which 

supplementation must occur. The Handbook provides 

that supplementation to the current (draft or final) EIS is 

necessary only in the case of: (1) substantial changes 

to the proposed action that are relevant to 

environmental concerns; (2) addition of a new 

alternative beyond the scope of analyzed alternatives; 

or (3) significant new circumstances or information 

relevant to environmental concerns and bearing on the 

proposed action or its effects. A seasonal restriction 

limiting industrial activity on the GMT2 road is 

qualitatively within the range of alternatives analyzed in 

the Draft SEIS. A seasonal restriction is a variation of 

the timing of activity on the road, however, the nature 

and context of the impacts of use of the GMT2 road 

remain the same. BLM has included Potential 

Mitigation Measures 2 and 8 that serves to minimize 

the impacts of the GMT2 during sensitive time of the 

year as part of the impact analysis for Subsistence in 

Section 4.4.5.6.
Supplemental Environmental Impact Statement

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

247

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L89-23 Wilderness 

Society, et.al.

BLM should also consider a deferred-approval 

alternative where the agencies do not issue 

permits until a Willow application is submitted to 

ensure that BLM understands the impacts from 

both projects and can impose any necessary 

protective measures to address impacts from the 

projects together. In January 2017, 

ConocoPhillips announced a significant new 

discovery within the Greater Mooses Tooth Unit at 

Willow, which is located just west of the GMT-2 

project. ConocoPhillips anticipates that the Willow 

development will produce 100,000 barrels per 

day. ConocoPhillips is aiming to permit the project 

and begin production by 2023. Willow is likely to 

be another Alpine-sized development in the 

region and is likely to require a new stand-alone 

oil processing facility. Given the proximity of 

Willow to GMT2, ConocoPhillips is likely to 

propose connecting any infrastructure back to the 

existing GMT and Alpine developments. 

Piecemeal permitting of the GMT2 project at this 

time, when there is an additional and massive 

project that will be moving toward permitting in the 

near future, is inappropriate and inconsistent with 

the BLM’s obligations under NEPA. Permitting the 

GMT2 project at this time is premature and will 

foreclose the possibility for the BLM to consider 

meaningful and less damaging alternatives to the 

proposal in light of the broader development 

scheme moving forward in the region. The 

community of Nuiqsut is only beginning to 

experience and fully understand the impacts from 

the expanded Alpine satellite developments, but 

those impacts are already significant. 

2.1 Proposed 

Action & 

Alternatives

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 project has independent utility from GMT2 

and is not considered a connected action under NEPA. 

The Willow find is sufficiently large that even in the 

absence of a road connection between GMT2 and 

GMT1, the Willow project could be developed 

roadlessly similar to the Alpine field. Deferral of a 

project authorization would be inconsistent with the 

directive in the Naval Petroleum Reserves Production 

Act to expeditiously carry out an oil and gas leasing 

program and the rights ConocoPhillips acquired with 

the subject leases to reasonably develop the oil and 

gas within those lease tracts.
Supplemental Environmental Impact Statement

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

248

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L89-23

Continued

Wilderness 

Society, et.al.

ConocoPhillips only constructed and started 

production at CD5 within the past few years, but it 

is already having a significant effect on the 

community and has caused problems with things 

like access to subsistence resources. GMT-1, 

which is permitted, but has yet to be fully 

constructed, will only magnify these impacts. 

Despite this, BLM has yet to determine how it will 

adequately address and mitigate against the 

serious impacts of development on subsistence 

and other values. BLM should respect the wishes 

of the Native Village of Nuiqsut and postpone 

authorizing GMT2 until the potential impacts and 

the effectiveness of any mitigation measures to 

address those impacts are better understood.

2.1 Proposed 

Action & 

Alternatives

See above BLM response

L89-24 Wilderness 

Society, et.al.

BLM should also consider other alternatives to 

reduce the size of the road and its potential 

impacts on subsistence. One of the main 

concerns about the road cited by the community 

is its height, which has the potential to deflect 

caribou movements and create access issues for 

the community. As a result, one of the primary 

mitigation measures supported by Nuiqsut 

hunters is for BLM to lower the height of the GMT2 access road. However, BLM has stated that the 

design of the road is required to support heavy 

industrial traffic with the smallest possible 

footprint. BLM should consider an alternative that 

would limit the timing and type of industrial traffic 

and activity on the road to minimize the need for 

the road to be built to height and size 

specifications capable of supporting such a 

significant amount of industrial activity. 

2.1 Proposed 

Action & 

Alternatives

Section 5.3 of the BLM NEPA Handbook and CEQ 

regulations describe the conditions under which 

supplementation must occur. The Handbook provides 

that supplementation to the current (draft or final) EIS is 

necessary only in the case of: (1) substantial changes 

to the proposed action that are relevant to 

environmental concerns; (2) addition of a new 

alternative beyond the scope of analyzed alternatives; 

or (3) significant new circumstances or information 

relevant to environmental concerns and bearing on the 

proposed action or its effects. A seasonal restriction 

limiting industrial activity on the GMT2 road is 

qualitatively within the range of alternatives analyzed in 

the Draft SEIS. A seasonal restriction is a variation of 

the timing of activity on the road, however, the nature 

and context of the impacts of use of the GMT2 road 

remain the same. BLM has included Potential 

Mitigation Measures 2 and 8 that serves to minimize 

the impacts of the GMT2 during sensitive time of the 

year as part of the impact analysis for Subsistence in 

Section 4.4.5.6.
Supplemental Environmental Impact Statement

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

249

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L89-25 Wilderness 

Society, et.al.

We believe that the air quality modeling analyses 

performed by the BLM for the dSEIS for the 

proposed development of petroleum resources in 

the Greater Mooses Tooth Unit – at the proposed 

GMT2 drilling and production pad – are deficient 

and likely underestimate impacts. As a result, it is 

likely that air quality impacts would be predicted to 

be more extensive than what is presented in the 

dSEIS. In addition, all of the alternatives fall short 

of establishing enforceable mitigation measures 

that reflect assumptions that were made in the 

analysis to ensure that no significant air quality 

impacts will occur. More detailed comments on 

the areas of greatest concern are provided below.

3.5 Air Quality & 

Meteorology

The modeling analysis is comprehensive and includes 

assumptions that provide conservatively high estimates 

of impacts. In multiple steps of the air quality impact 

assessment, model inputs and the approach were 

selected to develop a conservatively high estimate of 

potential air impacts. As documented on page 7 of the 

far-field modeling report: “the far-field modeling 

conservatively (i.e., to be protective of the environment) 

used the maximum of the short-term and long-term 

emission rates for each pollutant.” Similarly: “For the 

Class II PSD increment analysis (i.e. for 

concentrations) years/scenarios were mixed, and the 

scenario with the highest (worst-case) emissions for 

each pollutant was selected. “ Also on page 12 of the 

far-field modeling report, it is stated: “Similarly, a 

release height of 12 feet was used as a conservative 

estimate of a typical height of a 1-story structure.” 

Lastly, on page 25 of the far-field modeling report it is 

stated: ” Model predicted highest first-high (H1H) 

concentrations were compared with the Class II PSD 

increments. Using the H1H instead of the highest 

second-high (H2H) values will conservatively overpredict the values to be compared to the PSD 

increments.”
Supplemental Environmental Impact Statement

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

250

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L89-26 Wilderness 

Society, et.al.

BLM has Failed to Rigorously Assess Impacts 

from Each of the Proposed Alternatives in the 

dSEIS. BLM only conducted an air quality impact 

analysis for the Draft Preferred Alternative (A –

CPAI Proposed Project) and for Alternative C 

(Roadless Development). No independent impact 

assessment was completed for Alternatives B 

(Alternate Alignment of GMT1 – GMT2 Access 

Road) and D (No Action Alternative). 

A direct comparison of the emissions inventories 

for Alternatives A and B shows that: (1) NOx 

emissions in years one through three are higher 

for the Alternative B development scenario by 

almost 5%; (2) PM10 and PM2.5 emissions in all 

years are higher by as much as 10%; (3) 

hazardous air pollutant (HAP) emissions are also 

higher for Alternative B (e.g., formaldehyde 

emissions are 10% higher for Alternative B); and 

(4) even VOC emissions are slightly higher under 

Alternative B.

 

The BLM should consider whether increased 

emissions associated with the changes in road 

alignment and length (e.g., increased truck traffic 

and fugitive dust emissions related to travel and 

construction) under Alternative B would result in 

significant air quality impacts. This would be 

especially important to consider with regard to the 

24-hour average PM10 National Ambient Air 

Quality Standards (NAAQS).

3.5 Air Quality & 

Meteorology

The determination to not exclusively model Alternative 

B was made due to the following similarities to 

Alternative A, resulting in the conclusion that the 

impacts from Alternative A are representative of 

Alternative B:

1.The pad size and road alignment nearest the GMT2 

Pad is the same.

2.The emissions per constructed road segment, 

constructed pipeline segment, and mile travelled for 

both Alternatives are the same. 

3.The difference between Alternative A's and B's road 

and pipeline alignment is farthest from the GMT2 Pad 

and where the predicted maximum impacts occurred.

Alternative D was not modeled as there are no

proposed project emissions under that alternative. 

To additionally address this comment, a linear 

correlation was created to conservatively estimate 

Alternative B impacts based on Alternative A modeled 

results and the ratio of Alternatives B and A emissions. 

With this conservative linear analysis, the modeled 

impacts for Alternative B are still below the respective 

NAAQS/AAAQS.

For the assessment of far-field impacts, the impacts 

assessed for Alternatives A and C were well below the 

air quality standards and the 5-10% difference in the 

emissions between the Alternative B and Alternative A 

would not change this conclusion. Therefore, it is 

reasonable to assess potential impacts for Alternative B 

qualitatively without explicitly modeling the alternative.
Supplemental Environmental Impact Statement

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

251

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L89-26

Continued

Wilderness 

Society, et.al.

A quantitative assessment of the air quality 

impacts from the Alternative B development 

scenario, based on modeling of emissions 

associated with the alternate alignment of the 

GMT1 to GMT2 access road would be needed in 

order to understand whether or not impacts would 

be greater than Alternative A for some pollutants, 

in some locations. 

3.5 Air Quality & 

Meteorology

See above BLM response

L89-27 Wilderness 

Society, et.al.

Cumulative air quality impacts are only presented 

in the dSEIS for Alternative A. Emission rates for 

Alternatives A and C are presented in the 

underlying far-field air quality report, with 

Alternative C emission rates higher than 

Alternative A for all pollutants except PM10. 

3.5 Air Quality & 

Meteorology

Cumulative air quality impacts are quantitatively 

assessed for Alternative A. A qualitative assessment of 

the cumulative far-field impacts from Alternative C is 

conducted based on project-alone impacts. Projectalone impacts from Alternative A (shown in Tables 4.2-

20 and 4.2-21) contribute less than 1 percent to the 

total estimated air quality concentrations. Comparing 

Project-alone impacts from Alternative A to Alternative 

C (shown in Tables 4.2-29 and 4.2-30) indicates that 

the increased emissions under Alternative C would not 

affect the total estimated air quality concentrations. 

Therefore, the cumulative far-field impacts for 

Alternative C would be almost identical to those 

predicted for Alternative A as shown in Tables 4.6-5 

through 4.6-8 and is not quantitatively assessed. 

L89-28 Wilderness 

Society, et.al.

Section 3.2.3.2 states that there are “minimal 

man-made and natural emission sources that 

negatively affect air quality in the NPR-A.” In this 

context, “minimal” is an over-generalization of air 

quality in the NPR-A. Also, BLM should add 

gravel mining to list of emission sources in the 

text. 

3.5 Air Quality & 

Meteorology

Based on the reviewer comment, the text was modified 

to state that man-made and natural emission sources 

affect air quality. Also, gravel mining was added as a 

man-made source of emissions.
Supplemental Environmental Impact Statement

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

252

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L89-29 Wilderness 

Society, et.al.

BLM’s Modeling Analysis is Deficient and Likely 

Underestimates Impacts. BLM relies on outdated 

modeling for the far field air quality analysis. As 

acknowledged by BLM, EPA removed CALPUFF 

as a preferred model in its recent update to its 

Guideline on Air Quality Models (40 C.F.R. Part 

51, Appendix W). And while BLM notes that 

EPA’s removal of CALPUFF as a preferred 

model, “does not affect its use under the FLM’s 

guidance regarding AQRV assessments (FLAG, 

2010)” it fails to address the use of a 

photochemical grid model (e.g., CAMx) to assess 

source impacts on ozone and secondary PM 

levels. BLM should assess regional impacts using 

a photochemical grid model. Specifically, EPA 

describes such models, in its preamble to the 

Guideline of Air Quality Models update, as 

follows: Publicly available and documented 

Eulerian photochemical grid models such as the 

Comprehensive Air Quality Model with Extensions 

(CAMx) and the Community Multiscale Air Quality 

(CMAQ) model treat emissions, chemical 

transformation, transport, and deposition using 

time and space variant meteorology. These 

modeling systems include primarily emitted 

species and secondarily formed pollutants such 

as ozone and PM2.5. In addition, these models 

have been used extensively to support ozone and 

PM2.5 SIPs and to explore relationships between 

inputs and air quality impacts in the United States 

and elsewhere.

In addition, BLM uses an older version of 

CALPUFF for the far-field air quality impact 

analysis (“Although more recent versions of 

CALPUFF are available, CALPUFF version 5.8.5 

was used for the far field analysis.”).

3.5 Air Quality & 

Meteorology

The modeling analysis is comprehensive and includes 

assumptions that provide conservatively high estimates 

of impacts. First, as stated in the Far-field modeling 

report: “In the preamble to the updated rule (Federal 

Register Vol. 82, No. 10, January 17, 2017) USEPA 

clearly stated that their action to remove CALPUFF 

from Appendix A ‘does not affect its use under the 

FLM’s guidance regarding AQRV assessments (FLAG, 

2010).’” CALPUFF version 5.8.5 was the regulatoryapproved version of the model when CALPUFF was 

listed as a preferred model by USEPA. More recent 

versions of CALPUFF were not approved by EPA and 

so were not deemed to be appropriate for the analysis 

of GMT2 impacts. As stated in the far-field modeling 

report: “Although more recent versions of CALPUFF 

are available, CALPUFF version 5.8.5 was used for the 

far field analysis. This was the most recent USEPArecommended and FLM-approved regulatory version of 

CALPUFF before the recent rulemaking became 

effective.” 

Recent photochemical grid modeling analyses 

conducted by the Bureau of Ocean and Energy 

Management (BOEM) included an assessment of 

ozone and secondarily formed PM2.5 in the Alaska 

North Slope and found no issues of concern (see 

BOEM (2017) report titled “Arctic Air Quality Modeling 

Study Photochemical Modeling Report.” BEOM Arctic 

Air Quality Impact Assessment Modeling Study. By 

Ramboll Environ, Novato, CA. Available at: 

https://www.boem.gov/2016-076/). Generally, the 

findings of the BOEM study are consistent with 

available measurements and that no notable changes 

to air quality or AQRVs are predicted to occur under 

future development scenarios analyzed by BOEM. 
Supplemental Environmental Impact Statement

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Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L89-29 Wilderness 

Society, et.al.

See comment above 3.5 Air Quality & 

Meteorology

The regional modeling analysis predicts both current 

and future ozone and total PM2.5 concentrations are 

well below the NAAQS in the Alaska North Slope and 

analyzed Class I and sensitive Class II areas. (Note to 

BLM: BLM advised us that a Photochemical Grid 

Modeling study was going to be conducted for the 

Alaska North Slope for resource management planning 

and therefore it wouldn’t be required for this project.)

Furthermore, in multiple steps of the air quality impact 

assessment, model inputs and the approach were 

selected to develop a conservatively high estimate of

potential air impacts. As documented on page 7 of the 

far-field modeling report: “the far-field modeling 

conservatively (i.e., to be protective of the environment) 

used the maximum of the short-term and long-term 

emission rates for each pollutant.” Similarly: “For the 

Class II PSD increment analysis (i.e. for 

concentrations) years/scenarios were mixed, and the 

scenario with the highest (worst-case) emissions for 

each pollutant was selected. “ Also on page 12 of the 

far-field modeling report, it is stated: “Similarly, a 

release height of 12 feet was used as a conservative 

estimate of a typical height of a 1-story structure.” 

Lastly, on page 25 of the far-field modeling report it is 

stated: ” Model predicted highest first-high (H1H) 

concentrations were compared with the Class II PSD 

increments. Using the H1H instead of the highest 

second-high (H2H) values will conservatively overpredict the values to be compared to the PSD 

increments.”
Supplemental Environmental Impact Statement

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

254

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L89-3 Wilderness 

Society, et.al.

The analysis of economic impacts is also

deficient. The economics section of the dSEIS 

only touts the potential economic benefits to the 

community. It does not quantify or discuss the 

potential economic harms given the reality of the 

subsistence economy in Nuiqsut. The dSEIS also 

acknowledges elsewhere that GMT2 will 

potentially impact community members by 

causing them to travel further for subsistence 

activities, which will make it harder for individuals 

to afford to engage in traditional subsistence 

activities

and may limit the ability of individuals with fewer 

financial means to engage in those activities. BLM 

has failed to account for these economic harms in 

its analysis of the potential economic impacts of 

the project.

3.16 Economy Section 3.4.4 recognizes that the economy in the 

region is mixed, relying on both subsistence and cash. 

Section 3.4.4 and 4.4.3 focus on the conditions and 

effects on the cash economy as it relates to oil and gas 

activity. The baseline characterization and potential 

effects to subsistence are comprehensively addressed 

in standalone Sections 3.4.6 and 4.4.5
Supplemental Environmental Impact Statement

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

255

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L89-30 Wilderness 

Society, et.al.

It appears that the near-field modeled scenarios 

do not account for concurrent construction, 

drilling, and well intervention activities in Year 3 

and therefore may underestimate potential air 

quality impacts in Year 3. The dSEIS indicates the 

following: 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. Construction would take 

place from late Year 1 through Year 3 of the 

project during Construction Schedule 1. ... 

Developmental drilling would take place during 

Year 3, and infill drilling would take place from 

Years 4 through 10 of the GMT2 Project.98 

The dSEIS states that, “[m]aximum annual 

emissions would occur during the construction 

and drilling phases (Years 2 and 3).” And the 

modeling report includes detailed emissions 

summaries showing Year 3 emissions from 

construction, developmental drilling, and well 

intervention activities occurring at the same time. 

BLM should ensure that the modeling fully 

accounts for all emissions sources in Year 3, 

when construction, drilling, and well intervention 

activities will be occurring in parallel. In particular, 

for NOx, VOC, SO2, and CO2e emissions, it is 

possible that impacts in Year 3 would be higher 

than modeled impacts presented in the dSEIS 

since combined emissions in Year 3 (e.g., in Year 

3 Month 6) exceed those modeled for the dSEIS 

(i.e., Year 2 Month 2). 

3.5 Air Quality & 

Meteorology

Thank you for the comment. The modeling in the SEIS 

does account for concurrent activities including drilling, 

well interventions, operations, and construction. A 

schedule of when these activities may overlap is 

included in the AQIA emissions summaries found in 

Appendix B. As pointed out by the reviewer, Year 3 has 

the potential for drilling, well intervention, routine 

operations, and construction emissions. The model 

accounts for the expected operation of each activity 

during Year 3 including simultaneous activity. 
Supplemental Environmental Impact Statement

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Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L89-31 Wilderness 

Society, et.al.

The cumulative impact analysis is tiered off of the 

analysis completed for GMT1. It’s not entirely 

clear, however, if the maximum emissions were 

considered in the development scenario that were 

assumed for the far-field modeling. The far-field 

modeling report indicates that, “[f]or the Class II 

PSD increment analysis (i.e. for concentrations) 

years/scenarios were mixed, and the scenario 

with the highest (worst case) emissions for each 

pollutant was selected.” Specifically: For the 

Alternative A Class II PSD increment analysis, the 

PM2.5 emissions were taken from the 

Construction year, while the rest were taken from 

the Developmental Drilling year. Similarly for 

Alternative C, the PM10 emissions were taken 

from the Infill Drilling year, while the rest were 

taken from the Developmental Drilling year. 

As with the near-field analysis, however, BLM 

should also ensure it is accounting for all 

emissions sources that would reasonably occur at 

the same time (e.g., construction, drilling, and well 

intervention activities that are projected to all 

occur in Year 3). And BLM should ensure that the 

emissions from reasonably foreseeable 

development (RFD) sources also reflect the 

maximum emissions scenario for each pollutant. 

3.5 Air Quality & 

Meteorology

The far-field analysis analyzes the maximum emissions 

sources by including multiple types of activities that 

would reasonably occur at the same time. As stated in 

the far-field modeling report on page 7: “The 

years/scenarios [in Table 3-1] are named for the 

primary activity occurring during that year, but include 

other activities as well. For example, some construction 

emissions will occur during the year labeled 

Developmental Drilling. During the year labeled Infill 

Drilling, some Routine Operations emissions will also 

occur.” Thus, for the example selected by the 

commenter, for the Alternative A Class II PSD 

increment analysis, while the PM2.5 emissions were 

taken from the Construction year and the NOx, SO2, 

and PM10 emissions were taken from the 

Developmental Drilling year, the modeled emissions for 

a given pollutant include both drilling and construction 

activities and these worst-case emissions 

years/scenarios are used in the air quality impact 

analysis. The inclusion of construction and drilling 

equipment in the Alternative A scenario is shown 

explicitly in Table 4-1 of the far-field modeling report 

which lists all equipment and emissions modeled for 

Alternative A. Table 4-2 of the far-field modeling report 

lists all equipment and emissions modeled for 

Alternative C. The SEIS has been revised to clarify this.
Supplemental Environmental Impact Statement

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

257

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L89-31

Continued

Wilderness 

Society, et.al.

See comment above 3.5 Air Quality & 

Meteorology

For the cumulative analysis that included RFD sources, 

a tiering approach was used to estimate impacts. The 

tiering approach is based on a ratio of total modeled 

emissions for GMT1 to a revised estimate of RFD 

emissions for this project (see Table 4-15 of the farfield modeling report). As discussed below, the 

emissions rates used for RFD sources in the 

cumulative analysis represent worst-case and worstcase allowable emissions based on available 

information. Table 4.6-3 of the SEIS includes the RFD 

sources included in the cumulative analysis and 

sources to their emissions data are included in the 

near-field and far-field AQIAs.

For six of the eleven RFD sources, emissions rates are 

based on the modeled emissions rates presented in the 

Revised RFD Source Far-Field AQIA for the GMT1 

Alternative A project. As described in Section 2.2 of 

the report, “Modeled emission rates now closely match 

what was previously used for modeling in support of air 

quality permit applications submitted to the State of 

Alaska. This is a change from relying on the annual 

permitted allowable documented in AECOM 2013 a, b. 

In most cases, this resulted in an emission rate 

increase since the modeling submitted to the State of 

Alaska relied on worst-case emissions scenarios that 

are not reflected in the source allowable.”

Emissions rates for the Brooks Range Petroleum 

Mustang RFD source are based on the permitted 

emissions presented in the Technical Analysis Report 

(TAR) that accompanied the issued minor source 

permit. The modeled emissions rates are based on 

potential to emit (PTE) rates which in general do not 

always represent the worst case short term emissions 

allowed. 
Supplemental Environmental Impact Statement

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

258

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L89-31

Continued

Wilderness 

Society, et.al.

See comment above 3.5 Air Quality & 

Meteorology

However, as discussed on Page 7 of the TAR, for those 

units where the PTE did not represent the maximum 

short term emissions, Alaska DEC imposed permit 

conditions that limited operations such that the short 

term ambient air standards were protected: 

“The modeled emission rates should generally reflect 

the maximum emissions allowed during a given 

averaging period. However, an applicant may use the 

annualized emission rate for intermittent EUs For the 

probabilistic one-hour NO2 and SO2 standards. BRPC 

assumed a shared 28 hours-per-day for EUs 06A and 

06B in their modeling analysis. Therefore, the 

Department will impose permit conditions that limit the 

combined operation of these EUs, as modeled, to 

protect the one-hour NO2, the 24-hour, three-hour, and 

one-hour SO2, and the 24-hour PM-10 AAAQS. BRPC 

also assumed a liquid fuel operational regime of 500 

hour-per year each for the dual-fuel turbine EUs, 0lA 

and 01B. Therefore, the Department will impose permit 

conditions that limit the liquid-fueled operational regime 

of these EUs, as modeled, to protect the one-hour 

NO2, the 24-hour, three-hour, and one-hour SO2, and 

the 24-hour PM-10 AAAQS.” 

Emissions rates for the four Nanushuk RFD sources 

are based on the modeled emissions rates presented in 

the 2017 draft SEIS AQIA. As discussed in Section 5.2 

of the AQIA, the “modeled EU [emission unit] locations, 

physical parameters, and emission rates, respectively, 

of each modeled EU are based upon “worst-case” 

emission scenarios for the Construction and Drilling 

and Drilling and Operations scenarios, respectively.” 

Table 5-2 presents the worst-case modeled emissions 

rates for Construction, Drilling, and Operations 

scenarios.
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L89-32 Wilderness 

Society, et.al.

The dSEIS assumes annualized hourly emissions 

from the following intermittent sources: drill rig 

cement pumps; the drilling backup power 

generator; well intervention coil tubing equipment; 

well intervention non-mobile support equipment; 

tailpipe emissions from well intervention mobile 

equipment; fugitive dust from well intervention; 

GMT2 pad emergency generator; and pigging 

venting. When determining short-term air quality 

impacts, this method will likely underestimate 

impacts. For example, if the drilling backup power 

generator is only estimated to operate 4 days per 

month and the emissions from those 48 days are 

spread out over the entire year, the 1-hour 

average NO2 impacts are likely grossly 

underestimated. Maximum hourly emissions from 

the generator would need to be modeled in order 

to ensure that hourly impacts do not exceed the 

hourly NAAQS. Annualizing emissions is only 

appropriate when looking at annual standards and 

will underestimate impacts from these sources 

when comparing impacts to short-term standards, 

such as the hourly NO2 NAAQS and daily 

average PM10 and PM2.5 NAAQS. 

3.5 Air Quality & 

Meteorology

The modeling of intermittent sources such as 

generators, drill rig cement pumps and well intervention 

sources, was conducted per the Appendix W Modeling 

Guidance memo issued by the U.S. Environmental 

Protection Agency in March of 2011 (see draft SEIS 

references). The reasoning as to why the annualization 

of the hourly rates is an appropriate modeling 

procedure is detailed in the memo. Following guidance 

procedures, using short-term emission values, the NO2 

results are not expected to be underestimated. Pigging 

venting was not treated as an intermittent source in the 

modeling.
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L89-33 Wilderness 

Society, et.al.

The dSEIS relies on monitoring data collected in 

Nuiqsut by CPAI to represent background 

concentrations for the air quality analysis. BLM 

should consult with EPA, the State, and the North 

Slope Borough regarding the appropriate 

representative background concentrations to be 

used for the dSEIS. Any data used in the analysis 

should be reviewed and approved by EPA or the 

State to ensure the data have been properly 

collected and quality-assured. In 2011, EPA 

issued a determination of appropriate background 

values for the North Slope, for use in Outer 

Continental Shelf (OCS) permitting. At the time, 

EPA did not consider the CPAI data collected in 

Nuiqsut, providing the following reasoning: [EPA] 

Region 10 is aware that air quality monitoring data 

has been collected at Nuiqsut and at the Endicott 

MPI air monitoring site but we have decided not to 

consider these data sets for determining 

background levels for the current modeling 

analyses being conducted. The data for these two 

monitoring sites have not been submitted to 

Region 10 for OCS permitting purposes therefore 

a review has not been performed by Region 10 to 

determine whether either data set is appropriate 

for PSD modeling. In 2011, EPA established the 

following appropriate representative background 

concentrations for the village of Nuiqsut, which 

are significantly higher than what is used in the 

dSEIS for GMT2: (1) a 24-hour average PM2.5 

concentration of 17 μg/m3 compared with 7.3 

μg/m3 in the dSEIS; (2) a 24-hour average PM10 

concentration of 53 μg/m3 compared with monthly 

values presented in the dSEIS ranging from 10-40 

μg/m3; and (3) a 1-hour average NO2 

concentration of 50 ppb compared with hourly 

values presented in the dSEIS

3.5 Air Quality & 

Meteorology

Thank you for the comment. The background data used 

at Nuiqsut was reviewed by EPA for 2014 where they 

issued a memo (included as a reference to the AQIA) 

detailing their review of the data and the procedures for 

which to calculate background concentrations. This 

memo was followed carefully for years 2015 and 2016. 

Also, EPA along with other members of the air quality 

practice working group reviewed the modeling protocol 

and draft reports for both the near-field and far-field 

analyses which included the background data for all 

pollutants.
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L89-33

Continued

Wilderness 

Society, et.al.

ranging from 3-25. In addition to CPAI-collected 

data, BLM should consider data from the same 

monitors EPA relied on in determining 

background values for Nuiqsut.

3.5 Air Quality & 

Meteorology

See above BLM response

L89-34 Wilderness 

Society, et.al.

Of concern, BLM has removed data from the 

monitoring dataset, as follows: 

After review of the background PM10 values, 

there were a number of hours within 2014, 2015, 

2016 where high wind events caused 

unrepresentative hourly and daily readings. 

Furthermore, the Nuiqsut Monitoring station is 

known to capture PM10 from the Nigliq Channel 

during such high wind events (AECOM, 2013b) 

and there will not be a similar channel with 

sediment near the proposed GMT2 Drill Pad, 

substantiating their removal from the background 

value analysis for PM10. The days along with 

their daily average speed that were removed from 

the PM10 background analysis are listed in Table 

4-23. 

EPA has established rigorous criteria and 

procedures for determining whether data are 

considered and treated as exceptional events and 

BLM must make a determination based on similar 

criteria and procedures prior to removing any data 

from the dataset used in determining 

representative background concentrations for the 

dSEIS. If high wind events are occurring year 

after year it would seem unlikely that the resulting 

pollutant concentrations would be considered to 

be exceptional. And if the analysis intends to 

assess impacts in Nuiqsut then it should consider 

these high wind events as representative of 

conditions there. 

3.5 Air Quality & 

Meteorology

Thank you for the comment. The removal of a few 

background PM10 values from the Nuiqsut Monitoring 

station was done following a procedure evaluating the 

daily wind speed and annual average wind speed of the 

years where the exceptional events occurred. In 

addition, the location of the monitoring station must be 

considered as the pollutant concentrations during these 

high wind events are impacted primarily by the Nigliq 

Channel. No similar structure or landscape will be near 

the proposed GMT2 Pad, further substantiating the 

removal of the data from high wind events at the 

Nuiqsut Monitoring Station, as the concentrations are 

not representative of Nuiqsut nor the proposed project 

area.
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L89-35 Wilderness 

Society, et.al.

Given that the near-field modeling analysis 

presented in the dSEIS predicts NOx and PM 

impacts that are approaching levels of the 

NAAQS (e.g., 1-hour NO2 concentrations are 

88% of the NAAQS for Alternative A and 24-hour 

PM10 concentrations are 81% of the NAAQS for 

Alternative A), it is imperative that BLM fully 

account for all sources of background air quality in 

order to ensure that additional impacts from the 

proposed GMT2 development will not cause or 

contribute to exceedances of the NAAQS. 

3.5 Air Quality & 

Meteorology

The near-field modeling included background data from 

the closest, most representative monitoring station 

(Nuiqsut Monitoring Station). That data is meant to 

account for existing nearby sources to combine with 

and determine potential impacts from GMT2 

development. Furthermore, reasonably foreseeable 

developments that are expected to impact ambient air 

that would not be included in existing background data 

such as GMT1, Nanushuk, and Mustang developments 

were included as cumulative sources to assess 

cumulative impacts to the GMT2 Project. 

L89-36 Wilderness 

Society, et.al.

BLM’s impact analysis relies on seasonallyvarying hourly background concentrations for 

NO2. Specifically, instead of adding a single 

representative background concentration to the 

modeled design value concentration, the dSEIS 

relies on a different background concentration for 

each hour of the day, by season. According to the 

near-field modeling report, the seasonally varying 

hourly NO2 background values are based on air 

monitoring data from Nuiqsut for calendar years 

2014, 2015 and 2016. For each of four 3-month 

seasons (e.g., Season 1 = December, January, 

February, etc.) each hour of the day is 

represented by the 3-year average of the 98th 

percentile value of all valid observations for that 

hour during the season. While not explicitly 

described in the dSEIS, it appears that this 

analysis method pairs the 3-year average of 98th 

percentile monitored NO2 concentrations by hour, 

in a given season, with corresponding modeled 

concentrations for that hour. This method of 

pairing data, in time, likely underestimates 

impacts by overlooking hours when higher 

background concentrations coincide with the 

highest modeled concentrations. 

3.5 Air Quality & 

Meteorology

A less conservative approach was used for the NO2 

modeling as the level of conservatism was resulting in 

over predictions of potential impacts of the GMT2 

Project. The analysis and procedures for use of the 

seasonal and hourly refinement of background NO2 

used for the dispersion modeling was proposed to the 

air quality working group members, including the EPA,

and was approved. To ensure that the data were valid, 

only valid hourly observations were included. A detailed 

account of the refinement procedure is included in the 

near-field modeling protocol. 
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L89-36

Continued

Wilderness 

Society, et.al.

And while EPA guidance discusses cases where 

this type of methodology might be used, EPA 

admits that these alternative analyses result in “a 

less conservative” estimate of impacts. This type 

of analysis could be considered appropriate if, for 

example, there is a concern about doublecounting of monitored and modeled contributions 

but this does not seem likely for GMT2. BLM must 

justify why this less conservative analysis is 

warranted. The near-field modeling report briefly 

mentions seasonal variance and describes 

consistency with the GMT1 analysis as potential 

reasons for this type of refined analysis but fails to 

provide any evidence for why, in addition to a 

seasonal variation, the modeling should consider 

diurnal variations in its analysis for GMT2. And 

even if this type of analysis is justifiable, EPA 

guidance indicates that background values should 

be based on the 3rd highest value for each 

season and hour-of-the-day combination (as 

opposed to the 98th percentile, or 8th highest 

value).

3.5 Air Quality & 

Meteorology

See above BLM response
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L89-37 Wilderness 

Society, et.al.

Fundamentally, the modeling for GMT2 should be 

used as a tool to ensure that adverse impacts will 

not occur in the future, not simply to determine 

whether or not an adverse impact occurs over the 

period of time modeled. The most protective 

approach, and one presented by EPA without 

need for further justification, would be to add the 

overall highest hourly background NO2 

concentration (across the three year monitoring 

record) to the modeled design value based on the 

maximum emissions scenario. A less 

conservative approach outlined by EPA, but one 

that still would not need further justification, would 

be to combine the modeled design value based 

on the maximum emissions scenario to the 

monitored NO2 design value, i.e., the 98thpercentile of the annual distribution of daily 

maximum 1-hour values averaged across the 

three years of monitored data (irrespective of the 

meteorological data period used in the dispersion 

modeling). The method of varying background 

concentrations seasonally and by hour-of-day 

likely results in a less conservative analysis and, 

given that the modeling shows impacts close to 

the NAAQS (i.e., 88% of the 1-hour NO2 NAAQS 

for Alternative A and 95% of the 1-hour NO2 

NAAQS for Alternative C), BLM should consider 

adopting mitigation measures aimed at minimizing 

NOx emissions from the GMT2 development.

3.5 Air Quality & 

Meteorology

Thank you for the comment. The methodology used to 

model potential 1-hour NO2 impacts used a refined 

approach, but one that is still conservative. The 

conservative assumptions that were included in the 

near-field modeling analysis are detailed in the AQIA. 

See Section 4.2.3.2, Potential Mitigation Measures 4, 6 

and 9 for proposed mitigation to reduce the emissions 

of NOx
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L89-38 Wilderness 

Society, et.al.

In addition to potential underestimates of NO2 

impacts from the use of varying background 

concentrations in the modeling, NO2 impacts may 

be further under-predicted by the use of sourcespecific in-stack NO2/NOx ratios in the modeling 

analysis. The dSEIS uses ratios based on source 

test data for all sources except for flares (for 

which the analysis uses the EPA-approved default 

value of 0.5). These in-stack ratios can be 

important parameters in the modeling and, 

therefore, BLM must ensure the ratios used are 

reasonably conservative since small changes to 

the ratios used could have a measurable impact 

on predicted concentrations. If BLM wants to rely 

on source-specific data it should ensure it is 

basing source-specific data on a reasonable 

sample size representing a wide load range for 

these sources. In the absence of sufficient data 

points, BLM should consider using the EPAapproved value of 0.5 for these sources.

3.5 Air Quality & 

Meteorology

The U.S. EPA in-stack ratio (ISR) database for NO2 

sources was used in order to determine in-stack ratios 

for all applicable sources, except where the default 

ratio was used, namely for the flares or where other 

approved and highly referenced data was available 

(i.e., Nanushuk Project AQIA). The EPA NO2 ISR 

database contains extensive data for natural gas-fired 

and diesel-fired engines, heaters, and incinerators. The 

ISR used for the GMT2 modeling was specific to tested 

sources in Region 10, and specifically Alaska. In many 

instances, the ISR was rounded up to the nearest 

tenth, so as to be conservative.
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L89-39 Wilderness 

Society, et.al.

Similar to the NO2 impact analysis, BLM’s PM10 

analysis relies on monthly-varying background 

concentrations. Specifically, instead of adding a 

single representative background concentration to 

the modeled design value concentration, the 

dSEIS relies on a different background 

concentration for each month. Absent any EPA 

guidance on the use of varying background 

concentrations for assessing PM10 impacts on 

compliance with the NAAQS, BLM must provide 

clear and convincing justification for why this type 

of variation – which would likely result in a less 

conservative analysis of PM10 impacts – is 

warranted and protective of the NAAQS. Given 

that the modeling shows impacts close to the 

NAAQS (i.e., 81% of the 24-hour PM10 NAAQS 

for Alternative A and 87% of the 24-hour PM10 

NAAQS for Alternative C), BLM should consider 

adopting additional mitigation measures aimed at 

further minimizing fugitive dust from the GMT2 

development.

3.5 Air Quality & 

Meteorology

Thank you for the comment. A monthly PM10 

background value was used for the near-field modeling 

analysis as a refined, yet still conservative, approach to 

estimate potential PM10 impacts. The use of one 

maximum background value across all days of a year 

over estimates the varying meteorological conditions of 

the year. Namely, the maximum background value 

likely to occur in the summer with dry land cover and 

higher wind speeds would over estimate impacts during 

the winter when the ground would be frozen and 

background values for particulate matter would be 

lower.

L89-40 Wilderness 

Society, et.al.

The dSEIS includes a list of 12 RFD sources and 

their estimated SO2, NOx, PM10 and PM2.5 

modeled emission rates. BLM should ensure the 

cumulative source inventory includes all existing 

and reasonably foreseeable air pollution sources 

impacting the same areas impacted by emissions 

from the proposed GMT2 project. The assumption 

that existing sources are accounted for in the 

background concentrations may not fully account 

for the cumulative impact from these sources. 

Background air monitoring data is generally 

added to the results of a cumulative source 

modeling analysis in determining compliance with 

the NAAQS.

