The Imuruk Basin Subsistence Protection Project
A Canadian based mining company’s proposal to develop a vertically integrated mine located 37 miles north of Nome at the base of the Kigluaik Mountains is directly threatening the subsistence resources that Alaska Native Tribes have depended on for millennia. The “Graphite Creek” Project, named after one of the many small salmon bearing creeks that drain the mountain range, would involve the processing and manufacture of high grade coated spherical graphite primarily for lithium-ion electric batteries, to capitalize on a potential supply crunch from China and a growing appetite for electric vehicles.
Since 2012, as part of Graphite Creek mining exploration activities, the Alaska Department of Natural Resources has allowed the company to divert up to 130,000 gallons of water per day from several creeks and ponds without requiring the company to obtain a permit. Concerned about the impacts of such water withdrawals on fish and wildlife habitat, the Tribes formed the Imuruck Basin Inter Tribal Watershed Council (IBITWC) to address these and other water and subsistence related issues.
Between 2018 and 2020, the IBITWC took a number of actions in order to protect Tribal subsistence resources. These actions included sending a letter to the Nome Office of the Alaska Department of Fish and Game (ADF&G) requesting that they amend the Habitat Permit to ensure adequate flows for salmon in the Creeks affected by the TWUAs, pointing out that the ADF&G Permit and the TWUAs decision require the agency to take action to limit potential impacts to salmon and other species that may occur under the TWUAs decision.
ADF&G responded that it believes the activities of the mining company “will not impact the fish in Hot Springs Creek.” However, this conclusion was reached without collecting any data on the Creek nor visiting the site. During a hearing last fall, Sen. Don Olson stated that “If the community does not want this mine, it should not go through.” The IBITWC, therefore, requested that Sen. Olson take whatever measures he can to encourage the DNR, ADF&G and/or the Mining Company to work with the Tribes to protect salmon habitat in the Creeks in order to preserve vital subsistence resources. NBITWC continues to closely monitor this project and coordinate the response by the Tribes.
North Bering Sea Tribal Climate Self Determination Project
The Norton Bay Inter-Tribal Watershed Council (NBIWTC) has kicked off its project to address the Bureau of Ocean Energy Management’s (BOEM’s) recent 2019-2024 Outer Continental Shelf Oil and Gas Leasing Program (Leasing Program) which proposes to revive a long-abandoned government campaign to encourage oil and gas drilling in the North Bering Sea Region (NBSR).
As part of the Project the NBITWC will: 1) Partner with the tribal entities located in the NBSR (Tribes) in submitting comments to BOEM on the Leasing Program and; 2) Continue working with the Alaska Delegation and Governor Walker to request that the NBSR Leases be removed from the Proposal; 3) Work with Senator Murkowski regarding her commitment to the Tribes to use legislation to require that Department of Interior policies be vetted by the Tribes and that analysis consider Traditional Ecological Knowledge and;
4) Hold DOI Secretary Ryan Zinke accountable to his commitment to bring Alaska Tribes to the table before making any decisions to open more areas in the NBSR to oil and gas leasing, including engaging in Government-to-Government (G2G) Consultation with tribal entities in order to discuss the potential impacts on subsistence resources and human health and welfare and; 5) Work with government agencies and other stakeholders to establish local oil and gas clean-up emergency response teams in the NBSR. (This Project is funded in part by the Unitarian Universalist Fund for Just Society)
Norton Bay Climate Risk Assessment Project
Beginning in 2010, the Norton Bay Inter-Tribal Watershed Council (NBITWC) and the Native Villages of Elim, Koyuk, Unalakleet and Shaktoolik initiated a Norton Sound adaptation planning process using the “Steps to Resilience” under the U.S. Climate Resilience Toolkit including: 1) Explore Hazards; 2) Assess Vulnerability and Risks; 3) Investigate Options; 4) Prioritize and Plan; and 5) Take Action.
In 2011, as part of Step 1: “Explore Hazards”, the Native Village of Elim (NVE) and the NBITWC worked with partners to monitor environmental conditions and initiated a planning effort to identify risk from climate change and potential mining development activities within the Norton Bay Watershed (Watershed). The results were an Assessment of Mining Impacts on Subsistence Ecosystems of the Tubutulik River Watershed; the Quality Assurance Project Plan for the NVE Tubutulik River Subsistence Protection Project; and the NVE Instream Flow Water Reservation Application (Planning Documents).
These documents were developed using both Traditional Ecological Knowledge (TEK) and contemporary science, and included the local community in decision making by holding community gatherings and participating in public gatherings. The planning effort also included surveys designed to gather TEK, and documentation of observations and concerns, as well as success stories. Data on water flow, quality and temperature were also applied to the Planning Documents to address the potential impacts of mining activity and climate change on subsistence resources and human health and welfare within the Tubutulik River Watershed.
As part of Step 2: “Assess Vulnerability and Risks”, the NBITWC and partners engaged the Climate Solutions University (CSU) Adaptation Plan Development Program created by the Model Forest Policy Program (MFPP) to develop the Norton Bay Climate Change Adaption Plan (NBCCAP). This process engaged an array of stakeholders and expertise in building partnerships, gathering extensive information, thinking critically, and planning focused on a community-based team effort. The result was a regional action plan that the Norton Bay community and supporters are working to implement.
