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DOCKET NO. PF14-21-000
DRAFT RESOURCE REPORT NO. 4
CULTURAL RESOURCES
PUBLIC
Document Number: USAI-PE-SRREG-00-000004-000
ALASKA
LNG PROJECT
DOCKET NO. PF14-21-000
DRAFT RESOURCE REPORT NO. 4
CULTURAL RESOURCES
DOC NO: USAI-PE-SRREG-00-
000004-000
DATE: JULY 15, 2016
REVISION: 0
PUBLIC
4-i
RESOURCE REPORT NO. 4
SUMMARY OF FILING INFORMATION 1
Filing Requirement Found in Section
1. Initial cultural resources consultation and documentation, and documentation of consultation with Native Americans. (18 C.F.R. § 380.12(f)(1)(i) & (2))
See 18 C.F.R. § 380.14 for specific procedures.
4.2.3
Table 4.2.3-1
Appendix C
2. Overview/Survey Report(s). (18 C.F.R. § 380.12(f)(1)(ii) & (2)
See 18 C.F.R. § 380.14 for specific procedures.
For the offshore area this will usually require completion of geophysical and other underwater surveys before filing.
4.4
Appendix B
Additional Information Often Missing and Resulting in Data Requests
Provide a Project map with mileposts (MP), clearly showing boundaries of all areas surveyed (ROW, extra work areas, access roads, etc.) and to be surveyed with corridor widths clearly specified.
Appendix A
Provide documentation of consultation with SHPOs, THPOs, and applicable land-managing agencies regarding the need for and required extent of cultural resource surveys.
4.2
Appendix C
Provide a narrative summary of overview results, cultural resource surveys completed, identified cultural resources and any cultural resource issues.
4.4
4.5
Provide a Project specific Ethnographic Analysis (can be part of Overview/Survey Report).
Interim report available in Appendix B of this report. Will be updated for Federal Energy Regulatory Commission (FERC) application.
Identify by mileposts any areas requiring survey for which the landowner denied access. Appendix D
Provide written comments on the Overview and Survey Reports, if available, from the SHPOs or THPOs, as appropriate, and applicable land-managing agencies.
Appendix C
Provide a Summary Table of completion status of cultural resource surveys, and SHPO or THPO and land-managing agency comments on the reports.
Table 4.4-2, Appendix D
Provide a Summary Table of identified cultural resources, and SHPO or THPO and land-managing agency comments on the eligibility recommendations for those resources.
Table 4.5-1, Appendix E
Provide a brief summary of the status of Native American consultation, including copies of all related correspondence and records of verbal communications.
4.2.3
Appendix C
Provide a schedule for completing any outstanding cultural resource studies.
Remaining areas requiring survey will be completed for the FERC application where survey permission has been
1 Guidance Manual for Environmental Report Preparation (FERC, 2002). Available online at:
http://www.ferc.gov/industries/gas/enviro/erpman.pdf.
ALASKA
LNG PROJECT
DOCKET NO. PF14-21-000
DRAFT RESOURCE REPORT NO. 4
CULTURAL RESOURCES
DOC NO: USAI-PE-SRREG-00-
000004-000
DATE: JULY 15, 2016
REVISION: 0
PUBLIC
4-ii
RESOURCE REPORT NO. 4
SUMMARY OF FILING INFORMATION 1
Filing Requirement Found in Section
granted.
Provide an Unanticipated Discoveries Plan for the Project area, referencing appropriate state statutes.
Appendix F
Additional Information Sometimes Requested
Identify the project APE in terms of direct or indirect effects to known cultural resources. 4.3.1
Resource Report No. 4 Agency Comments and Requests for Information Concerning Cultural Resources
Agency Date Comment Response/Resource Report
Location
Alaska
Department of
Natural
Resources
(ADNR)/Office
of History and
Archaeology
(OHA)/State
Historic
Preservation
Office (SHPO)
3-Apr-15 Section 4.2. Table 4.2.1-1 - We have record of
participating in more of these consultation meetings
than is shown in the table. We have record of our
participation in the 2/25-2/27/2014 and 3/4/14
meetings; as well as additional informal consultation
meetings on 5/15, 6/27, 8/27, and 12/17.
Comment acknowledged. Tables 4.2.1-
1 and 4.2.2-1 have been updated.
ADNR/OHA/
SHPO
3-Apr-15 ALL. Please explain up front that the Alaska State
Historic Preservation Office(r) (SHPO) is housed
within the State’s Office of History and Archaeology
(OHA). Then, throughout, refer to our office as
OHA/SHPO. These are used interchangeably in the
document (and mostly it refers to OHA), which is
confusing for the reader.
Comment acknowledged. For the
SHPO/OHA explanation, see Section
4.1.2. The text also modified
throughout to read “OHA/SHPO.”
ADNR/OHA/
SHPO
3-Apr-15 Section 4.3.1 - Does the APE include borrow
areas/material sources?
Section 4.3.1 has been updated.
ADNR/OHA/
SHPO
3-Apr-15 Section 4.3.2 - Third full paragraph, second
sentence: change “data was” to “data were”
The text has been revised.
ADNR/OHA/
SHPO
3-Apr-15 Section 4.4 - End of second sentence: remove extra
comma behind “i.e.,”
The text has been revised.
ADNR/OHA/
SHPO
3-Apr-15 Section 4.5.1 - End of first paragraph: It is curious
why BET-00137 is called out specifically regarding
not having a formal NRHP eligibility determination
when the beginning of the fourth paragraph states
that the majority of the sites identified have not been
formally evaluated.
Comment acknowledged. The site was
originally included as a point of interest;
however, it has now been removed to
stay consistent with the text.
ALASKA
LNG PROJECT
DOCKET NO. PF14-21-000
DRAFT RESOURCE REPORT NO. 4
CULTURAL RESOURCES
DOC NO: USAI-PE-SRREG-00-
000004-000
DATE: JULY 15, 2016
REVISION: 0
PUBLIC
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Resource Report No. 4 Agency Comments and Requests for Information Concerning Cultural Resources
Agency Date Comment Response/Resource Report
Location
ADNR/OHA/
SHPO
3-Apr-15 Section 4.5.2 - Near end of first paragraph, the
acronym for Federal Highway Administration is
FHWA.
The text has been revised.
ADNR/OHA/
SHPO
3-Apr-15 Section 4.5.2 - Second to final paragraph, change
“low” to “lower.”
This edit was made. The paragraph on
CHN-00025 was changed to reflect the
determination that the site was eligible
for the NRHP.
ADNR/OHA/
SHPO
3-Apr-15 Section 4.7 - First paragraph, fifth sentence should
read: “Project redesign to avoid effects may be an
option, depending on SHPO, FERC, and/or BLM
concurrence or requirements.”
This edit was made. The sentence is
now in the fourth paragraph of this
section.
ADNR/OHA/
SHPO
3-Apr-15 Section 4.7 - First paragraph, third sentence from
end. Change “Criterion D” to “NRHP Criterion D.”
This edit was made. The sentence is
now in the fourth paragraph of this
section.
ADNR/OHA/
SHPO
3-Apr-15 Section 4.7 - Second paragraph, change “effected”
to “affected.”
This edit was made. See revised text in
Section 4.7, paragraph 5, sentence 2.
ADNR/OHA/
SHPO
3-Apr-15 Section 4.7 - This entire section needs work to
introduce and explain the need for and purpose of a
Programmatic Agreement. The second paragraph
refers to a Memorandum of Agreement, which would
not be appropriate for a project of this magnitude.
Any treatment approaches, including avoidance,
minimization, and mitigation measures would all be
built into a PA for the project as a whole. Please
provide much more detail on the consultation that
goes into a PA and the anticipated outcomes.
The Section 4.7 text was revised per
guidance from the Federal Energy
Regulatory Commission (FERC) that it
would not advance a Programmatic
Agreement (PA), but rather a
Memorandum of Agreement (MOA), for
any National Register of Historic Places
(NRHP)-eligible sites that cannot be
avoided by construction of the Alaska
LNG Project (Project).
ADNR/OHA/
SHPO
3-Apr-15 Section 4.9 - The Discoveries Plan will be
incorporated into or appended to the PA. In addition,
we recommend, for a project of this site, that the
Discoveries Plan should either clearly delineate the
discovery and notification process for cultural
resources versus human remains, or perhaps that a
separate Human Remains Discoveries Plan be
developed. This section, like 4.7 and 4.8 before it,
needs a great deal more detail on the need for and
purpose of a PA.
Please see the response above
regarding the use of an MOA rather
than a PA for this Project. The
Unanticipated Discovery Plan in
Appendix F has been revised to
address the individual processes for
discovery of cultural resources (Section
3) and human remains (Section 4). It is
anticipated that it would be incorporated
into the MOA for the Project.
ADNR/OHA/
SHPO
3-Apr-15 Appendix F - The table that provides a list of
potential impacts is nearly useless for consideration
of potential impacts to cultural resources and historic
properties. It does nothing to explain how things like
erosion, or spills/releases, for example, actually
affect cultural resources. Furthermore, the List of
Potential Plans that follows does not include the
primary tool which will be used to address cultural
resource/historic properties impacts on this project:
the PA.
Appendix F has been replaced with a
discussion of impacts and mitigation
(Sections 4.7 and 4.8) in the body of the
Resource Report. As noted above,
FERC would not advance a PA on this
Project, but would use an MOA. Text in
Section 4.7 has been updated to better
reflect the importance of the MOA.
ALASKA
LNG PROJECT
DOCKET NO. PF14-21-000
DRAFT RESOURCE REPORT NO. 4
CULTURAL RESOURCES
DOC NO: USAI-PE-SRREG-00-
000004-000
DATE: JULY 15, 2016
REVISION: 0
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Resource Report No. 4 Agency Comments and Requests for Information Concerning Cultural Resources
Agency Date Comment Response/Resource Report
Location
ADNR/OHA/
SHPO
3-Apr-15 Appendix G - This plan should be much more
robust. Also, we recommend not combining the
procedures for cultural resources and human
remains. These should be separated out in this plan
or two separate plans should be developed. It does
not address if/when archaeological monitors will be
on site nor provide sufficient detail on how personnel
will be appropriately trained in cultural resource and
human remains sensitivity. Under item 1 on first
page, change “material of potential cultural
significance” to “material culture.” Under item 5 on
the second page, change “fine” to “find.” Laurie
Boros’s name and email address are incorrect
throughout. Under item 6.A.4., change “’not
significant’ finding” to “the recommended
determination of eligibility.” This section also needs
to specify that consultation with FERC and SHPO
regarding any eligibility determinations shall occur
before moving forward with assessing effect. Under
item 6.A.5, change “as directed by the SHPO or
FERC.” to “as directed by FERC, in consultation with
the SHPO.” Under item 6.A.6, please list FERC first,
then SHPO. Under item 6.A.6, please note that
through the development of the PA, ideally these
Treatment Plans will be prepared in advance, rather
than on a case-by-case basis. This approach would
be incredibly time-consuming and potentially cause
substantial project delays (case-by-case
consultation and development of individualized
treatment plans for each discovery). Under item
6.A.7, please list FERC first, then SHPO. Under item
6.B.3, please change “’not significant’ finding” to “the
recommended determination of eligibility.” Under
item 6.B.5 and 6.B.6, FERC should be included first
in the list of parties that are consulted. The human
remains section should be much more robust. Also,
for State and private lands, please discuss this with
Richard VanderHoek, State Archaeologist. Under
item 6.C.3, a discussion of consultation should be
included in this section; that it is required before any
decisions are made to excavate or re-inter any
human remains. Finally, for the Federal lands within
the project area, each Federal agency will likely be
preparing a NAGPRA Plan of Action (POA) for their
portion of the project. This should be addressed,
discussed, and explained.
The Unanticipated Discoveries Plan has
been revised, based on a plan that was
previously approved by OHA/SHPO for
geotechnical and geophysical work. It
is now included as Appendix F. The
Project would be happy to continue
consultation with OHA/SHPO to
improve on the existing plan as needed.
Treatment plans will be developed once
FERC and the agencies have agreed to
the determination of eligibility that has
been provided with this draft. See
Appendix B, Reports# USAI-P1-
SRZZZ-00-000007-000, USAI-P1-
SRZZZ-00-000005-000, and USAI-P1-
SRZZZ-00-000004-000.
OHA/SHPO provided comments on the
determination of eligibility (DOE) reports
in a letter dated Feb 11, 2016.
FERC 15-May-15 General - 1. Include citations for sources and
referenced materials, including web-based data.
Attachment B includes a list of identified missing
citations/references; however, this list is not
considered all-inclusive.
Comment acknowledged; please see
the updated Section 4.10. All
references cited in the text have been
checked. Attachment B does not
include specific comments on Resource
Report 4.
ALASKA
LNG PROJECT
DOCKET NO. PF14-21-000
DRAFT RESOURCE REPORT NO. 4
CULTURAL RESOURCES
DOC NO: USAI-PE-SRREG-00-
000004-000
DATE: JULY 15, 2016
REVISION: 0
PUBLIC
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Resource Report No. 4 Agency Comments and Requests for Information Concerning Cultural Resources
Agency Date Comment Response/Resource Report
Location
FERC 15-May-15 General - 2. Include complete reports and
appendices, without placeholders for data or
information required to meet the minimum filing
requirements. Also, resolve each acknowledged
data gap and each location where a placeholder
indicates information is forthcoming. Attachment C
provides a summary of the identified data gaps and
forthcoming information that Alaska LNG has
already confirmed is pending.
Comment acknowledged. Most blank
appendices have been filed with this
draft; the remainder are planned for the
FERC application. Attachment C gaps
are provided in each Resource Report
pointing where data gaps have been
addressed.
FERC 15-May-15 General - 3. Address/respond to the comments
provided by the National Oceanic and Atmospheric
Administration’s (NOAA) National Marine Fisheries
Service (NMFS); U.S. Army Corps of Engineers
(USACE); U.S. Fish and Wildlife Service (FWS);
U.S. Department of the Interior, Bureau of Land
Management (BLM); U.S. Environmental Protection
Agency (EPA); National Park Service; U.S. Coast
Guard (USCG), and State of Alaska. These
comments are included as attachment D.
See Agency Comment response tables
in each Resource Report.
FERC 15-May-15 General - 4. Include cross references between
resource reports for information applicable to
multiple reports so it is clear where the information
can be found.
Comment acknowledged. See above.
FERC 15-May-15 All material filed with the Commission containing
location, character, and ownership information about
cultural resources must have the cover and any
relevant pages therein clearly labeled in bold
lettering: “CONTAINS PRIVILEGED INFORMATION
– DO NOT RELEASE.”
Comment acknowledged. This draft
has been labeled accordingly.
FERC 15-May-15 1. Update correspondence (including any
enclosures/attachments, in color if originally
provided in color), meeting notes, phone logs, etc.,
to and from the:
a. SHPO (section 4.2.2.1, page 4-6), including:
i. any comments regarding the definition of the direct
and indirect Area of Potential Effects (APE);
ii. any comments on the Unanticipated Discovery
Plan (appendix G of Resource Report 4);
iii. revise communications with the SHPO that are
not listed in table 4.2.2-1; but are listed in appendix
D, table D-2 of Resource Report 1 (for example
OHA, 3/12/2014); and
iv. comments on the reports produced to date;
Comments received have been
included in Section 4.2.1.1; Resource
Report 1, Appendix D; and Resource
Report 4, Appendix C.
FERC 15-May-15 b. BLM and other consulting federal agencies
(section 4.2.1.2, page 4-5), including comments on
the reports produced to date;
Comments received have been
included in Section 4.2.1.2.
ALASKA
LNG PROJECT
DOCKET NO. PF14-21-000
DRAFT RESOURCE REPORT NO. 4
CULTURAL RESOURCES
DOC NO: USAI-PE-SRREG-00-
000004-000
DATE: JULY 15, 2016
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Resource Report No. 4 Agency Comments and Requests for Information Concerning Cultural Resources
Agency Date Comment Response/Resource Report
Location
FERC 15-May-15 c. federally recognized Indian tribes in Alaska, local
and regional corporations as defined in the Alaska
Native Claims Settlement Act (ANCSA; Title 43
United States Code [U.S.C.] Section 1602), and
non-profit Alaska Native organizations (section
4.2.3, page 4-6), including any comments on the
reports produced to date; and
Text revised to include available
correspondence. See Section 4.2.3.
FERC 15-May-15 d. parties that have an interest in cultural resources
that may be affected by the Project. (Section 4.2.4,
page 4-7)
No correspondence or comments from
other parties have been received.
