[From the U.S. Government Printing Office, www.gpo.gov]




                                                     Office of the Governor
        I                            ~~~~~~~~Division of Governmental Coordination


U   Cumulative -mpacts in 'Alaska
I ~~Where They Occur and How Agencies and Districts Address Them

              I                                              ~~~~~~~~~~~Final Report










                  I  .  -  Y   -              -               ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~..... 






             I             . .~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~  '..  -.~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~........






I HT                                                           ASPS #01-95-004
I 39 3
   .A4                                                                June 1 995
Ii 99 5    ________








    Cumulative Impacts in Alaska
                 Where They Occur and
How Agencies and Coastal Districts Address Them

                        Final Report


                         Submitted to:

                   Glenn Gray, Project Leader
                         State of Alaska
                     Office of the Governor
              Division of Governmental Coordination
                        P.O. Box 110030
          240 Main Street, Court Plaza Building, Suite 500
                     Juneau, AK 99811-0030

                            and the
      Cumulative Impacts in Alaska Management Team:
         Glenn Gray, Division of Governmental Coordination
       Fran Roche, Department of Environmental Conservation
                 Sue Flensburg, Bristol Bay CRSA
                Linda Freed, Kodiak Island Borough
            Glenn Seaman, Department of Fish and Game
         Rob Walkinshaw, Department of Natural Resources
Gabrielle LaRoche, Department of Commerce and Economic Development

                       ASPS #01-95-004

                                            Ua. S. DEPARTMENT OF COMMERCE NOAA
                                            COASTAL SERVICES CENTER
                                            2234 SOUTH HOBSON AVENUE
                    HIDR Engineering, Inc. CHARLESTON   SC  29405-2413
                       2525 C Street, #305
                    Anchorage, Alaska, 99503

                  Louisa Moore, Project Manager
                 Mark Dalton, Contract Manager
           John McPherson, Project Researcher and Writer
               Elizabeth Benson, Project Researcher

                           June 1995







                           Acknowledgments 

HDR Engineering would like to thank all respondents for their time and contributions toI
this report. Without the expertise of those persons interviewed, this report would not
have been possible. Moreover, we would like to acknowledge the time. effort, and
guidance contributed by members of the Cumulative Impacts in Alaska Management Team
members.
This report was prepared with financial assistance from the Office of Ocean and CoastalI
Resource Management, NOAA, under the provisions of Section 309 of the Coastal Zone
Management Act Reauthorization Amendments of 1990. The views expressed herein are3
those of the author and do not necessarily reflect the views of NOAA or any of its sub-
agencies.







        I                                    ~~~~~~~Table of Contents
I      ~~~Section                                                                                             Page

       Executive Summary ...........................................................I

E1.0  Intrrdctoo....................................................................1-
         1.1I Purpose   .....  ....................... .~................................1-1
         1.2 Scope                                              ................................................................1-1
         1.3 Organization ...........................................................1-2
I        2.020Bakrun Bac.................................................................1-
         2.1 Project History                           ..........................................................2-1
         2.2 Cumulative Impacts Defined ...............................................2-2
         2.3 The ACMP Program and Cumulative Impacts..................................2-3
         2.4 Cumulative Impact Assessment in Alaska .....................................2-4

I        3.030Mehdloy..........Met......................................................1-
         3.1 Survey Method .........................................................3-1
         3.2 Survey Sample .........................................................3-2
         3.3 Interview Procedures ....................................................3-3
         3.4 Analysis of Survey Results and Application of Evaluation Criteria...................3-5

U        4.040Fnins................Fin...................................................1-
         4.1 Introduction...........................................................4-1
         4.2 Respondent's Frame of Reference...........................................4-1
I    ~~~~4.3 Geographic Areas.......................................................4-4
         4.4 Addressing Cumulative Impacts ............................................4-7
           4.4.1 Identification of Cumulative Impacts .....................................4-7
I        ~~~~4.4.2 Consideration of Cumulative Impacts....................................4-10
           4.4.3 Control of Cumulative Impacts.........................................4-12
         4.5 Obstacles and Difficulties ................................................4-14
I    ~~~~4.6 Techniques Used ......................................................4-17
         4.7 Successful and Unsuccessful Methods and Techniques ..........................4-18

I    ~~~5.0 Recommendations ........................................................5-1

3       ~~References

       Appendix A: Introductory Letter from DGC to all Selected Respondents
I       ~~Appendix B: Survey Instrument (blank)
       Appendix C: Cumulative Impacts in Alaska Survey Instrument and Survey Responses
       Appendix D: Sites Where Cumulative Impacts Are Occurring, As Observed By Survey
  3                  ~~~~Respondents










Tables                                                                                  Page

Table 3.1 Survey Respondents Selected and Interviewed .............................3-3
Table 4.1 How Techniques Have Been Unsuccessful (Question I I c).....                             .    ..............4-203
Table 5.1 Recommendations on Cumulative Impacts from Recent Reports ...............5-10


Figures                                                                                 Page

Figure 4.1 Obstacles Perceived by Respondents in Addressing Cumulative Impacts 
          Question 9.......................................................4-14
Figure 4.2 Obstacles Perceived by Respondents in Addressing Cumulative Impacts

          Question I10......................................................4-16







       I                                ~~~~~~Executive Summary

I         ~~As  Alaska grows,  increased activity to support  its population causes  impacts  to
          environmental, economic, social, and cultural resources. While these impacts are more
           Pgeographically dispersed than in other states, they are adding up over time resulting in
          reduced resource values. As with many parts of the country, these cumulative impacts are
          most pronounced in the coastal regions of the -state where the majority of population and
          activity exists.

          The overall goal of the Cumulative Impacts in Alaska project is to define and characterize
I        ~ ~~the problem of cumulative impacts statewide, so that any program changes made in the
           future are based on a solid understanding of what needs to be "solved." Designed to serve
           as an independent assessment of cumulative impacts in Alaska, this project focuses on
I        ~ ~~three main areas of inquiry, namely, (1) identifying where in Alaska significant cumulative
           impacts are occurring; (2) describing how state agencies and local coastal districts
           currently address cumulative impacts; and (3) evaluating the overall effectiveness of these
I        ~ ~~practices and providing suggestions on how they can be improved. This report's findings
           are based on information gathered during a telephone survey of resource management
3         ~~~practitioners statewide.

           Eighty-five people were identified to participate in this telephone survey including 52
           representatives from state agency divisions that deal with cumulative impacts, and a
I        ~ ~~contact from each of the 33 coastal districts.  The goal was to select a sample that
           represented a cross section of the practitioners who work with the Alaska Coastal
           Management Program or with resources in the coastal zone. Of these 85 people, 70
I        ~    ~participated in the telephone survey.  Each of these 70 people responded to survey
           questions regarding the locations of and current practices used to address cumulative
*         ~~~impacts.

           Once the interviews were completed, both qualitative and quantitative assessments of the
3         ~~~survey results were conducted. In conjunction with design of the survey, evaluation
           criteria were developed to determine the success of the respondents' methods for
           addressing cumulative impacts. By analyzing survey results and applying these criteria, an
*         ~~~overall evaluation of the effectiveness of current practices was developed.
           More than 175 individual geographic sites were identified by respondents as having
           experienced cumulative impacts. This total does not include respondents' comments such
           as b"95% of all the small villages in the state have cumulative impacts from inadequate
           waste disposal and water systems." The cumulative impacts are varied and widespread.
I        ~ ~They incur costs for communities and reductions in the quality of resources those
           communities depend upon.

I         ~~~The study found that current practices are inadequate for identifying, considering, and
           controlling cumulative impacts in Alaska. Basically, there is no concerted statewide effort




                                                            Cumulative Impacts in AlaskaI
                                                                    Executive Summary


to address cumulative impacts. In general, respondents have the experience and ability to
address cumulative impacts, but many obstacles exist and very few formal steps or
methodologies are consistently applied to address cumulative impacts. Success occurs inI
isolated cases where the components necessary for success are in place.

The obstacles identified by respondents include: a lack of a commitment from top-levelI
officials; unclear mandates and directives; uncertainty about the definition of cumulative
impacts; insufficient resources such as staff time and funding; a lack of guidance, tools,
standards or thresholds for practitioners to apply; a lack of training and experience in
smaller coastal districts particularly; lack of public understanding about cumulative impact
problems and how they can be addressed; inadequate information sources; and political3
pressure against addressing cumulative impacts.

Based on analysis of the survey findings and suggestions from survey respondents, the3
report concludes that there is a need for improving how cumulative impacts are addressed
in Alaska. The following recommendations are presented.

ï¿½  Establish a top-level commitment to address cumulative impacts in Alaska, supported
   by practitioners and the public statewide.
ï¿½  Pursue  more  explicit  authority  to  address  cumulative  impacts  in  legislation,I
   regulations, or policy.
ï¿½  Develop more formalized cumulative impact assessment guidance to be used by
   agencies and coastal districts based on existing statutory authorities.
ï¿½  Establish a cumulative impact definition in regulation.
*  Provide training for those responsible for cumulative impact assessment, particularly
   for small coastal districts to assist them in identifying, considering, and controlling
    cumulative impacts.
*  Provide adequate resources (including funding and devoted staff time).3
ï¿½  Develop a public education program.
ï¿½  Develop better sources of informnation and information sharing among agencies.
The findings and recommendations in this report form a framework for addressing
cumulative impacts statewide. Until action is taken on these recommendations, steps to
address cumulative impacts are likely to continue as they are now, largely informal, ad hocI
and rarely effective.











                                        Page ii







        U                                  ~~~~~~~1.0 Introduction


          When the Alaska Coastal Management Program was established by the Alaska Legislature
           in 1977, cumulative impacts in state resource management were not the focal issue they
I       ~ ~~are today.  The cumulative effects of multiple uses in particular coastal regions over time
           seemed a pressing issue only for the lower 48 states, and perhaps for Alaska some -time in
          the future. But as coastal populations and coastal uses have increased, resource managers
           statewide have had to face this difficult issue. Several court cases in recent years have
           also escalated cumulative impacts into a critical legal issue.

          The Alaska Coastal Management Act calls for consideration of cumulative impacts, but
           with no clear direction as to how the state should do so. This issue gained recognition in
           coastal states nationwide during the 1 980s. In 1990, the reauthorization of the federal
           Coastal Zone Management Act made cumulative impacts into a national priority with
           funding available through Section 309 of the Act for states to address this complex
3         ~~~problem.  This project, funded by Section 309 money, comprises one part of the state's
           process in determining its policy direction.

3         ~~1.1  Purpose

           The overall goal of the Cumulative Impacts in Alaska project is to define and characterize
           the problem of cumulative impacts statewide so that any program changes made in the
           future are based on a solid understanding of what needs to be "solved." The results of this
           project should lay the foundation for future measures. The Division of Governmental
I       ~ ~~Coordination (DCG) is conducting an assessment of federal methods used in identifying
           and addressing cumulative impacts. The next step in Alaska's cumulative impacts strategy
           is to convene discussion groups to develop broader recognition of the problems and
           potential solutions.
3         ~~1.2  Scope

           To provide useful baseline information, the scope of work for this project focuses on three'
3         ~~~main areas of inquiry.

                  * Identifying where in Alaska significant cumulative impacts are occurring, or are
  *                  ~~~~~~likely to occur in the future.

                  *  Describing how state agencies and local coastal district currently address
  I                ~ ~~~~~cumulative impacts and the direction they have to do so.

                  *  Evaluating  the  overall  effectiveness  of  these  practices  and  providing
  I                ~ ~~~~suggestions on how they can be improved.




                                                         Cumulative impacts in AlaskaI
                                                             Chapter 1.0 Introduction
This  project's  methodology  consists  of  gathering  information  through  telephoneI
interviews. A research methodology consisting of interviews with state and local planners
and resource managers has several advantages and disadvantages. Most importantly, the
research provides a collective picture of individual interpretations of cumulative impactI
problems from a selected sample of practitioners within and related to the Alaska Coastal
Management Program (ACMP). This collective picture provides a snapshot of the
problem and the current practices for addressing cumulative impacts. The most important
feature is that the -information gathered comes directly from those with current roles-("the
experts") in identifying and addressing cumulative impacts in Alaska. These respondents
were selected to represent a diverse group of perspectives and include planners, field
personnel, scientific researchers, permitters, and administrators from across the state.
More detailed information on the methodology of this report is contained in Chapter 3.0.I
The methodology does, however, have some limitations. For example it will not result in
a comprehensive list of geographic sites, but rather will identify primary sites ofI
cumulative impacts. Moreover, the project scope did not include reaching the many
others who have worked with cumulative impact problems in Alaska, such as attorneys,
outside consultants, or private permit applicants. The methodology does not provide forI
independent field verification of the sites mentioned to find out the degree to which
cumulative impacts are occurring or if methods to address the impacts are actually
working.   Thus, the success of current practices is evaluated based on secondaryI
information. The information is, however, from the professional practitioners who are the
experts in addressing cumulative impacts under Coastal Zone Management in Alaska.
Finally, the scope of this report is to examine how cumulative impacts are addressed inI
Alaska, particularly through the Alaska Coastal Management Program (ACMP). The
report does not, however, attempt to characterize implementation problems with the
ACMP overall and how the more general problems with the ACMP could be addressed.
These issues are discussed in a Department of Natural Resources report referenced in
Section 2.4.3

1.3 Organization of this Report

The first chapter of this report provides a brief introduction to the project and describes
the project's purpose and scope. Chapter 2.0 provides a project history, a definition of
cumulative impacts, and a brief review of cumulative impacts in relation to the AlaskaI
Coastal Management Program. Chapter 3.0 explains the methodology used to gather and
analyze information.  It specifically explains who  was interviewed, how  they were
selected, and describes the criteria and methods used to analyze the information providedI
by respondents. Chapter 4.0 describes the survey findings and evaluates the success of
the methods used. Chapter 5.0 presents recommendations based upon the findings in
chapter 4.0  and includes suggestions for further study.  Chapter 6.0 provides theI
conclusions of the report.





                                        1-23







       1                                 ~~~~~~2.0 Background

1         ~~2.1  Project History

          Alaska's strategy for addressing cumulative impacts to coastal resources as part of its
          section 309 assessment has been underway for three years. Federal funding, authorized
          under Section 309 of the 1990 reauthorization=-of the Coastal Zone Management. Act, is
          being used to fund research on four issues important to Alaska, of which, control of
          cumulative and secondary impacts is one. Several projects in addition to this report have
          been completed. In 1993 the Division of Governmental Coordination completed a study
          entitled "Regulation of Cumulative and Secondary Impacts in Alaska." Several other
          agency reports on cumulative impacts were also completed in Alaska during 1993 and
           1994, each with varying assessments of the issue. A detailed technical field study has been
3         ~~~completed on the cumulative impacts to one coastal resource, the main stem of the Kenai
          River. The Kenai Peninsula Borough coastal district drew on this study to develop local
          support for new cumulative impacts policies. A brief summary of these Section 309
*         ~~~Assessment projects is included in Section 2.4.

          Work done to date has gone a long way toward defining the problem, identifying what has
          been done in other states, identifying what statutory and regulatory authorities pertain in
          Alaska, determining some current practices in Alaska for addressing cumulative impacts,
          and cataloguing the shortcomings of current practices in protecting coastal resources.
I       ~ ~State agency discussions surrounding  the implementation of regulations, however,
          indicated that there was no consensus about the extent of cumulative impacts in Alaska
          and little information about where impacts occur or how state agencies and coastal
          districts address them.
          To help research and clarify the issue, an intergovernmental management team was formed
I       ~ ~~and tasked with overseeing a research effort to further study the issue. The management
          team was composed of individuals from the Alaska Department of Natural Resources; the
          Alaska Department of Fish and Game; the Alaska Department of Environmental
I       ~ ~Conservation; the Alaska Department of Commerce and Economic Development; the
          Office of the Governor - Division of Governmental Coordination; the Kodiak Island
          Borough Coastal District; and the Bristol Bay Coastal Resource Service Area coastal
          district. HDR's Environmental Services Division in Anchorage was selected as the
          consultant to conduct the research and prepare this report.

U         ~~The management team decided that a phone interviews should be used as the research
          method. The team identified 85 potential respondents including 51 representatives from
          state agency divisions that deal with cumulative impacts and a contact from each of the 34
          coastal districts. In short, the intent of the project is to characterize the problem of
          cumulative impacts statewide by surveying a broad cross-section of individual agency and
I       ~ ~~coastal district practitioners regarding sites impacted by cumulative effects and current
          practices used to address these impacts. A survey was developed and pretested in early


                                                    2-1




                                                          Cumulative Impacts in AlaskaI
                                                               Chapter 2.0 Background


1995 and interviews were conducted in March and April. This report summarizes the
findings of the interviews and provides recommendations on addressing cumulative
impacts in Alaska.
This project is important because of Alaska's unique opportunity to be proactive in the
management of its coastal resources. Whereas other states are struggling to restore their
coastal resources from decades of cumulative- impacts, Alaska has an opportunity to
preserve its coastal resources before cumulative impacts become difficult and expensive to
reverse.

2.2  Cumulative Impacts Defined 

Cumulative impacts are defined in federal regulation, not in the federal Coastal Zone
Ma nagement Act, but in the Council on Environmental Quality's (CEQ) regulations.
These regulations guide environmental impact assessment required by the National
Environmental Policy Act. Found in 40 CFR Part 1508.7, the regulations state:                          3 

       Cumulative impact is the impact on the environment which results from the
       incremental impact of the action when added to other past present, and
       reasonably foreseeable future actions regardless of what agency (Federal or
       non-Federal) or person undertakes such other actions. Cumulative impacts
       can result from individually minor but collectively significant actions taking
       plac e over a period of time.

The "general concept" of a cumulative impact used in this study is largely based on this
definition but was modified slightly to be more loosely defined and understandable. The
general concept was read to each of the respondents after asking them what the term
meant to them. It was deemed important to provide each of the respondents with a
definition so that all respondents would have a consistent point of reference with which to
answer the interview questions. The concept used in this study and read to all respondents
is as follows:I

       A cumulative impact is the effect of an action when added to the effect of
       other past, present, and reasonably foreseeable future actions, regardless of
       who undertakes the various actions. A cumulative impact can result from
       individually minor but collectively significant actions taking place over
       time. In other words, several minor effects add together to cause a moreI
       severe impact. A cumulative impact can be environmental, economic,
       social, or cultural in nature. The impact can be from a single source or
       from multiple sources added together or added together over time. For
       this survey, cumulative impacts are presumed to be adverse effects.




                                        2-2




                                                                      Cumulative Impacts in Alaska
                                                                           Chapter 2.0 Background


          Two assumptions should be noted here. First, the assumption that cumulative impacts are
          adverse is rooted in HDR's interpretation of the CEQ definition and the literature on
          cumulative impacts. The general implication is that cumulative impacts need to be
          assessed to determine  whether they constitute a significant adverse  effect.   The
          management team and the consultant recognize that some cumulative impacts (such as
          economic developments) are viewed as having beneficial cumulative impacts. To prevent
          potential confusion in the analysis of results, we-asked respondents to speak about adverse
I       ~ ~~cumulative impacts.

          Second, it was decided that the interviews would not address secondary impacts except
          where secondary impacts persist over time or are additive with other impacts, in which
          case they become cumulative. The team recognized secondary impacts as an important
          part of the overall spectrum of impacts to coastal resources, but decided to focus this
I       ~ ~~study on cumulative impacts. Thus, secondary impacts are addressed in the report only
          where they are cumulative as well.

          2.3 The ACMIP and Cumulative Impacts

          The Alaska Coastal Management Program was established in 1977 by the Alaska
I       ~    ~~Legislature which signed into law the Alaska Coastal Management Act (AS 46.40). This
          act, which was amended in 1994, provides the legislation for implementing the federal
          Coastal Zone Management Act of 1972. The intent of the Alaska's program is essentially
          six-fold and summarized here from the legislative policy which accompanies the act. It is
          state policy to: (1) preserve, protect, develop, use, and where necessary, restore of
          enhance coastal resources; (2) encourage coordinated planning and decision making in the
          coastal area; (3) develop a management program to guide and resolve conflicts involving
          the use of coastal resources; (4) ensure participation of the public and various levels of
          government in the program; (5) use existing governmental authority and structure in
          achieving the legislative policies, and (6) authorize and require state agencies to carry out
          their duties and responsibilities in accordance with the pro-ram.

          To implement the program, state regulations (6 AAC 50 & 6 AAC 80) have been adopted.
          These regulations describe how the state reviews projects for consistency with the
I       ~ ~~program, provide state standards for the review of coastal development, and set out
          guidelines for the development and amendment of local coastal management programns.
          The role that cumulative impacts play in the program is mentioned in statute and in
          regulation.
          The term "cumulative impacts" is explicitly and implicitly referred to in several ACMP
          statutes, regulations, and enforceable policies.   The most thorough analysis of the
          legislation regarding cumulative impacts is found the 1993 report titled "Regulation of
          Cumulative and Secondary Impacts in Alaska" (Glenn Gray, DGC, 1993). According to
          that document, the legislative intent and codified language of the Alaska Coastal
          Management Act implicitly provides direction to consider cumulative impacts. The


                                                    2-3




                                                          Cumulative Impacts in AlaskaU
                                                              Chapter 2.0 Background


direction is most specific in the definition of "use of direct and significant impact," found
in AS 46.40.210, which states in part:3

      Use of direct and significant impact means a use, or activity associated with
      the use, which proximately contributes to a material change or alteration in
      the natural or social characteristics of a part of the state's coastal area and
       in which..-.the use would, of itself, constitute a tolerable change or-
       alteration of the resources within the coastal area but which, cumulatively,
       would have an adverse effect [emphasis added].

In addition, the consistency review notice process requires consideration of cumulative3
impacts by the coordinating agency. Specifically 6 AAC 50.070(f0 states:

       In evaluating the need for public notice of a project, the coordinating3
       agency shall consider the magnitude of likely impacts, including cumulative
       impacts on the affected area.3

Finally, the DGC report identifies that nine coastal district plans specifically have
enforceable policies relating to cumulative impacts and a number other plans implicitly
require cumulative impacts to be considered based on the term "use of direct andI
significant impact." There are, however, still many questions about what is and is not
legally required regarding cumulative impacts.

2.4 Cumulative Impact Assessment in Alaska

This section provides a brief annotated bibliography on recently completed cumulativeI
impact studies in Alaska. These projects were funded under the State of Alaska's Section
309 assessment.  This section is intended to provide background for this report by3
highlighting research that has been conducted in the last three years. (It does not include
the many environmental impact statements and other legal documents which may have
addressed cumulative impacts in Alaska in recent years.)3

Regulation of Cumulative and Secondary Impacts in Alaska. This report by the DCC
(1993) documents the findings of a research project on the regulation of cumulative andI
secondary impacts in Alaska. The purpose of this project was to evaluate existingC
provisions in Alaska and other states regarding cumulative and secondary impacts to make
recommendations on changes to the ACMP program.
Cumulative and Secondary Impacts and the Alaska Coastal Management Program.
This report was prepared by the Southcentral Regional Office of the Alaska Department ofI
Natural Resources' Division of Lands (DNR) (1994). It was based on field work on the
Kenai Peninsula and elsewhere, and discussions with staff responsible for permitting,
monitoring, and enforcement work in the field. It establishes a framework for addressing
cumulative and secondary impacts. It also discusses the DNR's perspective on what must

                                        2-4





                                                                      Cumulative Impacts in Alaska
                *                                                            ~~~~~~~~~~~~~~~~~~~~Chapter 2.0 Background


          be in place for progress to be made on controlling cumulative and secondary impacts in
          the ACMP.

          Kenai River Fish Habitat Cumulative Impacts Project. This report was prepared by Jon
          Isaacs and Associates, Resource Analysts, Louisa Moore, and Nancy Wainwright (1994)
          to develop coastal management policies for~incorporation into the Kenai Peninsula
          Borough's coastal management program. Developed through a series of facilitated -public
I       ~ ~and working  group  meetings, recommendations  and coastal management  program
          revisions were recommended.

