Kodiak State Parks Advisory Board letter to FAA

For background information on the runway extension proposals, see the January 3rd post.

Kodiak State Parks

CITIZENS’ ADVISORY BOARD

1400 Abercrombie Dr.

Kodiak, AK  99615

Phone 486-6339 Fax 486-3320

kodiakstateparks@alaska.gov

May 27, 2009

Leslie Grey - AAL 614

Federal Aviation Administration, Airports Division

222 West 7th Avenue, Box #14

Anchorage, Alaska 99513-7587

Dear Ms. Grey:

Here are comments on the Kodiak Airport Environmental Impact Statement (EIS) from the Kodiak State Parks Citizens’ Advisory Board.  The KSPCAB consists of Kodiak residents representing a cross-section of the community. We are interested in all issues as they pertain to Alaska State Parks in the Kodiak archipelago and their effects on all user groups of the parks. We are commenting on this EIS because it has the potential to directly affect the Buskin River State Recreation Site.

The Board is unanimous in its opposition to any extension of Runway 18/36 in the direction of the Buskin State Recreation Site; in addition, we are strongly opposed to extension of Runway 07/25 into Chiniak Bay.

BACKGROUND:  On April 20, 2009, Brad Rolf from the Barnard Dunkelberg & Company Consulting Team gave a presentation to the KSPCAB and answered questions concerning the proposed runway extensions. In preparation for a discussion of the proposed alternatives, Board members individually reviewed the information on the project web site.  We met on May 18, 2009, and discussed the project at great length over a period of approximately two hours with the information from the web site available for reference. Eleven members were present: ten voting and one USCG ex-officio non-voting member.  The entire Board has unanimously approved the comments in this letter.

RUNWAY 18/36:  KSPCAB endorses “Runway 18/36 Alternative 4 – Extend Runway end 36

RSA landmass by 600 feet and use declared distances” as the preferred alternative. Our second choice would be “Alternative 1 No Action.” We absolutely oppose Alternatives 2, 3, & 5 because they involve extension toward the Buskin River.  It should be noted that there was considerable support for “Alternative 1 – No Action” for this runway.

Our support for Alternative 4 stems from the following reasons:

            Sports fishers, picnickers, hikers, beachcombers, campers, etc., use the Buskin River State Recreation Site,

            which is probably the most important outdoor recreation area on the Kodiak Road System.

            Group sites are used by all the different socio-economic and ethnic groups of our community for picnics

            and other group activities.  It is the one sport fish area that people can access easily from town to fish for

salmon and Dolly Varden trout – in fact, kids can ride their bikes to this river to go fishing.  Furthermore, many people who fish this river are rod and reel subsistence fishers.  The area is very scenic with long beautiful beaches for walking and beachcombing, woodland trails, and wildlife viewing, including bears, foxes, birds and marine mammals such as sea otters and sea lions. Tourists as well as locals use this area for recreation.

Concern for impact on fisheries: the Buskin River red salmon run was extremely low in 2008.  Even if  the reasons for this collapse can be determined, we feel that any disturbance of the river cannot be allowed.

            Chiniak Bay just off the mouth of the Buskin River is a vital gill-net subsistence area.  We cannot afford

            to do anything that might jeopardize that fishery in any way. Any fill beyond the current existing runway

            in the direction of the Buskin River is unacceptable.

Concern for aesthetics:  any sort of extension toward the mouth of the Buskin River will create an eyesore that will greatly distract from the recreational experience of users of the area. A huge gravel berm looming over the river is not what residents and visitors want to see when they visit this area.

RUNWAY 07/25:  KSPCAB endorses “Runway 07/25 RSA Alternative 1 – No Action”; in the event that some action is deemed necessary, we support “Runway 07/25 RSA Alternative 3 – Extend Runway end

25 RSA landmass by 425 feet and install EMAS” because it would have less direct impact on Chiniak Bay.

            Basically, the KSPCAB fears that any fill extending into Chiniak Bay has the potential for negative

            impacts on currents and tidal action in the area, which could adversely impact boaters, salmon migration,

            subsistence and sport fisheries, waterfowl, and marine mammals.