FERC 15-May-15 2. As defined in 36 CFR 800.16 (m) “Indian tribe”
means an Indian tribe, band, nation, or other
organized group or community, including a native
village, regional corporation or village corporation,
as those terms are defined in section 3 of the Alaska
Native Claims Settlement Act (43 U.S.C. 1602).
Define the parties included in “Alaska Native
Organizations and Groups” (section 4.2.3, page 4-
6). Revise sections 4.1.2, 4.2.3, and 4.2.4 to
address the Knik Tribal Council’s comments of
February 20, 2015.
Section 4.2.3 has been revised to
include comments from Knik Tribal
Council received February 20, 2015.
FERC 15-May-15 3. The preliminary direct APE is defined as a 300-
foot-wide cultural resource corridor. (Section 4.3.1,
page 4-8)
a. The 2010, 2011, and 2013 Phase I Cultural
Resource Summary Report: Archaeological Survey
and Site Documentation (USAKE-UR-SRZZZ-00-
0017) states that the APE includes a 300- to 600-
foot right-of-way corridor. Clarify the apparent
discrepancy with the definition of the preliminary
direct APE.
Section 4.4.3 has been revised to
explain that the first studies for the
Project anticipated a 300–600-foot-wide
right-of-way (ROW) corridor and this
was narrowed to a 300-foot-wide
corridor for the 2014 field season.
FERC 15-May-15 b. Identify the survey corridor width inventoried
along planned Project access roads.
Section 4.4.3 has been revised to
indicate that the survey corridor was
150 feet centered on the access road
centerline.
FERC 15-May-15 c. Clarify whether surveys for submerged cultural
resources are planned where alteration of the
seabed may occur. Include the report for any
planned submerged cultural resources survey and
the SHPO’s and other appropriate agencies’
comments on the report.
Geophysical survey data were reviewed
and the results are included in Sections
4.2.4.1.2 and 4.2.4.2.8; the report is
included in Appendix B. Text added
summarizing the proposed methods for
evaluating the presence of submerged
cultural resources in Cook Inlet has
been provided in Section 4.3.2.
FERC 15-May-15 d. Include a final definition of the direct and indirect
APE (terrestrial and marine).
The direct Area of Potential Effect
(APE) is discussed in Section 4.3.1.
The indirect APE will be defined upon
further consultation with agencies after
their review of this Draft.
ALASKA
LNG PROJECT
DOCKET NO. PF14-21-000
DRAFT RESOURCE REPORT NO. 4
CULTURAL RESOURCES
DOC NO: USAI-PE-SRREG-00-
000004-000
DATE: JULY 15, 2016
REVISION: 0
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Resource Report No. 4 Agency Comments and Requests for Information Concerning Cultural Resources
Agency Date Comment Response/Resource Report
Location
FERC 15-May-15 4. Clarify whether artifacts identified at the ground
surface were collected for curation and where all
materials collected would be curated. (Section 4.3.2,
page 4-10)
The Section 4.3.2 text has been
clarified. Diagnostic artifacts, stone
tools, and unique artifacts were
collected. A curation agreement with
University of Alaska Museum of the
North (UAMN) is in place.
FERC 15-May-15 5. Research on previous surveys and known sites
was documented within a 2,000-foot-wide study
corridor (section 4.4.3, page 4-11). The Phase I
survey reports (in appendix B of Resource Report 4),
USAKE-UR-SRZZZ-00-0017 and USAKE-UR-
SRZZZ-00-0021, discuss previously recorded
resources within a 1-mile buffer. Report USAI-UUR-
SRZZZ-00-000014-000 includes a 3-mile buffer for
the background research. Clarify the apparent
discrepancy between the buffer(s) used for
conducting background research.
The background study areas varied
between the pipeline and Liquefaction
Facility. The buffer was larger at the
Liquefaction Facility due to the need to
eventually consider indirect effects.
See Section 4.4.3.
FERC 15-May-15 6. Regarding the 2010, 2011, and 2013 Phase I
Cultural Resource Summary Report: Archaeological
Survey and Site Documentation (USAKE-UR-
SRZZZ-00-0017), 90 sites were identified in the
survey corridor, including 47 prehistoric and 13
historic sites (page 11). Clarify the temporal
affiliation for the remaining 30 sites.
All sites located within the direct APE
are listed in Tables E-2 and E-3.
Because the Project footprint has
changed since cultural resource
investigations began, not all sites
discussed in the technical reports would
be located within the direct APE. The
maps in Appendix A and tables in
Appendix E provide information about
all resources found as well as depict the
direct APE.
FERC 15-May-15 7. Regarding the 2013 Phase I Cultural Resource
Report: Archaeological Survey and Site
Documentation (USAKE-UR-SRZZZ-00-0021):
a. about 122 acres were reported as excluded from
survey due to a desktop review or based upon
proximity to previously surveyed land (page 33).
Clarify if this acreage was excluded from survey
based on the geomorphic context;
See Appendix B, Report (USAKE-UR-
SRZZZ-00-0021), Page 32, for
clarification. The text notes that very
small parcels were considered low
potential areas due to steep slope, low
topographic relief, long distances to
water, and restricted vistas.
FERC 15-May-15 b. page 3 indicates 9 previously recorded sites were
revisited, page 38 indicates 14, tables 6-3 to 6-5 list
10, and table 8-1 lists 8. Clarify the number of sites
revisited; and
c. define what constitutes an “anomalous landform”
(page 49).
An anomalous landform could include
prominent rock feature, such as a tor or
bedrock outcrop, in an area where
others are not found.
ALASKA
LNG PROJECT
DOCKET NO. PF14-21-000
DRAFT RESOURCE REPORT NO. 4
CULTURAL RESOURCES
DOC NO: USAI-PE-SRREG-00-
000004-000
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FERC 15-May-15 8. The 2014 Phase I Cultural Resources Inventory
Report for the Proposed Liquefaction Facility
Component of the Alaska LNG Project, Nikiski,
Alaska (USAI-UUR-SRZZZ-00-000014-000) states
that the archaeological survey was in part intended
to develop a preliminary list of aboveground
resources that would be assessed for historic and/or
architectural significance (page 22). Clarify whether
aboveground resources were identified for
assessment or were excluded from further
assessment as a result of this survey.
The report of the Liquefaction Facility
indicates that the buildings within the
direct APE that were surveyed are
modern and were, therefore, excluded
from further assessment (see Appendix
B).
FERC 15-May-15 9. Include a copy of the 2014 Cultural Resources
Data Gap Analysis and Sensitivity Model (USAKE-
UR-SRZZZ-00-0033) report, which was missing from
appendix B of Resource Report 4.
See Appendix B.
FERC 15-May-15 10. In tables E-2 and E-3 of appendix D of Resource
Report 4, include a column for Alaska LNG’s
recommended future action.
See Tables E-2 and E-3. The
requested columns were added.
FERC 15-May-15 11. Include the Ethnographic Study referenced in
section 4.6 (page 4-17).
The ethnographic study conducted to
date is described in Section 4.6. An
interim report is available in Appendix
B. The final report will be filed with the
FERC application.
FERC 15-May-15 12. In section 4.1.1, note the National Historic
Preservation Act has moved from 16 U.S.C. 470 to
54 U.S.C. 300101.
The text in section 4.1.1 has been
updated.
FERC 15-May-15 13. Delete the last sentence in section 4.7. Clarify
that the Advisory Council on Historic Preservation
may participate in consultation to resolve adverse
effects to historic properties and that a
Memorandum of Agreement outlining the measures
to avoid, minimize, or mitigate adverse effects on
historic properties would be prepared in consultation
with the SHPO and others such as Alaska Native
tribes.
See Section 4.7 for the revised text.
FERC 15-May-15 14. Clarify what types of impacts on cultural
resources Alaska LNG anticipates from operation of
the Project, and why these would not have been
addressed during the survey, evaluation, and
impacts assessment phases of the Project.
See Section 4.8.
FERC 15-May-15 15. Ensure that the Matanuska-Susitna Borough
receives all required information and updates (see
comment of April 16, 2015).
Comment acknowledged.
FERC 15-May-15 16. In the Unanticipated Discovery Plan (appendix G
of Resource Report 4), correct the FERC contact to:
Laurie Boros, Archaeologist; [email protected].
The text has been corrected. The
appendix numbering has changed; now
the Unanticipated Discovery Plan is
Appendix F.
ALASKA
LNG PROJECT
DOCKET NO. PF14-21-000
DRAFT RESOURCE REPORT NO. 4
CULTURAL RESOURCES
DOC NO: USAI-PE-SRREG-00-
000004-000
DATE: JULY 15, 2016
REVISION: 0
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Agency Date Comment Response/Resource Report
Location
FERC 15-May-15 17. Include the enclosures (in color, if originally
provided in color) to Alaska LNG’s October 23, 2014
letters to the tribes (contained in Resource Report 1,
appendix D).
Correspondence is provided in
Appendix D of Resource Report No. 1.
FERC 15-May-15 18. The land required to construct the GTP facility is
estimated to be 1,000 acres (Resource Report 1,
section 1.4, table 1.4-1, page 1-20). The Alaska
Pipeline Project surveyed about 743 acres between
2010 and 2012 within the current footprint of the
GTP. Alaska LNG surveyed an additional 8 acres of
the GTP in 2013, but has not yet surveyed the
associated facilities (sections 4.4.2 and 4.4.3, page
4-11 and table 4.4-1, page 4-13). Confirm whether
the unsurveyed portions of the GTP depicted in
appendix 4A, sheets T1 and T2 require survey and,
if not, explain why additional survey is not needed.
Also, include comments from the Alaska SHPO
regarding the adequacy of the previous Alaska
Pipeline Project survey coverage of the GTP.
Calculations for survey of the Gas
Treatment Plant (GTP) and facilities are
included in the updated survey status
Table 4.4-2. The Project did not obtain
any correspondence from OHA/SHPO
on the adequacy of the Alaska Pipeline
Project (APP) survey data. However,
because the methodology is the same
for the Alaska LNG Project, and the
OHA/SHPO has concurred with the
current methodology, the prior survey
data is consistent and can be applied to
this Project.
FERC 15-May-15 19. Two paleontological sites are reported within the
preliminary APE (section 4.5.2, page 4-15 and
appendix E, table E-1). Clarify whether these sites
are archaeological in nature. Also, include the
regulatory context or guidance for assigning state
archaeological site numbers to paleontological sites
identified on non-federal lands. (Section 4.1.2, page
4-4).
The text was revised to clarify that
paleontological sites are not
archaeological and not regulated under
Section 106 of the National Historic
Preservation Act (NHPA). The report
mentions them only in that the SHPO
issues site numbers to “some
paleontological sites.” See Section 4.5
text and footnote.
FERC 15-May-15 20. Confirm that Alaska LNG would avoid all
National Register of Historic Places (NRHP)-eligible
sites.
The text in Section 4.7, Paragraph 4,
was revised to indicate that the Project
would avoid NRHP-eligible sites to the
extent practicable.
FERC 15-May-15 21. Include copies of all cultural resources reports
prepared for surveys undertaken by Alaska LNG in
2013 and 2014. The results of these surveys should
be included in a report(s) prepared in accordance
with FERC and applicable state guidelines. Also
include the Phase II report. Include the SHPO’s and
other appropriate agencies’ comments on the
reports.
Copies of the reports and SHPO
correspondence are provided in
Appendix B (reports) and Appendix C
(correspondence).
Resource Report No. 4: Cultural Resources Scoping Comments
Date Type Individual/
Organization Comment
Resource Report Location
4-Dec-15 Letter Sattler (Tanana Chiefs Conference)
2. Cultural resources review should include extensive outreach on traditional and customary use areas and develop mitigation measures to minimize impacts to subsistence
Outreach to Alaska Natives and other interested parties has been occurring since 2013 and is documented in Resource Report No. 4, Appendix C. Consultation will continue through the
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Resource Report No. 4: Cultural Resources Scoping Comments
Date Type Individual/
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Resource Report Location
economies where incomes are low and unemployment high. ...Particularly concerning are issues posed by user conflicts, trespassing and encroachment through the pioneering corridor in the eastern Minto Flats area.
Environmental Impact Statement (EIS) process. Traditional knowledge surveys are included in Appendix D of Resource Report No. 5.
16-Oct-15 Letter Call (Knik Tribal Council)
Concerns about Project impacts on Knik tribe people, tribal lands and resources
Both Resource Reports Nos. 4 (Cultural Resources) and 5 (Socioeconomics) provide assessments of potential Project impacts to Alaska Native tribes. Additional information will be provided in the FERC application and EIS as consultation continues through the review process.
27-Oct-15 Meeting Transcript
FERC Public Scoping Meeting – Nikiski
Families have spread ashes off the bluff, it is sacred ground.
Project representatives, as the non-federal representative for Section 106 consultation under the National Historic Preservation Act (NHPA), have initiated information outreach to consulting parties and provided the information gathered in that process in Appendix C of Resource Report No. 4. Memorandums of Agreement (MOAs) would be developed by FERC with the appropriate consulting parties prior the start of construction to mitigate, minimize, or avoid potential adverse effects from the Project to properties eligible for listing on the National Register of Historic Places (NRHP).
18-Nov-15 Meeting Transcript
FERC Public Scoping Meeting – Tyonek
The Chuitna River is the area of our ancestors.
By following the Parks Highway for a significant portion of the crossing of the Chulitna River basin, new impacts would be minimized and a new corridor through the region would be avoided.
4-Dec-15 Letter EPA – Seattle, WA
Historical and Cultural Resources - We recommend that you consult with the Alaska State Historic Preservation Officer (SHPO) and impacted tribal governments, respecting tribal sovereignty and the G2G relationship between the Federal and tribal governments. We recommend that this consultation process run concurrently with the NEPA and Federal/State permitting processes. If adverse effects to traditional cultural properties, sacred sites, or other areas of cultural resource concerns are identified, we recommend that any Memorandum of Agreement (MOA) developed to resolve these concerns be developed prior to issuance of and included in
The Project representatives, as the non-federal representative for Section 106 consultation under the NHPA, have conducted information outreach to all affected parties and provided the information gathered in that process in Appendix C of Resource Report No. 4. FERC has initiated the government-to-government consultation process and will continue to do so through the EIS process. MOAs would be developed by FERC with the appropriate parties prior the start of construction for any eligible properties that may be impacted by the Project.
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Resource Report No. 4: Cultural Resources Scoping Comments
Date Type Individual/
Organization Comment
Resource Report Location
the Record of Decision (ROD) for this EIS
4-Dec-15 Letter EPA – Seattle, WA
Historical and Cultural Resources - Consider the perspectives of the tribal government(s) to determine whether the area of potential effects would be eligible for the National Register of Historic Places. Include significant events that may have taken place in the past (tribal wars, establishment of trade routes, etc.)
Results of the cultural field studies are shared with the Office of History and Archaeology (OHA)/State Historic Preservation Office (SHPO), which determines whether a site is eligible for listing under the NRHP. Areas of Potential Effects (APEs) (direct and indirect) are discussed in Section 4.3.1 of this report. FERC will also continue the government-to-government consultation process started in 2015.
4-Dec-15 Letter EPA – Seattle, WA
Historical and Cultural Resources - Consult with tribal governments, local governments, the public, in addition to SHPO on historic preservation issues
The Project representatives, as the non-federal representative for Section 106 consultation under the NHPA, have conducted information outreach to all affected parties, including those mentioned, and provided the information gathered in that process in Appendix C of Resource Report No. 4. FERC has initiated the government-to-government consultation process and will continue to do so through the EIS process. MOAs would be developed by FERC with the appropriate parties prior the start of construction for any eligible properties that may be impacted by the Project.
4-Dec-15 Letter EPA – Seattle, WA
Historical and Cultural Resources - Evaluate the Native Alaskan historical and traditional significance of the project area, the importance of ethno botany, hunting, fishing, and gathering uses of the area by Alaska Natives, any long term traditional ecological management of the area, and any significant historic events that took place in the area
A Traditional Knowledge survey has been conducted by the Project and is included in Appendix D of Resource Report No. 5.