I         ~~An Assessment of the Cumulative Impacts of Development' and Human Uses on Fish
          Habitat in the Kenai River. This technical report prepared by the Alaska Department of
          Fish and Game (ADF&G) (1994) was designed to identify and evaluate the cumulative
          impacts of development actions on Kenai River fish habitat. The U.S. Fish and Wildlife
          Service (USFWS) Habitat Evaluation Procedures process was used for analyzing the
          impacts. Field data was collected, mapped, and analyzed to assess the impacts on rearing
          habitat of juvenile chinook salmon. (The importance of this study was to quantify habitat
          units to provide an indication of the cumulative impact on the river, and to provide a basis
*         ~~~for managing effects of future developments.)

          Nonregulatory Mechanisms for Habitat Protection.   This ADF&G  report (I1993)
          provides an evaluation of nonregulatory mechanisms for assessment and control of
          cumulative impacts of coastal uses on fish habitat along the Kenai  River.   The
          nonregulatory approach encourages landowner participation in the conservation and
I       ~ ~~protection of natural resources through education and positive incentives that increase the
          attractiveness of conservation activities.











          I~~~~~~~~~~~~~~~~~-







                             3.0 MethodologyI

3.1 Survey Method

Telephone interviews were the method used to gather data for this project. This method
was chosen for several reasons. First, because of Alaska's size and time and money
constraints, it was clearly impractical to conduct in-person interviews with all respondents.
Second, the physical presence of an interviewer can often affect some respondents'
thinking. Telephone contact, however, reduces the contact to one of voice only.
A  written questionnaire was not chosen because of the advantages of the telephone
interview process. First, it was determined that interviewing would result in more in-
depth answers. In a written questionnaire, respondents often skip open-ended questions,
or leave cryptic, vague answers. During an interview process the interviewer is able to
interact with the respondent to clarify responses, and this results in more complete
responses to complex issues. Another advantage of interviews is the opportunity to pre-
schedule time with respondents and ensure a higher percentage of completed surveys,
compared with the comparatively low percentage of returns associated with mailed out,
written questionnaires. For these reasons, telephone interviews were selected as the most
appropriate method to reach all respondents across the state.

A survey was designed to facilitate interview interactions, record keeping, and
documentation of responses. A copy of the survey is located in Appendix C. The survey3
questions were designed to be neutral to avoid leading respondent toward a particular
answer or presenting any bias. The approach to the survey design followed a "funneling"
methodology.   Generally each topic of inquiry starts with one or more open-endedI
questions and is followed up by a closed question which requires the respondent to
respond to a predetermined list of items. The philosophy behind this approach is that
asking the open-ended question first allows for the respondent's open, unbiased response.I
Subsequently, specific answers to the predetermined list are sought.

The final survey included 15 questions in four parts.I

    ï¿½  The respondent's concept of cumulative impacts and authorities or sources of
       direction, if any, that they used for addressing cumulative impacts.I
    *  Sites in the respondent's area where cumulative impacts have occurred.
    ï¿½  Steps or methods used to identify, consider, and control cumulative impacts.
    *  Closing information from the respondent (their related work experience and any
       recommendations).

It is useful to acknowledge several limitations to this survey. First, the survey acted as a
mechanism for collecting and evaluating information reported by respondents. In other
words, this project's findings are based on experts' interpretations of current situationsI
and practices. Second, this method incorporates no work to independently evaluate


                                        3-1





                                                                       Cumulative Impacts in Alaska
                                                                           Chapter 3.0 Methodology

          success of the methods in the field which have been used to address cumulative impacts.
          While one respondent may report that a given process is successful, another may report
          that it is not successful. No independent field verification of that success is incorporated
          into this project scope. For this reason, much of the evaluation is "process oriented," that
          is, it is assumed that if the process is effective outcomes will also be effective. There are,
I       ~ ~however, questions in the survey designed to determine whether the techniques and
          methods used have resulted in successful outcomes. These questions, however, still rely
          on the expert opinion of those interviewed. Thiird, respondents reported their experience
I       ~ ~according to survey questions asked. While all respondents were asked all questions
          directly from the survey, responses in part depend on the follow-up questions asked.
          Therefore, in some cases respondents may have reported more or different information
I       ~ ~~depending on follow-up questions asked. Prompting and follow-up questions are used in
          an interview process to elicit more complete and accurate information. The ability of the
          interviewer to read the respondents to ensure understanding of the question and obtain
I       ~ ~~complete responses to all questions is the main advantage to interviewing over a mail-out
          written survey.  It can, however, cause slightly different interpretations among the
          respondents where the interview deviates from the written questions. These types of
          limitations are prevalent in many types of survey methodologies and should be
          acknowledged.

          3.2 Survey Sample

          The objective of designing the survey sample was to establish a respondent pool that was
          representative of a cross section of the practitioners that work in ACMIP-related functions
          or with resources in the coastal zone. The management team had the responsibility of
          selecting the respondent pool. Each agency representative on the management team
          selected the respondents for their agency.   The criteria used to select respondents
          addressed a need for a broad representation:

                * geographically across Alaska,
              *  from the various program areas within each agency, and
I             *~~~~ among the types of responsibilities within each agency, such as field work, policy-
                  making, permitting, planning, and so on.

           Approximately 15 respondents were selected from each of the three resource agencies
           (ADEC, ADNR, ADF&G) and three respondents were selected from the Alaska
           Department of Transportation and Public Facilities (ADOT&PF), the Alaska Department
           of Commerce and Economic Development (ADEC), and the Division of Governmental
           Coordination (DGC). Each management team member also identified a list of alternate
3         ~~~respondents to be used in case interviewers were unable to reach an initial respondent or
           the respondent indicated an inability to participate. In addition to the agency respondents,
           one respondent was identified from each of the 33 coastal districts. This person was
3         ~~~generally the coastal district representative, who  is usually a planner in the larger
          jurisdictions but often a city manager or mayor in the smaller ones. The total pool ended
           up being a group of 85. Table 3-1 summarizes this group.


          *                                          ~~~~~~~~~~~~~~~~3-2




                                                            Cumulative Impacts in Alaska
                                                                Chapter 3.0 Methodology


                                     Table 3-1
                                Survey Respondents
                             Selected and Interviewed
                           N b&er C :Contact ed Number :NAttemptedi
            ADF&G                  11                      15
            ADNR                   12                      14
            ADEC                   13                      14
            DGC                     3                      3
            ADOT&PF                 3                      3
            ADCED                   3                      3
            Districts              25                      33
            :STota4ii    ::   li ::i:I  . :70 

3.3  Interview Procedures

The interview process began by contacting the respondents. An initial letter was sent to
each of the 85 respondents by the management team to describe the project, explain its
purpose, provide background and a cumulative impact definition, describe the survey
method, request their participation, and indicate that HDR  interviewers would be
contacting them.   HDR  interviewers were to make three attempts to contact each
respondent.  If respondents were not available, were unwilling to be interviewed, or did
not return calls after three attempts to reach them, HDR contacted an alternate respondent
on the list.

When respondents were reached, they were asked whether they had received the initial
mailing and had had a chance to review it. If they had, they were asked whether they were
available for an interview at that time, or if they were willing to set up a time for an
interview.  Where the respondents had not seen the mailing, or where they could not
remember the exact purpose for the project; the interviewers reviewed the purpose of the
project and described the interview process, and sent via fax a copy of the letter on
request.

Before beginning the questions, HDR provided introductory points regarding the project.
The information given to each respondent was as follows.

   *  All individual responses will be kept confidential (that is, only the interviewer will
       know the respondent's name).
   *  The survey is designed to find out where problems are located, what sorts of
       problems exist, and how you address them. Though the project is funded through
       the Alaska Coastal Management Program, all cumulative impacts are of interest.
   *  In each part, we will first ask an open-ended question (like how do you accomplish
       "X"), followed by multiple choice type questions (such as do you use the following
       methods to accomplish "X").
   *  We are happy to repeat or clarify any interview questions.


                                         3-3




                                                                       Cumulative Impacts in Alaska
                                                                            Chapter 3.0 Methodology

                aIt is perfectly legitimate to answer "I don't know,' and frank responses are the
                 most useful to the purposes of the project.
I          ~ ~~~* If interested, you will be sent a copy of the draft report of the project findings, for
                  their review and comment.

I         ~~The survey instrument was pretested on five individuals to ensure that questions were
          understood and that answers resulted in informnation required for the objectives -of the
          study. The pretest revealed that the time it took to conduct the survey (as initially written)
I       ~ ~was at least 50% above the amount anticipated. The time required (a minimum of 50
          minutes, to a maximum of I hour 50 minutes) proved to be a burden of time and effort for
          respondents.   Moreover,  arranging for such an extensive  time  for interviews  'in
          respondents' busy schedules was exceptionally difficult and time consuming.   Most
          importantly, such a long interview process was deemed to have the likelihood of some
          unintentional negative side effects, particularly a high non-response rate and potentially
          negative associations with the cumulative impact issue and the cumulative impact section
          309 Strategy. In recognition of the busy schedules of the respondents, the limited
          interviewing budget, and the desire to have time to talk with each of the selected
1         ~~~respondents, the survey instrument was consolidated. The survey was revised to ensure
          that the critical questions were retained, bias was eliminated, questions were asked in such
          a way that the information could be analyzed and summarized in a useful way, and
          duplicative and nonessential questions were eliminated. The final survey instrument
          required a minimum of 20 minutes to administer and a maximum of over two hours to
          administer. The average time was approximately 40 minutes.

          To maintain a high degree of consistency among respondents, only 'three HDR project
I       ~ ~team members served as interviewers.  Before the interviewing began an orientation
          session was held to review and initiate the interviewers on the survey procedures.

I         ~~Each interview was conducted from the survey instrument; thus each respondent was
           provided the same information about the survey, asked the questions in the same order,
           and, as closely as possible, the same wording for all questions. Prompting and follow-up
I       ~ ~~questions were used to elicit more complete and accurate information where it was clear
           the respondent did not understand the question as written. Interviews that had to be cut
           short were rescheduled and continued by the same interviewer from the point at which
           they left off.
           At the end of each interview, the respondents were thanked for their time and contribution
           to the study. The address used for the initial mailing was confirmed. Responses were
           recorded in the spaces provided on the survey. For open-ended questions, all responses
           were recorded in words as close to those that were spoken by respondents. To ensure that
           information was still fresh (and therefore complete) when it was documented, interviewers
           completed a written record on the survey instrument directly after conducting each
           interview. Each interview was timed and the time recorded on the survey instrument.





          I                                         ~~~~~~~~~~~~~~~3-4




                                                           Cumulative Impacts in AlaskaI
                                                               Chapter 3.0 Methodology

3.4  Analysis of Survey Results and Application of Evaluation Criteria 

Both qualitative and quantitative assessments of the survey results were performned.
Questions which lent themselves to database manipulation were entered into a Microsoft
Access database. These questions primarily involved the closed questions on the survey
instrument. Some open-ended questions were coded and entered into the database.
Because of the nature of the information gathered through interviewing, very few
descriptive statistics were run on the data. Frequencies (raw counts) and some -means
were calculated but no variances, standard deviations, or cross-tabulations were run. The
frequencies were run by geographic area, agency, and district.

To help in the qualitative assessment, hand written notes made by the interviewers for al
open-ended questions from all respondents were typed onto a survey form.  The
exceptions to this step were responses to Questions 4 through 8 and 1 2b, which were not
entered into the survey formn but were coded manually for analysis. This allowed HDR to
see all responses together, to qualitatively assess the results as a whole. The survey
instrument, with typed responses is contained in Appendix C.

In conjunction with the survey design, two sets of evaluation criteria were developed to
evaluate the effectiveness of how cumulative impacts are addressed, (1) to evaluate the
effectiveness of specific techniques and methods used by practitioners, and (2) to evaluateI
the success of those methods being used overall, at a statewide level. The criteria were
developed through a joint effort by the Cumulative Impacts Management Team and HDR.
Management team members and HDR  project team members each suggested lists ofI
potential criteria, and through discussions, HDR consolidated the criteria to meet the
requirements of the original request for proposals while also trying to faithfully represent
and incorporate all criteria presented by the individual management team members.
The purpose of the first set of criteria was to evaluate the effectiveness of a given
technique or method used (the steps taken) by respondents to address cumulative impacts.
For this purpose, the evaluation criteria are as follows:

     ï¿½Adequate steps are taken to identify the nature and extent of a potential cumulative 
       impact. In other words there are adequate measures to define the "problem," its
       causes, its effects, and particularly whether the impacts from the problem are
       adding up over time (or are likely to) from past, present and foreseeable future
       causes.

    *  Adequate steps are taken to consider whether the cumulative impact requires
       action. That is, the cumulative impact is judged or measured against some
       recognized threshold or standard.
    ï¿½  Adequate steps are taken to control the cause of the cumulative impact to prevent,

       stop, minimize, or mitigate the affects of the cumulative impact.



                                         3-5I





                                                              Cumulative Impacts in Alaska
                                                                  Chapter 3.0 Methodology

       Effectiveness of the steps taken is measurable in the field, in the economy, in the
       culture, or in the social system affected, and it is in fact measured in some way
       such as with on-going monitoring.

While there are potentially numerous additional detailed criteria which could be applied,
the above four are the principles which are applied in analysis of the compiled qualitative
and quantitative results. These criteria must be met in order for a method to be effective,
and for practitioners or others to know how effective it is.

A series of questions was designed to directly ask survey respondents how they identify
(Questions 4a, 6, and 11 a) consider (Questions 4b, 7, and I I a), and control (Questions 4c,
8, and 11 a) cumulative impacts and how adequate and effective they feel those methods
have been (Questions 4d, 4e, 1 lb, and 1 lc).

The second purpose of evaluation was for HDR to provide an independent assessment of
whether the steps being taken are adequate and effective statewide. Several additional
questions were specifically designed to do this. In creating these questions, HDR and the
management team developed a list of elements (criteria) deemed important to have in
place, for practitioners to yield effective results. The elements deemed important and
gauged by the survey include:

   *  Having a clear definition of what cumulative impacts are (Question 1, and 10);
   ï¿½  Having authority in statutes, regulations, and/or policy (Questions 2, and 2b);
   *  Having directive to address cumulative impacts (Questions 2, 2b, and 10);
   *  Having clear guidance on how  to identify, consider, and control cumulative
       impacts (Questions 10, 13a, 13b and 14);
   *  Having experienced, competent, trained staff (Questions 10, 12a and 12b);
   *  Using techniques for addressing cumulative impacts (Question 1 l a);
   *  Using methods which result in political/institutional support for controls (Question
       10);
   *  Having adequate resources, including staff time and funding (Question 10);
   *  Having sufficient information for decision making (Question 10 and 1 l a);
   *  Using resources, information, and methods to accomplish cumulative impact
       controls (Questions 4d, 4e, 8, 1 lb, and 1 Ic); and
   *  Applying measures to determine whether the methods are controlling cumulative
       impacts ( lla, I lb, and  l c).

By analyzing survey results in relation to the four criteria and the elements listed above, an
overall evaluation of the effectiveness of current practices was developed. This evaluation
is presented in Chapter 4.0.

To help illustrate the range of cumulative impact work going on in the state, site examples
were chosen. These site examples illustrate typical processes of addressing cumulative
impacts or particularly successful or innovative techniques. These site examples appear as
"Cumulative Impacts in Brief" in sidebar boxes throughout Chapter 4.0.


                                           3-6







                                 4.0 Findings 


4.1 Introduction

This chapter presents the findings regarding where cumulative impacts occur and how theyI
are addressed by state agencies and coastal districts. The findings are based on individual
telephone interviews conducted in March and April (1995) with the selected state agency
and local coastal district representatives. See Section 3.3 "Survey Sample" for more
information on the interview participants.

Of the 85 potential interview participants contacted by HDR, 70 were available and willing
to complete interviews-a return of 82% of the initial survey pool. Eighty-two percent of
agency respondents were interviewed (43 out of 52). Seventy-six percent of district
respondents were interviewed (25 out of 33). The compiled results are presented question
by question in Appendix C.  On that survey instrument, frequency counts are listed for 
each of the closed questions to indicate the numbers of respondents who answered a                      f
certain way. For those open-ended questions for which it was appropriate, the transcribed
notes of the interviewers are typed in. This appendix is a useful reference during review of
the findings presented in this chapter.
The findings are discussed below question by question, except in some cases where related
questions are discussed together.  In these cases, the questions do not all appear inI
numerical order. The survey questions were designed to elicit information which
pertained to the criteria listed in Section 3.4. Each of the questions is intended to provide
information that is deemed important to applying the criteria or in making a judgment onI
whether each criterion is being met. For example, having practitioners that know and
understand the definition of cumulative impacts is considered crucial to taking steps in
adequately identifying, considering, and controlling cumulative impacts.
4.2 Respondents' Frame of Reference

Several questions were asked about the respondents' knowledge and frame of reference in
addressing cumulative impacts. These questions were asked to identify what levels of
skills, background,,and knowledge program practitioners have for addressing cumulative
impacts. It should be noted that shortcomings identified in this section do not necessarily
reflect inadequacies of the program practitioners, but rather gaps in the current statewideI
practice of addressing cumulative impacts.

Question 1: Cumulative Impact Definition. To be successful at addressing cumulativeI
impacts, one important consideration is that those responsible for addressing them know
what they are. In the first question of the interview respondents were asked, "What does
the term cumulative impact mean to you?"  This question was intended to identify howI
many respondents have a working concept of cumulative impacts, and whether or not their

                                         4-1





                                                                  Cumulative Impacts in Alaska
                                                                          Chapter 4.0 Findings

concepts resemble the definition used by the Council on Environmental Quality (CEQ),
which was adopted for this study.

Sixty-four percent of the respondents had a working definition of cumulative impacts
which resembled the CEQ definition, and 36% did not. Agency respondents were more
apt to have a working definition than coastal district respondents with 79% verses 40%,
respectively. In the northern region of the_state, only 43% overall had a working
definition verses 66% and 71% for the southcentral and southeast regions, respectively.
The results are not poor, but considering that the introductory letter to respondents
provided a general definition, the percentages are somewhat low. This may suggest the
                                                              need   for   an   educational
              Cumulative Impacts in Brief                       campaign, especially to reach
                                                              out to some of the smaller,
          Site:: South Unalaska                   .             more remote coastal districts.
          Bay, Unalaska::                           ' '    0'
 Cumulative mlnpact.- Multiple seafood processing plant discharges,   After asking respondents for
 among other impacts, have been accumulating over several years in  their definition,  the definition
 the semi-enlosed- nearshore:: marine environment of the bay.  or concept used for this study
 Beachcombems complained about wastes occasionally washing up-on   was  read  to  each  of them.
 the beach:
                ~~~~~the beach.     ~This was necessary to make
 Steps to Address: it: Processing plants are required to monitor the size                t
 and volume of their seafood waste piles on the bottom of the bay and  sure that all respondents had
 dissolved oxygen levels. Plant operator monitoring has identified  the  same  concept  in  mind
 depressed levels of dissolved oxygen in the water at certain times of  before  proceeding  with  the
 year. The Environmental Protection Agency (EPA) evaluated the data  remainder  of  the  interview.
 from the: site: and decided to require a reduction in pollutants
 discharged. A Total Maximumr:Daily Load (TMDL) was established  Establishing a common  point
 Iby EPA  to reduce pollutants, specifically seafood wastes and  of    reference    on    what
 biochemical}oxygen (BOD). Thisiallocates "shares"of pollutants for  cumulative  impacts  are  and
 each discharge tom abideby: in their respective processing operations.    how  they  are  distinguished
 Notable Features:: In a fairly defined coastal area, with known,  from  isolated  impacts  was
 regulated pollution sources, hard data could be collected from the
 permittees and through agency field work on site.  Once the  deemed   important   to   the
 cumulative impacts were identified and confirmed, they were   collection   and   analysis   of
 considered against recognized federal and state water quality  survey responses.
 standards and violations were clear. In this case the regulatory
 agency had the authority and direction to enforce an additional control
 measure through  the  NPDES  permit which  assigns specific  Question 2:  Direction and
 responsibilities for reducing the collective impacts. The TMDL was   Authorities.    A    major
 issued in February, 1995 and revised permits have not been issued, so  shortcoming of any attempt to
 its success is not yet known, but it appears to be an effective method   address  cumulative  impacts
 for addressing at least one: source of cumulative impacts in Unalaska
 Bay-seafood waste discharges.                                   through    the    ACMP 
                                                              otherwise appears to be the
lack of statutes, regulations, enforceable policies, or other direction or guidance on
cumulative impacts. When asked if their coastal district or agency was directed by statute,
regulation, or enforceable policy to identify, consider, and/or control cumulative impacts,
40 out of 70 respondents (57%) indicated that they were unaware or were unsure of
direction regarding cumulative impacts. Statutes, regulations, and enforceable policies are
not specific enough in their approach to cumulative impacts to be used by agencies and



                                             4-2




                                                           Cumulative Impacts in AlaskaI
                                                                   Chapter 4.0 Findings

districts to appropriately consider and control cumulative impacts. In the case where theI
respondent indicated that direction exists for addressing cumulative impacts, most of that
direction was weak at best. Respondents indicated that the state statutes and regulations
"indirectly," or "implicitly" addressed cumulative impacts. Several respondents indicated
that it was federal law or regulation which provided direction, noting that this direction
was often only relevant to federal actions or projects funded with federal money. Only
one respondent specifically cited "use of direct and significant impact" within the ACMP
statutes (6 AAC 46.40.2 10) and the fact that-this phrase includes cumulative adverse
affects. See Appendix C, Question 2.3

Question 13: Internal Guidance. Respondents were also asked if they were aware of
any written guidance within their agency or coastal district for addressing cumulative
impacts. The majority of respondents were not aware of any guidance. In fact, only 16
out of 70 (23%) indicated that they were aware of any internal guidance. Those that were
aware that guidance was available, generally found that guidance to be useful.  TheI
guidance was mainly used to generate an awareness of cumulative impacts or for process
or assessment procedures. The more specific the guidance was on actually providing a
process, or specific standards, the more successful it appeared to be to respondents. SeeI
Appendix 0, Question 13.

These questions revealed that there is a lack of direction and guidance, or at least a lack ofI
knowledge about what direction and guidance exist. Moreover, respondents criticized the
direction that does exist, indicating that it only indirectly relates to cumulative impacts.
Without more specific commitment, direction and authority from the state, cumulative
impact identification, consideration, and control will continue to be applied haphazardly
and inconsistently, if at all. Agencies have a limited ability with which to address
cumulative impacts and lack the political support to fund and staff the positions necessary
to effectively work on cumulative impacts. In the absence of legislation or regulation
more specific to cumulative impact assessment, additional internal guidance could resolve
this.

Question 12: Work Experience. Experience is an important component to a successful
program of addressing cumulative impacts. Respondents were asked about their
experience at the end of the interview. In general, respondents from agencies and larger
coastal districts have background in addressing cumulative impacts. Over 64%  of theI
respondents have had some type field experience either in their current job or in previous
jobs. Moreover, over 74% have had positions other than the present one in which they
encountered cumulative impact issues. This would indicate that there is a good balancedI
pool of personnel available with a wide range of experience. The general observations of
the interviewers is that those in the smaller coastal districts had less direct experience in
addressing cumulative impacts. Often their position was city mayor, or city clerk, or cityI
manager, and yet among their duties was the implementation of the coastal management
program. Conversely, state agency people did not generally have prior experience dealing
with cumulative impacts at the local level. Very few individuals indicated that they had
private sector experience with cumulative impacts. These observations could indicate a



                                         4-3I





                                                                        Cumulative Impacts in Alaska
                                                                                Chapter 4.0 Findings

          gap in the common understanding of cumulative impacts amongst state, local, and private
          interests.

          4.3 Geographic Areas

          This section presents a discussion of the sites which respondents indicated were
           experiencing cumulative impacts.   Respondents were asked the question: "Ar e_ there
           geographic sites in your jurisdiction/area of concern where you believe uses and activities
I       ~ ~~are causing environmental, economic, social, or cultural effects to add up over time?"
           Ninety percent of the respondents indicated that they know of sites that were experiencing
           cumulative impacts. For the 63 respondents that answered yes, they were asked to name
           and locate the site resulting in a list of over 175 sites. They were then asked to note the
           environmental resources or economic, social, or cultural uses that are affected and the
           cause of the impacts. In general, cumulative impact problems are specific and localized,
           occurring in areas of concentrated use and settlement. Problems often relate to water
           quality, impacts to habitat, and quality of life considerations such as recreation experience
           and subsistence.   Finally, the definition of sites often remains general, such  that
           respondents rarely identified problems in specific terms. For example, what habitat, or
           what aspect of the habitat is being impacted. The complete list of sites, resources
           affected, and causes cited by respondents is contained in Appendix D. A brief discussion
           of the sites by region appears below.

           Statewide Sites. Several respondents expressed concern over rural Alaskan villages,
           stating "every small village"~ or "95% of the small villages" are experiencing cumulative
           impacts. The main resources affected were listed as public health facilities such as
I        ~ ~drinking water systems and solid waste disposal.  The main causes of the impacts
           according to respondents were lack of a tax base or means to combat the problems. Other
           cumulatively impacted statewide sites noted included all transportation facilities, waters on
I        ~ ~~the statewide impaired waterbody list, placer mining sites, state special areas (such as state
           habitat areas and game refuges), and development impacting all larger communities.

           Southeast. The southeast region includes all Alaska communities and coastal districts
           east of the 141st meridian. The most frequently mentioned sites were Ward Cove in
           Ketchikan, Thorne Bay northwest of Ketchikan, and the Juneau area.

           Respondents indicated that the main resource being affected in Ward Cove is water
           quality, which in turn affects fish habitat and air quality. In this area a number of sources
           of impacts add up to cause the cumulative problems. This includes discharge from a pulp
           mill, waste from seafood processors, runoff from homes, and industrial and residential air
           emissions. A similar situation is occurring in
           Thorne Bay, where discharge from a pulp mill, storm water runoff from the community,
           bark deposition, and pollution from the small boat harbor, added together over time to
           impact the water quality. The Juneau area is experiencing cumulative impacts in a number
           of areas in and around the city. Water quality, which




                                                     4-4




                                                            Cumulative Impacts in Alaska
                                                                    Chapter 4.0 Findings

has been impacted from urban and industrial development and boat traffic; air quality and
visibility, which are impacted by wood smoke and cruise ships; and wetland and other
                                                            habitats, which have been
                                                            lost   due    to   urban
                                                            encroachment,  are  some
                                                            of the cumulative impacts
                                                            occurring.     Numerous
                         .,,,.0                             other sites (streams,-bays,
                                                            and     habitat)     were
                                        * ,.~,~-. -~ .,      mentioned    as    being
                                                            impacted     from      the
                                                    ".,' ,,~  cumulative   affects   of
                          ~'-'~ - Southeast                 logging.    For  instance,
       ,,.,-~'"~ '                  Region                   over 25 individual creeks
                                                            and 8 bays were cited as
being impacted by logging.

Southcentral Alaska.  The southcentral area, as shown on the accompanying map,
includes all of the Anchorage area, the Kenai Peninsula, the Kuskokwim Delta, and
southwest Alaska. The areas most often mentioned by respondents as experiencing
cumulative impacts include wetlands and creeks in the Anchorage area, and the marine
environment of Unalaska Bay, rivers on the north and west side of Cook Inlet, creeks near
the road system, rivers and fishing areas on Kodiak Island, and the rivers and marine
enviomments  on   the   Kenai                        .
Peninsula, particularly the Kenai
River and Kachemak Bay.                                     ."                                        I

Wetlands  in  Anchorage  have
mainly 'been lost to residential      Sou'h-entral
and    industrial   development         Region
thereby impacting riparian and
terrestrial  habitat  and  water                      ..                               %
quality.    Several  respondents
mentioned that the Anchorage
area creeks (Ship Creek, Chester
Creek, Campbell Creeks) have
been impacted by community expansion, runoff, and military contaminants, and this has
degraded fish habitat and water quality. The Unalaska Bay and Dutch Harbor have been
impacted by disposal of fish processing wastes and fill, and harbor activities. The result
has been a cumulative effect on the water quality and marine habitat of the bay.

According to several respondents, rivers and habitats in the Cook Inlet area, including the
Susitna, Little Susitna, Deshka, Yentna, and Talachulitna Rivers and the Susitna Flats and
Matanuska Valley state game refuges, are being impacted by increasing public recreational




                                          4-5





                                                                        Cumulative Impacts in Alaska
                 *                                                             ~~~~~~~~~~~~~~~~~~~~~~Chapter 4.0 Findings

          use, timber harvesting, and grazing. Similar activity is occurring along rivers and streams
          accessible to the southcentral road system. Streams, such as Deep Creek on the Kenai
I       ~ ~~Peninsula, are experiencing  increasing public recreation use which in turn is impacting
          fisheries, wildlife, and the experience of the users.   Finally, according  to several
          respondents, areas such as Ayakulik River, Pillar Creek, Near Island Channel, and the
          Karluk River and Lake on Kodiak Island are also experiencing cumulative impacts. The
          main causes are increased commercial and sportfishing use, tourism.

          Finally, the Kenai Peninsula was frequently mentioned as experiencing some of the
          heaviest cumulative impacts in the state. Impacts in this area range from wildlife habitat
          destruction due to -razing at Fox River Flats, to water quality and fisheries resources
          degradation in Kachemak Bay caused by increasing residential development, tourism, and
          fishing pressure, to salmon stream degradation caused by logging, residential
          development, and fishing. The most studied and the most impacted site mentioned is the
          Kenai River.

          Northern Alaska.
          The most mentioned site
          in  the  northern  region              N-orten
          (shown       on       the              Rgo 
          accompanying       figure)
          was the Prudhoe Bay oil
          and   gas   development                       .Qr:4, 
          complex.      The      oil
          exploration and develop-. 
          ment that has occurred in
          this area has impacted
          wetlands, lakes, caribou,
          cultural resources, air and water quality, vegetation, waterfowl habitat, and the near shore
          marine habitat of the Beaufort Sea.   The causes of the impact is the incremental
          development of gravel pads, roads, spills, debris, gravel mining, noise, pipelines, dust, and
          human activity accumulated over time that has accompanied oil and -as development.
          Another frequently cited cause of impacts was mining. Several respondents mentioned the
          Red Dog Mine and other mines near Nome as generally impacting air, water, visual,
          habitat, and other resources. Mining has also caused impacts near Fairbanks (Fort Knox
          Gold) and along drainages of Interior Alaska. Causes include runoff, tailings, storage,
          shipment, road building, human activity, and ore loading and shipment. Other cumulative
          mining impacts cited by respondents include placer mining on the Seward Peninsula, which
           has impacted streams, fish habitat, and cultural values. Gravel raining for road building
           was another cause of mining-related impacts.

          Urban development around Fairbanks was cited as the cause of cumulative impacts by
          respondents. The North Pole area experiences severe flooding due to poorly located
          residential development. The south Cushman Street industrial area is contamninatingZ


          *                                         ~~~~~~~~~~~~~~~~4-6




                                                           Cumulative Impacts in Alaska1
                                                                   Chapter 4.0 Findings

around water due to the industrial shops' use of leaching pits for wastewater disposal. AirI
quality caused by development is also of concern. For a complete list of the sites,
resources affected, and the causes identified by respondents, see Appendix D.

4.4 Addressing Cumulative Impacts

One of the main purposes of the project was to assess the methods used to address
cumulative impacts in Alaska. The process of addressing cumulative impacts was broken
down into three steps namely, (1) cumulative impact identification, (2) cumulative impact
consideration, and (3) the cumulative impact control. In other words, how do practitioners
typically learn that cumulative impacts are occurring, how do they decide the impact is
serious and what should be done about it, and finally what actions do they take or what
techniques have they used to keep the impacts from getting worse? It should be noted
that these steps do not represent an official process, either mandated in regulation or set
forth in theory as an absolute. They are presented to provide a framework for discussion.
In actual practice, the same techniques may be used in one, two, or all three steps, the
steps may be merged together, or they may occur in a different order. 

4.4.1 Identification of Cumulative Impacts

The identification step of addressing cumulative impacts is that step where the practitionerI
determines or learns of a cumulative impact. Questions in the interview were intended to
determine how respondents learn of cumulative impacts and what techniques or methods
are used to identify cumulative impacts.
Questions 4a and 6: Identifying Cumulative Impacts. To obtain information on the
process, respondents were asked to choose the site or situation they knew the most about
and then were asked, "How was it determined that impacts were adding up and causing
problems over time?" Later, if the steps they described in Question 4a were atypical, they3
were asked to describe more common practices (steps or techniques) used to determine
whether a cumulative impact is occurring or has the potential to occur.

Findings indicate that overall, the process used is very informal and is often not specifically
intended as a means of identifying cumulative impact. The two most common methods for
identifying cumulative impacts were through "public complaints" and "personal/
professional observation" and not through a formal process." In general, practitioners are
not specifically looking for cumulative impacts. Form-al processes or methods are not
employed specifically for cumulative impact identification.  The impacts are identifiedI
through the processes of normal job routines. Thus, permitters identify cumulative
impacts during permit reviews either through public comment on the permit or based on
professional judgment during the permit application and review process.   Similarly,I
planners identify cumulative impacts during public meetings on a plan, and those that write
or review environmental documents identify them during the Environmental Impact
Statement (EIS) scoping process.   The most formal methods were used by those
practitioners that actually monitor or conduct special studies for impacts.   These


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                                                                   Cumulative Impacts in Alaska
                                                                            Chapter 4.0 Findings

practitioners often have extensive field responsibility and use hard science in their jobs.
Thus, biologists in the ADF&G and health scientists in the ADEC were more likely to use
monitoring. The use of monitoring and special studies does, however, similarly fall within
the normal job duties of these professions (such as water quality or air quality testing,
habitat or species surveys, and so on) and were not usually conducted specifically to look
for cumulative impacts.

By  "coding"  or  sorting  the
responses to Questions 4a to 6
into categories,  the following                                            i
techniques    for    identifying          ite  No   Slope Oil
cumulative      impacts       were                                                        ..
determined.  These  techniques
are  ranked  roughly  based  on   Cumulative Impact:  The combination of roads, drilling pads.
the   frequency   of  response.   physical use of the land, noise, dust, and aircraft and boat traffic has a
                                    cumulative effect on wildlife (particularly caribou), subsistence uses,
While responses to Question 4a   and;air and water quality.
provide  a good  indication of   Steps toAddressit:: Potential oil exploration problems have come to
the types of techniques used to   agencyattention from public comment during meetings about specific
identify cumulative impacts and   projects, most recently: onri whether to open or close the Arctic
                                    National.. Wildlife Refuge to oil exploration.  Through personal
describe briefly how  they .are   observation: and anecdotal stories of subsistence users, it was
used.   Because  the questions   determined that the cumulative problems in this area need attention.
were open ended, it likely does   The steps taken to control. the impacts have been to remind agencies
I  not    provide    an    accurate   of their responsibilities, to notify  the congressional delegation,
"count" of the frequency with   through implementation and enforcement of the borough's permitting,
                                    zoning, and other planning authorities, the actual filing of, as well as
which   these   techniques   are  the threat: of law suits, and the application of political pressure
used.   The reason for this is  through participation- in- coalitions which have included at times
that many  respondents  simply   Native:organizations, environmental groups, the oil industry, and
do  not  think  of a  particular  commercial: fishermen associations.
                                    Notable Features:  This case example highlights very typical
technique  when  asked  cold,   identification and consideration steps used in the state. Most districts
with  no  prompts.   However,   and many agencies do not have a formal process to identify and
used   in   conjunction   with   assess cumulative impacts, particularly those occurring beyond the
Question  I la,  it provides  a   scope of their own limited jurisdictions, but rather rely on public
more   clear  picture  of  the   comment and informal discussions to assess whether there is a
                                    problem.   Moreover,  it highlights the subjectivity that often
numbers  and  rankings of the   accompanies a cumulative impact.  For example, while the public
techniques by their frequency of   may fear a cumulative impact, the oil companies will argue there is
use (see section 4.6). It should   none. Whether there is one or not is very often debated.
be noted that respondents often used and identified more than one of these methods and
often used the techniques listed below in conjunction with one another.

            Public Comment - Public complaints on nuisances or comments during EIS
            scoping, permit review, and public meeting on pending plans, for example.
            were the most commonly mentioned ways in which practitioners identify
            cumulative impacts.
        *   Professional Judgment - This method included personal observations often
            when in the field, or during permitting, planning, or EIS review.



                                              4-8




                                                          Cumulative Impacts in AlaskaI
                                                                  Chapter 4.0 Findings

        *No  Process - Many respondents indicated they take no steps specific toI
          cumulative impact identification or have no formal process. Although several
          respondents indicated that there was no "process" specific to cumulative
          impact identification, they nonetheless may have used techniques which did in
          fact allow them to identify cumulative impacts.
        *Monitoring (tracking permits, taking samples, photo documentation).
        *Field Investigations (field surveys, site visits) - This method is used heavily in
          conjunction with professional judgment.
        *Agency Identification - Through contact with, or directly from other agenciesI
          many respondents noted that they identify a cumulative impact when another
          agency comments on a plan, permit, or EIS review.
        *Planning Processes - Public comment on a plan during a planning processI
          sometimes identifies cumulative impacts.
        *Permit Application and Review - Public comment or professional judgment
          during a permit process identifies the cumulative impacts.I
        *Modeling and Special Study - Some respondents identified cumulative impacts
          through the use of a special study. Most uses of special studies or monitoring
          identified cumulative impacts when investigating an activity for some other
          reason. Only in a very few instances was a special study conducted specifically
          to look for cumulative impacts, (such as Section 309-funded studies on the
          Kenai River).

If the ability of respondents to list sites experiencing cumulative impacts is any indication3
of the success of the methods used to identify those sites, then we can say that the
techniques used for the identification step are working. Clearly respondents are able to
identify sites across the state. They understand the causes and know what resources and3
uses are being impacted. See Section 4.3 and Appendix D, for a discussion of the
identified cumulative impact sites. In general, however, the methods used to identify
cumulative impacts are not specifically intended to identify cumulative impacts.  MostI
often they result out of a process intended for other purposes. One reason for this is that
practitioners do not have a mandate to look for cumulative impacts.   Interestingly,
however, many respondents indicated that whether or not an impact is occurring is aU
matter of perspective and opinion and is often in dispute. Moreover, the point at which an
adverse cumulative impact occurs (the threshold) was identified as being a subjective or a
political decision in many instances.  The result is that impacts are not always clearlyI
defined nor specific but are often politically defined and  disputed.   Thus,  while
respondents are able to identify sites, which in their opinion (which they "~know") are
being cumulatively impacted, what is "known" is often disputed. While respondents were
told that cumulative impacts include reasonable foreseeable future impacts, few
respondents discussed future impacts.  It appears that obtaining consensus in identifying3
currently impacted areas is difficult enough, to identify "reasonable foreseeable future
impacts" would be even more disputed.

A limitation of this report and with may of the methods used by respondents, is the lack of
field verification. Generally respondents indicated the value in field verification but often



                                        4-9I




                                                                         Cumulative Impacts in Alaska
                 *                                                              ~~~~~~~~~~~~~~~~~~~~~~~Chapter 4.0 Findings

           cited the lack of money and time to adequately study and verify cumulative impacts in the
           field. This study relies on the opinions of the experts which generally rely on their
I        ~ ~~professional judgment and public outcry to identify cumulative impacts.

           4.4.2 Consideration of Cumulative Impacts

           The consideration step of addressing cumulative impacts is that step where practitioners
           assess or determine whether there is a problem severe enough to require action and
I        ~ ~~determine the actions they should take to try to control the problem. In other words, after
           they know a cumulative impact is occurring or is likely to occur, what do they do to
           decide that the cumulative impact is significant and needs attention? Moreover, how do
           they determine what attention it needs?
           Questions 4h and 7: Considering Cumulative Impacts. Respondents were asked to
I       ~     ~~explain how they determine that problems need attention and to discuss the processes or
           techniques used to consider cumulative impacts. Very similar techniques are used in this
           step as those used in the identification step but with a slightly different emphasis. The
           most frequently received response was that "no process"~ or "~no formal process" was used
           "4specific" to cumulative impacts. Monitoring, professional judgment, and special studies
           were the next most frequently used steps for considering cumulative impacts. In general it
           appears that after learning of a problem, agencies and districts take a more focused
           structural approach to assessing whether or not that problem is significant. Monitoringt~
I        ~ ~~the problem and studying it are the most frequent precursors to taking action.
           A ranking of the respondents' methods used for considering cumulative impacts was
I        ~ ~~generated from the responses to Questions 4b and 7. These methods are listed below.
           For more information on the actual frequency with which respondents used each of these
           techniques, see section 4.6.

                  * No Formal Process - Many respondents stressed that there is not really a
                      formal or official effort made to consider or evaluate cumulative impacts.
  I                ~ ~~~~This indicates that there are not explicit steps used to assess cumulative
                      impacts and where there are specific steps employed, they are not usually
  *                  ~~~~~~applied specifically to cumulative impacts.