3.5 Air Quality & 

Meteorology

The far-field air quality cumulative effects analysis was 

conducted at two sensitive Class II areas - Arctic 

National Wildlife Refuge and Gates of the Arctic 

National Park and Preserve using conservatively high 

emissions for Project and other reasonably foreseeable 

sources. Existing sources in the vicinity of the GMT2 

project area are located 200 kilometers (125 miles) or 

more from these two areas. The relative proximity of 

the existing sources to Nuiqsut as compared to the 

large distance of these existing sources to the Class II 

areas analyzes justifies the selection of the ambient air 

monitoring data from Nuiqsut to represent potential 

impacts of existing sources to air quality at these two 

areas.
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L89-40

Continued

Wilderness 

Society, et.al.

However, as discussed in EPA’s Guideline on Air 

Quality Models, if the source being modeled is not 

isolated, as is the case in this modeling 

assessment, then modeling of existing sources is 

necessary for sources that are not adequately 

represented by ambient monitoring data (e.g., 

“sources that cause a significant concentration 

gradient ... are not likely to be adequately 

characterized by monitored data due to the high 

variability of the source’s impact.”). See Section 

8.3.3 of 40 C.F.R. Part 51, Appendix W. 

Background monitoring data is limited to providing 

a historical account of concentrations observed at 

a fixed location. Whereas, modeling shows 

potential concentrations from all sources under 

maximum operating scenarios at a grid of 

receptors across the area of impact. So, it’s likely 

that monitoring data from one location at one 

point in time may not reflect what could potentially 

occur at another location under maximum 

operating scenarios and under different 

meteorological conditions. Thus, unless the BLM 

can demonstrate that the impacts of all existing 

sources are reflected in the monitoring data, and 

show that the monitoring data are reflective of 

maximum concentrations in the area and have 

been properly collected and quality-assured, the

BLM cannot use the background monitoring data 

to reflect all existing sources in or affecting the 

region.

3.5 Air Quality & 

Meteorology

See above BLM response
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L89-41 Wilderness 

Society, et.al.

Examples of existing reasonably foreseeable 

future development sources that BLM should 

consider including in the cumulative modeling 

analysis that may not be reflected in the 

background monitoring data include the following 

sources identified by Trustees for Alaska: 

...potential emissions were not included for 

Willow, Bear Tooth, Kuparuk, Putu, and 

Horseshoe. Kuparuk is an existing source of 

emissions, with some new development projects 

already under permitting, and Willow is widely 

considered to be reasonably foreseeable for 

purposes of future BLM permitting. 

3.5 Air Quality & 

Meteorology

For the purposes of quantitatively assessing cumulative 

air quality impacts from reasonably foreseeable future 

developments, the BLM was only able to include 

developments for which there was an existing 

emissions inventory. For example, the Nanushuk 

development was included in the near field modeling 

because it was far enough along in the permitting 

process to have an emissions inventory, but the Willow 

development was not included because there was not 

enough information available about the development to 

develop an emissions inventory. 

L89-42 Wilderness 

Society, et.al.

The near-field cumulative analysis includes some 

existing sources (e.g., GMT1, Mustang 

Pad, Nanushuk) but does not include construction 

impacts from these sources. BLM must include 

construction emissions from these sources unless 

it will be imposing a requirement that GMT2 

development will not occur until after construction 

is completed for GMT1 and Nanushuk. BLM 

should also consider including other sources 

listed in Table 3-13 of the near-field modeling 

report. Again, unless BLM can demonstrate that 

the cumulative impacts from these existing 

sources are reflected in the monitoring data, and 

show that the monitoring data are reflective of 

maximum concentrations in the area (i.e., 

operating and meteorological conditions that 

result in maximum concentrations in the impacted 

area) the BLM should model all nearby sources 

that impact the same area impacted by the

proposed GMT2 development. 

3.5 Air Quality & 

Meteorology

Based on the timelines for the GMT1 and Nanushuk 

Projects, the construction phases are expected to be 

complete by the time the GMT2 Project begins 

construction. Therefore, the emissions from the 

operational phases were used for these cumulative 

sources in the models. Furthermore, it is important to 

note that the emissions from the operational phase of 

the Nanushuk Project, as presented in their SEIS, are a 

magnitude larger than during the construction phase, 

therefore the emissions for that Project are 

conservatively included. 

As reasoned in the near-field modeling report, the 

cumulative sources included in Table 3-13 of the report 

that were not exclusively modeled were determined to 

be accounted for in the background data based on their 

proximity and location to the Nuiqsut Monitoring Station 

and the years of background data chosen. 
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L89-43 Wilderness 

Society, et.al.

The near-field cumulative analysis did not include 

an analysis of cumulative hazardous air pollutant 

(HAP) impacts. Specifically, the near-field 

modeling report states: HAPs were not modeled 

for cumulative sources because potential health 

effects from HAPs are assessed as an 

incremental increase due to the proposed GMT2 

project, not cumulative. BLM should assess and 

disclose the cumulative HAP impacts to the 

exposed population. In order to determine if the 

proposed development will adversely impact 

public health, BLM’s HAP assessment must be a 

cumulative one, not just an analysis of the 

incremental risk associated with the proposed 

GMT2 development, which would be imposed on 

top of existing health risks in the area. 

3.5 Air Quality & 

Meteorology

Thank you for the comment. Health risk assessments 

are conducted for project-specific emission sources 

and are not evaluated on a cumulative basis. The 

conservative nature of the HAPs near field models and 

cancer risk assessment at the maximum impacts (near 

the GMT2 Pad) and lower at Nuiqsut support the 

minimal potential for negative health effects.

L89-44 Wilderness 

Society, et.al.

The DEIS only discusses quantitative analyses for 

the cumulative far-field impacts, but no similar 

analysis for near-field impacts. Thus, there is no 

analysis of cumulative impacts to air quality in 

Nuiqsut in the dSEIS. This oversight is troubling 

considering the concerns of residents of Nuiqsut 

over air quality impacts. The Final EIS must 

contain a thorough analysis of near-field 

cumulative impacts. 

3.5 Air Quality & 

Meteorology

Cumulative sources were included in all near-field and 

far-field models as presented in the AQIA. The AQIA 

mentions the impacts at Nuiqsut are a fraction lower 

than the maximum impacts presented in both the AQIA 

and SEIS. To address the reviewer's comment, tables 

specific to the impacts at the Nuiqsut community have 

been added to Section 4.2.3.2. 
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L89-45 Wilderness 

Society, et.al.

BLM’s far-field analysis for the dSEIS shows 

adverse cumulative impacts to visibility at 

locations in the Arctic National Wildlife Refuge 

and Gates of the Arctic National Park. BLM’s 

modeling is tiered off of the modeling for GMT1 

and does not provide a complete assessment of 

the scope and magnitude of visibility impacts from 

the GMT2 development. Figure 2 of the far-field 

modeling report shows the general locations of 

the sensitive Class II receptors for the far-field 

modeling domain. The receptors are located 

along the western border of the Arctic National 

Wildlife Refuge up to the Beaufort Sea and west 

of the Village of Kaktovik and all along the 

northern border of the Gates of the Arctic National 

Park. The dSEIS states: The [] 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 4.6-7. Cumulative 

visibility impacts are small. Because a tiering 

analysis was performed, the total number of days 

where the change in visibility is above the any ddv 

threshold cannot be determined.

3.5 Air Quality & 

Meteorology

In the Federal Land Managers’ (FLMs) Air Quality 

Related Values Work Group (FLAG) 2010 guidance, 

the FLMs have defined visibility thresholds as the 

project’s 98th percentile change in light extinction 

(expressed as delta deciview [Δdv]) evaluated relative 

to 0.5 Δdv and 1.0 Δdv to determine when the project 

contributes to or causes visibility impairment, 

respectively. However, the FLMs have not established 

haze index thresholds for cumulative visibility impacts 

(FLAG 2010). Specifically, FLAG (2010) guidance 

indicates “FLMs recognize the need to assess 

cumulative impacts and the difficulties associated with 

this process...The agencies will evaluate a proposed 

new source within the context of the total impacts that 

are occurring or that potentially could occur from 

permitted/existing sources on the AQRVs of the area 

and should consider the effects of both emission 

increases and decreases.” The FLAG (2010) guidance 

further states “When reviewing modeling and impact 

analysis result, all FLMs consider frequency, 

magnitude, duration, location of impacts and other 

factors in determining whether impacts are adverse.”
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L89-45

Continued

Wilderness 

Society, et.al.

Even without a specific GMT2 analysis to assess 

the number of days where the change in visibility 

is above haze index thresholds (i.e., the maximum 

number of days that the modeled change in 

deciview (Δdv) exceeds 0.5 and 1.0), the reported 

98th percentile Δdv exceeds haze index 

thresholds for all three years modeled at both the 

Arctic National Wildlife Refuge and Gates of the 

Arctic, with Δdv as high as 1.05 in Gates of the 

Arctic and as high as 4.66 in the Arctic National 

Wildlife Refuge. In order to assess the scope and 

magnitude of the visibility impacts BLM would 

need to evaluate the number of days that exceed 

haze index thresholds and where these 

exceedances occur. 

These visibility impacts would appear to fall under 

the definition of “significant” defined in the dSEIS: 

Modeled project impacts exceeded visibility 

thresholds listed in National Park Service Federal 

Land Managers’ Workgroup guidance, perceptible 

visibility impacts will occur and be visible from 

many areas, occur many days over the course of 

a year, or be visible to a majority of people on the 

days they occur; For reference, BLM’s far-field 

modeling for GMT1 (Alternative A) indicates that 

impacts greater than the 0.5 deciview haze index 

is exceeded on 103 days at the receptors located

in the Arctic National Wildlife Refuge and on 18 

days at the receptors located in the Gates of the 

Arctic National Park.

3.5 Air Quality & 

Meteorology

The analyses suggested by the FLMs were conducted 

during the Greater Mooses Tooth Unit 1 (GMT1) project 

for both the project impacts and cumulative impacts to 

visibility. Given that the GMT2 project impacts are 

lower than (or comparable to) GMT1 and the GMT2 

cumulative impacts are derived from tiering, the 

analysis of potential cumulative source contributions 

conducted for GMT1 is applicable for GMT2. The 

GMT1 analysis included an assessment of the 

magnitude of impacts from both the project and 

cumulative sources assessing both maximum visibility 

impacts and the 98th percentile impacts, as well as the 

number of days exceeding 0.5 Δdv and 1.0 Δdv, and 

the source locations relative to the Class II area 

boundaries and receptor locations. The modelpredicted visibility impacts from the GMT2 project are 

lower than the GMT1 project and the estimated 

cumulative impacts are similar for the two projects. 
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L89-46 Wilderness 

Society, et.al.

The dSEIS directly compares modeled project 

impacts to Class II PSD increments for the Infill 

Drilling modeling scenario under Alternatives A 

and C. According to these comparisons, predicted 

modeled concentrations from project development 

alone consume as much as one third of some of 

the PSD Class II increments (e.g., for NO2 and 

PM2.5). BLM should complete a proper PSD 

increment analysis to determine how much of the 

available increments have already been 

consumed in the affected area (e.g., by GMT1 

and other sources) and how much additional 

increment is available for consumption from the 

proposed GMT2 development. Without this level 

of analysis, BLM is not adequately ensuring that 

air quality will not deteriorate more than allowed 

under the CAA. Specifically, BLM should 

complete an analysis of all increment consuming 

and increment expanding sources that impact the 

same area impacted by the proposed action, 

including an inventory of increment-affecting 

emissions (i.e., emissions from major stationary 

sources which commenced construction or 

modification after the applicable “major source 

baseline date” and emissions increases from 

minor, area and mobile sources that occurred 

after the relevant “minor source baseline date”).

3.5 Air Quality & 

Meteorology

Formal cumulative increment PSD increment 

consumption analyses are the jurisdiction of the States. 

Formal project increment consumption analyses for 

GMT2 will be conducted if required as part of the 

ADEC’s permitting process. It is not appropriate to 

conduct a formal PSD increment assessment as part of 

an EIS because under the National Environmental 

Policy Act all emissions sources are considered and 

assessed to disclose potential impacts; however, 

consumption of PSD increments only apply to a subset 

of applicable emissions sources. Therefore, an 

assessment of air quality impacts from all project 

emissions sources, as required by NEPA, compared to 

PSD increments results in a conservatively high 

estimate of the potential project impacts to PSD 

increments and is not a method that is sufficiently 

accurate to be a formal increment consumption 

analysis. 
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L89-47 Wilderness 

Society, et.al.

The dSEIS includes an inventory of emissions 

which relies on certain emissions controls and 

operating assumptions that may not be 

representative of actual operating scenarios and 

that are not reflected in the proposed mitigation 

measures for the dSEIS. For example, BLM 

makes the following statements: 

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 ...

3.5 Air Quality & 

Meteorology

Thank you for the comment. The assumptions and 

methodologies for each of the Alternative's emissions 

inventory are detailed in a report (references included 

in the Reference Section of the SEIS) including the 

justification and reasoning behind control efficiencies, 

load factors, vehicle speeds, and engine technologies. 

Furthermore, the inventories and corresponding reports 

were completed with collaboration with the proponent in 

order to accurately reflect their proposed construction, 

drilling, and operational practices. 

The list of best management practices and best 

available control technology options presented in 

Section 4.2.3 will be considered for inclusion in the 

GMT2 Record of Decision.
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L89-47

Continued

Wilderness 

Society, et.al.

Based on the schedules detailed in the emission 

inventories in Appendix B for Alternative A and 

Alternative C, sources were “turned on” in the 

model when there was a potential for emissions. 

For example, fugitive dust would not occur during 

the winter months, so in that case, the modeling 

for PM10 and PM2.5 only included June through 

September. Appropriate adjustments to the gram 

per second (g/s) modeled emission rates were 

made to ensure that, for those sources that do not 

operate continuously, emissions are not over- or 

under-stated in the AERMOD model. 

BLM does not reference many of the underlying 

assumptions used in developing the emissions 

inventories. For example, the near-field modeling 

report does not include information on assumed 

engine load factors, drilling and completion times, 

drilling engine technologies (e.g., whether engines 

meet Tier II or better engine standards), traffic 

estimates (e.g., speeds, VMT, etc.), flare gas 

volumes and destruction efficiencies, fugitive 

emission capture / destruction efficiencies, etc. 

BLM must ensure that all assumptions regarding 

operation and control effectiveness which are the 

basis for the modeling analysis are established as 

enforceable mitigation measures and 

implemented through permit stipulations. 

Otherwise, BLM should model emission sources 

under maximum possible operating conditions 

and assuming no controls. 

3.5 Air Quality & 

Meteorology

See above BLM response
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L89-48 Wilderness 

Society, et.al.

The dSEIS includes a list of Best Management 

Practices and Best Available Control Technology 

but fails to commit to implementation of these 

measures. The compulsory air quality mitigations 

found in the dSEIS include the need for an 

approved dust control plan and the use of 

reduced-sulfur fuel in diesel-fueled equipment. 

There are many other practices and control 

technologies included in the dSEIS that are 

discretionary measures and, therefore, do not 

assure measurable impact reduction. Specifically, 

in reference to the Best Management Practices 

and Best Available Control Technology, the 

dSEIS states: 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 best management practices 

and best available control technology that are 

proven emission reduction strategies and 

technologies that should be evaluated by 

ConocoPhillips.

BLM must identify the specific Best Management 

Practices and Best Available Control Technology 

that CPAI will implement. The dSEIS must include 

a more comprehensive set of required, 

measurable and enforceable mitigations to ensure 

there will be no significant impacts to air quality 

from the proposed GMT2 development. A diligent 

approach to future development in the area is 

critical given the significant air quality concerns in 

the nearby Nuiqsut community. 

3.5 Air Quality & 

Meteorology

Decisions on which mitigation measures are 

appropriate to implement are made when an agency 

issues a Record of Decision. All reasonable mitigation 

measures have been included in the Final SEIS for 

consideration in the Record of Decision. 
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L89-49 Wilderness 

Society, et.al.

Significant NOx reductions could be achieved 

through field electrification and the requirement of 

Tier 4 drill rigs and Tier 2 or better construction 

equipment. Potential fugitive dust impacts would 

be also be reduced through field electrification, as 

well as steps to minimize traffic (e.g., through 

continuous monitoring systems) and the use of 

Tier 2 or better construction equipment. Concerns 

about climate change warrant addressing fugitive 

methane emissions through implementation of 

readily-available and cost-effective technologies 

and practices to reduce fugitive emissions. In 

particular, BLM should require advanced leak 

detection and repair protocols, the use of plunger 

lifts and “smart” well monitoring, high-efficiency 

(i.e., minimum of 98% VOC destruction efficiency) 

flares coupled with auto-igniters and surveillance 

systems, the use of “green completion” practices 

that provide for the capture rather than 

combustion of saleable or otherwise usable gas, 

and the use of pump-down techniques during 

pipeline maintenance activities.

3.5 Air Quality & 

Meteorology

See section 4.2.3, Potential Mitigation Measure 6, 7, 9, 

11, and 12. These mitigation measures will be 

considered for adoption in the ROD. 
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L89-50 Wilderness 

Society, et.al.

BLM should also make clear whether GMT1 AQ 

New Mitigation measures have been effective 

thus far. They are relevant to the area’s air 

quality, and reliability of background concentration 

modeling, as well as BLM’s assumptions in its EIS 

about the effectiveness of mitigation measures. 

BLM should include, if known, to what extent 

CPAI has used natural gas or electric powered 

vehicles for construction at GMT1. More 

importantly, Nuiqsut’s air quality monitoring 

station, run by CPAI, is relied on specifically for 

modeling background values. The DEIS states 

that: “The measurements in Table 3.2-6 are 

based on data collected from 2014 through 2016 

at the Nuiqsut Monitoring Station.” BLM should 

clarify in the Final EIS whether the reports from 

the monitoring station have been provided to 

BLM, the State, NSB, and the local community 

and tribal government, and whether the technical 

reviews have affirmed the reliability of the 

monitoring station data. 

3.5 Air Quality & 

Meteorology

BLM did not require CPAI to report data regarding 

emission reductions due to mitigation measures; 

therefore BLM is not able to provide a quantitative 

evaluation of the effectiveness of these measures. For 

GMT2, BLM will require CPAI to track emission 

reductions as a result of any mitigation measures 

adopted in the ROD and report these to BLM annually 

beginning 1 year after the ROD is signed, see Potential 

Mitigation Measure 3.

Regarding the monitoring data: The GMT1 ROD did not 

specify a timeframe on air quality data review and 

reporting to BLM, North Slope Borough and State, local 

and tribal governments. BLM will propose an additional 

mitigation measure for GMT2 requiring CPAI to provide 

the monitoring data from their Nuiqsut site quarterly 

beginning with the quarter after the ROD is signed.
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L89-51 Wilderness 

Society, et.al.

Section 1.4.5 states “there are no appreciable 

changes in the physical, biological, or social 

resources associated with the project study area 

since BLM (2004).” This statement ignores 

population-level changes for multiple species, 

including caribou, which may affect the impacts of 

development and other human activities, as well 

as having implications for subsistence. 

Additionally, in Table 1.4-2 it is noted that sitespecific information on caribou migration patterns 

and habitat use have been collected, but no 

mention is made of population trends or of other 

scientific information, such as studies of caribou 

response to roads conducted in Alaska (e.g., 

Wilson et al. 2016) and elsewhere (e.g., Leblond 

et al. 2013, Panzacchi et al. 2013). Population 

fluctuations are later noted in Section 3.3.4.1, but 

presence of the data should be noted in the 

earlier table as well. Similarly, Wilson et al. (2016) 

is mentioned in Section 4.3.4.1, but it would be 

good to also reference such information in this 

table. 

3.11 Caribou Thank you for your comment. To clarify the statement 

in Section 1.4.5 should state " other than natural cycles 

and perturbations, there are no appreciable changes in 

the physical, biological or social resources associated 

with the project study area since BLM (2004).
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L89-52 Wilderness 

Society, et.al.

The Teshekpuk Caribou Herd (TCH) range map in 

Figure 3.3-1 appears to under-represent the herd 

range on the eastern edge. This figure presents a 

misleading picture of range use by the TCH, 

which does not seem to correspond to the 

telemetry-based figures of seasonal use in Map 

3.3-10 or with other previously published maps 

(e.g., Person et al. 2007, Wilson et al. 2012). 

Such a distribution may be accurate at certain 

seasons of the year, but not as a “total range” 

map, which the legend claims for this figure. This 

information is important to allow all readers to 

assess the degree to which project activities may 

affect the TCH. Furthermore, the source of data 

for this figure is not clearly indicated, making it 

difficult for readers to evaluate the quality of the 

claimed information. Figure 3.3-1 should be 

replaced with a better-supported range map, such 

as Figure 1 in Wilson et al. (2012). 

3.11 Caribou Thank you for your comment. In Section 3.3.4.1 the 

DEIS states that the 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 Coleville River delta 

and the Central Arctic Herd ranging east of the delta. 

The title for Figure 3.3-1 has been reworded to depict 

this generalization. 
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L89-53 Wilderness 

Society, et.al.

When discussing use of the project study area by 

caribou, it would be helpful to distinguish absolute 

and relative use. In the Caribou Density and 

Distribution portion of Section 3.3.4.1 it is pointed 

out that the TCH “inhabits the project area 

throughout the year, although usually at low 

densities.” Absolute densities of caribou often are 

fairly low, as caribou herds in northern Alaska 

cover vast areas. However, it would be worth 

pointing out that, according to Map 3.3-10, 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. It only 

occurs in a low use contour for two out of eight 

periods. These differences are especially notable 

because 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, and because of the recognition 

that some years winter and fall densities can be 

high in absolute, as well as relative, terms (Figure 

3.3-3). Thus, it should be made clear that the 

project area falls within locations of relatively high 

overall use by the TCH, even if absolute densities 

are low. 

3.11 Caribou Thank you for your comments. a discussion of relative 

and absolute densities has been added to section 

3.3.4.1 Density and Distribution. The following text has 

been added: "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 3.3-3)."
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L89-54 Wilderness 

Society, et.al.

Consideration of potential impacts of project 

infrastructure and activity to caribou used a 2.5-

mile (approximately 4 km) buffer distance. This is 

likely a reasonable distance for such an analysis 

based on observational studies of displacements 

covering about that distance in the nearby Central 

Arctic Herd (e.g., Cameron et al. 2005 and 

references therein). However, it should also be 

noted in the SEIS that some studies have 

reported responses to infrastructure and activity in 

caribou that cover greater distances (e.g., up to 

14 km, Boulanger et al. 2012), so it is possible 

that caribou could exhibit behavioral or 

distributional responses that extend beyond the 

analyzed area. 

3.11 Caribou Added citation the commenter recommended. Added 

text describing maximum distance at which disturbance 

has been documented. Made minor changes to 

paragraph discussing 2.5 mile buffer.

L89-55 Wilderness 

Society, et.al.

Wilson et al. (2012) is given as a reference for 

studies of behavioral response to disturbance, 

however this was not studied in that paper. 

Perhaps the reference should have been given to 

Wilson et al. (2016). 

3.11 Caribou Thank you for your comment. The citation for Wilson et 

al. (2012) on in 4.3.4.1 has been corrected. The citation 

was changed to Wilson et al (2016).

L89-56 Wilderness 

Society, et.al.

Dust deposition as a result of road construction 

and vehicle activity is mentioned, but the effects 

discussed are limited to snow-melt and timing of 

green-up. Further discussion is needed of the 

potential for changes in vegetation composition 

(not just phenology) due to dust effects (e.g., 

Myers-Smith et al. 2006) and its potential 

influence on caribou forage, such as reductions in 

lichen cover (e.g.,Chen et al 2017) – a key winter 

food source – and habitat use (e.g., Boulanger et 

al. 2012). This is important to address both in the 

Construction and Drilling & Operation sections of 

the final SEIS. 

3.11 Caribou Added the Myers-Smith et al. (2006) reference and 

added associated discussion. While the Chen et al. 

(2017) citation does contain valid discussion regarding 

the relationship between dust, soil pH, and lichen 

cover, the magnitude of dust impacts associated with a 

large diamond mine vs. the GMT2 project area and 

associated gravel roads are not synonymous (most 

notably the 1 km zone of influence for the diamond 

mine vs. the 300' zone of influence for gravel roads). 

Therefore, the citation was included but discussion was 

brief.
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L89-57 Wilderness 

Society, et.al.

Point 2 in the Roads and Vehicle Traffic section is 

overstated and contains errors. The dSEIS claims 

that “Wolfe et al. (2000) reported that, once 

caribou were initially exposed to infrastructure, 

crossing transportation corridors occurred more 

often than expected.” Wolfe et al. (2000)’s 

statement was actually in the context of 

comparing different mitigation measures –

elevated pipelines, buried pipelines, sag bends, 

etc. Wolfe et al. (2000) said that “caribou selected 

buried sections of pipeline as crossings more 

often than expected.” This distinction is important. 

The key observation is that buried pipeline 

sections facilitated caribou crossing compared to 

other mitigation approaches. This is not what the 

dSEIS statement seems to indicate. It also is an 

odd point to make to support a discussion of 

roads, since it deals with pipelines, not roads, and 

since there is no proposal of buried pipelines or 

roads associated with GMT2. The dSEIS 

statement that “roads did not have an observable 

effect on animal distribution or individual energetic 

cost” also does not seem to align with the 

conclusions of Wolfe et al. (2000). Rather, it takes 

portions of sentences in Wolfe et al. (2000) out of 

context and presents them together. An extensive 

paragraph on p.65 of Wolfe et al. (2000) 

describes altered caribou distribution, presumably 

in response to roads, other infrastructure, and 

related activity. Wolfe et al. (2000) do state that 

“infrequently travelled transportation corridors 

resulted in low numbers of road-kills, did not deter 

road crossing by caribou, and had no observable 

effect on traditional migration routes, annual 

distribution or energetic costs” (p.65). 

3.11 Caribou Revised(ing) the paragraph and text discussing vehicle 

traffic. Reexamining the literature to present a more 

concise narrative of the past and current findings 

related to caribou and roads. The commenter makes 

valid points and points out contradictions that should be 

rectified, however the literature is often conflicting itself. 
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L89-57

Continued

Wilderness 

Society, et.al.

The context of “infrequently travelled 

transportation corridors” is very important and is 

excluded from the dSEIS statement. Use of roads 

associated with GMT2 is not likely to be 

“infrequent” and thus the claim in the dSEIS is 

misleading at best. While Wolfe et al. (2000) 

mention that during periods of insect activity one 

study (Cronin et al. 1998) found no relationship 

between caribou distribution and infrastructure, 

they also point out that Cameron et al. (1995) 

found decreasing movements of caribou through 

the most intensively developed areas for the 

same herd. Again, even if the Cronin et al. (1998) 

study is taken as evidence of a lack of effect 

(which the Cameron et al. 1995 study presumably 

challenges, though the reference for this and for 

Cronin et al. 1998 are not included at the end of 

the dSEIS, making it difficult to verify), the context 

must be specified. These details are very 

important for the resulting effects on caribou and 

to omit them is not acceptable.

In summary, the claims of the dSEIS with regards 

to road habituation do not seem supported by the 

associated references and must be clarified. It 

does not seem sufficiently established that 

“habituation to the GMT1-GMT2 Access Road is 

likely, but will take time” according to the best 

available science. This also calls into question the 

assertion on that “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.”

3.11 Caribou See above BLM response
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L89-58 Wilderness 

Society, et.al.

Although the polar bear interaction plan 

mentioned above is approved by the U.S. Fish 

and Wildlife Service rather than BLM, the Record 

of Decision should require the use of USGS den 

habitat maps and den surveys to remove any 

doubt about the applicability of these mitigation 

measures. The FEIS should disclose whether 

operators and FWS have complied with these 

required mitigation measures in previous projects 

and set forth any relevant information about their 

effectiveness. The FEIS and ROD should also 

clarify that the bear interaction plan and all 

mitigation measures are required notwithstanding 

the project location being more than five miles 

from the coast; one recent FWS publication 

implies that bear interaction plans are not required 

for projects beyond the five-mile boundary.

3.13 Threatened 

and Endangered 

Species

Thank you for your comment. The polar bear 

interaction plan is a FWS requirement and requires 

FWS review and approval. Once FWS approves the 

plan BLM adopts it as is. The FWS requires use of the 

most up to date den habitat maps for all interaction 

plans and LOA applications, it is not BLM role to redo 

what FWS is required to do.
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L89-59 Wilderness 

Society, et.al.

The draft SEIS’s discussion and analysis of the 

gravel source and related impacts for the GMT2 

project is insufficient. The dSEIS contains 

numerous conflicting statements about the exact 

status of the Arctic Slope Regional Corporation 

(ASRC) gravel mine and its associated impacts. 

The dSEIS also downplays the potential impacts 

that might occur from additional gravel mining by 

seemingly indicating that any such impacts are 

existing, will not be new, or are likely to be minor. 

For example, in Table 2.1-1, BLM states that the 

“[g]eographic location of impacts would be 

confined to previously disturbed areas.” 

Elsewhere, the draft SEIS acknowledges that 

“Phase 3 is only partially permitted” and that 

“authorization would have to be obtained from the 

U.S. Army Corps of Engineers prior to gravel 

extraction for the construction of GMT2.” 

Nevertheless, the dSEIS states that the impacts 

from the mine have already been considered by 

the Corps in issuing permits for the mine. The 

dSEIS assumes that some impacts, such as 

disturbance of vegetation and habitat associated 

with removal of overburden and the creation of 

ramps would be less than for development of a 

mine in an undisturbed location. The dSEIS also 

notes that a reclamation plan is in place for Phase 

1 & 2 of the mine, but does not address any of the 

reclamation concerns associated with Phase 3.

2.1 Proposed 

Action & 

Alternatives

The gravel to be utilized for the GMT2 project will be 

authorized by the U.S. Army Corps of Engineers for the 

Phase 3 expansion currently under environmental 

review. BLM has considered the impacts of the Phase 

3 gravel mine expansion as indirect effects of a 

connected action. Additional expansion at the ASRC 

Gravel Mine Site is also included as part of the 

cumulative effects scenario as listed in Table 4.6-2, and 

was considered for all resources. 
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L89-59

Continued

Wilderness 

Society, et.al.

The public notice for the Corps of Engineers’ 

permit indicates that the anticipated gravel 

material source for GMT2 is Phase III of the 

ASRC mine site. The Corps is “currently 

evaluating a proposal to open Phase III in the 

near future, which would provide [ConocoPhillips] 

with their gravel needs for the GMT2 proposed 

project.” As recently as 2014, Phase III of the 

ASRC mine site was characterized by BLM as 

being an unproven resource, which may not have 

had sufficient gravel to support development at 

GMT1, let alone GMT2.

2.1 Proposed 

Action & 

Alternatives

See above BLM response

L89-60 Wilderness 

Society, et.al.

BLM is also required to consider the cumulative 

impacts of the gravel mine... The expansion of 

ASRC’s gravel mine is a connected action that 

BLM should fully evaluate as part of the dSEIS. 

Based on past information about gravel needs, 

BLM estimated that twenty-three acres of the 

ASRC mine site would be disturbed to provide 

gravel for GMT2. Twenty-three acres is a 

substantial area. This additional twenty-three 

acres of disturbance will occur as a direct result of 

this project and its gravel needs. BLM cannot 

simply assume for purposes of its NEPA analysis 

that any such impacts have already been 

considered and addressed elsewhere. An 

expansion of the mine will be necessary to obtain 

sufficient gravel for the GMT2 project, and that 

expansion has yet to be permitted.

2.1 Proposed 

Action & 

Alternatives

Mining the gravel to be utilized for the GMT2 project 

from the ASRC Mine Site is considered a connected 

action in the SEIS. That is why the mine site is 

included within the boundary of the project study area, 

and why applicable resource sections identified direct 

and indirect impacts to the resource resulting from 

gravel mining at the site. Additional expansion at the 

ASRC Gravel Mine Site is included as part of the 

cumulative effects scenario as listed in Table 4.6-2, and 

was also considered in the impact analysis for all 

resources. 
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L89-61 Wilderness 

Society, et.al.

BLM should not assume that simply because the 

ASRC mine is already in existence, that mining 

gravel will be less impactful than at another 

location. Indeed, the Clover material site is 

located closer to the proposed GMT2 pad, 

potentially decreasing some aspects of 

construction impacts (e.g., noise, dust, traffic, 

emissions). Further, Clover is located in a less 

environmentally sensitive area outside the Colville 

River Delta. BLM should evaluate and compare 

potential impacts from both mine sites as part of 

this analysis. 

2.1 Proposed 

Action & 

Alternatives

While the BLM recognizes that some impacts 

associated with utilizing the ASRC mine site are 

potentially less than developing a new mine in an 

undisturbed location, it is not for this reason that other 

gravel sources were not considered in the action 

alternatives. Instead, the reason why the ASRC mine 

site was considered for all alternatives is because it 

was in the process of being authorized by the U.S. 

Army Corps of Engineers, a cooperating agency to the

GMT2 SEIS. BLM NEPA guidance states that "when 

working with cooperating agencies, your range of 

alternatives may need to reflect the decision space and 

authority of other agencies, if decisions are being made 

by more than one agency." Through our cooperating 

agency process, the BLM determined that use of the 

ASRC Mine Site was appropriate for all alternatives, 

and best meets the purpose and need of the proposed 

action.

L89-62 Wilderness 

Society, et.al.

Gravel mining has very serious impacts that 

should be fully considered in the SEIS. Open pit 

mines require extensive overburden removal —

for example, a large amount of vegetation and soil 

needed to be excavated to reach suitable gravel 

in the mines created for Kuparuk. The resulting 

overburden stockpile disturbs tundra, and the 

gravel pit itself causes permanent changes to the 

area’s thermal regime due to “thaw bulbs” forming 

in the permafrost around the unfrozen water 

during flooding. Indirect effects such as these 

have led some researchers to approximate that a 

one acre (0.4 ha) gravel pit may impact as much 

as 25 acres surrounding the site.

3.2 Soils & 

Permafrost

The gravel pit is on land owned by ASRC. They have 

decided to expand the pit into Phase 3 to continue to 

provide gravel for many projects, and while this 

expansion would occur regardless of the construction 

of GMT2, GMT2 cannot go forward without the 

expansion of the gravel pit. The gravel pit is therefore 

considered a connected action to GMT2 and is 

analyzed in the GMT2 SEIS. The expansion of the pit 

was analyzed by the Corps of Engineers in a separate 

EA and is incorporated by reference. The effects of 

expanding the pit have also been analyzed as part of 

GMT2 as required by NEPA for connected actions.
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L89-63 Wilderness 

Society, et.al.

There are also likely to be other significant 

impacts to the community and surrounding area, 

such as noise impacts, that have not been fully 

accounted for in the draft SEIS. The draft SEIS 

states that there is no noise data for the gravel 

mine available and only provides estimates of the 

potential noise levels. The estimated noise level in 

Nuiqsut from mine blasting is anticipated to be 

around 112.8 decibels and, closer to the source, 

could be closer to 140.3 decibels. A level of 110 

decibels is at the average human pain threshold 

and is equivalent to industrial noises such as a 

riveting machine, steel mill, or turbo-fan aircraft 

taking off from approximately 200 feet away. A 

decibel level of 140 is equivalent to the noise on 

an aircraft carrier deck. This level of industrial 

noise has the potential to cause significant 

disturbances to Nuiqsut and wildlife across a vast 

area. The dSEIS notes the presence of these 

noises from the gravel mine, but fails to analyze 

the potential direct, indirect, and cumulative 

effects they might have on people and wildlife in 

the surrounding area. 

3.6 Acoustical 

Environment

Noise impacts from blasting and other project-related 

sources are evaluated in EIS Sections 4.4.2 

Sociocultural systems and 4.3.4 Mammals. 
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L89-64 Wilderness 

Society, et.al.

Aircraft activity is a significant concern, 

particularly to North Slope communities, and this 

topic needs significantly greater analysis and 

discussion in the final GMT2 SEIS. BLM should 

do a better job of quantifying and assessing the 

total number of flights occurring in the region as 

part of its cumulative impacts analysis. A starting 

point would be to summarize aircraft activity 

collected by BLM (and required from all NPRA 

permittees reliant on aircraft) by: 1) user group 

(e.g. basic science research (non-industry), 

agency monitoring, industry ecological 

baseline/monitoring, pipeline inspection, 

exploration and development access (e.g. staking, 

stick-picking) site access, etc., agency 

administrative flights, permitted visitors and other 

significant users; 2) month and 3) aircraft type. 

These data should be evaluated for the periods of 

construction, drilling, and production operations. 

BLM then should use this information to evaluate 

the cumulative effects of all aircraft use (i.e., for 

development and non-development purposes). 

4.0 Cumulative 

Effects Projects 

and Methodology

Discussion of the impacts of aircraft is covered in detail 

in Section 4.4.5 Subsistence.

L89-65 Wilderness 

Society, et.al.

Finally, BLM should use this information to 

develop an aircraft transportation plan for 

northeast NPRA that reduces aircraft activity and 

increases flight sharing among agencies, industry, 

and others. 

4.2 Mitigation See Section 4.4.6, Subsistence, Potential Mitigation 

Measures 2, 3, 4, and 5.
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L89-66 Wilderness 

Society, et.al.

BLM also needs to clarify its analysis of the 

potential number of flights and flight impacts. The 

dSEIS’s estimates of the number and types of 

flights under each alternative over time are 

confusing. For example, in Table 2.5-4, it is 

unclear why the construction years overlap 

between years 1–2 and 2–3. This makes it 

unclear which flights are associated with the 

overlapping year, Year 2. It is also unclear 

whether the number of flights listed is for the total 

number of years or are per year. BLM should also 

clarify why it does not estimate there will be any 

DC-6 flights from Deadhorse to Alpine.

2.1 Proposed 

Action & 

Alternatives

The reference to years and specific timing has been 

addressed and will be reflected in the final document. 

Those clarifications are also reflected in a revised 

version of Appendix B.

L89-67 Wilderness 

Society, et.al.

The dSEIS should do more than just tally the 

number of flights associated with each alternative. 

BLM should consider the flight routes, whether 

repeated take offs and landings occur in 

concentrated locations, and the time of year when 

they take place to evaluate the impact on 

subsistence ...

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

At this time, the BLM and the applicant can only 

estimate the number of flights by fixed-wing and rotorwing aircraft. Flight routes are extremely variable, are 

dependent on the weather, and environmental or 

monitoring studies required. More specific flight 

estimates are provided to the BLM before every 

summer season, and actual flights that occurred are 

reported at the end of the season. 
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L89-68 Wilderness 

Society, et.al.

The dSEIS should do more than just tally the 

number of flights associated with each alternative. 

BLM should consider the flight routes, whether 

repeated take offs and landings occur in 

concentrated locations, and the time of year when 

they take place to evaluate the impact on 

subsistence as well as migration, calving, and 

other sensitive life phases. BLM also should 

consider the ecological sensitivity of the location 

of landings and takeoffs. 

