NANA
NANA Draft SEIS comments on AAP
The Ambler Access Project ( AAP ) is one of the most debated potential development projects of our time in Alaska , and shareholders opinions about the proposed project vary . To better understand the opinions of all shareholders , NANA conducted listening sessions on the topic . Our board also receives shareholder comments on the matter during the open session of NANA board meetings and we included questions on AAP in the recent NANA Shareholder Survey .
After receiving all that direct feedback from shareholders , NANA ’ s board developed a specific list of criteria that the potential project would need to meet before our corporation would consider supporting the project . The criteria can be found on the NANA website at www . nana . com / aap /.
NANA staff are engaged in evaluating the potential project based on the board ’ s criteria . On Dec . 19 , 2023 , NANA submitted comments as part of a public process conducted by the Bureau of Land Management ( BLM ) to receive feedback on their AAP Draft Supplemental Environmental Impact Statement ( DSEIS ). The DSEIS is the federal government ' s way of studying the potential impacts of proposed development projects . The public can read their studies and comment on them .
You can find NANA ’ s AAP DSEIS full comments on our website at www . nana . com / aap /. We ’ ve also provided a summary for you below that has key quotes of the primary points we made in each section of the comments .
We are providing this information to shareholders to help you clearly understand NANA ’ s current position on the project . If you have any questions regarding these comments , please email lands @ nana . com .
Quyana for your involvement on this and other important matters . Shareholder feedback is critical to guiding NANA in decisions that impact our lands , people and corporation .
SUMMARY OF INTRODUCTORY REMARKS
NANA explained that we are commenting on the DSEIS because of our status as landowner in Northwest Alaska and as the Alaska Native Corporation ( ANC ) for the region . We stated that we are evaluating the project . We also explained , in detail , the board ’ s initial criteria that must be met before support for the proposed project is considered . ( Editor ’ s note : The criteria are listed at nana . com / aap /). We acknowledged that Alternative A would cross 21.5 miles of NANA lands and 3.11 miles of NANA selected lands . Additionally , we supported the authority of Doyon , Ltd . over its lands . Doyon is our neighboring Regional ANC to the east .
Introduction Key Quote :
“ NANA is conducting an evaluation to determine if these [ the board ' s ] criteria can be met in the context of the right to free , prior , and informed consent . Additionally , and most importantly , NANA is evaluating to ensure that AAP will not compromise the fee simple ownership rights to our lands in any manner or disrupt our Iñupiat way of life that is based on our connection to our lands , waters , and subsistence practices .”
A . NANA ’ s Mission
– p . 2 NANA COMMENTS
In Section A , we commented on NANA ’ s mission and our policy that subsistence is the highest and best use of NANA lands . The comments discuss how this perspective informs all lands choices , including our approach to responsible resource development .
Section A Key Quote :
“ Subsistence is the highest and best use of NANA lands . Accordingly , we approach management of our lands and engagement with other landowners in the NANA region in furtherance of the Iñupiat subsistence way of life .”
B . Controlled , Permitted Access Along the Entire Route
– p . 2 NANA COMMENTS
Section B discusses the remote nature of the NANA region and common modes of transportation . NANA ’ s comments focus on the Alaska Industrial Development and Export Authority ’ s ( AIDEA ’ s ) assertion that AAP would remain a private , industrial access road . In alignment with the board ’ s criteria , our comments state we will not permit access to NANA lands if the road is not private .
Section B Key Quote 1 :
“ As stated above , NANA is evaluating the proposed AAP to determine whether our initial criteria can be met , including whether AAP can and will remain private . NANA will prohibit access to our lands if there are not explicit legal assurances that the AAP will be designed and constructed as a private road and will remain private throughout its existence .”
– p . 3 NANA COMMENTS
Additionally , the comments in Section B discuss the Ambler-Kobuk-Shungnak sub-region , and assumptions the DSEIS makes regarding how this area will be connected and the anticipated disruptions BLM considered . NANA ’ s comments state that AIDEA must provide the public with comprehensive information about how it intends to legally keep the road private indefinitely to protect this area , including providing a robust trespass-prevention plan . NANA emphasized this considering the DSEIS ’ finding of the potential for drug and alcohol importation , potential human trafficking , as well as other forms of violence , as possible adverse impacts of AAP .
Section B Key Quote 2 :
“ Additionally , AIDEA must provide the public with documentation of the legal mechanism ( s ) which would protect against the AAP from being converted to a public transportation system in the event members of the public sue to open the proposed road for public use as is desired by various individuals and organizations ( see , for example , the Alaska Outdoor Council ’ s 2019 comments on the initial EIS7 ).”
C . Community Benefits
– p . 4 NANA COMMENTS
Section C discusses the assumptions the DSEIS makes regarding reductions in the cost of living to the Kobuk-Ambler-Shungnak sub-region . The DSEIS assumes Kobuk would connect to the AAP via the Bornite Road , and that while AAP would not connect directly to Ambler and Shungnak ; it assumes the two villages would pursue public roads connecting to the AAP . In our comments , NANA challenged that assumption and stated the the villages ' voices are required to make any decisions regarding potential road connection .
In our comments , we strongly suggested that BLM require neutral , independent economic studies to validate assumptions regarding reductions to the cost of living in the region , as that is cited as a primary reason for development of the project by project supporters . Our shareholders and the public have a right to review comprehensive research regarding the potential economic impacts of the proposed project .
Section C Key Quote :
“ NANA strongly suggests that BLM require neutral , independent economic studies to evaluate whether , in fact , AAP will reduce the cost of transporting goods , fuel , equipment , and supplies to these impacted communities and accordingly , reduce the extremely high cost of living .”
– pp . 4-5 NANA COMMENTS
NANA asserted in our comments that any roads built in that area would require approval of impacted communities , as well as NANA if they will cross or come near NANA lands . Given NANA ’ s status as landowner and steward , NANA would need to significantly review any proposed connection roads , particularly if they were expected to be public .
D . Shareholder Jobs & Workforce Development
The DSEIS highlights potential jobs related to construction and operation of AAP . NANA ’ s comments in Section D discuss AAP through the lens of the Alaska National Interest Land Conservation Act ( ANILCA ).
ANILCA was the law by which Congress ensured the proper balance between the designation of national conservation areas and the necessary disposition of public lands for more intensive private use that would address the economic and social needs of the people of Alaska . The comments also reference Executive Order No . 14096 that seeks to ensure that there are economic opportunities for “ underserved and overburdened communities ” like those of Northwest Alaska .
In Section D , NANA states that AIDEA must submit a robust workforce development plan in consultation with Tribes and ANCs to ensure meaningful benefits from any proposed project flow to the communities impacted .
2 The Hunter | 2024 February