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Resource Report No. 4: Cultural Resources Scoping Comments
Date Type Individual/
Organization Comment
Resource Report Location
4-Dec-15 Letter EPA – Seattle, WA
Historical and Cultural Resources - The scope of impacts to these resources would include the direct, indirect, and cumulative impacts to sacred sites; traditional cultural properties or landscapes; hunting, fishing, gathering areas; access to traditional and current hunting, fishing, and gathering areas and species; changes in hydrology or ecological composition of springs, seeps, wetlands, and streams, that could be considered sacred or have traditional resource use association; historical and currently used travel and migration routes; and historic properties, districts or landscapes
A preliminary assessment of impacts to historic properties is provided in Sections 4.7 (Potential Construction Impacts and Mitigation Measures) and 4.8 (Potential Operational Impacts and Mitigation Measures) of Resource Report No. 4. A Traditional Knowledge survey, including subsistence hunting and fishing, has been conducted and is included in Appendix D of Resource Report No. 5. A Subsistence Impact Analysis will also be completed for the FERC application. Details about the methodology for this analysis are in Appendix E of Resource Report No. 5. FERC’s government–to-government consultation would reveal if any traditional cultural properties or landscapes are within the Project footprint and would address those in the EIS process.
4-Dec-15 Letter EPA – Seattle, WA
Historical and Cultural Resources - Conduct the review of historic preservation issues concurrently with the EIS process. Complete the review prior to issuing the ROD, which would provide for the implementation of the MOA terms
FERC would complete the 106 consultation process in the course of developing the EIS as indicated in this comment.
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TABLE OF CONTENTS
4.0 RESOURCE REPORT NO. 4 – CULTURAL RESOURCES ................................................ 4-1 4.1 PROJECT DESCRIPTION .......................................................................................... 4-1
4.1.1 Purpose of Resource Report ............................................................................... 4-3 4.1.2 Regulatory Context ............................................................................................. 4-4
4.2 AGENCY AND ORGANIZATION CONSULTATION ............................................ 4-5 Consultation with Federal Land Managing Agencies ......................................... 4-5
4.2.1.1 Bureau of Land Management (BLM) .................................................. 4-5 4.2.1.2 Other Federal Agencies ....................................................................... 4-6
Consultation with State Agencies ....................................................................... 4-7 4.2.2.1 Office of History and Archaeology (OHA)/State Historic Preservation
Office (SHPO) .................................................................................................... 4-7 4.2.3 Consultation with Federally Recognized Indian Tribes and Alaska Native
Corporations..................................................................................................................... 4-9 4.2.3.1 Comments from Specific Tribes and Alaska Native Organizations .... 4-9 4.2.3.2 Cultural Resource Advisor Program .................................................. 4-10
4.2.4 Consultations with Other Interested Parties ...................................................... 4-14 4.3 AREA OF POTENTIAL EFFECT AND SURVEY METHODOLOGY ............... 4-15
4.3.1 Area of Potential Effect (APE) ......................................................................... 4-15 4.3.2 Survey Methodology......................................................................................... 4-18
4.3.2.1 Existing Data/Desktop Study ............................................................. 4-18 4.3.2.2 Current Project Field Studies ............................................................. 4-19
4.4 ARCHAEOLOGICAL AAND ABOVEGROUND RESOURCES BACKGROUND
RESEARCH AND SURVEY RESULTS ................................................................... 4-21 4.4.1 ASAP Project .................................................................................................... 4-21 4.4.2 Alaska Pipeline Project (APP) .......................................................................... 4-22 4.4.3 Point Thomson Project ...................................................................................... 4-22 4.4.4 Project Survey Summary and Status ................................................................. 4-22
4.5 ARCHAEOLOGICAL, MARINE, AND ABOVEGROUND RESOURCES:
BACKGROUND AND SURVEY RESULTS ............................................................ 4-26 4.5.1 Sites Located within the 2,000-Foot-Wide Study Area .................................... 4-26 4.5.2 Results of Surveys within the Preliminary APE ............................................... 4-28
4.5.2.1 Liquefaction Facility .......................................................................... 4-30 4.5.2.2 Mainline ............................................................................................. 4-31
4.5.3 Sites Located within Mainline Associated Infrastructure ................................. 4-37 4.5.3.1 Pipe Storage Yards ............................................................................. 4-37 4.5.3.2 Compressor Stations .......................................................................... 4-38 4.5.3.3 Camps ................................................................................................ 4-38 4.5.3.4 Additional Temporary Workspace (ATWS) ...................................... 4-38 4.5.3.5 Material Sites ..................................................................................... 4-39 4.5.3.6 Access Roads ..................................................................................... 4-39
4.5.4 Non-Jurisdictional Facilities ............................................................................. 4-40 4.6 ETHNOGRAPHIC STUDY ........................................................................................ 4-41 4.7 POTENTIAL CONSTRUCTION IMPACTS AND MITIGATION MEASURES 4-42
4.7.1 Liquefaction Facility ......................................................................................... 4-43
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4.7.1.1 Cultural Resource Treatment Plans ................................................... 4-43 4.7.2 Interdependent Facilities ................................................................................... 4-44
4.7.2.1 Pipeline .............................................................................................. 4-44 4.7.2.2 GTP and Associated Infrastructure .................................................... 4-46
4.7.3 Non Jurisdictional Facilities ............................................................................. 4-46 4.8 POTENTIAL OPERATIONAL IMPACTS AND MITIGATION MEASURES .. 4-46
4.8.1 Liquefaction Facility ......................................................................................... 4-47 4.8.2 Interdependent Facilities ................................................................................... 4-47
4.8.2.1 Pipelines ............................................................................................. 4-47 4.8.2.2 Gas Treatment Plant (GTP) ............................................................... 4-48
4.8.3 Non Jurisdictional Facilities ............................................................................. 4-48 4.9 UNANTICIPATED DISCOVERIES PLAN ............................................................. 4-48 4.10 REFERENCES ............................................................................................................. 4-48
LIST OF TABLES
TABLE 4.2.1-1 Summary of Consultation with Federal Agencies (Through March 31, 2016) .............. 4-5 TABLE 4.2.2-1 Summary of Meetings and Communication with State of Alaska and Local Agencies
(Through March 31, 2016) ............................................................................................. 4-7 TABLE 4.2.3-1 Summary of Consultation with Federally Recognized Indian Tribes and Alaska Native
Corporations (Through March 31, 2016) .................................................................... 4-11 TABLE 4.2.4-1 Summary of Consultation with Other Interested Parties (through March 31, 2016) ... 4-14 TABLE 4.4-1 Cultural Resource Survey Completed within the Direct APE by Field Season
(acres) ........................................................................................................................... 4-23 TABLE 4-5-1 Cultural Resources Identified in the Direct APE by Project Component and NRHP
Status* .......................................................................................................................... 4-28
LIST OF APPENDICES
Appendix A Cultural Resources Mapping (CONTAINS PRIVILEGED INFORMATION – DO NOT
RELEASE) (provided under separate cover) Appendix B Cultural Resources Reports (CONTAINS PRIVILEGED INFORMATION – DO NOT
RELEASE) (provided under separate cover) Appendix C Agency Correspondence (CONTAINS PRIVILEGED INFORMATION – DO NOT
RELEASE) (provided under separate cover) Appendix D Table of Survey Coverage
Appendix E Cultural Resources within the Preliminary Area of Potential Effect (APE) and the Study Area (CONTAINS PRIVILEGED INFORMATION – DO NOT RELEASE) (provided
under separate cover) Appendix F Plan for Unanticipated Discovery of Cultural Resources and Human Remains
Appendix G Site Cultural Resource Data Recovery/Treatment Plans (TO BE INCLUDED IN THE FERC APPLICATION)
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ACRONYMS AND ABBREVIATIONS
ABBREVIATION DEFINITION
AAC Alaska Administrative Code
ACHP Advisory Council on Historic Preservation
ADF&G Alaska Department of Fish and Game
ADNR Alaska Department of Natural Resources
ADOT&PF Alaska Department of Transportation and Public Facilities
AGI Apex Gas Injection
AGPPT Alaska Gas Pipeline Producers Team
AHPA Alaska Historic Preservation Act
AHRS Alaska Heritage Resources Survey
Alaska LNG Project Plan
Alaska LNG Project Upland Erosion Control, Revegetation, and Maintenance Plan
Alaska LNG Project Procedures
Alaska LNG Project Wetland and Waterbody Construction, and Mitigation Procedures
ANGTS Alaska Natural Gas Transportation System
ANCSA Alaska Native Claims Settlement Act
APE Area of Potential Effect
APP Alaska Pipeline Project
Applicants Alaska Gasline Development Corporation, BP Alaska LNG LLC, ConocoPhillips Alaska LNG Company, and ExxonMobil Alaska LNG LLC
ARPA Archaeological Resources Protection Act
ARRC Alaska Railroad Corporation
ASAP Alaska Stand Alone Pipeline
ATWS additional temporary workspace
AY Atigun Pass to Yukon River
BIA United States Bureau of Indian Affairs
BLM United States Department of the Interior, Bureau of Land Management
BOEM/MMS United States Department of the Interior, Bureau of Ocean Energy Management/Minerals Management Service
BP Before Present
C.F.R. Code of Federal Regulations
CGF Central Gas Facility
CLG Certified Local Government
CRA Cultural Resource Advisor
CVTC Chickaloon Village Traditional Council
DOE Determination of Eligibility
EIS Environmental Impact Statement
EMALL ExxonMobil Alaska LNG LLC
EPA United States Environmental Protection Agency
FEED front-end engineering design
FERC Federal Energy Regulatory Commission
GIS Geographic information system
GPS Global Positioning System
GTP Gas Treatment Plant
HT Healy to Trapper Creek
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ABBREVIATION DEFINITION
IN Marine crossing of Cook Inlet to Kenai Peninsula, and Kenai Peninsula to the Liquefaction Plant in Nikiski
IPS Initial Production System
LH Livengood to Healy
Liquefaction Facility natural gas liquefaction facility
LNG liquefied natural gas
LNGC liquefied natural gas carrier
Mainline an approximately 804-mile-long, large-diameter gas pipeline
MGS Major Gas Sales
MLBV Mainline block valve
MMTPA Million metric tons per annum
MOF Material Offloading Facility
MP milepost
NEPA National Environmental Policy Act
NGA Natural Gas Act
NHPA National Historic Preservation Act
NLURA Northern Land Use Research Alaska, LLC
NOAA National Oceanic and Atmospheric Administration
NOAA AWOIS National Oceanic and Atmospheric Administration Office of Coast Survey’s Automated Wreck and Obstruction Information System
North Slope Alaska North Slope
NPS United States Department of Interior, National Park Service
NRHP National Register of Historic Places
OHA Alaska Department of Natural Resources, Division of Parks and Outdoor Recreation, Office of History and Archaeology
PA Prudhoe Bay to Atigun Pass
PBTL Prudhoe Bay Gas Transmission Line
PBU Prudhoe Bay Unit
PL Public Law
Project Alaska LNG Project
PTTL Point Thomson Gas Transmission Line
PTU Point Thomson Unit
ROW right-of-way
SHPO Alaska Department of Natural Resources, Division of Parks and Outdoor Recreation, Office of History and Archaeology, State Historic Preservation Office
SPCS Alaska State Pipeline Coordinator’s Section
TAPS Trans-Alaska Pipeline System
TCC Tanana Chiefs Conference
THPO Tribal Historic Preservation Office
TI Trapper Creek to Cook Inlet
U.S. United States
UAMN University of Alaska, Museum of the North
USACE United States Army Corps of Engineers
USCG United States Coast Guard
USFWS United States Department of the Interior, Fish and Wildlife Service
USGS United States Department of the Interior, United State Geological Survey
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ABBREVIATION DEFINITION
VSM vertical support member
YL Yukon River to Livengood
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4.0 RESOURCE REPORT NO. 4 – CULTURAL RESOURCES
4.1 PROJECT DESCRIPTION
The Alaska Gasline Development Corporation, BP Alaska LNG LLC, ConocoPhillips Alaska LNG
Company, and ExxonMobil Alaska LNG (Applicants) plan to construct one integrated liquefied natural
gas (LNG) Project (Project) with interdependent facilities for the purpose of liquefying supplies of natural
gas from Alaska, in particular from the Point Thomson Unit (PTU) and Prudhoe Bay Unit (PBU)
production fields on the Alaska North Slope (North Slope), for export in foreign commerce and for in-
state deliveries of natural gas.
The Natural Gas Act (NGA), 15 U.S.C. § 717a(11) (2006), and Federal Energy Regulatory Commission
(FERC) regulations, 18 Code of Federal Regulations (C.F.R.) § 153.2(d) (2014), define “LNG terminal”
to include “all natural gas facilities located onshore or in State waters that are used to receive, unload,
load, store, transport, gasify, liquefy, or process natural gas that is ... exported to a foreign country from
the United States.” With respect to this Project, the “LNG Terminal” includes the following: a
liquefaction facility (Liquefaction Facility) in Southcentral Alaska; an approximately 804-mile gas
pipeline (Mainline); a gas treatment plant (GTP) within the PBU on the North Slope; an approximately
62-mile gas transmission line connecting the GTP to the PTU gas production facility (PTU Gas
Transmission Line or PTTL); and an approximately 1-mile gas transmission line connecting the GTP to
the PBU gas production facility (PBU Gas Transmission Line or PBTL). All of these facilities are
essential to export natural gas in foreign commerce and will have a nominal design life of 30 years.
These components are shown in Resource Report No. 1, Figure 1.1-1, as well as the maps found in
Appendices A and B of Resource Report No. 1. Their proposed basis for design is described as follows.
The new Liquefaction Facility would be constructed on the eastern shore of Cook Inlet just south of the
existing Agrium fertilizer plant on the Kenai Peninsula, approximately 3 miles southwest of Nikiski and
8.5 miles north of Kenai. The Liquefaction Facility would include the structures, equipment, underlying
access rights, and all other associated systems for final processing and liquefaction of natural gas, as well
as storage and loading of LNG, including terminal facilities and auxiliary marine vessels used to support
Marine Terminal operations (excluding LNG carriers [LNGCs]). The Liquefaction Facility would
include three liquefaction trains combining to process up to approximately 20 million metric tons per
annum (MMTPA) of LNG. Two 240,000-cubic-meter tanks would be constructed to store the LNG. The
Liquefaction Facility would be capable of accommodating two LNGCs. The size of LNGCs that the
Liquefaction Facility would accommodate would range between 125,000–216,000-cubic-meter vessels.
In addition to the Liquefaction Facility, the LNG Terminal would include the following interdependent
facilities:
Mainline: A new 42-inch-diameter natural gas pipeline approximately 804 miles in length would
extend from the Liquefaction Facility to the GTP in the PBU, including the structures, equipment,
and all other associated systems. The proposed design anticipates up to eight compressor
stations; one standalone heater station, one heater station collocated with a compressor station,
and six cooling stations associated with six of the compressor stations; four meter stations; 53
Mainline block valves (MLBVs); one pig launcher facility at the GTP meter station, one pig
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receiver facility at the Nikiski meter station, and combined pig launcher and receiver facilities at
each of the compressor stations; and associated infrastructure facilities.
Associated infrastructure facilities would include additional temporary workspace (ATWS), access roads, helipads, construction camps, pipe storage areas, material extraction sites, and material disposal sites.
Along the Mainline route, there would be at least five gas interconnection points to allow for future in-state deliveries of natural gas. The approximate locations of three of the gas interconnection points have been tentatively identified as follows: milepost (MP) 441 to serve Fairbanks, MP 763 to serve the Matanuska-Susitna Valley and Anchorage, and MP 804 to serve the Kenai Peninsula. The size and location of other interconnection points are unknown at this time. None of the potential third-party facilities used to condition, if required, or move natural gas away from these gas interconnection points are part of the Project. Potential third-party facilities are addressed in the Cumulative Impacts analysis found in Appendix L of Resource Report No. 1;
GTP: A new GTP and associated facilities in the PBU would receive natural gas from the PBU
Gas Transmission Line and the PTU Gas Transmission Line. The GTP would treat/process the
natural gas for delivery into the Mainline. There would be custody transfer, verification, and
process metering between the GTP and PBU for fuel gas, propane makeup, and byproducts. All
of these would be on the GTP or PBU pads;
PBU Gas Transmission Line: A new 60-inch natural gas transmission line would extend
approximately 1 mile from the outlet flange of the PBU gas production facility to the inlet flange
of the GTP. The PBU Gas Transmission Line would include one meter station on the GTP pad;
and
PTU Gas Transmission Line: A new 32-inch natural gas transmission line would extend
approximately 62 miles from the outlet flange of the PTU gas production facility to the inlet
flange of the GTP. The PTU Gas Transmission Line would include one meter station on the GTP
pad, four MLBVs, and two pig launcher and receiver facilities—one each at the PTU and GTP
pads.