3.11 Caribou Thank you for your comment. The BLM requires 

authorization for all aircraft take off and landings in the 

NPRA. Along with the authorization is a list of 

stipulations that the permittee is required to follow. A 

list of permittees include Federal and State agencies, 

North Slope Borough Dept. of Wildlife, industry, 

companies working on infrastructure, Legacy well clean 

up, research, recreation etc. BLM also conducts 

Section 7 consultation due to 3 ESA threatened 

species. BLM requires permittees to estimate the 

number of take off and landings prior to authorization 

and record the actual number during activity. Flight

data collected by the BLM includes location, dates, and 

timing of take off and landings. Part 1. Take off and 

landing numbers given in the EIS represent the 

applicants best estimate of those flights needed and as 

such they are concentrated in the area of proposed 

development. Part 2. The seasonality is documented 

in the authorization. Public meetings, Resource 

Advisory Council, Subsistence advisor program call in 

program during summer to notify residents of daily air 

traffic are used in the evaluations. Part 3. Caribou 

monitoring studies are being conducted by Industry, the 

NSB, ADGF, and BLM to monitor herds during different 

times of the year to help monitor the health of the herd. 

All of this information was considered in the analysis in 

the environmental consequences chapter of the DSEIS. 

It is important to note that the BLM does not tract the 

route, altitude or speed of aircraft. 

L89-69 Wilderness 

Society, et.al.

The dSEIS should also do a better job of 

quantifying the number of flights associated with 

studies, both for the GMT2 project and overall in 

the region. It is unclear if the totals related to 

helicopter landings include the number of landings 

required to support environmental studies.

2.1 Proposed 

Action & 

Alternatives

The number of flights detailed in Appendix B are 

directly related to the applicant's activity. They are not 

separated by activity as some landings may cover 

operation mission as well as carry personal that 

conduct the related studies. These charts do not 

contain additional information or other flight operations 

not relative to the proposed project. The DEIS does 

address the number of flights in Section 4.4.4.2 
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L89-7 Wilderness 

Society, et.al.

BLM also acknowledges that there are potential 

concerns related to thermokarst and use of the 

ramps that are likely to create problems with 

overuse, but has failed to analyze whether there 

are additional ramp locations, designs, or other 

mitigation measures that could address such 

problems. BLM cannot tout the ramps and 

pullouts as providing benefits to the community, 

while at the same time acknowledging the 

significant problems and uncertainty around 

whether such mitigation measures are likely to be 

effective. BLM also acknowledges that there are 

likely to be lingering concerns with public safety 

and traffic on the road. BLM should require that 

ConocoPhillips adopt further mitigation and 

design measures to address the significant safety 

concerns likely to result from both heavy industrial 

use and community use of the road. 

4.2 Mitigation See Section 4.4.5 Subsistence, Potential Mitigation 

Measure 7: Road Pullouts and Access Ramps along 

the GMT2 Road.

L89-70 Wilderness 

Society, et.al.

As discussed in the cumulative impacts section, 

BLM needs to quantify the total number of flights 

occurring related to special studies to assess the 

cumulative impacts on the region. For example, 

ConocoPhillips’ latest application for studies in the 

Reserve estimates that it will conduct 7,844 

helicopter takeoffs and landings in summer 2018 

alone. BLM should better quantify the number of 

flights and potential impacts from the flights 

associated with these studies in the Reserve. 

4.0 Cumulative 

Effects Projects 

and Methodology

GMT2 was originally approved for development as CD7 in 2004 under the Alpine Satellite Development Plan 

EIS. The purpose of the SEIS is to supplement the 

2004 analysis and to include new information relevant 

to environmental concerns that have bearing on the 

proposed action or its effects. The GMT2 SEIS tiers to 

and incorporates by reference previous NEPA analysis 

including the cumulative effects analysis in the ASDP 

EIS (2004), NPR-A IAP (2012) and GMT1 SEIS (2014). 

The estimated number of flights for the 5-year 

authorization requested by CPAI in the summer of 2018 

were analyzed in in both the IAP and GMT1. CPAI 

reports the total combined numbers in association with 

the summer activities authorization pursuant to the ESA 

consultation requirements in determining level of take.
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L89-71 Wilderness 

Society, et.al.

BLM should also assess whether all of those 

activities actually require aircraft access or if there 

are other practical and less impactful alternatives 

such as boat or foot access, even if such 

alternatives are less convenient. 

4.2 Mitigation The project proponent is aware of the impacts of 

aviation use, and has worked closely with Nuiqsut to 

reduce the number of flights in the general vicinity of 

the community. The number of flights estimated for the 

various alternatives in the SEIS reflect the amount 

anticipated as necessary to carry out the actions as 

proposed within that alternative. The BLM has included 

three potential mitigation measures that would 

additionally serve to assist in minimizing the impacts of 

helicopter use to residents of Nuiqsut. See Section 

4.4.5 Subsistence, Potential Mitigation Measures 2, 3 

and 5.
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L89-72 Wilderness 

Society, et.al.

BLM has also failed to adequately account for and 

address the potential impacts of climate change 

on the region and on the proposed project. The 

dSEIS provides almost no analysis of the potential 

impacts of climate change on the project and the 

need for additional mitigation measures or design 

features to address those vulnerabilities. This is 

particularly important for a project like this, which 

is located in the Arctic and is likely to be 

susceptible to the effects of climate change. 

Although the current administration repealed the 

Council on Environmental Quality’s guidance on 

how agencies should consider greenhouse gas 

emissions and the effects of climate change in 

environmental impact statements, that in no way 

excuses agencies from continuing to meet their 

statutory obligations to consider these impacts 

and effects for purposes of the National 

Environmental Policy Act. 

The dSEIS provides only a bare-bones overview 

of the potential impacts climate change might 

have on the region and project area and no

analysis of whether additional measures are 

necessary to account for likely changes. For 

example, the dSEIS notes that permafrost extent 

is predicted to decrease significantly by 2100 and 

the increase in the depth of the active layer in the 

permafrost is expected to have a negative effect 

on the ability of the soils to carry loads. However, 

there is no analysis of whether the project is 

designed in a way that will appropriately address 

and mitigate against permafrost degradation 

issues. 

3.7 Climate 

Change

In the GMT2 Supplemental EIS, the BLM tiers to and 

incorporates by reference previous NEPA analysis 

including the ASDP EIS (2004), NPR-A IAP (2012) and 

GMT1 SEIS (2014). The impacts of climate change on 

the resources in the Arctic is analyzed in section 3.2.4, 

Climate Change. CEQ regulations direct that: Agencies 

shall incorporate material into an environmental impact 

statement by reference when the effect will be to cut 

down on bulk without impeding agency and public 

review of the action. The incorporated material shall be 

cited in the statement and its content briefly described. 

No material may be incorporated by reference unless it 

is reasonably available for inspection by potentially 

interested parties within the time allowed for comment. 

(40 CFR 1502.21). The text provided in the GMT2 SEIS 

incorporates by reference and summarizes the text 

from the GMT1 SEIS and includes updated information 

where such information was available (i.e., most up to 

date information on minimum sea ice extent). Our 

understanding of climate change and its effects on the 

Arctic are not significantly different than what is stated 

in the GMT1 SEIS. Regarding project infrastructure 

design, the project applicant has adjusted design 

standards over the years to ensure a conservative

safety margin. One example of this is changing road 

thickness from an average 5-foot thickness to a 

minimum 5-foot thickness. 
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L89-73 Wilderness 

Society, et.al.

The dSEIS is also completely lacking the level of 

site-specificity necessary to understand and 

assess the potential impacts of climate change on 

this project and each of the alternatives. The 

generalized statements about potential impacts 

that might occur across a broad region are not 

sufficient to fully understand the likely impacts 

from and to this project, and how those impacts 

might be exacerbated by climate change. 

3.7 Climate 

Change

In the GMT2 Supplemental EIS, the BLM tiers to and 

incorporates by reference previous NEPA analysis 

including the ASDP EIS (2004), NPR-A IAP (2012) and 

GMT1 SEIS (2014). The impacts of climate change on 

the resources in the Arctic is analyzed in section 3.2.4, 

Climate Change. CEQ regulations direct that: Agencies 

shall incorporate material into an environmental impact 

statement by reference when the effect will be to cut 

down on bulk without impeding agency and public 

review of the action. The incorporated material shall be 

cited in the statement and its content briefly described. 

No material may be incorporated by reference unless it 

is reasonably available for inspection by potentially 

interested parties within the time allowed for comment. 

(40 CFR 1502.21). The text provided in the GMT2 SEIS 

incorporates by reference and summarizes the text 

from the GMT1 SEIS and includes updated information 

where such information was available (i.e., most up to 

date information on minimum sea ice extent). Our 

understanding of climate change and its effects on the 

Arctic are not significantly different than what is stated 

in the GMT1 SEIS. Regarding project infrastructure 

design, the project applicant has adjusted design 

standards over the years to ensure a conservative 

safety margin. One example of this is changing road 

thickness from an average 5-foot thickness to a 

minimum 5-foot thickness. 

L89-74 Wilderness 

Society, et.al.

Further, BLM must take into account the impacts 

of the project on local subsistence hunters in light 

of the fact that communities are already being 

heavily impacted by climate change.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Text has been added to discuss the impacts of Climate 

Change to Section 4.6.8 Cumulative Impacts to Social 

Systems, Sub-section 4.6.8.2 Sociocultural Systems 

and Sub-section 4.6.8.9 Subsistence.
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L89-75 Wilderness 

Society, et.al.

BLM should analyze the potential impacts of 

climate change on each of the alternatives to 

determine how that alternative should be 

designed or how mitigation measures should be 

incorporated into that alternative to address the 

potential impacts from climate change in a region 

that is experiencing the effects of climate change 

first-hand. BLM should also assess, based on 

things like the permafrost conditions and 

hydrology in the vicinity of the specific 

alternatives, how these impacts are likely to play 

out over time in the project area. BLM has tools, 

such as the Rapid Ecoregional Assessment for 

the North Slope, that it should use to forecast 

potential changes that could impact each of the 

alternatives and the region. 

3.7 Climate 

Change

In the GMT2 Supplemental EIS, the BLM tiers to and 

incorporates by reference previous NEPA analysis 

including the ASDP EIS (2004), NPR-A IAP (2012) and 

GMT1 SEIS (2014). The impacts of climate change on 

the resources in the Arctic is analyzed in section 3.2.4, 

Climate Change. CEQ regulations direct that: Agencies 

shall incorporate material into an environmental impact 

statement by reference when the effect will be to cut 

down on bulk without impeding agency and public 

review of the action. The incorporated material shall be 

cited in the statement and its content briefly described. 

No material may be incorporated by reference unless it 

is reasonably available for inspection by potentially 

interested parties within the time allowed for comment. 

(40 CFR 1502.21). The text provided in the GMT2 SEIS 

incorporates by reference and summarizes the text 

from the GMT1 SEIS and includes updated information 

where such information was available (i.e., most up to 

date information on minimum sea ice extent). Our 

understanding of climate change and its effects on the 

Arctic are not significantly different than what is stated 

in the GMT1 SEIS. Regarding project infrastructure 

design, the project applicant has adjusted design 

standards over the years to ensure a conservative 

safety margin. One example of this is changing road 

thickness from an average 5-foot thickness to a 

minimum 5-foot thickness. 
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L89-76 Wilderness 

Society, et.al.

The dSEIS includes a discussion of impacts to 

climate and quantifies greenhouse gas 

(GHG) emissions from the proposed GMT2 

development but fails to seriously consider any 

potential climate change mitigation. Methane is a 

prime contributor to short-term climate change 

over the next few decades and a prime target for 

near-term GHG reductions. And, in fact, there are 

many proven technologies and practices already 

available to reduce significantly the methane 

emissions from oil and gas operations. These 

technologies also offer opportunities for significant 

cost-savings from recovered methane gas. 

Indeed, reducing methane emissions is important 

to not only reduce potential impacts to the climate, 

but to prevent waste of the oil and gas resource 

itself and the potential loss of economic value, 

including royalties. 

There is a large body of scientific work 

documenting the adverse impacts to public health 

and welfare from climate change caused by 

greenhouse emissions, such as methane. In 

addition, many of the proven methane emission 

controls for the oil and gas sector also reduce 

VOCs and HAPs, as noted above in the air quality 

section. The associated air quality benefits that 

result from reductions in VOC and HAP emissions 

are a huge co-benefit of methane reduction 

technologies. 

3.7 Climate 

Change

BLM has included two potential mitigation measures

related to preventing unnecessary emissions of 

methane, see Section 4.2.3.2. All reasonable mitigation 

measures have been included in the Final SEIS for 

consideration in the ROD. 
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L89-77 Wilderness 

Society, et.al.

The dSEIS notes that 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, and that this conveyance of 

surface ownership would also result in the transfer 

of associated mineral resources to ASRC. BLM 

states that once this likely transfer occurs, ASRC 

(as the new lessor) may enforce, or adopt similar, 

lease stipulations and Best Management 

Practices on the conveyed lands. This 

assessment of ASRC’s obligations is inconsistent 

with the plain language of BLM’s NPR-A leasing 

regulations, which state “If the regional 

corporation assumes administration of a lease 

under paragraph (a) or (b) of this section, all lease 

terms, BLM regulations, and BLM orders in effect 

on the date of the assumption continue to apply to 

the lessee under the lease. All such obligations 

will be enforceable by the regional corporation as 

the lessor until the lease terminates.” There is 

nothing in these regulations indicating that ASRC 

has the option to follow, or not follow, all of the 

applicable lease stipulations if such a conveyance 

takes place. Further, the dSEIS environmental 

impacts analysis assumes that all of these 

existing protections are in place for the life of the 

GMT2 development project. Therefore, BLM must 

ensure through its conveyance process that 

ASRC expressly assumes all of these stipulations 

and BMPs. 

3.17 Land Use Changed the wording, however note that BLM has no 

authority to ensure that the lease requirements are 

followed. The BLM cannot dictate how a private 

landowner manages their land once it is conveyed. 
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L89-78 Wilderness 

Society, et.al.

BLM should explain the final SEIS what 

infrastructure will be needed on the GMT2 pad, or 

if any additional equipment will need to be added 

to the GMT-1 pad, for purposes of separating and 

measuring mineral interests. As exploration wells 

are drilled, BLM will establish the participating 

area boundaries to allocate production for 

royalties between federal and private leases. 

Rather than install additional metering equipment 

at GMT-2, BLM may require three-phase 

hydrocarbon to be separated and measured at the

GMT-1 pad, which may increase the level of 

activity, and therefore power needs, at GMT-1. 

The additional processing and equipment needed 

for royalty measurement should be explained, and 

any impacts analyzed, in the dSEIS. 

2.1 Proposed 

Action & 

Alternatives

Section 2.4.3 in Features Common to All Alternatives 

describes all on-pad facilities anticipated for work on 

the GMT2 pad. No additional metering equipment 

beyond what is described in this section is required at 

GMT2. All required metering of fluids from GMT2 will 

occur at GMT1 or CD5, both of which are currently 

engineered to handle the volume anticipated from 

GMT2.

L89-79 Wilderness 

Society, et.al.

The presence of roads has a significant impact on 

caribou, especially in combination with pipelines. 

Habitat fragmentation from roads can impede 

caribou migratory patterns, foraging options, 

access to calving grounds, and ultimately lead to 

herd decline. For these reasons, roads can 

reduce the number of caribou accessible to Arctic 

communities. BLM should utilize fragmentation 

metrics and assess road-related indirect impact 

areas in acres in tables for all alternatives in 

addition to footprint estimates in acres. 

3.11 Caribou The DSEIS relies on existing literature to explore and 

discuss the implications of habitat fragmentation.
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L89-8 Wilderness 

Society, et.al.

BLM has also not adequately addressed the 

potential health concerns should there be some 

sort of disaster, such as a blowout, fire, or large 

spill. BLM simply notes in the dSEIS they are a 

possibility, but provides no analysis of how such a 

disaster might impact public health, particularly 

given the close proximity of the community to 

development. Community members have 

significant concerns about the potential health 

impacts from such a disaster. BLM should fully 

assess the potential ramifications to human health 

and the environment that would occur if there 

were such a disaster. 

3.18 Public 

Health

The risk of a catastrophic event such as a blowout is 

evaluated in Section 4.5. Such an event is extremely 

unlikely, and the impact analysis for public health 

focuses on the likely impacts resulting from the planned 

GMT2 development. 

L89-80 Wilderness 

Society, et.al.

roads can have long-term impacts on bird habitat. 

Several studies have concluded that populations 

of bird species decrease along roads due to noise 

disrupting the communications key to mating and 

warning, as well as general disturbances. This 

impact should be further analyzed within the 

SEIS. 

3.10 Birds Thank you for your comment. Text has been added in 

Chapter 4 of the bird section to address your comment

L89-81 Wilderness 

Society, et.al.

In correspondence on the CD5 Alpine Satellite 

expansion project, the U.S. Fish and Wildlife 

Service expressed its concerns regarding road 

development in the Colville Delta. The letter 

explained that the hydrology and geomorphology 

of the Colville Delta is driven by sediment 

deposition and erosion, and a road would 

decrease the flow of water moving downstream 

during flood events. This would result in the 

deposition of sediment upstream of the road and, 

even with water moving though culverts, habitats 

on the downstream side could become sediment 

starved. This issue also must be examined for the 

GMT2 project. 

3.9 Fish No other streams within the GMT2 project area are 

similar to the hydrology, geomorphology, and sediment 

regime of the vast Colville River and its delta (the 

largest river system in the AK Arctic), which is dynamic 

due to sediment deposition and erosion. The GMT2 

gravel road may cross one stream (under Alternative A 

only), which is a small tundra stream outlet to Lake 

M9925. This and other tundra streams in the area do 

not have notable sediment loads, even during the 

highest flows at spring breakup.
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L89-82 Wilderness 

Society, et.al.

To protect the underlying permafrost, the 

proposed gravel road to GMT2 “would be a 

minimum of 5-feet high with side slopes of 

2:1...[and] 32-feet wide.” Such a high road with 

steep slopes has posed challenges for local 

hunters seeking to cross the road via 

snowmachines and sleds even with the 

construction of ramps. This problem should be 

further analyzed and addressed in the final SEIS. 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

BLM has included a potential mitigation measure 

requiring ConocoPhillips to work with the community of 

Nuiqsut to identify the location and design specification 

for the access ramps and pull outs along the GMT2 

road. See Section 4.4.6, Potential Mitigation Measure 7

L89-83 Wilderness 

Society, et.al.

In a conversation with Dr. Tom Ravens, Professor 

of Civil Engineer and Associate Dean for 

Research at the University of Alaska Anchorage 

(UAA), engineer Lois Epstein of The Wilderness 

Society learned that there are potentially three 

alternative road designs that might reduce the 

adverse impacts of road height and side slopes 

on both caribou reluctant to cross and hunters: 

1. Thermal insulation to protect permafrost: If 

insulation significantly lowered the height of 

roads, hunter crossings would not be as 

problematic and much less gravel would be 

required which would have economic and 

environmental benefits. Such insulation would 

need to be biodegradable and non-spreading so it 

would not harm the tundra if portions of it were 

scattered either during installation or removal. 

UAA staff have a patent-pending prototype for 

such insulation made of fungi.

4.2 Mitigation BLM discussed your suggestions with CPAI. With 

regard to using fungus-based insulation, CPAI is aware 

of the research, and has contributed funds to support 

the project. They believe that an effective insulation 

could reduce project impacts and project costs. 

However, the insulation needs to be something that is 

commercially available. While the idea of an insulation 

other than Styrofoam merits research and 

development, the fungus-based material being 

explored by UAA is not a viable option for GMT2 which 

is scheduled to begin construction in January 2019. 

Caribou are not known to prefer existing bridges on the 

North Slope as road crossings, so the benefit of adding 

more is questionable. Construction of additional bridges 

would increase the overall project footprint and would 

increase the cost of the project. Bridges and 

underpasses are ill-suited to the large, heavy 

equipment and drill rigs that will travel the road to 

GMT2. For these reasons, it is impractical to add such 

structures at this stage, which would result in project 

delays. Placement of thermosyphons would need to be 

within the toe of the road side-slope to ensure proper 

function. This would make the road impassable for 

large loads, including drill rigs and other camps. This, 

as well as the impact of thermosyphons on drifting 

snow and performing maintenance on the road, make it 

not a viable option for the GMT2 road.
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L89-83

Continued

Wilderness 

Society, et.al.

2. Constructing bridge/underpass structures for 

caribou and hunters: These types of structures 

have been effective in lower latitude regions to 

facilitate ungulate passage under roads.

3. Passive or active thermosyphons to protect 

permafrost: “A thermosyphon (or thermosiphon) is 

a device that transfers heat via natural convection 

in a fluid. The natural convection is driven by 

gravity with the colder, denser fluid flowing 

downhill and the warmer, less dense fluid flowing 

back up.” Because the vertical thermosyphons 

would have to be relatively close together, 

however, this approach might pose sight-line 

problems for caribou.

We recommend that BLM work with 

ConocoPhillips to evaluate these options, 

including trying to implement one or more of them 

on a portion of any new road that is built to GMT2. 

If successful, these strategies might greatly 

reduce the impacts on caribou and hunters for 

future roads in the Arctic. 

4.2 Mitigation Thermosyphons are used on the pad near heated 

buildings and well houses. BLM discussed your 

suggestions with CPAI. With regard to using fungusbased insulation, CPAI is aware of the research, and 

has contributed funds to support the project. They 

believe that an effective insulation could reduce project 

impacts and project costs. However, the insulation 

needs to be something that is commercially available. 

While the idea of an insulation other than Styrofoam 

merits research and development, the fungus-based 

material being explored by UAA is not a viable option 

for GMT2 which is scheduled to begin construction in 

January 2019. Caribou are not known to prefer existing 

bridges on the North Slope as road crossings, so the 

benefit of adding more is questionable. Construction of 

additional bridges would increase the overall project 

footprint and would increase the cost of the project. 

Bridges and underpasses are ill-suited to the large, 

heavy equipment and drill rigs that will travel the road 

to GMT2. For these reasons, it is impractical to add 

such structures at this stage, which would result in 

project delays. Placement of thermosyphons would 

need to be within the toe of the road side-slope to 

ensure proper function. This would make the road 

impassable for large loads, including drill rigs and other 

camps. This, as well as the impact of thermosyphons 

on drifting snow and performing maintenance on the 

road, make it not a viable option for the GMT2 road. 

Thermosyphons are used on the pad near heated 

buildings and well houses.. 
Supplemental Environmental Impact Statement

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

303

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L89-84 Wilderness 

Society, et.al.

The dSEIS states that “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; therefore, Class I wastes 

would be transported offsite for disposal at 

CD1/Alpine Central Processing Facility, Prudhoe 

Bay drill site 4 grind and inject, or another 

appropriate facility.” This means that many truck 

trips which are disruptive to caribou and other 

wildlife would occur without GMT2 pad injection. It 

is unclear to us how carefully ConocoPhillips and 

BLM have looked for an “acceptable disposal 

horizon.” Because on-site injection would be 

preferable environmentally, this option needs to 

be thoroughly examined before granting a GMT2 

authorization to drill. 

2.1 Proposed 

Action & 

Alternatives

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 towards 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 via truck 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. SEIS 

text has been updated to address this comment. 

L89-85 Wilderness 

Society, et.al.

The field office should require Conoco to measure 

and report natural gas waste from venting, flaring 

and leaks and require methane waste capture 

technologies with the approval of any APD 

associated with this GMT2 project area. In the 

absence of the protections established by the 

2016 methane rule such steps are necessary in 

order to ensure the agency fulfills its federal 

obligation to reduce waste of natural gas. 

...

The revision of the 2016 waste rule along with the 

deficient Alaska state regulations means 

inadequate measures are in place to ensure the 

BLM meets its waste prevention mandate. The 

field office should seize the opportunity to reduce 

waste and increase federal revenues by ensuring 

adequate waste minimization measures are 

required for all oil and gas development 

associated with the GMT2 project area. 

4.2 Mitigation See Section 4.2.3 Atmospheric Environment, Potential 

Mitigation Measure 3: Minimize Methane Waste. 
Supplemental Environmental Impact Statement

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

304

Comm # Commenter 

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Comments Comment 

Category Code

Comment Response

L89-86 Wilderness 

Society, et.al.

Inexplicably, the draft SEIS ignores two significant 

and recent blowouts – also known as losses of 

well control – on the North Slope. One of these 

blowouts occurred 18 miles northeast of Nuiqsut 

in 2012 from a Repsol exploration well and the 

other occurred in 2016 from a BP production well. 

Blowouts need to be addressed in the SEIS as 

they pose significant safety and environmental 

concerns... BLM should include documentation of 

the cause and effects of these two important 

incidents in chapter 4 of the final SEIS. BLM’s 

analysis should include discussions with the 

Alaska Oil and Gas Conservation Commission on 

the agency’s latest efforts to prevent blowouts and 

how they will apply to GMT2. 

3.19 Hazardous 

Materials Spills

Added discussion of past blowouts and summary of 

blowout response plan to section 4.5.

L89-87 Wilderness 

Society, et.al.

Although it is unlikely, a worst-case blowout could 

require weeks or even months to bring under 

control, requiring mobilization of a large quantity 

of specialized equipment and personnel to the 

well site and potentially requiring one or more 

relief wells to be drilled. Relief wells are a costly, 

time-, labor- and support-services-intensive 

process. While these efforts are underway, the 

total area contaminated and heavily impacted 

could expand. The final SEIS needs to consider 

the potential effects of a worse-case scenario 

blowout to workers and the surrounding 

environment. 

3.19 Hazardous 

Materials Spills

Added discussion of past blowouts and summary of 

blowout response plan to section 4.5
Supplemental Environmental Impact Statement

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

305

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L89-88 Wilderness 

Society, et.al.

The state of Alaska has both leak detection and 

leak shut-down requirements for crude oil 

transmission pipelines in its regulations, however, 

the pipeline carrying crude oil from GMT1 to 

GMT2 is not considered a “crude oil” pipeline 

since it also carries gas and produced water. We 

urge BLM to require ConocoPhillips to meet the 

requirements of 18 AAC 75.055 (see footnote 

below) including prompt leak detection, e.g., using 

external leak detection for these types of multiphase pipelines, daily flow verification, weekly 

aerial surveillance (ConocoPhillips currently is 

performing visual surveillance only “at least 

monthly,” p. 39 of the draft SEIS), and the ability 

to stop flow within one hour of release detection. 

4.2 Mitigation See Section 4.5 Impacts of Oil, Saltwater and 

Hazardous Materials Spills, Potential Mitigation 

Measure 2: Leak Detection and Leak Shut Down 

Requirements. 
Supplemental Environmental Impact Statement

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306

Comm # Commenter 

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Comments Comment 

Category Code

Comment Response

L89-9 Wilderness 

Society, et.al.

BLM’s analysis under Section 810 of the Alaska 

National Interest Lands Conservation Act 

(ANILCA) is deeply flawed and fails to account for 

the full scope of potential impacts to subsistence 

users and the community of Nuiqsut. 

BLM found that the GMT2 project may 

significantly restrict subsistence based on the 

redistribution of resources, but completely failed 

to address the potential impacts on access to 

subsistence resources. Significant restrictions to 

access have consistently been identified as one of 

the primary concerns related to development 

projects in the region. BLM’s failure to find there 

would be a significant restriction on access to 

subsistence resources — and complete failure to 

address why there is no significant restriction to 

subsistence access — is completely at odds with 

the discussion in the dSEIS and with previous 

determinations related to subsistence impacts. 

BLM has previously identified access impacts and 

the overall reduction in Nuiqsut’s subsistence use 

areas as one of the most significant impacts from 

development in the region. In the GMT1 decision, 

BLM found there would be a significant restriction 

to subsistence for the village of Nuiqsut based on 

the reduced access to subsistence use areas, 

reduced availability of subsistence resources, and 

hunter avoidance of industrial areas. 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

BLM's ANILCA 810 guidance, derived from case law, 

specifies that the evaluation must address a limitation 

on the access of subsistence users to harvestable 

resources, and that the evaluation includes only 

physical or legal barriers. While the access road, pad, 

and pipeline are potentially all physical barriers, the 

ability for subsistence users to utilize the road itself, 

utilize ramps across the road, and travel underneath 

the pipeline all contribute to finding that the 

infrastructure does not constitute a physical barrier or a 

legal barrier to access for subsistence uses. This and 

other input received on the draft evaluation have been 

considered in the final ANILCA 810 determinations. 
Supplemental Environmental Impact Statement

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

307

Comm # Commenter 

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Comments Comment 

Category Code

Comment Response

L89-9

Continued

Wilderness 

Society, et.al.

Some of the specific concerns included hunter 

avoidance of infrastructure that would extend well 

beyond the direct GMT1 project area; noise, 

traffic, and infrastructure that could impact the 

availability of key resources such as caribou, 

wolves, and wolverine; the number of caribou use 

areas in the GMT1 project area; the diversion of 

caribou from the road and traffic; increased 

helicopter impacts on caribou hunting; increased 

risks to hunters and increased investments in 

time, money, fuel, equipment, and hunting 

success; and numerous sociocultural and 

socioeconomic impacts. These concerns are 

identical to and will be magnified by the GMT2 

project. The GMT1 project acknowledged that 

these impacts would only increase in light of 

GMT2 and other developments in the region. 

BLM also recognized the potential circling effect 

of development for purposes of the cumulative 

impacts analysis under Section 810: 

“Development of GMT2 would, with the combined 

footprint of existing development in the Colville 

Delta, west of the Colville (CD5 and GMT1), and 

the reasonably foreseeable development in the 

Bear Tooth Unit/Willow area, encircle Nuiqsut with 

development to the north, northwest, west, and 

southwest.” These same impacts to subsistence 

will occur in light of GMT-2 — and not just in the 

cumulative case. These impacts should have 

been fully considered in the Section 810 analysis. 

Impacts to access and the loss of traditional 

subsistence areas are repeatedly identified as 

one of the primary unavoidable adverse impacts 

to subsistence in the dSEIS. 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

See above BLM response
Supplemental Environmental Impact Statement

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

308

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L89-9

Continued

Wilderness 

Society, et.al.

Despite the repeated acknowledgement in the 

dSEIS and previous decision documents that 

impacts to subsistence access and reduced 

availability of hunting grounds are some of the 

most significant impacts from development in the 

region, BLM completely failed to make any sort of 

finding related to the impacts of GMT2 on access. 

BLM needs to explain its findings as to the 

potential impacts of the project on subsistence 

access. BLM’s failure to address the impacts to 

subsistence access and to make a positive finding 

as to the potential for the GMT2 project to restrict 

subsistence access is inconsistent with BLM 

guidance related to Section 810... BLM failed to 

make a finding as to whether GMT2 would 

significantly restrict access.

BLM’s failure to find that there may be a 

significant restriction to subsistence from the 

GMT2 project is inconsistent with the standards in 

its guidance on when it should make a positive 

finding. It would be contrary to the overwhelming 

weight of the evidence, acknowledged through the 

GMT2 dSEIS, for the agency to make a negative 

finding as to subsistence access. BLM also failed 

to evaluate the significance of the impact or to 

articulate its findings as to the factors outlined in 

the instruction memorandum. As noted earlier in 

the comments, BLM completely failed to include 

impact criteria and overall rankings assessing the 

potential impacts of the project in the dSEIS. The 

Section 810 analysis similarly does not include 

any sort of analysis of those criteria with regard to 

the potential impacts to access.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

See above BLM response
Supplemental Environmental Impact Statement

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

309

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L90-1 Native Village 

of Nuiqsut

NVN asks that BLM not permit the GMT2 project 

at this time. Development is happening too fast 

and the full effects of the Alpine Satellite Field, 

including the Greater Mooses Tooth One (GMTl) 

project have not been fully felt or understood by 

the community. While predicted within the final 

GMTl 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 GMTl's construction is complete. 

2.1 Proposed 

Action & 

Alternatives

As stated in Sections 1.3 and 1.4, the BLM is unable to 

postpone processing the GMT2 Application for Permit 

to Drill based on regulatory requirements in NPR-A 

found at 42 USC Section 6506(a). Deferral of a project 

authorization would be inconsistent with the directive in 

the Naval Petroleum Reserves Production Act to 

expeditiously carry out an oil and gas leasing program 

and the rights ConocoPhillips acquired with the subject 

leases to reasonably develop the oil and gas within 

those lease tracts. GMT2 was originally approved for 

development as CD-7 in 2004 under the Alpine Satellite 

Development Plan EIS. The purpose of the SEIS is to 

supplement the 2004 analysis and to include new 

information relevant to environmental concerns that 

have bearing on the proposed action or its effects. 

EIS's are inherently speculative documents, because 

their purpose is to identify potential impacts that could 

occur from a proposed action using the best available 

information at the time of the analysis, so that an 

informed decision can be made. This information 

includes scientific studies, input from stakeholders, as 

well as identified impacts that have resulted from 

similar actions that could be reasonably inferred to 

occur from the proposed action. The BLM believes that 

we have accurately described the comprehensive suite 

of potential impacts that could occur from the proposed 

action, and alternatives to that action, sufficient to make 

a reasoned decision. 
Supplemental Environmental Impact Statement

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Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L90-11 Native Village 

of Nuiqsut

As exploration and development activities 

continue to inundate the community, residents are 

forced to travel greater distances for subsistence 

purposes. In addition to being costlier, this 

additional travel presents increased risks to 

hunters' safety. We request that search and 

rescue resources, such as radio communications, 

be made available to help ensure hunters ability 

to travel safely across the landscape. 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

The following new potential mitigation measure has 

been added to Section 4.4.2.8. 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 Also, the 

Subsistence Mitigation section (4.1.2.6) describes the 

State of Alaska NPR-A Impact Mitigation Program;

Nuiqsut is able to submit applications to that for 

increased funding for Search and Rescue to respond to 

these impacts. 

L90-12 Native Village 

of Nuiqsut

A comprehensive Health Impact Assessment 

(HIA) should be completed for our community. 

This HIA should analyze the cumulative health 

impacts of oil development within the region. 

This analysis, among other topics, should include 

such topics as the impacts of development on 

subsistence, and how the health benefits of 

subsistence resources and practices has been 

compromised by development. This analysis 

should be carried out by a trusted independent 

party. 

3.18 Public 

Health

A Health Impact Analysis was done for GMT2, the 

results of which are in Appendix G. Appendix G 

provides the Baseline Human Health Summary for the 

North Slope, including a description of current 

subsistence practices and summarizes Areas of 

Vulnerability as well as Areas of Resilience/Success. 

Cumulative effects for Public Health are found in 

Section 4.6.8. 
Supplemental Environmental Impact Statement

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Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L90-13 Native Village 

of Nuiqsut

Nuiqsut's traditional subsistence use areas are 

places of great traditional importance where 

abundant resources can be harvested. These 

places are culturally irreplaceable and are 

incrementally (but consistently) being changed by 

oil exploration activities and outright lost to 

development projects. As we have advocated for 

in the past, we want remaining, high-value 

subsistence use areas to be protected for future 

generations. 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

The BLM strives to find the balance between fulfilling 

the legislative mandate of allowing oil and gas leasing, 

exploration and development within the National 

Petroleum Reserve in Alaska, while at the same time 

protecting other resources and uses to the maximum 

extent possible. As a petroleum reserve, oil and gas 

leasing is the primary allowable use of the area, and 

other resource uses or protections must be consistent 

with the ability for oil and gas activity to occur. Existing 

protections for high-valued subsistence use areas 

include: Lease Stipulation/BMP K-1, which includes 

set-backs along rivers, including a 2-mile setback on 

the western shore of the Colville River, a 3 mile setback 

on both shores of Fish Creek, and 1/2 to 1 mile 

setbacks along most other major rivers utilized for 

subsistence purposes; various restrictions in the 

established special areas, including the Teshekpuk 

Lake Special Area; and restrictions and protections in 

major coastal waterbodies managed by the BLM.

L90-14 Native Village 

of Nuiqsut

A particular area of importance, among others, is 

the Colville (Kuukpik) River. This river not only 

provides numerous subsistence resources, but it 

is also a major transportation route for our hunters 

to access resources across the landscape. With 

progress towards the finalization of the Colville 

River access road, which has taken decades to 

advance and will be completed at great cost, we 

believe that protecting the Colville is particularly 

important. As we have stated before, if the Colville 

River access road and boat ramp is going to be 

meaningful into the future, the areas it enables 

access to must be protected. 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

The BLM management of the Colville River is limited to 

the western bank of the river, which is the boundary of 

the NPR-A. Lease Stipulation/BMP K-1 (a) specifies a 

2-mile setback from the boundary. Within this setback, 

permanent oil and gas facilities, including gravel pads, 

roads, airstrips, and pipelines are prohibited, with the 

exception of essential road or pipeline crossings 

perpendicular to the river, and roads that are 

constructed for public transportation systems (i.e., such 

as the Colville Access Road mentioned by the 

commenter). 
Supplemental Environmental Impact Statement

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L90-15 Native Village 

of Nuiqsut

NVN would like a meaningful role in the 

stewardship of these protected subsistence use 

areas. This role can involve both management 

and monitoring efforts that provide employment 

opportunities for residents of the community. 

These jobs can be paid for by a compensatory 

mitigation fund. 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

The Subsistence Mitigation section (4.1.2.6) describes 

the State of Alaska NPR-A Impact Mitigation Program; 

the City of Nuiqsut is able to submit applications for this 

and could partner with NVN. 

L90-2 Native Village 

of Nuiqsut

Moreover, and as NVN has recently shared with 

the Army Corps of Engineers (ACOE), we are 

inundated with development proposals and 

planning exercises. 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 of development 

will be more understood and NVN will have 

greater time to consider the risks of development 

and rigorously engage in this proposed project. 

4.1 Stakeholder 

involvement and 

tribal 

engagement

GMT2 was originally approved for development as CD7 in 2004 under the Alpine Satellite Development Plan 

EIS, as was GMT1 (as CD-6). As described in Section 

1.4 Purpose and Need for Federal Action, under federal 

statutes the BLM is required to issue the GMT2 permit 

for oil development in the NPR-A and cannot choose 

the No-Action alternative.
Supplemental Environmental Impact Statement

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313

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L90-3 Native Village 

of Nuiqsut

Exploration and development activities within the 

region continue to compromise our irreplaceable 

subsistence use areas. Currently, within just the 

boundaries of the NPR-A, more than 1.4 million 

acres of our communities' traditional subsistence 

use area has been leased to oil companies. 

Several hundred thousand more acres have been 

leased on adjacent state lands. With active 

exploratory drilling to the east, west, and south, 

our community Is on the verge of being 

surrounded by oil and gas development. BLM has 

taken no actions to meaningfully protect 

subsistence resources and our remaining 

subsistence use areas from the impacts of oil 

development within the region. 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

The BLM strives to find the balance between fulfilling 

the legislative mandate of allowing oil and gas leasing, 

exploration and development within the National 

Petroleum Reserve in Alaska, while at the same time 

protecting other resources and uses to the maximum 

extent possible. As a petroleum reserve, oil and gas 

leasing is the primary allowable use of the area, and 

other resource uses or protections must be consistent 

with the ability for oil and gas activity to occur. Under 

the NPR-A IAP, 11 million acres within the reserve are 

unavailable for oil and gas leasing. These areas 

comprise those lands that support and sustain the most 

vulnerable resources utilized for subsistence, namely 

the core calving areas for the Teshekpuk Lake and 

Western Arctic caribou herds. In addition, there are 

numerous protections that apply to rivers, lakes, and 

coastal waterbodies, all of which support and sustain 

fish, waterfowl, and subsistence use and transportation. 

