Fix eroding Road 250 crossings near Snag Lake

Issues on the record, awaiting the decision

• PendingPROPOSED WORK identifies the fill target as palustrine wetlands but provides no description of the ecological functions and values of the 0.68-acre area to be permanently filled.

  PROPOSED WORK identifies the fill target as palustrine wetlands but provides no description of the ecological functions and values of the 0.68-acre area to be permanently filled. Whether these wetlands provide wildlife habitat, water quality filtration, flood storage, or other services that would be permanently lost is never assessed. A decision to permanently fill wetlands without assessing their functions cannot demonstrate that the proposed fill is the minimum needed to achieve the project purpose. The agency should conduct and disclose a wetland functional assessment for the 0.68 acres of palustrine wetlands before approving any permanent fill.

  A hole PLAN found in the agency’s own notice, quote verified against the text

• PendingPROPOSED WORK acknowledges the road has not received routine maintenance and is now entrenched two to three feet, which the notice presents as the root cause of the erosion problem.

  PROPOSED WORK acknowledges the road has not received routine maintenance and is now entrenched two to three feet, which the notice presents as the root cause of the erosion problem. Yet the notice contains no maintenance plan, no maintenance schedule, and no funding commitment for the new alignment. If the same maintenance failure recurs on the realigned road, the permanent fill in 0.68 acres of wetlands and 0.18 acres of streambed will have accomplished nothing at lasting cost to the watershed and to the public. The agency should provide a binding maintenance plan and funding commitment for the new alignment before the project is approved.

  A hole PLAN found in the agency’s own notice, quote verified against the text

• PendingPROPOSED WORK describes placing 350 cubic yards of fill into 0.68 acres of palustrine wetlands and 206 cubic yards into 0.18 acres of streambed, but the notice contains no compensatory mitigation plan

  PROPOSED WORK describes placing 350 cubic yards of fill into 0.68 acres of palustrine wetlands and 206 cubic yards into 0.18 acres of streambed, but the notice contains no compensatory mitigation plan, no mitigation ratio, and no reference to a mitigation bank. These are permanent impacts, and without a mitigation plan the agency has not demonstrated it will minimize and offset that loss. The agency should provide a compensatory mitigation plan, including a mitigation ratio and the location where compensation will occur, or explain under what authority permanent fill in 0.68 acres of palustrine wetlands and 0.18 acres of streambed requires no mitigation.

  A hole PLAN found in the agency’s own notice, quote verified against the text

• PendingPROPOSED WORK presents only one course of action and describes no alternatives.

  PROPOSED WORK presents only one course of action and describes no alternatives. The notice provides no explanation of why the proposed alignment, which requires permanent fill in 0.68 acres of palustrine wetlands and 0.18 acres of streambed, is the least environmentally damaging practicable option. No no-action baseline is analyzed. No alignment avoiding wetland fill is discussed. Without an alternatives analysis, there is no basis for concluding the proposed scope of fill is the minimum necessary. The agency should analyze at least a no-action alternative and at least one alignment that avoids or reduces permanent wetland fill, and explain why those options were rejected.

  A hole PLAN found in the agency’s own notice, quote verified against the text

• PendingPROPOSED WORK states the project will reclaim four perennial stream crossings and one intermittent crossing in the 18-Mile Creek system, but provides no analysis of what fish or aquatic species use th

  PROPOSED WORK states the project will reclaim four perennial stream crossings and one intermittent crossing in the 18-Mile Creek system, but provides no analysis of what fish or aquatic species use those crossings. The project is located near Cordova, Alaska, yet the notice gives no indication the agency assessed whether these streams support anadromous fish, resident fish, or other aquatic species whose habitat would be affected by reclamation or by rerouting the road away from the creek. The agency should conduct and disclose a fish passage and aquatic species analysis for all five crossings before approving permanent work.

  A hole PLAN found in the agency’s own notice, quote verified against the text

• PendingPROPOSED WORK states the USFS plans to reclaim four perennial stream crossings and one intermittent crossing in the 18-Mile Creek system, but the notice never defines what reclamation means.

  PROPOSED WORK states the USFS plans to reclaim four perennial stream crossings and one intermittent crossing in the 18-Mile Creek system, but the notice never defines what reclamation means. Will old fill be excavated and removed? Will stream channels be actively restored to natural grade and profile? Will culverts or other structures be installed or removed? The environmental benefit attributed to reclaiming these crossings depends entirely on the methods used, and no methods are described. The agency should define the specific reclamation method for each of the five crossings and analyze the environmental effects of each method separately.

  A hole PLAN found in the agency’s own notice, quote verified against the text