David Rak PO Box 1852 Wrangell, Alaska 99929 (907) 874-3824 home phone To: Robert Dalrymple July 18, 2017 Wrangell District Ranger Attn: Sonar Cabin Replacement P.O. Box 51 525 Bennett Street Wrangell, AK 99929-0051 Re: Comments on the Sonar Cabin Replacement Environmental Assessment (EA) and Freedom of Information Act (FOIA) Requests. My comments are submitted subject to 36 CFR 218.5 to maintain eligibility to file an objection to the draft decision notice. I have been employed with the Forest Service in Alaska for over 39 years. For over 25 of those years I have been the administrator for the Stikine-LeConte Wilderness and the special use permits therein, of which I have extensive personal and professional knowledge. I provided written comments during the project scoping in month year but was not officially involved in the preparation of the EA. I was contacted by members of the Interdisciplinary Team (IDT). National Environmental Policy Act (NEPA) direction is to involve the public and interested parties early and often. No Forest Service equipment, supplies or time were used in the preparation of these comments or this document. My participation is as a private citizen interested in the appropriate NEPA process and Wilderness management. Federal regulations require the Forest Service to conduct two-level screening on a proposal that is received. Has the initial screening been completed and the State s proposal for building a permanent cabin in Wilderness been accepted as a formal application under 36 CFR 251.54? I am requesting under the FOIA the documents that show the two levels of screening, and the acceptance of the State s proposal as an application. Forest Service Manual (FSM) 2703.2 directs that use of National Forest System (NFS) lands only be authorized if the proposed use cannot be reasonably accommodated on non-nfs lands. FSM 2703.2 directs denial of proposals for uses of NFS lands which can reasonably be accommodated on non-nfs lands. And not authorizing the use of NFS lands just because it affords the applicant a lower cost and less restrictive location when compared with non-nfs lands. This is my FOIA request for the documents that address these three FSM requirements for the replacement of the former FS Sonar Cabin.
Comments on the Sonar Cabin Replacement EA Page 2 of 11 The 1964 Wilderness Act section 4(c) includes a general prohibition of structures in designated Wilderness except as necessary to meet the minimum requirements for the administration of the area for the purposes of the Act. Section 1315(b) of the Alaska National Interest Lands Conservation Act (ANILCA) provides that the Secretary of Agriculture may permit fishery management activities within national forest wilderness subject to reasonable regulations. Wilderness and Forest Service regulations are applicable. The 1982 Sonar cabin was a panelized temporary cabin constructed to house ADF&G employees monitoring salmon for potential impacts from proposed hydroelectric projects in British Columbia, Canada. The former FS Sonar cabin was not constructed to support the Pacific Salmon Treaty The Forest Service permitted the Alaska Department of Fish and Game (ADF&G) to use and occupy the former FS Sonar Cabin for fisheries studies from 1982 through 1989. ADF&G did not request and, therefore, was not authorized to use the FS Sonar Cabin from 1990 through 1996. In 1997 ADF&G was again permitted use of the Sonar Cabin for fisheries studies, this time in support of the Pacific Salmon Treaty, ratified by Canada and the U.S. in 1985. In 2014, ADF&G discovered rot in the FS Sonar Cabin s wooden framing members and determined it to be unsuitable for occupation. The Wrangell District Ranger concurred and the FS Sonar Cabin was removed by ADF&G in June 2015. ADF&G s permit for use of the Sonar Cabin expired on December 31, 2015. The addition of the first and only permanent Forest Service (FS) administrative cabin into the Stikine-LeConte Wilderness would be an action with significant impact to Wilderness character, therefore, the agency could not support a Finding of No Significant Impact (FONSI) for this action. An Environmental Impact Statement (EIS) would need to be prepared. To be clear the past two administrative cabins in Wilderness (one which was removed in 2014) were temporary cabins constructed by ADF&G in about 1983 and given to the Forest Service. ADF&G has been authorized to occupy and maintain those temporary cabins at various times during the past 30+ years. The construction of a new permanent cabin in Wilderness to replace a temporary cabin would have more impact and a larger footprint in Wilderness than a float house outside Wilderness, or using existing structures (tent platform and cabins) within the Wilderness. The construction of a cabin at the former FS Sonar Cabin site would increase the number of structures in the Wilderness by one cabin. (The Sonar Cabin has been removed and the Kakwan Tent Platform would remain.)