Existing State of Alaska transportation infrastructure would be used during the construction of these new
facilities including ports, airports, roads, railroads, and airstrips (potentially including previously
abandoned airstrips). A preliminary assessment of potential new infrastructure and modifications or
additions to these existing in-state facilities is provided in Resource Report No. 1, Appendix L. The
Liquefaction Facility, Mainline, and GTP would require the construction of modules that may or may not
take place at existing or new manufacturing facilities in the United States.
Draft Resource Report No. 1, Appendix A, contains maps of the Project footprint. Appendices B and E
of Resource Report No. 1 depict the footprint, plot plans of the aboveground facilities, and typical layout
of aboveground facilities.
Outside the scope of the Project, but in support of or related to the Project, additional facilities or
expansion/modification of existing facilities would be needed to be constructed. These other projects
may include:
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Modifications/new facilities at the PTU (PTU Expansion project);
Modifications/new facilities at the PBU (PBU Major Gas Sales [MGS] project); and
Relocation of the Kenai Spur Highway.
4.1.1 Purpose of Resource Report
As required by 18 C.F.R. § 380.12, this Resource Report has been prepared in support of a future
application under Section 3 of the NGA to construct and operate the Project facilities. The purpose of this
Resource Report is to:
Describe consultations with regulatory agencies, federally recognized Indian Tribes, and
Alaska Native Corporations with land or other responsibilities in reasonable proximity to the
Project;
Identify the preliminary area of potential effect (APE) and cultural resource survey
methodology;
Describe the status of cultural resource investigations conducted within the Project survey
corridor;
Identify historic properties and cultural resources within the preliminary APE and the Project
area;
Assess potential Project effects to cultural resources and historic properties and preliminary
potential mitigation measures that are based on best practices; and
Address how unexpected discoveries would be managed if encountered during Project
construction activities.
The data for this Resource Report were compiled based on a review of:
Pre-front-end engineering design (FEED), to the extent available;
United States Geological Survey (USGS) topographic maps;
Recent aerial photography;
Field survey data;
State Historic Preservation Office’s (SHPO’s) state archaeological database and review of
other studies and surveys pertinent to the proposed Project footprint;
Agency-supplied comments and data;
Feedback from FERC;
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Scientific literature; and
Geographic information system (GIS) data from federal and state agencies.
The results of the cultural resource investigations are presented in Appendices A and B (labeled as
Privileged and Confidential—Do Not Release). Appendix A shows the results of the archaeological
surveys on USGS quadrangles. Appendix B provides the technical survey reports on these investigations.
Because these appendices contain information on the location, character, and ownership of cultural
resources, they are marked privileged and are not for public release in accordance with FERC guidance
for environmental report preparation (FERC, 2002). Archaeological information is restricted and
confidential under state and federal law including AS 40.25.120(a)(4), Alaska State Parks Policy and
Procedure No. 50200, the National Historic Preservation Act (NHPA) [Public Law (PL) 89-665, 54
United States Code (U.S.C.) 300101], and the Archaeological Resources Protection Act (ARPA)[PL 96-
95].
4.1.2 Regulatory Context
The National Environmental Policy Act (NEPA) requires federal agencies to assess the environmental
impacts of proposed federal actions, including impacts to historic and cultural resources. FERC, as the
lead federal agency for this Project responsible for compliance with NEPA, is required to assess potential
impacts to historic and cultural resources.
In addition, Section 106 of the NHPA of 1966 and its implementing regulations (36 C.F.R. Part 800)
require federal agencies to take into consideration the effects of their undertakings upon historic
properties and to afford the Advisory Council on Historic Preservation (ACHP) an opportunity to
comment on such undertakings. Historic properties are cultural resources that are listed or eligible for
listing in the National Register of Historic Places (NRHP) (36 C.F.R. Part 60). The Section 106 process
seeks to balance historic preservation concerns with the requirements of the federal undertaking through
consultation among the responsible lead federal agency (in this case, FERC) and other parties, including
SHPO, federal land-managing agencies, federally recognized tribes and other Alaska Native groups,
representatives of local government, and other potentially interested parties (36 C.F.R. § 800.2). The goal
of such consultation is to identify historic properties potentially affected by the undertaking, assess the
effects of the undertaking, and seek measures to avoid, minimize, or mitigate adverse effects to historic
properties.
Legislation addressing cultural resources and historic properties in the State of Alaska includes the Alaska
Historic Preservation Act of 1971 (AHPA) (Alaska Statute 41.35.010-41.35.240). The AHPA established
state policy to preserve and protect the historic, prehistoric, and archaeological resources of Alaska from
loss, desecration, and destruction so that the scientific, historic, and cultural heritage embodied in those
resources may pass undiminished to future generations. The AHPA, administered by SHPO under the
authority of the Alaska Historical Commission, affords protection to cultural resources on lands owned
and administered by the state.
SHPO is housed within the Alaska Department of Natural Resources, Division of Parks and Outdoor
Recreation, Office of History and Archaeology (OHA) and serves and administers historic preservation
programs pursuant to the Alaska Administrative Code (AAC) (11 AAC 16.010-16.090). OHA/SHPO is
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responsible for the issuance of Alaska Cultural Resource Permits authorizing the investigation,
excavation, gathering, or removal of cultural resources from state-owned or state-administered lands
(Alaska Statute 41.35.080 and 11 AAC 16.030). Professional qualifications and the structure for cultural
resource surveys and reporting are established through the permitting system.
4.2 AGENCY AND ORGANIZATION CONSULTATION
Consultation with Federal Land Managing Agencies
The Bureau of Land Management (BLM) would be a cooperating agency for this Project under NEPA
and a consulting party for the Project throughout the NHPA Section 106 process. The BLM manages a
large portion of the land traversed by the Project. Informal consultation with the BLM on the Project was
initiated in October 2014; however, discussions and meetings with the BLM regarding cultural resources
have been ongoing since 2013. These discussions focused on obtaining permits under the ARPA, the
Antiquities Act of 1906, and BLM’s specific statutory and regulatory authority over lands that it manages
along the proposed Project route. The consultation efforts are summarized in Table 4.2.1-1 and are
provided with additional detail in Appendix C. Also included in Appendix C are copies of
correspondence associated with archaeological permit applications, discussion of survey protocols, and
date of permit issuance for the 2013 and 2014 summer archaeological field sessions. An informal
discussion was held on December 2014 to discuss sites recorded during cultural resource investigations
prior to the Project. The BLM staff offered preliminary unofficial recommendations and comments on
the eligibility of these sites for the NRHP. Prior to the 2015 field season, consultation regarding cultural
resources on BLM property continued for the protocols for survey and site-specific evaluations. The
2015 Desktop Determination of Eligibility (DOE) and Phase II Cultural Resource Evaluation reports were
submitted to the BLM on January 26, 2016.
TABLE 4.2.1-1
Summary of Consultation with Federal Agencies (Through March 31, 2016)
Agency Date Contacted Summary
U.S. Army Corps of Engineers (USACE), U.S. Coast Guard (USCG), Bureau of Land Management (BLM), National Park Service (NPS), U.S. Environmental Protection Agency (EPA), U.S. Fish and Wildlife Service (USFWS)
2/25–2/27/2014 and 3/4/2014
Multi-agency meeting to discuss Project right-of-way (ROW) and permitting with state and federal agencies (also included Alaska Department of Natural Resources (ADNR), Office of History and Archaeology (OHA)/State Historic Preservation Office (SHPO), State Pipeline Coordinator’s Section (SPCS), Alaska Railroad Corporation (ARRC), and the Alaska Department of Fish and Game (ADF&G)
BLM, USACE 6/9/2014 Discussion regarding historical field survey data and protocols (also included OHA/SHPO and ADF&G)
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TABLE 4.2.1-1
Summary of Consultation with Federal Agencies (Through March 31, 2016)
Agency Date Contacted Summary
BLM 6/3/2013
6/21/2013
7/3/2013
4/22/2014
5/23/2014
Discussions regarding archaeological permit
06/14/2013
06/21/2013
Discussion with the BLM regarding status of Archaeological Resources Protection Act (ARPA) permit application
Discussion with BLM regarding Archaeological Collection Permit
6/27/2013 Letter to the BLM regarding request for 2002 cultural resources GIS data
12/10/2013 Discussion regarding 2014 field study scope
2/18/2014 Submittal of Project 2013 Phase I Cultural Resource Report
10/3/2014 Discussion of FERC, OHA/SHPO, and SPCS regarding pre-filing schedule and Section 106 consultation
12/16/2014 Discussion of preliminary recommendations for sites located with the preliminary Area of Potential Effect (APE); planning for 2015 fieldwork
8/13/2014 Letter to the BLM requesting review of cultural resources reports
8/28/2014 Discussion regarding cultural resource data
5/15/2015 Letter providing the BLM (Mr. Hedman and Dr. King) a copy of site-specific plans for National Register of Historic Places (NRHP) eligibility evaluations
5/20/2014 Submittal of Cultural Resource Field Study Protocol
10/27/2014 Letter to the BLM (Dr. King) requesting informal consultation under Section 106 of the NRHP
06/10/2015 Meeting to review proposed methodology for NRHP Determinations of Eligibility (DOEs) at specific sites in the Project corridor
07/13/2015 Letter providing the BLM (Nichelle Jacobson) a copy of site-specific plans for NRHP eligibility evaluations
10/23/2015 Letter from the BLM (Nichelle Jacobson) regarding concurrence on proposed Phase II Site-specific Methodology for Evaluation
01/26/2016 Desktop DOE report submitted to the BLM.
01/26/2016 2015 Evaluation Report submitted to the BLM.
Other federal agencies with NHPA Section 106 responsibilities related to the Project include the U.S. Fish
and Wildlife Service (USFWS), the U.S. Army Corps of Engineers (USACE), the U.S. Coast Guard
(USCG), the U.S. Bureau of Indian Affairs (BIA), and the National Park Service (NPS). No formal
consultations have been initiated with any of these agencies, but informal meetings and discussions about
the Project were held with agency representatives in 2013, 2014, and 2015. A comprehensive summary
of the informal Project discussions is contained in Appendix D of Resource Report No. 1. A multi-
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agency kick-off meeting was held on February 25–27, 2014, and on March 4, 2014, to discuss the 2014
summer field season, the proposed Project right-of-way (ROW), and permitting.
Consultation with State Agencies
As SHPO, OHA would provide input regarding compliance with all relevant state historic preservation
laws and would act as a consulting party throughout the Section 106 process. Although formal
consultation with OHA/SHPO under Section 106 of the NHPA was initiated in October 2014, informal
discussions and meetings with OHA/SHPO have been ongoing since 2013. In addition, applications for
Field Archaeology Permits were submitted and approved by OHA/SHPO for summer field studies in
2013, 2014, and 2015. These applications, associated permit numbers, and other permit correspondence
with OHA/SHPO are listed in Table 4.2.2-1 and included in Appendix C. Other meetings and informal
discussions with OHA/SHPO also are summarized in Table 4.2.2-1.
Meetings with OHA/SHPO have focused on historical field survey data and survey protocols, discussion
regarding cultural resources data, and discussion of the FERC pre-filing schedule and Section 106
consultation. OHA/SHPO and other state and federal agencies were included in a kick-off meeting for
the 2014 summer field season held in Anchorage on February 25–27, 2014. That meeting provided an
introduction to the Project and discussed permitting for the field studies. Project representatives met with
OHA/SHPO in December 2014 and January 2015 to discuss the results of the archaeological survey and
plan for the 2015 field season. OHA/SHPO provided preliminary comments on the eligibility of sites
located within the APE. In March 2015, Project representatives met with OHA/SHPO to discuss methods
for evaluating the presence of submerged cultural resources in Cook Inlet and later provided a letter
outlining the proposed approach. In June 2015, Project representatives met again with OHA/SHPO to
further discuss determinations of eligibility and avoidance and mitigation measures taken by other
projects in the state.
The 2015 Desktop and Phase II Cultural Resource Evaluation reports were submitted to OHA/SHPO on
January 26, 2016. The OHA/SHPO provided comments on the evaluation reports in two letters. A letter
dated February 11, 2016, provided comments on 70 cultural resources and another dated March 21, 2016,
commented on another 24 cultural resources.
TABLE 4.2.2-1
Summary of Meetings and Communication with State of Alaska and Local Agencies (Through March 31, 2016)
Agency Contact Date Contacted Summary
ADNR, SPCS, ARRC, ADF&G
2/25–2/27/2014 and 3/4/2014
Multi-agency kick off meeting to discuss the 2014 summer field season, Project ROW and permitting (also included USACE, USCG, BLM)
ADNR 6/27/2014 Pre-application meeting
OHA/SHPO 4/10/2014 Submittal of GIS geodatabase accompanying 2013 Resource Report
OHA/SHPO 5/20/2014 Submittal of cultural resource field study protocol
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TABLE 4.2.2-1
Summary of Meetings and Communication with State of Alaska and Local Agencies (Through March 31, 2016)
Agency Contact Date Contacted Summary
OHA/SHPO, ADF&G 6/9/2014 Discussion regarding historical field survey data and protocols (also included BLM and USACE)
SPCS, OHA/SHPO, ADNR Office of Project Management and Permitting
6/10/2014 Discussion regarding cultural resources survey protocols and data
OHA/SHPO, SPCS 8/27/2014 Discussion regarding cultural resource data
OHA/SHPO, SPCS 10/3/2014 Discussion of FERC pre-filing schedule and Section 106 consultation (also included BLM)
OHA/SHPO, SPCS 12/17/2014
01/07/2015
Discussion of preliminary recommendations for sites located within the preliminary APE; planning for 2015 fieldwork
OHA/SHPO 6/21/2013, 4/22/2014, 6/2/2014, 8/25/2014
Discussions regarding archaeological permits (see Appendix C)
2/18/2014 Submittal of Project 2013 Phase I Cultural Resource Report
4/15/2014 OHA/SHPO review of ADNR Temporary Land Use Permit (see Appendix C)
5/15/2014 Discuss 2014 Cultural Resource survey program with OHA/SHPO
8/13/2014 Letter requesting review of cultural resource reports
8/27/2014 Meeting to discuss prior cultural data north of Livengood
10/27/2014 Letter request for informal consultation under Section 106 of NHPA
11/11/2014 Letter to OHA/SHPO regarding cultural resource evaluation for proposed 2014 Ambient Air Quality Station
11/12/2014 Letter from OHA/SHPO regarding cultural resource evaluation for proposed 2014 Ambient Air Quality Station
12/17/2014 Meeting to discuss prior cultural data north of Livengood
2/3/2015 Letter to OHA/SHPO submitting 2014 Phase I Cultural Resources Inventory report
2/5/2014
Meeting to discuss 2014 Phase I Cultural Resources Inventory Report, Nikiski, Alaska, report and recommendations.
2/12/2015 Letter from OHA/SHPO indicating concurrence on eligibility for the Nikiski LNG Facility
4/17/2015 Discussion regarding a methodology for evaluating the presence of submerged cultural resources in Cook Inlet
4/27/2015
Letter to OHA/SHPO providing methodology for evaluating the presence of submerged cultural resources in Cook Inlet
5/15/2015 Letters to OHA/SHPO and SPCS with Phase II site-specific plans for NRHP Eligibility Evaluations
05/27/2015
Meeting to review proposed methodology for NRHP DOEs at specific sites in the Project corridor
5/29/2015 Letter to OHA/SHPO re proposed Phase II site-specific methodology for evaluation of NRHP eligibility
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TABLE 4.2.2-1
Summary of Meetings and Communication with State of Alaska and Local Agencies (Through March 31, 2016)
Agency Contact Date Contacted Summary
06/08/2015
Memo indicating that OHA/SHPO has no objection to the proposed methodology for evaluating the NRHP eligibility of select sites in the Project corridor
07/2/2015
Letter indicating that OHA/SHPO has no objection to the proposed methodology for evaluating presence of submerged cultural resources in Cook Inlet
7/29/2015 Discussion regarding strategy schedule, and approach to Programmatic Agreements, NRHP eligibility
01/26/2016 Project representatives submitted a copy of the desktop DOE and 2015 evaluation reports to OHA/SHPO
02/11/2016 SHPO provided comments on eligibility recommendations for 70 cultural resource sites within Project Area.