                  * Monitoring (tracking permits, change, sampling measurable impacts, and so
                      on)

                  ï¿½ Professional Judgment - This method involves making a field visit to assess a
                      complaint or situation, or employing a professional judgment on the
                      information available or collected. This technique is most used in situations
                      where impacts are not measurable or information, time, funding, or scientific
  I.               ~ ~~~~assessment is unavailable.



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                                                                Cumulative Impacts in Alaska
                                                                        Chapter 4.0 Findings

       *   Special Study -   Special studies were  commissioned  but not usually to
           specifically look at the cumulative impacts. Most of the special studies that
           have been commissioned to assess cumulative impacts are listed in Section 2.4.

       *   Public Comment   - The use of this method can best be described as the
           "squeaky wheel syndrome." Many respondents indicated that the process can
           be very political and not necessarily based on methodical assessment.
           Sometimes projects are stopped simply because public outcry indicates concern
           even though no  assessment indicates that there is a cumulative  impact.
           Conversely, even though an assessment may indicate a severe or impending
           cumulative impact, consideration of whether and how to control the impact is
           often decided by public sentiment.

   Application of Regulations or Planning Policies - This technique is often used in
   conjunction with professional judgment and is closely related to permit review.
                                                              Practitioners look to coastal
          *   Cumulative Impacts in Brief                        management plans,
                                                              comprehensive plans,
                                                              regulations, legislation, or
                                                              special area management
                                                              plans for policy guidance on
*  Cumulative Impact:  Like several popular bays on the lower     whether an identified
   Kenai Peninsula, Jakolof Bay is: being impacted by high       cumulative impact is
   recreation density and increasing fishing pressure. In this case,  acceptable. Potential
   the: demand for manculture in the bay where there is already
   residential development is the- perceived source of cumulative  problems with this method
   impacts.:                                                     are described in section 4.2.
*  Stepsa to::Address it: The problem was identified by public
   comment. and: assessed by professional judgment during theis
   permit review process on a batch of approximately  13
   mariculture permit applications. Permit stipulations were placed  technique is usually used in
   on the permits to require such controls as setbacks between   conjunction with applying
   farms, banning of shore ties, and closing the area to additional  professional judgment. or
   farms,                                                        regulations and planning
   Notable Features: The control methods have been successful.
   However, this case highlights the effect that strong public and  policies.
   political sentiment has on the process.  The strong permit
   stipulations and moratorium on additional farms stemmed more
   from politics than from science. Better public education has been   Internal  Discussion  - This
   suggested as a way to bridge the gap between what scientific
   assessment indicates and what the public believes.                                              i
                                                              a few respondents in the
   open-ended question and by many respondents in the closed question (see section 4.6).
   It is likely a technique used in nearly all agencies and districts usually as a component
   of some other method.

To most respondents the phrase "consideration of cumulative impacts" seemed unclear,
perhaps because they did not understand the phrase or because few processes for
considering cumulative impacts exist.


                                           4-11





                                                                 Cumulative Impacts in Alaska
                                                                         Chapter 4.0 Findings

4.4.3 Control of Cumulative Impacts

The third step in addressing cumulative impacts is controlling the impacts.  The survey
was designed to determine the kinds of methods used to control cumulative impacts in
Alaska. In other words, after a cumulative impact has been identified and determined to
need attention, what kinds of actions are taken to prevent or remedy a cumulative impact?

Questions 4c and 8:                             Cumulative=Impacts in Brief
Controlling         Cumulative
Impacts.   Respondents  were                S/te: Mendenhall
asked  to  discuss  steps  they             Valley, Juneau
have  taken  to  address  the
cumulative   problems   at   a
specific site of their choosing.   Cumulative Impact: The added effect of many individual, residential
                                  wood stoves and road dust caused a cumulative impact on air quality
                                   and made the area fall below federal air quality standards.
typical, respondents were asked  Steps to Address it:  After public complaints mounted,  direct
to discuss kinds of actions they  monitoring of the air was used to determine if air quality standards
typically take to control or limit  were violateAd  The local and state governments worked together to
cumulative  impacts  in  their  create and, enforce: a wood smoker ordinance: and fund an aggressive
                                   paving program to reduce the emissions and airborne particulates to
I   more common practices.  The   acceptable levels.
most    used    method    for  Notable Features:  This process highlights the success of a
controlling cumulative impacts  cooperative approach that is often needed to control cumulative
is through the use of permits  impacts.  Other keys to its success were: public support and
                                   acceptance measurable impacts with clearly identifiable causes,
                                   political acceptance and willingness to confront the problem,
This is followed closely by or  identified funding to fix the road dust problem, and enforcement of
used   in   conjunction   with  the ordinance.
coordination     among       the
applicant, other agencies, or
task forces.  A rough ranking of the actions used by agencies and districts in controlling
cumulative impacts, based on frequency of response in Questions 4c and 8, includes the
following:

*  Permit Stipulations/Permitting - Mitigation and minimization, often done through
    permit stipulations or physical/engineering changes in the design
*  Work with Agency, Applicant, and/or Task Force - This item was used frequently with
    other measures. Cooperating and helping an applicant was often deemed successful as
    opposed to being combative.
*  No  Formal Process - While respondents often listed methods  that they used in
    controlling cumulative impacts many indicated that there is no formal process or that
    the methods were not applied specifically to cumulative impacts.
*  Amendments to Policy or Plan Documents.
:  Education - Making the issue known to the public or other agencies.
ï¿½ Enforcement of Regulations.





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                                                                Cumulative Impacts in Alaska
                                                                        Chapter 4.0 Findings

*  Monitoring or Documentation of the Problem. Monitoring was used much more as an
   identification and consideration technique.
*  Land sale or Eminent Domain. Buying the land or taking over management of a
   facility.
*  Limitation of Access to Resource at Risk. This is often done through permit or
   licensing restrictions.
While several respondents indicated that these last two techniques are very effective, they
                                                            are not widely used because of
                                                            a lack of funding or political
                                                            support.
     Site- Streams on the
     Seward Peninsula
                                             SewardPeisula    One  of the main ways  that
                                                 , ?.       impacts   are  controlled   is
 Cumulative Impact: Each year a bit more stream habitat is lost  through permit processes that
 due to channelization and erosion: from- in-stream vehicle travel,  lead to mitigation of project
 mining operations: and road: building. This reduces the rearing  impacts.  Nearly every agency
 capacity of streams for anadromous and resident fish.       and district has some
 Steps-:to Address: it: A series of reports by private consultants
 and :agencies, including: ten years of on-the-ground observation  permit process that works in a
 helped identify the problem, which was confirmed through  similar  manner,  from  local
 specific study which included monitoring the density of fish  conditional  use  permits,  to
 populations in disturbed and undisturbed streams.           each agency's permits, to the
 Notable Features: The measures used to control the cumulative  consistency  review  process.
 impacts have been exemplary. Steps taken or planned include:                                               I
 public education through radio and newspaper spots, road  In  general,   project   mod-
 maintenance worker training which increased construction crew  ifications    and    mitigation
 awareness. of the: resources at risk, increased presence and  measures   occur   during   a
 enforcement, and-cooperative agency, industry, high school, and  project's    review    period.
 loal civic:: group projects: which have turned materials sites into These mitigation measures are
 fisheries enhancements.
                                                            often   decided   upon    by
working with the applicant and coordinating with the other agencies involved. The
mitigation measures are then usually included as a permit stipulation on the authorization.
According to respondents, such stipulations are most effective when they are linked clearly
to the project impacts and when they are, in fact, enforceable.  Problems with using
stipulations tend to be the lack of follow through, due to time and funding constraints, to
ensure that they are being met.  Therefore, there is not always evidence that these
measures actually control cumulative impacts nor are there always sufficient resources to
ensure that the mitigation measures are employed and enforced.

Respondents  often  indicated  the  importance  of monitoring  and  field presence  in
controlling cumulative impacts but usually reported they would like to accomplish more
of this but do not due to insufficient resources.  Many respondents indicated that there is
not enough funding or staff time to allow them to know if methods are successful on the
ground. These resource limitations are discussed further in section 4.5.






                                            4-13





                                                            Cumulative Impacts in Alaska
                                                                    Chapter 4.0 Findings

4.5 Obstacles and Difficulties

The existence of obstacles makes effective cumulative impact assessment and control
difficult. A lack of obstacles would indicate that cumulative impacts are being addressed
or, at a minimum, are not impeded from success. Obstacles to addressing cumulative
impacts were identified in Questions 9 and 10 of the survey.


                                Figure 4.1
               Obstacles Percieved by Respondents in
                    Addressing Cumulative Impacts


                                  # of Respondents
                  0           5           10           15          20

   Lack of Public/Political _ 18
       Support

            Lack of $                  'S  17


         Lack of Time     __ M                                 17


       Lack of Authority .i                               15

        Lack of
   Planning/Coordination

         Lack of
     Defintion/Guidance                       10

        Lack of Public
          Education

     Cumulative Impacts -  . ..~ï¿½...    ..
      not Addressed

      Lack of Technical               7
          Ability

              Other                6


     Lack of Information    H i     6




Questions 9: Respondents were first asked the open-ended question: "What obstacles or
difficulties, if any, do you face in identifying, considering, or controlling cumulative
impacts?" Figure 4.1 indicates the coded categories of responses for all those answering
the question. It should be noted that many people provided more than one answer and


                                         4-14




                                                            Cumulative Impacts in A laskcaI
                                                                   Chapter 4.0 Findings

thus the total number of responses is greater than 70. This question is closely related toI
Question 10 which asked a closed question with a list of obstacles from which respondents
could choose. The open-ended question, however, provides slightly different information
because the responses are not prompted, resulting in a more "pure"~ picture of what
respondents perceive as key obstacles. Moreover, a comparison of the two questions
enables us to gauge whether the list that was developed before the interviews missed any
potential obstacles

Interestingly, the top four responses al point to a lack of recognition and acceptance ofI
cumulative impacts as a problem by the state policy makers and leaders. While it was
clear that respondents felt there are cumulative impact problems around the state (as
evidenced by Appendix D). commitment by top-level management and policy makers inI
the state in addressing the problems is lacking. This is reflected in a lack of funding,
political/public support, staff devoted to the issue, and authority, all of which were
identified as obstacles by respondents.  If cumulative impacts were acknowledged as ani
important concern by state government, there would likely be money and staff allocated to
address cumulative impacts and legislation to provide stronger authority to back up that
acknowledgment.
Question 10. Following the open-ended question, a closed question was asked which
required respondents to identify obstacles from a list of potential obstacles devised by
HDR and the management team. This list of obstacles is, in essence, a list of components
necessary for successfully addressing cumulative impacts.   For  example,  adequate
direction, political support, funding, information, experience, and so on, are all deemed
important components of an effective program. If a significant number of practitioners
believe that obstacles to these components exist, this indicates that the success of currentI
efforts is questionable. The list from which respondents could choose included.


    *  Inadequate direction, guidance, or tools with which to address cumulative impacts.
    *  Lack of political or institutional support for doing so.
    *  Insufficient time to pay attention to cumulative impacts.I
    *  Insufficient funds to assess and evaluate cumulative impacts.
    *  Insufficient site-specific information (such as baseline data) about resources at risk.
    *  Insufficient information to determine whether a cumulative impact will beI
       significant.
    *  Inadequate experience to address cumulative impacts.
    *  The absence of a definition of "cumulative impacts" established in regulation.
    *  Limited authority to address cumulative impacts, due to land ownership.








                                         4-15





                                                                                Cumulative Impacts in Alaska
                                                                                        Chapter 4.0 Findings

                        Cumulative Impacts- in Brief                    It should  be  noted  that  the
                                                                          closed list of obstacle choices
                                                             3  :~Iin lï¿½Iprovided to respondents closely
                  Site--.Uyak Bay,                                       matched    the    coded    list
                                                             Kda Isan ;  7    developed   from   the  survey
           X I                  :                                        responses in Question 9.  This
           Cumulative Impact: A  land- distribution program has made   would    indicate    that    the
           numerous.i:l:ots: available for development: of. residential and small
                                                                          responses obtained in Question
           lodge proeries. Thetlecalspublic has.'called iin: complaints about h responses obtained m Question
           increasing.:number:of people int':area:antt:thef fearof'intensive   10  are  representative  of  the
           privateownership on.prime:shorelines.of:thebay:  .            range  of likely responses  for
           Steps to: Address i: Based on complaints, public testimony and  this  question,  with  a  couple
           discussion at public meetings, the Kodiak Island Borough determined  exceptions.  Had "lack of public
           the concerns subject to Borough jurisdiction. The Borough issues
           permits for land use, but cannot has difficulty effectively enforcing  education" or "conflicting value
           permit regulations. The Assembly: asked the:Planning Department to  system"   been   provided   as
           look for:models and suggest ideas for dealing-with- the potential  closed question choices, those
           impacts.  The staff: did:: so, but: each: recommendation (such as  answers   would   likel   have
           minimum. lot sizes for rural:.areas): but trecommendations were not
           forared to the Assembly:'s byZ:                               received responses.
           Notabkl:Features.:Common obstacles are evident here, first a lack of
           concrete informationon real impacts and a lack of political consensus  Figure    4.2    indicates    the
           on how: to-consider a potential: cumulative- impact once it occurs.  frequencies of the responses to
           There is local polarity of opinion: on the level of  resource   each obstacle for aencies and
                                                                          each obstacle for agencies and
           development and protection.
                                                                          districts. It is important to note
           that these are the perceptions of the 70 practitioners that were interviewed. In general,
           agency and coastal districts do not have adequate staff or time to identify, consider, or
           control cumulative impacts. The obstacle that received the largest number of responses
           was "insufficient funding to assess and evaluate cumulative impacts with 74% of
           respondents identifying                                   Figure 4.2
           this item. Closely              Obstacles Perceived by Respondents
            following this was "a lack                 in Addressing Cumulative Impacts
            of information," with
            "insufficient site-specific
            information about                       __
            resources at risk" (49
            responses) and
            "insufficient information
            to determine whether a
3I~ ~ cumulative impact will be  u.
            significant" (48
            responses). These                     ,,_
            findings tend to indicate   ï¿½ nad:nlaue nrcc                          Imo.:
                                                                           to Acs..Signitii.c.ne:
            that there may be a lack                ak 0'Suppr                  n.lduatEpriencC
                                                          In fllfeicn  lTime
            of information to allow                                                    Lack of 'DctiniFonu-
                                                                                               l~lmalc//uthonlv
            respondents to make                                         D Inuuelil~lt Site Data  Duc oLanI.Owncrq]p
            assessments necessary to
            balance development and           Note: This figure differs from Figure 4.1 in that questions were posed as chlosed
                                              yesino questions. See discussion of Question 9.


                                                          4-16




                                                                 Cumulative Impacts in Alaska
                                                                         Chapter 4.0 Findings

protection of coastal resources. Certainly, there is seldom sufficient information available                     I
to examine all aspects of a project's cumulative impacts on coastal resources and uses.

Interestingly, over 40 respondents indicated as obstacles all of the choices except for
"inadequate experience to address cumulative impacts" and "limited authority to address
cumulative  impacts  due  to land ownership"  which  received  36  and  30  responses
respectively. The largest differences between agency and district responses was that
districts did not perceive lack of support, insufficient time, insufficient funds, or the lack of
a definition as obstacles at the                  Cumulative  Impactsin W    Brief 
same      rate     as     agency
respondents did.
                                      Site: Ship Creek, 
                                      Anchorage                                     A,
Overall, results to this question
do not indicate that cumulative
impacts are being successfully   Cumulative Impact: Ship Creek, like many of the Anchorage area                  3
                                   g  streams, is being affected by cumulative impacts. In Ship Creek the
addressed. On every one of the  impacts: from non-point source pollution running off military bases,
obstacles,  over  40%   of  the  golf courses, junkyards, and railroad property is impacting aquatic
respondents indicated that they  life, recreation, and drinking water.
face that obstacle.  In fact, on   Steps to:Address it. It was: determined that the site needed attention
                                   after Elmendorf Air Force Base and a junkyard were listed as
e0ght of the rne obstaclesp, over   superfund sites.  The Resource Conservation and Recovery Act
50%    of   the   respondents   (RCRA) required analysis and assessment Also, the fish hatchery
indicated that they  face  that  had an increase in plant life, indicating nutrient-rich water. A "Best
obstacle. While no attempt was   Technical Advisory Group" was formed to address the issues, and the
                                   creek was listed as an impaired water body. The most effective steps
                                   taken to control the problem have been education--simply making
rank the obstacles or to assess  responsible parties aware that their actions affect creek resources.
their severity, the fact that so  Notable Features: This process highlights some of the difficulty of
many   agency   and   district  working with a multitude of government entities in a complex,
respondents  perceive  such  a  bureaucratic environment.  The time frames for action under the
                                   various laws at the federal level are extremely varied and often
             hgh  umber of obstacles  s not  conflict. For example, "superfund sites under RCRA are on a 5 to 10
conducive    to    successfully  year schedule and the Comprehensive Environmental Response,
addressing cumulative impacts.   Compensation and Liability Act (CERCLA) schedule is too short. It
                                   is difficult to get federal agencies together because their timeframes
4.6  Techniques Used                  nfli

Question Ila: Respondents were asked a closed question that required them to indicate                            3
whether or not they used certain techniques to address problems associated with
cumulative impacts. Overall, the most used techniques were "apply your own professional
judgment" and "hold discussions internally." The techniques used by the largest number
of district respondents are "hold discussions internally" and "apply ,permit review
techniques," while the techniques used by the largest number of agencies are "hold
discussions internally" and "draw on  other agencies' activities, information  or staff
knowledge."

By  looking at the respondents' techniques identified by Questions 4 through 8 and
Question 11 on the survey (see section 4.3) it is possible to get a better picture of how



                                            4-17





                                                                        Cumulative Impacts in Alaska
                 1                                                             ~~~~~~~~~~~~~~~~~~~~~~Chapter 4.0 Findings
          techniques are used to address cumulative impacts. Section 4.4 indicates the techniques
          used for addressing cumulative impacts. Figure 4.3 depicts the number of people using
          that method.
          4.7 Successful and Unsuccessful Methods and Techniques

          Question lib: Respondents were asked to determine the techniques most successful in
          addressing cumulative impacts.   Overall, the respondents  indicated that the most
          successful process is an effective permit process. For this process to be effective, it must
          provide communication and coordination between agencies, involve the applicant in a
3        ~~cooperative learning process upfront, and be based on a sound plan with enforceable
          policies. Enforceable permit stipulations should be attached to the permit, and those
          stipulations should ensure that the activity will avoid, minimize, or mitigate the cumulative
3        ~~~impact. Finally, the project must be monitored and the stipulations enforced through field
          investigation.    This process, while viewed as the most effective, is not always
          accomplished because of the obstacles mentioned in section 4.5.

          The following is a list of the most successful techniques used by respondents, roughly
          ranked by frequency of response from a coding of Question I11 b. These techniques were
I       ~ ~seldom mentioned as working well in isolation, but in conjunction with the other
          techniques in the process described above, they are successful.

3         ~~~For each of these techniques, ten or more respondents indicated they are successful.

          :  Enforceable permit stipulations and permitting with intent to mitigate or limit impact
            0Coordination with applicant & agency internal discussions
          *  Enforceable policies/good planning
           *  Field presence
           *  Professional judgment
           0  Monitoring
1          *~~ Enforcement

          The following is the remainder of the techniques mentioned by respondents. Each of these

           techniques received mention by less than five respondents.
           0  Public education
I~           ~~~ Legal action
           *  Modification of policy
           :  Search of files
            0Limited access
           0  None
           a Cartographic techniques





          1                                        ~~~~~~~~~~~~~~~4-18




                                                                      Cumulative Impacts in Alaska
                                                                               Chapter 4.0 Findings

  *   Special studies
  *  Environmental indicators    Cumulative Impacts in Brief
  *   NEPA studies
  *   Local knowledge                    Site: Comstock Road             |
  *   Outside consultants                area,Haines

  To   review   all   responses
                                     TCmulative:Impact: Increasing residential development and lack
                                     regarding  successful  compliance with on-site: wastewater regulations have resulted
  techniques, see Appendix C,  in:-failing septic systems:: and increased concentrations of fecal
  Question l1 b.                     col'iform:1 bacterial.   Sawmill Creek, an anadromous creek.
                                     Increased concentrations of fecal coliform bacteria Development
      In question 1 Ic               outside city limits is not under city jurisdiction.
  respondents were asked which
              re s poniues wehad been  Steps to Address it: Water quality sampling and monitoring
  techniques had been                identified the problems.  The developments are outside city
  unsuccessful. The responses    limits, therefore not under city jurisdiction.  The city hired a
, to this question resulted not      consultant to write the "Sawmill Creek Management Plan", using
  so much in a list of techniques   ACMP funds. The plan maps and describes sensitive areas and
  that do not work but rather in   recommends measures to prevent further cumulative impacts.
  cautions or tips for properly      Additional educational' efforts: have reached property owners and
                                     other users as to the valuable resources and permit procedures
  using certain techniques and       thatneed to be followed
  criticisms. Table 4-1
  highlights respondents'            Notable Features:. The special management plan approach has
  criticisms and tips. Many          been effective in addressing an area outside city jurisdiction. No
  respondents indicated that all   significant illegal activity has occurred in the area, which is
  techniques were useful,            presumed to be due to the raised public awareness from the
                          indicating things like: "None  planning and education efforts.
  indicating things like: "None
  were unsuccessful-they are all useful in their own way," or "They all work to some
  extent." Respondents noted that if improperly used or applied they could be ineffective or
  even backfire. The following table summarizes the comments on how techniques had been
  unsuccessful for respondent's efforts to address cumulative impacts. These limitations
  could be addressed in the next steps of the state's cumulative impact strategy.



