L90-4 Native Village 

of Nuiqsut

We have significant concerns about how the 

GMT2 project will further compromise subsistence 

practices within the community. The development 

of the GMT2 project 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. 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Under Section 4.4.5 Subsistence, Sub-Sections 4.4.5.4 

and 4.4.5.5 contain detailed descriptions of impacts 

related to oil and gas activity and infrastructure derived 

from recent subsistence studies and communicated to 

the BLM by Nuiqsut subsistence users. 
Supplemental Environmental Impact Statement

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Comments Comment 

Category Code

Comment Response

L90-5 Native Village 

of Nuiqsut

As you know, BLM's ANILCA 810 Analysis is 

required to review how a development could 

reduce the abundance of subsistence resources, 

reduce the availability of resources because of 

changes to use areas and distribution patterns, 

and limit access to subsistence resources. We are 

particularly concerned that BLM's analysis did not 

find that GMT2 will impact access to subsistence 

resources. This is particularly troubling as this 

was a finding of the GMTl project, and GMT2 will 

only compound impacts to subsistence. We 

request that BLM more rigorously analyze the 

impacts of GMT2 by comprehensively building on 

the GMTl findings. Within the SEIS, BLM should 

describe in greater detail and clarity how this 

project impacts subsistence, sociocultural 

systems, and our community's environmental 

justice. 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

BLM's ANILCA 810 guidance, derived from case law, 

specifies that the evaluation must address a limitation 

on the access of subsistence users to harvestable 

resources, and that the evaluation includes only 

physical or legal barriers. While the access road, pad 

and pipeline are potentially all physical barriers, the 

ability for subsistence users to utilize the road itself, 

utilize ramps across the road, and travel underneath 

the pipeline all contribute to finding that the 

infrastructure does not constitute a physical barrier or a 

legal barrier to access for subsistence uses.

L90-6 Native Village 

of Nuiqsut

We do not feel that the human health impacts of 

GMT2 are accurately and comprehensively 

captured within the DSEIS. Consideration is 

lacking on the various social and environmental 

systems that contribute to our community's health 

and wellness. For example, how exploration and 

development activities impact resident's mental 

health should be considered in greater detail.

3.18 Public 

Health

Appendix G provides the Baseline Human Health 

Summary for the North Slope, including a description of 

mental health and summarizes Areas of Vulnerability 

as well as Areas of Resilience/Success

L90-7 Native Village 

of Nuiqsut

Furthermore, how impacts to subsistence 

practices alter food security and nutrition 

should be examined more thoroughly. 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Text has been added to the discussion regarding 

concerns about food security and the importance of the 

Fish Creek area to Section 4.4.5.2 Summary of Nuiqsut 

Subsistence Uses.
Supplemental Environmental Impact Statement

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Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L90-8 Native Village 

of Nuiqsut

We also continue to have serious concerns about 

air quality. As residents, we have personally 

experienced and observed the impacts of oil 

development on air quality within our region; and 

we do not believe that BLM is doing enough to 

ensure that our community's air is safe. 

Independent outside experts should design and 

conduct the necessary analysis to study the air 

quality of our community and the surrounding 

region. This analysis will take time and is another 

reason why we believe GMT2 should be delayed.

3.5 Air Quality & 

Meteorology

BLM is aware of the air quality concerns in the 

community. The federal and State air permitting 

process is designed to prohibit any significant 

deterioration of air quality. As part of the GMT2 NEPA 

analysis, the projected air quality impacts for GMT-2 

sources have been assessed and been found to be 

minimal. Nonetheless, BLM is considering mitigation 

measures to guarantee continued air quality monitoring 

to alleviate concerns, see Section 4.2.3.2, Potential 

Mitigation Measures 1-11

L90-9 Native Village 

of Nuiqsut

As we stated above, we firmly believe that GMT2 

should not be permitted at this time. However, we 

also believe that meaningful actions to lessen and 

offset the impacts of development should be 

considered within the SEIS.

Throughout this process, BLM has failed to 

meaningful engage NVN and the larger-Nuiqsut 

community about employing the full mitigation 

hierarchy (avoidance, minimization, and 

compensatory offsets) for the purposes of this 

project. BLM efforts to minimize the impacts of 

this project are often too simplistic and fail to 

meaningfully address the actual impacts of 

development. While the proposed project's 

impacts should always be minimized to the 

greatest extent possible, oil projects around our 

community and within the Arctic always have 

unavoidable impacts. These unavoidable impacts 

must be offset with meaningful and lasting 

compensatory mitigation actions. 

4.2 Mitigation The Native Village of Nuiqsut is a cooperating agency 

to the SEIS. As such, they have been involved in all 

phases of the preparation of the SEIS, including 

reviews afforded to cooperating agencies. In addition, 

the BLM has conducted numerous GMT2 meetings and 

teleconferences with NVN pursuant to USDOI and BLM 

tribal consultation policy. NEPA Guidance and CEQ 

regulations for EIS analyses require that all relevant, 

reasonable mitigation measures that could improve the 

project are to be identified, even if they are outside the 

jurisdiction of the agency [40 CFR 1502.14(f), 40 CFR 

1502.16(h)]. However, the decision to adopt mitigation 

is not required, and is at the discretion of the decisionmaker. BLM Instructional Memorandum 2018-093 

Compensatory Mitigation issued July 24, 2018 

supersedes all previous policies regarding 

compensatory mitigation, and forbids the BLM from 

requiring compensatory mitigation from public land 

users. 
Supplemental Environmental Impact Statement

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L91-1 State of 

Alaska, Alaska 

Department of 

Environmental 

Conservation 

(ADEC)

Page 7, second full paragraph: “The Secretarial 

Order further directed the BLM Draft Regional 

Mitigation Strategy for the NPR‐A to be revised 

and to include public comment where necessary; 

and it directed the BLM to henceforth revise the 

IM No. 2008‐204, which outlines the policy for the 

use of offsite mitigation for authorizations issued 

by the BLM. The 2008 is to be used as guidance 

on mitigation for the foreseeable future.” It is not 

clear if this last sentence is meant to read “The 

revised Instructional Memorandum 2008‐204 is to 

be used as guidance....” Also, Secretarial Order 

3360 called for IM No. 2008‐204 to be revised by 

late January 2018, but this agency is not aware of 

its availability. Please clarify. 

1.1 Executive 

Summary & 

Introduction

Text has been revised for clarity.

L91-10 State of 

Alaska, Alaska 

Department of 

Environmental 

Conservation 

(ADEC)

Pages 14 and 15: 

"Depending on the resulting migration patterns for

the Teshekpuk Lake Herd, and the areas of reloc

ation for other subsistence species, the communiti

es of Barrow ..." Reviewers familiar with the 

area may understand that references to Barrow in 

earlier analyses refer to the recently renamed 

community of Utqiagvik. Recommend including a 

footnote or other clarifying feature to clarify the 

relationship and in what context one name is used 

instead of the other throughout the document.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Text has been revised to address Barrow renamed 

Utqiagvik.
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L91-11 State of 

Alaska, 

Division of 

Mining, Land, 

and Water 

(DMLW)

Page 32: Has an analysis been done regarding

wellhead spacing and gravel pad subsidence? 

The smaller the spacing, the greater the likelihood 

for accelerated subsidence do to the warmer oil 

traveling through the permafrost at the wellheads. 

This in turn leads to potential issues with wellhead 

instability, increased gravel resource needs for 

maintenance, and higher oil spill potential. While 

smaller wellhead spacing reduces localized 

wetland impacts, it may not be beneficial in the 

long term. The section mentions the use of 

thermosyphons at infrastructure to maintain 

thermal stability, but these are not depicted on the 

Appendix A, Sheet 21 drawing and most likely 

these would not be located at the wellheads due 

to their high cost. Please clarify.

2.1 Proposed 

Action & 

Alternatives

Text has been revised to clarify that the proposed 

action includes the use of insulated conductors and 

thermosiphons on the well pad to reduce subsidence 

and protect structural components from freeze-thaw 

damage. The proposed well spacing and use of 

insulation has been engineered to avoid wellboregenerated subsidence, and this spacing has been used 

successfully at other Alpine satellite pads.

L91-12 State of 

Alaska, 

Division of 

Mining, Land, 

and Water 

(DMLW)

Page 34 and Appendix A Sheet 23: The pipeline 

set up appears to be slightly off balance, but the 

weight of each pipeline on the HSM is not 

detailed. There are a few examples of where an 

imbalance in HSM weight relative to the VSM 

have caused HSMs to break from their VSMs, 

particularly during winter months with high snow 

loads. Weight and balance on the HSMs should 

be taken into consideration as necessary to 

protect the structural integrity of the pipeline 

system.

2.1 Proposed 

Action & 

Alternatives

The horizontal support members (HSM) proposed 

between GMT1 to GMT2, and currently existing 

between GMT1, CD5, and CD4N have been 

engineered to ensure balance is maintained and the 

HSMs can withstand a wide variety of ice conditions 

and snow loads, including unusually heavy and/or wet 

snow loads.
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L91-13 State of 

Alaska, 

Division of 

Mining, Land, 

and Water 

(DMLW)

Page 34: What criteria are being used to 

determine when ice road construction may begin 

on BLM‐managed land?

2.1 Proposed 

Action & 

Alternatives

The 2013 NPR-A IAP Record of Decision adopted a 

suite of performance-based best management 

practices that specify the objective to be achieved, and 

the requirement/standard that an operator must 

demonstrate in conjunction with an authorization for 

activity. Best Management Practice C-2(a) requires that 

ground operation shall be allowed only when frost and 

snow cover are at sufficient depths to protect the 

tundra. An operator wanting to obtain an authorization 

for access to public lands must demonstrate to the BLM 

how they will satisfy these requirements. This has 

taken multiple forms. Some operators have installed 

thermistors to monitor frost depth, some monitor onthe-ground conditions. In general, the BLM uses the 

industry standard of 12 inches of frost depth and 6 

inches of snow, which research has shown is sufficient 

to project the tundra in coastal areas of the North 

Slope. However, the performance-based nature of the 

BMP allows for operators to propose a start date 

based on the nature of their project, technology and 

equipment employed, and by explaining how they will 

meet the requirement of the BMP. 

L91-14 State of 

Alaska, Alaska 

Department of 

Environmental 

Conservation 

(ADEC)

Page 40, first paragraph: The reference to 

ADPDES General Permit AKG332000 for 

domestic wastewater discharges is incorrect. The 

correct general permit is AKG572000 ‐ Small 

Publicly‐Owned Treatment Works and Other 

Small Treatment Works.

1.1 Executive 

Summary & 

Introduction

Correction was made as suggested.

L91-14 State of 

Alaska, Alaska 

Department of 

Environmental 

Conservation 

(ADEC)

Page 40, first paragraph: The reference to 

ADPDES General Permit AKG332000 for 

domestic wastewater discharges is incorrect. The 

correct general permit is AKG572000 ‐ Small 

Publicly‐Owned Treatment Works and Other 

Small Treatment Works.

2.1 Proposed 

Action & 

Alternatives

Changed in document.
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L91-16 State of 

Alaska, 

Department of 

Fish and Game 

(ADFG)

Population dynamics: The Draft SEIS indicates 

that the most data shows the Teshekpuk Caribou 

Herd (TCH) population declining; however, the 

2017 TCH photocensus illustrates that the 

population has increased since 2015. It is 

apparent that the herd increased between 2015 

and 2017, which conclusion is corroborated by the 

Alaska Department of Fish and Game (DFG) 

survey and inventory program for this herd. The 

gap between photocensuses included one of the 

lowest overwinter mortality rates of adult cows 

measured in this herd. Additionally, both 

parturition and short‐yearling recruitment rates 

were above average both years. These factors 

are likely a result of many variables, which may 

include milder winters, cooler summers, and an 

age‐class structure that was weighted with more 

reproductively prime animals.

3.11 Caribou Thank you for your comment. 2017 caribou 

photocensus data for the TCH and CAH has been 

incorporated into the SEIS. Fig. 3.3-1 has been 

updated to include 2017 data and a new figure 

depicting TCH abundance from 1990 through 2017 be 

added. 

L91-17 State of 

Alaska, 

Department of 

Fish and Game 

(ADFG)

Page 148, paragraph 3: "...but it is rare east of 

Point Utqiagvik (formerly Barrow)..." The 

community of Barrow was renamed Utqiagvik; 

the landform, Point Barrow, was not part of the 

renaming. This issue is also present in Table 3.4‐

2 Regional history synopsis in the first row, under 

Synopsis. 

3.13 Threatened 

and Endangered 

Species

Thank you for your comment. The place name error 

has been corrected in the T&E section as indicated.
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L91-18 State of 

Alaska, Office 

of Project 

Management 

and Permitting

Page 176, second paragraph: It is unclear why 

the in‐depth discussion of the NPR‐A Impact 

Mitigation Grant Program is reserved to 3.4.4.2 

Regional Economy: North Slope Borough (p 173, 

last paragraph). As described in that section, the 

program serves as an important source of funding 

for Nuiqsut's local economy; however, this section 

fails to describe the substantial amount of funds 

awarded to date or the projected increase in funds 

that will be available for the express purpose of 

mitigating impacts associated with oil and gas 

development in NPR‐A. The program is 

implemented by the State of Alaska, Department 

of Commerce, Community, and Economic 

Development (DCCED), which can provide both 

historical and current information regarding the 

eligibility of the City of Nuiqsut to receive funds. 

DCEED reports awarding grants directly to the 

City of Nuiqsut from 2005‐2017, with three 

applications recommended for funding in 2018, 

and awarding grants to the North Slope Borough 

for projects that benefit(ted) Nuiqsut during the 

same period, including five applications 

recommended for funding in 2018. Recommend 

revising this section to reflect the most current 

information available.

3.16 Economy Revised and incorporated updated information for 

section on "Local Economy: Community of Nuiqsut" 

and oil and gas operations impacts.

L91-19 State of 

Alaska, 

Department of 

Fish and Game 

(ADFG)

Page 190: Table 3.4‐8. Nuiqsut annual cycle of 

subsistence activities. The table draws from a 

number of different sources, including ADFG 

subsistence reports. While the seasonal round of 

subsistence activities is accurately represented, 

what method was used to characterize activities 

into high, moderate, and low categories? Please 

clarify.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

SRB&A added a footnote explaining the methods used 

to develop this table.
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L91-2 Department of 

Natural 

Resources 

Division of Oil 

& Gas (DOG)

Page 9: The Alaska Department of Natural 

Resources must also authorize transportation of 

hydrocarbons from a federal unit into a state unit, 

a likely scenario if a processing facility is not 

constructed near GMT2 

1.1 Executive 

Summary & 

Introduction

Updated text in Introduction to reflect this requirement.

L91-20 State of 

Alaska, 

Department of 

Fish and Game 

(ADFG)

Page 192, first paragraph: "In 2014, the most 

recent comprehensive study year for Nuiqsut, the 

highest rates of harvest participation were for 

caribou (66 percent of households), geese (66 

percent), broad whitefish (60 percent), 

cloudberries (aqpik) (55 percent), and Arctic cisco 

(52 percent)." There appears to be some 

inconsistency in comparing resource general 

categories (geese) and specific species. It is 

unclear how the 66% household harvest 

participation for geese in general was calculated 

as it was not published in the final report. White‐

fronted geese were among the highest harvested 

species (60% of HH). Please clarify. Page 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

It is true that these data (household participation for 

geese or for white-fronted geese) are not available in 

the referenced table; however, they are available on 

the ADF&G’s Community Subsistence Information 

System (CSIS). SRB&A has revised the text by citing 

the CSIS which contains the data, and to change 

“geese” to “white-fronted geese” for consistency. 

L91-22 State of 

Alaska, Alaska 

Department of 

Environmental 

Conservation 

(ADEC)

Page 228, eighth paragraph: “Furthermore, recent 

research into the transportation of pollution 

nanoparticles (not regulated by EPA) from oil and 

gas activities in Prudhoe Bay (Kolesar et al. 2017) 

indicates that there are potentially forms of 

pollution that are not currently monitored in 

Nuiqsut.” This statement could be misleading 

because the EPA regulates particulate matter 

(PM), commonly referred to as PM 10 and PM 

2.5. The numbers following the PM refers to the 

size of the particles in micrometers. The EPA 

regulates PM 2.5 pollution, which consists of 

particles 2.5 micrometers and smaller, which 

includes ultrafine and nanoparticles. The existing 

monitoring site in Nuiqsut does monitor for PM 

2.5. Please revise accordingly.

3.18 Public 

Health

Omitted. See also response to L88-15
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L91-23 State of 

Alaska, Alaska 

Department of 

Environmental 

Conservation 

(ADEC)

Page 243, fifth paragraph: Proposed New 

Mitigation Measure 1: Alaska Natural Resources 

Conservation Service Level II Soil Survey. It is not 

clear how a soil survey can be considered a 

mitigation measure for the proposed activity. As 

indicated in the objective, the survey would 

establish baseline conditions; however, to 

effectively mitigate impacts, the measure should 

identify what action(s) would be taken when 

subsequent surveys reveal an XX% departure 

from baseline conditions. Please provide 

additional detail on how this monitoring effort 

addresses specific impacts associated with the 

proposed GMT2 development.

3.2 Soils & 

Permafrost

This data will help delineate changes based on 

development activities from general changes from 

natural conditions because there is presently no way to 

quantify impacts or current conditions. The data will 

help improve future engineering, design and permitting 

decisions, thus mitigating future impacts. Until we 

know the magnitude of the changes it is difficult to set 

trigger points for adaptive management actions

L91-24 State of 

Alaska, Alaska 

Department of 

Environmental 

Conservation 

(ADEC)

Page 250, first paragraph: "In addition to the BLM 

stipulations and best management practices, 

project activities that could impact water 

resources will be subject to federal, state, and 

local permit 

requirements." This sentence implies that BLM sti

pulations and BMPs are more stringent than feder

al and state permit requirements. The order of the

regulatory authorities should be reversed in this 

sentence so that the reader knows that federal 

and state requirements exist to avoid or reduce 

the potential impacts and that BLM stipulations 

and BMPs are also an important part of this 

protections scheme.

3.4 Water 

Resources

The sentence was modified as suggested.

L91-25 State of 

Alaska, 

Division of 

Mining, Land, 

and Water 

(DMLW)

Page 264: Limiting GMT2 acreage, while a 

worthwhile goal, should be balanced against the 

predicted wellhead subsidence with 20‐foot 

wellhead spacing.

4.2 Mitigation The wellhead spacing of 20 feet has been used 

effectively by CPAI on other development pads on the 

North Slope. CPAI will use thermosyphons and 

insulated conductors to reduce the potential for 

subsidence and protect structural components from 

freeze-thaw damage.
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L91-26 State of 

Alaska, Alaska 

Department of 

Environmental 

Conservation 

(ADEC)

Page 265: The table entry for mitigation under the 

topic "Lakes and Ponds" notes that "Traffic and 

dust control measure for roads and construction 

areas to avoid the impact on nearby water 

bodies." Please identify if a Dust Control Plan will

be required, and which agency will be responsibl

e for compliance and enforcement of this mitigatio

n measure.

3.4 Water 

Resources

The Dust Control Plan is part of the Alpine Erosion 

Control Plan - Greater Mooses Tooth. This plan, as part 

of CPAI's approved application, will be incorporated 

into future BLM monitoring inspections.

L91-27 State of 

Alaska, Alaska 

Department of 

Environmental 

Conservation 

(ADEC)

Page 272: This table and the accompanying text 

do not tell the non‐technical reader what the 

calculated cancer risk is for Nuiqsut residents for 

these hazardous air pollutants. At a minimum, 

please explain the use of numbers expressed in 

scientific notation for the non‐technical reader.

3.5 Air Quality & 

Meteorology

Per the reviewer's comment, the range of 1 to 100 in 1 

million was explained in scientific notation along with an 

explanation as to what the risk threshold translates to. 

Also, the calculation methodology for the potential 

cancer risk is included in the GMT2 AQIA.

L91-28 State of 

Alaska, Alaska 

Department of 

Environmental 

Conservation 

(ADEC)

Page 276: This table provides an impact summary 

for criteria pollutants at the "Nuiqsut Community 

Receptor", but does not disclose the exact 

location or the boundaries used for the impact 

model. Please clarify and present in a manner 

that would be easily understood by the community 

members in Nuiqsut.

3.5 Air Quality & 

Meteorology

A single receptor was placed in the model to represent 

the Nuiqsut Community as described in Section 4.2.6 of 

the GMT2 AQIA. The relevant sections have been 

updated to explain the Nuiqsut Community Receptor is

a single receptor at coordinates 70.21720, -150.99556.

L91-29 State of 

Alaska, Alaska 

Department of 

Environmental 

Conservation 

(ADEC)

Page 276: It would be helpful if tables 4.2‐17 a & 

b included columns with the background 

concentrations, similar to tables 4.2‐20 and 4.2‐

21. That way it is easier to see the project impacts 

to the near‐field as well as the impacts to the 

community of Nuiqsut.

3.5 Air Quality & 

Meteorology

Each of the tables includes background concentration, 

project impacts, and cumulative source impacts as 

detailed before Table 4.2-17a. For ease of reading and 

to compare total potential impacts to the 

NAAQS/AAAQS, we did not include background 

concentrations in this table. A detailed calculation of 

background values, project impacts, and cumulative 

source impacts is included in the GMT2 AQIA. In 

addition, model runs for 1-hour NO2 and 24-hour PM10 

had background values worked into the model and 

were not a single value added to the project impacts as 

was done in the far-field analysis. Therefore, including 

background values in these tables may have the 

opposite intent the commenter suggests. 
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Category Code

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L91-3 State of 

Alaska, Alaska 

Department of 

Environmental 

Conservation 

(ADEC)

Page 9, second bullet: Correctly states that the 

Division of Water can issue a CWA 401 

certification of reasonable assurance, and that an 

NPDES permit issued by EPA under CWA 

Section 402 would comply with the State's water 

quality standards. For completeness, 

recommending adding here or in a separate bullet 

that the Water Division also issues CWA 401 

certifications for Corps wetland permits under 

CWA Section 404.

1.1 Executive 

Summary & 

Introduction

Correction was made as suggested.

L91-30 State of 

Alaska, Alaska 

Department of 

Environmental 

Conservation 

(ADEC)

Page 277: The implications of the information in 

Table 4.2‐18 is unclear because PSD increments 

are explained on page 271, but no reference to 

that explanation has been provided for this table. 

Please add an explanation adjacent to this table 

for non‐technical readers.

3.5 Air Quality & 

Meteorology

A sentence following the PSD increment analysis was 

added to say that project impacts are below their 

respective increments therefore no potential air quality 

degradation is expected at the Nuiqsut community.

L91-31 State of 

Alaska, Alaska 

Department of 

Environmental 

Conservation 

(ADEC)

Page 278: This table and the accompanying text 

do not tell the non‐technical reader what the 

hazardous air pollutant impact is for Nuiqsut 

residents. The table does not disclose the exact 

location or the boundaries used for the impact 

model. Please clarify and present in a manner 

that would be easily understood by the community 

members in Nuiqsut.

3.5 Air Quality & 

Meteorology

A sentence following the results summary of the HAPs 

impacts table was added to say that the maximum 

scenario potential impacts are below their respective 

thresholds. The same model used for the criteria 

pollutants was used to estimate potential HAPs 

impacts.

L91-32 State of 

Alaska, Alaska 

Department of 

Environmental 

Conservation 

(ADEC)

Section 4.2.3 does not contain any discussion of 

Arctic haze. Arctic haze has been mentioned by 

local residents and should be addressed in this 

section.

3.5 Air Quality & 

Meteorology

The following text has been added to Section 3.2.3 

“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.”
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L91-33 State of 

Alaska, Alaska 

Department of 

Environmental

Conservation 

(ADEC)

Page 289, sixth and seventh paragraphs: Please 

identify what agency will be responsible for 

compliance and enforcement of the Fugitive Dust 

plan and/or the best management practices for 

fugitive dust control identified.

3.5 Air Quality & 

Meteorology

The BLM Arctic District Office is responsible for fugitive 

dust plan and BMP enforcement. This potential 

mitigation measure was removed from the Draft SEIS

L91-34 State of 

Alaska, Alaska 

Department of 

Environmental 

Conservation 

(ADEC)

Revegetation is most successful when gravel 

infrastructure is trimmed down to 1 ‐ 2 feet above 

tundra grade, covered with overburden, and then 

seeded and fertilized. This should be included as 

a potential reclamation process.

3.8 Vegetation 

and Wetlands

Although it is mentioned that post development some 

areas would be restored there is no in-depth discussion 

on restoration techniques or methods. Since the life of 

this project is to be approximately 30 years research 

will provide new and likely improved methods for 

restoration at that time.

L91-35 State of 

Alaska, Alaska 

Department of 

Environmental 

Conservation 

(ADEC)

Page 344: The first bullet on this page describes 

monitoring water withdrawal volumes and water 

body discharge. Monitoring should not be 

characterized as mitigation unless corrective 

actions are identified that will be taken when a 

specific threshold or percentage change is 

identified.

4.2 Mitigation Bullet has been removed from the discussion of 

mitigation.

L91-36 State of 

Alaska, Alaska 

Department of 

Environmental 

Conservation 

(ADEC)

Page 448, fifth paragraph: This paragraph 

discusses other mitigation but fails to provide an 

update on the air quality monitoring mitigation that 

was discussed on pages 8 and 41 of the GMT‐1 

Record of Decision. Please address.

4.2 Mitigation The section being referenced is Subsistence. Please 

see Section 4.2.3 Atmospheric Environment for a 

discussion of potential mitigation measures related to 

Air Quality.
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L91-37 State of 

Alaska, 

Department of 

Fish and Game

(ADFG)

Potential Mitigation Measure 2: Suspend Non‐

essential Helicopter Traffic during Peak Caribou 

Hunting Season. The Division of Wildlife 

Conservation (DWC) avoids using helicopters in 

caribou hunting areas in general, and specifically 

during peak hunting times. Because this 

mitigation measure would not be expected to 

affect other operators, including DWC, it would 

not be effective in addressing cumulative impacts 

of flight activity from other sources. Identifying 

how this proposed mitigation measure would 

affect the project proponent's operations is 

important to assessing its effectiveness. Defining 

“non‐essential” operations may prove difficult in 

some cases. How helicopter activities affect 

caribou distribution, and wariness, is an open 

area for research.

4.2 Mitigation This mitigation measure is applicable to the applicant, 

ConocoPhillips, in response to their projected number 

of flights within the project are. If adopted, this potential 

mitigation measure would be included in the terms and 

conditions of their permit to drill. Any effort to reduce 

the number of flights during this key time period will 

serve to reduce cumulative impacts.

L91-38 State of 

Alaska, 

Department of 

Fish and Game 

(ADFG)

Potential Mitigation Measure 3: Consultation 

Regarding Aircraft Communication Protocols. 

Improving communication and making 

consultation procedures more robust could have 

positive impacts on people’s perceptions of 

aircraft in the area.

4.2 Mitigation Thank you for your comment.
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Name

Comments Comment 

Category Code

Comment Response

L91-39 State of 

Alaska, 

Department of 

Fish and Game 

(ADFG)

Potential Mitigation Measure 4: Aircraft Monitoring 

Data Requirements: Improving aircraft activities 

monitoring could have positive benefits. 

Currently, quantification of aircraft activity is 

limited to a few basic metrics that may not be 

meaningful for drawing conclusions about the 

effects of aircraft activities. Comprehensive data 

from a wide range of operators could support 

quantitative analyses of the relationships between 

aircraft activity and caribou movements; however, 

without a corresponding comprehensive plan for 

collection, dissemination, and evaluation of the 

data from BLM, this proposed mitigation measure 

would likely increase cost/effort for the operator 

without meeting the requirement/standard for 

"meaningful analysis" even if the project 

proponent is fully compliant with providing the 

data.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Agree, and BLM supported the UAF research 

quantifying aircraft noise in the Nuiqsut area that is 

described in Appendix C. The BLM aircraft monitoring 

data currently collected is used to compare the number 

of projected versus actual flights, and could be used to 

inform a number of potential future analyses. The BLM 

will continue to partner with researchers from other 

agencies on projects or studies that can utilize this 

data, including the application of the data to resource 

understanding and management. 

L91-4 State of 

Alaska, Alaska 

Department of 

Environmental 

Conservation 

(ADEC)

Page 10, first bullet: The list of statutory 

authorities for public drinking water systems 

should be revised to delete the reference to AS 

46.03.070 and include a reference to AS 

46.03.710. Please remove the reference to 18 

AAC 80.005 and replace it with a reference to the 

entire chapter of 18 AAC 80.

1.1 Executive 

Summary & 

Introduction

Correction was made as suggested.

L91-4 State of 

Alaska, Alaska 

Department of 

Environmental 

Conservation 

(ADEC)

Page 10, first bullet: The list of statutory 

authorities for public drinking water systems 

should be revised to delete the reference to AS 

46.03.070 and include a reference to AS 

46.03.710. Please remove the reference to 18 

AAC 80.005 and replace it with a reference to the 

entire chapter of 18 AAC 80.

1.1 Executive 

Summary & 

Introduction

The text has been revised as suggested.
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Name

Comments Comment 

Category Code

Comment Response

L91-40 State of 

Alaska, 

Department of 

Fish and Game 

(ADFG)

Potential Mitigation Measure 5: Reduce Flights by 

Utilizing Unmanned Aerial Vehicles (UAVs). DFG 

cannot comment on the potential for UAV‐based 

operations to replace activities that currently 

require helicopter support beyond its own 

use/requirements, but it may be valuable for BLM 

to be aware that the existing technology is 

inadequate for most of DWC's own fieldwork, 

which includes but is not limited to netgunning, 

picking up collars, investigating mortalities, and 

composition counts over large geographic areas. 

The same constraints may or may not be true for 

the project proponent's monitoring activities.

4.2 Mitigation The BLM recognizes that this is currently an infeasible 

use of UAV technology, but recognizes that the 

technology is improving rapidly. The mitigation 

measure includes the requirement that the permittee 

will consult with the BLM every 3 years to determine 

feasibility of this technology and appropriate monitoring 

activities for its use. 

L91-41 State of 

Alaska, 

Department of 

Fish and Game 

(ADFG)

Potential Mitigation Measure 6: Subsistence 

Monitoring Studies. The BLM's ANILCA Section 

810 analysis finds that there may be a significant 

impact to subsistence activities, partly because of 

uncertainty in the existing literature. Therefore, 

continued subsistence monitoring at the level that 

has been conducted over the past 10 years is vital 

to understanding the impacts of new 

development(s). Research fatigue is a serious 

issue that needs to be contended with during the 

planning and implementation of monitoring 

studies.

4.2 Mitigation The BLM agrees. Please also see Section 4.4.5 

Subsistence, Potential Mitigation Measure 8: 

Subsistence User Monitoring and Adaptive 

Management
Supplemental Environmental Impact Statement

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Name

Comments Comment 

Category Code

Comment Response

L91-42 State of 

Alaska, Alaska 

Department of 

Environmental 

Conservation 

(ADEC)

Page 457, eighth paragraph: The last sentence on 

this page notes that "Emissions associated with 

GMT2, including vehicle exhaust emissions, are 

within the range of Alaska Department of 

Environmental 

Conservation air quality regulations and are subje

ct to Alaska Department of Environmental Conser

vation permitting regulations." This sentence is in

error. Vehicle exhaust emissions are not subject 

to Alaska Department of Environmental 

Conservation permitting regulations. Rather, 

vehicle exhaust emissions are subject to the 

regulatory oversight of the Environmental 

Protection Agency through emission standards for 

engines and vehicles.

3.18 Public 

Health

Text updated to correct error. 

L91-43 State of 

Alaska, Alaska 

Department of 

Environmental 

Conservation 

(ADEC)

Page 465, first and second paragraphs: This 

section discusses spill history on the North Slope; 

however, the February 15, 2012 drilling mud spill 

at the Q2‐Pad appears to be missing. Because 

the spill was located 18 miles northeast of 

Nuiqsut, and there were concerns of emissions 

from the shallow well blowout impacting Nuiqsut, 

recommend including in this section.

3.19 Hazardous 

Materials Spills

Added discussion of this spill to section 4.5

L91-44 State of 

Alaska, Alaska 

Department of 

Environmental 

Conservation 

(ADEC)

Page 472: 

The listing for the Nanushuk project notes that "Pr

oposed project scheduled to begin construction i

n 2018." The EIS process has not been complete

d for the Nanushuk project, and construction is 

not anticipated to begin in 2018 as previously 

anticipated. Please update accordingly.

2.1 Proposed 

Action & 

Alternatives

Changed in document.
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L91-45 State of 

Alaska, Alaska 

Department of 

Environmental 

Conservation 

(ADEC)

Page 474: The final listing in this table for Utilities 

in the community of Nuiqsut should also include 

planned facility upgrades for the Nuiqsut Natural 

Gas Pipeline (NNGP). The North Slope Borough 

has plans for the installation of equipment for 

removal of hydrogen sulfide from the gas stream. 

The proposed project will require 1.5 acres of land 

to be added to the NNGP right‐of‐way lease. 

4.0 Cumulative 

Effects Projects 

and Methodology

Edits have been made to Table 4.6-2.

L91-46 State of 

Alaska, Alaska 

Department of 

Environmental 

Conservation 

(ADEC)

Page 477: This section describes cumulative 

impacts to water resources through 2011 or 2012, 

but there is no reference to more recent 

information. Is this because more recent 

information is not available? Please clarify and/or 

update to include most recent data.

3.4 Water 

Resources

There has been little change in development since 

2012, however, impacts from GMT1, GMT2 and Willow 

were considered in the future impacts section. 

L91-47 State of 

Alaska, Alaska 

Department of 

Environmental 

Conservation 

(ADEC)

Page 510, fifth paragraph: 

"New development, research or recreational activ

ity in conjunction with the proposed GMT2 Projec

t increases the likelihood of future identification, di

sruption, or destruction of cultural resources." It 

is not clear why there would be any recreational 

activity associated with the GMT2 Project. Please 

explain or remove the reference to recreational 

activity from the sentence.

3.14 Cultural and 

Paleontological 

Resources

This has been modified to reflect "other activities that 

may result from the project" and the bit about 

recreation has been removed.

L91-48 State of 

Alaska, Alaska 

Department of 

Environmental 

Conservation 

(ADEC)

Page 516, eighth paragraph: 

"With the Nuiqsut Spur Road and upcoming comp

letion of the GMT1 road and Colville River Access

Road, resident of Nuiqsut will have facilitated to

subsistence areas and will be able 

to commute to work in the Alpine field." Recomm

end editing to reflect, "Nuiqsut residents will have

access to subsistence areas...."

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Text has been revised to correct sentence.
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Comment Response

L91-49 State of 

Alaska, Alaska 

Department of 

Environmental 

Conservation 

(ADEC)

Page 523, first paragraph: 

"The BLM (2004a) predicted that short‐

term impacts, such as green trails and disturban

ces from noise and other activities, would not acc

umulate." It is not clear what the inclusion of "gre

en trails" in this sentence means. This issue was 

not discussed in earlier sections regarding 

recreation. Please clarify.

3.17 Land Use Added a description of green trails to 4.4.4 Recreation

L91-5 State of 

Alaska, Alaska 

Department of 

Environmental 

Conservation 

(ADEC)

Page 10th, sixth bullet: Please remove the 

reference to 18 AAC 60.005 and .200 and replace 

it with a reference to the entire chapter of 18 AAC 

60. Doing this would include references to Article 

6 ‐ User fees, Article 7 ‐ Monitoring and Corrective 

action requirements, and Article 8 ‐ General 

Provisions which are important parts of the 

regulations.

1.1 Executive 

Summary & 

Introduction

The text has been revised as suggested.

L91-50 State of 

Alaska, Alaska 

Department of 

Environmental 

Conservation 

(ADEC)

Page 530, second bullet: This bullet mentions that 

the Putu exploratory well is located approximately 

three miles east of Nuiqsut. The text on page 473 

notes that the well is located five miles from 

Nuiqsut. Please resolve this conflict.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

The text has been revised to indicate the correct 

distance to Putu from Nuiqsut.

L91-51 State of 

Alaska, Alaska 

Department of 

Environmental 

Conservation 

(ADEC)

Page 532, first paragraph: his paragraph 

discusses impact to public health under the GMT2 

action alternatives and notes "medium impacts as 

a result of exposure to hazardous materials (i.e. 

air quality 

emissions)......" It is not clear how this determina

tion was reached. Section 4.2.3.2 and 4.6.5 discu

ss air quality and the cumulative 

impacts to air quality and neither section appears

to support this conclusion. Please explain.

3.18 Public 

Health

Thank you for your comment. Public health section 

information came from Section 4.6.8.10, which also 

references BLM 2012 Section 4.8.7.21 where 

methodologies are described. Section 3.1.3 describe 

Hazardous and Solid Waste 
Supplemental Environmental Impact Statement

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L91-52 State of 

Alaska, Alaska 

Department of 

Environmental 

Conservation 

(ADEC)

Page 535, first paragraph: Sentence three in this 

paragraph notes that "Additionally, the increase in 

development could result in a cumulative negative 

impact to human health resulting from impacts to 

air quality, water quality, or spills, and the general 

overall effect of increasing stress and anxiety 

within the community as a result of the rapid 

changes that are taking place." It is not clear how 

the conclusion of cumulative negative impact to 

human health was reached. Please explain by 

citing support from other sections within this 

document. It might also be worthwhile to 

separate the human health impacts that are 

regulated by government agencies from the 

human health impacts of stress and anxiety into 

two separate sentences for clarity.

3.18 Public 

Health

Thank you for your comment. SEIS text is omitted, 

leaving the specific impacts as described.

L91-53 State of 

Alaska, Alaska 

Department of 

Environmental 

Conservation 

(ADEC)

Page 537, fifth paragraph: This paragraph 

discusses climate change in the context of 

environmental justice. It is not clear in this 

discussion what the connection is between 

climate change and the proposed action. Is this 

section implying that the proposed project will 

increase climate change or that multiple actions, 

including climate change and the proposed 

development will have impacts on Nuiqsut 

residents and their subsistence activities? Please 

clarify what is the proposed injury and the 

proposed remedy that can be addressed in the 

record of decision.

3.7 Climate 

Change

The section referred to is the cumulative effects 

analysis for Section 4.6.8.11 Environmental JusticeConclusion. The intent of referring to climate change 

within this section is to acknowledge that issues 

surrounding climate change constitute part of the suite 

of cumulative effects for environmental justice. Analysis 

of the proposed action's impacts to subsistence are 

found in Section 4.4.5, including several potential 

mitigation measures that could serve to minimize 

identified impacts.

L91-54 State of 

Alaska, Alaska 

Department of 

Environmental 

Conservation 

(ADEC)

Page 538, first sentence: "Alternative E would 

have incremental adverse cumulative impact to 

environmental justice on the North Slope." It 

should be noted that there is no "Alternative E" 

addressed in this EIS and whatever alternative is 

being discussed would probably have adverse 

cumulative impacts (plural).

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

The sentence referring to Alternative E has been 

deleted. 
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Comment Response

L91-55 State of 

Alaska, Alaska 

Department of 

Environmental 

Conservation 

(ADEC)

Pages 539-540: This section discusses the 

mitigation measures and monitoring required 

through the most recent BLM environmental 

impact statements. It is not clear why the air 

quality monitoring site in Nuiqsut that was 

mentioned on pages 8 and 41 of the GMT‐1 

Record of Decision (ROD) is not discussed here. 

