Thank you,Nancy IhlenfeldtHabitat BiologistAK Department of Natural ResourcesOffice of Habitat <strong>Management</strong> & Permitting Fairbanks Office907-459-7287Sent: Tuesday, June 21, 2005 3:18 PMTo: Barta Carrie L MS DPW NEPA COORDINATORCc: bob_henszey@fws.govSubject: <strong>Integrated</strong> <strong>Training</strong> <strong>Area</strong> Mgmt PlanCarrie:In addition to the comments sent on June 13, 2005 regarding the abovereferenced Environmental Assessment, the ADNR, Office of Habitat<strong>Management</strong> <strong>and</strong> Permitting (OHMP) has the following comments regardingAppendix C2 of the <strong>EA</strong>:(1) I think an introduction paragraph stating that all activitiesdescribed in this document require a permit(s) from one or more state<strong>and</strong>/or federal agency.(2) Page C2-1 through C2-2. C2-3. Culvert Installation. Using theheadings "Non Anadromous Fish Culverts" <strong>and</strong> "Anadromous Fish Culverts"is confusing.Culverts placed for maintaining area hydrology should be called"wetl<strong>and</strong>" or "drainage" culverts. Culverts placed in streams to allowfish passage are required in streams that support both anadromous <strong>and</strong>resident fish (i.e., not just streams designated as anadromous). Thewidth of the stream will designate the diameter of the culvert <strong>and</strong> if abridge would be more appropriate than a culvert(s).(3) Page C2-2 through C2-5. Dust Control. The water source should be aconsideration -- if withdrawing water from a stream, lake or pond a FishHabitat Permit as well as a Temporary Water Use Permit from the ADNR,Division of Mining, L<strong>and</strong> <strong>and</strong> Water may be required.(4) Page C2-5. Erosion <strong>and</strong> Sediment Control Structures.A. Asphalt. What would be the application of asphalt at a streamcrossing?B. Barbed Dike or Thalweg Deflector Devices. In-stream structuresshould be the last resort at solving stream bank erosion problems,especially in streams that have been designated as anadromous. Inaddition, these structures must be designed by an experiencedengineer/hydrologist. If these structures are not designed <strong>and</strong>constructed properly, they can be destructive. What is "AlaskaStreambank Repair #27", the last sentence in the paragraph?(5) Page C2-13. I. Gabions. First paragraph, second sentence -Why/when would you want to prevent fish passage from one waterbody toanother?_____________________________________________________________________________________________Environmental AssessmentUnited States Army Alaska, <strong>Integrated</strong> <strong>Training</strong> <strong>Area</strong> <strong>Management</strong> Program<strong>Management</strong> Plan E-8
Second paragraph - I do not underst<strong>and</strong> what is being described, is thestructure going all the way across the stream?(6) Page C2-18. III. Outlet Protection. Are these outlets drainingdirectly into streams that support fish? If so, the design <strong>and</strong>construction methods need to keep that in mind.(7) Page C2-19. Q. Reinforced Concrete. The first sentence states thatreinforced concrete can be used to control erosion at streamcrossings....what is the application for this? More details would be nice.(8) Page C2-20. R. Rip Rap. Third paragraph, second sentence - whatother materials (other than riprap) <strong>and</strong> what methods can be employed onslopes steeper than 2:1 for erosion protection? Riprap structuresplaced on the bottom of a stream to create riffles <strong>and</strong> pools must bedesigned by an engineer/hydrologist who has experience with these typesof projects. If installed <strong>and</strong>/or designed improperly, these structurescan be very destructive to a stream <strong>and</strong> the existing fish habitat.(9) Page C2-21. R. Rip Rap. First bullet - "Riprap limits. The riprapshould extend for the maximum flow depth, or to a point where vegetationwill be satisfactory to control erosion." What is meant by "maximumflow depth"? Should this be "ordinary high water elevation"? Thirdbullet - "Riprap Size. The size of riprap to be installed depends onsite-specific conditions." Please add at the end of the sentence,"...(e.g., hydrology, bank steepness, cause of erosion, etc.)"Second paragraph, second sentence - Please add at the end of thesentence, "...