                                                 4-19






                                                                                        Cumulative Impacts in Alaska
                                                                                                  Chapter 4.0 Findings



                                                            Table 4-1
                           How Techniques Have Been Unsuccessful (Question lc)

Enforceable         Policies are not enforceable; establishment takes too long; establishing enforceable policies is ineffective
policies           because the lead planning agency for the state has become politicized-they've forgotten public trust
                   doctrine in public planning process; the regulatory process only works if there is follow through.
                   Cannot tell whether or not the permit process works, because of lack of field monitoring and site
                   information; limited annual travel budget and too many remote sites to visit.
Enforcement        Avoid hard-core enforcement-try to work with people before problems develop; starting off immediately
                   with enforcement doesn't work-it is too confrontational; to have good enforcement you need someone with
                   more of a state trooper mentality; enforcement is difficult, have no environmental 'cop'; the regulatory
                   process only works if there is follow through.
Change Policy      Policy changes not used; Policy changes don't work well except for identifying potential cumulative impacts:
                   do not work until some issue is driving the change: when regulations or requirements are lacking, protection
                   against cumulative impacts is less effective/successful.
Agency             Going to other agencies for cooperation because they view an AMSA as a preservation document where it
coordination       should allow "balanced development." The institutional mind set is making it more difficult than it needs to
                   be. Communications with other agencies - because of different agendas, politics, etc.; The agency reviews
                   aren't always consistent (interpretations of regulations are different). Getting local government involved
                   because of local politics; Relying on agencies doesn't work because it depends on how interested that
                   particular agency is in addressing the cumulative impacts; Internal discussions not used like they could be to
                   address cumulative impacts; relying on agencies doesn't work because they do not know how to address
                   cumulative impacts; Using agency information is not always useful because it is a data "dump" with no
                   analysis/conclusions; efforts to be big brother, know what's best for you is contrary to attitudes of Alaskans:
                   also not protecting fish and wildlife resources even when the policies are stated in their own DNR plans:
                   with the Corps' 404 program, there is no successful protocol for evaluating Cl on watershed basis, this led to
                   the national policy on "no net loss" of wetlands and the outcome has not been good: success of techniques
                   has not been determined yet, for example: one agency has placed a moratorium on an activity in order to
                   study it but no results are out after 3-4 years; techniques to weigh [consider] different values are not
                   effective, because of the subjective judgment involved - and fights - about what outcome is better for most
                   people (this occurs when some people who depend on subsistence vs. others who are big business interests
                   have a difference in values).
Education          After-the-fact education ("re-active education") - once opinion on a project is formed it is difficult to change
                   people's minds; Education [about the need to deal with cumulative impacts] has been slow to develop, once
                   people understand, they want to do something about them, but until then it is just confusion:
                   Education [about the need to deal with CIs] has been slow, but until then it is just confusion.
Federal            Forest Service planning - because they don't take into consideration local comment: with the Corps' 404
Planning           program, there is no successful protocol for evaluating cumulative impacts on watershed basis, this led to the
                   national policy on "no net loss" of wetlands and the outcome has not been good.
Monitoring         In monitoring timber harvest techniques operators "perceived" the monitoring as an evaluation of staff.
                    Monitoring and field presence only work well if you have the staffing and funding; Monitoring information
                   does not always include analysis and does not always draw a consistent "picture" from which to evaluate
                   changes over time; Lack of analysis and "dumping" data into agency files does not constitute monitoring:
                    Monitoring and enforcement follow-through is weak, as with so many agency programs. due to limited staff
                   resources; Front end work is emphasized -planning, permitting, but don't have follow through: There are
                    things we wish we were doing but don't have the funds for (e.g. monitoring).
Planning           Long-term language and interpretation is not always effective or specific enough.
Special Studies    Study results will be used or ignored as it suits the various public constituencies; Receiving a 2 inch thick
                   document from somewhere else is not helpful; statistics / hard evidence are not conclusive proof that a
                   concern is 'legitimate'.
NEPA               NEPA over complicated and based on inaccurate models, enforced based on philosophy not science, too
                   expensive; NEPA is only valuable in early stages.
Consistency        Consistency reviews do not work; It has been ineffective to try to find a project inconsistent based on an
Reviews            enforceable policy regarding CIs, because districts or other entities overturned finding: It involves other
                   problems like which agency should carry a requirement: the elevation process in the ACMP is not effective
                   due to the prejudices of the people holding those positions - inevitably there will be a failure in the process,
                   and elevation also leads to lawsuits: when an applicant doesn't want to cooperate it is hard because unless



                                                              4-20




                                                                                 Cumulative Impacts in Alaska 
                                                                                          Chapter 4.0 Findings

                 Ted                                             ~~~~~~~~~~~~~Criticism 
                 the political will is there, we can't use the rest of the 'control' tools, also we try to treat everyone the same.
                 but it is not possible due to political directives to be more lenient to some.
Field Presence     Because there is not enough staff-, conducting f ield surveys and measuring impacts depend on staffing andI
                  funding; limited annual travel budget and too many remote sites to visit.
Cartographic       Mapping techniques are limited in availability.
Techniques
Establishing       Thresholds and standards difficult to enforce; good tools are not available to make a "'cut" in incrementalI
Thresholds         residential development activities; the Borough Assembly did not implement techniques proposed to them by
                  the planning staff, therefore there are still limitations on local regulatory authorities.
Permit             Stipulations only work well if you monitor compliance. Good tools are not available to make a "~cut" inI
Stipulations       incremental residential development activities; assembly did not implement techniques proposed to them by
                  planning staff on a conditional use permit, therefore local regulatory authorities are still limited.
Mitigation         Being forced into developing mitigation when we have no information - the mitigation ends up being way off
                  target, with good information and specific studies we would be able to sugge~st pgood, effective mitigation.
Limiting Access   Limiting access and thresholds would be effective if we did it but the agency mitigates and minimizes rather
                  than stopping cumulative impacts, thus the impacts are allowed and still adding up.

     Respondents also made general comments regarding their inability to spend time on
     addressing cumulative impacts, and therefore they were not prepared to comment on
     which techniques were ineffective. Similarly, comments were made that it is difficult to3
     know whether a particular technique is effective, as there is inadequate time or resources
     to find out whether the technique worked.

















                                                                           4-21~~~~~~







      1                              ~~~~~5.0 Recommendations


          Introduction

I         ~~~Chapter 3.0 put forth a set of general criteria necessary to successfully address cumulative
          impacts and described how those criteria were incorporated into the survey. Chapter 4.0
          presented findings from the interviews with respondents and gauged the adequacy of the
          methods being used to address cumulative impacts. In that chapter, analysis indicated that
          respondents clearly feel that there are cumulative impact problems occuring around the
          state, and that efforts to address them are not working well. This chapter discusses
          recommendations based on the findings from Chapter 4.0 to remedy identified
          inadequacies in how agencies and districts are addressing cumulative impacts.

          The recommendations discussed in this chapter are to:

          *  Establish a top-level commitment  to addressing cumulative  impacts  in Alaska,
              supported by practitioners and the public statewide;
          9  Pursue  more  explicit  authority  to  address  cumulative  impacts  in  legislation,
I          ~ ~~~regulations, and/or policy;
          *  Develop more form-alized implementation guidance based on established authorities;
          :  Establish a cumulative impact definition in regulation;
I   ~       ~ ~~ Provide training for those responsible for addressing cumulative impacts, particularly
              small coastal districts, to assist them in identifying, considering and controlling
              cumulative impacts;
N~            ~~~ Provide adequate resources (including funding and dedicated staff time);
            0Develop a public education program; and
            *Develop better sources of information and information sharing among agencies and
              districts.

          Each of these recommendations is now discussed in turn.


          Recommendation: Establish a top-level commitment to addressing cumulative
          impacts in Alaska, supported by practitioners and the public statewide.

I         ~~All the recommendations  in this chapter would  be best served  if preceded  by a
          commitment at the top-level of state government and among coastal policy makers in the
          state (for example, the Coastal Policy Council) that cumulative impacts are an important
I       ~ ~public policy issue for Alaska and will be addressed.  With such a commitment, many
          other steps and commitments are possible statewide. Without such a commitment, other
          steps and commitments may be made, but without firm legal standing, procedural support,
          or longevity. Such a top-level commitment must be based on widespread support from
          practitioners, and from their public constituents. Numerous repondents commented that




                                                              Cumulative Impacts in Alaska
                                                             Chapter 5.0 Recommendations

cumulative impact problems are not well recognized by top-level officials in Alaska.
Agency and district staff recognize the severity of problems, but are not supported by their
managers in addressing the problems. Respondents recommend that the State should
make it a priority to address cumulative impacts. For the State to make this commitment
however, district respondents in particular believe local and regional flexibility should be
retained, rather than a simple centralized state approach. This is consistent with the local
emphasis in the ACMP overall.

To develop widespread support, the leaders of the current State Cumulative Impacts
             Wha-:Re-p:ndenti ........d         :l    strategy need to continue efforts
                                                       to keep cumulative impacts in the
 Commitment - Respondents indicated that State and coastal  eye    of   the   public,   the
 policy makers need to admit that there is a cumulative impact  practitioners   and   the  policy
 problem and to make solving that problem a priority. The agency  makers, with focus and concrete
 staff know cumulative impacts are occurring but to address them
 they need more push from higher levels.  Among the needs  results. The "cumulative impact
 identified by respondents are:                         problem" and its consequences
                                                       and costs to the state must be
 *  A mandate                                           clear, or else no changes will
 *  Better mission
                                                       come about.
 *  Defined support

 In fact it was even suggested that agencies with the responsibility  The state has already shown the
 to address cumulative impacts are told not to do it from upper  federal  government  that
 levels of management.                                  cumulative   impacts   are   a
                                                       significant  public  policy  issue
deserving of study and action, by winning Section 309 funding from the federal Office of
Coastal Resource Management. Now, the results of this survey study could be forwarded
to the Governor, agency commissioners and members of the Coastal Policy Council for
their consideration and action. Another technique that could be effective in establishing
top-level commitment would be to have agency heads, members of the Coastal Policy
Council, legislators, and other coastal policy makers involved in the next phase of
cumulative impact study in Alaska, the "Group Discussions" Section 309 project. The
group discussions forum would provide an excellent opportunity for policy makers to
grasp the problem of cumulative impacts in Alaska.

An effective structure to addressing the programmatic problems with cumulative impacts
might be strategic planning. Strategic planning is a process that can help an organization
create and coalesce around a future vision, and devise strategies for implementing that
vision. Among the benefits that can result from a strategic planning process are to clarify
future direction, create a rational and justifiable basis for decision-making, making
decisions and policy across levels and functions in an organization, solving major
organizational problems, and most importantly building consensus.  The first step in a
strategic planning process is, however, to get agreement on the need to plan. Thus, two
recommended goals of the Group Discussion project should be to develop an upper-level
acknowledgment of cumulative impacts as a statewide problem and get a commitment to



                                           5-2





                                                                   Cumulative Impacts in Alaska
                                                                   Chapter 5.0 Recommendations

embark on a strategic planning process for developing a unified approach to addressing
cumulative impacts.

Recommendation: Pursue more explicit authority to address cumulative impacts in
legislation, regulations, and / or policy.

One   of   the   most   important  la                        :tiiRi  s its;..a.   mend
components        to     successfully   Authority - In general, respondents recommended that better
addressing cumulative impacts  is  authority for addressing cumulative impacts be developed.
strong, clear authority or direction.   However, there was less agreement as to what form of authority
                                        would work best.   Among  the means  for strengthening
Survey findings indicate that most cumulative impact authorities was:
respondents either are unaware of
any direction or that the direction    ï¿½  Statutes and Regulations  - Respondents recommended
is   weak.       In   fact,   several        everything from new statues and regulations to modifying
I  respondents  indicated  that  they        the existing regulations, to simply enforcing what is
                                            currently in place. Generally, respondents recognized the
                                            need  to  have  regulations  that  are  culturally  and
cumulative impacts.   As  a result           environmentally sensitive because blanket regulations do
there   is   not   a   widespread            not fit every place.
concerted effort made to identify,   '   Policies - Many respondents indicated the need for a clear
consider,  or  control  cumulative           policy regarding cumulative impacts from their department
                                            indicating that cumulative impacts will be addressed. In
impacts.                                     addition,  policies  in coastal  programs  need  to be
                                            enforceable.
Until there is a clear authority at   ï¿½   Enforcement - Respondents indicated that policies and
the state and district levels, steps         regulations had to be enforceable and that enforcement
                                            capabilities would be required:
to address cumulative impacts will
remain ad hoc.                           The types of statutes, regulations, and policy authorities that
                                        were suggested to be used or strengthened ran the gambit from
Opinions  vary  on  the  type  and   ACMP statutes and regulations, to Title 16, to greater use of
source  of authority  or direction   local district plans, and local government with planning and
                                        zoning authorities
needed.        Some    respondents
indicated that they would like to see strengthened legislation, others indicated current
legislation would work with strengthened regulation, others indicated that participation
should be voluntary. While the ACMP program regulations do indicate that cumulative'
impacts are among the "uses of direct and significant impact" which are to be addressed by
the program, this is not widely recognized by respondents.  Furthermore, there is little else
that respondents are aware of which provides them the authority to take adequate steps in
addressing cumulative impacts.

What is clear is that until agencies and districts are clearly directed to address cumulative
impacts, efforts will vary greatly, and steps taken will be adequate only in isolated cases.








                                               5-3




                                                               Cumulative Impacts in Alaska
                                                               Chapter 5.0 Recommendations

Recommendation:   Develop more formalized implementation guidance based on
established authorities.

Very little to no guidance has been provided to this sample of agencies and districts on
how to address cumulative impacts. Thus, even if there is strong state direction, there is
little to guide practitioners in steps to address a cumulative impact. In the absence of
legislation or regulation specific to addressing cumulative impacts, internal guidance could
be developed under the existing authorities. This recommendation could be implemented
   W gi? i.Ci!i:{i!iiif ;piiio-n   Recommi                 by the Coastal Policy Council,
 Guidance - Respondents overwhelming supported the idea of  given   the   Council's   broad
 specific guidance on how to address cumulative impacts. There are  representation   of   agencies,
 several technical questions frequently cited by respondents as areas  districts and the public. Such
 in which they required additional guidance or policy direction.  guidance should be flexible in
 Many respondents indicated a format for the guidance. In general it
                                                          its application and usable by a
 was recognized that a process or procedure was needed, such as a
 step-by-step process or checklist. Respondents recommended that  wide  range  of  practitioners.
 guidelines be procedural and not force conclusions and that they be  Establishing  checklists,
 flexible to local conditions. Among questions on which guidance is  thresholds, and procedures for
 needed are:
 n       eeded are:                                         cooperative   approaches    to
 *  What should be measured?
 *  What cumulative impacts are occurring?                  addressing  the  impacts  are
 *  How far back should you look to start adding impacts?   some of the suggestions made
 *   How do you avoid cumulative impacts first?             by respondents.  The methods
 *  What are the standards on the minimum retention for habitat?    that people  currently  use  to
 *  What should be key elements to look for?                identify cumulative impacts are
 *  At what point (threshold) does an activity or use create a
     cumulative impact?                                     very informal, mostly relying on
 *  At what point does a cumulative impact become significant?  public   complaints        or
 *  Where do you stop adding things in (i.e. within what  professional judgment.   While
     geographic area should impacts be added). For example, do  these   techniques   may   be
     you consider the tributary of the stream the entire drainage or  effective in initially identifying
     the entire ocean system).
                                                          potential  cumulative  impacts,
informal methods are not as effective in considering or controlling cumulative impacts.
More formal procedures should be developed and adopted for these steps.  Specific
procedures and tools were proposed in the report entitled, Cumulative and Secondary
Impacts and the Alaska Coastal Management Program (DNR, 1994). For example, in
the recommendation chapter a "Methodology for Addressing Cumulative and Secondary
Impacts" is presented.  This methodology presents a structured series of questions for
evaluating, making decisions about, and implementing controls for cumulative impacts.
Elements  from  this methodology  could  be adopted  to provide  structure  to ways
cumulative impacts are currently addressed.   The recommendations from this report
should be reviewed to determine which ones would be feasible for implementation once
the commitment and authority recommendations above have been met.

One issue that needs further resolution is the degree to which guidance should be
consistent statewide in order to effectively address cumulative  impacts.   Consistent
guidance may be advantageous from a legal liability standpoint, but may not be practical



                                           5-4





                                                               Cumulative Impacts in Alaska
                                                              Chapter 5.0 Recommendations

for implementation. Respondents called for clearer guidance, but also acknowledged the
difficulty of developing guidance that would be workable statewide.   There were
comments on the merits of consistency, as well as the importance of local interpretation
and flexibility. In addition, as was indicated in Section 4.2, the more exact the guidance
was on providing a specific process or standards, the more successful it was. Thus, State
standards may be necessary at a general level to ensure consistency, but specifics may best
be left to local flexibility.

Another thorny issue in addressing cumulative impacts is the concept of thresholds. Many
respondents would like thresholds to be in place to guide their evaluation and decision
making about how much impact is too much. A threshold can be an established limit
above  which  additional  impact  is unacceptable,  or acceptable  only  under certain
conditions. Thresholds involve at least two difficult issues: measurement of change and
standards for the results of change. Certain impacts, such as waste discharges from a pipe,
are more measurable than others, such as how subsistence uses are affected by a new
mining operation. But established standards for degrees of acceptable change are difficult
and uncommon in both cases. Thresholds are not simply technical; they need to be
adopted with adequate public involvement. With many issues, thresholds should not be
developed solely at the state level. They may best be developed on a local, district or
watershed basis. Amendments to coastal district plans could be a logical outcome of the
development and adoption of thresholds. Further work is needed on these issues.

A current 309 project is funding a study with the Sitka Coastal District to research and
establish coastal indicators that would lead to a benchmark system. Under this system
each indicator would have a specific measurement with short-term and long-term goals for
each indicator. Use of coastal indicators with benchmarks for improvment may prove to
be an effective means for dealing with thresholds.


Recommendation: Establish a cumulative impact definition in regulation.

A definition is an essential component to any legislation, regulation, policy direction. or
guidance. It is important that all practitioners be familiar with the definition and are
comfortable using it. This is not to say that criteria for determining when a cumulative
impact is reached should be identical throughout the state, because there are
some  good  arguments  that I                WhatiRespondents Recommend              l
regional or local conditions  Definition - Respondents indicated the need to have a working
should be weighted heavily.  (user friendly) definition of what cumulative impacts are. How
One respondent urged that the  this definition would be established varied. Some recommended
                                it be in regulation, others indicated that districts need their own
                                definitions. Some respondents suggested that the definitiion be
allowed different definitions,  measurable, have standards, and specific criteria on which to
rather than be forced into a  judge impacts.
homogeneous state definition.
A common regulatory definition would, however, provide a central framework for all



                                           5-5




                                                            Cumulative Impacts in AlaskaI
                                                            Chapter 5.0 Recommendations

practitioners to work with. Survey Findings indicate that most practitioners (64%) have aI
good  working  knowledge  of what  cumulative  impacts are.           However,  until all
practitioners understand what they are and can apply the definition, adequate steps are not
likely be employed statewide in addressing cumulative impacts.
Recommendation:            Provide                       RpOdUSecmnd
         trainng fo thos  respnsibl  forTraining Respondents indicated the need for specific training
addressing  cumulative  impacts,   on evaluation and assessment of cumulative impacts. Same of
particularly     small      coastal  the suggestions included:3
districts,  to  assist  them   in a    "Rainbow" type training;
identifying,   considering   and   ,  A one day training or work session in conjunction with the
controlling cumulative impacts.           annual conference;
                                      4Joint training for state and fe~deral agencies , 
                                      aTraining out in the districts to educate local leaders on the
Identifying,    considering    and        regulations.
controlling cumulative impacts is,I
in many cases very technical political.   To  be adequately conducting the steps in
addressing cumulative impacts will require training. Particularly in those interviews in
which the respondent did not have a working definition of  cumulative impacts, it wasU
clear that training was needed. Moreover, in smaller coastal districts without a Mul-time
planner, those implementing ACMP regulations are often city clerks, city managers, or
mayors, people without formal training in environmental, economic, social, or culturalI
assessment. Providing these practitioners with working skills in addressing cumulative
impacts is necessary for them to adequately employ effective methods.3

Recommendation. Provide adequate resources, including funding and dedicated
staff time.

To expect steps in addressing cumulative impacts to be successful will require adequate
support. But not simply political support in the form of new legislation and regulations.
The political support must be backed up with the resources, such as staff, staff time, and
funding necessary to adequately address cumulative impacts. Survey findings clearly
indicate that staff time and funding are currently inadequate for agencies and districts to3
address cumulative impacts. This lack of resources devoted to cumulative impacts
indicates  that  adequate  steps  are  not  being  taken.    Moreover,  any  additional
responsibilities placed on agency personnel or local coastal districts will have to beI
adequately funded in order to have any real hope that adequate steps will be taken to
address cumulative impacts.

Due to scarce resources at the state and local levels there is a need to identify additional
resources and cost-effective techniques. It is difficult to identify such resources or say
what is cost-effective until it is clear what has to be done (that is, until there is aI
commitment, authority, and guidance for practitioners to follow). Most of the
recommendations  put forth in this report are cost-efffective strategies for getting

cumulative impacts to be addressed and for improving the way they are addressed. While


                                         5-6





                                                                    Cumulative Impacts in Alaska
                                                                   Chapter 5.0 Recommendations

it may be cost-effect for the State to enact these recommendations, once they enacted
State and district practitioners will be required to do more than they currently are. It will
not be possible to go from not addressing cumulative impacts to addressing them without
incurring costs. Some cost-effective techniques or methods include photo documentation
of change over time in a given site, and requiring specific, documented information
necessary to address cumulative impacts to be supplied by applicants during the permit
process. Examples of the kinds of information that could be supplied by applicants include
accurate mapping, resource surveys, and a site plan.

Respondents   were  not  asked                      hat  es';ieSe!! : R ---c:
specifically   where    additional   . Resources:  Having  adequate  resources  to address
funding  should  come  from,  or   cumulative  impacts  was  identified  as  an  important
which   techniques   are   cost   recommendation. As could be expected, funding was one of
                                      the most needed resources.   Essentially,  respondents
                                      indicated they are just getting by now, to do anything more
were   made.        According   to   with cumulative impact will require additional funding.
respondents,       funding       for   Many of the comments can be characterized by this
cumulative impacts in the future   statement by one of the respondents: "Cumulative impacts
could  be  decentralized,  spent   are important but any new regulations must take into
                              - -  -  account limited staff and time. The resources mentioned as
"closer  to  the  problem  sites"   most needed include:
(rather    than    on    statewide   .   Time
studies,),    and      on      local   *   Staff
environmental           assessment.   *   Money
Permit application fees could be           Bettertools
used  as  a  means  to  pay  for   Many  respondents had very specific recommendations
cumulative impact assessment.          regarding funding over and above simply having more.
                                      Some of the recommendations include the following.
Recommendation:   Develop  a               Need ACMP grant funding to do own environmental
        public education program           studies in the region.
                                      public  Money should be spent closer to the problem sites.
                                      ï¿½ Small communities, can barely afford the basics much
The       issues       surrounding         less "extras" like studies or investigations.
cumulative impacts require value   ï¿½   Can't expect districts to do all of this work, especially
judgments.   Often  what  is an             with budget cuts.
                                      ï¿½ Use fees to increase funding to fund more 401 certified
unacceptable impact to one is not          staffers.
necessarily an impact to another.   .   Would like money to hire local environmental monitors.
Causing,  or  exacerbating  this   .   Funding so communities could obtain the professional
problem    is   the   fact   that          expertise or technical assistance they need.
cumulative impacts are often not   *   Funding for enforcement.
readily apparent, are difficult to   *   Project proponents should pay for the cumulative impact
                                          assessment work.
measure, or are based on
technical assessments which are difficult








                                              5-7




                                                             Cumulative Impacts in AlaskaI
                                                             Chapter 5.0 Recommendations

           Whaf-Res odenta.Recommend.:P i               to understand or in dispute.  Thus,I
*Public education: Several respondents suggested that public   cumulative  impact  issues can  be
education was needed. Because it is often difficult to determine   either very divisive, not accepted
when a serices of impacts becomes a cumulative impact and, in  by lay people, or must  be over-I
cases where determination involve a value judgement, betterstdeatgatxpneo"rv"
public education is needed to make the science and decisionstdeatgatxpneo"rv"
making process more understandable.  It was suggested that  that there is a problem.   Public
better public education can help to lessen the controversy that can education and citizen participation
be involved in addressing cumulative impacts.  Among- the  are important tools which can be
recommendations and considerations to keep in mind for public  effectively used to foster agreement
education are:   oanisu.Bprvdnal
*   Better education is needed for people to see successes notona ise.B           prvdgal
   just the failures-,                                   potentially  affected  interests with
  ï¿½ People need to have an open mind regarding  cumulative   information   on   a   cumulativeI
   impacts because they are dependent on the person and their  impact,  its  potential  costs  and
   philosophy - thus feelings shape the cumulative impact  potential   solutions,   appropriate
   discussion;                                    opin a emr aiyselected
ï¿½ The shortfall is that coastal districts are not realizing that  otoscnb   oeesl 
   cumulative impacts exist - in the search for economic   and accepted.
   development cumulative impacts have been ignored-,
 ï¿½ The Kenai River 309 project tried to address all issues thenI
   groups either warped or ignored the findings.

Recommendation: Develop better sources of information and information sharingI
among agencies and districts.

Many respondents indicated that lack of information is frequently an obstacle in their workI
on cumulative impacts. If this is to be remedied, better sources of information, improved
organization of information, and improved inform-ation sharing between agencies and local
jurisdictions is needed. Examples of information include mapping of impacted areas,
tracking of permits, and access to site/resource information from other agencies in the
affected area.

In regard to better sources, inform-ation needs to be more site-specific, more scientific
where possible, and baseline or historical information is needed. Several respondents'
called for recognition of local knowledge, which is so important in areas where local
knowledge is much more abundant (and often more highly valued) than is scientific
assessment.I

To improve the organization of information, watersheds or river systems as management
units make more sense in some locations, as opposed to political jurisdictions.  Also ,                   
standardized documentation systems used over the long-term would improve the ease of
adding or using information. Mapping of impacts makes sense to increase the utility of
site-specific information. Permitted activities and their impacts should be documented andI
mapped.






                                                                    Cumulative Impacts in Alaska
                                                                    Chapter 5.0 Recommendations

To improve access to information, agency databases could be more fully utilized.
Coordination between agencies and districts could be increased to improve access to and
use of agency databases. One way information and expertise could be shared better would
be to consolidate the number  of required   W;ltoso:ndetsrenme                                               [
permits into one which would require multi-   Information - Many respondents recommended the need for
agency review. Another method would be to   better more complete information in addressing cumulative
require permit reporting 'to a coordinating   impacts. The following list indicates some of the information
                                                   ieeded:
agency  such as DGC.    The  coordinating
                                                   a   Site histories - to learn what has occurred on the ground
agency could track, compile, and map  the                and to determine what happens incrementally;
information.  This technique is successfully   a  Data (particularly in communities);
used  in Oregon  to gauge  the cumulative   *   Baseline data;
effects of each individual county's land use   *   Monitoring data;
permitting.  Each county is required to file a   *   Practical information (in-the-field knowledge):
                                                   ï¿½   Need information on human carrying capacity, resource
yearly report of all land use permits to the             carrying capacity;
state planning agency.  The planning agency   .   Specific studies, in-depth studies in certain areas:
compiles the information and issues a report   *   Recognize experiential local knowledge and incorporate it
used to monitor the cumulative  change of                into decisions;
land use permitting by all the counties on the           Site-specific information;
                                                    *   Use agency files and incorporate information into decision-
state as a whole.                                        making process;
                                                        making process;
                                                    - Need a dynamic data collection system;
                                                    *   Information must gain ownership from the user groups and
Summary of Recommendations                               local boards;
                                                    *   Access to other agencies  successes  and  failures in
                                                        addressing CI (information from other agencies):
Several of the recommendations  advanced   .   Must use the data and there should be time to let it be
here have also been identified by at least two           absorbed and built on over years to see changes;
previous   reports   issued   on   cumulative   *   A mapping system (kept up to date);
impacts  (and  mentioned  in Chapter  2.0):   *   Must have more than academic information on cumulative
Cumulative and Secondary Impacts and the                 impacts in order for policy-makers to use it - for real
                                                        movement from policy makers, must put the information in
Alaska   Coastal   Management   Program                  a form that they can use.
(DNR, 1994) and Regulation of Cumulative   ï¿½  Need more work done on subtle indicators of biological
and  Secondary Impacts  in Alaska  (DGC,                 stress (such as enzyme changes).
1993)the DNR report and the DGC report.
Table 5.1 shows the recommendations common to these sources.
                                           Table 5.1
            Recommendations on Cumulative Impacts from Recent Reports
                                           HDRia    Surveys : Su    NR                DGC
                                           :  Analysis   :: Respondents   Report      Report
Commitment, Authority & Direction/                               /             /            ,/
Establish Definition/                                            / , ,/
Develop Guidance                                 /               /             /            /
Provide Training                                 /               /
Provide Adequate Resources                                       /             V/
Develop Public Education/                                        /
Improve Information                              //                             /            /



                                               5-9




                                                            Cumulative Impacts in Alaska 
                                                            Chapter 5.0 Recommendations


The above general recommendations have been developed independently from one
another, using different approaches than the survey approach used for this project. Wh-ile
the general recommendations are somewhat consistent, many discreet issues remain to be
resolved, such as whether authority should be strengthened via statutes, regulation and /
or policy, and how to Oro about establishing thresholds. Such questions should be dealt
with in the group discussion project of Alaska's Strategy on cumulative impacts, with a
wide audience of participants engaged. The current status of cumulative impacts practices
in Alaska has been investigated. If the State chooses to advance a program for addressingI
cumulative impacts in Alaska, the next steps can now focus on concrete decisions, actions,
and tools for successful implementation.