Please clarify. 

4.2 Mitigation Because construction of GMT1 began in early 2017, 

air quality monitoring data and reports required by the 

GMT1 ROD are just now being distributed. 

L91-56 State of 

Alaska, Alaska 

Department of 

Environmental 

Conservation 

(ADEC)

Page 548: The ADEC Water Quality Standards at 

18 AAC 70 are referenced here, but the version 

referenced is out of date. The most recent version 

of ADEC regulations can be found here at 

http://dec.alaska.gov/commish/regulations.aspx. 

Please update accordingly.

3.4 Water 

Resources

Fixed in document

L91-57 State of 

Alaska, Alaska 

Department of 

Environmental 

Conservation 

(ADEC)

Page 549: The ADEC Spills Database was 

referenced here, but the version and web address 

are outdated. The Spills Database can be found 

here 

http://dec.alaska.gov/Applications/SPAR/PublicM

VC/PERP/SpillSearch

3.19 Hazardous 

Materials Spills

Fixed in document

L91-58 State of 

Alaska, Alaska 

Department of 

Environmental 

Conservation 

(ADEC)

Page 575: 

The reference to Kolesar, K.R. et al. (2017), "Effe

ct of Prudhoe Bay emissions on atmospheric aero

sol growth events observed in Utqiagvik (Barrow),

Alaska was cited in section 3.4.7, page 228 

regarding pollution nanoparticles, with the 

conclusion that there are potentially forms of 

pollution that are not regulated or monitored. It 

should be noted that the paper cited addressed oil 

field emissions and sea spray aerosols (SSA) and 

how those components would affect aerosol and 

secondary aerosol precursors in the context of 

Arctic atmospheric composition and climate 

simulations and did not address air pollution from 

nanoparticles.

3.5 Air Quality & 

Meteorology

Citation removed. 
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L91-59 State of 

Alaska, 

Department of 

Fish and Game 

(ADFG)

While it is appropriate given the body of literature 

available to suggest that changes in caribou 

movement behavior are possible, and even likely 

at some level, moving from that to the conclusion 

that there will be significant reductions in the 

availability of caribou is not supportable, 

particularly with respect to this development alone 

(i.e. the cumulative case may be somewhat 

different).

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Please see responses to Comments L91-60, L91-61, 

and L91-68. Based on case law (e.g. Kunaknana et al. 

vs. Clark) pursuant to ANILCA Section 810 analysis, 

the BLM determines whether or not a proposed action 

may result in a significant restriction to subsistence use 

in order to apply the two-part process required by 

Section 810. We contend that there is enough 

evidence in the literature and based on input from 

subsistence users to reasonably claim that the various 

factors described, including the range of reactions by 

caribou to roads, satisfy the finding that the effects 

"may reach a level of significant restriction."

L91-6 State of 

Alaska, Alaska 

Department of 

Environmental 

Conservation 

(ADEC)

Page 10, seventh bullet: This bullet regarding 

solid waste processing and temporary storage 

facilities could be combined with the bullet above 

that just references the entire chapter of 18 AAC 

60, since much of the other information is 

duplicative.

1.1 Executive 

Summary & 

Introduction

The text has been revised as suggested.
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Name

Comments Comment 

Category Code

Comment Response

L91-60 State of 

Alaska, 

Department of 

Fish and Game 

(ADFG)

Page 9, paragraph 2: The documentation that 

local hunters report reduced availability over the 

course of a single year following the most recent 

road construction could be well within the range of 

natural variation in caribou availability

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

The complete sentence acknowledges the uncertainty 

in the information by stating "While construction of the 

road is too recent to document changes in caribou 

movements via multi-year collar or harvest data, 

Nuiqsut hunters and Native Village of Nuiqsut Tribal 

Council Members reported reduced availability of 

caribou south of the CD5 road." The analysis in the 

Draft was based on data collected in 2015, before the 

GMT1 road was built and during the second year that 

hunters reported on effects from the Spur Road and 

CD5 road. See Final SEIS Section 3.4.6.4: some data 

from Year 9 (2016 ) and a preliminary review data from 

Year 10, showing use of the newly constructed GMT1 

road, is now available. Recent data: some hunters 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. The GMT1 road was not constructed 

in the migration corridor of the TCH: it is reasonable to 

predict that 2-3 years of construction and 30 years of 

operational use of an industrial road in the eastern 

edge of the migration corridor that runs mainly northsouth and is located to the west of the Spur Road, the 

Colville River, and Nuiqsut will deflect animals from 

those areas outside the range of natural variation in 

availability in those areas. 
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Category Code

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L91-61 State of 

Alaska, 

Department of 

Fish and Game 

(ADFG)

Page 9, paragraph 3: Localized displacement may 

be possible, but stating that Nuiqsut is vulnerable 

to even minor changes in TCH distribution is not 

established, and the scale of evaluation is critical 

to this finding. The statement itself is not 

completely accurate, given the literature. More 

common is the finding of a delay rather than 

spatial displacement, particularly in seasons 

outside of calving.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

ADF&G spatial analysis shows GMT infrastructure in 

the TCH migration corridor. If GMT shifts any TH 

movement further west or south, it could put TH 

animals out of reach of many Nuiqsut hunters. BLM has 

established (GMT1 SEIS 2015 Section 4.3.4.1: 

Terrestrial Mammals) that traffic and increased access

may lead to an increased avoidance response for 

caribou, that caribou from the TH are less likely to be 

tolerant of disturbance than those in the Prudhoe Bay 

field, that gravel roads (or berms over 4 feet high) 

would potentially deflect or delay the movement of 

caribou, and that although these impacts were 

expected to be of low intensity, long-term duration, and 

local extent for the caribou herd itself, this resource fills 

a distinctive ecosystem and ecological service role 

within the locality, and that non-calving caribou could 

be disturbed at moderate levels of intensity for a long 

term duration from drilling and vehicle disturbances at 

the local level. Based on that analysis and other 

sources on Nuiqsut's subsistence patterns, the 

Subsistence section (GMT1 2015 4.4.5.3) found that 

"Even localized or "limited" changes in caribou 

distribution resulting from displacement can affect the 

availability of caribou at different times of the year and 

the fact that caribou are not always available near 

Nuiqsut," and "as noted in SRB&A (2013b), because 

the Colville River delta is in the peripheral range of both 

the TH and the CAH, Nuiqsut harvesters are 

particularly vulnerable to changes in the distribution 

and/or behavior of caribou in these herds." 
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L91-61

Continued

State of 

Alaska, 

Department of 

Fish and Game 

(ADFG)

See above comment 3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

This was re-established in the 2017 Update to the 

Nuiqsut Paisangich (SRB&A 2017f page 60: "The 

Colville Delta is situated on the easternmost and 

westernmost ranges of the two herds, and therefore 

Nuiqsut hunters are particularly vulnerable to any 

changes in herd distribution or migration." Based on 

case law (e.g. Kunaknana et al. vs. Clark) pursuant to 

ANILCA Section 810 analysis, the BLM determines 

whether or not a proposed action may result in a 

significant restriction to subsistence use in order to 

apply the two-part process required by Section 810. 

We contend that there is enough evidence in the 

literature and based on input from subsistence users to 

reasonably claim that the various factors described, 

including the range of reactions by caribou to roads, 

satisfy the finding that the effects "may reach a level of 

significant restriction."

L91-62 State of 

Alaska, 

Department of 

Fish and Game 

(ADFG)

Page 12, paragraph 5: The authors find that the 

combined effects of roads, pads and aircraft 

“would alter traditional movements of TCH caribou 

in the vicinity of Nuiqsut.” As the authors state 

later in the paragraph, a wide variety of reactions 

are possible. It may well be the case that some 

alterations in movement are possible, but 

alteration of traditional movements is not 

necessarily a foregone conclusion.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Please see response to Comment L91-61. Based on 

case law (e.g. Kunaknana et al. vs. Clark) pursuant to 

ANILCA Section 810 analysis, the BLM determines 

whether or not a proposed action may result in a 

significant restriction to subsistence use in order to 

apply the two-part process required by Section 810. 

We agree that alteration of traditional movements of 

TCH caribou is not necessarily a foregone conclusion, 

but contend that there is enough evidence in the 

literature and based on input from subsistence users to 

reasonably claim that the various factors described, 

including the range of reactions by caribou to roads, 

satisfy the finding that the effects "may reach a level of 

significant restriction."
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Name

Comments Comment 

Category Code

Comment Response

L91-63 State of 

Alaska, 

Department of 

Fish and Game 

(ADFG)

Page 13, paragraph 1: The authors find that 

caribou availability has already changed as a 

result of the CD5 – GMT1 road, which is a 

tenuous conclusion based on the short time span 

of inference, and that a “similar response to the 

GMT1‐GMT2 access road would be likely.” These 

conclusions seem too strong based on the 

available data. They later conclude that reduced 

availability would affect a significant portion of 

hunters, and would constitute a significant 

reduction in availability of caribou. Several issues 

exist with these conclusions; among the variety of 

responses caribou could have, delays are as 

possible as deflections, and the few examples we 

have appear to effect only portions of the 

population, and only in some years. The scale 

issue comes up again here; even if some low 

level of change in movement patterns were to 

occur, it is important to consider the scale of 

change. Outside of dramatic, large‐scale change 

in distribution that effects multiple seasons, it 

might be hard to argue that caribou access will 

go from excellent to poor. 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Please see responses to Comments L91-60 and L91-

61. Based on case law (e.g. Kunaknana et al. vs. Clark) 

pursuant to ANILCA Section 810 analysis, the BLM 

determines whether or not a proposed action may 

result in a significant restriction to subsistence use in 

order to apply the two-part process required by Section 

810. There is enough evidence in the literature 

(including the interpretation presented by the 

commenter), and based on input from subsistence 

users, to reasonably claim that the various factors 

described, including the range of reactions by caribou 

to roads, satisfy the finding that the effects "may reach 

a level of significant restriction."
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Name

Comments Comment 

Category Code

Comment Response

L91-64 State of 

Alaska, 

Department of 

Fish and Game 

(ADFG)

Page 13, paragraph 2: The authors conclude that 

given the importance of caribou, and uncertainty 

regarding extent and duration or altered caribou 

availability, that they cannot preclude a finding 

that the effects of Alternative A will not cause a 

major redistribution of caribou. Considering the 

scale of the analysis, a major distribution that 

might prove meaningful to harvest levels is 

unlikely, even with the uncertainty that exists. 

The authors do well here to point out a potential 

magnitude of effect, 1 day using 4 gallons and 2 

days using 8 gallons of fuel, but what this 

hypothetical change means in terms of significant 

restriction is unclear.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Please see responses to Comments L91-60 and L91-

61. Also, the comment omits the subsequent sentence, 

which addresses the question posed in the comment: 

"[] a successful harvest that involves 1 day-long trip 

and 4 gallons of fuel cannot be equated with a 

successful harvest that requires 2 day-long trips and 8 

gallons of fuel. If this occurs over the course of 32-33 

years, Nuiqsut hunters lacking adequate time, income, 

or equipment would experience a significant restriction 

due to the reduced local availability of caribou to meet 

their subsistence needs." Also please note that the 

scale of the analysis for subsistence (and the ANILCA 

810) is based on hunter use areas, not the caribou 

herd's overall range and health. The analysis finds that 

the likely redistribution would be significant for Nuiqsut 

hunters, not for the caribou. Harvest levels do not 

always reflect the amount of time, money, risk, and 

effort hunters must spend. Based on case law (e.g. 

Kunaknana et al. vs. Clark) pursuant to ANILCA 

Section 810 analysis, the BLM determines whether or 

not a proposed action may result in a significant 

restriction to subsistence use in order to apply the twopart process required by Section 810. We agree that 

alteration of traditional movements of TCH caribou is 

not necessarily a foregone conclusion, but contend that 

there is enough evidence in the literature and based on 

input from subsistence users to reasonably claim that 

the various factors described, including the range of 

reactions by caribou to roads, satisfy the finding that 

the effects "may reach a level of significant restriction."
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Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L91-65 State of 

Alaska, 

Department of 

Fish and Game 

(ADFG)

Page 14, first paragraph: "Under Alternative B, 

the road and pipeline would be slightly closer to 

Nuiqsut than under Alternative A. Some residents 

perceive an advantage in keeping industrial 

activities as close as possible to town, thereby 

leaving the more remote hunting areas less 

affected." Based on the description of the road 

and pad alignment in Alternative B, GMT2 pad is 

in the same location as in Alternative A. 

Therefore, it is the same distance from Nuiqsut to 

the GMT2 pad for both alternatives.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

The text has been corrected to note that only the road 

would be closer to Nuiqsut under Alternative B. 

L91-67 State of 

Alaska, 

Department of 

Fish and Game 

(ADFG)

Page 20: The comments above, about the 

magnitude of any potential adverse effects on 

subsistence activities, are limited to the scale of 

the new GMT1‐GMT2 road. When discussing the 

cumulative effect of multiple additional 

developments, the scale at which any minor 

changes in movements and distribution becomes 

much larger, and evaluating likely effects on 

subsistence, and where a person might begin to 

conclude that activities have been significantly 

impacted, becomes even challenging even for an 

experienced researcher. This is both due to 

compounding uncertainty regarding what 

developments are likely, their potential effects on 

caribou, as well as the much larger scale of 

development. The suggestion that the cumulative 

case begins to have significant impacts on 

subsistence resources in the communities of 

Atqasuk, Anaktuvuk Pass, and Utqiagvik is not as 

well‐supported (regardless of the accuracy in 

assessment of the significance or magnitude of 

impacts) as previous arguments about the 

findings related to the GMT2 analyses.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

The developments described are reasonably 

foreseeable and several have become more likely since 

the Draft SEIS was written. The cumulative scenario 

includes likely effects from all reasonably foreseeable 

future development, which includes infrastructure that 

would likely affect resources and access for hunters 

from those communities. Based on case law (e.g. 

Kunaknana et al. vs. Clark) pursuant to ANILCA 

Section 810 analysis, the BLM determines whether or 

not a proposed action may result in a significant 

restriction to subsistence use in order to apply the twopart process required by Section 810. There is enough 

evidence in the literature and based on input from 

subsistence users, to reasonably claim that the various 

factors described satisfy the finding that the effects 

"may reach a level of significant restriction."
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Name

Comments Comment 

Category Code

Comment Response

L91-68 State of 

Alaska, 

Department of 

Fish and Game 

(ADFG)

Page 21, paragraph 4: The authors state that the 

distribution and local availability of caribou 

populations have been affected by oil 

development; this is a broad statement, and the 

only information supporting this statement are 

changes in distribution that are specific to the 

Central Arctic Herd, during calving, and have no 

impact on hunting or harvest.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

There is no indication that harvest levels have 

decreased to date, but there is substantial data that oil 

development has affected hunting patterns (especially 

changed and restricted use areas) and resulted in 

disturbance to hunters (see Section 3.4.6.4 and Section 

4.4.5.4). It is explicitly not a broad statement; it 

specifies "local availability" which could be justified 

solely on direct loss of habitat from the footprint of 

infrastructure. Based on case law (e.g. Kunaknana et 

al. vs. Clark) pursuant to ANILCA Section 810 analysis, 

the BLM determines whether or not a proposed action 

may result in a significant restriction to subsistence use 

in order to apply the two-part process required by 

Section 810. There is enough evidence in the literature 

and based on input from subsistence users, to 

reasonably claim that the various factors described 

satisfy the finding that the effects "may reach a level of 

significant restriction."

L91-69 State of 

Alaska, Alaska 

Department of 

Environmental 

Conservation 

(ADEC)

This document tends to rely heavily on 

information or studies that were presented in 

earlier environmental documents; however, none 

of these documents area easily available or linked 

on the project page. This make it difficult for 

reviewers and interested stakeholders to access 

and provide meaningful comments. Please 

provide links to relevant documents on the project 

page.

1.1 Executive 

Summary & 

Introduction

Non-substantive to the SEIS. 

L91-7 State of 

Alaska, Alaska 

Department of 

Environmental 

Conservation 

(ADEC)

Page 10, seventh bullet: This bullet regarding the 

siting of hazardous waste management facilities 

could be combined with the bullet above.

3.19 Hazardous 

Materials Spills

Left bullets separate, and added reference to 18 AAC 

63, Siting of Hazardous Waste Management Facilities
Supplemental Environmental Impact Statement

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

342

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L91-70 State of 

Alaska, Alaska 

Department of 

Environmental 

Conservation 

(ADEC)

There is inconsistent spelling/use of "water body" 

versus "waterbody". Please use one spelling 

consistently throughout the document.

3.4 Water 

Resources

Text revised to use the term waterbody and 

waterbodies consistently throughout.

L91-71 State of 

Alaska, Alaska 

Department of 

Environmental 

Conservation 

(ADEC)

Pages xv and xvi: There are many acronyms used 

throughout this document that are not included on 

the acronyms pages, such as IAP, DNA, RMP or 

NOI. Undefined acronyms make the documents 

difficult to interpret. Please address during 

technical writing review.

1.1 Executive 

Summary & 

Introduction

The acronym list has been reviewed and revised as 

needed.

L91-72 State of 

Alaska, Alaska 

Department of 

Environmental 

Conservation 

(ADEC)

Page 41: Spelling error, line 18: "conducing" 

should be "conducting"

3.17 Land Use Corrected spelling.

L91-73 State of 

Alaska, Alaska 

Department of 

Environmental 

Conservation 

(ADEC)

Page 254, fourth paragraph: 

Sentence two in the paragraph notes that "Fugitiv

e dust which enters surface water bodies can also

increase turbidity." This information is duplicated

in the last sentence in the sixth paragraph six (at 

the end of the page). Please eliminate one of 

these duplicate statements. 

3.4 Water 

Resources

The last line on the page was deleted.

L91-74 State of 

Alaska, Alaska 

Department of 

Environmental 

Conservation 

(ADEC)

Page 346: Line 5: "Error! Reference source not 

found."

3.12 Mammals Text has been corrected.
Supplemental Environmental Impact Statement

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

343

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L91-75 State of 

Alaska, Alaska 

Department of 

Environmental 

Conservation 

(ADEC)

Page 415, first paragraph: "Chapter 3 ($ 3.4.5 

Subsistence)" Should be (3.4.6 Subsistence). 

Please address during technical writing review.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Text has been revised. 

L91-76 State of 

Alaska, 

Division of 

Mining, Land, 

and Water 

(DMLW)

Page 416, last paragraph: "the affected 

environment "Subsistence" section (section 

3.4.5.3)" ‐ this is a Visual Resources section. 

Please address during technical writing review.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Callout has been revised to reflect Section 3.4.6.

L91-77 State of 

Alaska, 

Department of 

Fish and Game 

(ADFG)

Page 419, third paragraph: "overlaps with many of 

Nuiqsut most concentrated subsistence use areas 

(see Figure 3.4‐6)". It is unclear whether this is 

the correct figure, appears to be 3.4‐2. Please 

address during technical writing review.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Text has been revised. 

L91-78 State of 

Alaska, 

Department of 

Fish and Game 

(ADFG)

Page 419, third paragraph: "Project area are 

described in detail in Section 3.4.5.3, “Overview of 

Subsistence Use Areas.” " ‐ 3.4.5.3 is Visual 

Resources. Please address during technical 

writing review.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Callout has been revised to reflect Section 3.4.6.

L91-79 State of 

Alaska, 

Department of 

Fish and Game 

(ADFG)

Page 420, second paragraph: "The monitoring 

report has also documented a general decrease 

in the percentage of harvests along the Nigliq 

Channel. Figure 4.4‐1." ‐ Should be 4.4‐2. Please 

address during technical writing review.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Text has been revised. 

L91-8 State of 

Alaska, Alaska 

Department of 

Environmental 

Conservation 

(ADEC)

Page 10, new bullet: 

A new bullet should be added to this list to read "

Reviews and approves food service facilities for c

amps serving 25 persons or more."

1.1 Executive 

Summary & 

Introduction

The text has been revised as suggested.
Supplemental Environmental Impact Statement

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

344

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L91-80 State of 

Alaska, 

Department of 

Fish and Game 

(ADFG)

Page 266, first paragraph: "The likelihood of 

impacts to the water resources identified in this 

analysis can be separated into reasonably 

foreseeable and potential (Table 4.2‐11). No 

evaluated effects were determined to have 

impacts." ‐ There were both reasonably 

foreseeable and potential/speculative impacts ‐

the column in the table of "Impact Anticipated" 

seems to have been erroneously inserted. Please 

address during technical writing review.

3.4 Water 

Resources

3rd column was removed.

L91-81 State of 

Alaska, 

Department of 

Fish and Game 

(ADFG)

Page 420, third paragraph: "shows the GMT2 

Project area overlain on Nuiqsut subsistence use 

areas for all resources documented by Pederson 

from 1973–1986, by BLM in 2004, by SRB&A for 

1995‐2006, and by Alaska Department of Fish 

and Game in 2014." ‐ Looks like the "Note" was 

incorrectly inserted in the middle of this sentence. 

Please address during technical writing review.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Text has been revised. 

L91-82 State of 

Alaska, 

Department of 

Fish and Game 

(ADFG)

Overall, there are numerous incorrect figure 

references, or text references, or cut and paste 

errors within the GMT2 DSEIS. This complicated 

content review for substantive issues within this 

document. Please address during technical 

writing review.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Text has been revised. 

L91-83 State of 

Alaska, 

Department of 

Fish and Game 

(ADFG)

Page 547: The list of References could use 

additional editing for style, format, capitalization, 

spelling, and consistency to improve the quality of 

this section of the document. Please address 

during technical writing review.

1.1 Executive 

Summary & 

Introduction

References have been reviewed and revised.
Supplemental Environmental Impact Statement

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

345

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L91-84 State of 

Alaska, 

Department of 

Fish and Game 

(ADFG)

Page 556: "Blank, J. 2013. Remote Identification 

of Maternal Polar Bear (Ursus maritimus) Denning 

Habitat on the Colville River Delta, Alaska. 

University of Alaska‐Anchorage." Change to: 

Blank, J. 

2013. Remote Identification of Maternal Polar Bea

r (Ursus maritimus) Denning Habitat on the Colvill

e River Delta, Alaska. M.S. Thesis. University of

Alaska‐Anchorage. Please address during 

technical writing review.

3.13 Threatened 

and Endangered 

Species

Chapter 6, References, has been updated. 

L91-85 State of 

Alaska, 

Department of 

Fish and Game 

(ADFG)

Page 559: Brown, W.E. 1979. Nuiqsut Paisanich‐

Nuiqsut Heritage ... Multiple entries of this one 

reference. Please address during technical writing 

review.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Duplicate entries have been deleted.

L91-86 State of 

Alaska, 

Department of 

Fish and Game 

(ADFG)

Page 563: Dale Guthrie R. 2006. The reference 

should begin Guthrie, R.D. 2006. Please 

address during technical writing review.

3.7 Climate 

Change

Edit has been made to text.
Supplemental Environmental Impact Statement

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

346

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L91-87 State of 

Alaska, 

Department of 

Fish and Game 

(ADFG)

Page 568: "George, J.C., J. Zeh, R. Suydam, and 

C. Clark. 2004. Abundance and Population Trend 

(1978‐2001) of Western Arctic Bowhead Whales 

Surveyed Near Utqiagvik (formerly Barrow), 

Alaska. Marine Mammal Science 20: 755–773. In: 

USDOI BLM. 2012. National Petroleum Reserve‐

Alaska (NPR‐A) Final Integrated Activity Plan 

(IAP)/Environmental Impact Statement (EIS)." 

The global search and replacement of "Barrow" 

with "Utqiagvik (formerly Barrow)" should be re‐

examined throughout this document, particularly 

within References. In this instance (and others), 

the original title of the reference should be used 

as it pre‐dates the community name change and 

Barrow was used in the original document. For 

this citation use: George, J.C., J. Zeh, R. 

Suydam, and C. Clark. 2004. Abundance and 

Population Trend (1978‐2001) of Western Arctic 

Bowhead Whales Surveyed Near Barrow, Alaska. 

Marine Mammal Science 20: 755–773. In: USDOI 

BLM. 2012. National Petroleum Reserve‐Alaska 

(NPR‐A) Final Integrated Activity Plan 

(IAP)/Environmental Impact Statement (EIS). 

Please address during technical writing review.

3.13 Threatened 

and Endangered 

Species

Chapter 6, References, has been updated. 

L91-88 State of 

Alaska, 

Department of 

Fish and Game 

(ADFG)

Page 579: McIntyre, C. L., D. C. Douglas, and M. 

W. Collopy. 2008. Reference duplicated. Please 

address during technical writing review.

3.13 Threatened 

and Endangered 

Species

Chapter 6, References, has been updated. 

L91-89 State of 

Alaska, 

Department of 

Fish and Game 

(ADFG)

Page 612: Wolfe, S. A., et al. (2000). Reference 

duplicated. Please address during technical 

writing review.

3.11 Caribou Thank you for your comment. This correction has been 

made.
Supplemental Environmental Impact Statement

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347

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L91-9 State of 

Alaska, Alaska 

Department of 

Environmental 

Conservation 

(ADEC)

Page 12: The text box for ADEC should also 

include "Plan Approvals for Drinking Water and 

Wastewater Treatment Systems." There are three 

essential APDES general permits to note: 

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 wastewater); and 

AKG380000 ‐ Wastewater Discharges from 

Drinking Water Treatment Facilities.

1.1 Executive 

Summary & 

Introduction

Correction was made as suggested.

L92-10 Environmental 

Protection 

Agency (EPA), 

Region 10

Section 3.2.3.2: We recommend this section 

include discussion regarding ozone and 

background concentrations of ozone ( ozone data 

were collected at the Nuiqsut monitor also). The 

discussion should note that background ozone on 

the North Slope is quite high due to natural 

processes. Stratospheric ozone intrusion is mostly 

responsible for the higher background ozone

episodes at the surface. 

3.5 Air Quality & 

Meteorology

Section 4.2.3.2 contains a discussion of the ozone 

concentrations monitored at Nuiqsut and the maximum 

concentrations were well below the NAAQS. The SEIS 

has been modified to note that stratospheric ozone 

intrusion could contribute to higher concentrations of 

ozone observed in the North Slope of Alaska. 
Supplemental Environmental Impact Statement

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

348

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L92-11 Environmental 

Protection 

Agency (EPA), 

Region 10

Table 3.2-6 and Table 3.2-7, page 89: We 

recommend the Final SEIS account for the criteria 

air pollutant ozone in these two tables. Please 

consider changing the column header in Table 

3.2-6, "Final Background Value", to "Background 

Design Concentration". We also recommend 

including a "Form of Standard" column in Table 

3.2-6 that explains how the design concentration 

is calculated (e.g., "3-year average of 98th 

percentile daily max", "3-year average of annual 

arithmetic mean", etc.). Finally, please include the 

measured background ozone in the table as well. 

For Table 3.2-7, we recommend including a 

"Form of Standard" column as well as the national 

ambient air quality standard for ozone in the table. 

3.5 Air Quality & 

Meteorology

Per the reviewer's comment ozone has been added to 

Tables 3.2-6 and 3.2-7. The header to Table 3.2-6 and 

the text following the table have revised "final 

background value" to read as "background design 

concentration". Lastly, the form of standard for all 

pollutants in Tables 3.2-6 and 3.2-7 have been added.

L92-12 Environmental 

Protection 

Agency (EPA), 

Region 10

Section 3.2.3.2, page 89, 1st paragraph: The 

phrase " ... the existing background air quality are 

below the national and state of Alaska standards," 

could be misinterpreted. We recommend stating, " 

... the existing background air pollutant 

concentrations do not exceed the national and 

state of Alaska ambient air quality standards." 

3.5 Air Quality & 

Meteorology

Thank you for the comment. The wording of this 

sentence has been changed to the reviewer's 

recommendation.

L92-13 Environmental 

Protection 

Agency (EPA), 

Region 10

Section 3.2.3.3, page 90: We note that the phrase 

"Haze is a form of pollution that occurs from 

refraction of sunlight on particles in the 

atmosphere," is not accurate. We suggest stating, 

"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."

3.5 Air Quality & 

Meteorology

Thank you for the comment. The wording of this 

sentence has been changed to the reviewer's 

recommendation.

L92-14 Environmental 

Protection 

Agency (EPA), 

Region 10

Section 4.2.3.2, page 271, paragraph 2: We note 

that a more accurate description of the 

background values used for the "final background 

concentration" column header may be 

"background design concentration."

3.5 Air Quality & 

Meteorology

Thank you for the comment. The wording of this 

sentence and the table heading in Table 3.2-6 has 

been changed to the reviewer's recommendation.
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349

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L92-15 Environmental 

Protection 

Agency (EPA), 

Region 10

Section 4.2.3 .2, page 271, paragraph 3: We note 

that the statement "A prevention of significant 

deterioration analysis is most appropriate at 

sensitive receptors such as the town of Nuiqsut, 

when there are no Class I or Class II areas in the 

near field," seems erroneous and suggest that 

this may be intended to read," ... Sensitive Class 

II areas ... ". We recommend clarifying in the Final 

SEIS.

3.5 Air Quality & 

Meteorology

Per the reviewer's comment, this sentence was 

reworded to note that the town of Nuiqsut is a sensitive 

Class II area.

L92-16 Environmental 

Protection 

Agency (EPA), 

Region 10

Section 4.2.3.2, pg. 276-277 and Table 4.2-18: 

We note that the PSD increment analysis 

discussion is limited on page 276 and incorrectly 

refers to Table 4.2-17b (as the results are in Table 

4.2-18). It is important to note the results are 

indicative of the maximum increment consumption 

expected in the community of Nuiqsut due to the 

project. We recommend that the Final SEIS 

describe what emissions were used in the PSD 

increment analysis (project-only versus 

cumulative emissions) as well as the results of the 

analysis. Given these values are well below the 

PSD increment, the modeling demonstrates the 

project will not contribute significantly to the 

deterioration of air quality in Nuiqsut. We also 

recommend additional discussion regarding the 

Table 4.2-27 results (alternative C PSD increment 

consumption). 

3.5 Air Quality & 

Meteorology

Per the reviewer's comment, additional detail was given 

regarding the PSD increment analysis including which 

modeling scenario was used, which impact values were 

used, and whether background values were included. 

For additional detail on the methodology for this 

analysis, please refer to the AQIA.
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Alpine Satellite Development Plan for the Proposed Greater Mooses Tooth 2 Development Project

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Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L92-17 Environmental 

Protection 

Agency (EPA), 

Region 10

Section 4.2.3.2: The EPA recommends either the 

Final SEIS or the accompanying modeling report 

included as an appendix show the concentration 

isopleth plots that demonstrate the spatial 

distribution of pollutant impacts in cases where 

the maximum concentrations are near the 

NAAQS, particularly 1-hour NO2 and 24-hour 

PM10 standards. These plots help provide agency 

decision-makers a tool to understand the extent of 

impacts and help gauge the need for mitigation. 

3.5 Air Quality & 

Meteorology

Figures including isopleths for all modeled alternatives 

and scenarios have been added as an appendix to the 

AQIA for the 1-hour NO2 and 24-hour PM10 model 

results in the near-field analysis. The far-field modeling 

results are well below all NAAQS/AAAQS and therefore 

isopleths were not created.

L92-18 Environmental 

Protection 

Agency (EPA), 

Region 10

Section 3.4.7.1, page 228, the first full paragraph 

states that cancer was the leading cause of death 

among North Slope Borough residents. Based on 

Table 9 in Appendix G, the statistics for lung, 

cervical and ovarian cancer are for the NSB, 

although not clearly conveyed as written. We 

recommend including a reference to the table in 

the text of Section 3.4.7.1 and clarifying what is 

meant. We also recommend clarifying the second 

paragraph, under Tobacco, to convey that " ... 

smoking among adults is high (62 percent). 

Smoking among teens (as reported by the 

household) was notably and significantly more 

common (43 percent) than the rest of the North 

Slope Borough communities overall (16 percent)." 

3.18 Public 

Health

Appendix G and SEIS text has been updated as 

suggested. 

L92-19 Environmental 

Protection 

Agency (EPA), 

Region 10

Section 3.4.7.1, page 228, 3rd and 4th 

paragraphs state that air monitoring data do not 

support the perception that oil and gas 

development is the source of air pollution. Most of 

the air quality data for Nuiqsut, however, are for 

criteria pollutants. We recommend that the 

inclusion of hazardous air pollutants data and 

discussion of these data in the Final SEIS may be 

helpful in understanding what sources contribute 

most to health risk and what HAPs may be 

present. 

3.18 Public 

Health

Section 3.4.7.1 has been updated to clarify that 

monitoring data is only available for criteria pollutants. 

Data on air quality modeling for hazardous air 

pollutants has been included to bolster the argument 

that there are no anticipated public health impacts from 

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

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Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L92-20 Environmental 

Protection 

Agency (EPA), 

Region 10

Table 4.2-14, page 272: We recommend defining 

the footnotes included in this table. We also 

recommend that the toxicity values for 

formaldehyde be included: REL= 55 ug/m3, RfC = 

9.8 ug/m3, IUR = l.3E-05 per ug/m3. 

3.5 Air Quality & 

Meteorology

Thank you for the comment. The footnotes are not 

required here as the source for the RELs, RfCs, and 

cancer unit factors can be retrieved from the AQIA, 

therefore they were removed. Also, the REL, RfC, and 

cancer unit risk factor for formaldehyde was added.

L92-21 Environmental 

Protection 

Agency (EPA), 

Region 10

Section 4.2.3.2, page 275: We recommend that 

the text acknowledge that the list of BTEX, nhexane, and formaldehyde included here is an 

abbreviated list of the possible HAPs associated 

with oil and gas development activities. 

3.5 Air Quality & 

Meteorology

Per the reviewer's comment, it was specified that 

selected HAPs were presented and analyzed for the 

GMT2 Project.

L92-22 Environmental 

Protection 

Agency (EPA), 

Region 10

Table 4.2-17a, page 276: We note that NO2 (Ihour) and PM10 (24-hour) are close to standards 

and we highly recommend and support a robust 

air quality monitoring program for the project to 

determine if standards for these NAAQS are 

exceeded. 

3.5 Air Quality & 

Meteorology

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

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Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L92-23 Environmental 

Protection 

Agency (EPA), 

Region 10

Section 4.2.3.2, page 277, first paragraph, and 

Page 284: We note that vehicle traffic is higher at 

certain times of the year, when maximums occur. 

The average is based on one year, and therefore, 

we recommend that the Final SEIS provide 

justification for this assumption as well as discuss 

that maximums will happen at certain times and 

when they typically occur. 

3.5 Air Quality & 

Meteorology

Thank you for the comment. It is not certain that the 

maximum impacts would occur at the same time as 

higher vehicle traffic. For example, the majority of 

construction traffic is expected to occur during the 

winter months based on the schedule detailed in each 

of the emissions inventories and maximum PM10 

impacts would likely occur during the summer months 

(June through September) when the ground isn't 

frozen. The assumption for monthly average traffic was 

based on the best available data provided by the 

Proponent. It is important to note that the average is 

not based on one year, but instead on the length of 

activity. For example, the monthly trips for construction 

are based on a three or four month period and not 

divided by a 12 month period. Details about data 

sources are found in the reports for the various 

emission inventories and AQIA. For the last suggestion 

from the commenter to discuss that maximums will 

occur during certain times and when they typically 

occur, the SEIS does that in detailing the methodology 

for near-field modeling. Sources were turned on and off 

depending on when they were expected to have a 

potential to emit. Again, we direct the commenter to the 

AQIA where that level of detail regarding expected 

impacts is analyzed.

L92-24 Environmental 

Protection 

Agency (EPA), 

Region 10

Section 4.2.3.2, page 277: Although inferred, we 

recommend that the meaning of the results be 

included, given the modeling results are 

significantly below the NAAQS, and project 

criteria pollutant emissions are not expected to 

affect the health of even the most sensitive 

individuals in the community.

3.5 Air Quality & 

Meteorology

Based on the commenter's suggestion, a sentence was 

added to both sections to state 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.
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Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L92-25 Environmental 

Protection 

Agency (EPA), 

Region 10

Table 4.2-19a, page 277: We recommend the 

cancer risks be presented by chemical, and then 

summarized, so the reader can see whether and 

how each chemical contributes to the cancer risk 

calculation. 

3.5 Air Quality & 

Meteorology

Based on the commenter's suggestion, the tables for 

Alternative A and C cancer risk results have added 

rows to break out benzene cancer risk, ethylbenzene 

cancer risk, and formaldehyde cancer risk.

L92-26 Environmental 

Protection 

Agency (EPA), 

Region 10

Page 278 and Page 286: The Draft SEIS states 

that for all HAPs, except formaldehyde, a 

conservative unitized run was conducted. We 

recommend that the Final SEIS provide 

discussion regarding what was done differently for 

formaldehyde. 

3.5 Air Quality & 

Meteorology

A sentence was added in the Alternative A and 

Alternative C sections stating "Formaldehyde was 

modeled using actual emission for each individual 

source so as to demonstrate that the unitized emission 

methodology over-estimated impacts."

L92-27 Environmental 

Protection 

Agency (EPA), 

Region 10

Page 283: If additional HAPs could be associated 

with airstrip activities, such as fueling, we 

recommend that the Final SEIS include these 

emissions in the Alternative C assessment. 

3.5 Air Quality & 

Meteorology

Only benzene, toluene, ethylbenzene, xylenes (BTEX), 

n-Hexane, and formaldehyde were chosen to be 

analyzed for all sources associated with the GMT2 

Project as they are the most predominant HAP 

emissions associated with oil and gas activity. Though 

there are many listed HAPs by the EPA, BTEX, nhexane, and formaldehyde, are consistently the 

majority of total HAP emissions for oil and gas sources.

L92-28 Environmental 

Protection 

Agency (EPA), 

Region 10

Table 4.2-28a, page 285: We note that 

formaldehyde and benzene comprise a high 

percentage of the 1-hour REL. If actual 

concentrations are higher than what was 

modeled, there is the potential for acute health 

effects, and we recommend that this should be 

discussed in the Final SEIS. Also, we recommend 

that cancer risk be presented by chemical, so 

each chemical's contribution to the total cancer 

risk can be evaluated.

3.5 Air Quality & 

Meteorology

The estimated maximum impacts for 1-hour 

formaldehyde and benzene are below 50% of the REL. 

Discussion regarding the conservative nature of the 

unitized model run used for benzene can be found in 

the GMT2 AQIA. Rows have been added to speciate 

benzene, ethylbenzene, and formaldehyde cancer risk 

at the Nuiqsut receptor.

L92-29 Environmental 

Protection 

Agency (EPA), 

Region 10

Appendix G, Table 9: We recommend that the 

age-adjusted rates for cervical and ovarian cancer 

be provided, as more than six cases were 

reported. If there is a reason these rates are not 

appropriate to report, then we recommend that 

the Final SEIS include that discussion as well.

3.18 Public 

Health

Community-level data are limited due to the restrictions 

in place for privacy concerns. Privacy concerns are 

explained in the Introduction to Appendix G. 
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Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L92-30 Environmental 

Protection 

Agency (EPA), 

Region 10

Section 3.2.3.2, page 87: We recommend 

replacing "Alaska belongs to Region 10 Pacific 

Northwest of the United States Environmental 

Protection Agency ... " to "Alaska is one of four 

Pacific Northwest states regulated under Region 

10 of the U.S. Environmental Protection Agency 

... " 

3.5 Air Quality & 

Meteorology

The wording of this sentence has been changed to the 

reviewer's suggestion.