(i.e., when water levels are at there lowest)." Thestatement, "Bypassing base flows or temporarily blocking base flows aretwo possible methods." is not really a true statement. As stated above,the OHMP prefers that this type of work be conducted when water levelsare low <strong>and</strong> the introduction of sediment can be minimized. Installingtemporary in-stream structures <strong>and</strong>/or blocking streams should be a lastoption for this type of work. And, the last sentence in this paragraphI do not believe is a true statement - it really depends on the cause oferosion <strong>and</strong> the stream type.Third paragraph, last sentence reads "Control of weed <strong>and</strong> brush growthmay be needed in some locations." It has been documented that rootstructures (e.g., grass, willows, shrubs) on <strong>and</strong> above a stream bank,especially within a riprap structure, immensely helps strengthen thestructure <strong>and</strong> bank. If there are willows growing in the riprap, Istrongly suggest not disturbing them.(10) Page C2-35. Y. Sediment Trap. Fourth paragraph - just toreiterate, even though a structure placed in a stream is "temporary" itwill still require a Fish Habitat Permit from the OHMP.(11) Page C2-36. Y. Sediment Trap. First paragraph, the third sentencereads "Fords are appropriate in steep areas subject to flashflooding..."The OHMP would include the following stipulations in a vehicle streamcrossing permit: (1) stream crossings shall be made from bank to bank ina direction substantially perpendicular to the direction of stream flow;_____________________________________________________________________________________________Environmental AssessmentUnited States Army Alaska, <strong>Integrated</strong> <strong>Training</strong> <strong>Area</strong> <strong>Management</strong> Program<strong>Management</strong> Plan E-9
- Page 1:
DEPARTMENT OF THE ARMYUNITED STATES
- Page 5 and 6:
TABLE OF CONTENTSCHAPTER 1: PURPOSE
- Page 7 and 8:
Table 3.9 Summary of Impacts to Hum
- Page 9 and 10:
and Training Land Program, the rang
- Page 11 and 12:
• Establish a defined land condit
- Page 13:
Donnelly Training AreaDonnelly Trai
- Page 17 and 18:
determine whether additional NEPA a
- Page 19 and 20:
Table 2.2 Summary of Environmental
- Page 21 and 22:
CHAPTER 3: DESCRIPTION OF THE AFFEC
- Page 23 and 24:
Maneuver Trail Maintenance and Upgr
- Page 25 and 26:
Mungoven 2001). Engineering soil ty
- Page 27 and 28:
projects and would result in wide,
- Page 29 and 30:
growth. Wind and sand fences would
- Page 31 and 32:
iological impacts of military train
- Page 33 and 34:
willow scrub communities are common
- Page 35 and 36:
disturbed. Further, hardening low w
- Page 37 and 38:
disturbance or removal, best manage
- Page 39 and 40:
SRAThrough the SRA program, soldier
- Page 41 and 42:
Ship Creek (from the Glenn Highway
- Page 43 and 44:
effective site drainage. Required p
- Page 45 and 46:
Game 1998). More information on wil
- Page 47 and 48:
Fort Wainwright and associated land
- Page 49 and 50:
Long-term beneficial impacts to wil
- Page 51 and 52:
1998).The Alaska Interagency Wildla
- Page 53 and 54:
Prescribed burns, mechanical thinni
- Page 55 and 56:
unplanned fires, soldiers are direc
- Page 57 and 58:
USARAK also implemented the USARTRA
- Page 59 and 60:
LRAM projects beneficial to public
- Page 61 and 62:
Cumulative ImpactsPast military act
- Page 63 and 64: Two surveys conducted on Yukon Trai
- Page 65 and 66: LRAM activities under Alternative 1
- Page 67 and 68: 3.9.1 Affected EnvironmentFort Rich
- Page 69 and 70: SRA program, which educates soldier
- Page 71 and 72: 3.10.2 Environmental ConsequencesAl
- Page 73 and 74: Fort Richardson receives few compla
- Page 75 and 76: Table 3.11 Summary of Impacts 1 to
- Page 77 and 78: oads and hauling fill and rock mate
- Page 79 and 80: CHAPTER 4: PREPARERS AND CONTRIBUTO
- Page 81 and 82: Benson, A.M. 1999. Distribution of
- Page 83 and 84: Neely, R. J. 2001. Early Mining His
- Page 85 and 86: CHAPTER 6: AGENCIES AND INDIVIDUALS
- Page 87 and 88: Project NameBulldog TrailWidening P
- Page 89 and 90: Project NameYukon TrainingArea Demo
- Page 91 and 92: Project NameYukon TrainingArea Firi
- Page 93 and 94: Project NameEddy Drop ZoneVegetatio
- Page 95 and 96: Project Name33 Mile LoopRoad Shortc
- Page 97 and 98: APPENDIX B: BEST MANAGEMENT PRACTIC
- Page 99 and 100: Sediment Trap(Permanent) SeedingSil
- Page 101 and 102: APPENDIX C: SAMPLE RECORD OF ENVIRO
- Page 103 and 104: APPENDIX D: ITAM PROJECT ASSESSMENT
- Page 105 and 106: Fire ManagementYes No□ □ Could
- Page 107 and 108: APPENDIX E: AGENCY COMMENTSThe foll
- Page 109 and 110: ___________________________________
- Page 111 and 112: ___________________________________
- Page 113: Sent: Monday, June 13, 2005 5:00 PM
- Page 117 and 118: sentence could read, "The trees are
- Page 119 and 120: The third paragraph seems too speci
- Page 121: USARAK does not have a current five