The recommendations in this chapter, and the findings presented in Chapter 4.0 form a
framework for addressing cumulative impacts at the state and coastal district levels. At
present, there is no concerted program to address cumulative impacts in Alaska. ToI
establish such a program, firm commitment from top-level officials (the Governor's Office,
State agency heads, and the Coastal Policy Council) would be needed and should be based
on broad-based support among practitioners and their local publics. Support for such anI
effort would be facilitated through strategic planning and public education.   Then
authorities would need to be more clearly delineated, such that legal and procedural
support would be established for all practitioners to use. Effective authority relies upon aI
recognized definition of cumulative impacts and guidance to carry out appropriate steps.
To carry out these steps, practitioners would need more training; adequate resources and
staffing; the ability to educate the public on the importance of cumulative impact
problems, consequences and solutions; and better information sources.   Until these
programmatic elements are corrected, efforts to address and control cumulative impacts
will continue as they are now, largely informal, ad hoc, and rarely effective, and the list of
cumultively impacted sites will continue to grow.









                                        References



Alaska Department of Natural Resources, Division of Land, Southcentral Regional Office. 1994.
"Cumulative and Secondary Impacts and the Alaska Coastal Management Program." Prepared by Rob
Walkinshaw.

Alaska Department of Fish and Game, Habitat and Restoration Division. 1994. "An Assessment of the
Cumulative Impacts of Development and Human Uses on Fish Habitat in the Kenai River." Prepared by
Gary S. Liepitz. Technical Report No. 94-6.

Alaska Department of Fish and Game, Habitat and Restoration Division.  1993.  "Non-regulatory
Mechanisms for Habitat Protection. Section 309 Grant Project: Assessment and Control of Cumulative
Impacts of Coastal Uses on Fish Habitat of the Kenai River." Prepared by Mark Fink, Celia Rozen, and
Glenn Seaman.

Alaska Office of the Governor, Division of Governmental Coordination.   1993.  "Regulation of
Cumulative and Secondary Impacts in Alaska." Prepared by Glenn Gray.

Bedford, Barbara L. and Eric M. Preston. 1988. "Developing the Scientific Basis for Assessing
Cumulative Effects of Wetland Loss and Degradation on Landscape Functions: Status, Perspectives, and
Prospects." In Environmental Manacement. Vol. 12, No. 5, pp. 751-771.

Dames and Moore. 1981. "Methodology for the Analysis of Cumulative Impacts of Corps Permit
Activities. Prepared for the U.S. Army Corps of Engineers.

Dickert, Thomas G. and Andrea E. Tuttle. 1985. Cumulative Impact Assessment in Environmental
Planning: A Coastal Wetland Watershed Example." In Environmental Imrnact Assessment Review 1985:
5:37-64. Elsevier Science Publishing Co., Inc..

E3 Consulting. 1994. "A Socioeconomic Assessment of Kenai River Fish Production on the Regional
Economy." Produced for the Kenai Peninsula Borough.

Irwin Frances and Barbara Rodes. 1990. "Making Decisions on Cumulative Environmental Impacts: A
Conceptual Framework." World Wildlife Fund, Washington, D.C.

Jon Isaacs and Associates, Resource Analysts, Louisa R. Moore, and Nancy Wainwright. 1994. "Kenai
River Fish Habitat Cumulative Impacts Project: A Report to the Policy Working Group and the Kenai
Peninsula Borough".

McCold, Lance and Jeremy Holman. 1995. "Cumulative Impacts in Environmental Assessments: How
Well Are They Considered?" In The Environmental Professional, Vol. 17, No. 1, March 1995.
Blackwell Science, Inc.

Smit, Barry and Harry Spaling. 1995. "Managing the EIA Process: Methods for Cumulative Effects
Assessment." In Environmental Impact Assessment Review, Vol. 15, No. I, January 1995. Elsevier
Science, Inc.



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            Appendix A    I
Introductory Letter From DGC to all Selected RespondentsI

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               a.~~~~~~~~~~~~~~~~~~N'  4bUr 

                                                                              TONY KNOWLES, GOVERNOR

      3                         ~~~~OFFICE OF TBE GOVERNOR
                           OFFICE OF MANAGEMENT AND BUDGET
                    DI VISION OF GOVERNMENTAL COORDINATION
r  OTCTAREIOA WOFFIC                                         E                  D aTALF  PIPIELINE COORDINATOR'S OFFICH
    381 *C, STREET, SUITE 370             P.O. BOX 110030   -411 WEST ATM AVENUE. SUITE 2C
 Ii    PW (907) 661.6131iFAX. (907) 51814PM: (907) 465-356WFfAX. (907) 466a 5     P- 90)28.S4FA. 97) 76

I        E~~f94 irsr name,) FIELD -last name)
            J3~fuI  addre ss

 I         FIE.LDitalutate/ion)


         We request your participation in an interagency project concerning cumulative impacts of
         growth and development. This project. funded with a federal grant administered through the
         Alaska Coastal Management Program, is maniaged by a seven-person team. Teami members
         rcprcscnt thei Division of Govcrnimcntal Coordination: the State De~partments of Natural
         Resources, Fish & Gamne, Environmental Conservation, and Commerce and Economic
         Development; the Kodiak- Island Borough coastal management program: and the Bristol Bay
          Coastal Resource Serice Area. A list of the team members is encloscd with this letter.

I       ~~Simply stated, cumulative impacts are the effects of activities and uses that persist over time.
         Cumulative impacts may be of a social, economic or environmental nature.

Ii      ~The primary purpose of the project is to determinc whcre cumulativc impacts occur and how
         State agencies and coastal districts address them. An evaluation committee selected HDR
         Engineeringz. Inc. of Anchorage to conduct telephone interviews to characterize curretii
I       ~~practices regarding cumulative impacts in Alaska.  A representative of this firm will contact
          you during February or March to learn more about your expcriencc with cumulatiVe
Ii       ~~impacts. The interview will take between 20 and 60 minutes,

          During the interview, the staff at HDR Engineering. Inc. will ask you a number of questions
          about the following topics:

             *  general information about you and your authorities-,
  I I         ~     ~~site-specific information about cumulative impacts in your area; and
             *methods used to identify, consider and control cumulative impacts.
II     ~ ~HDR will use information from the interview to write a report, but responses will not be
          atu-ibuted tu !5poifiw individuals. All respondents will be sent a copy of the draft report of
          project findings for review and com~ment.



nn-c-:JL  QLu  *5@Cw       uuQ;uu'-iLL.' vuSE>4            rn/t il,.  uLsc33UtQ                  r.












    Page 2
    February  13, 1995


    Thank you in advance for your participation in this important project.  If you have any
    questions regarding this project, please contact me  by calling 465-8792.

                                               Sincerely,


                                               Glenn Gray
                                               Project Leader



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I Appendix B
    I ~~~~~~~~~Survey Instrument (blank)

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                             Cumulative Impacts in Alaska
                                   Survey Instrument


Last Name:                        Phone:                             Respondent Code:
                                  Fax:
First Name:

Program Areas:

Agency or District / Division:

Address:                                                             Send Draft Report?
                                                                          Yes       No

                                                                    Address confirned?
                                                                          Yes       No


Attempt 1 Date:                                               Scheduled Interview Date:


                                                              Scheduled Interview Time:
Attempt 2 Date:



Attempt 3 Date:



Interview Date:                                               Actual Start Time:

                                                              End Time:

Interviewer:                                                  Minutes to Complete:

Notes:




HDR Engineering, Inc.                     Page 1              Cumulative Impacts in Alaska








                                                            Respondent Code:

Part A:  The Respondent's Frame of Reference and Authorities

1.    What does the term "cumulative impact" mean to you?






I  2.    Is your coastal district or agency directed by statute, regulation, enforceable policies,
       or by other direction to identify, consider and/or control cumulative impacts?

              Yes        No         Not sure

2b.    [If Yes] Could you please identify the source of direction, and what you are directed
       to do?
 Source of Direction               What are you directed to do?



























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Part B: Cumulative Impact Sites in the Respondent's Area.

For this survey, we are using a general concert of cumulative impact. When you respond to
questions, please think of your experience in light of this general idea rather than a strict
definition. I'd like to read it to you, then ask you whether you can think of sites in your area
where a cumulative impact has occurred.

A cumulative impact is the effect of an action when added to the effect of other past, present.
and reasonablv foreseeable future actions, regardless of who undertakes the various actions.
A cumulative impact can result from individually minor but collectively significant actions
taking place over time. In other words, several minor effects add together to cause a more
severe impact.  A cumulative impact can be environmental. economic. social or cultural in
nature. The impact can be from a single source or from multiDle sources added toeether or
added together over time. For this survey, cumulative impacts are presumed to be adverse
effects. Would it be helpful for me to read this concept again?

So in general terms,

3a.    Are there geographic sites in your jurisdiction /area of concern where you believe
       uses and activities are causing environmental, economic, social, or cultural effects to
       add up over time?

             Yes          No        Don't Know

3b.    [If Yes] Could you please name the geographic areas or sites (be as specific as
       possible) being affected? And for each site, please note environmental resources
       (such as wetlands) or economic. social or cultural uses (such as commercial or
       subsistence fisheries, or tourism) that are affected. Also, what seems to be causing
       the impacts?

 Area / Site                       Resources or                  Causes of the impacts
                                   uses affected                 [If it is unclear what causes the
                                                                 impact to be cumulative, ask
                                                                 them.]











HDR Engineering, Inc.                       Page 3                Cumulative Impacts in Alaska








           Area /Site                          Resources or                     Causes of the impacts
                                             uses affected                   [If it is unclear what causes the
                                                                            impact to be cumulative, ask
                                                                            them.]I






















~~~HDEniernInc ae4Cmltv mat nAak








4.     Could you choose the site or situation you know the most about, for a few follow up
      questions?

      Site/ Situation:

      4a.    How was it determined that impacts were adding up and causing problems
             over time?




      4b.    How was it determined that problems needed attention?






       4c.    What steps have you taken to address the cumulative problems, if any?





       4d. What steps have been effective and why?





       4e.    What steps have not been effective  and  why  not?
















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Part C: Process Used to Identify, Consider, and Control Cumulative Impacts.

Next. I would like to ask you about any steps you take to identify, consider, and control
cumulative impacts. In other words, how do you typically learn that cumulative impacts are
occurring, how do you decide there is a problem and what to do about it, and then what
actions do you take or what techniques you have used to control the impacts from getting
worse? Again, a -cumulative impact could affect environmental, economic, social or cultural
resources or uses. The impact can be from a single source or from multiple sources added
together or added together over time. So,

5.    Is the process you have just described for the     .    (impacted site) very typical of
       what you do? [If yes, skip to 9] If not, I want to ask you about your more common
       practices.




6.     Do you take particular steps or use certain techniques to determine whether a
       cumulative impact is occurring or has the potential to occur? If so, what are these
       steps or techniques?




7.     What kind of-process or techniques, if any, do you use to consider cumulative
       impacts? In other words, after you know a cumulative impact is occurring or is likely
       to occur, what do you do to decide if that cumulative impact is significant and needs
       attention? And how do you determine what attention it needs?




8.     What kinds of actions have you used to control or limit cumulative impacts? In other
       words, after it has been determined that a cumulative impact is occurring and it needs
       attention what do you do to remedy the impact?




9.     What obstacles or difficulties, if any, do you face in identifying, considering or
       controlling cumulative impacts?



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10.    Do you face any of the following obstacles in identifying, considering, and controlling
      cumulative impacts?

             inadequate direction, guidance or tools with which to address cumulative
             impacts
             lack of political or institutional support for doing so
             insufficient time to pay attention to cumulative impacts
             insufficient funds to assess and evaluate cumulative impacts
             insufficient site-specific information (such as baseline data) about resources at
             risk
             insufficient information to determine whether a cumulative impact will be3
             significant
             inadequate experience to address cumulative impacts
             the absence of a definition of "cumulative impacts" established in regulation
             limited authority to address cumulative impacts, due to land ownership
             Can you think of any other obstacles you face?3


I la   Next, I would like to read to you a fist of techniques which could be used to identify,
      consider or control cumulative impacts. As I read each technique, please indicate
      whether you use the technique to address the problems associated with cumulative
      impacts.  [Interviewer should note a number next to each technique used; 1,2,3, etc.]I

              searchr files to find out about impacts from past projects in a given area
              draw on other agencies' activities, information or staff knowledge3
              rely on other agencies to address cumulative impacts
             apply planning techniques (such as research techniques from land use planning,
             community planning, master planning, comprehensive planning, or economicI
             development planning)
              use NEPA or EIS processes
             use permit review techniques or consistency review techniques (such asI
             requests for additional -project information)
              conduct special studies (such as to monitor ecosystem health)
              conduct field surveys3
              measure an impact against specific environmental standards
             assess environmental indicators (such as species or conditions which may
             change over time)
              apply cartographic techniques (such as a Geographic Information System)
              apply your own professional judgement
          ___hold discussions internally (at your district or agency)



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              through planning, establish enforceable policies with the intent to prevent
              significant adverse cumulative impacts from occurring
              establish thresholds or standards beyond which impacts are not allowed
              attach enforceable stipulations or mitigation requirements to permits, leases. or
              licenses
              in a consistency review. find a project inconsistent based on an enforceable
              policy regarding cumulative impacts
              limit access to the resources at risk (such as with a lottery or a first-come-first-
              serve system)
              take enforcement actions (issue notices of violation)
               monitor site-specific impacts
               maintain a field presence to prevent further impacts in the vicinity
              based on impacts to date, make a change of policy regarding future impacts

              Do you use other techniques to identify, consider or control cumulative
              impacts?




I lb.   Of the techniques you just mentioned, which techniques have been the most successful
       in addressing cumulative impacts, and why?












I ic.   Which techniques have been unsuccessful in addressing cumulative impacts, and why?











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Part D: Closing Information From Respondent

We have a few closing questions about your work background and your outlook.

12a.  Have you worked in any positions in which you encountered cumulative impact
       issues?
             Yes         No          Not Sure

[If No or Not Sure, go on to question 13.]

12b.  [If Yes] In what context were you employed?, what was your title?, and what were
       your job duties (such as field work, monitoring, permitting, programming, or policy
      development)?

 Agency                        Title                          Job duties: field work?
                                                             monitoring? permitting?,
                                                             planning? or policy
                                                             development? etc.














13a.  Earlier we asked about statutory and reeulatorv direction on cumulative impacts.  Are
       you aware of any written internal guidance within your agency or district on how to
       address cumulative impacts?

             Yes         No         Not sure

13b.  [If Yes] What is it, and do you use it?



13c.  [If Yes] Has the guidance been useful? Why or why not?









14.    What additional guidance or tools. if any, would be useful to you in addressing
      cumulative impacts?













15.    Do you have any closing comments or recommendations regarding how cumulative
       impacts are - or could be - addressed by state agencies or districts, and if so what are
       they?













Thank you very much for your time and contributions to this study.

We will write a report based on the 85 interviews we are conducting. Are you interested in
seeing a copy of the draft report? If so, it will be sent to you for your review and comment
later this spring.      Yes          No

[If Yes] I'd like to confirm that we have the correct address for you [read the address on
cover sheet and make any corrections].

Thanks again for your time.



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                        Appendix C
Cumulative Impacts in Alaska Survey Instrument and Survey Responses                       I

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                                         APPENDIX C
                      Cumulative Impacts in Alaska Survey Instrument
                                     and Survey Responses


Part A: The Respondent's Frame of Reference and Authorities

11. i  What does the term "cumulative impact" mean to you?

            45  respondents had a working concept of the term which closely resembled the Council of
           Environmental Quality definition.

       *     25   respondents had a concept of the term which did not resemble the Council of
           Environmental Quality defintion , or they did not have a concept of the term " cumlative
           impact"'.


2.     Is your coastal district or agency directed by statute, regulation, enforceable policies, or by
       other direction to identify, consider and/or control cumulative impacts?

         30  Yes        40  No             Not sure

2b.    [If Yes] Could you please identify the source of direction, and what you are directed to
       do.

Source of Direction                                 What are you directed to do?

NEPA                                                Consider cumulative impacts when federally aided
                                                  projects are proposed; in preparing EA or EIS,
                                                  consider cumulative impacts
NEPA                                                Must consider CI but only under EIS review -
                                                  limited state role
FCZMA                                               Voluntary direction in Section 6217; discusses Cl
                                                  and Section 309 which provides funds to address
                                                  Cl
Clean Air Act                                       Sets standards
Clean Water Act                                     State sometimes uses the water quality regulations
Federal Regulation                                  Requires feds to look at CI but the state is directed
                                                  only when a federal project or federal funding is
                                                  involved
FHWA Policy, NEPA                                   Evaluate secondary and CI resulting from an action
FHWA Project Development Guidelines, CFR 23,  Directed to identify cumulative impacts and look at
and technical guidance in the form of memoranda  area of impact on economy and socioeconomics
from FHWA                                           (e.g. impacts to rates of growth in a community);
                                                  directed to characterize cumulative impacts (within
                                                  guidelines re: quantification) e.g. rates of growth
                                                  and   impacts  to  infrastructure;  directed  to
                                                  characterize positive cumulative impacts; directed
                                                  to inform units or people of potential impacts



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State Sou.rcesi of Di rec to
ADF&G Mitigation Policy                              Implicit and  explicit direction  to  look  at and
                                                    consider Cl; it is similar to NEPA but not specific to
                                                    Cl, it may, however, result in looking at Cl
AS 1605 (840) & (870)                                Not explicit regarding Cl but does not exclude it
                                                    either
5 AAC 95                                             Touches on Cl, regulations on special areas
18 AAC 50. (300) & (400)                             Application must look at indirect air quality impacts
Through ACMP                                         Take Cl into consideration before approval of a
                                                    permit
The ABC list                                         Must   look  at  Cl  when   proposing   general
                                                    concurrence
6 AAC 46.40.210                                      The term is defined and referenced in the act
ACMP Regulations                                     Not specific but there are various places where you
                                                    look at Cl
Statute                                              Land use planning does not specifically require Cl
                                                    consideration but it ends up being part of the
                                                    process
Forest Practices Act                                 Cl not addressed but there are some general goals
                                                    and  buffer  requirements  which  are  somewhat
                                                    applicable
Regulations adopting management plans for State  To take into account Cl when authorizing a special
refuges                                              area permit
Regulations 70.010                                   Water quality (anti-degradation clause)
Legislation allowing aquatic farming                 To look at affects of the number of aquatic farms
                                                    on an area
Aquatic Farm Program Statutes                        "Consider" CIs
Policy, but only indirectly                          To maintain fish and wildlife (indirectly addresses
                                                     Cl)
Through the permit process                           To identify and look at the ability of a facility to
                                                     handle impacts over time
18 AAC 70- Mixing zone standards                     Address  all  discharges  in  combination   or
                                                     separately - one of the only places where Cl are
                                                     alluded to
Memo from former director of DEC                     Provides  some  guidance  on  how  to  permit
                                                     activities on TMDL waterbodies
State Water Quality Standards                        Consider cumulative impacts and effect on water
                                                     quality; e.g. turbidity from 3 separate discharges
                                                     may add up over time to create impact
Oil Spill Response Regulations                       Consider  cumulative  impacts  from  industrial
                                                     wastewater and oil spills that add up over time
6 AAC 75 Spill Response                              Pollution prevention and mitigation of all pollution
                                                     including monitoring and overseeing spill cleanup
Title 41 and Title 46                                Consider all pollution prevention/oil spill cleanup
ACMP                                                 Directed to consider cumulative impacts
Title 38                                             Directed  to  consider  cumulative  impacts;  not
                                                     precluded from considering and controlling in the
                                                     best interest of state
Alaska Constitution                                  Provides for state agencies to create statutes and
                                                     regulations to address cumulative impacts
Title 38                                             Directed to consider cumulative impacts in the
                                                     management of state lands


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AAC 11                                                Provides guidance   for how Title 38  is to be
                                                     interpreted
AS 46.15.080                                          Requires   notice,   collection   of   information,
                                                     determination  regarding  impacts  of  proposed
                                                     project on public interest; consider impacts to fish
                                                     and wildlife; effects on economy; effects on health.
Water Quality Regulations                              Doesn't say "CI" but gives authority to develop regs
6 AAC 80                                              In spirit, CI is to be addressed
Section 401 Certification                             Must certify that water quality will be maintained (in
                                                     relation to a fill activity); on a permit-by-permit
                                                     basis but for large discharges, applicant may be
                                                     required to monitor whole waterbody
ACMP and regulations                                  Terms and definitions that "get to" CI
Statutes and Regulations                              Requires staff within agencies to look at numerous
                                                     items and effects on ALL interests (including all
                                                     people affected); enforcement authorities also
State and local statute                               To protect the environment

District Program                                      "...shall consider the CI of a proposed project on
                                                     AQ, WQ, etc."
District CMP                                          Minimizing and mitigating Cl through planning and
                                                     policies
Prince of Wales Area Plan                             To consider Ci
District   CMP    (Northwest   Arctic   Borough,   Protect subsistence uses and lifestyles
implementing NANA CRSA CMP)
Matanuska-Susitna Borough (MSB) Title 23              Directs management of borough-owned lands; sets
                                                     use criteria
MSB Title 17                                          Sets standards for land use, flood zone damage
                                                     protection
MSB Title 11                                          Sets standards for management or roads, streets,
                                                     sidewalks, trails in the public interest; design and
                                                     construction techniques for prevent impacts
MSB Title 9                                           Addresses water pollution control to ensure water
                                                     pollution is mitigated, specifically sewage disposal
MSB Title 8                                           Addresses health and welfare, litter and associated
                                                     impacts
MSB Title 6                                           Addresses clean air;environmental protection
District CMP (Pelican)                                Enforceable policies regarding cumulative impacts
                                                     (although not specifically stated)
City ordinances (zoning, building, harbor) (Pelican)   Directed to build according to zoning and building
                                                     codes
District Program (Kenai Peninsula Borough) (2.7)      Consider in the review of coastal projects, ambient
                                                     air and water quality and habitats;
Floodplain Ordinance (KPB)                            Cls are mentioned; include historical, current, and
                                                     future forseeable activities (only applies to mapped
                                                     areas in floodplain); all of floodplain is within the
                                                     coastal boundary
Kodiak Island Borough Zoning Code (1990)              Special district zoning with CI section - conditional
                                                     use permits (CUPs) required in rural zoning district
                                                     Conservation Zoning Code - all areas where CUPs
                                                     are required, burden is on Borough to deny the
                                                     CUP if cumulative impacts would occur, based on
                                                      "credible scientific evidence"

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L       r Coasta District SourcesofDirection (continued)                                                     I
District CMP [City and Borough of Juneau (CBJ] -  Staff reports on wetland projects to the Wetlands
Coastal Management Plan's Wetland Management  Review Board re: effect of a project on wetlands
Plan                                              base; this is a procedure but not a policy, because
                                                 it does not require them to take a particular stance
                                                 or action; an annual report is required re: all
                                                 wetlands impacts
Memorandum of agreement between CBJ and  The two parties are to consult re: impaired water
Alaska  Dept. of Environmental  Protection re:  bodies (7 listed in CBJ); no specific action required
impaired water bodies                             however
CBJ Ordinance for CUP                             Requires traffic planning to be done in association
                                                 with projects proposed, which could address effect
                                                 of project on existing traffic,i.e.Cls
District CMP (Haines)                             Draft plan included "consider Cl" (not  part of
                                                 adopted plan) (note: "CPC removed the draft
                                                 language before approval")
District CMP (BSCRSA)                             Review activity, consider potential CIs, address
                                                 them


Part B: Cumulative Impact Sites in the Respondent's Area.

For this survey, we are using a general concept of cumulative impact. When you respond to
questions, please think of your experience in light of this general idea rather than a strict
definition. I'd like to read it to you, then ask you whether you can think of sites in your area
where a cumulative impact has occurred.

A cumulative impact is the effect of an action when added to the effect of other past. Dresent. and
reasonably foreseeable future actions, regardless of who undertakes the various actions.   A
cumulative impact can result from individually minor but collectively sienificant actions taking
place over time. In other words, several minor effects add together to cause a more severe
impact. A cumulative impact can be environmental. economic, social or cultural in nature. The
impact can be from a single source or from multiple sources added together or added together
over time. For this survey, cumulative impacts are presumed to be adverse effects. Would it be
helpful for me to read this concept again? So in general terms,

3a.    Are there geographic sites in your jurisdiction /area of concern where you believe uses and
       activities are causing environmental, economic, social, or cultural effects to add up over
       time?

         63  Yes        7  No            Don't Know









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       3b.    [If Yes] Could you please name the geographic areas or sites (be as specific as possible)
               being affected? And for each site, please note environmental resources (such as wetlands)
               or economic. social or cultural uses (such as commercial or subsistence fisheries, or
               tourism) that are affected. Also, what seems to be causing the impacts?

                      [interviewers filled in Table, See Appendix B for all sites listed]

       4.     Could you choose the site or situation you- know the most about, for a few- follow up
 I         ~ ~~questions?
               Site/ Situation

                      [The responses from this section pertained to very specific sites and were not entered
                      verbatim. Coded responses are analyzed in Chapter 4.0 and specific case examples are
                      sited in the "Cumulative Impact in Brief" text boxes throughout Chapter 4.0.]

   I                 ~~~~~4a.    How was it determined that impacts were adding up and causing
                             problems over time?
                      4b.    How was it determined that problems needed attention?
                      4c.    What steps have you taken to address the cumulative problems, if any?
                      4d.    What steps have been effective and why?
                      4e.    What steps have not been effective and why not?


I      ~Part C: Process Used to Identify, Consider, and Control Cumulative Impacts.

        Next, I would like to ask you about any steps you take to identify, consider, and control
I     ~cumulative impacts.  In other words, how do you tyically learn that cumulative impacts are
        occurring, how do you decide there is a problem and what to do about it, and then what actions
       do you take or what techniques you have used to control the impacts from getting worse? Again,
         acumulative impact could affect environmental, economic, social or cultural resources or uses.
        The impact can be from a single source or from multiole sources added together or added
3      ~~together over time. So,

        5.     Is the process you have just described for the _____(impacted site) very typical of
               what you do? [If yes, skip to 9]  If not, I want to ask you about your more common
               practices.
        6.     Do you take particular steps or use certain techniques to determine whether a cumulative
               impact is occurring or has the potential to occur?  If so, what are these steps or
               techniques?

        7.     What kind of process or techniques, if any, do you use to consider cumulative impacts? In
               other words, after you know a cumulative impact is occurring or is likely to occur, what
  3           ~~~~do you do to decide if that cumulative impact is significant and needs attention? And how
               do you determine what attention it needs?


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8.      What kinds of actions have you used to control or limit cumulative impacts?  In otherI
       words, after it has been determined that a cumulative impact is occurring and it needs
       attention what do you do to remedy the impact?

               [The responses for questions 5 through 8 were were not entered verbatim. Responses
               were coded then analyzed in Chapter 4.0]

9.      What obstacles or difficulties, if any, do youj ace in identifying, considering or controlling
       cumulative impacts? 

Cl not a priority-, * Public/staff don't recognize the importance of monitoring of impacts and looking at
them in a cumulative way; * The state does not address Cl from logging anywhere - it is irresponsible of
the state; * We don't do any science; o Dependent on others to be forthright in divulging their plans-, 9 NoI
control over anyone elses development, i.e. no land use control over adjacent land; o S Funding; o Lack
of technical ability to do formal analysis such as water quality testing; * Lack of time and $ for big
projects, we have enough to do; e Need staff for inspection and monitoring; * For big projects replanning
up-front from multiple agencies working together (a task force); * Unclear definition and unclear prodess
or procedure to identify Cl, i.e. where do you stop? How many projects or impacts do you add in? How
far in the future do you project? ; * Public acceptance is lacking-, * Need a collective understanding by
the public of the functioning of systems; * Misinformation is often given to locals from outsiders
exagerating the potential impacts - bad advice; * Not having enforcement capability; o Not having $ and
staff time for field inspections and monitoring; * Local communities reluctance to accept responsibility for
permitting or land use; * Not having a hammer (where no permit is necessary) ; * Not enough staff (fieldI
presence) ; a Determining what an acceptable level of use is; a Politics; 0 Lack of $ for 0 & M in small
villages; * Never having really planned to control or address Cl (Never been called Cl) ; 's Lack of
recognition by public and other agencies of the additive nature of impacts over time - each small piece is
not thought to hurt; * No clear regulations to provide protection, in conjunction with a plan, for areas
experiencing CI; * Level of coordination missing from amongst state agencies; * Lack of manpower and
resources to even look at Cl, don't even have time to look at them during a consistency review; * Getting
people to look at both sides of the equation i.e. weighing both benefits and impacts, particularly benefits.I
Every decision has tradeoffs and consequences - getting people to see the positive is difficult-,;
Resistence based on economics/job loss (political pressure) ;* Institutional resistence - it's not been
done in the past, why now? ; * Insufficient time, $, and staff; *Measurement of the impacts is difficult
and determining the effects of the CI; * Insufficient staff time;-, The mindset i.e. no mandate, applicant
resistence, department backing etc. ; * Need specific regulations to minimize discharge or to consider
cumulative discharges; a Coming in at the tail-end of the development process, after development has
already occurred and trying to control the problems from that adjacent development; o Lack of funding,
staff time, and public awareness-, o Some staff not thinking it is an issue and local government claiming it
is an unfunded mandate; * Issues are emotional - public sentiment against aquatic farming, not
necessarily based on science; * Time constraints, lack of staff; 0 Lack of resource data; * Commenting
agencies not having time or $ to provide data; - Not having wetlands classified as to their values and
functions - results in piecemeal decisions; * Changing the way we treat habitat will require economic
sacrifices and the public will not accept this at this time; * Working strategy mutually acceptable to allI
agencies - it is nearly impossible to get all agencies to agree (on a rehab project for example)   0
Recognizing, documenting, and calculating the Cl; * Having little control over slowing down Cis or
reversing them - stopping them is best but is not possible; & Getting agencies or companies toI
acknowledge them and act on them; * Public opinion, i.e. you can't get support because of the economic
stakes of those that would be regulated; * The borough not having authority or control; *There is no
process; -, There are not obstacles, we just have not done it; - Not having Cl as a mandate; *No $; * The
AK mentality is that no government is good, i.e. no public support; * No $; e Trying to define what Cl are,
and how significant they are; o Budget is too small to get to sites (landfills) before permitting, during
construction, or after closed for monitoring; * Lack of resources (staff, monitoring equipment), funding,

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base information, and time for prevention. We are mostly reactive; * Lack of funding - access to sites is
too expensive; * lack of financial support, tools; * problems with attitude that government is an intrusion;
* climate and distance makes monitoring expensive; * other agencies are the problems in all phases of
addressing Cl; * definitions of problems/CI are different between agencies ( no consistency); * data
bases inadequate; * applicant has more data than agency; * difficult to coordinate agencies to discuss
mitigation; * difficult to determine significance when single impact (piece of project ) does not appear to
be substantial at first so not considered; * with older existing facilities, there are $ problems, difficulty
getting paperwork in, methods of inventorying are not good; * may be creating problem without realizing
it (e.g. fuel leaking gradually, unnoticed); * problems with identification - detection is haphazard; don't
see all impacts; other agencies have jurisdiction and are not communicating; * problems with considering
impacts - take place in context of politics in the office; no criteria for determining significance; too
subjective; not clear who is responsible; * problems with controlling - same as above; difficult to reach
agreement on approach; need consensus on how to resolve; * no problems with identification; more with
controlling; * mitigation is beyond control; * difficulty in considering Cl - limited expertise; new and big
issue; while there are technical models, methods are new and need to be modified on a case-by-case
situation; * control of Cl requires staff and authority; * need better monitoring and compliance and
analysis of carrying capacity of the resource; * jurisdictional problems - solutions may not be within
responsibility and authority of agency (i.e., land use changes); * problem with definitions especially on
how to address socioeconomic and environmental Cl; * not clear on how to balance socioeonomic with
environmental - difficult to determine which is moreimportant; * permitting is complicated and so industry
(i.e. visitor industry) goes to "easier" places to develop; * resource managers not familiar with economic
considerations (i.e., visitor industry); * direction and mandates are lacking * political reactions internally
in the department cause comments [by reviewers] to be extracted by managers, in an obligation to
encourage development * hard for people (users, decisionmakers, staff) to articulate the problem; * there
are legal and political constraints in crafting solutions; * time and money; * can't control a local
municipality in their enforcement of local ordinances; * lack regulatory BMPs for many activities in
Alaska; * the five year cycle of permitting limits the frequency with which EPA addressses a permitted
discharge [for NPDES permit renewal]; * haven't yet said whether a change in community diversity is
bad or good, don't know; * often don't know natural fluctuations as backdrop - need to look at biological
baselines that don't change; * routine operator monitoring reports [for NPDES permits] are not consistent
and not all operators are doing it; * inadequate staffing to verify through monitoring whether existing
controls are working, such as BMPs, must rely on permitees to monitor receiving water changes; *
property rights is a big obstacel, unless the city can enforce a law through state or federal regs, can't
enforce anything; a sort of curtain comes down beyond a line (i.e. the Corps' or DFG's authority) on a
waterbody; * [an obstacle to identifying and considering a potential Cl is that] before a public hearing, we
have little information about specific bays [where proposed activities would occur]; * [obstacles] depend
on the administration and who they are, whether they are sympathetic to a village's interests; * Cl is a
fuzzy problem, with turf wars and heads buried in the sand; * internal agency policy struggle, due to
department's interest in economic development, so it appears the department was not set up to address
Cls, because Cls would be seen as being used against economic development; * most of the time, the
community advocates and justifies the development of public projects, because they want public facilities
projects; ï¿½ biggest obstacle is how each agency has its own interpretation of Cl, and sees the other
agencies' roles as different; * lack of team work throughout the governing bodies (state studies are not
shared with locals and the borough, though this information could be very  useful; * federal and state
governments force us to study and wait, therefore problems compounded before we did anything; .
reactive individuals pay attention to what is pressing, meanwhile other problems are evolving and not
getting proactive attention; * money, staff and time - the cycle of permitting is frenetic and its hard to
think of the big picture while you crank through the applications, on a schedule; * even with a district
CMP policy, the wording is not strong enough, so it is hard to implement; * a project may not require a
permit for the activity which is causing the Cl, so it becomes very awkward to require stipulations,
mitigation, etc. though they are needed; * part of the obstacle is getting the people educated enough to
understand why the activity is significant and deserving of attention, department resources and action -
have to talk with people internally as well as outside the department; ï¿½ costs are #1 obstacle, but also

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weather, transportation (the area is landlocked 8 months of the year); * unfunded mandates, limited
resources.

10.    Do you face any of the following obstacles in identifying, considering, and controlling
       cumulative impacts?

         44    inadequate direction, guidance or tools with which to address cumulative impacts
         45    lack of political or institutional support for doing so
         44    insufficient time to pay attention to cumulative impacts
         52    insufficient funds to assess and evaluate cumulative impacts
         49    insufficient site-specific information (such as baseline data) about resources at risk
         48    insufficient information to determine whether a cumulative impact will be
               significant
         36    inadequate experience to address cumulative impacts
         41    the absence of a definition of "cumulative impacts" established in regulation
         30    limited authority to address cumulative impacts, due to land ownership
                Can you think of any other obstacles you face?

ï¿½ Federal agencies deciding against a development when the agency has no personal knowledge of local
conditions; * No systematic way of tabulating past permitting (i.e. tracking) as is being done on the
Kenai; * Not being brought into the loop early enough; * The institutional approach toward what
constitutes Cls and how you go about dealing with them; * Department recognition that there is a Cl
problem; ï¿½ Public perception - the regulated community may not see that they contribute to the sum total
of the impacts; * People were unaware of potential impacts and were taken advantage of by
governement and big corporations; * Not having a Cl process; * Need agency direction; * Only having
the time and resources to respond when the risk is great; * There is an organized group of the public that
fights any regulation, especially when economic loss is the result; * Need standards for evaluating and
measuring CI; * Public opinion - lack of public support; * Lack of authority to control Cl; * need
consensus and cooperation between others with the expertise in determining if Cl exists and if it is
significant; * need to work with other agencies in planning efforts as partners; *government leaders need
to acknowledge tourism is a resource not unlike natural resources therefore other developments have
impacts on tourism; * by the end of a project and permit issued, it could be out of compliance with Cl
regulations; ï¿½ project with timeline (financing, seasonal nature or project) could be affected by insufficient
time to pay attention to Cl; * tend to do more "office" work than field monitoring; *inadequate experience
with remediation techniques; * need state and federal agency funding; *politics of situation affect work; ï¿½
local knowledge invalidated because they are not "scientists"; ï¿½ lack guidance/tools regarding terrestrial
systems; * need to look at geographic focus, values and functions with regards to terrestrial systems; ï¿½
COE needs to look at nationwide permits (NWP) - no systematic monitoring to see if NWPs are adding
up; * obstacles depend on make-up of legislation and administrative tendencies to provide permits that
based on political convictions; * new regulations regarding tank farms seem ridiculous - cost to improve
safety is an impact; * staff resources and lack of travel money; * subjectivity in defining Cl; * tough to get
any of the techniques listed; * tough to define level of unacceptable impacts; .funding for field presence;
* CIs are subjective and easy to challenge; * lifestyle questions and quality of life - understanding Cls
and education regarrding problems is obstacle; * money.








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        1Ila   Next, I would like to read to you a list of techniques which could be used to identify.
                consider or control cumulative impacts. As I read each technique, please indicate whether
 I          ~ ~~you use the technique to address the problems associated with cumulative impacts.
                [Interviewer should note a number next to each technique used; 1,2,3, etc.]

                 46    search files to find out about impacts from past projects in a given area
                 59    draw on other agencies' activities, information or staff knowledge
                 49    rely on other agencies to address cumulative impacts
                 48    Apply planning techniques (such as research techniques from land use planning,
                       community planning, master planning, comprehensive planning, or economic
                       development planning)
                 35    use NEPA or EIS processes
                 60    use permit review techniques or consistency review techniques (such as requests
                       for additional project information)
                 34    conduct special studies (such as to monitor ecosystem health)
                 53    conduct field surveys
                 39    measure an impact against specific environmental standards
                 29    assess environmental indicators (such as species or conditions which may change
                       over time)
                 39    apply cartographic techniques (such as a Geographic Information System)
                 63    apply your own professional judgement
                 62    hold discussions internally (at your district or agency)
                 42    through planning, establish enforceable policies with the intent to prevent
                       significant adverse cumulative impacts from occurring
                 3 1   establish thresholds or standards beyond which impacts are not allowed
                 54    attach enforceable stipulations or mitigation requirements to permits, leases, or
                       licenses
                 23    in a consistency review, find a project inconsistent based on an enforceable policy
                   __regarding cumulative impacts
                 3 1    limit access to the resources at risk (such as with a lottery or a first-come-first-
                       serve system)
                 41    take enforcement actions (issue notices of violation)
                 52    monitor site-specific impacts
                 44   maintain a field presence to prevent further impacts in the vicinity
                 46    based on impacts to date, make a change of policy regarding future impacts
                   ___Do you use other techniques to identify, consider or control cumulative
   *                 ~~~~~impacts?