Comments on the Sonar Cabin Replacement EA Page 3 of 11 EA page 1: The Forest Service has prepared this EA in compliance with the National Environmental Policy Act (NEPA). It discloses the environmental effects of the project. This EA incorporates by reference the 2016 Final Environmental Impact Statement (FEIS) for the Tongass National Forest Land and Resource Management Plan (Forest Plan). Additional documentation may be found in the project planning record located at the Wrangell Ranger District Office. And on page 37: Project Record - Additional documents, including more-detailed analysis of project area resources, may be found in the project planning record located at the Wrangell Ranger District Office in Wrangell, Alaska. Other reference documents such as the Forest Plan are also available at the Wrangell office. Your email to me on July 7, 2017, stated: The planning record you requested is in an electronic format which is stored on a centralized agency server. It does not physically exist at the District. The wording in the EA for comment was not accurate; thank you for bringing that to our attention. I request the statement in the EA be corrected. EA page 3 and A1: The map on page three and the information listed in Appendix A-1 for Past and Current items within the Stikine LeConte Wilderness are not consistent. How well do the EA preparers and officials know the Wilderness they are analyzing? The map shows 13 tent platform sites, the appendix states there are 11; three of which are currently permitted. There are four current tent platform permit holders in the Wilderness: Benitz, Connor, Howell and Jenkins. The map shows two historic cabins, the appendix states there are five. Please identify the location of the other three historic cabins? The map shows 12 public recreation cabins, the appendix states there are 11: 10 active and one scheduled for decommission. There are 11 rentable public recreation cabins in the Wilderness: Flemer, Shakes 1 and 2, Rynda Twin Lakes. Mallard Slough, Little Dry, Gut 1 and 2, Sergief, Koknuk; and Binkley scheduled for decommissioning. The map shows 14 special use cabins, the appendix states there are a total of 16 special use cabins, including other agencies. The Fisher cabin on Shakes Slough is missing from the map. The former FS Sonar Cabin is incorrectly listed in the Appendix as the ADF&G Sonar Cabin. The ADF&G Gut Island Cabin is incorrectly listed in the appendix as the ADF&G Dry Island Cabin. The map shows two Administrative Cabins which are missing or not correctly listed in the appendix. The location of the former FS Sonar Cabin site in relation to the Stikine Chinook sampling location is very important to the analysis, and both locations need to be identified in the EA. The map on page three needs to display the reach of the river where the fisheries crews drift nets for sampling/monitoring the Stikine Chinook along with the site if the former FS Sonar Cabin. The crews currently drift from Kakwan Point on the upper end down to Hooligan Slough/the upper
Comments on the Sonar Cabin Replacement EA Page 4 of 11 river end of Limb Island on the lower end. This location is pictured on the Forest Service s Sonar Cabin scoping flyer dated 07/24/2015. EA page 4, second paragraph. ADF&G has been issued 5-year permits for occupancy of the Forest Service Wilderness Cabin near the upriver end of Andrew Slough and a 5-year permit for a tent platform at Kakwan point to shelter seasonal fisheries workers. A 5-year permit is the longest tenure authorization a District Ranger can issue for this use, and it is not considered short term. During the years the FS authorized ADF&G use of the former FS Sonar Cabin, 5-year permits were the standard authorization. EA page 4, third paragraph; page 6 fifth paragraph. The Pacific Salmon Treaty expires in 2018. Treaty continuation is being negotiated in strict secrecy. To state what the Treaty will require in the future is presumptuous and should be removed from the EA. EA page 4, fifth paragraph. The full crew of three ADF&G and two Canadian Department of Fisheries and Oceans (DFO) employees who drift net the Stikine Chinook are on site from the end of April to the beginning of July. ADF&G also monitors Chinook salmon in Andrew Creek, a tributary of the Stikine River, also within the Stikine-LeConte Wilderness. Monitoring is done each year in August and crews have sheltered when needed at the Kakwan Cabin. In 1997 the Forest Supervisor issued a special use permit to ADF&G allowing helicopter landings to support pedestrian surveys and