L92-31 Environmental 

Protection 

Agency (EPA), 

Region 10

Page 185, 2nd paragraph: We recommend 

changing the labels on Figures A-2 to A-9 to F-2 

to F-9. 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Text has been revised to correct Figure number 

reference.

L92-32 Environmental 

Protection 

Agency (EPA), 

Region 10

Page 229, 2nd paragraph: We recommend adding 

a table number for food insecurity data (Table 3.4-

18). 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Text has been revised to reference Table 3.4-18

L92-4 Environmental 

Protection 

Agency (EPA), 

Region 10

In working with the BLM and the Corps on the 

Greater Mooses Tooth-I project, we identified 

concerns with the wetland functional assessment 

and the impact criteria used to compare impacts 

to vegetation and wetlands between alternatives. 

We believe the analysis done for GMT-2 largely 

addressed our concerns and that the resulting 

impacts analysis is appropriate. 

3.8 Vegetation 

and Wetlands

No Change, supportive statement.
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Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L92-6 Environmental 

Protection 

Agency (EPA), 

Region 10

We note the Draft SEIS concludes the preferred 

alternative may significantly restrict subsistence, 

primarily due to impacts to caribou. While we 

recognize the past and on-going work by the BLM 

and applicant to address impacts to subsistence, 

we encourage additional coordination with the 

community of Nuiqsut and other subsistence 

practitioners in the project area. We also 

recommend continuing to identify any additional 

mitigation opportunities for these impacts that 

could be incorporated to the extent possible into 

the preferred alternative. 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Several new potential mitigation measures have been 

added to Chapter 4 to address recommendations made 

during the comment process to minimize identified 

impacts. See Sections 4.4.2.8 and 4.4.5.6.

L92-7 Environmental 

Protection 

Agency (EPA), 

Region 10

We recommend the development and inclusion of 

a comprehensive monitoring program plan in the 

Final SEIS. This plan should be developed in 

consultation with the applicable resource 

agencies and local stakeholders, and be included 

as an appendix to the Final SEIS. We recommend 

the plan include appropriate adaptive 

management strategies should actual impacts 

differ from what was anticipated in the Final SEIS. 

This monitoring should occur in all phases of the 

project (construction and operation) and focus on 

air quality, hydrology and subsistence. As with the 

monitoring program for GMT-1, we believe this 

information will be helpful not only for the 

understanding of this project, but also for other 

upcoming projects within the NPR-A. 

4.2 Mitigation According the BLM's NEPA Handbook, CEQ 

Regulations (40 CFR 1505.2), and as required by the 

NPR-A IAP ROD, monitoring is required to ensure the 

effectiveness of mitigation measures. BLM has an 

existing monitoring program that has been established 

through its previous Records of Decision. See Section 

4.2.3.2, Air Quality and Section 4.4.6, Subsistence, for 

a list of specific proposed mitigation measures for 

GMT2 that require additional monitoring. 
Supplemental Environmental Impact Statement

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

356

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

L92-8 Environmental 

Protection 

Agency (EPA), 

Region 10

Section 3.2.3.1, page 85: We recommend revising 

the statement, "Conversely, during unstable 

conditions, upward and downward movement in 

the atmosphere exists, and dispersion of 

pollutants in the atmosphere is enhanced," to 

"Conversely, during unstable conditions, vertical 

motions in the atmosphere are prevalent, and 

dispersion of pollutants in the atmosphere is 

enhanced". We also recommend revising the 

statement, "The GMI'2 Project area will typically 

have more large-scale temperature inversions in 

the winter ... " to "The GMT2 Project area will 

typically have more severe inversions in the 

winter ... ". 

3.5 Air Quality & 

Meteorology

The wording of both sentences in Section 3.2.3.1 have 

been revised to the reviewer's suggestion.

L92-9 Environmental 

Protection 

Agency (EPA), 

Region 10

Table 3.2-4, page 86: Under the "Weather Data" 

column, we recommend revising the "daily max 

temperature" and "daily min temperature" 

headings to "daily average max temperature" and 

"daily average min temperature", respectively. 

3.5 Air Quality & 

Meteorology

"Avg" was added to each of the rows depicting average 

maximum and average minimum daily temperatures 

per the reviewer's comment.

NQT1-1 Mamie Pardue Stick picking crews in summer are lax in 

performance of duties, longer road will make this 

worse. Want to see more collaboration between 

local crews and Alpine crews to clean up after 

winter activities. KSOP? Hire local youth to help?

4.2 Mitigation See Section 4.5 Impacts of Oil, Water and Hazardous 

Materials Spills, Potential Mitigation Measure 1: Trash 

Removal and Anti -Littering Campaign. 

NQT2-2 Frederick Tukie 

Sr

Delineators aren't removed after ice road season 

at Nigliq Channel and ice road to ASRC gravel 

mine.

4.2 Mitigation See Section 4.5 Impacts of Oil, Water and Hazardous 

Materials Spills, Potential Mitigation Measure 1: Trash 

Removal and Anti -Littering Campaign. 
Supplemental Environmental Impact Statement

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

357

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

NQT3-1 Peter Kosbruk, 

Native Village 

of Nuiqsut

Activities are allowing hunters to travel further and 

further, causing more stress to our search and 

rescue during harvest seasons. Our subsistence 

activities are already stressed. Animals and 

hunters are 2 different factors.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

The following new potential mitigation measure has 

been added to Section 4.4.2.8. 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

NQT4-1 Dora Leavitt At the Trilateral meeting last week, the public told 

Kuukpik that they need to remove the restriction 

on ATV access on the Spur Road - lots of 

interpretation on that, people are worried it will be 

enforced and or be extended to other sections of 

road. When that Spur Road went up it restricted 

our access - already 20-30 years of ATV access.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

BLM has included a potential mitigation measure 

requiring a road access agreement by ConocoPhillips 

for use of the GMT2 Road by the community of Nuiqsut 

that specifies the rules for utilizing the road, and 

guarantees continued access. See Section 4.4.6, 

Subsistence, Potential Mitigation Measure 1
Supplemental Environmental Impact Statement

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

358

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

NQT4-2 Dora Leavitt CD5 – GMT1 Roads are Restricting hunters: too 

steep = they got to go all the way around – CD5 

at the mouth of Tingmiaqsigvik – those ramps are 

not going to be that – no snowmachine is going to 

cross the road, it is too steep and this time of the 

year it is all gravel

THIS TIME OF YEAR – people are still traveling 

by snow machine because there is snow on the 

tundra but they can’t cross the road because it is 

gravel – right now they are going around the 

GMT1 road to go to those cabins – mouth of 

Ting/Fish Creek – because usually straight from 

Nui to those cabins – they stay on this side of the 

river (Nigliq) – when you should go right side of 

GMT1 where natignak (flat) we go through there 

to get there but now they are having to go way 

around or go through – we don’t travel that way –

everybody likes to stay on the natignak esp. this 

time – that is the trail – straight shot – trail is on 

the east side of CD5 between CD5 and Nigliq 

about an eight of a mile – from the dump there is 

a visible trail through lakes straight to CD5 when 

get to the mouth little bit northwest turn and that is 

the smoothest

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

BLM has included a potential mitigation measure 

requiring ConocoPhillips to work with the community of 

Nuiqsut to identify the location and design specification 

for the access ramps and pull outs along the GMT2 

road. See Section 4.4.6, Subsistence, Potential 

Mitigation Measure 7

NQT4-3 Dora Leavitt Ramps are not in the right place and even if they 

are no one is going to use it when they have a 

load (loaded sled being towed by snowmachine) 

they are not going to make it up the ramp, they 

are not going to block traffic, they are already all 

gravel and so steep - towards GMT with those 

little creeks very deep makes it dangerous travel –

creeks are deep when covered in snow , you don’t 

see the danger

4.2 Mitigation See Section 4.4.5 Subsistence, Potential Mitigation 

Measure 7: Road Pullouts and Access Ramps along 

the GMT2 Road.
Supplemental Environmental Impact Statement

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

359

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

NQT4-4 Dora Leavitt People are heading out that way for Fish Creek 

geese hunting, they love Fish Creek for that so 

this is a big impact. When they don’t have the ice 

road anymore people are going to access the 

spur road and walk away and going to access the 

GMT1 road – no restrictions – when no ice road, 

they will use the gravel road, the ice road become 

like a highway 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

The SEIS discloses both potential benefits and 

potential negative impacts of the road and attempts to 

be succinct. Recent data on use of roads, gathered 

since the Draft SEIS was published, and verbatim 

testimony from hunters, has been included in the Final 

SEIS. 

NQT4-5 Dora Leavitt What I don’t see CPAI doing anymore when they 

cut the creek now they don’t mark it with orange 

crosses – food coloring on what they cut big pile 

of cuttings both side – safety issue – big ditch in 

the middle – no communication

4.2 Mitigation See Section 4.4.6 Public Health, Potential Mitigation 

Measure 4 regarding the additional requirement to 

mark trails at ice bridges to indicate they have been 

slotted and are closed to travel.

NQT6-1 Dave Arnold, 

City of Nuiqsut

After reviewing the content of page 176 of the 

Draft SEIS for GMT2, the Nuiqsut City Council 

feels that given the delays in moving through this 

SEIS process, that the information which 

describes the state of the City is quite outdated 

given the number of changes that have occurred 

since it was first provided.

As a result the Mayor has asked me to provide 

the following narrative to replace that currently 

found on page 176.

Please let me know what else you may need to 

incorporate these changes. 

3.16 Economy Revised and incorporated updated information for 

section on "Local Economy: Community of Nuiqsut" 

and oil and gas operations impacts.
Supplemental Environmental Impact Statement

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

360

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

NQT6-2 Dave Arnold, 

City of Nuiqsut

Following notification by the State of Alaska 

DCCED of NPR-A Impact Mitigation Program 

awards to the City of Nuiqsut totaling $1,409,064 

for Fiscal Year 2019, the City has begun to move 

forward in improving administrative and financial 

management capacity, in developing recreation 

and enrichment opportunities for the community’s 

youth, and in renovating Kisik Community Center 

(City Hall) mechanical systems. 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. Although 

there is quite a bit of work yet to be done, 

especially given the extremely limited financial 

resources available over the prior ten years, 

progress is beginning to made and will continue 

as long as NPR-A Impact Mitigation Program 

grant awards are sufficient to address very rapidly 

changing physical, cultural and social 

environments.

3.16 Economy Revised and incorporated updated information for 

section on "Local Economy: Community of Nuiqsut" 

and oil and gas operations impacts.

NQT7- 1 Native Village 

of Nuiqsut

Need to say that hunters have a right to use the 

land, and have road usage posted.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

BLM has included a potential mitigation measure 

requiring a road access agreement by ConocoPhillips 

for use of the GMT2 Road by the community of Nuiqsut 

that specifies the rules for utilizing the road, and 

guarantees continued access. See Section 4.4.6, 

Subsistence, Potential Mitigation Measure 1

NQT7- 10 Sam 

Kunaknana

Continue caribou subsistence monitoring report, 

and year 9-10 needs to go into the Final EIS. 

There should be no publication of a Final without 

Year 9-10.

3.11 Caribou Information from years 9-10 was being finalized and is 

included in the DSEIS where appropriate.
Supplemental Environmental Impact Statement

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

361

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

NQT7- 10 Sam 

Kunaknana

Continue caribou subsistence monitoring report, 

and year 9-10 needs to go into the Final EIS. 

There should be no publication of a Final without 

Year 9-10.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

The analysis for Subsistence presented in section 4.4.5 

of the Final SEIS includes the most up-to-date data 

regarding subsistence harvest and use for the project 

area. The analysis utilizes data through year 9 of the 

SRB&A study referenced by the commenter. Each year 

SRB&A produces a detailed report that not only 

describes the data collected for that study year, but 

also the contribution of the data to the totality of data 

collected during the study period. In this way, each 

annual report provides the best available data overall 

on the subject of caribou use by the community of 

Nuiqsut. While the study referenced was envisioned as 

a 10-year effort it will continue to collect annual data 

pursuant to the GMT1 Record of Decision beyond year 

10. 

NQT7- 2 Native Village 

of Nuiqsut

Pipeline should be dark colored and higher 2.1 Proposed 

Action & 

Alternatives

The NPR-A IAP ROD BMP E-7 currently contains the 

requirement that pipeline be at least 7 feet above the 

ground surface, which has been found to be adequate 

for travel beneath by both subsistence hunters and 

animals such as caribou. It is currently industry 

standard that pipelines are matte, meaning not shiny, in 

order to match the natural background, and is included 

by the applicant as a design detail for their proposed 

action. 

NQT7- 3 Native Village 

of Nuiqsut

Put signs about road usages, and rules for using 

the different roads.

2.1 Proposed 

Action & 

Alternatives

Proposed Mitigation Measure 1: GMT2 Road Right of 

Access Agreement includes the requirement for 

adequate signage and communicating community 

information regarding rules for access.

NQT7- 4 Peter Kosbruk, 

Native Village 

of Nuiqsut

September or October, have a public meeting with 

Nanuq and CPAI where they explain all ice road 

activity to the community.

4.1 Stakeholder 

involvement and 

tribal 

engagement

See Section 4.4.6, Subsistence, Potential Mitigation 

Measure 10.
Supplemental Environmental Impact Statement

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

362

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

NQT7- 5 Eli Nukapigak, 

Native Village 

of Nuiqsut

NS Wildlife Department Studies, from 1975 to 

2000, from UAF's Gary Cofina, put these studies 

in 810 analysis.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

North Slope Borough studies regarding wildlife and 

subsistence use are included in the SEIS (e.g., Bacon 

et al; Brower and Hepa; Brower and Opie) in Section 

4.4.5 Subsistence. The ANILCA 810 uses information 

from the SEIS.

NQT7- 6 Jonah 

Nukapigak, 

Native Village 

of Nuiqsut

3rd party contractor to look at links between air 

quality and human health in winter during 

construction.

3.5 Air Quality & 

Meteorology

The near-field analysis evaluated human health risk 

during all phases of the GMT2 Project, including 

construction, through the modeling of hazardous air 

pollutants (HAPs) and comparing the potential impacts 

to the acute reference exposure levels (RELs), 

immediately danger to life or health values (IDLH/10), 

non-cancer reference concentrations for chronic 

inhalation (RfC), and cancer risk thresholds. The 

modeling results for all phases of the GMT2 Project 

under all proposed alternatives were lower than the 

respective thresholds used to determine the potential 

for negative health effects.
Supplemental Environmental Impact Statement

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

363

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

NQT7- 6 Jonah 

Nukapigak, 

Native Village 

of Nuiqsut

Need a fish study to examine impacts to fish and 

subsistence harvest of fish. Jason Libby at UAF 

has a study out. Especially look at Fish Creek, 

fish with fungi in Niglig and Kuukpik, so they move 

to Fish Creek. Why are fish sick and dying?

3.9 Fish Jason Leppi (sic) is conducting a broad whitefish study 

targeting the movement and habitat use of adult fish in 

the Colville River. The BLM is not aware that he has 

documented fish moving from the Colville to Fish 

Creek, although in 2003 the State did document broad 

whitefish moving between these two drainages (Morris, 

W. 2003. Seasonal Movements and Habitat Use of 

Arctic Grayling (Thymallus arcticus), Burbot (Lota lota), 

and Broad Whitefish (Coregonus nasus) within the Fish 

Creek Drainage of the National Petroleum Reserve –

Alaska, 2001-2002. Alaska Department of Natural 

Resources, Office of Habitat Management and 

Permitting, Technical Report No. 03-02). 

Broad whitefish (and subsequently humpback 

whitefish) have been observed with a water mold 

(Saprolegnia) in the Colville River in 2013-2016. While 

this mold exists worldwide, these are the first instances 

(excluding a single fish in 1980) documented on the 

North Slope. The North Slope Borough is spearheading 

a collaborative investigation into the extent of 

observations, possible drivers of the disease, and 

future implications for the fish. They have published 

one paper/report to date (Sformo, T.L. and 9 others. 

2017. Observations and first reports of saprolegniosis 

in Aanaakliq, broad whitefish (Coregonus nasus), from 

the Colville River near Nuiqsut, Alaska. Polar Science, 

Volume 14: 78-82.

NQT7- 7 Peter Kosbruk, 

Native Village 

of Nuiqsut

Inspection process for plugging and abandonment 

needs to be more transparent. Train KSOP 

personnel or send a trained 3rd party with KSOP 

to inspect well closure.

3.18 Public 

Health

See Section 4.4.2, Locally Requested Mitigation 

Measures, Establish a BLM Field Office in Nuiqsut 

NQT7- 8 Hazel 

Kanaknana, 

Native Village 

of Nuiqsut

Hire local liaison for CPAI to communicate. 4.1 Stakeholder 

involvement and 

tribal 

engagement

See Section 4.4.6, Subsistence, Potential Mitigation 

Measure 10.
Supplemental Environmental Impact Statement

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

364

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

NQT8- 1 Sam 

Kunaknana

Native Village of Nuiqsut needs to approve Final 

Caribou Subsistence Monitoring Report (CSMR) 

before publication and also approve study 

methodology.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

The methodology used for the Nuiqsut Caribou 

Subsistence Monitoring Report is described in Section 

4.1.2.1. The continuation of caribou monitoring was 

established by a BLM Supplemental BMP for GMT1 

and the BLM has included a Potential Mitigation 

Measure for GMT2 specifying that that BLM and NVN 

must approve of the methodology and review process.

NQT8- 1 Sam 

Kunaknana

Native Village of Nuiqsut needs to approve Final 

Caribou Subsistence Monitoring Report (CSMR) 

before publication and also approve study 

methodology.

4.2 Mitigation See Section 4.4.5 Subsistence, Potential Mitigation 

Measure 6: Subsistence Monitoring Studies.

NQT8- 10 Margaret 

Pardue, Native 

Village of 

Nuiqsut

When the community found out burbot was 

contaminated by heavy metals, people stopped 

eating it. This is an impact of development.

3.9 Fish Out of concern for potential subsistence food 

contamination, the Agency for Toxic Substances and 

Disease Registry (ATSDR) reviewed and evaluated 

four potential exposure scenarios for eating burbot from 

the Colville River (USDHHS 2003). 1) Eating fish from 

the Colville River every day for 70 years; 2) Eating 

whole burbot in high quantities four months of the year; 

3) Eating burbot livers four months of the year; 4) 

Eating several burbot livers in one sitting. While 

polychlorinated biphenyls (PCBs), 

dichlorodiphenyltrichloroethane (DDT), and DDT 

derivatives were detected in fish collected from multiple 

areas of the Colville River, the levels were very low and 

exposures to them are not expected to cause harmful 

health effects. Thus, ATSDR determined that it is safe 

to eat the fish. Additionally, burbot should be included 

in future subsistence foods contaminants monitoring 

required of CPAI.

NQT8- 12 Hazel 

Kunaknana, 

Native Village 

of Nuiqsut

BLM should train students to understand what's 

going on with industry.

4.2 Mitigation See Section 4.4.2 Sociocultural Systems for a 

discussion of community-requested potential mitigation 

measures that address social impacts.
Supplemental Environmental Impact Statement

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

365

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

NQT8- 2 Sam 

Kunaknana

Want to see data from air quality monitoring, and 

see a Native Village of Nuiqsut air quality 

monitoring station.

3.5 Air Quality & 

Meteorology

The data currently collected at the air monitoring site in 

Nuiqsut is property of CPAI. BLM is considering a 

requirement to expedite the timeframe for data review 

and dissemination of the Nuiqsut monitoring data in the 

GMT2 ROD, see Section 4.2.3 Atmospheric 

Environment, Potential Mitigation Measure 4.

NQT8- 3 Native Village 

of Nuiqsut

Native Village of Nuiqsut and Nuiqsut do not want 

to see GMT2 go forward until GMT1 is done being 

constructed.

2.1 Proposed 

Action & 

Alternatives

The BLM takes your suggestion seriously, but it is 

impossible for the BLM to suspend or set aside GMT2. 

As stated in Sections 1.3 and 1.4, the BLM is unable to 

postpone processing the GMT2 Application for Permit 

to Drill based on regulatory requirements in NPR-A 

found at 42 USC Section 6506(a). Deferral of a project 

authorization would be inconsistent with the directive in 

the Naval Petroleum Reserves Production Act to 

expeditiously carry out an oil and gas leasing program 

and the rights ConocoPhillips acquired with the subject 

leases to reasonably develop the oil and gas within 

those lease tracts. GMT2 was originally approved for 

development as CD-7 in 2004 under the Alpine Satellite 

Development Plan EIS. ConocoPhillips anticipates that 

the earliest that construction on GMT2 could begin is 

the winter operational season of 2018-2019. 

Construction at GMT1 was completed in July 2018, and 

first production is anticipated in October-December 

2018. 

NQT8- 4 Peter Kosbruk, 

Native Village 

of Nuiqsut

Wants to see emergency supplies like 

masks/respirators in community. Also have HEPA 

filters in schools to have clean space for 

evacuation.

3.18 Public 

Health

See Section 4.5, Potential Mitigation Measure 8: 

Creation of Emergency Respite Zone

NQT8- 5 Margaret 

Pardue, Native 

Village of 

Nuiqsut

Evacuation plan for villages in EIS. 3.18 Public 

Health

Please see Section 4.5, Potential Mitigation Measure 7 

- GMT2 Industrial Disaster Response Plan for Nuiqsut
Supplemental Environmental Impact Statement

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

366

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

NQT8- 6 Sam 

Kunaknana

Nuiqsut needs to have a role in enforcement of 

trash pickup and environmental violations.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

BLM has included a potential mitigation measure 

regarding trash removal and an anti-littering campaign. 

See Section 4.5, Potential Mitigation Measure 1

NQT8- 7 Sam 

Kunaknana

Broad whitefish die while overwintering, and there 

should be no action on further development until 

root cause is determined.

3.9 Fish There is currently no scientific evidence that broad 

whitefish are dying while overwintering in this region 

due to anything beyond naturally occurring conditions. 

Some individual fish of any species may select an 

overwintering area that is not adequate to support their 

needs (typically due to dissolved oxygen depletion, 

freeze down of ice, and/or depletion of energy 

reserves) which can lead to mortalities.

NQT8- 9 Margaret 

Pardue, Native 

Village of 

Nuiqsut

Chemicals used in fracking need to be tested for 

in the water.

3.18 Public 

Health

See Section 4.4.6, Potential Mitigation Measure 3, 

Water Quality Monitoring Program.
Supplemental Environmental Impact Statement

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

367

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

NQT9-1 George Sielak, 

Unknown 

Speaker, 

Eunice Brower, 

Roy Nageak

The yellow haze is real. It has not been 

thoroughly looked into whether it's toxic or air 

pollution to the community. You get a southwest 

wind. When you build GMT2, we have a strong 

southwest blizzards exactly coming towards from 

GMT2 unit. And that's going to form yellow haze. 

And the more you build drill sites and start 

developing, these yellow haze will not go away. 

This is the time of the year they start appearing. 

And it goes directly towards Barrow also. They 

always feel it. So these are the pollutants that 

have not been thoroughly studied whether they're 

not toxic or toxic to our people, our infants and our 

elders. So those need to be considered as a 

thorough study if BLM is going to go ahead and 

pursue GMT2.

We deal with that every season. Every spring we 

deal with yellow haze. And all those are coming 

from Prudhoe Bay working which way. We can 

see Alpine yellow haze covering, and it goes 

further northwest. And that's how far it goes from 

this industry and from the drill sites. It's a 

combination of numerous -- all companies that 

have drilled up and start producing. That's when 

this yellow haze starts forming.

It happens every -- every spring. You look at the 

north side of the -- of the shore line of Beaufort 

Sea. It's like a mound of yellow that will hover. 

It's a smoke that just hovers and stays there. And 

at some point when you have a wind direction, it 

will be blown away.

3.5 Air Quality & 

Meteorology

The air quality impacts of all known GMT2 sources 

have been assessed as part of the impact assessment. 

Effects were determined to be minimal. Arctic Haze is 

currently understood to be from transported air pollution 

from Northern Europe and Russia that reach Alaska in 

the winter and early spring and is not anticipated to be 

affected by emissions from equipment at GMT2. The 

SEIS has been revised to include information about 

Arctic Haze.
Supplemental Environmental Impact Statement

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

368

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

NQT9-1

Continued

George Sielak, 

Unknown 

Speaker, 

Eunice Brower, 

Roy Nageak

Yeah, because some days when it's stagnant, the 

wind -- when it's stagnant, you can clearly see it 

out there. You can see it because it's so clear, 

the white -- the whiteness of the snow just brings 

it out. You can clearly see it visible.

We're starting to see that in Barrow too. And I 

think because of our -- more vehicles and more 

heavy equipment, we're starting to see that 

yellow haze around Barrow too. It's mostly from 

possibly the running equipment, because we're 

not (indiscernible) in Barrow. That yellow haze 

kind of drifts away from Barrow right in front, and 

when it's not blowing, it just sits there.

I know. When the ice road season closes, that's 

when it starts hovering. That's when all the 

equipment all cease during -- when the ice flow 

seasons. When the ice road closes, that's when it 

starts hovering. It's not just from all vehicles or 

equipment, it's all coming directly from -- from all 

those facilities that are -- that are transporting oil. 

So that's something that's not just directly from 

any kind of vehicles that they have in town. If it 

did, we probably will see it here hovering in our 

Village.

3.5 Air Quality & 

Meteorology

See above BLM response
Supplemental Environmental Impact Statement

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

369

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

NQT9-10 Eunice Brower Because every piece of equipment that is used is 

diesel equipment. And all those diesel equipment 

put out nitrogen oxides. Nitrogen oxides are 

actually what make people more susceptible to 

sicknesses, and illnesses, respiratory especially. 

And they put or a fine particulate matter, so ultra 

fine it's smaller than that PM 2.5. And according 

to the American Lung Association, those ultra fine 

particulate matter are more extremely dangerous 

to human health and -- and wildlife that are in the 

vicinity and breathing in all of that. And can be 

endocrine destructors.

All of these pollutants that are coming from these 

diesel emissions, especially, really affect people's 

health. And you guys are not even addressing 

that. You guys say, "Well, there's no" this and 

that in here. It doesn't say it doesn't affect 

people's health. The chances of you guys have 

blowouts and then not even mitigating for that, for 

people getting sick, and then people having to get 

medevac'd out of this Village because of them 

getting sick. You guys don't even mitigate for 

that.

How can they say there's not enough nitrogen 

oxides in the air to make people sick from all 

these vehicles, all these diesel emissions, from 

every diesel equipment that's being run 24/7 for 

all I know? They might say they're putting --

plugging them into wall rails and this and that 

when they can easily build some big warm 

storage building for all their vehicles to park them 

in and not run them 24/7 and say, "Well, we have 

wall rails to plug them in."

All these diesel emissions are at a ground level. 

They're at a ground level. They're not -- they 

don't have smoke stacks way up high into the 

atmosphere where they can be safely emitted.

3.18 Public 

Health

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. 
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Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

NQT9-11 Rosemary 

Ahtuangaruk

When you put a project together and you say that 

you're going to look at emissions, but then you 

don't even enforce some of the process of 

development, like when we expanded Alpine. In 

your documents you said you're going to shut 

down the flare every few hours to allow the 

particulates to disburse. When you don't enforce 

that and allow it to be flaring for 23 days straight, 

those are very different modeling questions that 

are put out there.

When you're looking at the document, you can 

put your model together and say that "every 

couple hours the flare is shut off and those 

emissions are calculated at such." But if you're 

not enforcing it and showing that those 

emissions are being reduced by making sure 

those flares are shut off, that model is a very 

different model.

When industry is allowed to give exemptions so 

that they can allow 30 flares in one night around 

us in our community, that's a very impactful 

emission that isn't always calculated in your 

variables that can be controlled to say that we're 

not being exposed. When you don't calculate in 

the emissions that occur with the Repsol blowout 

and our Village only takes two hours to have 

respiratory distress, these are very serious 

concerns that can affect a modeling discussion 

that are not incorporated into what you're 

presenting to us.

3.18 Public 

Health

Thank you for articulating these social impacts (i.e., 

distrust, lack of power, concern over lack of 

enforcement of regulations) and concerns regarding the 

cumulative impacts being faced by Nuiqsut. BLM 

recognizes, documents, and tries to analyze with 

transparency, the impacts many residents of Nuiqsut 

experience as required by NEPA. The BLM manages 

the NPR-A pursuant to the requirements of the NPRPA 

of 1976 and the DOI Appropriations Act FY 1981 

implemented at 43 CFR 2360, and 43 CFR 3130. Many 

of the actions that you describe are for activities that 

occur outside the NPR-A, and are therefore, not under 

BLM's regulatory control or management. We 

recognize that it is frustrating to have so many different 

regulatory agencies--federal and state--that play 

different roles in terms of managing things such as 

emissions, erosion, and whether or not to permit oil and 

gas activity. We encourage local and regional 

stakeholders to utilize the avenues afforded them 

through State and Municipal law, and through the 

federal political process to identify and implement 

solutions that are beyond the management authority of 

the BLM to address.
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Comments Comment 

Category Code

Comment Response

NQT9-11

Continued

Rosemary 

Ahtuangaruk

So we've already been exposed to these 

concerns, and your modeling didn't help us to 

prevent our exposure. So you're coming back to 

us and showing a piece of paper, which you're in 

control of all of the numbers that go into that 

document. That doesn't reassure us at all. We 

need to make sure we have those numbers and 

we're incorporating that information, not be misled 

like you did with our monitoring station and didn't 

give us all the variables that we wanted in that

station. So we don't have that data from 20 years 

ago.

3.18 Public 

Health

See above BLM response

NQT9-12 Rosemary 

Ahtuangaruk

These are important discussions when you 

manipulate what's being presented to us. You 

guys are in control of this process. You're not 

looking at our temperatures that we're being 

exposed. You're not looking at our inversions and 

how many days we're having that. You're not 

calculating the severity of the exposures that 

we've already been through to add into this 

discussion and the hypersensitivity that some of 

these people are getting already related to these 

exposures. 

These are all serious discussions that can affect 

your modeling, but you're in control of that. 

That's not very reassuring when we're the ones 

that are suffering the decrease in air quality and 

go decade after decade after decade to 

meetings to say, "We're very concerned about our 

air quality."

3.5 Air Quality & 

Meteorology

The GMT2 SEIS air quality modeling uses the most 

recent meteorological data from Nuiqsut available and 

accounts for local weather patterns when evaluating 

the dispersion of air pollutants from GMT2 and other 

existing and planned development. Estimated pollutant 

concentrations are evaluated against federal and state 

ambient air quality standards, which are designed to 

protect the health of sensitive populations with a margin 

of safety. 
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Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

NQT9-13 Rosemary 

Ahtuangaruk

We talked about how your data could be 

manipulated because a spigot isn't appropriately 

monitored and maintained. And when you have 

ice accumulations, your data is decreased and 

you're not getting particulates that could otherwise 

be monitored.

But when you're not enforcing and making sure 

those maintenance efforts to allow us to have 

appropriate numbers, you can really change what 

occurs on your modeling. That's what we brought 

to the discussion decades ago, and that's what 

we're bringing back to this discussion, because 

we had this process to look at some of these 

concerns. But when you put a model together, 

you can manipulate what goes into that model.

3.5 Air Quality & 

Meteorology

BLM follows strict EPA and ADEC data review 

protocols. Most deviations from monitoring protocols 

will be caught in the data validation review.

NQT9-14 Unidentified 

resident

You know you got a store over here that cost 

hundreds of dollars for a loaf of bread, eggs to 

feed your children. You know, you guys don't look 

at those kind of situation we go through on a daily 

basis. You know?

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Section 4.4.2.1 Sociocultural - Impacts Common Under 

All Alternatives, subsection Economic Disparity 

discusses the high cost of groceries in Nuiqsut. The 

text has been revised to include recent updates on the 

cost of living in Alaskan communities from the Alaska 

Department of Labor and Workforce Development. 

NQT9-15 James Taalak Yeah, I don't like that phrase "hunter avoidance." 

If there's any way you can change that, if you 

please. I think that would be -- make more sense 

to me. Because we're displaced by all that out 

there.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

BLM identifies the loss of subsistence use areas as the 

primary adverse impact attributable to the presence of 

oil infrastructure, which is comparable to hunter 

displacement. The use of the phrase "hunter 

avoidance" is meant to characterize the decision that 

hunters make to not harvest near infrastructure, which 

is an impact separate from displacement. 
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Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

NQT9-16 Rosemary 

Ahtuangaruk

We've had workers from the fields comes to us 

while we're out hunting. I've had my son catch his 

first (indiscernible) when we only had Alpine, the 

first development, and it was right outside our 

cabin. He's never gone there to catch geese 

again because of all the increased changes 

around that area. These are real serious issues. 

It's not -- when you put words that decrease the 

severity of our impact, it really facilitates industry 

from allowing these impacts to continue. It 

doesn't prevent us from enforcing the hardship 

that is put upon our community.

We walked through this for decades, and we told 

you before when you changed the '90 -- '89 EIS 

and changed all of our prescriptive measures to 

be very protective of us. And then you went 

through and changed it with '97, and you took 

out all of the enforcement words in this process.

That's not helping us. And then you coming to us 

and wanting us to work with you in this 

discussion, we know we don't have goodness 

coming from working with you. We lose more and 

more.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Thank you for articulating these social impacts (i.e., 

distrust, lack of power, concern over lack of 

enforcement of regulations, tensions related to the 

permitting process). BLM recognizes, documents, and 

tries to analyze with transparency, the social impacts 

many residents of Nuiqsut experience as required by 

NEPA. The GMT2 DSEIS document (Section 4.4.21) 

cites recent Alaska Native studies that corroborate your 

comments: outreach to solicit insights and concerns on 

negative impacts are antithetical to positive intercultural interactions. However, BLM cannot (legally or 

ethically) proceed with permitting that is required by 

law/legislation without notifying residents and soliciting 

their input. Nor do residents want permitting to occur 

without outreach and consultation. BLM regrets that the 

pace of development and the permitting processes 

themselves can result in these impacts, but neglecting 

to consult with residents and document their concerns 

would be unacceptable.

NQT9-17 Eunice Brower We're losing our hunting areas, our land that we 

normally use to go hunt these animals that we eat 

throughout the whole year. And it's getting 

decreased. We have to go further and further to 

go hunt them. And then sometimes we can't even 

afford it because it costs so much. And then we 

have to end up paying more at the store for very 

little of what we could even afford, which isn't 

even in the same value of what we catch out 

there that's fresh and more healthier.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

BLM identifies the loss of subsistence use areas as the 

primary adverse impact attributable to the presence of 

oil infrastructure in Section 4.4.5 Subsistence.
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Name

Comments Comment 

Category Code

Comment Response

NQT9-18 Unidentified 

resident

Right now the impact is on the road. The height 

of the road is too high, blocking the caribou from 

the northwest, Teshekpuk Herd, (indiscernible) 

herd that migrate through during summer, and 

migrate and back fall time, making these hunters 

to go further out.

3.11 Caribou Gravel roads constructed in the plan area present an 

obstacle to caribou movements. The roads themselves 

and human activity may obstruct movement of caribou, 

particularly during migrations. Roads are constructed to 

accommodate traffic and wide load moves. Roads are 

engineered to maintain permafrost conditions by 

insulating the tundra and offsetting the loss of insulating 

effect caused by compression below the gravel and 

heat transmitted to the ground. Therefore a minimum 

depth of gravel laid for a new road is on average 5- 7 

feet above the tundra. The impact analyses discuss 

adverse effects from gravel access roads. For example, 

snow can pile up along side of these gravel roads an 

obstruct caribou movements. 

NQT9-19 Unidentified Over -- over two years Teshekpuk Herd has never 

come, spring, summer, fall, winter, for past two 

years since CD5 was built. They wintered in 

Wainwright, summered in Wainwright. Not even 

those big herd of Teshekpuk that comes through 

and goes to Teshekpuk Lake for their calving. 

And they're in separate areas, or pretty much 

empty. Why? You allowed these companies to 

build a five-foot height. And that five-foot hasn't 

even gone down yet. And those roads have 

already been built. They say by the time it settles 

down, it should -- supposed to be down to fourfoot. It's still the same.

So we've been mislead by the agencies, misled 

this community, and misled the hunters. And it 

should, by all means, listen to these people. 

Listen to the community. Migration of the 

caribous are getting harder to come through. 

They come -- it's okay when they come 

summertime, but on the west side, no, it's not.

3.11 Caribou Discussion of road bed height and its impact on caribou 

movement is discussed in the DEIS. No text changes 

made.
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Name

Comments Comment 

Category Code

Comment Response

NQT9-19 Unidentified 

resident

In order for that to reduce the impact, you need to 

have a minimum lift, a four-foot road, with a fourto-one slope so that the snowmachines and ATVs 

can have access crossing. And the ramps that 

they have set on right now are still too steep.

And the majority of our hunters don't know where 

those ramps are. Not because impact. It's the 

height of the road that diverts the caribou away 

from this Village. And the more you go towards 

the cliffs, pretty soon this road is going to be right 

on the edge of them cliffs toward the southwest.

So the biggest impact that needs to be reduced 

by BLM and Army Corps of Engineers, lower that 

road down. Not like from CD5 all the way to 

GMT1, not like (indiscernible). That's what we got 

out there.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

BLM has included a potential mitigation measure 

requiring ConocoPhillips to work with the community of 

Nuiqsut to identify the location and design specification 

for the access ramps and pull outs along the GMT2 

road. See Section 4.4.6, Subsistence, Potential 

Mitigation Measure 7

NQT9-2 Unknown 

Speaker

Have you taken the existing structures into 

consideration? Because there's processing 

facilities to our west which they wouldn't normally 

come from. And surely that pipeline was going 

all the way to the west, you know? It's going to be 

carrying all those oil and all them chemicals all the 

way down the pipeline. You know, they might 

have vents to exhaust some of that material and 

whatnot down the way. So that might be 

inaccurate by a long shot, you know. Because i 

just makes a little bit of sense, they're pumping it 

from out over here, and they're trying -- moving it 

down the pipeline to the west and there's 

processing for these (indiscernible), which, you 

know, this oil is going to pass through.

3.5 Air Quality & 

Meteorology

Both existing sources of air emissions and potential 

sources of future emissions were included in the 

analysis of air quality impacts and impacts were found 

to be minimal.
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Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

NQT9-20 Unidentified The further we go, 40 miles or so, to see at least 

one or two caribous out there. And none of our 

people here are being compensated for the loss 

of our caribous.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

The most recent harvest amount data for Nuiqsut 

(discussed in both Chapter 3: Subsistence: Affected 

Environment and in Appendix F: Overview of Nuiqsut 

Subsistence Uses) indicates stable harvest of caribou 

by community residents to date, with an annual harvest 

that ranges between 363 (2005-2006) to 774 (2014) 

individual caribou. In 2016, the last year for which there 

is harvest data, the total number of caribou harvested 

by Nuiqsut was 481.

NQT9-21 Unidentified Whose fault is it? ConocoPhillips? BLM? Army 

Corps of Engineers? It's all your fault, every one 

of them, because you folks didn't listen to this 

community how the road should be built. 

Because these roads are well away from the flood 

plains.