03/21/2016 SHPO provided comments on eligibility recommendations for 24 cultural resource sites within the Project Area
4.2.3 Consultation with Federally Recognized Indian Tribes and Alaska Native Corporations
Acting as FERC’s non-federal representative for the Project for purposes of information Section 106
consultation, Project representatives contacted federally recognized Indian Tribes and Alaska Native
Corporations in October 2014. In May 2015, FERC initiated formal government-to-government
consultation with federally recognized Indian Tribes and Alaska Native Corporations under Section 106
of the NHPA with introductory letters. Most of the affected Indian tribes and Alaska Native Corporations
had been contacted by Project representatives by letter in October 2014, and by telephone and email in
September 2015. Project representatives held numerous informal informational meetings with individual
federally recognized Indian Tribes and Alaska Native Corporations between 2013 and 2015. In addition,
an informational meeting was held with the ANCSA Regional Association in January and February,
2015. FERC participated in government-to-government consultation with several recognized Indian
Tribes in October 2015. This included the Chickaloon Native Village, the Knik Tribe, Kenaitze Indian
Tribe, and Native Village of Tyonek. Appendix C of this Resource Report provides information on the
meetings held with these groups. A list of federally recognized Indian Tribes and Alaska Native
Corporations that may have knowledge of, or an interest in, cultural resources potentially affected by the
Project is included in Table 4.2.3-1. Additional information regarding consultations with these groups
will be included in this table in the FERC application.
Project representatives began consultation with the Native Village of Tyonek in October 2014 and
continued engagement with the Village in several public meetings in April and May 2015 and calls and
emails in September 2015. FERC initiated government-to-government consultation on October 16, 2015,
and were informed that the Tribe is interested in understanding the impacts of the Project on cultural
resources. The Tribe recommended that alternative routes be analyzed near Cook Inlet.
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Consultation with the Kenaitze Indian Tribe was initiated by Project representatives in October 2014 and
follow-up calls and emails were placed in September 2015. A public meeting was held by Project
representatives, and FERC sent an introductory letter in May 2015. Discussions with Project
representatives continued in May 2015 and FERC initiated government-to-government consultation on
October 15, 2015. The Tribe noted concerns about social justice and the environmental and economic
impacts of the Project.
In October 2015, the Knik Tribe wrote to FERC to express concerns about the lack of consultation and
information exchange about cultural resource investigations, historic sites, and environmental and
conservation outcomes. Of particular concern to the Knik Tribe are areas between Cantwell and the
Tsi’lutnu (Chulitna River) drainage through Dengiht’u (Broad Pass) to the Suyitnu (Susitna River)
drainage. The Knik Tribe requested government-to-government consultation with FERC regarding the
project. FERC initiated consultation on October 16, 2015, shortly after the comments were received. The
Knik Tribe requested that Project representatives actively engage the Nation to use its expertise in cultural
and natural resources.
In November 2015, the Chickaloon Village Traditional Council (CVTC) wrote to FERC recommending
that the Project use field reports from other projects, such as the Alaska Stand Alone Pipeline (ASAP)
Project, for cultural and ecological resources and potential impacts of the Project. CVTC requested
government-to-government consultation under the Section 106 process for the Project.
In December 2015, the Tanana Chiefs Conference (TCC) wrote to FERC to provide scoping comments on
the Project. The letter noted that the Project poses impacts to several federally recognized Tribes in the
TCC region and traverses traditional lands of the villages of Allakaket, Alatna, Evansville, Stevens
Village, Rampart, Minto, Nenana, and possibly others. The TCC requested that FERC and Project
representatives meaningfully engage those villages in the federal environmental review. With regard to
cultural resources, TCC noted that the review should include extensive outreach to traditional and
customary use areas and develop mitigation measures to minimize impacts to subsistence economies
where incomes are low and unemployment is high.
In addition to correspondence, email, telephone, and community meetings, the Cultural Resource Advisor
(CRA) program was developed as a way to involve local Alaska Natives in the cultural resources field
programs (exp 2015). This helped expose tribal members to the 106 process and encourage Alaska
Natives to pursue an interest in archaeology or cultural resource management, and to provide the local
villages and tribal entities a way to be involved in the cultural resources program and provide feedback
and input as the work progresses. CRAs were chosen from candidates that identified as members of tribal
organizations, villages, and/or corporations. The CRAs provide insight to archaeology crews on
subsistence, cultural, and traditional knowledge in particular areas and in general during surveys. They
observe and participate in cultural investigations, documenting what is being studied, and assist the
Project in reporting information about the investigations to Alaska Native entities. CRAs include
members of the following Alaska Native Claims Settlement Act (ANCSA) Regional Corporations and
federally recognized Tribes: Doyon (Gana-A’Yoo [Galena]), Bean Ridge Corporation (Manley Hot
Springs), Cook Inlet Region Inc. (Native Village or Tyonek), Calista Corporation (Algaaciq Native
Village [Saint Mary’s]), and NANA Regional Corporation (Native Village of Kotzebue). A summary of
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the CRA program and the results of this effort are presented in a summary report that is included in
Appendix B (exp 2015).
TABLE 4.2.3-1
Summary of Consultation with Federally Recognized Indian Tribes and Alaska Native Corporations (Through March 31, 2016)
Organization Date Description
Alaska Native Claims Settlement Act (ANCSA) Regional Association
1/30/2015 Project representatives gave a Project update presentation in Juneau.
2/3/2015 Project representatives gave a Project update at board meeting in Juneau.
Alatna Village 10/23/2014 Project representatives sent a consultation request letter.
9/21–25/2015 Project representatives called and sent a follow-up email (could not leave message); the Corporation was not successfully contacted.
Allakaket Village 10/23/2014 Project representatives sent a consultation request letter.
9/21–25/2015 Project representatives called and sent a follow-up email; indicated that the tribe would have a council meeting and share information.
Chickaloon Native Village 5/20/2015 FERC sent an introductory letter.
10/13/2015 FERC held a government-to-government meeting; noted that the Project crosses the western edge of the Tribe’s traditional use area; would like the Alaska Stand Alone Pipeline (ASAP) Project’s field results to be used.
11/25/2015 The Chickaloon Village Traditional Council sent comments to FERC and requested government to government consultation.
Circle Native Community 5/20/2015 FERC sent an introductory letter.
Eklutna Native Village 10/23/2014 Project representatives sent a consultation request letter.
5/20/2015 FERC sent an introductory letter.
1/31/2015 A presentation was given at the Native Village of Eklutna annual shareholder meeting.
9/21–23/2015
Project representatives called and sent a follow-up email; Project representatives received a response that they did not have enough information to provide comments.
Evansville Tribal Council 10/23/2014 Project representatives sent a consultation request letter.
5/20/2015 FERC sent an introductory letter.
9/21/2015 Project representatives called and sent a follow-up email. The Council stated that the pipeline is its neighbor and it had already reviewed the Environmental Impact Statement (EIS) for the ASAP Project pipeline.
Inupiat Community of the Arctic Slope 10/23/2014 Project representatives sent a consultation request letter.
5/20/2015 FERC sent an introductory letter.
9/21–25/2015 Project representatives called and sent a follow-up email.
Kaktovik Village 10/23/2014 Project representatives sent a consultation request letter
1/14/2015 Project representatives held a public meeting.
5/20/2015 FERC sent an introductory letter
9/21–25/2015 Project representatives called and sent a follow-up email.
Kenaitze Indian Tribe 10/23/2014 Project representatives sent a consultation request letter.
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TABLE 4.2.3-1
Summary of Consultation with Federally Recognized Indian Tribes and Alaska Native Corporations (Through March 31, 2016)
Organization Date Description
9/21–22/2015 Project representatives called and sent a follow-up email; received a response that Ms. Brenda Trefonas is the point of contact for future Section 106 correspondence.
4/17/2015 Project representatives held a public meeting.
5/20/2015 FERC sent an introductory letter.
5/22/2015 Project representatives discussed subsistence activities in Cook Inlet.
10/15/2015 FERC held a government-to-government Meeting; concerns about social justice, environmental, and economic impacts of the Project were discussed.
Knik Tribe 10/23/2014 Project representatives sent a consultation request letter.
9/21–25/2015 Project representatives called and sent a follow-up email.
2/20/2015 The Knik Tribe formally requests FERC initiate government-to-government consultation under Section 106.
2/20/2015
The Knik Tribal Council provided comments on Draft Resource Report No. 4 to FERC.
10/16/2015 FERC held a government-to-government meeting; the Knik Tribe requested that the Project representatives actively engage the Nation to use its expertise in cultural and natural resources.
10/16/2015
The Knik Tribal Council sent a letter to FERC with comments and concerns.
10/26/2015 FERC sent a response to the comments from the Knik Tribal Council.
Nagsragmuit Traditional Council 10/23/2014 Project representatives sent a consultation request letter.
(Anaktuvuk Pass Federally Recognized Tribe)
1/29/2015 Project representatives held a public meeting.
9/21–25/2015 Project representatives called and sent a follow-up email.
Native Village of Barrow Inupiat
Traditional Government
10/23/2014 Project representatives sent a consultation request letter.
5/20/2015 FERC sent an introductory letter.
9/21–25/2015 Project representatives called and sent a follow-up email.
11/12/2015 Project representatives held a public meeting and FERC representatives attended.
Native Village of Cantwell 10/23/2014 Project representatives sent a consultation request letter.
5/20/2015 FERC sent an introductory letter.
9/21–25/2015 Project representatives called and sent a follow-up email.
11/5/2015 Project representatives held a public meeting and FERC representatives attended.
Native Village of Chenega 5/20/2015 FERC sent an introductory letter.
Native Village of Eyak 5/20/2015 FERC sent an introductory letter.
Native Village of Fort Yukon 5/20/2015 FERC sent an introductory letter.
Native Village of Gakona 5/20/2015 FERC sent an introductory letter.
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TABLE 4.2.3-1
Summary of Consultation with Federally Recognized Indian Tribes and Alaska Native Corporations (Through March 31, 2016)
Organization Date Description
Native Village of Kluti-Kaah 5/20/2015 FERC sent an introductory letter.
Native Village of Minto 10/23/2014 Project representatives sent a consultation request letter.
5/20/2015 FERC sent an introductory letter.
9/21–25/2015 Project representatives called and sent a follow-up email.
11/10/2014 Project representatives held a public meeting and FERC representatives attended.
Native Village of Nuiqsut 10/23/2014 Project representatives sent a consultation request letter.
1/13/2015 Project representatives held a public meeting.
5/20/2015 FERC sent an introductory letter.
9/21–25/2015 Project representatives called and sent a follow-up email.
Native Village of Port Graham 5/20/2015 FERC sent an introductory letter.
Native Village of Stevens 10/23/2014 Project representatives sent a consultation request letter.
9/21–25/2015 Project representatives called and sent a follow-up email—could not leave message; not successfully contacted.
Native Village of Tyonek
(Tyonek Native Corporation)
10/23/2014 Project representatives sent a consultation request letter.
4/10/2015 Project representatives held a public meeting.
5/15/2015 Project representatives held a public meeting with Tyonek Native Corporation.
5/21/2015 Project representatives held a public meeting with the Native Village of Tyonek.
9/21–25/2015 Project representatives called and sent a follow-up email.
10/16/2015 FERC held a government-to-government meeting; concerns about cultural resources, including archaeological sites and cultural landscape were discussed.
10/29/2015 Project representatives held a community meeting, and FERC representatives attended.
Nenana Native Association
(Toghotthele Corporation)
10/23/2014 Project representatives sent a consultation request letter.
11/6/2014 Project representatives held a public meeting, and FERC representatives attended.
4/20/2015 Project representatives held a public meeting with the Toghotthele Corporation.
9/21–22/2015 Project representatives called and sent a follow-up email; the Corporation indicated that they it had set up a FERC meeting on October 16, 2015, in Anchorage.
10/16/2015 FERC held government-to-government meeting.
Ninilchik Traditional Council 10/23/2014 Project representatives sent a consultation request letter.
4/3/2015 Project representatives held a public meeting.
9/21–24/2015 Project representatives called and sent a follow-up email; the Council responded by email to indicate that it did not have a need for a tribal consultation at this time.
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TABLE 4.2.3-1
Summary of Consultation with Federally Recognized Indian Tribes and Alaska Native Corporations (Through March 31, 2016)
Organization Date Description
Rampart Traditional Council 10/23/2014 Project representatives sent a consultation request letter.
9/21–25/2015 Project representatives called and sent a follow-up email.
Village of Salamatof 10/23/2014 Project representatives sent a consultation request letter.
5/5/2015 Project representatives held a meeting regarding subsistence activities in Cook Inlet.
5/26/2015 Project representatives held a meeting regarding subsistence activities in Cook Inlet.
9/21–24/2015 Project representatives called and sent a follow-up email; the Village responded that Chris Monfor is the president and point of contact. The Village is supportive of the Project and does not request tribal consultation at this time.
Tanana Chiefs Conference (TCC) 12/4/2015 TCC provided comments on the Project.
4.2.4 Consultations with Other Interested Parties
In addition to state agencies, federal agencies, federally recognized Indian Tribes, and Alaska Native
Corporations, the Section 106 process includes consultation with other parties that may have an interest in
the Project and the cultural resources that may be affected by the Project. These may include local
governmental organizations, Certified Local Governments (CLGs), boroughs, municipalities, and other
groups. To date, representatives of the Project have held informational meetings with a number of CLGs
that may qualify as consulting parties for Section 106. These are the Fairbanks North Star Borough, the
City of Fairbanks, the City of Kenai, the Kenai Peninsula Borough, the City of Seward, the Matanuska-
Susitna Borough, the Municipality of Anchorage, and the North Slope Borough. Although the Denali
Borough is not listed as a CLG it may qualify as a consulting party for Section 106.
Project representatives have held numerous workshops and public meetings along the Project route in
Alaska. Consultation with communities with CLGs and with the Alaska Gasline Development
Corporation is summarized in Table 4.2.4-1. Project representatives have met with the Kenai Peninsula
Borough, the Matanuska-Susitna Borough, and North Slope Borough multiple times about the Project.
TABLE 4.2.4-1
Summary of Consultation with Other Interested Parties (through March 31, 2016)
Organization Date Description
Anaktuvuk Pass 1/29/2015 Open House regarding the Project
Kenai Peninsula Borough 6/4/2014 Discussion regarding 2014 field activities
8/19/2015 Cook Inlet Routing and Construction Review
9/02/2015 Liquefaction Facility footprint review
Matanuska-Susitna Borough 8/19/2015 Cook Inlet Routing and Construction Review
4/16/2015 Matanuska-Susitna Borough Cultural Resources Division requests that agencies performing cultural investigations consult and keep the Borough informed on progress.
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TABLE 4.2.4-1
Summary of Consultation with Other Interested Parties (through March 31, 2016)
Organization Date Description
North Slope Borough 7/9/2014 North Slope Borough Iñupiat History Language and Culture permitting requirements
1/29/2015 Open House regarding the Project
6/24/2015 Part of multi-agency pipeline construction execution workshop
4.3 AREA OF POTENTIAL EFFECT AND SURVEY METHODOLOGY
4.3.1 Area of Potential Effect (APE)
The APE is the “geographic area or areas within which an undertaking may directly or indirectly cause
changes in the character of or use of historic properties, if any such properties exist” (36 C.F.R. §
800.16(d)). The APE for archaeological resources includes all areas where the ground or seabed may be
disturbed. The APE for historic architectural properties includes areas where direct and indirect impacts
have the potential to alter character-defining features of a property’s significance.