safely monitor the Chinook salmon along the South Fork of Andrew Creek. That permit has been reissued to keep current and requires ADF&G to report the time and number of helicopter landings each year. In 2014, 2015 and 2016 ADF&G reported no landings were needed as they had found a new preferred survey method. Aerial surveys were done in less time. A full work day was no longer needed for two employees to walk the length of the creeks spawning areas. If a new preferred method to monitor Stikine River Chinook salmon is also discovered, drifting gillnets in the river would be replaced with the improved technology and housing for employees would not be required. EA page 4, sixth paragraph. The fisheries monitoring crew most often consists of five individuals, with occasional oversight personnel. Three employees are sheltered at the ADF&G s Kakwan Cabin and Tent Platform, and two are sheltered at the FS Wilderness Cabin. The oversight personnel have been housed at the USGS Cabin and the FS Shakes Slough #1 public recreation cabin. All of these are existing structure in the Wilderness. No new structures are needed to meet the housing/shelter needs of the Stikine Chinook monitoring project. The yearround storage of equipment and supplies needed seasonally is not provided for in designated Wilderness as the minimum for the administration of the Wilderness. EA page 5, first paragraph. The purpose for the project should be to provide shelter for the fish monitoring crew. The shelter needs to be close to the work site and have minimum impact on the
Comments on the Sonar Cabin Replacement EA Page 5 of 11 Wilderness. The Stikine River Chinook salmon monitoring performed by ADF&G and DFO to meet the requirements of the Pacific Salmon Treaty is specific to the fish stocks of the Stikine River. Monitoring crews need to live near the reach of the Stikine River where the gillnet capture occurs. Personnel could be housed in existing structures on National Forest System lands in designated Wilderness. Or housing could be below the river s ordinary high water mark in the tidally influenced waters of the Stikine River claimed by the State of Alaska. EA page 5, second paragraph; and page 7, fourth paragraph. The site of the former FS Sonar Cabin is not close to the Chinook monitoring area in the Stikine River. The Sonar site is not in proximity to the sampling location, and is further from the work area than the existing FS Wilderness cabin site. EA page 5, second paragraph; page 7, sixth paragraph; page 8, third paragraph; and page 21, fourth paragraph. The year-round storage of equipment and supplies needed seasonally should not be in the purpose and need as it is not provided for in designated Wilderness. EA page 5, fourth paragraph. The Minimum Requirement Decision Guide (MRDG) signed April 21, 2017, is a flawed document written to support a decision already made. On June 15, 2015, I was at the site of the former FS Sonar Cabin with four other FS resource specialists and two ADF&G employees. We had been sent to the site to conduct resource inventories and identify the exact site for the new cabin. During the site visit one of the ADF&G employees told me the Alaska Regional Forester had already approved the reconstruction of the Sonar cabin at the site of the former cabin. I was told the Regional Forester gave her approval for the new cabin (at the same site) during a meeting in Juneau, AK earlier that year. I advised you that I would only prepare an MRDG based on an impartial MRA, not to support a decision already made. Although my duties include Stikine-LeConte Wilderness Manager, I was not tasked with the MRA. It is clear to me the MRDG and the EA were prepared to support a decision that had already been made. The Regional Forester s letter of March 9, 2016, withdraws, in part, the Forest Service s objection to issuance of a Recordable Disclaimer of Interest to the State of Alaska for the lands underlying the Stikine River. The Forest Service continues to object to the issuance of an RDI for the named and unnamed sloughs without a determination about whether the sloughs contain waters of the Stikine River and whether the sloughs are independently navigable. Upon withdrawal of the Forest Service objection, the BLM should assign clear title to the lands underlying the main stem of the Stikine River. The legal cloud over ownership of the lands underlying the main stem of the Stikine River is being lifted. With ownership, the State can provide housing for employees monitoring Stikine River Chinook salmon outside of the Wilderness.