As part of Step 3: “Investigate Options”, NBITWC and NVE, with grant funding from the Bureau of Indian Affairs Tribal Resilience Program, presented a climate adaptation planning curriculum from July 2016 through May 2017. The curriculum informed and guided Alaskan Native community leaders and staff to develop Localized Climate Change Adaptation Plans (LCCAPs) by assessing local climate risks; developing strategies to address those risks; and building the information, funding, and resource capacity to take action for climate adaptation and community resilience. Participants in the curriculum gained a clear understanding of the impacts from climate change in Alaska, locally specific climate risks, and adaptation options to address risks.
To engage in Step 4: “Prioritize and Plan”, NBITWC will continue our efforts to assist the Villages with climate resiliency planning. To this end, the Norton Sound Local Climate Change Adaption Planning Project will support the creation of climate-resilient action plans for Alaska Native Villages in the Norton Sound. Using a step by step process, participants will be provided with the information and tools needed to write a local adaptation plan and be ready to move into Step 5: “Take Action” in a variety of ways that make sense for their community.
In addition, NBITWC and our village partners have obtained funding to assist the Villages in applying for Hazard Mitigation Planning and to apply existing water quality and quantity baseline data; climate change scenarios, maps, background information and research; watershed assessments; and planning documents to take specific actions that will protect rivers and streams that support fish and wildlife habitat and subsistence uses, from climate change and development of related temperature increases and low flows using habitat improvement measures.
Finally, the NBITWC is engaging in a dialogue with other indigenous communities and nations, including the Inuit Circumpolar Council, the Arctic Circle, the Group on Earth Observations, the World Meteorological Organization (WMO), the European Polar Board (EPB) and the Sustaining Arctic Observing Networks (SAON), NBITWC to help the Villages respond and adapt to climate change.
Bering Sea Western Interior Resource Management Plan Response
NBITWC is closely monitoring and coordinating the Tribal response to a current Bureau of Land Management (BLM) proposal that poses a serious threat to subsistence resources and ecological integrity on the Seward Peninsula. In March 2019, the BLM released the first version of its Bering Sea Western Interior Resource Management Plan. The Plan – which is consistent with the Trump administration’s approach of opening public lands to extractive development regardless of the ecological and human rights consequences – will govern management of these critical and delicate ecosystems for the next 20 to 30 years.
The planning process, and the public comment period that followed, failed to adequately include and consult with the Alaska Native tribes that live in the planning area and depend on its natural resources for their physical and cultural survival. The result is a Resource Management Plan that revokes 50 year old public lands protections for sensitive fish and wildlife habitats under the Alaska National Interest Lands Conservation Act, opening over 46 million acres to mining and other development while removing protections from Areas of Critical Concern (ACECs), ignoring local communities’ requests that such designations remain in place.
Much of the Plan’s impacted area is the traditional land of over 69 Alaska Tribes, who have lived in the region for thousands of years and continue to sustainably manage the fish, plants, animals, and land. The Tribes are unified in their opposition to the land give away and have warned the BLM of the potential impacts on water resources, wildlife, future generations and their subsistence economy. During the land use planning process, local Tribes asked the BLM to designate more than 7 million acres of Areas of Critical Environmental Concern (ACECs) that would close mining in these areas in order to protect important watersheds and traditional tribal lands vital to community survival. The RMP’s Preferred Alternative, however, did not list a single watershed nominated by local Tribes and communities for ACEC status. In fact, no ACECs were designated in the Preferred Alternative at all, leaving the entire planning area open to mining and other development. The failure of this RMP to adequately protect these unique watersheds could have serious impacts on wildlife habitat and water quality for critical fish resources and community water sources. In fact, the BLM itself admitted that its Preferred Alternative will result in numerous adverse impacts from the destructive activities that it allows.
Because of the unprecedented impacts to natural and subsistence resources, there were multiple requests to extend the comment period on the DRAFT BSWI RMP. Regardless of these requests and DOI’s promise, made at the Tanana Chiefs Conference Annual meeting in March 2019, to modify the timeline allowing for Cooperating Agency meetings with Alaska Tribes to consider edits to the Draft plan, the BLM stuck to a mere 60 day comment period and the Record of Decision was complete by November of 2019.
NBITWC, whose board of directors includes members from tribal communities located within the Norton Bay Watershed which is within the planning area, has been closely monitoring the process, submitted comments on the RMP to voice the concerns of the tribes about the negative impacts to ecosystems and human health of which the current proposed RMP puts them at risk. and has been coordinating a response with several of the tribes on the Seward Peninsula. Additionally, NBITWC is partnering with the Native Village of Elim to secure funding to draft a climate risk assessment of the impacts of rising temperatures and mining development within critical salmon habitat on public lands.
Finally, last April, NBITWC and other tribal organizations and tribes sent a letter to the BLM’s Alaska State Director requesting a hold on the process for issuing the Final BSWI RMP due to the national and state emergency declarations and because many rural Alaskan communities are under travel and staff restriction and have been otherwise substantially distracted by the need to respond to the Covid19 emergency. In recognition of the fact that the tribes cannot realistically participate in the planning process at this time while their resources are focused on supporting their communities through the current health and economic crisis, the letter requests that the BLM place the process on hold
The Norton Bay Inter-Tribal Watershed Council organizes public gatherings to address issues that are impacting the Arctic. Civilized settlements and communities are witnessing their crucial infrastructure threatened by storm surges, eroding coastlines, degrading sea walls, melting sea ice, permafrost, and glaciers. Species in the Arctic are impacted by warming ocean temperatures and dramatic loss of sea ice.