Ambler Road Project
12-10-2019
A Briefing on the Ambler Mining District Industrial Access Project for Sierra Club Alaska Chapter
The proposed Ambler Mining District Industrial Access Project (aka “Ambler Road”, and hereafter, the Project or the Road) of interior Alaska is a monumental undertaking.
According to the Executive Summary of the Bureau of Land Management’s (BLM) Draft Environmental Impact Statement (DEIS), the Alaska Industrial Development and Export Authority (AIDEA) has applied for:
“a right-of-way (ROW) authorization across federal public land. The ROW approval would allow for an industrial access road from the Dalton Highway to the [Ambler Mining] District in north-central Alaska. The application proposes construction of a road, including multiple material sites, temporary construction camps and long-term maintenance camps, airstrips, a fiber optic communications line, radio communications sites, and guard stations. The requested term of the ROW authorization is 50 years, after which the road would be closed and reclaimed (i.e. camps, communications, bridges, and culverts removed).”
The Project is intended to be a restricted-access toll road, public access prohibited.
The basic idea here is that AIDEA wants to finance construction of the Road to connect the Ambler Mining District to Alaska’s limited road system, so that Canadian firm Trilogy Metals can commence operations on a series of Copper, Zinc, and Bornite open-pit mines in the District and have a way to truck the ore to ports near Anchorage and on from there.
The Road would traverse the river plains and foothills along the south side of the Brooks Range for 211 miles from the Dalton Highway to the Ambler Mining District (currently accessible only by air). The Road – as described by AIDEA’s preferred alternative – would cross about 45 miles of BLM and NPS-managed lands, parallel within 1-mile-proximity a 16-mile section of Wilderness-designated Gates of the Arctic National Park, have 18 major river crossings, require 11 major bridges (one of which would cross the Kobuk Wild and Scenic River), and would pose a multitude of threats to wildlife, fish, and soil-, air-, and water-quality…not to mention the visual impacts of such a major development and associated infrastructure marring an otherwise pristine landscape unmatched in but a few places on Earth.
One need only look to a similar operation – the Red Dog mine north of Kotzebue – for examples of toxic levels of windblown lead and zinc dust, and wastewater discharge issues that resulted in fines and a major lawsuit between developer Teck Resources and the Native Village of Kivalina.
The legislation allowing a project proposal with such a dizzying array of environmental impacts to even reach the desks of federal land managers is a subsection within the Alaska National Interest Lands and Conservation Act (ANILCA) of 1980 – Section 201 (4)(b):
(b) Congress finds that there is a need for access for surface transportation purposes across the Western (Kobuk River) unit of the Gates of the Arctic National Preserve (from the Ambler Minding District tot the Alaska Pipeline Haul Road) and the Secretary shall permit such access in accordance with the provisions of this subsection.
Interestingly, ANILCA 201 (4)(a) describes an equal provision for Gates of the Arctic National Park and Preserve to be managed “to maintain the wild and undeveloped character of the area…[and] to provide continued opportunities, including reasonable access, for mountain climbing, mountaineering, and other wilderness recreational activities.”
Yet public access will be prohibited on the proposed Road and associated airstrips, and in theory, the Road itself will be reclaimed after 50 years (despite the fact that reclamation in subarctic environments is notoriously difficult and the resultant mine sites and tailings repositories will need active maintenance and management in perpetuity to guard against airborne toxic levels of heavy metals and Naturally Occurring Asbestos, and that bane of so many heavy metal mining operations – Acid Mine Drainage).
While AIDEA officially submitted the application, the cast of characters is extensive, with the primary beneficiaries being Trilogy Metals Inc. (formerly NovaCopper, a subsidiary of NovaGold) – which plans to construct and develop a series of open-pit mines, and NANA Regional Alaska Native Corporation, which owns much of the land where the mines would be located and will partner in the venture with Trilogy.
Trilogy expects production of their anticipated Arctic operation to reach 10,000 tons/day of material, with annual yields of Copper at 125 million pounds, Zinc at 152 million pounds, Lead at 24 million pounds, Gold at 29,000 ounces, and Silver at 2.5 million ounces. The Road would provide access to this Arctic operation as well as a separate Bornite (Copper-rich mineral) operation within the Ambler Mining District.
Statements made by Trilogy CEO Rick Van Nieuwenhuyse at the Vancouver Resource Investment Conference January 21-22, 2018, indicate a strong interest in shipping product to the Asian countries of Korea, Japan, and China from Anchorage…nullifying any arguments that the ore produced will contribute to domestic self-sufficiency and/or alleviate any national security concerns about dependency on foreign nations for critical materials.
Let’s be very clear here: we are on the brink of irrevocably alterning one of the last great wildernesses on Earth so that a Canadian company can grow ever wealthier by selling the product to China. Let that sink in for just a minute…it’s the same tired story that’s been repeated time and again the world over; but the stakes are much higher now because these untrammeled landscapes are truly endangered, if not extinct already by most practical measures.
Tourism already far outpaces mining in contributing to Alaska’s economy (second only to petroleum production), yet again, we have chosen to degrade a sustainable, economically profound resource (wild landscapes), in favor of short-term gains from a non-renewable resource. The open-pit mines are expected to operate for no more than 15 years, providing a short-lived economic boost to local communities in exchange for long-term environmental problems and degradation of the sustainable economy.
AIDEA estimates that construction of the Project would be in the range of $190 to $300 million, whereas AKDOT estimates $400 million for initial construction and $8.5 million per year for maintenance. Research conducted by Ground Truth Trekking suggests that AIDEA’s favorable economic assessment for the project also indicates that Trilogy Metals is likely to pay back only a fraction of the Road’s cost to AIDEA…not the best optics for a State-sponsored entity.
Since the Project – or some iteration of it – is provide for in ANILCA, it may literally take another Act of Congress to block the planned development. At least two glaring deficiencies of the Project still need to be addressed:
1. No provision for public access. If the Project is approved, getting public access should be a high-priority issue.
2. Mitigations to the visual impacts of construction of the roadway itself, airstrips, towers, and all other engineered structures should be stringent. There are simple ways to minimize visual impacts of such an impactful development, such as contouring the road to match natural landforms, minimizing construction specifications wherever possible, utilizing road surface materials that closely match surrounding colors and textures, painting engineered structures to match natural colors and backgrounds, designing engineered structures to be the least obtrusive possible. If the Project is approved, we should ensure these mitigations are part of BLM’s stipulations for the Project.
Perhaps the best thing we can do is vote – and get aggressive about encouraging others to vote – for candidates at all levels of government who have demonstrated a commitment to valuing and protecting natural resources rather than selling this nation’s greatest wealth to the most convenient bidder.
The BLM is the lead federal agency conducting the environmental impacts analysis for the Project. The DEIS is available on the Central Yukon Field Office ePlanning website at:
https://eplanning.blm.gov/epl-front-office/eplanning/planAndProjectSite.do?methodName=dispatchToPatternPage¤tPageId=111130
The public comment period closed at midnight (AK time) on October 29, 2019.
Cooperating federal, state, and local agencies are:
U.S. Army Corps of Engineers
U.S. Coast Guard
Environmental Protection Agency
State of Alaska Department of Natural Resources
Northwest Arctic Borough
Alatna Village Council
Allakaket Tribal Council
Hughes Traditional Council
Noorvik Native Community
Participating federal agencies are:
National Park Service (Environmental and Economic Analysis)
U.S. Department of Transportation
U.S. Fish and Wildlife Service
Federal Highway Administration
More information can be found at:
Brooks Range Council (brooksrangecouncil.org)
Ground Truth Trekking (groundtruthtrekking.org)