Comments on the Sonar Cabin Replacement EA Page 6 of 11 The Minimum Requirements Analysis (MRA) for the State s proposal to construct a permanent cabin in the Stikine-LeConte Wilderness should not proceed beyond Step 1 of the MRA process. Page 8 of the MRDG includes the following explanation why that process should proceed to Step 2: The fisheries monitoring of salmon stocks on the Stikine River cannot take place outside of the wilderness. Shelter for the fish monitoring crews must be in close proximity to the monitoring site, and therefore needs to be within the Stikine-LeConte Wilderness. The need for the fish monitoring crew s shelter to be within proximity to the monitoring site is well demonstrated/documented, but the former FS Sonar cabin site is not close to the current salmon monitoring site. The FS Wilderness cabin or an ADF&G float house in a back-water above Kakwan Point would both be closer to the monitoring area used for the past several years. The FS Wilderness cabin is within the wilderness. A float house in the river channel would not be within the wilderness. EA page 6, first paragraph. The project was included in the Schedule of Proposed Actions (SOPA) since July 2015. Yet, the decision on the project was shared with ADF&G employees during a meeting in Juneau prior to that date. EA page 6, second paragraph, and page 37, third and fourth paragraphs. As noted in the Acting Regional Forester s correction letter of June 19, 2017, the newspapers of record for the Alaska Regional Forester would be the Juneau Empire and the Alaska Dispatch News. The EA lists only the Juneau Empire. This error should be corrected in at least three paragraphs throughout the EA. This is my FOIA request for the public or Code of Federal Regulation (CFR) notice identifying the papers of record for the Alaska FS officials, including the Regional Forester, for 2017. EA page 6, fifth paragraph It is presumptuous but safe to assume that the Pacific salmon treaty would require monitoring of Stikine River Chinook, but why assume that the labor-intensive method of drifting gill nets in the river for a little over two months each year would be continued. A more efficient survey method may be developed/discovered that would not require seasonal housing for five people near the work area. EA page 7, eighth paragraph. Waves from the wakes of passing boats is excessive along the river bank adjacent to the site of the former FS Sonar Cabin. Several years ago, ADF&G moved the storage of their fuel drums from the former FS Sonar Cabin riverbank to the FS Wilderness Cabin site to avoid the impacts of the boat wake. That river bank is not a secure boat moorage as identified in Issue 1 of the EA. Also, the permitted storage of fuel drums to support the Stikine Chinook monitoring would continue to be requested at the FS Wilderness Cabin Site. Should ADF&G be approved to construct a new permanent cabin at the site of the former FS Sonar cabin, they would continue to need to store the drums of outboard motor gas at the Wilderness
Comments on the Sonar Cabin Replacement EA Page 7 of 11 Cabin site. Crews roll the drums up the gently sloping bank to the NFS uplands. The River bank at the Sonar site is too steep to safely move the drums up onto the uplands. EA page 7, ninth paragraph. The riverbank adjacent to the site of the former FS Sonar Cabin is an active river cut bank. It is not a relatively stable river bank as identified in Issue 1. EA page 8, third paragraph; page 9, second paragraph, and page 21 fourth paragraph. On February 27, 2015, the ADF&G submitted a proposal to construct an 18 x18 feet (324 sq. ft.) permanent cabin within the Stikine-LeConte Wilderness as housing for employees doing inseason monitoring of Stikine River Chinook Salmon. On January 5, 2016, ADF&G sent a replacement cabin plan to the Wrangell District Ranger. Their replaced/amended cabin proposal is for a 16 x18 feet (288 sq. ft.) Pan-abode cabin. That replacement proposal and cabin design has not been used in the analysis for the EA, and is not included in the project record. This is my FOIA request for the January 2016, or the most recent cabin proposal and plans from ADF&G for a cabin at the site of the former FS Sonar Cabin. That proposal and plan should be included in the project record and incorporated into the EA. EA pages 11 and 13. The use of structures that exist in the Wilderness and have been used to shelter the fisheries workers and oversight personnel since 2015 needs to be fully analyzed as an alternative in an EIS. And the use of a float house as a shelter for the fisheries project also needs to be fully analyzed as an alternative in an EIS. EA page 13, 14th paragraph. The Forest Service s Wilderness Cabin has not been used by FS crews for the administration of the Wilderness for about ten years, and for the ten years before that, use was infrequent. The ADF&G was permitted to occupy the FS Wilderness cabin for a few years after the fire, as seasonal crew shelter, while ADF&G rebuilt its permitted Kakwan cabin. And Stikine Chinook monitoring crews have occupied the Wilderness Cabin from 2015 to the present, after the FS Sonar Cabin was abandoned and removed. EA page 13, 15th (final) paragraph. The Shakes Slough #1 and #2 public recreation cabins, are closest to the former FS Sonar cabin site, but those recreation cabins are not the closest to the current fisheries monitoring site. The Twin Lakes public recreation cabin is by far closest to the current Stikine Chinook monitoring area. EA page 14, first paragraph. The Unites States Geological Survey (USGS) welcomes ADF&G use of and watching over their cabin at the Stikine River gage. Emails from the USGS are in the file on the O drive and should be in the project record. Late April to early July are not the peak use time in summer for renting the public recreation cabins. The three-person ADF&G Stikine Chinook monitoring crew shelters at the ADF&G Kakwan cabin and tent platform. The Canadian DFO crew shelter at the FS Wilderness cabin. The occasional oversight person could