         *Outside professionals to assist them; a Talking with the applicant (public education) ;*Search literature
        to determine potential impacts; * Public education; a A general awareness of the projects going on in the
I     ~ ~district and monitoring them informally, a consult users for identification of CI; 4, working with other
        agencies as partners;* interview locals for information regarding conditions; e use consultant to get an
        independent evaluation, a prioritize to determine if it can be addressed; * general public awareness-,
        public education is critical - develop fliers and knowledge of how to reach public; erely on applicant's
        reporting and citizens' complaints; use school projects like water watch; *propose legislation; *use local
        input; * use local subsistence users - good "too1" for tracking Cl because they see changes; *partcipate
        in national surveys re CI ; 4, bonding for performance or certain permits actions; * talk with "old-timers";.

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DNR's public processes; * bring problem to public attention, neighborhood associations; * work with                I
village people.

1 lb.   Of the techniques you just mentioned, which techniques have been the most successful in                    |
       addressing cumulative impacts, and why?

ï¿½ On-site evaluations to learn from one project to use in the future; * Monitoring and field presence and
permit stipulations; * Good proactive approach - Planning; * Public education through the permit process;
ï¿½ Denying a permit; * Conditioning permits in order to avoid or mitigate impacts although there has not
been specific follow-up to determine success; * Application requirements because they specify what the
applicant must do (they are specific) ; * Consultation with company well before mining starts to try to
anticipate problems well in advance and then minimize or head them off; * Field presence and
information from the applicant on how to do things differently; * Monitoring, enforcement, permit
stipulations, and modifying policies - these enable us to correct for past problems and look at new
technology for minimizing Cl; * Interaction with agencies - i.e.drawing on other agencies information and
relying on them to address; * Best professional judgement - because there are no other guidelines; ï¿½ It
depends on the impact but generally the CMP and zoning regulations - because it allows case-by-case
analysis, landholders are informed, and conditions /stipulations are applied to each specific use; ï¿½
Notification to ublic (public education) ; * Field presence to enforce mitigation; * Planning activities; *
Depends on the situation and people - for some situations enforcement works best while for others it is
education coupled with permit stips; * Stipulation on the permit or lease - because you have the plan in
front of you and it is easier to prevent impacts than to change them once the project has started and time
and effort are easier given staff time available; * All parties coming together to present issues on the
table (proper communication and negotiation; * Being firm as a municipality; * Making sure you have the
tools and techniques; * Programs must be field-oriented or lead to field results or field work; ï¿½ Working
with planners up-front; ï¿½ Education with on-the-ground operators  (timber operators) ; ï¿½ Follow-
up/monitoring on how well the BMPs are working; * On-site review (field survey); * A court mandate -
because it forces the agency to do CI assessment; * Up front planning, although we don't do it enough; .
Permit stips and enforcement; * Permit review/consistency review - because people start thinking about
CI; * Monitoring followed up by enforcement; * Search files, drawing on other agencies, permit review,
professional judgement, and limiting access because it gave everyone a view of projects in a given area
and provided a mix between science and the emotions of the public; * a combination of the city working
with its council and also working with state agencies for gathering information; * Permit stipulations -
because that is all we use; * Some internal ADF&G policy changes have occured based on research
done in the state but they fall way short of controlling CIs; * Having time to study is needed because site
specific studies are useful; * Permit review - because it is most direct and specific method available to
me; * None of the techniques have been successful; * There is some good guidance in the area plans to
address Cl; * The locating, siting, design, operations, and monitoring to avoid CI before they happen; .
Better planning - poor planning is the cause of the problems but the permit process and enforcement is
the best one available; * It is a function of the specific subject e.g. for commercial uses enforceable stips
on the license works best, but on other uses mitigation and close monitoring work - a field presence is
most effective; * taking enforcement actions, monitoring, and maintaining field presence cause action
and consequences for not taking action; * applying cartographic techniques, professional judgement, and
internal discussions support enforcement and monitoring actions well; * on-site field work and
enforcement/stipulations; * enforceable policies and stipulations; field presence; * conducting special
studies, field work, and assessing environmental indicators identify problems ahead of time so they can
be handled before they get worse; * monitoring, field presence catch problems ahead of time; *                      I
experience in agency/internal discussion, professional judgement keep policies consistent; * consistency
reviews (finding inconsistent) gives options to applicant so they have a choice to comply or not; *
enforcement and stipulations provide "hammer"; * discussions and meetings and using professional
judgement; * planning and use of enforceable policies keeps public informed and prevents problems: ï¿½
permits and stipulations provide ability to enforce / levy fines; * all of those listed in survey instrument
work but use of cartographic techniques and planning work well because they are easily performed within

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time limits set forth by statute; * enforceable stipulations; * enforcement and monitoring; * changes in
policy; * searching files and using agency information work with varying degrees of success; * the more
professional advice, the more reliable the determination and the more reliable the action; * enforceable
stipulations work well; * limiting access (like through a lease or competitive sale process) ends up with
financially sound development of resource; * NEPA and studies are successful because they encompass
agency responsibilities and through the NEPA process the rest of the techniquese are addressed; ï¿½
attaching stipulations provides incentive to perform; * planning and development of enforceable policies;
* special studies, field surveys, and assessing environmental indicators require looking to other agencies
for technical help; * enforceable policies, stipulations; * professional judgement and internal discussions;
ï¿½ rely on other agencies; *research, agency knowledge, applying planning techniques makes Cl less
speculative because it expands information base; * measuring impact against env. indicators makes
easier to determine significance; * stipulations enforceable; * working with other agencies in planning
efforts as partners helps carry out mutual goals and objectives; * professional judgement and internal
discussions; * searching files, drawing on other agencies, relying on other agencies and applying
planning techniques somewhat effective; * planning, enforceable policies internal discussions, and
relying on agencies works now because easiest and most straightforward because of staff and funding; ï¿½
enforceable stipulations are specific and allow you to follow up/enforce; * planning and establishment of
enforceable policies gives you a "place" at the table (i.e., elevation); * interviewing locals gives you
information from your constituents as to the problem and if it is signficant; * using outside consultants
gives you expertise besides regulatory agencies in order to analyze the problem; * finding a project
inconsistent tells agencies that the problem is significant to you and it needs to be addressed; ï¿½
permitting / czm consistency review process gives ability to put conditions on development to prevent
impacts, avoid cumulative component; * reconsideration or making policy or ordinance changes has
strengthened ability to control CIs in the future (although it might not address specific impact at the time);
ï¿½ special studies effective (like Kenai River 309) due to adequate time and funding to document baseline
and historical conditions to show without a doubt that there has been a change...until a problem is
quantified, it is denied...studies must be dynamic and the results updated via the permitting system. ï¿½
state area plans go through full public review, subsequently there is alot of public support for carrying out
the plans; identify specific stipulations and mitigation requirements which are very performance oriented
so you can get measures of performance, violations are clear to any of the enforcement staff; * in
wetland ecosystems, would like to think the wastewater and NPDES permit programs are efffective, they
have the ease of numeric chemical measures of pollution; require applicant to do the work, and its a
legal document; in terrestrial ecosystems, its a different story because of relying on biological parameters
which is harder; * regarding enforceable regulatory best management practices (BMPs), want to know if
they're effective; * once data is available, tools open up to permitters, who then have a basis for
requiring protections to be in place before a project moves ahead; once the public can see the potential
losses, they start thinking "what can I do to prevent the potential losses?"; geographic information
systems (GIS) can be very useful to many user groups; the Kenai River is a world-renowned system, so
that is a strong 'attention-getter' for the problems there; so it is effective to have good data, then local
recognition, ('common ground') that something needs to be done, then implementation on the local level;
. reliance on other agencies is efffective, due to the expertise not available at the City level; * Field
presence is the most effective tool, in advance of a permit being issued, and in advance of a renewal of
a permit (at that time there is opportunity to require other activities; * the EIS for Red Dog Mine was very
effective - the areas that were discussed have been impacted, and the baseline information generated is
te only baseline information in the area, so that is still useful; ï¿½ field presence, working with other
agencies, and planning documents are the prevalent techniques that work well; ï¿½ money is most effective
tool...when an agency has support for their priorities; ï¿½ the state is trying to enable good district planning
to be done, but it is not clear what degree of success is attained; * working with local people (such as
elders) and local resources is most effective since they have the most knowledge about water quality and
habitats and they are the most affected by the use of renewable resources; * also working with the
company [applicant] causing the problems can be effective, if they are reasonable; * knowledge from
experience, and common sense are effective in addressing Cis; * being in the field and looking at the
problem with the person doing the activity because all parties see the problem and it is harder to deny; .


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trying to get voluntary compliance is effective as it gets people to buy into the solution more directly than
going through official enforcement notices from the department (which is more formal, more time, more
energy); * the most used techniques are: our own judgement, discussions with others in the office,
working with other agencies, and checking old files (these work well because they are accessible to
staff); * a combination of planning and historical review is effective, because we need something to
compare with, to know what impacts are occurring; * the most successful situations are when we go
through the Planning Commission, Port Commission or DEC, with a process in place to follow.

1 lc.   Which techniques have been unsuccessful in-addressing cumulative impacts, and-why?

* Cl is a new issue so we don't have a track record to know which techniques work and which don't; ï¿½
Having to rely on local government or someone else to put on land use controls; * Enforceable policies
are not enforeable; * Avoid hard-core enforcement - try to work with people before problems develop; ï¿½
Starting off immediately with enforcement; * Going to other agencies for cooperation because they view
an AMSA as a preservation document where it should allow "balanced development"; * We mostly look
at direct impacts, not Cls; * After-the-fact education ("re-active education") - once opinion on a project is
formed it is difficult to change people's minds; * The institutional mindset is making it more difficult than
it needs to be; * Department policy - because Cl is not addressed by the Department; * Forest Service
planning and DNR planning - because they don't take into consideration local comment; * There are no
Cls yet, we prevent them first - The Cls look significant on paper but there is still a vast expanse of
vacant, unimpacted land for example "90% of the Kenai Peninsula" ; ï¿½ Direct confrontation; ï¿½
Enforcement - it is too confrontational; * In monitoring timber harvest techniques operators "perceived"
the monitoring as an evaluation of staff * Communications with other agencies (DNR in particular) -
because of different agendas, politics, etc. the agency reviews aren't always consistent (interpretations of
regulations are different) ; * Planning process - long-term language and interpretation is not always
effective or specific enough; * Just that there are things we wish we were doing but don't have the funds
for (e.g. monitoring); * Maintaining a field presence - because there is not enough staff; * None were
unsuccessful - they are all useful in their own way; * A lack of knowledge of the tools available, lack of an
ordinance, and the lack of experience to recognize Cls; * They all work to some extent; * Limiting access
and threshholds would be effective if we did it but the agency mitigates and minimizes rather than
stopping Cl, thus the impacts are allowed and still adding up; * Being forced into developing mitigation
when we have no information - the mitigaton ends up being way off target, with good info and specific
studies we would be able to suggest good, effective mitigation; * Enforcement - because the ADF&G has
biologists which are not regulators by nature (to have good enforcement you need someone with more of
a state trooper mentality) The biologist should be doing the assessment. The suggestion made was to
pull enforcement out of Habitat Divison and put it into a division with and enforement mentality; * Getting
local government involved because of local politics; * Staying away from expensive planning in favor of
a field presence; * policy changes not used; * NEPA over complicated and based on inaccurate models,
enforced based on philosophy not science, too expensive; * enforceable policies applied beyond state
and federal law in area management plans; * consistency reviews do not work; * relying on agencies
doesn't work because it depends on how interested that particular agency is in addressing the Cl; ï¿½
applying professional judgement and holding internal discussions works well until Juneau steps in;
NEPA is only valuable in early stages; * conducting field surveys and measuring impacts depend on
staffing and funding; * thresholds and standards difficult to enforce; ï¿½ mapping techniques limited in
availability; * establishment of enforceable policies takes too long; ï¿½ policy changes don't work well
except for identifying potential CIs; * need incentive to do something (consequences like penalty) so
other than stipulations, the techniques listed do not work well; * stipulations only work well if you monitor
compliance; a monitoring and field presence only work well if you have the staffing and funding; a
internal discussions not used like they could be to address Cl; * policy changes not use as a technique to
address CI; * monitoring information does not always include analysis and does not always draw a
consistent "picture" from which to evaluate changes over time; * lack of analysis and "dumping" data into
agency files does not constitute monitoring; * relying on agencies doesn't work because they do not know


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how to address Cis; * using agency information is not always useful because it is a data "dump" with no
analysis/conclusions; * policy changes do not work until some issue is driving the change; * good tools
are not available to make a "cut"' in incremental residential development activities; assembly did not
implement techniques proposed to them by planning staff, therefore there are still limitations on local
regulatory authorities; education [about the need to deal with Cis] has been slow, once people
understand, they want to do something about them, but until then it is just confusion; * cannot tell
whether or not the permit process works, because of lack of field monitoring and site information; limited
annual travel budget and too many remote sites to visit * establishing enforceable policies is ineffective
because the lead planning agency for the state - DNR-has become politicized, they've forgotten public
trust doctrine in public plannning process; efforts to be big brother, know what's best for you is contrary to
attitudes of Alaskans; also not protecting fish and wildlife resources even when the policies are stated in
their own DNR plans; * with the Corps' 404 program, there is no successful protocol for evaluating Cl on
watershed basis, this led to the national policy on "no net loss"of wetlands and the outcome has not been
good; * it has been ineffective to try to find a project inconsistent based on an enforceable policy
regarding Cis, because districts or other entities overturned finding; * study results will be used or
ignored as it suits the various public constituencies); * no particular techniques have been ineffective,
because of a lack of time to even address cumulative impacts at all; * when regulations or requirements
are lacking, protection against cumulative impacts is less effective / successful; * success of techniques
has not been determined yet, for example: one agency has placed a moratorium on an activity in order to
study it but no results are out after 3-4 years; * finding a project inconsistent based on Cl hasn't worked,
it involves other problems like which agency should carry a requirement; the regulatory process only
works if there is follow through; * the elevation process in the ACMP is not effective due to the prejudices
of the people holding those positions - inevitably there will be a failure in the process, and elevation also
leads to lawsuits; * when an applicant doesn't want to cooperate it is hard, because unless the political
will is there, we can't use the rest of the 'control' tools; also we try to treat eveyone the same, but it is not
possible due to political directives to be more lenient to some; ï¿½ monitoring and enforcement follow
through is weak, as with so many agency programs, due to limited staff resources; front end work is
emphasized -planning, permitting, but don't have follow through; * statistics / hard evidence are not
conclusive proof that a concern is 'legitimate'; * techniques to weigh [consider] different values are not
effective, because of the subjective judgement involved - and fights - about what outcome is better for
most people (this occurs when some people who depend on subsistence vs. others who are big business
interests have a difference in values); * receiving a 2 inch thick document from somewhere else is not
helpful; * enforcement is diffficult, have no environmental 'cop'.


Part D: Closing Information From Respondent

We have a few closing questions about your work background and your outlook.

12a.   Have you worked in any positions in which you encountered cumulative impact issues?
         52  Yes         18  No             Not Sure

                [If No or Not Sure, go on to question 13.]

12b.   [If Yes] In what context were you employed?, what was your title?, and what were your
       job  duties  (such  as  field  work,  monitoring,  permitting,  programming,  or  policy
       development)?

               [Interviewers filled in a table, but it was not entered verbatim here. Results
               were coded and analyzed for Chapter 4.0]



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 13a.   Earlier we asked about statutory and regulatory direction on cumulative impacts. Are you
         aware of any written internal guidance within your agency or district on how to address
         cumulative impacts?

          16  Yes        54  No            Not sure

 13b.   [If Yes] What is it, and do you use it?

   TMDL policies -whether to pursue them, and how to deal with 404 permitting in TMDL watersheds; ï¿½
 memoranda of agreement (CBJ and DEC); * district program implementation chapter ; * planning
 commission review and findings; * district plan components used to identify concerns and prioritze and
 set standards; * guidance documents re: contaminated sites and industrial waste water; * FHWA policy
 papers on secondary and cumulative impacts; * procedural manuals direct staff how to adjudicate and
 consider Cl; * FHWA memoranda regarding project development; o no written guidance, just verbal;
 managers' point is that it is not politically astute to deal with certain cumulative impact issues, such as
 aesthetics or wildlife issues because the agency loses ground, loses friends and causes problems.

 13c.   [If Yes] Has the guidance been useful? Why or why not?

 Guidance                                    Useful?    How Used - Why Useful?
               . e~era~id-w. ..                             .......
 Federal Guidance on the Total  Maximum  No               Too new
... . ......................................................................................................................... ...............................................................................................................................................
 TMDL policies                               Too  soon
                                                to tell
....F.H.. .. ................................. .............................. ............................................................................................................................................................................................
 FHWA Policy Paper                           Yes          More specific than existing regulation s
 FHWA       Memoranda        re:    Project  Yes          FHWA  leads amongst federal agencies in
 Development                                              terms  of  dealing  with  difficult  issues;
                                                             memoranda helps DOT to address Cl issues

 In the EIS for the ACMP                     No           Very vague
 In the management  plans for individual  Yes            It gives you a document to hold up to
 state parks, e.g. Wood Tikchik State Park                express   the   public's  will   -  taking
                                                             management subjectivity o.utof it.. 
 DEC Commissioner Memo  _ __ Margina_   Has provided some ammunition
 Contaminated Sites Guidance                 Yes          Standardizes how agency will address
 DNR Procedural Manuals                      Yes          Requires open public process, multi-agency,
                                                             multi-purpose; describe how to implement
                                                             p_ lans
 Cumulative Impact Reports by DGC & DNR   Yes             The  DNR  report gets to the basics and
                                                             directs your thinking, telling you where to
                                                             start and how to outline a process.
 DNR CI Report                               Yes         It brought to the forefront the problems -
                                                             created an awareness
 DNR Policy and Procedure Manual             Yes          Threaded through the manual are guidelines
                                                             which indirectly relate - It is useful because
                                                             with each case type it tells you what to look
                                                             for. It is, however not specific to CI.
 State Implementation Plan                   Yes          It specifically outlines steps to mitigate and
                                                             avoid degradation to the air resource

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ADF&G Mitigation Policy                       Yes          Sets  standards  and   makes   permitting
                                                          consistent - resulting in no net loss.