You are just allowing CD5 south. When it starts 

melting, it makes a big massive big one lake down 

there blocking the drainage, natural drainage. 

That's what we see now. Never have we seen 

that before when there was no roads being built 

yet. Now we're seeing that.

3.4 Water 

Resources

In order to minimize ponding of water, 2 foot diameter 

culverts will be placed every 1,000 foot along the road 

route. An inundation analysis has been performed 

which can predict where ponding is likely to occur and 

larger or additional culverts will be installed at those 

locations. 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. Discussions of 

the inundation calculations can be found in section 

4.1.1.2 Construction under the Water Resources 

chapter. Impacts are discussed in 4.1.1.5 Mitigation. 

Sufficient culverts and proper placement should 

prevent issues with ponded water. 
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Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

NQT9-22 Unidentified We've asked for a four-foot lift, but they keep 

finger pointing at Corps of Engineers. They say 

this is Army Corps of Engineers, not BLM. BLM 

is here tonight to make this presentation and 

public hearing on GMT2 and your alternatives. If 

you're going to use an alternative, keep that road 

at a four-foot level.

2.1 Proposed 

Action & 

Alternatives

The GMT2 Access Road has been designed to be a 

minimum of 5 feet high above the ground surface once 

settling has occurred. This design is based on Arctic 

engineering intended to maintain the existing thermal 

regime of the tundra on which it is construction, thereby 

alleviating the potential for road subsidence and 

additional tundra damage. Roads in the existing oil field 

that are currently at a much lower final height above the 

ground surface, are so due to various possible reasons, 

including differing surface conditions, age and longterm settling. It has been found that for the conditions 

that exist along the road routes between GMT1 and 

GMT2, a 5 foot minimum thickness is needed to keep 

the thermal regime intact.

NQT9-23 Unidentified And the road is so -- so high, way up high, not 

low. They're near -- I know they're near -- near 

CD -- CD1, GMT1, GMT2 pollution. I go out to 

Fish Creek, and the wind change is shifting from 

southwest. More pollution is going to head into 

Big Creek. Caribou eat grass, and we eat fish. 

The river that the fish -- the fish that was in the 

river, and that's more pollution going in the river, 

in the water. Then we eat that fish, and we get 

that disease. More pollution coming from that 

side. More, more, and more, so either way.

3.9 Fish BMP A-11 requires CPAI to conduct a monitoring study 

of contaminants in locally-used subsistence foods. This 

BMP was added to the 2012 NPR-A EIS/IAP in 

response to concerns voiced by local residents.
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Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

NQT9-24 Unidentified The ramps are too high, like a V shape. You said 

the road is low. No.

When you're going on and off when you're loaded 

with -- can't get up.

It's added risk. It's a little more tipsy and --

Yeah, they're hard to get up.

[The ramps need to be] wider and longer

I think some of the hunters have tried to use those 

ramps towing a sled. And they couldn't. It won't 

work.

But they -- they weren't able to go over.

Nope. Too narrow. 

So they have to go all the way around.

Their tracks are just spinning.

The ramps are too steep and the road is too high 

and it's straight down.

The ramps are kind of narrow, too.

4.2 Mitigation See Section 4.4.5 Subsistence, Potential Mitigation 

Measure 7: Road Pullouts and Access Ramps along 

the GMT2 Road.

NQT9-25 Unidentified Go low, the road is too high. The caribous can't -

- you know, can't go up high.

4.2 Mitigation The GMT2 Access Road has been designed to be a 

minimum of 5 feet high above the ground surface once 

settling has occurred. This design is based on Arctic 

engineering intended to maintain the existing thermal 

regime of the tundra on which it is construction, thereby 

alleviating the potential for road subsidence and 

additional tundra damage.

NQT9-26 Eunice Brower If they built pads for these staging workmen and 

building, how come they can't

build us one? Why are we just getting little 

ramps?

4.2 Mitigation See Section 4.4.5 Subsistence, Potential Mitigation 

Measure 7: Road Pullouts and Access Ramps along 

the GMT2 Road.
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Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

NQT9-27 Rosemary 

Ahtuangaruk

I know I talked about if we were to put the road, 

she wanted it away from the ridge because the 

caribou go up there for wind relief. And she didn't 

want the road near those high points where we 

know caribou are going to be easy to spot when 

we're out subsistence. That's what she was 

asking about the alternative, the variable on a 

lower elevation on the Nuna versus a higher 

elevation on the ridge

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

The GMT2 Access Road route has been selected to 

be the least impactful to hydrological systems, thereby 

alleviating the potential for road subsidence, additional 

tundra damage, pooling and flooding. As such, the 

route chosen is located on higher ground to the extent 

possible, as this will result in less potential impacts to 

existing hydrology.

NQT9-28 Unidentified And then the hunters who are to go look for a 

ramp, they have to go further out to look for a 

ramp. Wasting a lot of gas. And gas is so much 

here.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Having to travel further to hunt is recognized as an 

impact to subsistence. BLM has included a potential 

mitigation measure requiring ConocoPhillips to work 

with the community of Nuiqsut to identify the locations 

and design specification for the access ramps and pull 

outs along the GMT2 road. See Section 4.4.6, 

Subsistence, Potential Mitigation Measure 7.

NQT9-29 Unidentified They're both the same. If the road is higher or 

lower, it will be the same, because the caribous 

have -- are -- are first experiencing these kind of 

roads in our region. When the road was built at 

CD5, the majority of the caribous go on the north 

side, weren't able to cross the road, and they just 

stayed on the north side of CD5 road. At a later 

time -- at a later time they start crossing, but not 

the major ones. We saw just a small herd I'm 

talking about, a handful. But major caribou 

migration have not come and crossed these roads 

yet. They avoid that regardless of that lower 

elevation, the higher road is in a higher elevation 

it's still the same.

3.11 Caribou The Teshekpuk Lake Caribou have not been exposed 

to new roads and development so it is reasonable to 

expect that roads and traffic may be disruptive and 

cause displacement in some cases. Other studies 

have document caribou habituation to roads. Other 

Studies have shown impacts from roads and traffic 

during calving season. Research shows that the roads 

and traffic could displace caribou from preferred 

habitats. It is important to note that disturbance 

reactions may vary and caribou may habituate over 

time. 
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Name

Comments Comment 

Category Code

Comment Response

NQT9-3 Eunice Brower Especially I want to reference the Repsol blowout 

of 2012. I don't care if they want to say it could 

have been from natural gas from wherever, but 

there's pollutants in the air, especially when they 

have a blowout. And from these drilling muds, 

there's crystalline silica in them. That's even 

another dangerous chemical. And it's such a fine 

particulate matter it's easy to get swept up into the 

air. And all these fine particulate matters take 

longer to fall down than a bigger 2.5 or 10.0, 

bigger than those PM 10. They fall quicker 

because they're bigger, but these ultra fine 

particulate matter stay in the air much more 

longer, and yet carried much more further. 

Wherever the source is coming from, it's still 

there. It's going to be there. These winds are 

carrying it. You guys can say there's no impact, 

but there are. You guys are just not looking at it. 

You're not educating the people enough to let 

them understand those impacts. You guys might 

be putting out this and that and saying this and 

that but...

How can they say there's not enough nitrogen 

oxides in the air to make people sick from all 

these vehicles, all these diesel emissions, from 

every diesel equipment that's being run 24/7 for 

all I know? They might say they're putting --

plugging them into wall rails and this and that 

when they can easily build some big warm 

storage building for all their vehicles to park them 

in and not run them 24/7 and say, "Well, we have 

wall rails to plug them in."

All these diesel emissions are at a ground level. 

They're at a ground level. They're not -- they 

don't have smoke stacks way up high into the 

atmosphere where they can be safely emitted.

3.5 Air Quality & 

Meteorology

Thank you for the comment. Blowouts are not planned 

operations rather they are accidents that the industry 

works actively to prevent. The air quality impact 

analysis in the SEIS considers activities known to occur 

under each alternative to enable an informed selection 

of an alternative based on relative differences between 

impacts. Drilling mud and other fluids used during the 

hydraulic fracturing process are not sources of air 

emissions and thus are not entrained in the air nor 

transported by winds or atmospheric processes. 

The near-field and far-field analyses modeled 

particulate matter and NO2 for all sources that had the 

potential to emit those pollutants during the 

construction, drilling, well intervention, and routine 

operations phases. These sources were assumed to 

operate for 24 hours per day, 7 days per week, unless 

otherwise stated to not occur during certain times (e.g., 

fugitive dust only expected from June through 

September). 

The stack parameters or fugitive release parameters 

used in the dispersion modeling were used based on 

the expected release heights of each source. 

Therefore, the dispersion modeling results take into 

account the expected operation and equipment for the 

proposed GMT2 Project.
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Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

NQT9-30 Unidentified That's why we're asking for a four-foot lift. 2.1 Proposed 

Action & 

Alternatives

The GMT2 Access Road has been designed to be a 

minimum of 5 feet high above the ground surface once 

settling has occurred. This design is based on Arctic 

engineering intended to maintain the existing thermal 

regime of the tundra on which it is construction, thereby 

alleviating the potential for road subsidence and 

additional tundra damage. Roads in the existing oil field 

that are currently at a much lower final height above the

ground surface, are so due to various possible reasons, 

including differing surface conditions, age and longterm settling. It has been found that for the conditions 

that exist along the road routes between GMT1 and 

GMT2, a 5 foot minimum thickness is needed to keep 

the thermal regime intact.

NQT9-31 Unidentified Now you -- I see a picture of the caribou up there. 

These two Conoco characters right here, they 

know, and I know that where the caribous used to 

roam right here are now roaming upriver because 

of these activities. And it's -- I thought this 

meeting was going to be last week, but then I 

realized -- I was walking by, I realized it was 

today. Now I pressed Conoco, too, as a result of 

the caribou migration deflecting to the north of us 

-- I mean, to the south of us. I asked for -- about 

gasoline help for us when we go hunting.

Well, we used to go hunting this way for the 

caribous, now we're going hunting this way for the 

caribous. Directly related to this activity you're 

talking about. And that is very concerning to me 

right now that this -- these facilities are about to 

be set up. Major facilities that will not only impact 

the caribou, but every wildlife that's in that area is 

going to be deflected. And that's something that I 

look at.

3.11 Caribou Discussion of roads, road characteristics, and their 

impact on caribou movement and distribution is 

discussed in the DEIS.

Thank you for your comments. Development is 

anticipated to continue to impact caribou behavior and 

distribution on the north slope, particularly during 

calving seasons. Human activity and development can 

displace caribou which can impact caribou hunting 

opportunities. This is likely to continue into the future, 

particularly in the area west of Nuiqsut. The GMT2 

SEIS will include a cumulative impact analysis (past, 

present and reasonably foreseeable future impacts) 

including impacts from the Willow project. These 

impacts will include direct habitat loss, alteration of 

habitat, obstruction of movement, disturbance and 

displacement, and mortality. These impacts will 

encompass the construction and operation phases and 

full-field development. It is critical that all of the 

potential impacts to caribou are disclosed in the SEIS. 
Supplemental Environmental Impact Statement

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Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

NQT9-32 Unidentified I asked for -- about gasoline help for us when we 

go hunting. It's -- we're starting to get all -- trying

to seek some kind of assistance with our animals 

being deflected from these activities.

4.2 Mitigation See Section 4.4.2 Sociocultural Systems for a 

discussion of community-requested potential mitigation 

measures that address social impacts.

NQT9-33 Unidentified We used to have major area right here, but we 

can't anymore. So we're -- as a result, we don't 

find the animals we're looking for here, we're 

supposed to go to this store here. But a piece of 

meat like that costs 30-something dollars. So 

that's something you guys need to think about as 

you go back to your homes where your meat is 

$11, where it's $30 for us here.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Section 4.4.2.1 Sociocultural - Impacts Common Under 

All Alternatives, subsection Economic Disparity 

discusses the high cost of groceries in Nuiqsut. 

NQT9-34 Eunice Brower What about the ice roads? How much of impact is 

that to the vegetation to deterring these animals?

3.11 Caribou Thank you for your comment. Ice roads can cause long 

term damage to certain types of vegetation. Ice roads 

crush standing dead vegetation, damage dwarf shrubs 

and tussock tundra. Nonetheless the impact of ice 

roads on vegetation and caribou habitat is relatively 

minor compared to new gravel access road. 

NQT9-35 Eunice Brower Does that include where our drinking water lake is 

on that map? Does it show where's our drinking 

water lake source? Well, it should, because we 

should be looking at it.

5.1 Maps and 

GIS Data

A label identifying Nuiqsut's drinking water lake was 

added to the Project Area map for the FEIS (Map 3.1-1)

NQT9-36 Eunice Brower We should be protecting our only drinking water 

source. And part of our subsistence is living off of 

-- you know, we get this water that we drink.

You guys use a lot of these water all over then 

place, and you guys put it them the map, but what 

about our drinking water source? Is it not that 

important to know where it is or how much it's 

being impacted as well?

3.4 Water 

Resources

A label identifying the lake used for Nuiqsut drinking 

water has been added to both Project Area (Map 3.1-1) 

and Surface Waterbodies (Map 3.2-3) maps in the 

FEIS.
Supplemental Environmental Impact Statement

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Comment Response

NQT9-37 Eunice Brower I'd like to know to protect it because that's what I 

drink. Every one of us here drinks that water. And 

what happens if there's something that gets into 

our only drinking water lake source? What are you 

guys -- what are you guys going to do about it? 

Are you guys going to provide us a distillery so we 

could make distilled water? How much are we 

going to pay for water? Is it going to cost more? 

Because I used to go to -- when I used to go 

camping and get water, we used to go ahead and 

get water from these lakes that are easy to 

access, and it would be even cleaner. We can't 

even -- we have to worry about where our water is 

coming from. How much -- how much of it is 

actually contaminated? How much of it is being 

protected? What's getting into our water source?

4.2 Mitigation See Section 4.4.6 Public Health, Potential Mitigation 

Measure 4 regarding the additional requirement to 

mark trails at ice bridges to indicate they have been 

slotted and are closed to travel.
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Comment Response

NQT9-38 Unidentified I wanted to make a comment regarding the -- how 

the impact (indiscernible) we stand over here in 

Nuiqsut. When we're talking about subsistence, 

the caribous, fish, the geese that we're trying to 

hunt, Conoco knows we are trying to get 

assistance with regards to these subsistence 

activities, but they go behind closed doors with 

the leadership of Nuiqsut, taking all our concerns 

we're voicing now, water it down, and then these 

directors folks are off center while our subsistence 

concerns are kind of washed away to the side. 

That is very concerning, and I see that pattern 

now the last few years, especially with this -- try to 

have a little committee. Without question they're 

going to take what we're saying today and they're 

going to start picking up that phone and calling 

you guys and start watering down our concerns 

we have we're voicing today. And they're going to 

sit with these Conoco characters and then begin 

to shape how they're going to receive impact 

funds and how these funds are going to be used. 

That's something you guys have to think about --

that's you -- when you go home from here.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Section 4.4.2.1 Sociocultural Systems - - Impacts 

Common to All Alternatives describes impacts related 

to economic disparity described by community 

residents regarding the non-equitable distribution of 

impact funds or other monetary benefits resulting from 

oil development and infrastructure. That section also 

documents the prevalence of testimony on distrust, 

including district that conflicts of interest are influencing 

decisions. BLM is committed to working with the 

community to establish any mitigation measures that 

are within BLM's authority to establish. BLM 

encourages Nuiqsut to submit applications to the State 

of Alaska NPR-A Impact Mitigation Grant Program for 

funds to address subsistence impacts.

NQT9-39 Unidentified Your pipeline is cutting off the view of the horizon 

to see -- and I don't know if they're coming or 

going. Now you've got to go climb something 

higher or go down below and see about walking 

(indiscernible) area on that GMT1 road. And A lot 

of the pull-offs are split apart. And if you want to 

stop on the road to look for some animals, you 

can't really see because the pipeline is in your 

way, the way the elevation is at the road and the 

pipeline. So you don't have no view of the 

horizon.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

BLM has included a potential mitigation measure 

requiring ConocoPhillips to work with the community of 

Nuiqsut to identify the location and design specification 

for the access ramps and pull outs along the GMT2 

road. See Section 4.4.6, Subsistence, Potential 

Mitigation Measure 7
Supplemental Environmental Impact Statement

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Comment Response

NQT9-4 Unknown 

Speaker

And earlier I mentioned about the yellow haze. 

Back in them days, we have never seen those 

hovering nearby. Only towards the east. Our air 

quality was good. Never have we had any kind of 

pollutant until they started coming west. The 

farther they explore westward, that's when they 

start showing up. Our air quality right now is poor. 

You go to another Village, you go to a town, 

you're going to breathe better, healthy air away 

from industry. When you come back home, you 

feel the difference. Our air quality is very poor. 

And you do your modeling. When you say you do 

your monitoring, we are being put in a class, too, 

and monitoring the whole Village by putting so 

many people in there.

You haven't done your scientific study thoroughly. 

The majority of our wind comes through at the 

southwest, exactly where GMT2 is going to be at. 

Blizzards, high winds, those are unaccounted for 

on your model. What are the wind speeds? What 

direction? Downwind? Upwind? What are the 

others that might cause more pollutant that this 

Village has already been experiencing and have 

already been polluted?

...

Of all eight Villages in the whole North Slope, this 

Village is the worst air pollutant.

3.5 Air Quality & 

Meteorology

Thank you for the comment. The modeling conducted 

for the GMT2 Project was done accounting for the wind 

directions and speeds of the North Slope. Wind speed 

and direction data used in the modeling were retrieved 

from the Nuiqsut Monitoring Station near the proposed 

GMT2 Project Area. Upper air data were retrieved from 

Barrow, Alaska, the closest available station to the 

proposed GMT2 Project Area with upper air data. The 

meteorological data were processed using 

recommended procedures from ADEC and default 

values so as to ensure the model properly accounted 

for local meteorology.
Supplemental Environmental Impact Statement

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Comment Response

NQT9-40 Unidentified Over there in Prudhoe Bay, I don't see roads that 

high. I see -- they haul in all kinds of loads on 

those lower -- lower roads like that.

2.1 Proposed 

Action & 

Alternatives

The GMT2 Access Road has been designed to be a 

minimum of 5 feet high above the ground surface once 

settling has occurred. This design is based on Arctic 

engineering intended to maintain the existing thermal 

regime of the tundra on which it is construction, thereby 

alleviating the potential for road subsidence and 

additional tundra damage. Roads in the existing oil field 

that are currently at a much lower final height above the 

ground surface, are so due to various possible reasons, 

including differing surface conditions, age and longterm settling. It has been found that for the conditions 

that exist along the road routes between GMT1 and 

GMT2, a 5 foot minimum thickness is needed to keep 

the thermal regime intact.

NQT9-41 Unidentified when you're driving down the road and you want 

to stop and look for game, your pipeline is in the 

way of the horizon. Either build the pipeline 

higher, or build

your roads lower. That way you can have a view 

of the horizon.

4.2 Mitigation The GMT2 Access Road has been designed to be a 

minimum of 5 feet high above the ground surface once 

settling has occurred. This design is based on Arctic 

engineering intended to maintain the existing thermal 

regime of the tundra on which it is construction, thereby 

alleviating the potential for road subsidence and 

additional tundra damage. NPR-A ROD BMP E-7(a) 

requires that all pipelines be elevated a minimum of 7 

ft. from the ground surface to allow for the free 

movement of caribou. 

NQT9-42 Unidentified But majority of our caribous we depend on is all 

Teshekpuk Herd. No other herds. When those are 

gone, our hunters have to travel further and 

further. And what they do, they come home empty 

handed. The majority of the caribous are 200-

some miles away from us. And those happens 

when there's a lot of activities going on.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Section 4.4.5.2 Summary of Nuiqsut Subsistence Uses 

discusses in detail recent information regarding 

changes in caribou harvests, use areas, and hunting 

trips.
Supplemental Environmental Impact Statement

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Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

NQT9-43 Unidentified When everything is on full bore. So many ice 

roads crisscross. So much of those seismic 

activities going on are diverting and back the 

other way around. Because I told you two years 

we've never had Teshekpuk Herd stay in Colville 

Delta region. Fish Creek area, that's where they 

hover the most, that's where they feed and graze 

around at Fish Creek area before calving season 

(indiscernible) leave areas at Teshekpuk Lake 

area. So when you say -- when you put all those 

accumulated impacts, including all the other 

Villages that are 2-, 300 miles away from us, how 

are they being impacted when they have caribou 

year round when we don't. It seems like you're 

putting it opposite.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Section 4.4.5.2 Summary of Nuiqsut Subsistence Uses 

discusses in detail recent information regarding 

changes in caribou harvests, use areas, and hunting 

trips.

NQT9-44 Unidentified And there's less impact on the other Villages, 

because they're harvesting caribou almost daily. 

Caribou recently I've seen in Barrow, right behind 

the hospital. Nunavak Road, that's where the 

caribous were in Barrow, downtown Barrow. -- like 

we used to see them here in town, but we used to 

see them here in town before these roads were 

built. Since the roads were being built, they don't 

come closer to town.

3.15 Sociocultural Systems,

Subsistence, and 

Environmental 

Justice

The SEIS discloses both potential benefits and 

potential negative impacts of the road and attempts to 

be succinct. Recent data on use of roads, gathered 

since the Draft SEIS was published, and verbatim 

testimony from hunters, has been included in the Final 

SEIS (section 4.1.2.5). 
Supplemental Environmental Impact Statement

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Comment Response

NQT9-45 Unidentified You know, back to what you're saying about the 

impacts to the environment, for the caribou and 

the wildlife, and, you know, when you talk about 

GMT2 human impact area, you know, we haven't 

even seen what GMT1 is doing. So I don't 

understand why 

you guys are talking about the impacts for GMT2 

when we haven't even felt the impacts of GMT1 

yet. Because, you know, we've lost a lot on the 

Colville River Delta area, the Alpine satellite 

development area. East side we lost of 

subsistence usage, and now that we're on the 

west side, you know, you guys are -- there is data 

that shows that we've lost a lot of subsistence 

usage area because of development. When you 

talk about ConocoPhillips saying, "We're building 

a small footprint," you know, that small footprint 

impacts us greatly, not moderately but greatly.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

GMT2 was originally approved for development as CD7 in 2004 under the Alpine Satellite Development Plan 

EIS, as was GMT1 (as CD-6). As described in Section 

1.4 Purpose and Need for Federal Action, under federal 

statutes the BLM is required to issue the GMT2 permit 

for oil development in the NPR-A and cannot choose 

the No-Action alternative. BLM identifies the loss of 

subsistence use areas as the primary adverse impact 

attributable to the presence of oil infrastructure in 

Section 4.4.5 Subsistence, and has included potential 

mitigation measures specific to monitoring subsistence 

harvest and subsistence use.

NQT9-46 Unidentified There's a lot more in the SEIS that we really need 

to talk about when it comes to the HIA and about 

what -- and what we're saying about the winter 

exploration. You know, it's not just that one little 

small footprint you guys are talking about that's 

going to, you know, impact this small area right 

here. That small area impacts the whole -- the 

whole ecosystem.

3.18 Public 

Health

A Health Impact Analysis was done for GMT2, the 

results of which are in Appendix G. Appendix G 

provides the Baseline Human Health Summary for the 

North Slope, including a description of current 

subsistence practices and summarizes Areas of 

Vulnerability as well as Areas of Resilience/Success. 

Cumulative effects for Public Health are found in 

Section 4.6.8. 
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Comment Response

NQT9-47 Unidentified You guys -- they've been saying that since Alpine 

satellite development area, CD5, and GMT1. Now 

GMT2. So, you know, if we can get a third party to 

analyze the studies that have been done from 

Stephan (indiscernible) & Associates to come 

over here through BLM, through ConocoPhillips to 

come and read the reports that are sent over 

here, the -- I'm talking about the rough drafts that 

come over here for us to approve. And when it 

gets approved over here, another report goes out 

there to ConocoPhillips and to another -- to 

another entity, BLM, where that report changes. 

We -- you know, it would be good to get 

somebody to come over here and get a third-party 

consultant to analyze what's been going on over 

here to help Nuiqsut out when it comes to you 

talking about minimization of impacts. 

Question from BLM: And so you would like to see 

a third party working on behalf of Nuiqsut to do 

quality control of the data?

Yes, quality control. And to analyze the impacts, 

to compare the reports that are going out to these 

different entities.

4.2 Mitigation See Section 4.4.2 Sociocultural Systems, Potential 

Mitigation Measure 1: Nuiqsut Area Environmental 

Data Review and Information Dissemination.
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Comment Response

NQT9-48 Unidentified This summer we need gas help from Conoco, 

maybe 10, 20 gallons for the hunter, and at the 

same time we need -- I think we need a 

(indiscernible) store (indiscernible) for the women 

of Nuiqsut, so they could have a place with their 

kids where we can't hunt in these areas anymore. 

This -- what we're talking about needs to be 

separate from the trilateral committee.

The trilateral committee is going to take control of 

what we're talking about here and use their 

governing powers to take what we're saying 

tonight, wash it all away and say "This is what 

Nuiqsut wants." And I see that a lot. So we're 

talking about our ability to feed our family now. 

This is what we're talking about. We need the 

gas. And if we can't catch these animals, if we 

have a hard time, then some help for the women 

of Nuiqsut, even a $100 gift card so they could go 

to the store and get their kids something to eat.

It might offset these impacts a little bit.

4.2 Mitigation See Section 4.4.2 Sociocultural Systems for a 

discussion of community-requested potential mitigation 

measures that address social impacts.

NQT9-49 Eunice Brower You're changing the ecosystem around the Arctic 

where it usually defrays -- it reflects all this 

sunlight on the snow. But when you put these 

roads and infrastructure on our snow, on our --

how our climate is in the Arctic, it dramatically 

changes the climate around here. These dusts 

from the roads and particulate matter gets 

scattered from these roads, and I don't know how 

far it goes off from the roads, but that's affecting 

all the snow that's usually accumulated on the 

North Slope. It affects the permafrost. All this dust 

that's coming from these roads changes the 

snow. It melts it faster.

3.7 Climate 

Change

Dust deposition along roads can increase turbidity of 

adjacent water bodies, increase the rate of 

thermokarst, and affect the vegetation, soils and 

permafrost at distances of 600 to 1000 meters from the 

road. These affects are most pronounced within 200 

meters of the road and increase logarithmically as 

distance to the road decreases. These impacts and 

how they interact synergistically with climate change 

impacts are examined in Section 4.6.3, Terrestrial 

Environment. 
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Comment Response

NQT9-5 George Sielak one of the things that we always have fought 

about is the regulations to be stringent, more 

stricter, starting from Alpine. And to make sure 

that if they built these facilities, that they provide 

more stricter guidelines because of the Village. 

People live here. Just right here. I don't know if 

there's any place up here because it's really just 

up to Nuiqsut, Nuiqsut being the closest that you 

need to show us that you have put up more 

guidelines for the oil industry to have more 

cleaner emissions coming out from their facilities 

and to show our community that we have a facility 

here.

...

And that's what we want to see to make sure that 

our -- not just for our community, but for the 

wildlife and the subsistence that live within our 

area have safer area to breathe. So I think that 

that's one of the things that I want to see if the 

agents is -- they work very hard. And I know we 

have brought this to the borough, too, and I don't 

know if it has been brought up to BLM too.

3.5 Air Quality & 

Meteorology

BLM takes its responsibility seriously and is working 

with various subject matter experts within other 

agencies to ensure that air quality is protected. The 

NEPA analysis is intended to gauge the impact from 

planned activity. Once the facility is in operation, they 

work under a permit from the State of Alaska. The 

Alaska Department of Environmental Conservation 

(ADEC) Air Compliance program is charged with 

enforcing compliance with the state permit. If deviations 

of operations are brought to BLM’s attention, we will 

notify ADEC to correct the issue.

NQT9-50 Eunice Brower And what about the underlying permafrost that's 

under these roads? Do you guys even insulate 

these roads? Do you protect the permafrost from 

melting? Especially when you do all this drilling, 

where all these sites are at. How much changes 

are going to the permafrost? How much is it going 

to affect our Village?

3.7 Climate 

Change

The GMT2 road will not include insulation, such as 

Styrofoam or other man-made materials, as part of the 

construction. Instead, it has been engineered to ensure 

that the gravel roadbed will not affect the underlying 

tundra through the transference of heat. Constructing 

the road in winter also assists with maintaining the 

thermal regime. On the drill site itself, thermosiphons 

and insulated conductors are used to ensure that the 

wells do not result in thawing the permafrost. 
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Comment Response

NQT9-51 Eunice Brower Some of our sigiuaq are already melting. That's 

changing them. That's changing how we store our 

food. We have to buy these walk-in freezers now 

to help protect our food. You guys don't even put 

that in there. With the amount of methane that you 

guys are

Yeah, it's impacting our subsistence lifestyle 

because, first of all, some of our sigiuaq are 

melting, our ice cellars. We store our food in 

there, our whale, our caribou, our geese that we 

hunt all year long to store in our ice cellars. 

They're melting. That affects how we store our 

food and how we're going to store our foods in our 

future. And how are you going to mitigate all that 

once we have no more permafrost underlying our 

Village from a lot of this development?

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Text has been added to discuss the impacts of Climate 

Change to Section 4.6.8 Cumulative Impacts to Social 

Systems, Sub-section 4.6.8.2 Sociocultural Systems, 

and Sub-section 4.6.8.9 Subsistence.

NQT9-52 Eunice Brower All this methane that's being released from these 

flares are very potent. It's a potent greenhouse 

gas. It's 80 times more potent than carbon 

dioxide. Methane. It's heavy. The life -- the 

lifespan of that greenhouse gas is 12 years. It's 

going to stay in the air for 12 years, the lifespan of 

it. With the amount of methane that you guys are 

emitting, it's changing the climate more faster 

than we could even know. We can't even 

understand it.

3.7 Climate 

Change

Greenhouse gas emissions projected from the GMT2 

project are discussed in Section 4.3.2.1 Climate and 

Meteorology. Estimates of downstream greenhouse 

gas emissions are provided in the DSEIS to facilitate 

comparison of impacts associated with various 

alternatives and support analyses of cumulative 

impacts. The DSEIS indicates that emissions from 

anthropogenic activities such as production and 

combustion of fossil fuels do contribute to ongoing 

climate change processes, but existing models and 

tools are not sufficient to quantify specific impacts upon 

local resources. Climate change is by nature a 

cumulative global issue and no single action 

contributes an amount of greenhouse gases that can 

significantly impact global systems. Specific regulatory 

thresholds for greenhouse gas emissions have not 

been promulgated and there is no means to 

quantitatively assess major, moderate, or minor 

impacts to local resources. It is recognized in the DEIS 

that there is inherent uncertainty in these estimates 

(from market influences and other factors). 
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NQT9-53 Eunice Brower Are you going to buy all of us freezers for our 

food, for our whale? Are you going to pay for the 

electric -- electrical costs to generate for that 

walk-in freezer now that we have to get one and 

pay for electrical just to keep it running when we 

could have it -- a natural ice cellar underground?

4.2 Mitigation See Section 4.4.2 Sociocultural Systems for a 

discussion of community-requested potential mitigation 

measures that address social impacts.

NQT9-54 Sam 

Kunaknana

The data that -- I don't know who got the data. 

ConocoPhillips or somebody did some tests on 

the air, and it said we can -- they can't produce 

this data because it's temporary. And for the first 

four to eight years it said that the emissions were 

going to be really high. Eight to twelve years it's 

going to go lower. And once -- once they get into 

the production phase, this is what -- this is what 

we're looking at. We're looking at what this little 

footprint will emit. So, you know, my -- my 

concern is that, you know, since 2000, since 

Alpine got started building ice roads year in, year 

out, and building roads from CD1, 2, and 3 --

actually CD1, 2. CD3 doesn't have a road. It's a 

roadless pad.

You know, for the -- during the construction 

phase, you have -- the emissions really, really 

high. And it says that you can't use that data 

because it's temporary. To me, you know, for the 

past 18 years, they've been building ice roads in 

this area, and that data should be used. All the 

data from all the tests that they've been doing 

since the building of the ice roads in this area 

should be used to see how much emissions 

comes to our Village during the winter months, 

because that -- that statement says that, "Okay. 

We're building the roads." 

What he's saying is the word "temporary" has 

never quit being temporary. It's always temporary.

3.5 Air Quality & 

Meteorology

Thank you for the comment. The near-field modeling 

included ice road construction along with other 

construction sources that are considered temporary, as 

they are planned for the proposed GMT2 Project. 

Therefore, the results presented in the SEIS do 

account for construction and other temporary activities 

in order to comprehensively evaluate proposed GMT2 

Project impacts.
Supplemental Environmental Impact Statement

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Comment Response

NQT9-55 Sam 

Kunaknana

We're at the lowest spot. All the emissions are 

going to come to us because we're at the -- we're 

on the low end of the bowl.

3.5 Air Quality & 

Meteorology

Thank you for the comment. The modeling conducted 

for the GMT2 Project was done accounting for the wind 

directions and speeds of the North Slope. Wind speed 

and direction data used in the modeling were retrieved 

from the Nuiqsut Monitoring Station near the proposed 

GMT2 Project Area. Upper air data were retrieved from 

Barrow, Alaska, the closest available station to the 

proposed GMT2 Project Area with upper air data. The 

meteorological data were processed using 

recommended procedures from ADEC and 

conservative default values so as to ensure the model 

properly accounted for local meteorology. The location 

for sources of pollutants including the proposed GMT2 

Project and other reasonably foreseeable 

developments such as GMT1 and Nanushuk were 

accurately input to the model as well. Therefore, the 

trajectory of emissions were modeled in order to 

accurately account for existing meteorology to 

determine pollutant dispersion.

NQT9-56 Unidentified There's already literature right there. And that 

literature right now, from my understanding, is 

being summarized in this SEIS. And there's just --

the only things in there that are being put to make 

it look like Nuiqsut isn't being impacted greatly. 

That's my understanding from the ten-year 

project. They just got done with Year 9. Year 10 

this year. And they're just finally finishing Year 9 

rough draft report. They haven't finished Year 10. 

Yet, you guys are still moving forward without 

even trying to analyze the ten-year project that 

Stephan (indiscernible) & Associates was 

supposed to do to see what the impacts were 

going to be from development for this community.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

The analysis for Subsistence presented in section 4.4.5 

of the Final SEIS includes the most up-to-date data 

regarding subsistence harvest and use for the project 

area. The analysis utilizes data through year 9 of the 

SRB&A study referenced by the commenter. Each year 

SRB&A produces a detailed report that not only 

describes the data collected for that study year, but 

also the contribution of the data to the totality of data 

collected during the study period. In this way, each 

annual report provides the best available data overall 

on the subject of caribou use by the community of 

Nuiqsut. While the study referenced was envisioned as 

a 10-year effort it will continue to collect annual data 

pursuant to the GMT1 Record of Decision beyond year 

10. 
Supplemental Environmental Impact Statement

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Comment Response

NQT9-58 Unidentified So legally can we ask someone to, like, get a third 

party to come and analyze the HIA during the 

winter months on that document that 

(indiscernible) and use this data because it's 

temporary? When, in fact, you know -- when, in 

fact, we do have a lot of issues on handling this 

Village when it comes to the winter month 

exploration, ice roads, and road construction, to 

compare the data and do an HIA from Nuiqsut. 

Because I know State of Alaska came over here 

at one point and went straight to the clinic, 

(indiscernible) the North Slope Borough. But to 

me, you know, the borough, ADEC, they're for 

development, and maybe all you guys are working 

together in unison to move forward with 

development.

3.18 Public 

Health

Appendix G is an HIA and establishes baseline 

conditions for the health of Nuiqsut residents. 

Cumulative effects of existing and planned 

development, including temporary ice infrastructure in 

the winter months are addressed in Section 4.6.8. 

NQT9-59 Unidentified But my -- my concern is that, you know, I would 

like to see a third party not affiliated with the State 

of Alaska or with the borough -- or with 

ConocoPhillips. A different entity that's not 

affiliated with industry in any way to come and 

analyze the air data and the HIA. I want a third 

party, not BLM.

4.2 Mitigation See Section 4.4.2 Sociocultural Systems, Potential 

Mitigation Measure 1: Nuiqsut Area Environmental 

Data Review and Information Dissemination.
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NQT9-6 Eunice Brower But the Arctic is more different. It's not like the 

Lower 48. Okay? The Arctic is special. We 

shouldn't even follow the national ambient air 

quality standards. They're insufficient enough for 

the vegetation here in the Arctic. According to the 

National Academies of Press, the national 

ambient air quality standards are insufficient for 

protection for vegetation. All the lichen suck up all 

those pollutants. And then what, our caribou eat 

those lichen. They're impacted by what they eat.

3.5 Air Quality & 

Meteorology

At this time, the National Ambient Air Quality Standards 

and Alaska Ambient Air Quality Standards are the 

standards to protect public health and welfare. Where 

there are no NAAQS published (i.e., 24-hour and 

annual SO2), the analysis included evaluation of 

modeling results against the AAAQS in order to ensure 

GMT2 Project impacts are below the more stringent 

thresholds Alaska regulates.

For far-field impacts, critical loads are thresholds 

designed to assess the cumulative effects of 

atmospheric deposition on vegetation including lichen. 

The estimated cumulative impacts for nitrogen 

deposition including the existing (measured) nitrogen 

deposition at the Arctic National Wildlife Refuge and 

the Gates of the Arctic National Park and Preserve 

(Table 3.2-10) are below the range of critical loads. 
Supplemental Environmental Impact Statement

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Category Code

Comment Response

NQT9-60 Rosemary 

Ahtuanagaruk

There's a lot of concern over all these different 

ways. We've tried to work in many different ways, 

but the reality is that the state and federal 

government had broken many promises to this 

community over ways that the planning activities 

on the development in this area was to occur. You 

gave us promises that you were going to protect 

our subsistence. We worked out a subsistence 

calendar. We told you times when things should 

not occur and when you should decrease 

activities. You never honored those promises. 

You never restricted flights during our increased 

subsistence harvest. We talked to you about that. 

We told you over flights were going to cause us a 

lot of problems. You didn't honor those 

discussions. We had 1,200 flights in six weeks 

when you started constructing Alpine. So when 

you put some planning efforts into the process 

and say you're going to do this one thing, like 

restrict flights during June and July where we're 

only supposed to have 20 in a month, then there's 

no way that we can try to prepare to respond to 

this process. We put in very prescriptive methods 

of ways that we could try to protect subsistence, 

pushed industry back from our tributaries where 

we're boating and hunting and trying to harvest 

our caribou. What did you do? Turn around and 

put CD4 right up on the riverbank where we told 

you it shouldn't happen. 

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

While the BLM did not have a role in the approval of 

permits for the Alpine Development infrastructure 

mentioned in the comment (which are located on State 

of Alaska lands east of the Colville River), the BLM 

understands the intent of the comment is to 

communicate the level of frustration that is felt by 

residents of Nuiqsut regarding agreements or decisions 

by government in general that they believe have not 

been upheld or that were changed by later decisions, 

and the general sense of mistrust in government. 

Section 4.4.2 Sociocultural Systems, Tensions Related 

to Permitting Processes for Development describes 

these social impacts. The BLM acknowledges that 

these are legitimate concerns resulting from oil and gas 

development on State and Federal lands near Nuiqsut. 