Comments on the Sonar Cabin Replacement EA Page 8 of 11 shelter at the USGS cabin or the closest FS public recreation cabin for the few nights each monitoring season they are on the river. EA page 15, second and third paragraphs. The State could address the need for seasonal housing to monitor the fishery by using a float house anchored and/or shore tied in the Stikine River. In March 2016, the Regional Forester withdrew the Forest Service objection to the State s claim of sovereignty of the main stem of the Stikine River. The main stem of the Stikine River is not Wilderness. In 2016 eighteen permanent float houses were inventoried along the Stikine River and its channels. Two of those float houses are (up river) between the ADF&G Kakwan Cabin/Tent Platform sites and the sites of the former FS Sonar and the USGS Cabins. Both of the float houses have been on site and safely used by their owners for about 15 years. Neither have a history of being unsafe, nor their presence being threatened by strong currents and rapidly fluctuating river levels as described in the EA. This is my FOIA request for the Stikine River Floathouses 2016 report. There is a back-water area of the main river channel between Kakwan Point and the long term private float houses that would nicely accommodate a seasonal float house that could shelter two ADF&G or DFO seasonal workers outside of the Wilderness. An ADF&G float house in the river adjacent to the Wilderness uplands could be provided for by ANILCA Section 1315(b) because it would be for fisheries management. ADF&G employees monitor the State fisheries in Clarence Straits, including waters of the Wrangell Ranger District, from a float house anchored seasonally in Salmon Bay. A float house in a backwater area of the Stikine River main channel above Kakwan Point would be similar. The seasonal facility would only need to be there for about 2 1/2 months each year which would be less impact to the Wilderness than a permanent cabin at the former FS Sonar Cabin site. EA page 16, third paragraph. The site of the former FS Sonar site was chosen in 1982 because it was the best site for the sonar monitoring equipment that was operated for salmon monitoring during the BC Hydro project. A fish wheel for salmon sampling was placed on the opposing river bank near the site of the FS Wilderness Cabin. The former FS Sonar cabin site is a cold, dark, bug infested site, which in past years accumulates winter snow pack hindering spring access. The EA states: The Kakwan Cabin is located at the lower end of the drift gillnet sampling reach and the Sonar site is located at the upper end of the reach; the combination provides the crews with efficient access to the entire sampling reach and access to shelter and safety equipment at both ends. This statement is not true. The drift area has been changed. The crews currently drift from Kakwan Point on the upper end down to Hooligan Slough/the upper river end of Limb Island on the lower end. This location is pictured on the Forest Service s Sonar Cabin scoping flyer dated 07/24/2015 Also from that paragraph: The Sonar site is not adjacent to the projects net maintenance area; it is upriver from the site permitted for net repair. The EA needs to be changed to correct these errors.
Comments on the Sonar Cabin Replacement EA Page 9 of 11 EA page 16, fourth paragraph. Again, the site of the former FS Sonar cabin is not near the salmon monitoring location on the river. Also, the river bank up stream and adjacent to the former FS Sonar Cabin site is an actively eroding cut bank. It is a steep, unstable, rocky surface. EA page 17, first paragraph. The EA states: ADF&G is authorized under a special use permit to use the (former FS Sonar Cabin) site to support salmon monitoring and research. The special use permit to ADF&G to occupy and maintain the former FS Sonar cabin expired on December 31, 2015. This is my FOIA request for the special use special permit that currently authorizes ADF&G to use the former FS Sonar Cabin site to support salmon monitoring and research after December 31, 2015. Also for the NEPA document/decision, and MRA/MRDG that were prepared prior to the issuing of that special use permit to ADF&G to use the former FS Sonar Cabin site to support salmon monitoring and research beyond December 31, 2015. EA page 18. Alternative 4 which would authorize ADF&G to continue sheltering crews at the existing cabin in the Wilderness should be added EA page 18, seventh and eighth paragraphs. There is no history of large animal damage, theft high winds, or evidence of falling trees and branches at the former FS Sonar Cabin Site in the past 30 years EA page 18, ninth paragraph and page 26, third paragraph. Previous Recreation Opportunity Spectrum (ROS) inventories and documents concerning opportunities for solitude and portions of the Stikine-LeConte Wilderness that were at risk of not providing opportunities for solitude have demonstrated that Wilderness uplands adjacent to portions of the main stem of the Stikine River would not provide opportunities for solitude due to the motor boat traffic. The ROS for the lands adjacent to the main river from the river mouth up river to Shakes Hot Springs was Roaded Modified (RM) for social encounters. The Stikine River valley within the Stikine LeConte Wilderness has been referred to by Meg Mitchell, WRD Planner, as that part of the National Wilderness Preservation System with the greatest concentration of human made structures. Legislative direction is to preserve the undeveloped character of Wilderness. The Forest Service meets this direction by working to decrease the number of structures within designated Wilderness. Current Forest Service Manual (FSM) direction includes the following: Limit structures and improvements for administrative purposes or under special-use permit to those actually needed for management, protection, and use of the wilderness for the purposes for which the wilderness was established (FSM 2324.31). When existing improvements deteriorate to the point that normal maintenance does not keep them useable, analyze the need for such structures (FSM 2324.34).