In conclusion, on behalf of the KSPCAB, I would like to reiterate our concern for the negative impacts of runway extension in the Buskin River area.  While we do not claim to be experts on aviation safety, we have not seen any evidence in any presentation or on-line materials that a safety problem currently exists at the Kodiak State Airport and that the proposed runway extensions are necessary.  No statistics or safety studies have been cited that demonstrate a need for any action on runway extension.  In light of this fact and the potential for negative impacts on the Buskin River area, we feel that our recommendations deserve serious consideration in determining what action, if any, will be recommended in the EIS.

Thank you for considering our remarks on this EIS.

Sincerely,

Mike Sirofchuck

KSPCAB Chairperson

Introduction to the FAA Kodiak Runway Extension Proposals

The red line on the photo shows the original plan that the FAA was proposing. They wanted to fill in the area within the line to extend the entire land mass surrounding the runways out 1000 feet beyond where the shore is presently. The red and yellow blocks represent the FAA's current alternatives.   

Stewards of the Buskin River State Recreation Site

The purpose of this group is to oppose any plans by the FAA (Federal Aviation Administration) to extend the north-south runway #18/36 at the Kodiak Airport toward the Buskin River. This is a proactive effort to get the facts out about this issue to interested people before this proposal is a done deal. At this point, your action can shape the future of the Buskin River State Recreation Site. If you are willing to help, read on.

For the last 3 years, the FAA has been preparing an EIS (Environmental Impact Statement) for a proposal to expand the Runway Safety Areas on the runways at the Kodiak Airport. The FAA believes that by doing this, it will lesson the potential for aircraft damage.

Currently, a PDEIS (Preliminary Draft Environmental Impact Statement) is circulating among a select group of agencies and organizations that have direct regulatory jurisdiction over the area and its resources. (USFWS, ADF&G, Alaska State Parks, Tribal groups, USCG) A few scoping meetings were held to gather input from these agencies and a select group of organizations but no meetings have been held for the general public to review the plans and various alternatives. No opportunities for the general public will be scheduled to review or comment on the plans until the DEIS (Draft Environmental Impact Statement) is completed sometime early in 2010.

Although Preferred Alternatives have not been identified yet, the FAA is seriously considering Alternative #3, to extend the landmass of runway #18/36 (the north-south runway) 1,200 feet toward the mouth of the Buskin River from the present end of the runway parallel to the existing beach between the river and the ocean.  (see attached photo)

In addition, the FAA is considering extending the landmass of runway #07/25 (the east-west runway) 800 feet straight out into Chiniak Bay from the existing end of runway.

The potential for impacts on the environment, fish and wildlife, recreation, and subsistence by Alternative #3 make the proposed action impracticable and unacceptable, especially when there is a viable alternative. Alternative #4 would extend the landmass of the north-south runway southward instead of northward and would have far fewer impacts.

Because of its close proximity to town, the Buskin River is used more for sport and subsistence fishing than any other river on the road system. 

Here are some of the potential impacts of Alternative #3 on the Buskin River area.

• Placing fill in marine waters would result in direct habitat loss for marine birds. Chiniak Bay was designated as an Important Bird Area of Global Significance in 2008 by Birdlife International and the National Audubon Society for habitat of three bird species of conservation concern; Black oystercatcher, Steller’s Eider, and Emperor Goose.

• Placing fill in marine waters would have adverse impacts on pink, chum, red, and coho salmon.

• Placing fill in this area would have direct effects on natural physical processes that dictate stream flow and hydrodynamics that shape aquatic habitats and species that live there.

• Placing fill in this area will directly impact the view shed of the ocean from Buskin River. With the 1,200 foot landmass extension that will be approximately 30 feet high, from the existing north end of runway #18/36, most of the present ocean view from the Buskin River beach and parking lot will be obstructed and only a small view of the ocean will remain toward town.

• Placing fill in this area will reduce access to beach areas at the mouth of the Buskin River for sport and subsistence fishing, environmental education, birding, beach combing, walking.

Here’s what you can do:

Promote Alternative #4 for Runway 18/36 to extend the N-S runway to the south instead of to the north toward the mouth of the Buskin River.

Stay informed. Read the information on the FAA’s website: http://www.kodiakairporteis.com/ 

Watch for announcements of meetings and attend meetings to get the facts.

Write to the FAA: Leslie Grey: Leslie.Grey@faa.gov or comments@kodiakairporteis.com 

Write letters to the editor of the Kodiak Daily Mirror: 

Get others involved by spreading the information.