District CMP, Comprehensive Plan, Zoning  Yes              These have allowed them to go forward with
Ordinance, and Subdivision Standards                       needed development without harmful Cls -
                                                          Has helped avoid Cls
In the District CMP                           Yes    -
District Plan components                      Yes          Identifies concerns and places priorites

14.    What additional guidance or tools, if any, would be useful to you in addressing cumulative
        impacts?

Training; * Specific training on evaluation and assessment of Cl; * State needs to develop procedures for
doing CI assessment (i.e. what to measure, and what Cls are occurring); * Time * $ * Site Histories - to
learn what has occured on the ground and to determine what happens incrementally; * The ability to do a
formal assessment to provide better baseline data to better monitor change. * More clear definition; .
Better sideboards - thresholds (when do Cl start, and where do you stop adding things in); * Training on
how to identify and deal with Cl; * Good definitions; * Timeline guidance - How far back should you
look?; * A checklist; * Criteria to determine what a CI is; * Geographic specific guidelines to be used by
permitters and applicants- to avoid Cl first; * Public education; * Collaborative enhancement to reduce
past problems (e.g. tax rebates or incentives); * A process or procedure on what to look for (a definition)
and how it applies to what we are doing; ï¿½ Specific studies, in-depth studies in certain areas; .
Establishing threshholds; * Getting practical information (in-the-field knowledge); * Need a method to
document impacts over time - standardized - to document long-term impacts from applications. Perhaps
a checklist and the ability to use it consistently by department (would require training to all departments);
. Direction by the Division, the agency, and the state (in statute and regulation) on a Cl definition,
standards on the minimum retention for habitat; * We need multi-media permitting - i.e. we need to look
at everything at once instead of each individual agency looking only at their individual perview. (e.g. the
State of NJ, and also the way EPS inspections are done); * Cls need to be addressed in statute and
regulation; ï¿½ Cooperative agreements between the regulators and the regulated community regarding Cl;
* We need a Department policy saying we do address Cl and a definition of what Cl includes; * Baseline
and monitoring data; * Getting administration to admit that there is a CI problem and not being
compartmentalized - recognizing the other regulations that regulators must deal with. "Rainbow" type
training * Have to have integrated philosophy between agencies; ï¿½ One day training or worksession in
conjunction with the annual conference; * Specific guidance; * Policies; * Data (particularly  in
communities); * A mapping system (kept up to date); * A policy that defines Cl and articulates the way Cl
jepordizes the mission of sustaining fisheries; * Getting the department to simply recognize that Cl exist;
ï¿½ A policy on how to address and balance Cl with the mission for maintaining recreatioinal harvest
opportunities for fish; * A Department policy regarding Cl (There are no regulations, policies, or
guidance. The agency staff know Cl are occuring but need more push from higher levels to address CI);
* Standars and measurements that let anyone I.D. and assess to what degree Cl are occurring; * A
working (user friendly) defintion; ï¿½ Better guidelines from the state; * A mandate; ï¿½ Interdivisional
communication group within the departements; * Need a vision as to what rivers should look like; * Need
better mission regarding Cl; * Coordinated effort between all resource agencies to establish criteria to
I.D. Cl; * Better education for people to see successes not just failures; * More resources to be out there
looking at impacts before they get out of hand - prevention - by the time complaints come in it is too late;
. Access to other agencies' successes and failures in addressing Cl (Information from other agencies); ï¿½
Regulations and implementation manual for the regulations; * Better planning; * Staff and $; * Guidance
or criteria to determine at what point Cl become significant - When do Cl become a problem? - Before
that threshold is reached you should not have to address Cl, but after it is reached you do ï¿½ better
regulations; * definition in statutes with very distinct boundaries drawn/described otherwise could get out

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of hand (e.g., do you consider the tributary of the stream for Cl or the tributary and drainage or the entire
drainage or the entire ocean system?); * additional data for evaluating Cl; * need regulations or use
existing regulations an dpply to spill prevention at smaller tank farms; * use agency data bases already
in existence; * need definition describing how Cl occur; * better understanding by other agencies of
state water rights program and laws; * solid definition and guidance that discusses how CI accumulate
and what should be key elements to look for; * guidance should not make decision as to whether Cl
tolerable - only spark consideration and how to obtain further information; * guidance shouldn't become
policy - should be procedural and not force conclusions; * more guidance from FHWA or any agency with
jurisdiction over projects (e.g. COE and FAA); * more enforcement capabilities; * need staff ,-time, and
funding; *  need guidance from other state and federal agencies like the COE (especially regulatory
agencies); ï¿½ need information on human carrying capacity, resource carrying capacity; * need to describe
what would be considered socially-acceptable limits to viewing resources; * need more specific
guidelines (may already be in the existing DGC documents); * districts need their own definitions; ï¿½ for
more undeveloped areas of districts a definition would help avoid situations where district left with
agency definitions; * need to get state and federal agencies who create project documents for review to
have joint training for reviewers; * need step-by-step process; ï¿½ need better understanding of what a CI is
and easier ways to control them; * make it possible to incorporate into decision making the experiential,
traditional and local knowledge on same level as scientists / biologists; Do not have to have been born
here, could have extensive knowledge; * all agencies just starting to realize a need to address those
issues and what conditions we would like to have included to preserve certain areas (land, social, cultural
values); * like to see ACMP grant a set of funds so could start doing own environmental studies in the
region; * delegate as the authority and they will do what they can in the region; * tools like people, time,
money to do what needs to be done; * don't feel the need for more DGC-type studies - elicits more
frustration; * priority should be on gathering site-specific info; * money should be spent closer to the
problem sites; ï¿½ when we go to get data/staff assistance, local input, there are too few resources; * can't
even get administrative habitat regulations to implement statutes after 15 years, so not sure how Cl
guidance could be established * would be nice to have Cl guidelines specific to Title 16 rather than just
the Air, Land and Water Quality standard; * control over wildlife and birds (terrestrial species) on private
lands not reached like fish in waterways (supposed to be done via DNR land use planning but not
working well); * would be helpful to have a practical, common sense approach to the issue; * very
complex - easy to say we need additional guidance but very difficult to address (not much confidence it
can be done); * DNR does decent job addressing Cl; * need additional statutory powers; * need
definitions; * who should carry responsibility for Cl? (possibly the lead agency?); * need defined support
(and strong enough policy language or adequate ACMP statutes) which when appealed/elevated it can
stand; * would like a report like the previous DGC report but easy to read, digest, identify issues,
problems, solutions; create starting point for decision-makers; otherwise they won't use it; * must have
more than academic information on CI in order for policy-makers to use it * only academic information
seems to be available on Cls -if want real movement from policy makers, must put info in a form that
they can act on * DNR definition needs to be clarified; guidelines should include what DNR wants to look
at for CIs * would be helpful if state would coordinate between regions based on river systems and
watersheds - use of unrecognizable land divisions does not help management - impacts often occur
upstream and flow downstream ï¿½ may be other Cis in the area that the district is not aware of due to
current boundaries of jurisdiction ï¿½ have to recognize that Alaska is different and differences within the
state by region - culturally, environmentally; * regulations do not fit every place * can't expect districts to
do all of this work, especially with budget cuts * structured protocols to asess functions of terrestrial
systems (also with wetlands); * would like greater use of local district plans and local government with
planning and zoning authorities - most Cl problems are in communities with P &Z so the government
structures are in place with comprehensive and district plans and enforcement powers * fees to increase
funding for more Section 401 certification staff ï¿½ structured protocols to assess functions of terrestrial
systems, such as through regulatory BMPs; this gets down to functional attributes of the area...if
terrestrial, need a definition of the functions - once they are known there should be protocols in place to
assess and protect them and determine if they are well maintained over time? * would like money to hire
local environmental monitors ï¿½ need greater use of local district plans and local government authorities,


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especially as links to non-point source solutions * most problems are in a location with planning and
zoning, government structure, and coastal district plans and enforcement powers to address non-point
sources of pollution * need more work done on subtle indicators of biological stress (such as enzyme
changes, rather than simple presence of infauna, for instance) * need regulatory BMPs for certain uses -
the responsible land management agency should have them, such as DNR for agriculture * for a small
community like ours, we can barely afford to do the basics such as adopt a CMP, much less these
"extras" (studies, investigations) because we lack the resources * a standard checklist might be helpful if
it is possible, it would have to be adopted generally so it is consistent among communities * need
definite regulatory language and mandate; * NEPA provides good mandate and methods but -leed state
level method; * need to use what is available, cost-effective, time efficient, need management
assessment and methodology * Kenai River 309 study is good on main stem if river but does not address
tributaries; * COE used cookbook approach; * no tools exist to deal with the intangibles, there is a
disparity of opinions and anyone can refute a position on intangibles; * Kenai River 309 tried to address
all issues then groups either warped or ignored findings.

15.    Do  you have any closing comments or recommendations  regarding how  cumulative
       impacts are - or could be - addressed by state agencies or districts, and if so what are
       they?

ï¿½ Don't use "Homeless stipulations" on coastal consistency findings which the agency has no authority to
enforce, such as stips on reclamation of a private gravel source over which DOT&PF has no authority; ï¿½
funding so communities could obtain the professional expertise or technical assistance; * The
stakeholder is the coastal district so put Cl into the CZM plans - make it a section in the plan; * No
unfunded mandates - if there are Cl regulations make sure they are funded; * ADF&G needs clear policy
direction through all branches doing Cl assessment; * The shortfall is with coastal districts not realizing
Cl's exist - in the search for economic development Cl's have been ignored; * Natural conditions need to
be taken into account (e.g. natural levels of pollutants) ; * Baseline studies are needed in certain areas; .
Provide more $ for field presence; * Track impacts as they occur and minimize them; * Sort through the
ACMP (it is an obstacle) clean up overlapping authorities, straighten DGC's interpretation, etc,; * There
needs to be a documented policy - we live in the short-term as brush fire specialists - we need to move
toward long-term solutions; * DEC has gotten into fees for inspections and technical assistance - the
process is not cheap for communities - we should consider "mulit-media" fees; * The CMP already does
it - not for Cl in particular - but it "zones" areas for development, in essence it controls where Cl will be
allowed. It is ridiculous for Congress to make the states address these issues, it should only encourage
them; * The definition should be tightened up - it should be measureable, have standards, better specific
criteria on which to judge impacts for adjudicators; * Policies in coastal programs are not enforceable; -
The state needs to come out to the communities to educate local leaders on the regulations i.e. better
outreach and communication. There is a lack of training in the small communities, a mayor with multiple
responsiblities has little time or training to deal with the issues and regulations of something like CI; ï¿½
Impacts from  log transfer facilities need  enforeable standards/policies,  especially a  restoration
policy/guidance; * We have to be careful that Cl assessment does not just become another tool for
stopping development.  That is why you need a threshhold - addressing future impacts is too much
guesswork; * Just do it - make it a priority. Require Cl assessment in permit reviews and ACMP
regulations; ï¿½ The big problem is we need baseline data, even with good policy direction you need good
data, with good baseline and monitoring data we could tell what might happen in a cumulative sense; ï¿½
Need to work together more - agency staff need to look past their narrow job descriptions, not becoming
so compartmentalized; * Pre-planning at communities on what kind of development they want to see in a
10-20 year timeframe; . Prefer to have Cls addressed at the state level - because the local level has no
time, but the local level could help provide information; ï¿½ A uniform definition and specific criteria on
when the Cl has occured - is it with the first house in the development or the 5th?; * The agency needs to
work closer with other political entities on oversight of land use to get information to them so they
incorporate ADF&G information in land use decisions - be more proactive - decisions are currently made


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in a vacuum; * Need help for smaller cities from agencies - we don't have the staff; * First the state
government, and the ADF&G should take responsiblity; * The reduction in budgets means a loss of
employees which means we must do more with less. Cl are important but any new regulations must take
into account limited staff and time; * People need to have an open mind regarding Cls - CIs are                     I
dependent on the person and their philosophy - thus feelings shape the CI discussion. We need to focus
on the successes too; * Need more help (staff); * address more realistically particularly relating to real
impacts relative to overal natural, economic, social or cultural environment; * tailor to local conditions
and relate to problems facing districts; * definition would set limits on application of CI terms; * time is a
limiting factor in addressing Cls; * people need to understand agencies use data bases in making
decisions; * funding not there for enforcement (southeast); * baseline data lacking for decision-making
re: Cls (e.g. water resource data, quantity, quality); * do not include highly speculative impacts in
definition of Cl; * do not extrapolate to extreme; * be sure there are really impacts before requiring
changes by applicant - provide more certainty that effects are there and have a high probability of
occurring; * characterize CI objectively, not subjectively; give criteria under which a Cl would become
significant; * any change is not necessarily significant; *need to measure over the long term; * add
human and resource carrying capacity analysis to evaluation of CI; * districts experiencing Cl should talk
to agencies regarding their experiences and level of frustration - not in written form only but "people-to-
people" so as to increase communication; * get baseline data up front; * seek practical solutions; * talk to
local people for creative approaches to problems; * maintain teamwork approach; * use agency files and
incorporate information into decision-making process; * improve lines of communication between local
communities and resource agencies; * need good cost-effective methodologies; * talk about political
ramifications; need better implementation at the local level * bigger picture may be much different - not
good at looking at the whole picture; tend to address what is most obviously their responsibility; * EA and
EIS processes are cumbersome and not always practical; don't wait for CI study - 309 study on Kenai
River was 2 year study and information is constantly changing; * need dynamic data collection system; ï¿½
information must gain ownership from the user groups and local boards; * must use the data and there
should be time to let it be absorbed and built on over years to see changes; * agencies with big
responsibility to address Cl are told not to do it (e.g DFG); * applaud DOT for having other agencies on
their planning teams regarding projects, but there is not adequate funding for this, its like blood from a
turnip * agree on a definition of "adverse" Cl; * write out protocols to address them * provide adequate
staffing to verify through monitoring whether existing controls are working * districts could look into
protecting ocean/coastal bottom (i.e. dragging /fishing bottom scour) which dramatically changes things
and washing up on shore; * elders are seeing marine organisms on the beaches that they've never seen
before, the district needs to emphasize this problem - possible catastrophy could occur in the absence of
regulatory authority; * ACMP should not be limited to inland waters, but consider coastal waters issues;  
need a lot more interagency coordination on difficult projects; * can only do it if environmental people
know what is going on early in planning stages; * not enough people, time (e.g.DOT has 2 regions that
do engineering and project construction  in the PWS area - have to get to know two offices/people in
order to work with them); * state does woefully bad job of training people so train them to work with these
issues; * find some dedicated funding to be able to address these problems; * project proponents should
pay for the Cl asessment work; * generally people know what they're trying to do but a matter of not
being able to (lack of money); * now have impaired water bodies program for the big ones but not for
others because spotlight is on the big ones with the press and public; * many small projects need to be
addressed for Cis to be addressed overall; * the state always seems to need more information & studies,
yet no action; * could move too quickly and cause damage [to current decision making processes]; . not
much money to be thrown at these issues; so the approach should be pragmatic and easy to implement;
* a "cautionary comment" re: a definition of Cl - and trying to make it homogenous by compiling all
jurisdictions; each agency has developed different definitions and should be allowed to do so; otherwise             I
rename powers of each agency or people "buying into it"; it would be better to beef up each agency's
definition and understanding of their definitions than to try to blend them all * no easy solution; * need all
agencies, district, proponent to be part of process; * need some improvements; * those who make the
rules should understand the real issues and be able to articulate and enforce them; * Cl is an issue for
state resources, it would be an impossible mess if individual communities were required to come up with


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U      ~~methods - just getting a CMP adopted is alot for a small community - too burdernsome to add Cis; * a
        standard approach would have to be adopted generally so it is consistent among communities, a huge
       task - it is not practical for communities to do it on their own * local knowledge should be considered
        more than it is; * local say should be weighed more heavily than other non-local people's say; a regions
        are so different and reviewers don't pay attention to what is best for local area's people; 0 local
       community should be given general guidelines for one thing; * let community determine what level of
        service/quality of life they want to maintain; * best decisions and expenditures are made locally.
        Thank you very much for your time and contributions to this study.

        We will write a report based on the interviews we are conducting. Are you interested in seeing a
3 ~~copy of the draft report? If so, it will be sent to you for your review and comment later this
        spring. ___Yes  ___No

        [If Yes] I'd like to confirm that we have the correct address for you [read the address on cover
I     ~~sheet and make any corrections].

3      ~~Thanks again for your time.
















~~CuuaieImatinAsk6295

           I~~~~~~~~~~~~~~C1



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             Appendix D                                               I
Sites Where Cumulative Impacts are Occurring,
    As Observed by Survey RespondentsI

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                                         APPENDIX D
                      Sites Where Cumulative Impacts Are Occurring,
                            As Observed By Survey Respondents

        Site or Area            Resources or Uses Affected          Cause(s) of Cumulative
                                                                              Impact
STA'WDSLS ' S:|0- 'oc or   'e 0'Af'fet'e'd-i::t -             _  I - :  I:-- - -  tyS:tEE;00. .. .   ..
every small village and town in  village economies, quality of     money costs for drinking water
the state                        life, if we do something they     testing, air monitoring, solid
                                 can't afford to fix the problem,   waste tests, etc., etc.; fee
                                 if we don't they get sick -      based response, we go out, we
                                 regulatory compliance costs      find problems, we charge, but
                                 the community, costs of          they can't pay
                                 compliance w/ all water, air,
                                 solid waste costs is
                                 bankrupting communities
95% of all the small villages    inadequate, poor drinking         tundra ponds make it
                                 water; solid waste disposal      impossible to site solid waste,
                                 impossible, wastewater           drinking or wastewater
                                 disposal impossible              facilities, communities lack tax
                                                                   base to do so
rural Alaska villages            environmental (WQ and land)    solid waste accumulation &
                                                                   improper management of solid
                                                                   wastes - not maintained,
                                                                   unsanitary, unregulated
village tank farms - Barrow,     environmental, human health    fuel contamination
Nome; and other fuel storage
like Eielson AFB and
Fairbanks (refineries)
all transportation facilities like   environmental, social,        direct effect of
roads, highways, airports, ferry  economic, cultural               removal/modifying the
terminals, public buildings                                        resource for the project;
                                                                  wetlands, rivers, fish and
                                                                  wildlife habitats; increased
                                                                   noise and congestion;
                                                                   increased access to new
                                                                   development; impacts to
                                                                  cultural or
                                                                   historical/archeological sites
list of impaired waterbodies     water quality                    sewage, runoff, point source
(statewide list)                                                  discharges over decades
placer mining sites              environmental                    multiple mines on a stream
                                                                  add up over time to create
                                                                   impact to water quality/habitat
development in all larger        social economic impacts, local   growth in the state, limited land
communities (Juneau,             governments to expand             to develop = development
Anchorage, Fairbanks,            services, natural wetlands and   concentrated in site specific,
Ketchikan, Kenai Peninsula)      streams                           increase in road length = more
                                                                  wetlands filled, more stream
                                                                  crossings, more relocation -
                                                                   more roads, etc., etc.




 Cumulative Impacts in Alaska                                                             6/29/95
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        Site or Area             Resources or Uses Affected           Cause(s) of Cumulative
                                                                               Impact
state special areas (Critical     environmental (fish streams -    recreation, oil and gas,
Habitat Areas, game refuges)    water levels for overwintering,    logging, timber sales, flying
                                 spawning), wildlife               services, grazing activities
                                  overwintering
statewide                         local users and existing           tourism growth causing
                                  lifestyles                        conflicts, impacts starting to
                                                                   add up
                               i-    il-... -- 0 0-0 ---0 0.....i..liS-
Hobart Bay (NE of Sitka)          water quality and fish habitat     logging and road building
(several streams on 303D list)
Baranof Island (several           water quality and fish habitat     logging and road building
watersheds, Nixon Creek,
Rudman Creek, Starrigavin
Creek, Akwasima Creek)
Kruzof Island (NW of Sitka)       water quality and fish habitat     logging and road building
Kuiu Island (Saginaw Creek        water quality and fish habitat     logging and road building
and Security Creek)
Prince of Wales Island (Staney  water quality and fish habitat       logging and road building
Creek, Harris River/Fubar
Creek, Rio Beaver, Sligle
Creek, Sal Creek, Cable
Creek, 12 Mile Creek, 3 Mile,
Dora Lake, # of Native
Corporation sites)
Prince of Wales Island Forest    old growth forest, fish streams,   economic development of
Highway Improvements              wetlands                           mining, logging, etc.; access
                                                                    into new areas or improved
                                                                    access = Cl and secondary
Skagway                           erosion onto the roadway,          crowded conditions, gravel
                                  slope degradation, boulders on   extraction and road cut; mining
                                  the road, road to major tourist    activity of the hillside
                                  destination
Skagway                           personal hazard, sewage and    recreation vehicles, tenters on
                                  water connections                 hillside
Mendenhall wetlands               water quality, environmental       sewage from residential
                                                                    development
City of Hoonah                    subsistence - salmon streams,   logging on Sea Alaska lands
                                  deer distribution, social/cultural  will start up this year - taking
                                  economic impact to residents    place outside the city (but it
                                                                    does give economic benefit to
                                                                    the residents)
Monti Bay                         scallops, subsistence use          human activity outfall from
                                                                    cold storage and sewage
                                                                    facility and marine traffic
Situk River                       quality of experience for both    commercial and sport fishing
                                  commercial and sport              and recreation and tourists
                                  fishermen
Lost River (Yakutat)              quality of experience for both    commercial and sport fishing
                                  commercial and sport              and recreation and tourists, to
                                  fishermen, to a lesser degree     a lesser degree in general and
                                  in general and less on            less on commercial fishing
                                  commercial fishing

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        Site or Area             Resources or Uses Affected         Cause(s) of Cumulative
                                                                              Impact
Ankau (Yakutat)                  subsistence use - recreation      sport fishing
Yakutat Area                     visual experience, habitat,       logging
                                 economy
Thorne Bay                       fish, marine environment          hydrogen sulfide accumulation,
                                                                  bark from log transfer
                                                                  facility/storage
Thorne Bay Harbor                fish                              sort yard log transfer facility,
                                                                  sewer discharge, harbor, boat
                                                                  grid, cold storage permit - sited
                                                                  to cause least environmental
                                                                  impacts while also meeting
                                                                  economy consolidates impacts
Thorne Bay                       water quality, bottom habitat     log transfer facility, community
                                                                  runoff, roads, boat harbor, bark
                                                                  deposition (hydrogen sulfide)
Thorne Bay                       water quality and air quality     logs, pulp mill

Thorne River                     fish habitat, visual aesthetics,    increased use over time will
                                 fish stocks                      probably experience bank
                                                                  erosion, outboard motor
                                                                  pollution, trash
Thorne Bay                       aquatic life and habitat          nonpoint source pollution,
                                                                  development
Kake watershed, Gunnick          floods, water turbidity           cumulative impact of logging
Creek                                                              sediment
Straits right out of town (a     clam subsistence                  fish slurry (from processing),
Southeast community)                                               cold storage outfall
Kuiu Island                      subsistence                       logging, blowdowns
Port Camden                      dog salmon subsistence            logging
Security Bay                     salmon streams subsistence        logging sediment - lake has

                                                                  now 10 feet
Comstock Road area of Haines  water quality in Sawmill Creek   population growth & residential
                                 - fecal coliform bacteria in     development with failing septic
                                 creek (anadromous waterway)   systems; fill, culverts,
                                                                  diversions, runoff into creek
Ketchikan Gateway Borough        water quality                     ownership for wastewater

                                                                  unplanned development
Whipple Creek (Ketchikan)        drinking water                    logging
Bear Valley (near Ketchikan)     not a nonattainment area but    wood stoves
                                 has problems they are
                                 monitoring
Ward Cove (Ketchikan)            water quality, crab fishery       sludge deposit, pulp mill
                                 (personal use), fish habitat     (numerous discharges),
                                                                  seafood processor, air
                                                                   emissions, leachate
Ward Cove                        water quality                     mill, homes, putting runoff into
                                                                  the cove
Ward Cove                        air quality                       wood smoke in Bear Valley,
                                                                  from mill, # of wood stoves


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        Site or Area            Resources or Uses Affected         Cause(s) of Cumulative
                                                                            Impact
Ward Cove                       environmental (water quality)    Ketchikan Pulp discharges
                                                                 organic material
Ward Cove                       impaired waterbody               discharges (pulp mill and other
                                                                 industrial uses)
Ward Cove                       extensive violation of water     Ketchikan Pulp discharges
                                quality standards, dissolved    organic material; organic mats
                                oxygen, biological oxygen       form on bottom of cove -
                                demand, dioxins
Ketchikan                       water quality                    waterfront activities
Tongass Narrows (near           alluvial fan at mouth of salmon  fill in the narrows because so
Ketchikan)                      stream, kelp beds, fisheries     much of the tidelands had
                                migration and rearing,          been filled
                                reduction of habitat
Silver Bay (Sitka)              habitat, water quality for use by  pulp company discharges
                                aquaculture farms; recreation
impaired waterbodies in the     water quality; fisheries         urban development,
City and Borough of Juneau      resources                        stormwater, encroachment into
                                                                 riparian areas
Juneau                                                           Road
Juneau Airport                  wetlands, anadromous fish        expansion fills, stormwater
                                streams                         runoff
Juneau's downtown waterfront   land use (a resource limited in   tourism - tremendous
                                 space); social resources        downtown impact mostly due
                                                                 to cruise ships
Gastineau Channel (Juneau)      water quality                    cruise ships, marine facilities,
                                                                 discharge sites
Juneau                          adverse economic effect          Kensington and AJ mines add
                                 (Kensington mine - increase     to prior effects of Greens
                                 demand for public services,     Creek mine (though that is now
                                 mitigation required to fund a   closed)
                                 new school)
Mendenhall Valley               Air quality, non attainment      residential growth, wood
                                 area                            stoves, i.e. when all stoves
                                                                 added together = Cl and road
                                                                 dust
Port of Juneau                  visibility                       marine vessels, cruise ships
                                                                 arrivals and departures = CI
Lemon Creek (Juneau)            not a nonattainment area but    wood stoves
                                 has problems they are
                                 monitoring
Auke Bay / Spuhn Island         local users                      commercial operator wants to
(Juneau)                                                         put in a kayak dock, if you
                                                                 allow it to go in, others
                                                                 impacted
                                 habitat loss, water quality, fish   wetlands fills, urban runoff,
Jordan Creek, Lemon Creek,      habitat loss                     failed septic, some seafood
Switzer Creek, Mendenhall                                        processors, outfalls, some
River, Gastineau Channel                                         industrial
(Juneau)
Gold Creek (Juneau)             fish habitat (fish kill)         water appropriation



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         Site or Area            Resources or Uses Affected          Cause(s) of Cumulative
                                                                               Impact
 Silver Bay (near Sitka)          hatchery, marine mammals,         pulp mill, road runoff, wood
                                  active community fishing use,    waste leachate, sludge deposit
                                  had had seafood advisories,
                                  subsistence
 logging in southeast Alaska      social and environmental          amount of timber harvest that
                                                                   industry wants verses
                                                                   competition for tourism,
                                                                   recreation uses,
 25 streams in Southeast          salmon habitat loss               logging practices
                                  (overwintering)
SOTILENTRAL.s ALAStl S TS-
 mouth of Deshka River            social and environmental          over use by the public
 shore-based fisheries            social and environmental          amount of competition for sites
                                                                   for fishing/taking of fish is
                                                                   increasing
 groundwater (along Hillside,     drinking water, groundwater       onsite wastewater further
 from Rabbit Creek to Eagle                                         downhill gets worse
 River, even on the Kenai
 Peninsula)
 Anchorage wetlands (Furrow       public use of wetlands,           continual loss of wetlands in
 Creek condo development east  greenbelts and quiet places,         the bowl, revisions in
 of New Seward Hwy, Tudor         habitat (wide variety), nesting    regulations decreases agency
 and C St.)                       and brood for water               ability to protect, has allowed
                                                                   development to occur, not
                                                                   effective plan to coordinate.
 freshwater wetlands in           wetlands                          community expansion, regional
 Anchorage Bowl (Klatt Bog,                                         commercial industry,
 Connors Bog, Turnagain Bog)                                        roads/utilities, human use
                                                                   activity
 all Anchorage Bowl stream        riparian terrestrial habitat,     community expansion, regional
 corridors (Furrow Creek,         water quality                     commercial industry,
 Rabbit Creek, Little Campbell                                      roads/utilities, human use
 Creek, etc.)                                                       activity
 Chester Creek                    aquatic and contact recreation   light industry, auto repair,
                                                                   landfill leachate, urban runoff
 Chester Creek                    riparian terrestrial habitat,     community expansion, regional
                                  water quality                    commercial industry,
                                                                   roads/utilities, human use
                                                                   activity, storm drain nonpoint
                                                                   source
 Ship Creek                       fish habitat                      appropriation of water
 Anchorage Bowl, Ship and                                           urbanization
 Campbell Creeks
 303D List (Ship Creek from       fish, aquatic life, recreation,   military (Army and Air Force),
 Davis Highway Down)              drinking water                    golf course, storm water, junk
                                                                   yards, ARCC = runoff
 lower Ship Creek                 riparian terrestrial habitat,     community expansion, regional
                                  water quality                    commercial industry,
                                                                   roads/utilities, human use
                                                                   activity
 Campbell Creek (midreach)        aquatic and contact recreation   urban runoff, light industry,
                                                                   zoos and horses

