Kodiak State Parks
CITIZENS’ ADVISORY BOARD
1400 Abercrombie Dr.
Kodiak, AK 99615
Phone 486-6339 Fax 486-3320
kodiakstateparks@alaska.gov
March 9, 2010
Kodiak/Aleutians Subsistence Regional Advisory Council
Office of Subsistence Management
U.S. Fish and Wildlife Service
1011 E. Tudor Road, Mail Stop 121
Anchorage, Alaska 99503
Dear Council members:
The Kodiak State Parks Citizens’ Advisory Board is very concerned about FAA proposals for runway extensions at the Kodiak Airport. The current draft version of the project EIS states clearly that a proposed 1200 foot extension of the North/south Runway 18/36 toward the mouth of the Buskin River will have serious adverse effects on salmon runs in the Buskin River. The draft admits that salmon runs will be damaged. In addition, the extension will block some areas where subsistence fishers have traditionally placed their nets.
We also oppose any extension of Runway 07/25 into Chiniak Bay due to potential interference with subsistence fishing and damage to Buskin River salmon runs.
The area offshore of the Buskin is the most important subsistence fishing area on the Kodiak road system for both Native and non-native Kodiak residents and has a long tradition of local families and individuals depending on it for their yearly supply of salmon. It is an easily accessible area, relatively sheltered, and highly productive for both red and Coho salmon (and the occasional king salmon as well). Because it can be fished with a small skiff and motor launched from the Dog Bay boat ramp just a couple miles away, the equipment required does not impose a restrictive financial burden on subsistence fishers nor does is entail high risk to fishers.
The EIS drafts state that damage to Buskin River runs is not a cause for concern as fishers can simply move to other areas such as Pasagshak or Litnik. Pasagshak and Litnik have higher expenses and risk, as they require either trailering a boat over a narrow, winding mountain pass road or traveling a considerable distance over open ocean.
We urge you, as a Council, to oppose any extension of 18/36 in the direction of the Buskin River. As you will see in our comments to the FAA copied below, we favor extending the runway in the opposite direction toward what is locally known as “Jewel Beach” on the USCG Base. (Alternative 4) This area is not regularly used for subsistence fishing. We also urge to oppose extension of Runway 07/25 into Chiniak Bay.
Comments on the Kodiak Airport Environmental Impact Statement (EIS) submitted by the Kodiak State Parks Citizens’ Advisory Board in May 2009
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 of 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
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