Comments on the Sonar Cabin Replacement EA Page 10 of 11 EA page 20, second paragraph. An ADF&G float house near Kakwan Point or continuing the use of the FS Wilderness Cabin would not be marginal structure, and they would be closer to the monitoring site than a new permanent cabin at the site of the former FS Sonar cabin. EA page 22, third paragraph; page 23, sixth paragraph; and page 25, first paragraph. The construction of the first permanent administrative cabin in the Stikine-LeConte Wilderness would have a significant adverse impact on the undeveloped quality of the wilderness, wilderness character, and cumulative effects. EA page 23, third paragraph; and page 26 fifth paragraph. Past and current special use permits for cabin on the Wrangell Ranger District, including the Stikine-LeConte Wilderness, include a nonexclusive use clause, specifying that the area around the cabins remains open for public access. The inside of the cabin would not be available to the public, but the NFS lands around the cabin are not closed, and would be available for recreation. EA page 24, third paragraph. Vegetation clearing along the US/Canada boundary adjacent to the National Forest and Wilderness is not an activity in the Stikine-LeConte Wilderness. It is more similar to motor boats or hover crafts on the main channel of the river, or aircraft, including helicopters, in the airspace over the wilderness. EA page 25, second paragraph. Why would the temporary shelters be set up from April to August? The dates for Stikine Chinook monitoring are late April to early July. Where did the August date come from? Current permitted work in August for Andrew Creek Chinook is supported, when needed, from the ADF&G Kakwan Cabin and tent platform. The former FS Sonar cabin nor the FS Wilderness Cabin have not been occupied by fisheries workers in August. For the past three years aerial surveys have been done for Andrew Creek, and no on-site shelter was needed. EA page 26, second paragraph. There could be a problem for seasonal fisheries crews sheltered in tents, but there has been no reported compromise or diminishment in the amount and type of data for any of the years the seasonal fisheries monitoring crews have sheltered in the FS Wilderness Cabin. EA page 30, fourth paragraph. The replacement for the former FS Sonar cabin would (not will) occur on the same footprint of disturbed site as the original cabin, but according to design feature 2 (EA page 10) the cabin would be adjusted for visuals. EA page 34, fourth paragraph. The EA states: The crews need shelter in close proximity to the monitoring sites. But the former FS Sonar cabin site is not close to the current salmon monitoring site.
Comments on the Sonar Cabin Replacement EA Page 11 of 11 EA page 36. This is my FOIA request for details of the three cost estimates provided by ADF&G and referenced in the Economics section for Alternatives 1, 2 and 3. EA page 37, last section. We are taught in NEPA 101 that environmental analysis should be interdisciplinary. That the Interdisciplinary Team (IDT) should meet, and there should be notes taken at those meetings. It is noted that the Wilderness Specialist on the IDT has not been to the Stikine -LeConte Wilderness so lacks any personal knowledge of the area and the proximity of the locations and structures included in this analysis. I hope that can be corrected soon. Also, I was told by one IDT member, who upon requesting the time for an IDT meeting, was informed to just submit their report, there would be no IDT meeting. This is my FOIA request for the project initiation letter (PIL) that was sent to the IDT members listed in the EA. Also, my FOIA for the dates that the IDT listed in the EA met for a team meeting, and any notes that were taken at those IDT meetings. EA page A2, first section. The ADF&G Andrew Creek fisheries monitoring special use permit includes helicopter access to two sites in the Andrew Creek drainage. Petersburg High School and the University of Alaska are authorized by a special use permit for LeConte Glacier monitoring and research including helicopter access. EA page A2, ninth and tenth paragraphs. The correct name for the Stikine River town in British Columbia is Telegraph Creek, not just Telegraph as stated in the EA Thank you for considering my comments to the Sonar Cabin Replacement Environmental Assessment. David Rak Interested Person