   Cumulative Impacts in Alaska                                                             6/29/95
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        Site or Area            Resources or Uses Affected        Cause(s) of Cumulative
                                                                           Impact
Chester Creek, Campbell         water quality                   stormwater system, fecal
Creek (Anchorage)                                               coliform bacteria (from
                                                                animals, humans), sediments,
                                                                heavy metals
Dutch Harbor                    environmental (water quality -   filling of nearshore habitats,
                                fish processing wastes, fill,   deposition of crab wastes on
                                hydrocarbons)                   seafloor result in water quality
                                                                problems and DO standards
                                                                violated from increased level
                                                                of BOD; nearshroe habitat
                                                                impacted from fill for docks
                                                                and support facilities; oily
                                                                wastes from buried
                                                                underground storage tanks and
                                                                boat activity/bilge pumping
Beaver Inlet, Unalaska area     environmental (water quality)    seafood processing wastes
                                                                accumulated on shoreline;
                                                                numerous floating processors
                                                                can go into areas like Beaver
                                                                 Inlet under a GP and discharge
                                                                yet inlets lack adequate
                                                                circulation to flush wastes
docks and fills, Unalaska       environmental (water quality    fills and docks, especially
                                and fish habitat)               bulkheads, can destroy
                                                                 intertidal habitats
south Unalaska Bay (Dutch       nearshore marine environment   seafood processing
Harbor)                         & habitats; local               dischargers EPA issued
                                beachcombers complained         permits w/ allocated shares for
                                about waste on beach            BOD & TMDLs
Dutch Harbor                    harbor                          seafood processing
shorelines to increase          fish habitat                    shore-based processors and
processing and developments                                     floaters due bottomfishing
                                                                 increase = accumulation of
                                                                waste
Unalaska Inner Harbor           loss of water quality & near    harbor development,
                                shore habitat                   bulkheads, fish processing,
                                                                 sediment deposition from
                                                                 vessel washing
Unalaska                        marine resources, crab, bottom  commercial fisheries in Bering
                                fish, waterfowl, marine         Sea and North Pacific and
                                mammals                         pollution from cannery
Unalaska Bay                    marine water quality            discharges from fishing
                                                                 vessels & fish processors
Iliuliuk Bay & Margaret Bay     loss of herring spawning, small
                                subsistence fishery
Akutan Harbor                   one mile of biological          processing plants, a new 800'-
                                resources now displaced,        1000' sheetpile bulkhead
                                including 12-15 acres of
                                shellfish beds, previously used
                                for subsistence
Akutan Harbor, King Cove        shore based processors          waste accumulation
Bay, Popof Strait


  Cumulative Impacts in Alaska                                                          6/29/95
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        Site or Area             Resources or Uses Affected         Cause(s) of Cumulative
                                                                             Impact
Akutan                           marine resources, crab, bottom  commercial fisheries in Bering
                                 fish, waterfowl, marine          Sea and North Pacific and
                                 mammals                          pollution from cannery
Atka                             marine resources, crab, bottom  commercial fisheries in Bering
                                 fish, waterfowl, marine          Sea and North Pacific
                                 mammals
Nikolski (Umnak island,          marine resources, crab, bottom  over harvest of Bering Sea
Aleutian Is.)                    fish, waterfowl, marine           fisheries
                                 mammals
Adak (Aleutian Is.)              wetlands                         landfill
Adak (Eskimo Creek)              water quality                     septic and hydrocarbons
City of Dillingham (bluff and    housing eroding into the river    wave action (tides), wind,
SE corner erosion - Nushigak    (150 feet of erosion), sewer       human activity (housing and
Bay)                             line exposed                      sewer line)
Dillingham area                  banks, streams, wetlands         docks and facilities change
                                                                  bank stabilization/erosion, road
                                                                  crossings from the new roads
Nushagak/Mulchatna River         increased demand on resident   increased number of
Drainages (N of Dillingham)      and anadromous fisheries in       commercial/ recreational
                                 these drainages, & on            facilities on state and private
                                 landscape and riparian areas     lands, largely for sportfishing
                                                                  and ecotourism
mouth of the Stuyahok and        Native Allotment and old          one of the most heavily used
Mulchatna Rivers (confluence)   village (historic site) quality of   public used sites, float planes
                                 experience and conflicts         (air taxis)good fishing, beach
                                 between users                    for camping, standoffs over
                                                                  trespassing, litter, heavy local
                                                                  and subsistence use
Bethel Seawall                   river channel is changing,        scour might be due to bank
                                 more water in overflow           hardening project or natural
                                 meanders; subsistence use &    circumstances
                                 transportation / access may
                                 change overtime
City of Bethel                   air quality, water quality in    gravel roads and particulate
                                 lakes and ponds                  from roads affecting
                                                                  surrounding village (health,
                                                                  quality of life, operation of
                                                                  equipment)
Goodnews Bay, Lower                                                platinum occurs there/copper
Kuskokwim
Red Salmon mining site above   traditional fishing, trapping,     placer mining up to 1980s,
Platinum (Kuskokwim Bay)         camping on Salmon River          disregard for current
                                                                  regulations
Cape Vancouver                   effect on bird population         lots of lubricants discharged
(Nelson Island, SW of Bethel))                                    into marine waters, offshore
                                                                  fishing, cumulative impacts
                                                                  from activities in federal waters
Salmon River, S of Goodnews   physical disruption of fisheries   historic mining operations -
Bay, & Tuluksak River (8-10      (river channels narrower and      floating bucket line dredges,
miles), & Bear Creek             shorter - altered habitat).       since 1929-1979 on the
                                 On Tuluksak, subsistence and   Salmon, since 1926 on the
                                 commercial fishing               Tuluksak;


  Cumulative Impacts in Alaska                                                             6/29/95
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        Site or Area             Resources or Uses Affected         Cause(s) of Cumulative
                                                                              Impact
Tuluksak River headwaters        cultural impacts - traditional    Nyak Mining company placer
                                 cemetery, hunting grounds;       operations since 1930s (prior
                                 fish and wildlife destroyed for    to regulations)
                                 several miles, ( large
                                 sociological effect -villagers
                                 have to go further to
                                 subsistence fish), cut off water
                                 supply, heavy metals in water,
                                 elders dying of cancer
Tikchik River (N of Dillingham)   vegetation damage at variety    increased use, funding
                                 of areas along 60 miles of
                                 river, increased litter, and
Koktui River, Pebble Copper      Rainbow trout fishing             potential for largest open pit
deposit (Lake and Peninsula                                        copper mining in North
Borough)                                                           America, tailings - see
                                                                   Appendix of Lake & Penn
                                                                   public hearing draft
Agulapak River public camping  vegetation damage, trails           increased use adding over
at north end (Wood Tikchik)      damage, and creation, fish        time
                                 stocks impacted
North End Agulapak River         quality of experience is          increased use
                                 changing
Nishlik Lake shoreline (SW of   litter, vegetation damage, drain  dramatize increased public use
Sleetmute)                       it                                due to hunting pressure
increased competition at broad   quality of experience, litter,    increased commercial use -
number of locations in Tikchik   vegetation damage                 guide operations
park
Port Graham (Nonwhaleek,         cultural concerns and water       aquatic farming, logging
English Bay)                     quality                           (transfer facilities) conflict over
                                                                   water quality
Ayakulik River (S end of         major salmon habitat, kings,      major commercial seine
Kodiak Island)                   coho, reds; prime bear habitat;   fishery off mouth of river;
                                 social impact from more          floaters on river - sportfishing,
                                  people                           wildlife viewing; "overflow" of
                                                                   fly-in sportfishermen as other
                                                                   areas become more crowded
                                                                   (King Salmon)
Anton-Larsen Bay (Kodiak)        fisheries                         set net, commercial fishing,
                                                                   aquatic farming
Pillar Creek (Kodiak)            fish habitat                      appropriation of water
Near Island Channel, Kodiak      Near Island King Crab nursery   expansion of small boat
side                             area                              harbor, additional industry,
                                                                   float plane facility in near
                                                                   future
Kodiak                           viewshed, water quality           logging, recreation
                                                                   development
Karluk River and Lake            same as Ayakulik River            same as Ayakulik River
(Kodiak)
numerous Kodiak fishing areas   habitat destruction;               increased numbers of people;
accessible from road system      competition amongst user          a church brings busloads of
                                  groups                           people 200 at a time



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        Site or Area             Resources or Uses Affected         Cause(s) of Cumulative
                                                                              Impact
Susitna River                    fisheries                         logging, recreation,
                                                                   urbanization
Little Susitna JDeshka           environmental /socioeconomic   increased water traffic results
/Yentna Rivers, etc.                                               in increased erosion of river
                                                                   banks and damage to fish and
                                                                  wildlife habitat, water quality
                                                                   and tourism; increased road
                                                                   traffic results in increased
                                                                   noise and disturbance and
                                                                   runoff; increased development
                                                                   changes habitat, drainage,
                                                                   groundwater; changes to
                                                                   economic, cultural aspects,
                                                                   quality of life
Anchorage area refuges (Cook   waterfowl (spring and fall          increased public use,
Inlet, Susitna Flats State       staging areas) and nesting        unenforced land use activities
Game Refuge)                     habitat                           (trespassing, cabins), illegal
                                                                   overland access to sites
six recreational rivers across   user groups are affected          power boating & increased
Cook Inlet - Susitna,            no proof of habitat destruction    recreational pressures on
Talachulitna, others                                               rivers
Matanuska Valley Moose           moose habitat                     timber harvest, grazing
Range                                                              activity, support facilities,
                                                                   timber harvest not promoting
                                                                   browse as required.
Susitna Flats Refuge             fish streams, waterfowl, bears    potential oil and gas, road
                                 and moose                        development, duck shacks,
                                                                   sport fishing
Big Susitna/Matanuska Rivers   environmental/socioeconomic    river course changes naturally
                                                                   and affects development
core area between Palmer and   socioeconomic                       increase population results in
Wasilla                                                            increased crime and increased
                                                                   concern with safety
core area rivers                 environmental/socioeconomic    erosion of rivers affects
                                                                   development and conversely
                                                                   development affects riverbed
                                                                   stability and habitat
Chitina / McCarthy area          groundwater, litter in heavily    influx of people during summer
                                 used areas                       - visitors, fishers without the
                                                                   infrastructure/ services for
                                                                   them
Cordova                          infrastructure in Cordova         road, increased tourism,
                                                                   development, mining, oil, and
                                                                   timber
Whittier                         Prince William Sound              access
Two Moon Bay, Irish Cove,        fish and wildlife habitat, water    year to year no problem - over
etc. (Port Fidalgo, Prince       quality, recreation and tourism   a long time (10 years) CI -
William Sound)                   biggest                           logging
Prince William Sound             water quality, fisheries          oil spill, commercial
                                                                   overfishing, logging, runoff
                                                                   from activities on uplands



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        Site or Area             Resources or Uses Affected         Cause(s) of Cumulative
                                                                              Impact
Site?                            money for city (Not being able   over regulation, regulations
                                 to operate container terminal)    imposed by feds make
                                                                  financial impact to city
Deep Creek                       fisheries and wildlife            urbanization
Deep Creek at Seward             fishery, quality of experience    more and more people fishing
Highway                          decreased to local residents      there over time
all Kenai roadside streams       fisheries, wildlife, marine       ecotourism, fishing, large
(Deep Creek)                     mammals, birds and their          numbers of people
                                 habitat
Portage Creek (Turnagain         king salmon fishing               heavy use are for short
Arm)                                                               duration
Glacier Creek (Near Girdwood)   contact recreation                 despite NPDES permits
                                                                  (mixing zones) is causing
                                                                  impacts
Anchor River                     fisheries and wildlife            logging in headwaters
Ninilchik                        fisheries and wildlife            public use
Crescent River (near Tuxedni                                       primarily logging
Bay)
Birch Creek                      Drainages, vegetation, aquatic   placer mining by a bunch of
                                 life, fish                       individual placer operations
                                                                  past and present
Afognak Island                   fish and wildlife habitat, water    year to year no problem - over
                                 quality, less so on recreation or  a long time (10 years) CI -
                                 private land                     logging
Captains Bay (Unalaska Bay)    nearshore marine habitat, was   safe harbor, vessels were bilge
                                 used for subsistence gathering   pumping, ship washing and
                                 of mussels, clams                discharging effluents
MacNeil River                    environmental, social, cultural   increased number of people
                                                                   attracted to view wildlife
Lake Iliamna (northern) and      environmental (fish and game)   getting close to threshold for
Lake Clark                                                         subsistence and visitor
                                                                   industry/recreational hunting
                                                                   and fishing; guiding; economic
                                                                   activities may impact
                                                                   subsistence resources
Cook Inlet                       fisheries resources               oil & gas development and
                                                                   exploration
Cook Inlet (lower Kenai          subsistence use and the           Valdez oil spill, commercial
Peninsula, inner and outer       resources, salmon, marine         harvest and competition for
Kachemak Bay, upper Cook         mammals, bottom fish              resources
Inlet, Susitna Basin drainages)
Cook Inlet                       economic                          where oil and gas lease sales
                                                                  are stopped or delayed has an
                                                                   economic effect - no new
                                                                   discoveries
Cook Inlet mineral                                                 Red Mountain citronite,
development                                                        Johnson River gold, silver,
                                                                   zinc, Beluga coal
Kachemak Bay                     water quality & fisheries         intensity of use - too many
                                                                   sites in one area; conflicts of
                                                                   users


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                                               D-10








        Site or Area             Resources or Uses Affected           Cause(s) of Cumulative
                                                                               Impact
Resurrection Bay's east side -   similar to Kachemak Bay            similar to Kachemak Bay
Thumb Cove, Humpy Cove
Kachemak Bay (Jakalof Bay,        Social/Biological impacts         high recreation density,
Kasitsna Bay, Peterson Bay,       viewshed, lost crab fishery,      increasing over time, fishing
Halibut Cove)                     clamming                          increase, camping/hiking areas
Kachemak Bay (critical habitat   water quality decreased, fish      shoreline development,
area)                             and shellfish could affect        particularly on-site pipes into
                                  aquatic farms, human use of       bay
                                  fish and shellfish
Fox River Flats                   wildlife habitat, recreation uses   grazing leases
Fox River Flats                   grasses trampled and water        grazing
                                  fowl habitat decreased
Caribou Hills area                social, political effects on cabin  state decision to authorize
                                  users; increased pressure on      initial trespass cabins, then
                                 trails, hunting, moose            increase in use of trespass
                                                                   cabins by new users wanting to
                                                                   establish rights
Resurrection Bay (Thumb           recreationalists, social impact,   overcrowding of boating
Cove and Humpy Cove)              cabin owners, anchorages          potential conflict with upland
                                                                   owner and crowing in cove or
                                                                   aquatic farm in cove
Funny River Bridge (over          Kenai River wetlands loss         increased residential
Kenai River)                                                        development
Kenai Peninsula anadromous    fisheries resources; social &         conflicting uses 7 degradation
rivers: Kenai, Kasilof, Anchor    economic impacts                  of habitat, other complex
Rivers                                                              issues
Kenai Peninsula salt water        water quality                     pollution from hydrocarbons &
harbors: Mouth of Kenai River;                                      waste disposal
Homer Small Boat Harbor;
Seldovia Small Boat Harbor;
Seward Harbor & coal facility                                       coal loading
Kenai Peninsula                   fisheries and wildlife and their    logging, tourism, commercial
                                  habitat                           fishing, recreational fishing
                                                                    (economies are driving it)
Kenai River                       fisheries and wildlife and their   development and recreational
                                  habitat                           fishing
Kenai Peninsula/Kenai River       fisheries and wildlife            no planning, filling wetlands,
                                                                   stormwater use
Kenai River                       fish habitat, recreational        fishermen / tourists trampling
                                  resources                         river banks
Kenai Peninsula                   social, cultural, environmental    overfishing/too many people
                                                                   and lack of road to other areas
                                                                   to reduce impacts to this area
Kenai River                       environmental - recreational,     projects along the river
                                  commercial, personal dipnet
                                  fisheries;








  Cumulative Impacts in Alaska                                                                6/29/95
                                                D-l I








        Site or Area             Resources or Uses Affected         Cause(s) of Cumulative
                                                                              Impact
Kenai Peninsula (Kenai River    fish activities, wildlife habitat  changes in land ownership -
and other major salmon           that have a relationship to the    mixture, private ownership of
drainages, Anchor River, Deep   streams, loss of vegetation        corporation = decreased ability
Creek, Ninilchik)                                                  of state to provide habitat
                                                                   protection, private
                                                                   development activities
                                                                   (logging, road building, public
                                                                   access)
Kenai River                      pressure on river banks,          boat wake, recreational &
                                 habitat                          commercial fishing
Kenai Fjords on Seward side      fisheries, wildlife, marine       ecotourism, fishing, large
                                 mammals, birds and their         numbers of people
                                 habitat
Kenai Peninsula between          Fish and wildlife habitat,        logging = cuts in small batches
Kasilof and Anchor River         recreation and tourism, water    from 40 acres to 30,000 over
                                 quality                          several owners' properties
Moose Pass, Kenai Lake, and    fish and wildlife aesthetics,       nothing now but, plans coming
Trail Lakes area                 recreation and tourism, water    to fruition for timber harvesting
                                 quality                          on state, federal, and private
                                                                   lane
Ninilchik drainage (SW of        fishery in stream                 logging, Cls are a matter of
Kenai)                                                             perception, some say very little
                                                                   impacts to stream but no one
                                                                   has specifics, and Cls don't
                                                                   really exist, they [agency]
                                                                   minimizes impacts first [before
                                                                   impacts occur]

Prudhoe Bay                      air quality                       NoX and black smoke
                                                                   particulates from gas flares,
                                                                   turbines, generators, industrial
                                                                   activity combined
Prudhoe Bay, oil and gas         wetlands and lakes                initially - large pads, defense
development                                                        sites, road routes, debris, fuel
                                                                   spills, areas devegetation,
                                                                   barrels of contaminants
North Slope Prudhoe Bay          coastal plain wetlands            gravel mining, road
development                                                        construction
North Slope                      caribou (contested data),         well densities will increase,
                                  viewsheds                        infrastructure roads and
                                                                   pipelines, human activity,
                                                                   thinks they are close to
                                                                   threshold
Prudhoe Bay oil complex          environmental and                 roads, drilling pads, physical
                                  cultural/economic (wildlife,     use of the land, noise, dust,
                                  subsistence, air and water       aircraft and boat traffic
                                  quality, habitats)
old exploratory sites            vegetation damage, some           gravel pads
                                  growing back
North Slope Oil Field            decreased tundra wetlands,        gravel fill over 20 years, pads,
                                  habitats for waterfowl, caribou,   roads
                                  etc.

  Cumulative Impacts in Alaska                                                             6/29/95
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        Site or Area            Resources or Uses Affected          Cause(s) of Cumulative
                                                                              Impact
718th US Air Force ACNW site  seepage into ocean; cancer           unknown (possibly due to
(Bering Straits region)          rates are elevated and            hazardous waste dumpsite
                                 unexplained in the area          near ocean)
Cape Beaufort (Chukchi Sea),   beluga migration                   fuel spills
NW Arctic Coal
Beaufort Sea Natural Gas         beluga migration (timing would   ice breaker natural gas tanker,
                                 be important)                    no plans by state
Beaufort Sea                     near-shore marine habitat         causeways, change
                                                                  temperature and salinity
Nuiqsit                          environmental and                 noise and disruption of
                                 economic/cultural                access/prevention of access;
                                 (subsistence, human              displacement from traditional
                                 habitation, quality of life, air  hunting; air quality from
                                 and water quality, visual,       industrial activities at Prudhoe
                                 psychological)                   Bay
Kaktovik                         same as above                     aircraft traffic (recreational,
                                                                   commercial, scientific,
                                                                   political); recreational use or
                                                                   rivers and impacts on
                                                                   traditional camps; removal of
                                                                   firewood; degradation of
                                                                   experience; scientific studies
                                                                   and "taking" of animals creates
                                                                   anxiety and conflict with
                                                                   traditional values and respect
                                                                   for resources;
Anaktuvuk Pass                   same categories as above          commercial guiding activities
                                                                   generate air traffic,
                                                                   flightseeing, recreation hikers,
                                                                   sport hunters, and result in
                                                                   federal regulations and park
                                                                   designations limiting access
                                                                   and use of resources by all
all villages in northwest arctic    cultural lifestyle changes     economic activity, housing
                                                                   changes, water & sewer
                                                                   systems
Kotzebue                         subsistence uses in area have   population growth - from one
                                 declined, used to be very        horse town to 3500 people;
                                 productive - Beluga whales,
                                 fish, geese have moved further
                                 away;                            operation of cannery effected
                                 herring fishery                  this
Kotzebue area                    negative impacts on culture       Red Dog Mine Joint Venture -
                                 and subsistence in villages due  influx of economic activity,
                                 to economic disparities          salaries and wages
Kotzebue and villages            subsistence village lifestyle     tourism -outfitters, air taxis,
                                 changed by presence of           guided recreational hunting,
                                 tourists                         raft and canoe parties dropped
                                                                   off high up on the rivers
Kotzebue area (Kobuk River       salmon fishery                   Ambler copper belt, in the
mining and development)                                           foreseeable future it will be
                                                                   developed


  Cumulative Impacts in Alaska                                                             6/29/95
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        Site or Area             Resources or Uses Affected         Cause(s) of CumulativeI
                                                                          Impact
Coastal Villages (Kotzebue,                                        small Cis - roads, housing,
Nome mining)                                                       pads, spills, etc.I
Moonlight Springs (Nome)         water supply for city of Nome 7  possibly mining within the
                               quantity & wellhead pressure     recharge area (unsure) which
                               has dropped, pH has risen        is a designated "WatershedI
                                                               Area"
Nome open pit mine               air                               diesel power and electric-
                                                               generation
Nome area                        crab fishery                      several potential deposits in
                                                               one area, ports, roads leitering
Snake River "Turning Basin"      contaminated sediments in         possibly natural levels of
(Nome's safe harbor)             basin; current loss of economic   metals in Nome area geology,I
                               value as harbor cannot be        possibly mining upstream
                               developed (dredged), so          (unsure)
                               access to commercial fishing is  shoreline crowded with small
                                limited                          boats
Red Dog Mine                     air, water, visual, social and    runoff, tailings, impoundment,
                               economic                         hole in the ground which will
                                                               be a lake, road, hauling,I
                                                               concentrated (zinc, lead), fuel
                                                               storage and shipment, blasting,
                                                               acid mine drainage into river.
                                                               Mine created jobs but some
                                                               are not happy with the mine -
                                                               threat to subsistence
Red Dog (Kivalina Port Site)     Beluga migration and water        freighters going in and out,I
                                quality                          transportation corridor (road),
                                                               loading facilities
Seward Peninsula                 rivers (turbidity, arsenic),      placer mining over 95 years w/
                                habitat has created moose        reclamation still fairly new and
                                habitat and benefit              benefit resulted in Nome
Seward Peninsula                 year by year, lose a bit of the    placer mining, stream vehicle
                                stream-, loss of rearing         travel, ruts in the streams,I
                                capacity of streams,             channelizes streams
                                meanders, dolly warden and
                                coho
Bering Straits villages          nearby waters, lands              small fuel spills over time fromI
                                                               fuel tanks, outboards, 4-
                                oiled birds, seals               wheelers;
                                                               source of oil unknownI
Kivalina and Shishmaref          solid waste (plastic), demand     mining, money coming in, TV -
                                for water and wastewater,        causes consumption, birth
                                water shortages                  rates, physical limits, soils notI
                                                               conducive to the development
Gambell                          petroleum contamination           fuel storage
Lower Chena River (Badger        channelization, spawning and    urban encroachment, private
Slough, Chena Slough)            rearing habitat                   land owner culverts, waterI
                                                               impoundment and septic
                                                               systems
Upper Chena River in             recreational use, arctic greyling  road construction led toI
recreation area                  fisheries, chinook run            channel length removed


  Cumulative Impacts in Alaska                                                             6/29/95
                                             D- 143







                   Site or Area            Resources or Uses Affected         Cause(s) of Cumulative
                                                                                           Impact
           Dalton Highway                   social, environmental            need infrastructure in place to
           North Slope (Hickel Hwy,         vegetation, scarred tundra,      sleds (1 960s) hauled by tracker
          Tundra Route)                    deep furrows got wet and now    cat caused deep furrows over
        I                               ~    ~~~~~~~~~~~~green, distinctive noticeable  time
                                             impact
           material sources on              economic                         resources mined out so not
          Richardson Highway                                                available for construction
                                                                               thereby increasing costs
                                                                               because materials have to be
                                                                               imported from long distance
I       ~    ~~along all Road Systemns     fish rearing habitat             culvert installation (undersized
           (Denali Hwy, Steese Hwy,                                          pipes = perched pipes cuts off
           Elliot Hwy)                                                       running habitat and aquatic
                 I                                                        ~~~~~~~~~~~~~~~~~~~~~habitat
           past State land disposal (a      the land itself, timber to       settlement is haphazard, trash
           number around the interior like  environmental pollution
           Kokomo Creek on the Steese
I       ~~Hwy)
           Denali National Park             economic, social, not sure       too many people and activities
                                             whether environmental            attracting them to one place;
                 I                                                        ~     ~~~~~~~~~~~~~~~~~~~not enough infrastructure to
                                                                               allow everyone to use park;
                                                                               crowding
           Denali                           streams                          mining at the Valdez Creek
                 I                                                        ~~~~~~~~~~~~~~~~mine
           Interior                         Most Cl has occurred because
                                             it is site specific and limited in
        I                               ~     ~~~~~~~~~~close proximity
           Harding Lake (near junction of   land erodes into lake            residential cabins recreation,
           Salcha, Tanana Rivers)                                            small lot development
           Nenana River Canyon              bears                            employees living and camping,
                 I                                                        ~     ~~~~~~~~~~~~~~~~~~not caching food
           Timber Creek area (Koyuk         trapping, hunting                consumptive uses in the area
           River)                                                            by cabin users with state
                                                                               permits
           Iditarod trail                   various                         traffic of dog teams &
                                                                               increasing amount of support
                                                                               activities
           White Alice Twin Radar Site      contamination - North river      hazardous dlumpsite
           near North River                 flows to the Unalakleet River &
                                             Little North River
I       ~    ~~Project Chariot site (NW arctic)  hunted and fished resources  fish, birds may be
                                                                               contaminated as they pass by
                                                                               the site on their way N and S
                                                                               then pass by villages
           South Cushman Street             environmental (groundwater,      industrial shops use leaching
           Industrial Areas (Fairbanks)     surface water, wells)            pits for wastewater disposal
                                                                               and adding up over time-, wells
                 I                                                        ~     ~~~~~~~~~~~~~~~~~contaminated by metals,
                                                                               hydrocarbons

            Cumulative Impacts in Alaska                                                            6/29/95
                                                           D-15






       Site or Area             Resources or Uses Affected         Cause(s) of CumulativeI
                                                                     Impact
City of Fairbanks storm drains    environmental (water quality)    non-point source from
and collection points discharge                                    snowmelt, snowpiles anI
into Tanana and Chena Rivers                                       hydrocarbon runoff
Fort Knox Gold (Fairbanks)       environmental                     mineral extraction verses
                                                           environmental protection
Fairbanks - North Pole           wetlands annual flooding          housing urbanI
                             sewage backs up -~               development/growth over time
Fairbanks AMATS                  air quality                       development contributing to
                                                           decreasing air qualityI
City of Fairbanks proper         air quality and increased CO      mobile emissions from cold-
                                                           starts

















                          Cumulative ~~~~~~~~ImatinAak6295
                                                        D- 16~~~~~~