The APE for direct impacts to archaeological resources from the Project includes all areas that would be
impacted during construction of the Project facilities (Appendix A). The APE encompasses the
workspace needed for construction of the Liquefaction Facility, pipeline and aboveground facilities,
access roads, pipe storage areas, contractor yards, additional temporary work areas, and other associated
facility locations. This includes submerged and submersible land offshore across Cook Inlet and from the
Liquefaction Facility, GTP, and West Dock on the North Slope, where dredging or alteration of the
seabed might occur. For purposes of the Project, the APE has been defined to include the following:
A Liquefaction Facility consisting of the 982-acre LNG Plant and temporary construction camp
site onshore and an 82-acre Marine Terminal offshore. The offshore facilities include a Product
Loading Facility, a temporary Material Offloading Facility (MOF), the Dredging Area for the
MOF, and a shoreline protection area. Offshore activities also will require a dredge disposal area
of approximately 1,200 acres, the location of the disposal area has not been sited yet;
An approximately 804-mile-long, 42-inch-diameter, natural gas pipeline (the Mainline),
extending from the GTP on the North Slope to the Liquefaction Facility on the shore of Cook
Inlet near Nikiski, including an offshore pipeline section crossing Cook Inlet. Onshore the APE
consisting of the permanent and construction rights-of-way (ROWs) and ATWS would be located
within a 300-foot-wide (91.4-meter) cultural survey. Offshore the marine permanent and
construction ROWs, measuring 100 feet and 1 to 2.5 miles wide respectively, would be reviewed
for cultural resources. The expanded cultural study area is intended to encompass the impacts of
direct lay of the pipe and anchors for the lay barge;
Additional infrastructure in the area of the permanent Mainline ROW would be required during
construction and operation of the pipeline. The associated infrastructure may include the
following facilities:
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o Temporary workspace for construction activities totaling approximately 1,090 acres (e.g.,
staging areas, truck turnarounds, and utility crossovers);
o Access roads totaling approximately 2,969 acres would be located within a 150-foot-wide
(45.7-meter) cultural resource survey corridor centered on the centerline of the proposed road
(many of these would be improvements to existing roads, See Resource Report No. 1);
o Compressor and heater stations totaling approximately 218 acres;
o Compressor station camp totaling approximately 27 acres;
o Helipads and airstrips, mainly at existing facilities;
o Mainline Construction camps totaling approximately 602 acres;
o Pipe storage and contractor yards totaling approximately 476 acres;
o Rail spurs and rail workpads totaling approximately 48 acres;
o Material sites to supply sand, granular material, and rock/stone totaling approximately 5,625
acres;
o Disposal sites for excavated material, stumps, blast rock, acid drainage rock, and slash
removed from the permanent pipeline ROW (yet to be defined);
o A Mainline MOF measuring 15 acres (located on the North side of Cook Inlet);
o Pipe coating yards and concrete coating facilities (locations to be defined); and
o Other associated facilities such as Mainline block valves (MLBVs), launchers and receivers,
cathodic protection facilities, pipeline corrosion protection system, stray current interference
mitigation facilities, alternating current mitigation, telluric current dampening systems, and
cathodic protection system test stations (found mainly within the footprint of other facilities).
An approximately 62.5-mile, 32-inch-diameter aboveground PTTL pipeline to transport natural
gas from the PTU to the GTP and associated facilities. A 300-foot-wide (91.4-meter) cultural
survey corridor encompassed an APE consisting of the permanent and construction ROWs,
including ATWS;
Additional infrastructure in the area of the permanent PTTL ROW would be required during
construction and operation of the pipeline. The associated infrastructure may include the
following facilities:
o Temporary workspace for construction activities totaling approximately 22 acres (e.g.,
staging areas, truck turnarounds, and utility crossovers);
o Helipads and airstrips totaling approximately 19 acres;
o PTTL Construction camps totaling approximately 111 acres;
o Pipe storage and rail work pads totaling approximately 48 acres.
An approximately 1-mile, 60-inch-diameter aboveground PBTL pipeline to transport natural gas
from the Central Gas Facility (CGF) to the GTP. A 300-foot-wide (91.4-meter) cultural survey
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corridor encompassed an APE consisting of the permanent and construction ROWs, including
ATWS.
An approximately 284-acre GTP would be located in the PBU near the Beaufort Sea coast. This
facility would include the GTP Pad and associated facilities such as a control building,
Operations Center, inlet facilities, and module haul road. The GTP and facilities would be
located near existing PBU facilities; and
Several facilities associated with construction of the GTP are planned including:
o West Dock Causeway modifications including construction of the approximately 3-acre Dock
Head 4 to facilitate offloading of modules arriving by sealift. Dredging of approximately 67
acres would be necessary to provide a sufficient channel and turning basin. The proposed
dredge disposal area for the dredge spoil is estimated at approximately 255 acres;
o A new module staging area measuring approximately 86 acres would be constructed adjacent
to an existing West Dock staging area;
o A 47-acre water reservoir site and pump facility pad;
o Approximately 70 acres of associated transfer pipelines;
o Material site totaling approximately 141 acres;
o Access roads totaling approximately 168 acres; and
o Construction of two camps including a Pioneer camp to support development of construction
infrastructure during GTP construction and a construction and operations camp to support
Project construction, and eventually operations. The preference would be to locate the
Pioneer camp (approximately 30 acres) on an existing granular pad in the PBU or in the
Deadhorse area. The construction and operations camp would be located on site on the
Operations Center granular pad.
Indirect impacts are defined in FERC guidance as “…those effects on historic properties which are
removed in time and/or space from their proximate causes” (FERC 2002). The APE for indirect impacts
is generally defined as the area in which a project could affect the qualities for which a historic property is
eligible or listed in the NRHP. The potential indirect impacts associated with construction of the Project
are often visual in nature, but could include noise and vibration from construction or operating activities.
Indirect effects could also include the greater potential for vandalism to historic properties as a result of
the Project increasing access to the remote areas. The APE for indirect effects would be established in
consultation with OHA/SHPO and federal agencies when more engineering details are available about the
aboveground facilities.
The indirect impacts of the three non-jurisdictional facilities must be analyzed as part of the
Environmental Impact Statement (EIS) for the Project because they are considered “connected” actions
under NEPA. These non-jurisdictional areas include:
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Point Thomson Gas Expansion Project (PTU Expansion Project) – Granular expansion of existing
Central and West Pads; construction of an East Pad and associated granular access road;
gathering line connecting East Pad wells to Central Processing Facility; new granular material
mine to support infrastructure construction; minor dredging of sealift bulkhead berths;
PBU Major Gas Sales (MGS) Project – expansion of two granular pads, construction of a new 10-
mile gas pipeline connecting the Apex Gas Injection (AGI) Pad with Gathering Center #1;
construction of new pipelines to deliver GTP Byproduct to Well Pad W, Well Pad Z, the AGI
Pad, Drill Site 9, and Drill Site 16; and
Relocation of the Kenai Spur Highway – several proposed routes are under consideration to
relocate the Kenai Spur Highway east of the Liquefaction Facility.
4.3.2 Survey Methodology
Prior to initiating cultural surveys for the Project, meetings were held with representatives from various
agencies (Table 4.2.2-1) to review data collection methodologies, protocols, and scope for the 2013, 2014,
and 2015 field seasons. Subsequent to agreement on the path forward, existing data were compiled from
relevant cultural resource surveys previously completed along the proposed Project corridor. The results
of these investigations provided the basis for predictive models and survey methods employed during the
Project studies to date. A discussion of the source of these datasets follows.
Two previous pipeline projects conducted surveys that covered portions of the Project corridor between
Prudhoe Bay and Livengood and provided preliminary information on a number of archaeological sites
recorded in the vicinity of the Project route. Investigations for the Trans-Alaska Pipeline System (TAPS),
which coincides in part with the Mainline study corridor, were conducted between 1969 and 1977 by the
University of Alaska Fairbanks and Alaska Methodist University (now Alaska Pacific University).
Surveys for the proposed Northwest Alaska Pipeline Project were conducted in the late 1970s along a
study corridor that generally follows the Project route from Prudhoe Bay to Livengood before turning east
toward the United States-Canada border. Concerns expressed by OHA/SHPO about the quality of the
archaeological information available from older surveys caused the most recent investigations to re-
examine areas that may have been included in previous surveys. The early surveys often lack accurate
site locations and sufficient data to determine the NRHP eligibility of those sites.
Subsequent pipeline projects resulted in additional cultural investigations along the proposed Project
corridor. In 2001, investigations for the Alaska Gas Pipeline Producers Team (AGPPT) pipeline were
conducted by Northern Land Use Research Alaska, LLC, (NLURA) and Chumis Cultural Resources
Services (NLURA/Chumis) along a corridor from Prudhoe Bay and the United States-Canada border
(Port Alcan) (Potter et al., 2001). A predictive model based on geomorphic variables ranked the potential
of finding culturally significant sites and was used to structure the field investigations. Portions of the
route were ranked as Type A (low potential), Type B (moderate potential), or Types C and D (high
potential). Type A locations were spot-checked by helicopter survey whereas Types B, C, and D were
examined via pedestrian surveys and shovel testing. Approximately 624 miles of the AGPPT route were
surveyed with 122 cultural resources identified during those investigations. Because the northern portion
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of the 2001 AGPPT corridor (Prudhoe Bay to Livengood) is similar to the proposed Mainline route for
this Project, the results of those surveys provided the foundation for the Project study area and the site
location sensitivity mapping effort.
In 2008, Denali-The Alaska Gas Pipeline LLC (Denali Project) proposed to construct a gas pipeline from
Prudhoe Bay to Alberta, Canada. The northern portion of the route followed the route of the AGPPT.
Cultural resources survey data from three previous major pipelines within or immediately adjacent to the
Denali Project area were reviewed. Researchers determined that the data from the TAPS and Alaska
Natural Gas Transportation System (ANGTS) projects were “questionable due to the change in standards
for site identification, location, and analysis as well as survey methodology, location and coverage”
(NRG, 2008). They concluded that most TAPS and ANGTS site information or survey areas within the
Denali Project area would require resurveying and updated location information and analysis using
current archaeological standards (NRG, 2008). Data collected in 2001 as part of the AGPPT Project was
deemed satisfactory for reconnaissance level survey, but that focused delineation of site boundaries and
testing areas within areas with high potential to contain buried archaeological sites was necessary.
Cultural resource reconnaissance surveys conducted in 2008 were focused on the portion of the project
between Delta Junction and the Canadian border.
In 2010, the Alaska Pipeline Project (APP) applied the results of the 2001 AGPPT archaeological
sensitivity model using GIS data and observations from pre-field survey helicopter overflights to develop
a generalized sensitivity map of the entire proposed pipeline facilities corridor (Higgs et al. 2011a, 2011b,
2012). This essential step enabled stratification of the 2010 pipeline facilities corridor into areas of
cultural resource sensitivity (Type A or Type B, described subsequently) based on relationships between
known sites and key environmental variables. The APP did not maintain the distinction between Type B,
C, and D survey methods and reported pedestrian and shovel testing as Type B. The 2010 Phase I
cultural resource surveys for the APP were completed within a nominal 328-foot-wide (100-meter)
corridor, with some areas expanded to up to 2,625 feet wide (800 meters).
South of Livengood, the Project used survey results of the ASAP Project for surveys ASAP conducted
between 2010 and 2014. These data were made available by OHA/SHPO and consist primarily of Type
A and B surveys, site locations, and site form information. The ASAP Project conducted surveys in a
200-foot corridor centered over its proposed centerline; portions of their route overlap with that of this
Project. Building on approaches developed for other earlier projects, a sensitivity model was developed
for the Project that allowed field surveys to effectively target high-sensitivity areas while still providing
data on areas deemed to have low potential of containing cultural resources. The sensitivity maps
developed for the Project were based on data from overflights, previous surveys, recorded site locations,
geomorphologic setting, and other environmental variables. These data were combined to define areas of
low and high potential for cultural resources.
Field investigations were designed based on the mapped sensitivity or archaeological potential of areas
along the Project corridor. Pre-survey helicopter overflights were employed to demarcate generally high
or low potential segments and note any visible historic buildings or structures. A desktop review of the
corridor, which applied the predictive model, identified areas with very low to no potential for cultural
resources and those areas were eliminated from field surveys. The remaining areas were segregated into
low potential (Type A) and high potential (Type B) areas. For Type A areas, helicopter or vehicular
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surveys of segments not previously surveyed were used to identify isolated higher-potential areas for
targeted field survey. For Type B areas, field investigations were implemented, including pedestrian
transect surveys with systematic shovel testing of previously un-surveyed areas, as well as targeted
surveys where the previous surveys (e.g., Denali Pipeline Project, AGPPT, APP, or ASAP) were
considered inadequate.
As previously stated, the field investigations included a combination of walkover, surface inspection, and
shovel testing. Of these techniques, walkover transects or vehicular/aerial surveys were used most
frequently in Type A survey areas, with visual inspection of areas where previous surveys were conducted
or where topography and vegetation cover suggested a lower potential for cultural resources. These areas
included wetlands or inundated areas, previously disturbed locations, and areas where the slope exceeded
15 percent. Shovel testing was the primary survey method for Type B areas. Shovel tests were placed at
a maximum interval of 15 meters and assigned a unique identification number. Location data were
collected using handheld global positioning system (GPS) units; both location data and survey results
were recorded on survey forms. The shovel tests were excavated to a depth below which cultural
materials might be found, as little as 10 centimeters below the base of the Type A horizon or over 100
centimeters in alluvial or colluvial settings. To investigate strata below the base of standard shovel tests,
1-inch-diameter cores were used. Selected prehistoric and historic period artifacts were collected from
the surface and in shovel tests. Prehistoric artifacts found on the surface in shovel tests were recorded
using GPS and documented in photographs and notes. Diagnostic items and tools were collected for
further analysis. Unique diagnostic historic artifacts also were retained for analysis, however non-
diagnostic or mass-produced items were recorded and left at the site. A provisional artifact curation
agreement was obtained with the University of Alaska, Museum of the North (UAMN) in Fairbanks for
the eventual disposition of the artifacts. The UAMN is the repository for all archaeological collections
made on federal and state lands in Alaska. A deed of gift would be obtained for any collections from
private lands to be curated at UAMN.
Surface inspection was conducted along transects spaced at 5- to 10-meter intervals. This survey method
was principally used on historic-age sites where surface materials were sufficiently abundant to determine
the approximate age, function, and limits of the site. Provenience2 information on diagnostic items or
tools found on the surface was recorded using GPS units and documented in photographs and notes. This
method also was used on prehistoric sites, but was supplemented by shovel tests on landforms where
there was also a strong potential for subsurface prehistoric components.
Investigations to determine the potential for deeply buried cultural deposits within the APE for the Project
footprint were initiated during the 2015 field season (Proue, 2016a). Recent studies documented stratified
Late Pleistocene and Holocene sites in dune fields of the Tanana Valley. Project representatives sought to
investigate eolian landforms similar to these where deeply stratified cultural materials were recorded.
Dune deposits in the lower Nenana River and the loess deposit mantling the lower foothills bordering the
east side of the Tolovana River were selected for deep testing (Proue et al., 2016a; Appendix F). Field
investigations included excavation of 1-meter by 1-meter test units to a depth of at least 1.2 meters into
dune and loess deposits to search for cultural materials and to collect charcoal and sediment samples.
Sediments were excavated with shovels and trowels, then passed through 1/8-inch mesh screens.
2 Provenience refers to the three-dimensional location or find spot of an artifact of feature within an archaeological
site.
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Deposits below 1.2 meters were examined using a 1-inch soil probe with extensions to permit sampling to
5 meters belowground surface (Greiser et al., 2015a; Appendix F).
Cultural resource investigations in Cook Inlet reviewed information in databases maintained by the U.S.
Department of the Interior, Bureau of Ocean Energy Management/Minerals Management Service
(BOEM/MMS), OHA/SHPO, and National Oceanic and Atmospheric Administration (NOAA), as well as
geological, geotechnical coring, and available remote sensing data. The potential for encountering
historic period resources in Cook Inlet was assessed by reviewing information on potential and specific
submerged shipwreck sites in: (1) the Alaska Shipwreck Database maintained by BOEM/MMS; (2) the
Alaska Heritage Resources Survey (AHRS) site files; and, (3) the NOAA Office of Coast Survey’s
Automated Wreck and Obstruction Information System (NOAA AWOIS). The potential for prehistoric
period resources was evaluated based on prehistoric site databases, Pleistocene/Holocene geology, known
geomorphological features, available geotechnical cores and available acoustic remote sensing data (i.e.,
side-scan and multi-beam sonar, sub-bottom profiling) (Alaska LNG Project, 2015).
4.4 ARCHAEOLOGICAL AAND ABOVEGROUND RESOURCES BACKGROUND
RESEARCH AND SURVEY RESULTS
File searches and literature reviews were conducted to identify previous cultural resource surveys and
previously recorded cultural resources in the Project vicinity. The previous surveys and data then were
used to form the foundation for the research and field methodology for the Liquefaction Facility and
interdependent facilities (i.e., Mainline, GTP, PBTL, and PTTL). Data sources from previous large-scale
survey efforts that have occurred in or adjacent to the Project corridor provided the most substantive data
on the corridor and include TAPS data summaries, Northwest Alaska Pipeline data summaries, AGPPT
data and summaries, APP data and summaries, and AHRS inventory data, which contains supplemental
information on cultural resources that were located during other surveys not associated with pipeline
projects. The background research is described in detail in the 2010, 2011, and 2013 Phase I Cultural
Resources Summary Report for the Project, located in Appendix B, and is summarized in Section 4.4.3.