The BLM also acknowledges that as the agency 

responsible for management of the National Petroleum 

Reserve in Alaska, we have very little regulatory 

authority to address these issues to the satisfaction of 

Nuiqsut residents.
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NQT9-60

Continued

Rosemary 

Ahtuanagaruk

So any way that we have tried to protect 

subsistence, you've broken every promise that 

you've given us to try to help us protect it. It's not 

just about caribou harvesting. It's about the birds 

migrating in. Ever since the activity prior to alpine 

being constructed, that's when I was always 

having enough food on my table. That's when I 

had the most to share with the extended family 

members in every other Village that live around 

us, as well as extended family members in their 

hubs and going to college. But after construction, 

that's when we started having not enough. We 

told you we weren't going to have enough 

caribou. When you constructed Alpine, it went 

from 120 houses harvesting caribou to absolutely 

only 3 hung caribou to dry during that construction 

time. We didn't get any help to try to help some of 

those things. Still to this day we have houses in 

this Village that do not get caribou every summer 

to dry to give us the foods that we need. That's 

the amount of change that we're going through. 

Still to this day we've had people that have put 

fish nets in the water that are impacted because 

we've got changes to the way that you're putting 

the migration to come through to our area. 

There's a lot of infrastructure that's been 

developed, failures to maintain those 

infrastructures of fish passages. It prevented us 

from harvesting the Arctic cisco. We talked 

through many different meetings to try to get that 

return of that harvest, and trying to protect who 

and what we are.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

See above BLM response
Supplemental Environmental Impact Statement

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Comment Response

NQT9-61 Rosemary 

Ahtuangaruk

We put in recommendations to not allow seismic 

activity to happen in Camden Bay. What did you 

do? Go out and do seismic activity in Camden 

Bay. What happened to us? Our whale strikes 

went off 20 miles off across (indiscernible). Every 

time we try to put in protective measures, you fail 

to enforce anything that we put for it. Now you put 

a document in that prevents us from even trying to 

enforce any of the recommendations that we put 

in because it's so industry friendly. Everything that 

we wanted to try to protect, industry gets to 

choose whether or not they're going to protect it. 

ASRC can choose whether or not they're going to 

support our Village when we opposed to put a 

project three miles from our Village. And we had 

over 200 people, 200 adults, stomping their feet 

like this saying, "No, no, no." But yet we have 

teachers at our schools saying, "Oh, we work 

together. We get to avoid some of these impacts." 

Ah, baloney. We work together to come to this 

process and try to protect subsistence. You 

haven't protected us in any way. Every time we 

put a concern through, you mitigate it into a model 

that says, "Oh, it's great and fine and dandy. Don't 

worry you don't have any emissions." Then why 

do we have xylene in our fresh water lake? Why 

do we have hydrology issues that are impacting 

our fresh water source so that we have erosion 

that's going to jeopardize whether or not we're 

going to have that lake for fresh water? Why do 

we have erosion that is impacting our water tanks 

right over here with the increased development 

that you've done in the Delta that has changed 

the hydrology? Is that impacting why we're having 

the erosion that's going to give our brand new 

water tanks just two years' life? 

4.2 Mitigation Thank you for articulating these social impacts (i.e.,

distrust, lack of power, concern over lack of 

enforcement of regulations, tensions related to the 

permitting process) and concerns regarding the 

cumulative impacts being faced by Nuiqsut. BLM 

recognizes, documents, and tries to analyze with 

transparency, the impacts many residents of Nuiqsut 

experience as required by NEPA. The BLM manages 

the NPR-A pursuant to the requirements of the NPRPA 

of 1976 and the DOI Appropriations Act FY 1981 

implemented at 43 CFR 2360, and 43 CFR 3130. Many 

of the actions that you describe are for activities that 

occur outside the NPR-A, and are therefore, not under 

BLM's regulatory control or management. We 

recognize that it is frustrating to have so many different 

regulatory agencies--federal and state--that play 

different roles in terms of managing things such as 

emissions, erosion, and whether or not to permit oil and 

gas activity. We encourage local and regional 

stakeholders to utilize the avenues afforded them 

through State and Municipal law, and through the 

federal political process to identify and implement 

solutions that are beyond the management authority of 

the BLM to address.
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NQT9-61

Continued

Rosemary 

Ahtuangaruk

These are serious impacts, and yet we're here 

talking on this, "Oh, maybe they're moderate 

impacts, maybe they're just maybe not so 

significant." Ah, baloney. It's very significant every 

step of this way. When we started these 

discussions, our whole Village was united in the 

way that these activities were going to occur. But 

you came to us and said it was only going to be 

14 acres. Yeah, 400 acres within the first year. 

That's not what happened. These were lies that 

were given to us so that once you got in there, 

now you get to choose that piecemeal. You want 

to these activities to occur, nothing should happen 

to the south side. You're going to develop this, the 

road is over there, go north, don't go south.

4.2 Mitigation See above BLM response

NQT9-62 Rosemary 

Ahtuangauruk

We have hopes that we're going to have caribou 

that come to us from the south. You've already 

impacted caribou coming from the east. You're 

impacting caribou coming from the west. You're 

impacting caribou coming from the north. The only 

hope we have is from the south. I can't stand the 

thought of what's going to happen to my Village if 

you disrupt their migration to come into this 

Village. I've already seen it, the domestic violence 

increase, the alcohol and drug uses, the conflicts 

in our Village, the unwillingness to work and come 

to our local community meetings. How many 

hunters are missing from this meeting because 

they're so tired of coming here for decades and 

having all of these promises broken? Every one of 

my kids, all four of my sons, have bad backs 

because they try so hard to go out and subsist. I 

have a son who's traveled from Barrow to Nuiqsut 

subsisting. He had to come all the way over here 

hoping that they would get something.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Thank you for articulating these social impacts (i.e., 

distrust, lack of power, concern over lack of 

enforcement of regulations, tensions related to the 

permitting process). BLM recognizes, documents, and 

tries to analyze with transparency, the social impacts 

many residents of Nuiqsut experience as required by 

NEPA. The GMT2 DSEIS document (Section 4.4.21) 

cites recent Alaska Native studies that corroborate your 

comments: outreach to solicit insights and concerns on 

negative impacts are antithetical to positive intercultural interactions. However, BLM cannot (legally or 

ethically) proceed with permitting that is required by 

law/legislation without notifying residents and soliciting 

their input. Nor do residents want permitting to occur 

without outreach and consultation. BLM regrets that the 

pace of development and the permitting processes 

themselves can result in these impacts, but neglecting 

to consult with residents and document their concerns 

would be unacceptable.
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NQT9-62

Continued

Rosemary 

Ahtuangauruk

They didn't get anything around us. They went 

over to Atqasuk, they went over to Wainwright. 

They went all the way to Point Lay. They're trying 

to harvest because it's important to us to feed our 

families.

But he shared it with families. That's the 

complexity of our sharing systems. Six caribou. 

He would be illegal with the recommendations 

that were put in to restrict caribou hunting and 

reduce our harvest to five in a day. That would 

have been illegal if that goes through. These are 

serious complaints that we're going through. But 

it's the heart and soul that you're breaking down 

with every one of these processes. And that's 

what you're -- caused the most damage in all of 

our local community meetings. You get the anger 

and frustration from all of our people coming into 

this process because we have tried. We've

worked with you. We've read thousands and 

thousands and thousands of pages.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

See above BLM reponse
Supplemental Environmental Impact Statement

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NQT9-63 Rosemary 

Ahtuangauruk

We have over a thousand development sites. We 

have contaminants in our fish from the historical 

development process. We have no assessments 

that know where the development activities occur 

and where you've been putting reinjection and 

what's still coming out into that water. We have no 

assessments of any of that concerns. We know 

your developments are eroding and causing more 

leakage and concerns to the Colville River. Umiat 

is a big concern. We asked that you go out there 

and clean up any of these activities prior to 

coming out here and doing more development. 

What's happening? We're still waiting for it. Umiat 

hasn't been cleaned up properly. You put a cap 

on it, watched it erode into the river. What good 

did it do? You did the same thing at Oliktok, in 

which we were assaulted because ASRC's 

lawyers got involved and worked with one of the 

board members, but our other community 

member that had a Native allotment in that same 

area, we didn't get any help from that. We were 

ignored in that process. So ASRC is a great 

thing? No, ASRC cost us that reaction and that 

mitigation that could have been a resource for us 

to help clean up that area and some of the other 

areas of concern. All of these various factors are 

really concerning. I really hate that you've come 

through this process and put this through to us, 

and yet you're just coming through just to approve 

the project.

4.2 Mitigation GMT2 was originally approved for development as CD7 in 2004 under the Alpine Satellite Development Plan 

EIS, as was GMT1 (as CD-6). As described in Section 

1.4 Purpose and Need for Federal Action, under federal 

statutes the BLM is required to issue the GMT2 permit 

for oil development in the NPR-A and cannot choose 

the No-Action alternative. The clean-up at Umiat is 

under the auspices of another federal agency, and is 

moving forward as federal funding allows. The BLM 

also continues to move forward with it's Legacy Wells 

Program as federal funding allows, performing surface 

clean-up and plugging wells at sites from the 1940-

1980's. 
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NQT9-64 Rosemary 

Ahtuangauruk

How much more do we have to go without? How 

many more tables are not going to have the 

caribou? How many more tables are not going to 

have the fish? How many tables are not going to 

have the whale? Because we've had enough 

tables without them. That's what we're talking 

about. We don't want to continue to go without it. 

It's not about trying to come back and talk to us 

about more and more documents about why you 

want to continue, it's about us wanting to be who 

we are into the future. I want my grandkids to be 

able to harvest, but none of them want to go to 

our cabin because it's already impacted with the 

oil and gas development. When I took my 

grandson out to go to that same area where his 

grandfather and his great-grandfather harvested 

caribou, we saw no caribou in the short time that 

he was able to come here to visit with us. He 

couldn't harvest in the same lands and waters as 

his elders had. That's the devastation we don't 

want to continue to happen.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Although Nuiqsut's subsistence harvest amounts have 

remained stable to date, documentation of residents' 

testimony shows that concerns about food security, the 

ability of future generations to hunt and fish in 

traditional areas, Inupiaq culture, and issues 

concerning access/land loss/ and avoidance are 

prevalent and consistent. These social impacts, 

including the most recent testimony, are discussed in 

4.4.2.1 of the SEIS. BLM is committed to working with 

the community to establish any mitigation measures 

that are within BLM's authority to establish. 
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NQT9-65 Peter Kosbruk Yeah, just GMT1 and GMT2 now coming into 

reality and the other prospects further west, you're 

using the road and the structure of the road to 

benefit the ability of the hunter. You know, they're

getting further and further, and you know it's got a 

lot more wear and tear on the vehicles and on the 

hunters too. You know? So there's a greater 

potential for hunters breaking down, you know, 

safety issues for the hunter, you know. So that put 

a lot more stress on our local search-and-rescue 

team and their efforts. And, you know, they're 

hurting in some areas. I know they could use 

some -- a little bit of help. I'd like to see the 

search-and-rescue property mitigated as well to 

respond to these further and further searches 

(indiscernible) in order to be -- they should be 

able to get out there with no problem. Just I'd like 

to see the search-and-rescue upgraded to handle 

the level of capacity of the lives and, you know, 

missions and safety issues that are going to come 

about with further distance the hunters are 

traveling, and, you know, the -- for the cause of 

things that search-and-rescue might have taken 

into consideration go out there and, you know, 

safely return these individuals home.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Impacts such as those described by the commenter 

(e.g., traveling farther, more wear-and-tear on vehicles) 

are presented in Section 4.4.5.4 Subsistence -

Resource Avoidance. A Potential Mitigation Measure 

(Section 4.4.2 Sociocultural) in the Final GMT2 SEIS 

identifies the request for additional Search and Rescue 

resources, however this is not a requirement that BLM 

has the regulatory authority to impose on the applicant. 

BLM encourages Nuiqsut to submit applications to the 

State of Alaska NPR-A Impact Mitigation Grant 

Program for funds for Search and Rescue.

NQT9-66 Eunice Brower I'd like to see some real baseline data. Why don't 

you do your air monitoring or water sampling or 

whatever, soil sampling, before these projects are 

developed? You can't just -- you can't just, "Oh, 

we're modeling this.

We're just going to model it." Where's the actual 

data? Can we request some actual real data and 

not modeling?

4.2 Mitigation See Section 4.4.2 Sociocultural Systems, Potential 

Mitigation Measure 1: Nuiqsut Area Environmental 

Data Review and Information Dissemination.
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NQT9-67 Unidentified There's no infrastructure at GMT1, just the road 

and the pad itself. Let's do this GMT1 first before 

we can pursue GMT2 road. See what kind of --

what kind of impacts we're going to be feeling 

besides CD5. What kind of impacts are we going 

to feel once GMT1 starts running and starts going 

on production line before you pursue GMT2? 

GMT2 should be tabled or suspended until GMT1 

is completely set in place. BLM, ConocoPhillips 

are on the fast track before they decided building 

infrastructure for one that's already been --

already set in place, which is completely empty, 

just gravel pad. Let's see what GMT1 is going to 

do compared to CD5 before we pursue CD --

GMT2 for the road and pad and possible pipeline 

route.

2.1 Proposed 

Action & 

Alternatives

As stated in Sections 1.3 and 1.4, the BLM is unable to 

postpone processing the GMT2 Application for Permit 

to Drill based on regulatory requirements in NPR-A 

found at 42 USC Section 6506(a). Deferral of a project 

authorization would be inconsistent with the directive in 

the Naval Petroleum Reserves Production Act to 

expeditiously carry out an oil and gas leasing program 

and the rights ConocoPhillips acquired with the subject 

leases to reasonably develop the oil and gas within 

those lease tracts. GMT2 was originally approved for 

development as CD-7 in 2004 under the Alpine Satellite 

Development Plan EIS. The purpose of the SEIS is to 

supplement the 2004 analysis and to include new 

information relevant to environmental concerns that 

have bearing on the proposed action or its effects. 

EIS's are inherently speculative documents, because 

their purpose is to identify potential impacts that could

occur from a proposed action using the best available 

information at the time of the analysis, so that an 

informed decision can be made. This information 

includes scientific studies, input from stakeholders, as 

well as identified impacts that have resulted from 

similar actions that could be reasonably inferred to 

occur from the proposed action. The BLM believes that 

we have accurately described the comprehensive suite 

of potential impacts that could occur from the proposed 

action, and alternatives to that action, sufficient to make 

a reasoned decision. 

NQT9-68 Rosemary 

Ahtuangaruk

Also I wanted to put in that there's a lot of concern 

about the river usage. There's a lot of conflict 

that's occurring on the river. We talked about fan 

boats before. That's a really big impact that 

extends a lot of concern with the noise that they 

bring in.

3.6 Acoustical 

Environment

No fan boat operations are proposed in association 

with the GMT2 project. 
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NQT9-69 Rosemary 

Ahtuangaruk

There's also a lot of concern around the airports. 

Airports can reduce the long-term impacts on 

development with roads. There's impacts with 

roads, there's impacts with airplanes. Both are 

very impactful If you had supported some of our 

concerns to

restricting activities during subsistence, maybe 

our discussions would have been different as to 

whether or not we want to think about roads or if 

we want to think about planes. But we were 

manipulated in this process by failing to effectively 

give us information to respond to the process, and 

led along claiming that protections would be given 

to us that were never honored.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Thank you for articulating these impacts regarding 

airports and flights. BLM recognizes, documents, and 

tries to analyze with transparency, the impacts many 

residents of Nuiqsut experience as required by NEPA. 

The GMT2 DSEIS document (Sections 4.4.2.1 and 

4.4.5.5) cites recent reports that corroborate your 

comments regarding airports, aircraft and roads. 

However, BLM cannot (legally or ethically) proceed with 

permitting that is required by law/legislation without 

notifying residents and soliciting their input. Nor do 

residents want permitting to occur without outreach and 

consultation. BLM regrets that the pace of 

development, the permitting process, and the type and 

amount of information that is shared in conjunction with 

the NEPA analysis can be confusing, but neglecting to 

consult with residents and document their concerns 

would be unacceptable.

NQT9-7 Eunice Brower the lichen absorbs all those toxins, and then 

they're getting sick. Some of these caribou are 

getting sick. They -- they're growing up in these 

areas where there's all this development going 

on. So more people are concerned because of 

the caribou are being sick. And they're scared to 

eat them because they're different.

3.11 Caribou This comment is not supported by the literature, nor do 

harvest surveys indicate that incidence of sick caribou 

harvested has increased. No text changes made.

NQT9-70 Rosemary 

Ahtuangaruk

The Nuiqsut paisainich has the highest local 

control. Right now that document is still in effect 

and that is what should be used to guide the 

planning process, the highest, strongest 

protective mechanisms with the local control is 

with the Nuiqsut paisainich

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

The Nuiqsut Paisangich-Cultural Plan is discussed in 

detail in Section 4.4.2 Sociocultural Systems.
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NQT9-71 Unidentified Before you say it, I'd like you to take into serious 

consideration, deal with GMT1 first. Deal with it 

first, set aside GMT2 now -- for now. Build those 

infrastructures that Conoco has started. Let them 

finish it with all this indiscernible) mounts the rig 

and the (indiscernible) down there before you 

pursue GMT2 road. Let's see what GMT1 is going 

to do to this community. And I want you folks to 

understand that should be taken under serious 

consideration. Table GMT2, suspend GMT2 for 

now.

2.1 Proposed 

Action & 

Alternatives

The BLM takes your suggestion seriously, but it is 

impossible for the BLM to suspend or set aside GMT2. 

As stated in Sections 1.3 and 1.4, the BLM is unable to 

postpone processing the GMT2 Application for Permit 

to Drill based on regulatory requirements in NPR-A 

found at 42 USC Section 6506(a). GMT2 was originally 

approved for development as CD-7 in 2004 under the 

Alpine Satellite Development Plan EIS.

NQT9-72 Rosemary 

Ahtuangaruk

Five years, [in reference to suspending GMT2, in 

order to understand impacts from GMT1] and 

come back and talk about it and say what we can 

do to address some of the concerns that we've 

already identified and get those mitigations in 

place. And see if they're responding and helping 

us in some of our concerns, and then come back 

and talk with us about coming back to the table for 

this project.

4.2 Mitigation GMT2 was originally approved for development as CD7 in 2004 under the Alpine Satellite Development Plan 

EIS, as was GMT1 (as CD-6). As described in Section 

1.4 Purpose and Need for Federal Action, under federal 

statutes the BLM is required to issue the GMT2 permit 

for oil development in the NPR-A and cannot choose 

the No-Action alternative.

NQT9-73 Rosemary 

Ahtuangaruk

California can only allow for ten flares in their 

state related to oil and gas development. We deal 

with over 30 in a night. We need to change that 

enforcement. We're not being under the same 

enforcement as it is in other areas. We also 

request that the flaring is not possible during 

inversions. We know that flaring has a large 

emission that occurs with that. We know we are at 

greatest risk. We've asked this for over five years 

that in -- that during inversions that flaring is 

limited.

4.2 Mitigation See Section 4.2.3 Atmospheric Environment, Potential 

Mitigation Measure 3: Minimize Methane Waste.
Supplemental Environmental Impact Statement

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

408

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

NQT9-74 Rosemary 

Ahtuangaruk

We asked that we have an independent 

assessment industry reports most every one of 

their flares as an emergency. We want to make 

sure that what they're reporting is not reality for 

their profitability, and why they're causing the 

flaring because they're keeping production rates 

up very high to allow for their profitability. And 

that's why they're fighting. These kind of issues 

are really important.

4.2 Mitigation See Section 4.4.2 Sociocultural Systems, Potential 

Mitigation Measure #1: Nuiqsut Area Environmental 

Data Review and Information Dissemination.

NQT9-75 Rosemary 

Ahtuangaruk

We also ask that vehicle shutdowns occur so that 

we're reducing their emissions all around our 

community with these concerns so that we can try 

to get some reduction in the amount of emissions.

4.2 Mitigation See Section 4.4.6 Public Health, Potential Mitigation 

Measure 2: Minimize Undue Idling of all Vehicles.

NQT9-76 Rosemary 

Ahtuangaruk

We want to make sure that there's an 

enforcement to all the recommendations of the 

environmental recommendations for 

improvements that are made. And we want to 

increase the penalties for the process. We went 

through your process where we looked and did an 

assessment over at Alpine. We identified that 

there were more wells drilled than was permitted. 

We also identified that were a failure to enforce 

some containment issues.

4.2 Mitigation Thank you for articulating these social impacts (i.e., 

distrust, lack of power, concern over lack of 

enforcement of regulations, tensions related to the 

permitting process). The BLM manages the NPR-A 

pursuant to the requirements of the NPRPA of 1976 

and the DOI Appropriations Act FY 1981 implemented 

at 43 CFR 2360, and 43 CFR 3130. Many of the 

actions that you describe are for activities that occur 

outside the NPR-A, such as at Alpine, and are 

therefore, not under BLM's regulatory control or 

management. The BLM is committed to operational 

inspections and enforcement of our regulations, BMPs 

and federal law.

NQT9-77 Rosemary 

Ahtuangaruk

We really wanted our air quality monitoring station 

to be a high-level, quality monitoring station. We 

didn't get all the factors identified to properly 

assess. We know a lot more information after 

what happened in other areas of oil and gas 

development.

4.2 Mitigation See Section 4.4.2 Sociocultural Systems, Potential 

Mitigation Measure #1: Nuiqsut Area Environmental 

Data Review and Information Dissemination.
Supplemental Environmental Impact Statement

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

409

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

NQT9-78 Rosemary 

Ahtuangaruk

The Children's Environmental Health Textbook 

has recommendations for 69 different criteria to 

be assessed. That's the level of air quality 

monitoring that we want to have, and we want to 

have some improvements into why industry gets a 

say.

3.5 Air Quality & 

Meteorology

BLM is aware of the air quality concerns in the 

community. The federal NEPA and State air permitting 

process is designed to prohibit any air quality impacts. 

As part of the Environmental Impact Analysis, the 

projected air quality impacts for GMT-2 sources have 

been assessed and been found to be minimal. 

Nonetheless, BLM is considering mitigation measures 

to guarantee continued air quality monitoring to 

alleviate concerns, see Section 4.2.3.2, Potential 

Mitigation Measures 1-11

NQT9-79 Peter Kosbruk Just random trash around the construction pads, 

you know? Stricter policies and stricter 

regulations. I recommended that they had put 

company names and vehicle numbers to -- you 

know, to identify where the containments are 

coming from because, you know, we find all these 

containers and containments and liners and trash 

out all these pads and scattered throughout the 

tundra, and nobody is having to, you know, pay 

the consequences for littering in the State of 

Alaska. And, you know, stricter policies and, you 

know, the duck pond thing and writing the vehicle 

numbers on the duck pond liners will help identify 

where these trashes are coming from some of 

the ice road construction. And, you know, for one 

company to have a section of the ice road and 

have, you know, the pad -- operation of the pad 

and everything around the pad, they should have 

a big area around that pad where they are 

obligated to clean up and overseeing it. And if 

there's something left behind, there should be 

some sort of enforcement that should be able to 

take place. Yes, for the specific company and 

everything, so that when they do bring these duck 

ponds and everything back, that company can 

comply with a stipulation that was agreed upon 

way in the beginning.

4.2 Mitigation See Section 4.5 Impacts of Oil, Water and Hazardous 

Materials Spills, Potential Mitigation Measure 1: Trash 

Removal and Anti -Littering Campaign. 
Supplemental Environmental Impact Statement

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

410

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

NQT9-8 Eunice Brower That's one of the subsistence impacts from all this 

development that's been occurring since 

Deadhorse, all the way coming here to Alpine. 

You see all that infrastructure right there, that's 

the Central Arctic Herd's calving ground. They 

grow and they develop in that area. And then 

they end up, some of them, getting sick. People 

don't know why. Maybe they don't understand it 

could be the toxins in the air or what they're 

eating. The lichen absorbs all those toxins. 

That's the first thing that happens to the caribou is 

they get sick and they start to get -- develop 

differently.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Concern by local residents that subsistence resources 

may be contaminated by oil and gas development is 

recognized by the BLM. NPR-A IAP BMP A-11 

required ConocoPhillips to implement a monitoring 

study on contaminants in locally-used subsistence 

foods. The intent of this monitoring is to establish preinfrastructure baseline condition of subsistence 

resources, and to then monitor those same resources 

to identify whether or not there is any increase in 

contaminants.

NQT9-80 Peter Kosbruk And we need local -- a local enforcement agency, 

other than a case office, because the case office 

out there only recording and collecting data. We 

need some enforcement from our local community 

out there to identify and follow the proper 

enforcement procedures to, you know, better 

protect our land.

4.2 Mitigation See Section 4.4.2 Sociocultural Systems for a 

discussion of community-requested potential mitigation 

measures that address social impacts.

NQT9-81 Rosemary 

Ahtuangaruk

As well some kind of reward system for our local 

hunters. Because our hunters are coming across 

these duck ponds, but we've had difficult in 

getting them reclaimed by the oil and gas 

companies. And so we find all sorts of stuff. 

Maybe if we can try to incorporate a rewards 

system so if they do bring something back, they're 

rewarded for the effort to help and maintaining 

and protecting our environment. Because industry 

is not doing enough to try to go back and recover 

what they've already lost in the environment from 

their activities.

4.2 Mitigation See Section 4.5 Impacts of Oil, Water and Hazardous 

Materials Spills, Potential Mitigation Measure 1: Trash 

Removal and Anti -Littering Campaign. 
Supplemental Environmental Impact Statement

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

411

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

NQT9-82 Unidentified And having a company name and vehicle 

identification number on all these, you know, tools 

and necessities for each vehicle that are required 

out there, having a specific vehicle number and 

everything pertaining to that piece of equipment, I 

mean, it will easily identify exactly where these 

things are coming from, you know. Better the 

future, really.

4.2 Mitigation See Section 4.5 Impacts of Oil, Water and Hazardous 

Materials Spills, Potential Mitigation Measure 1: Trash 

Removal and Anti -Littering Campaign. 

NQT9-83 Unidentified Rock coy fish are starting to be common as one of 

unedible that we harvest during fall time. There 

are a lot that has to be done early. For five years 

now, close to five years since we had the harvest 

fall rock coy fish. why Alaska coming down on 

new shore. And I believe this gentleman knows 

from North Slope Borough why. In the past, they 

were all healthy. Coming here during summer, 

coming down fall time after freeze-up. These are 

what we're experiencing after 40 years of 

(indiscernible). What's causing those is still 

unknown. So how can you best protect our food 

security when it's becoming so insecure? Merely 

that we have to rely on which food are -- are 

edible, which are not. Same thing with the animals 

that are eating the plants, lichens for the caribous, 

berries for (indiscernible) and(indiscernible). 

Those are the things that hasn't been studied. 

Because I've gone to one ICC Alaska Food 

Security Workshop in Barrow. And of all eight 

Villages, when this lady was asked that she 

wanted to go to Point Lay, the other Village, she 

said, "No, Point Lay is not impacted. You need to 

go to this man's Village." That's me. "You need to 

go to Nuiqsut first." And she (indiscernible) their 

feeling, their food security. Every year, every 

season, our food security is depleting, becoming 

more unedible.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Text has been added to the discussion regarding 

concerns about food security and the importance of the 

Fish Creek area to Section 4.4.5.2 Summary of Nuiqsut 

Subsistence Uses.
Supplemental Environmental Impact Statement

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

412

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

NQT9-84 Unidentified How much more of those fish are going to be 

unedible without coming and going during 

summer and fall time? And who's going to monitor 

them during the duration of all of this?

4.2 Mitigation Impacts to Fish are described in Section 4.3.2 , 

including existing Best Management Practices that 

describe monitoring requirements.

NQT9-85 Unidentified All these lakes to the west in NPRA, those are the 

lakes that have underground stream connected, 

spawning lakes. That is one thing that has really 

been talked of, is underground stream from lake 

to lake. And they say that this lake or that lake 

doesn't have any fish. How do they know? They 

don't know there's an underground stream.

3.9 Fish There is currently no scientific data providing evidence 

of underground connectivity of lakes. Recent and 

ongoing research in this region of the Arctic Coastal 

Plain includes assessments of lake/stream connectivity. 

Fish sampling is conducted in lakes by methodology 

approved by ADF&G for the purpose of water use 

under Fish Habitat Permits.

NQT9-86 Rosemary 

Ahtuangaruk

Yeah, when the sampling in July, there's other 

times when sampling can occur that may identify 

there are fish in that water-bearing area that are 

not being identified and can mislead what's being 

interpreted.

3.9 Fish Sampling of fish in lakes and streams for water-use 

permitting and land-use management typically occurs 

between early June and early September - not all water 

bodies can be practically sampled during all 

timeframes. It is accurate to note that some species 

may be missed with this approach, but this is not 

expected to lead to widespread mis-interpretation of 

fish communities on the landscape and many BMPs 

intend to broadly protect aquatic habitat, regardless of 

fish species present. Furthermore, CPAI's current

sampling of stream systems includes 3 different 

sampling events - early, mid, and late summer, in order 

to account for variability in fish species presence.

NQT9-87 Rosemary 

Ahtuangaruk

I also wanted to put in an opinion for restoration 

has not been occurring in a good way. It needs to 

be done in a really good way. That's another 

reason to push back on this activity. We really 

should have had a lot more restoration and 

recovery and restoring of areas that have already 

been impacted by oil and gas to try to improve 

some of the subsistence impacts that we've 

already been facing.

4.2 Mitigation NPR-A ROD Lease Stipulation G-1 requires that land 

used for oil and gas infrastructure--including but not 

limited to well pads, production facilities, access roads 

and airstrips--shall be reclaimed to ensure eventual 

restoration for ecological function, in order to achieve 

the stated objective of the stipulation of reclamation of 

the land to its previous condition and use.
Supplemental Environmental Impact Statement

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

413

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

NQT9-88 Rosemary 

Ahtuangaruk

So we really want to see some of that happen, as 

well as if we have to development on the south 

side of us, you have to come back here and talk 

to our Village. There has to be a better process of 

discussing ways that we may have hopes of 

protecting subsistence. I do not feel that activities 

in the south side will give our Village hope of 

having subsistence. The impacts that are already 

felt on the east side, the north side, and the west 

side of us are already tremendous. If you add the 

impacts from the south side to our Village, we're 

very concerned.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Section 4.6.8.9 Cumulative Impacts to Subsistence 

documents the presence of existing oil infrastructure to 

the east, north, and northwest of Nuiqsut. GMT2 would 

result in infrastructure to the west of Nuiqsut. The 

Cumulative section (4.6.8.9) discusses reasonably 

foreseeable future exploration to the south of Nuiqsut 

that may lead to development and infrastructure and 

anticipates additional impacts on subsistence use 

patterns, including the need to travel further and the 

reduced ability to avoid hunting near infrastructure. 

BLM encourages Nuiqsut to submit applications to the 

State of Alaska NPR-A Impact Mitigation Grant 

Program for funds to address subsistence impacts. 

NQT9-89 Rosemary 

Ahtuangaruk

But we also have a lot of concern for the migration 

for the caribou to our sister Village, Anaktuvuk 

Pass, and we have worked really hard to try to 

support their concerns and protecting their 

migration routes that have been tremendously 

with the amount of change around between the 

two Villages.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Section 4.6.8.9 Cumulative Impacts to Subsistence 

includes all reasonably foreseeable future development 

and anticipates that if those developments occur, 

combined with impacts from climate change, potential 

impacts to Anaktuvuk Pass could result. AKP is eligible 

to apply for funding from the State of Alaska NPR-A 

Impact Mitigation Grant Program for funds to address 

subsistence impacts.
Supplemental Environmental Impact Statement

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

414

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

NQT9-9 Rosemary 

Ahtuangaruk

When you put a project together and you say that 

you're going to look at emissions, but then you 

don't even enforce some of the process of 

development, like when we expanded Alpine. In 

your documents you said you're going to shut 

down the flare every few hours to allow the 

particulates to disburse. When you don't enforce 

that and allow it to be flaring for 23 days straight, 

those are very different modeling questions that 

are put out there. When you're looking at the 

document, you can put your model together and 

say that "every couple hours the flare is shut off 

and those emissions are calculated at such." But 

if you're not enforcing it and showing that those 

emissions are being reduced by making sure 

those flares are shut off, that model is a very 

different model.

3.5 Air Quality & 

Meteorology

The NEPA analysis is intended to gauge the impact 

from planned activity. Once the facility is in operation, 

they work under a permit from the State of Alaska. The 

Alaska Department of Environmental Conservation 

(ADEC) Air Compliance program is charged with 

enforcing compliance with the state permit. If deviations 

of operations are brought to BLM’s attention, we will 

notify ADEC to correct the issue.

UTQ1- 1 Brian Person Comment regarding that major impacts to 

subsistence activities were analyzed in GMT1, but 

the impact criteria for GMT2 is being done 

differently, i.e. major impacts are not being 

included.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

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 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. 
Supplemental Environmental Impact Statement

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

415

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

UTQ1- 10 Todd Sformo Comment that the BLM should use a more 

objective, independent strategy of using a 

quantitative approach to determine cumulative 

impacts.

4.0 Cumulative 

Effects Projects 

and Methodology

The current cumulative effects analysis supplements 

the analysis presented in the Alpine Satellite 

Development Plan EIS (BLM 2004), updating that 

analysis to include the current list of reasonable 

foreseeable future developments on the North Slope. 

Following NEPA guidance, this analysis also tiers to the 

cumulative effects analysis presented in the NPRA IAP 

EIS and the GMT1 EIS. 

UTQ1- 11 Lars Pears Comment that significant findings on subsistence 

need to be stated earlier in the main volume of the 

document. Seeing subsistence impacts and 

findings in Appendix L solely seems to minimize 

the emphasis and importance of the issue.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

Significant restrictions of subsistence uses is specific 

terminology required by ANILCA Section 810. The 

ANILCA Section 810 criteria is specific to answering a 

single question: whether or not there may be a 

significant restriction to subsistence use, and our 

guidance is based on case law regarding that 

overriding factor. Reference to the ANILCA 810 

evaluation has been added to the Executive Summary 

in the beginning of the document.

UTQ1- 12 Robert Suydam The BLM should continue to do caribou 

monitoring. While Conoco Phillips has some 

responsibility for monitoring caribou populations, 

the BLM should be the lead party for doing so, 

and also look at both the impacts to caribou 

populations from both GMT2 and other 

developments.

3.11 Caribou Thank you for your comment. The NSB, AGFD, and 

BLM will continue to collaborate on caribou monitoring 

efforts in the NPRA. 
Supplemental Environmental Impact Statement

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

416

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

UTQ1- 2 Robert Suydam Comment that it doesn't make sense to have 

impact measures for all resource areas except for 

social issues.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

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 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. 

UTQ1- 3 Taqulik Hepa, 

North Slope 

Borough 

Department of 

Wildlife 

Management

Comment that North Slope Borough and Conoco 

Phillips should continue caribou monitoring.

3.11 Caribou CPAI has stated their commitment to continue caribou 

monitoring. No in-text changes made.

UTQ1- 3 Taqulik Hepa, 

North Slope 

Borough 

Department of 

Wildlife 

Management

Comment that North Slope Borough and Conoco 

Phillips should continue caribou monitoring.

4.2 Mitigation See Section 4.4.5 Subsistence, Potential Mitigation 

Measure 6: Subsistence Monitoring Studies.

UTQ1- 4 Brian Person The BLM should put more financial resources 

towards studying wildlife.

3.12 Mammals The BLM Wildlife Management Program total budget is 

not under the control of BLM Alaska. BLM Alaska does 

receive funds for labor, operations, and projects under 

the program, which are primarily allocated at the state 

level. Most projects are ranked and funded on a 

statewide basis. The Arctic does receive more than a 

proportional share of BLM Alaska wildlife project 

dollars.
Supplemental Environmental Impact Statement

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

417

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

UTQ1- 5 Robert Suydam Comment that if a hunter does not prefer to go 

within 10 miles of development, that choice does 

represent a safety issue and a restriction.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

The SEIS discloses both potential benefits and 

potential negative impacts of development and 

attempts to be succinct. Recent data on use of roads, 

gathered since the Draft SEIS was published, and 

verbatim testimony from hunters, has been included in 

the Final SEIS. 

UTQ1- 6 John Hopson, 

City of 

Wainwright

Comment that communities only have a 3 mile 

buffer for firearms being discharged, whereas 

development areas have a 10 mile buffer. 

Question on why there is a 7 mile additional buffer 

for development.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

It is unclear what the commenter is referring to. The 

BLM has no knowledge of either the 3 mile or a 10 mile 

buffer that is described.

UTQ1- 7 Lars Pears Question regarding who manages the denial of 

access on road surfaces.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

The Nuiqsut Spur Road is a private road located on 

Kuukpik Corporation land. Access to this road is 

managed by the Kuukpik Corporation, and users are 

required to have a valid drivers license and are 

expected to sign a road-access agreement, in part to 

understand the rules for road use. The GMT1 Road is a 

private road operated by ConocoPhillips, and residents 

of the community of Nuiqsut have free access and use 

of the road under general safety guidelines. However, 

all access to drill pads located along the road requires 

a ConocoPhillips escort. Alpine Security is the point of 

contact regarding use of the GMT1 Road. The GMT2 

Road is expected to be managed under the same 

conditions as the GMT1 Road.
Supplemental Environmental Impact Statement

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

418

Comm # Commenter 

Name

Comments Comment 

Category Code

Comment Response

UTQ1- 8 Todd Sformo Comment that the restrictions on subsistence 

needs to be stated more clearly earlier in the 

document, outside of Appendix L. It is difficult to 

determine restrictions to subsistence earlier in the 

document without going to Appendix L.

3.15 Sociocultural Systems, 

Subsistence, and 

Environmental 

Justice

The Executive Summary has been updated to identify 

the results of the ANILCA 810 analysis. "Significant 

restrictions of subsistence uses" is specific terminology 

required by ANILCA Section 810, and that is why it is 

found in Appendix L. The ANILCA Section 810 criteria 

is specific to answering a single question: whether or 

not there may be a significant restriction to subsistence 

use, and our guidance is based on case law regarding 

that overriding factor. A detailed description of impacts 

is located in Section 4.34.5 Subsistence, identifies a 

host of positive and negative impacts to subsistence 

use beyond the criteria used in Appendix L. It is 

therefore more comprehensive. The current effects 

analysis supplements the analysis presented in the 

Alpine Satellite Development Plan EIS (BLM 2004), 

updating that analysis to include the current data. 

Following NEPA guidance, this analysis tiers to the 

effects analysis presented in the NPRA IAP EIS and 

the GMT1 EIS. 

UTQ1- 9 Taqulik Hepa, 

North Slope 

Borough 

Department of 

Wildlife 

Management

Comment that the areas of subsistence for fur 

bearers (in Slide 21 of the ANILCA hearing 

presentation) has been getting gradually smaller 

over the last 27 years, and that something needs 

to be done soon in terms of mitigation to help 

Nuiqsut and local hunters find animal populations 

as the animals move further west.

4.2 Mitigation While use of an observer to communicate the presence 

and location of game species is not specifically 

addressed in the Federal Subsistence Hunting 

Regulations, taking wildlife with the aid of "radio 

communication" is prohibited under both Federal and 

State regulations. The BLM lacks the regulatory 

authority to create a program by which observers assist 

local hunters with locating the presence of game 

animals for harvest.