4.4.1 ASAP Project
The ASAP Project is a pipeline project that has been under consideration since 2010 and has generated
additional cultural resources data (ASRC 2011, 2012). Project researchers examined ASAP Project data
from surveys conducted in 2010 and 2011 and identified areas where the two projects would be
collocated. Large-scale maps were available to Project researchers and used to compare the ASAP
Project gross centerline to the Project’s preliminary base route. Initial reviews of the ASAP Project data
indicated that approximately 25 miles of the ASAP Project 2010 and 2011 survey coverage between
Livengood and the Susitna River Crossing were adequately surveyed (Greiser et al. 2014: Table 4-6).
Additional review of available data from the ASAP Project revealed several issues with using the data for
this Project. Discrepancies in the survey methods, a narrower survey corridor (200 feet wide), and
incomplete GIS data limited the utility of the ASAP Project data; therefore, none of the surveys
completed for the ASAP Project were used for this Project.
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4.4.2 Alaska Pipeline Project (APP)
A majority of the northern spreads3 of the Project Mainline, as well as the GTP area and PTTL, were
surveyed as part of the APP 2010–2012 field work. These surveys examined a 300- to 600-foot-wide
corridor within which the APE for the planned pipeline would be located. This survey corridor width is
designed to accommodate the construction ROW footprint and additional temporary work areas, but is
larger than the footprint that would be impacted by the Project. Associated facilities such as pipe yards,
ATWS, and access roads also were surveyed. A review of the cultural resources survey data from the
APP (Greiser et al., 2013a) indicated:
3,539 acres were surveyed on the Mainline;
1,697 acres were surveyed for facilities and pipeline segments that were off the ROW for the
Mainline;
42 acres were surveyed for the GTP in the PBU;
352 acres were surveyed along the PTTL route; and
27 acres were surveyed for facilities associated with the PTTL.
4.4.3 Point Thomson Project
A part of the PTTL route was examined in 2008 as part of the cultural resource investigations for the
Point Thomson Project (USACE 2012). The study examined four alternatives for construction of a 22-
mile-long gas condensate export pipeline, as well as associated facilities within the Point Thomson Unit
including a central granular pad for wells and facilities, two outlying granular pads for wells, an airstrip, a
service pier, a sealift facility, a granular material mine site, infield granular roads, and infield gathering
pipelines. According to the EIS, there were no direct impacts to cultural resources associated with the
preferred alternative (Alternative B) and one site might be potentially directly affected by one of the other
three alternatives. The EIS notes that 43 sites would be potentially indirectly affected by Alternative B.
Available map information indicates that the PTTL closely follows the route of Alternative B for the 22
miles where PTTL parallels the gas condensate pipeline.
4.4.4 Project Survey Summary and Status
Cultural resource investigations included background research and field investigations. Background
research compiled information on previously recorded cultural resources located within 1 mile of the
pipeline centerline and within 3 miles of the proposed Liquefaction Facility to provide regional data to
study settlement patterns and develop historic context for cultural resources identified during the
investigations. Data were gathered in a larger area in the vicinity of the Liquefaction Facility due to its
greater size and visibility on the landscape. A subset of the data collected for this context is presented in
this Resource Report; cultural resources located within a 2,000-foot-wide study corridor centered on the
3 Spreads are manageable lengths of a pipeline used to coordinate crews during construction. The northern spreads of the Mainline refers to the
following: Prudhoe Bay to Atigun Pass (PA), Atigun Pass to Yukon River (AY), and Yukon River to Livengood (YL).
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proposed Project corridor are presented subsequently. Field investigations sought to identify cultural
resources located within the provisional 300-foot-wide study corridor or, in some cases, a 600-foot-wide
study corridor (Greiser et al., 2013a). Cultural resource surveys conducted after the 2013 field season
were narrowed to a 300-foot-wide study corridor. These investigations were conducted in accordance
with standards and guidelines issued by FERC and OHA/SHPO (FERC, 2002; OHA/SHPO, 2003). The
field investigations conducted for the Project’s Mainline in 2013 focused on completing surveys of those
few areas where the Project centerline diverged from the APP route north of Livengood. The results of
those investigations are presented in separate reports for work on BLM lands (Greiser et al., 2013b) and
on private and state lands (Greiser et al., 2013c).
South of Livengood, the Mainline diverges from the APP route. Although portions of the Project corridor
are collocated with the ASAP Project, differences in survey methods and GIS data quality have precluded
use of the ASAP Project data from the areas that overlap with the proposed Project route between
Livengood and the Susitna River crossing (Greiser et al., 2014).
TABLE 4.4-1
Cultural Resource Survey Completed within the Direct APE by Field Season (acres)
Facility APP
2010–2012
Alaska LNG 2013
Alaska LNG 2014
Alaska LNG 2015
Total
GTP 42 252 - 151 445
Liquefaction Facility (LNG Plant and Marine Terminal)
- - 464 72 536
Mainline ROW 3,539 368 3,177 27,849 34,933
Mainline Facilities 1,697 778 708 1,833 5,016
PBTL - - - 0 0
PTTL 352 1 - 1,137 1,490
PTTL Facilities 27 2 - 16 45
Total 5,656 1,401 4,349 31,059 42,465
Cultural resource surveys conducted in 2014 examined select survey target areas along the Mainline
corridor south of Livengood and the proposed Liquefaction Facility site near Nikiski (Greiser et al., 2014;
URS/AECOM, 2015). In 2015, the investigations included additional cultural resource surveys of the
Mainline corridor and additional off-ROW facilities required for the Project, and evaluation of a large
number of resources identified during previous investigations (Greiser et al., 2015; Proue et al., 2016a,
2016b, 2016c, 2016d, 2016e). Additional surveys were conducted at the Liquefaction Facility in
connection with some geophysical and geotechnical activities (URS/AECOM, 2015). A summary of the
status of cultural resource surveys completed through the 2015 field season is presented in Table 4.4-2.
The status of cultural resource surveys along the Project footprint is varied. Cultural resource surveys
conducted to date have focused primarily on the northern half of the Mainline route and other northern
Project facilities. Approximately 93 to 100 percent of the route north of Cook Inlet is complete.
Examination of remote sensing data obtained during geotechnical surveys along the Mainline route across
Cook Inlet will be completed in 2016. Surveys on the spread south of Cook Inlet are approximately 82
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percent complete. The surveys for the proposed GTP and PTTL were substantially complete prior to
recent engineering adjustments to the Project route; approximately 45 and 86 percent, respectively, of the
footprint is surveyed on those components of the Project. More than 61 percent (42,465 acres) of the
70,150-acre direct APE for the Project were surveyed to date. Survey is complete for nearly 74 percent
(28,812 acres) of the terrestrial portion of the APE and more than 52 percent (41,338 acres) of the marine
APE.
TABLE 4.4-2
Status of Cultural Resource Survey through 2015 (acres)
Project Component Undefined
Survey Typea
Type A Survey
Type B Survey
Marine Not
Surveyedb
No Survey Accessc
APE (footprint)
Percent APE
Completed
LIQUEFACTION FACILITY
LNG Plant e 462 - - 0 521 - 983 47.0%
Marine Terminal f 3 - - 72 8 - 82 90.3%
PIPELINES
Mainline Operations and Construction ROW (by Survey Spread)
Point Thomson to Prudhoe Bay
6 2 - - - - 8 100.0%
Prudhoe Bay to Atigun Pass 1,134 675 1,059 - - - 2,869 100.0%
Atigun Pass to Yukon River 1,880 33 1,250 - 6 - 3,168 99.8%
Yukon River to Livengood 503 30 271 - 0 - 805 100.0%
Livengood to Healy 16 133 2,034 - 8 5 2,196 99.6%
Healy to Trapper Creek - 503 2,009 - 51 171 2,734 98.1%
Trapper Creek to Cook Inlet - 131 1,644 - 3 50 1,829 99.8%
Trapper Creek to Cook Inlet (Marine)
- - 3 - 2 - 5 62.8%
Cook Inlet (Marine) - - 0 21,563 19,775 - 41,338 52.2%
Cook Inlet to Nikiski - - 52 104 189 85 577 82.0%
MAINLINE FACILITIES
Access Road ROW 215 418 940 - 1,352 45 2,969 54.5%
ATWS 273 98 574 - 120 25 1,090 89.0%
Material Site 1,007 34 472 - 4,103 8 5,625 27.1%
Camp 88 52 301 - 159 1 602 73.5%
Compressor and Heater Stations
29 1 169 - 0 18 218 100.0%
Compressor Station Camp 3 0 22 - 0 2 27 100.0%
MLBV 7 2 12 - 1 1 24 95.7%
Meter Station - 0 - 0 - 0 69.0%
Pipe Storage Yard 73 28 196 - 141 39 476 70.4%
Railroad Spur - - - - 5 6 11 57.7%
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TABLE 4.4-2
Status of Cultural Resource Survey through 2015 (acres)
Project Component Undefined
Survey Typea
Type A Survey
Type B Survey
Marine Not
Surveyedb
No Survey Accessc
APE (footprint)
Percent APE
Completed
Railroad Workpad - - - - 12 25 37 67.7%
PTTL
PTTL ROW d 352 1,138 0 - 241 - 1,731 86.1%
PTTL ATWS 2 14 - - 5 - 22 76.4%
PTTL Camp 16 2 - - 94 - 111 15.9%
PTTL East Pad - 2 - - 17 - 19 9.6%
PTTL Helipad 1 - - - - - 1 100.0%
PTTL Mainline Block Valve (MLBV)
0 0 - - - - 0 100.0%
PTTL Meter Station - 0 - - - - 0 100.0%
PTTL Pipe Storage Yard 8 - - - 20 - 28 27.1%
GTP
GTP Pipeline ROW d 7 24 - - 39 - 70 44.5%
GTP Access Road 5 55 0 - 108 - 168 35.9%
GTP Barge Bridge - - - - 3 - 3 0.0%
GTP Camp - 13 - - 43 - 57 23.7%
GTP West Dock - - - - 28 - 28 0.0%
GTP Dredge f - - - 67 - 67 0.0%
GTP Material Site 26 43 - - 72 - 141 49.1%
GTP Module Staging Area - 62 3 - 21 - 86 75.7%
GTP Pad 2 178 13 - 35 - 228 84.7%
GTP Reservoir 1 11 - - 33 - 45 27.5%
GTP River Intake 0 0 - - 2 - 2 4.3%
PBTL
PBTL Pipeline ROW - 0 - - 7 - 7 5.8%
GRAND TOTAL e 6,121 3,684 11,025 21,635 27,203 482 70,150 61.2%
Notes:
Type A (low potential; reconnaissance survey), Type B (moderate-high potential; pedestrian or shovel testing survey) a Survey undefined includes a mixture of Types A and B. b Not surveyed does not include areas where there was no access. c No access data only available for 2014 and 2015 season. d Percent complete includes area for which there was no access for survey. e Total summary removes overlapping features. f Total does not include estimated area for dredge disposal area.
“0” indicates acreage less than 0.5 acre but greater than 0; “-“ indicates that there are no acres
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4.5 ARCHAEOLOGICAL, MARINE, AND ABOVEGROUND RESOURCES:
BACKGROUND AND SURVEY RESULTS
4.5.1 Sites Located within the 2,000-Foot-Wide Study Area
Table E-1 in Appendix E provides a list of archaeological sites that are located within the 2,000-foot-wide
study area for the Project, but are not within the 300-foot-wide preliminary APE. These sites include
those identified during cultural resource surveys conducted for the Project, as well as previously recorded
sites listed in the AHRS database maintained by SHPO. All of these resources are depicted on maps in
Appendix A of this report. These data and the data in Appendix E provide information to assist in
defining a route that minimizes impacts to known historic resources. Data collected on sites in the study
area are also intended to provide information on the types of cultural resources recorded in the vicinity of
the Project. Of the 207 sites recorded in this study area, 146 are described as prehistoric, 3 have both
prehistoric and historic components, 48 are historic and/or modern, 1 is recent, and 9 lack sufficient data
to identify them temporally as either prehistoric or historic and are undetermined. Another three sites
included in the AHRS data are identified as paleontological and are not cultural resources.4 Of the
prehistoric sites, the majority are characterized as lithic scatters. Other sites are described as villages,
camp sites, a rock shelter, house pits and cache pits, and artifact and bone scatters.
The majority of the sites identified within the 2,000-foot-wide study area have not formally been
evaluated for NRHP eligibility. Fifty-seven of the sites are eligible or listed in the NRHP and eight trails
or highways are recorded as “treat as eligible” meaning that, in all likelihood, the portion of site crossed is
eligible for listing in the NRHP. One site, a prehistoric lithic scatter (WIS-00426), has been
recommended as eligible for the NRHP, pending review by OHA/SHPO. One isolated lithic site (LIV-
00719) has been determined not eligible for the NRHP. Most of the sites are located along the Mainline
of the Project, none are within the GTP, and only two are within the PTTL study corridor.
There is only one site in the vicinity of the Project that is listed as a National Historic Landmark. This
Paleoarctic site (PSM-00050) is considered one of the oldest on the North Slope. Although it is not
located within the proposed footprint of the Project, it should be noted to ensure protection during
construction.
Two sites along the PTTL study corridor are noteworthy. Both were located on a previous alignment of
the PTTL ROW, but are avoided in the proposed Project route. Site XBP-00020 is an Inupiat winter sod
house located along the bank of the Sagavanirktok River. Several cache pits and depressions were
identified, along with the remains of a boat rack, caribou bone, and a scatter of cans. The site has not
been evaluated for NRHP eligibility. Site XFI-00036 is also located between Point Thomson and
Prudhoe Bay. It has been described as a domestic trash scatter dating from the 1960s, probably associated
either with U.S. military activity, or with oil exploration in the 1960s.
A portion of the Atigun Archaeological District (PSM-00204) is located within the study area in the
Prudhoe to Atigun Pass spread, in the vicinity of Galbraith Lake on the north slope of the Brooks
4 Paleontological sites recorded are noted in the text since they are recorded in AHRS inventory. They are not cultural in origin and are not
regulated under Section 106 of the NRHP. For additional information on the Project’s paleontological studies, please refer to Resource Report No. 6, Section 6.6.
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Range. This district, most recently investigated in 1981, is attributed to the late prehistoric Athapaskan
Kavik culture. The complex of sites has undergone damage from haul road and pipeline
construction. Site PSM-00074, Atigun I, is a prehistoric camp dating from Before Present (BP) 360+/-
100 and 310+/-140 containing a scatter of Kavik material including chert flakes, fire-cracked rock, and
animal bones. Located within sand dunes that extend along the Atigun River, the site consists of several
discrete loci that include hearths. NRHP nomination has been closed for the district and for PSM-00074,
pending reevaluation.
Also within the study area are several sites associated with the Rosebud Knob Archaeological District
(LIV-00284, listed in Table E-2). Site LIV-00030 is a small primary workshop-quarry locus, Site LIV-
00040 is a scatter of lithic artifacts adjacent to a chert outcrop, and Site LIV-00043 is a large prehistoric
camp site including a variety of points, edge tools, cores, microblades and burins, as well as two small
hearths/charcoal smears and two circular piles of ochre-covered stones. All of these sites would need to
be reevaluated for NRHP eligibility if they would be impacted by the Project.
Site PSM-00049, Mosquito Lake Archaeological Site, is a prehistoric camp consisting of about 24 small
isolated loci scattered over an area measuring 400 by 1,200 feet on the east side of Mosquito Lake. The
site includes a variety of lithic materials representing Denbigh and probably later occupations;
radiocarbon dates indicate that the site was occupied about 600 to 500 BC, a late date for a Denbigh site.
The Mosquito Lake and Atigun I Sites are two of several sites that comprise the proposed Atigun
Archaeological District (PSM-00204; Table E-1), which is considered significant for its association with
the Kavik Phase (AD 1500–1800), a late prehistoric complex that most archaeologists attribute to the
ancestors of modern Athapaskans (AHRS Card accessed Oct 17, 2014). A National Register nomination
form was prepared for the district, but it has not yet been formally evaluated, and the sites associated with
the district are currently listed in the AHRS files as “Nomination Closed.”
One other noteworthy site is the Prudhoe Bay Oil Field Discovery Well site (XBP-00056), located
adjacent to the GTP facility (Wooley, 1999). This NRHP listed site is the location where explorers from
the Atlantic Richfield Corporation and Humble Oil Company made a major oil discovery in 1968. The
discovery of the largest oil field in the United States “…brought unexpected and almost unimaginable
prosperity to the financially strapped new State of Alaska” (Wooley, 1999:13). Efforts to exploit these
newfound oil deposits led to a wave of activity on the North Slope, including construction of the Hickel
Highway and later the Dalton Highway to transport equipment and other materials to the oil fields. The
discovery altered the Inupiat people’s use of the land in the Prudhoe Bay area and the employment and
tax base funded basic village infrastructure. TAPS was completed in 1977 to efficiently deliver the oil to
the port of Valdez for shipment to refineries.
The Ch’u’itnu Archaeological District (TYO-00132) is located approximately 1 mile south of the
proposed Mainline corridor. The district contains 48 rectangular house pits that are grouped into 16
clusters that may represent concurrent or sequential occupations (AHRS 2016). The smaller depressions
attached to the house pits are interpreted as side rooms or steam baths. More than 277 smaller cache pits
are located near the house pits. The district was considered eligible for listing in the NRHP under
Criterion A because it clearly conveys its significance as a place that represents the broad patterns of
history regarding the uninterrupted use, from pre-contact times to the present, of salmon subsistence not
merely as a dietary supplement, but as an integral part of contemporary Tyonek culture. The district also
was “considered eligible under Criterion D for its potential to expand knowledge of Dena’ina seasonal
winter residences for the historic and prehistoric periods” (AHRS 2016). According the DOE form, “the
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concentration of undisturbed house pits and number of associated food processing and storage pits
exceeds that of most known Dena’ina winter residential sites” (AHRS Card accessed February 9, 2016).
4.5.2 Results of Surveys within the Preliminary APE
To date, 207 cultural sites and three paleontological sites have been recorded within the direct APE for
the Project (Table 4.5-1; Appendix E, Tables E-2 and E-3). Two previously identified cultural sites were
not relocated in the APE during the survey; it is likely that these sites were misplotted in the AHRS data.
Of the sites identified within the direct APE, 128 are classified as prehistoric sites, 63 date from the
historic or modern periods, 4 have both prehistoric and historic components, and 2 others date from the
protohistoric and prehistoric/historic periods. Ten additional sites did not have sufficient data for
classification by temporal period. The eligibility for listing in the NRHP has been assessed for more than
half of the sites. About 30 percent of the sites are recommended or determined eligible for listing on the
NRHP. Fifty-four sites are recorded as eligible and nine more are treated as eligible for listing in the
NRHP. The prehistoric sites include isolated lithic finds, lithic scatters, artifact scatters, house pits, cache
pits, and camp sites. Historic sites include domestic refuse scatters, house sites, camp sites, trails, a road,
a tunnel, mine sites, and other historic or modern cultural materials. Numerous segments of the Dalton
Highway, which parallels the proposed Project centerline between Prudhoe to Livengood, are treated as
eligible for the NRHP under the terms of a Programmatic Agreement with the Federal Highway
Administration. In addition, two other roads and several trails cross the proposed centerline of the
Project; the eligibility of these other transportation features has not been evaluated (Appendix E, Table E-
2).
Table E-2 in Appendix E indicates the distribution of the identified sites within each of the eight spreads.
Twelve sites were identified in the surveyed portions of the Liquefaction Facility near Nikiski. Most of
the sites are located along the Mainline. The distribution is weighted to the northern portion of the
Mainline partially because there are more gaps in the survey in this section of the route but may also
relate to the type and duration of settlement in these regions. No sites were recorded within the GTP or
PTTL pipeline route.
TABLE 4-5-1
Cultural Resources Identified in the Direct APE by Project Component and NRHP Status*
Project Component Eligible Treat as eligible
Avoid Phase I Phase II Ineligible Grand Total
LIQUEFACTION FACILITY 1 - - ** - 11 12
LNG Facility 1 - - - - 11 12
Marine Terminal - - - ** - - **
MAINLINE - TERRESTRIAL 50 7 0 3 55 36 150
Prudhoe Bay to Atigun Pass 9 3 - 3 13 7 35
Atigun Pass to Yukon River 9 4 - - 12 6 31
Yukon River to Livengood 6 - - 1 3 5 16
Livengood to Healy 9 - - 1 12 10 32
Healy to Trapper Creek 2 - - - 2 6 10
Trapper Creek to Cook Inlet 7 - - - 6 1 14
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TABLE 4-5-1
Cultural Resources Identified in the Direct APE by Project Component and NRHP Status*
Project Component Eligible Treat as eligible
Avoid Phase I Phase II Ineligible Grand Total
Cook Inlet to Nikiski 9 - - - 5 - 14
MAINLINE - MARINE - - - ** - - **
Cook Inlet Crossing - - - ** - - **
MAINLINE FACILITIES 17 18 1 8 19 22 85
Access Roads 8 8 - 2 6 3 27
ATWS 18 6 - 2 9 2 37
Material Sites 8 0 - 2 1 3 14
Camps 1 1 - - 1 1 4
Compressor Stations - 1 - - 1 - 2
MLBV - - - - - - 0
Meter Station - - - - - - 0
Pipe Storage Yards 1 1 - - - - 2
Railroad Spurs - - - - - - 0
Railroad Workpads - - - - - - 0
PTTL 0 0 0 0 0 0 0
PTTL ATWS - - - - - - 0
PTTL Camp - - - - - - 0
PTTL East Pad - - - - - - 0
PTTL Helipad - - - - - - 0
PTTL MLBV - - - - - - 0
PTTL Meter Station - - - - - - 0
PTTL Pipe Storage Yards - - - - - - 0
PTTL ROW - - - - - - 0
GTP 0 0 0 0 0 0 0
GTP Access Roads - - - - - - 0
GTP Camp - - - - - - 0
GTP West Dock - - - - - - 0
GTP Material Site - - - - - - 0
GTP Module Staging Area - - - - - - 0
GTP Pad - - - - - - 0
GTP ROW - - - - - - 0
GTP Reservoir - - - - - - 0
GRAND TOTAL 68 25 1 10 74 69 247
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TABLE 4-5-1
Cultural Resources Identified in the Direct APE by Project Component and NRHP Status*
Project Component Eligible Treat as eligible
Avoid Phase I Phase II Ineligible Grand Total
Notes:
Large linear sites such as trails and highways may have more than one AHRS number (i.e., Dalton Highway).
Paleontological sites with AHRS numbers are not included in these counts since they are not cultural resources.
Totals reflect the number of AHRS sites for each Project component; because sites may be located in more than one Project component footprint, the totals reflect the actual number of sites regardless of how many facilities it intersects.
* The NRHP status of many sites is a recommendation rather than a DOE (although OHA/SHPO has provided comments on 94 sites, BLM or FERC have not provided comments on the recommendations of the cultural resource consultant).
** Acoustic targets identified in remote sensing data identified as anthropogenic in origin however data was insufficient to determine whether they may be cultural resources that should be considered for eligibility to the NRHP
Twelve cultural resources were identified within the areas surveyed for the Liquefaction Facility at
Nikiski (URS/AECOM, 2014, 2015). Of these sites, one dates from the prehistoric period, one has both
prehistoric and historic components, and eight date from the historic or modern period. The sites with
prehistoric components are characterized by pit features, whereas the historic/modern sites are the
remains of mid-20th century domestic and industrial activity. Only one site (KEN-00656) was
recommended as eligible for listing in the NRHP. The remaining sites were determined ineligible for
listing in the NRHP.
Site KEN-00656 consists of four house pit depressions and about 11 cache pit depressions in two clusters
on a flat terrace overlooking a wetland and a small unnamed lake. Both rectangular and circular house
depressions are present. Although four pit depressions were tested, no artifacts, faunal materials, birch
bark, or other cultural materials were recovered.
Review of remote sensing data from the Marine Terminal and approach channel identified 12 sonar
targets and 77 magnetic anomalies (Rogers 2016). Three of the 12 sonar targets (Sonar Targets 1, 2, 3)
were coincident with weak magnetic anomalies (<30 gammas) and three larger sonar targets (Sonar
Targets 5, 7, 8) likely represent objects lost or dropped from the existing dock structure. Target number 5
is a rectangular object measuring approximately 6.5 by 23 feet (1.98 by 7 meters) flush with the seafloor.
Target number 7 is a rectangular object measuring approximately 9 by 31 feet (2.7 by 9.4 meters) with
ladder-like form. Target number 8 is a linear object measuring approximately 3.5 by 38 feet (1.1 by 11.6
meters) and probably represents a section of pipe or cable. The remaining targets were considered likely
geologic features such as boulders or outcrops. Forty of the 77 magnetic anomalies had high amplitudes.
The analysts noted that the surveyors indicated that operating conditions produced rather noisy profile
data but considered them to be legitimate anomalies. Anecdotal evidence suggests that at least some of
the anomalies may be related to fishing practices on the coast where seaward gill-net ends are often
secured to the seabed with steel anchors. Other anomaly clusters are clearly associated with existing piers
and berthing facilities.
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The submerged cultural resources report indicated that the existing data indicates that Sonar Targets 5, 7,
and 8 are located next to existing dock facilities north of the proposed Marine Terminal and were most
certainly anthropogenic in origin. The marine report implies that these targets are modern in origin and
unlikely to be considered eligible for the NRHP. The report also notes that although none of the magnetic
anomalies were coincident with sonar targets, the anomalies probably represent materials that are buried
in sediment and should be investigated further prior to Project-related ground-disturbing activities in the
vicinity of these anomalies. Most of the anomalies are located adjacent to existing dock facilities north of
the proposed Marine Terminal area. The two magnetic targets mapped in the Terminal area are located
along the shoreline northeast of the Project footprint. Further investigation of these targets and anomalies
with appropriate techniques is recommended if it appears that final routing and Project design would
result in ground-disturbing impacts in these locations (Rogers 2016).
The Project plans to locate the Marine Terminal and facilities (MOF, MOF dredge, shoreline protection,
etc.) adjacent to the planned onshore LNG Plant and south of the of the existing dock facilities. All of the
sonar targets and most of the magnetic anomalies are located outside of the facility locations and are
unlikely to be directly affected by construction of these facilities. Further investigation of some of the
targets/anomalies may be necessary should Project plans change, or anchor plans might result in ground-
disturbing impacts in these locations.
A total of 35 cultural resources were identified along the pipeline corridor between Prudhoe Bay and
Atigun Pass. Thirty-one of these resources are prehistoric and four are historic or historic/modern. One
AHRS site is paleontological and is not counted among the cultural resources. These sites include nine
archaeological sites that are eligible or recommended as eligible for listing in the NRHP and three
properties that are treated as eligible for the NRHP. Eight of the remaining sites were determined or
recommended ineligible for NRHP listing and 13 sites are recommended for Phase II evaluation. Two
other sites require additional Phase I investigation to evaluate their eligibility for the NRHP.
Ten prehistoric sites in the Prudhoe Bay to Atigun Pass spread were determined or recommended eligible
for listing in the NRHP. Most of these sites (PSM-00049, PSM-00501, PSM-00572, PSM-00573, PSM-
00578, and PSM-00604) consist of scatters of lithic artifacts, occasionally with animal bone (PSM-00075,
PSM-00192). Two sites (PSM-00075 and PSM-00076) may be campsites because evidence of cooking in
the form of fire-cracked rock also was found. Two of the sites are part of the Atigun Archaeological
District (PSM-00204), a collection of sites in the vicinity of Galbraith Lake that are associated with the
late prehistoric Kavik groups believed to be the ancestors of the modern northern Athapaskan people
(Proue, 2016a). The concentration of sites recorded in the Galbraith Lake and Atigun River area include
several lookout and camp sites with integrity and research potential.
The Project would cross two highways that were constructed to facilitate trucking access to the Prudhoe
Bay oil discovery in the late 1960s (Greiser, 2013a). The Project APE intersects the Hickel Highway
(SAG-00098, BET-00201) several times in the two northernmost spreads. The highway was a winter trail
that was constructed in the winter of 1968 from Stevens Village (north of Livengood) to Sagwon (south
of Deadhorse). The 550-mile highway was constructed in just over 100 days; even though it was quickly
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abandoned in favor of the Dalton Highway, the profound changes to the region initiated by the
construction of the road accelerated in the decades that followed.
The 415-mile-long Dalton Highway (SAG-00097, PSM-00570, XBP-00114, BET-00200, CHN-00070,
LIV-00501, TAN-00118, and WIS-00408) extends from the Elliott Highway at Livengood to Prudhoe
Bay and is crossed numerous times by the Mainline and a large number of the related facilities. The
Dalton Highway was constructed during the early 1970s as a more permanent trucking route to the North
Slope. Both the Hickel Highway and the Dalton Highway are treated as eligible for listing in the NRHP
by the Alaska Department of Transportation and Public Facilities (ADOT&PF), a status that requires that
projects must evaluate the portion of the resource that may be impacted by an undertaking (ADOT&PF,
2012).
A total of 31 cultural resources are recorded within the APE for the pipeline corridor between Atigun Pass
and the Yukon River. Twenty of the sites date from the prehistoric or protohistoric period, 10 are
historic, and one is historic/modern in age. Nine of the resources are eligible or recommended eligible for
listing in the NRHP, and four are treated as eligible. Of the remaining sites, six were determined or
recommended ineligible for NRHP listing and 12 were recommended for Phase II evaluation.
The resources determined, recommended, or treated as eligible for the NRHP include five prehistoric
lithic scatters, one prehistoric site with stone and bone tools, one prehistoric site with bone tools (BET-
00074), as well as several listings for the Dalton Highway (CHN-00070, WIS-00408, BET-00200, LIV-
00501) and mining-related sites dating from the early and mid-20th century (CHN-00025 and CHN-
0018).
The NRHP-eligible lithic scatter sites all exhibit intact and well-preserved subsurface deposits that
contain artifacts that suggest the site has the potential to yield significant information about prehistoric
activities in the area. Minimal testing conducted during the survey and Phase II evaluation, at the behest
of the BLM, resulted in the recovery of few chronologically diagnostic artifacts from some of these sites,
even though the evidence from the site indicated that they may be present (Proue et al., 2016e).
CHN-00025 is a historic trash scatter adjacent to Gold Creek dating from ca. 1899–1918 during the gold
rush period in the Koyukuk Historic Mining District. The site was determined eligible for the NRHP
under Criteria A and D for its association with the historic mining district and its potential to yield
information as a contributing element to the Koyukuk Historic Mining District (WIS-00386) (Proue et al.,
2016c).
CHN-0018 is a shelter camp occupied by Ross Brockman, a prominent resident of Wiseman and the
Upper Koyukuk region who moved there shortly after WWII to pursue gold prospecting and the remote
subsistence lifestyle. The site consists of a small shelter, a small stack of firewood, some poles leaned
against a tree, and associated artifacts. The structure and associated artifacts represent a unique post-
WWII period site type that may only exist at the local Koyukuk River region and was determined eligible
for listing in the NRHP under Criterion D (Proue et al., 2016e).
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South of the Yukon River, 16 cultural resources and one paleontological site were identified within the
pipeline corridor. Eleven of the resources are prehistoric, three are historic, and two are undetermined.
Six of the resources are eligible or recommended as eligible for listing in the NRHP and three sites are
recommended for Phase II evaluation. A majority of the resources are prehistoric sites that were
temporary hunting or resource procurement camps, or lithic extraction and processing sites. All three
historic resources are trails and roads. These trail and road features include the Elliott Highway
(LIV00752), the Dunbar-Brooks Terminal Trail (LIV-00556), and the Livengood Tram Road (LIV-
00392). The Elliott Highway was determined not eligible for listing in the NRHP in 2015, the Dunbar-
Brooks Terminal Trail was determined eligible for listing in the NRHP, and Phase I survey is
recommended for the Livengood Tram Road (LIV-00392) (Proue et al., 2016c).
Several archaeological sites (LIV00055, LIV-00104, LIV-00047, LIV-00284, LIV-00402) associated
with the Rosebud Knob Archaeological District were identified south of Livengood. That district (LIV-
00284) consists of a dense concentration of prehistoric archaeological sites associated with exposed layers
of chert, which were extracted and used in tool manufacture. The sites range from lookouts and flaking
stations to complex, multi-component camps. Archaeological testing and/or excavation was completed at
many of the Rosebud Knob Archaeological District sites, and most of the sites are considered eligible for
listing on the NRHP for their ability to contribute to an understanding of land and resource use by Interior
aboriginal peoples. The Rosebud Knob Archaeological District was determined eligible for listing in the
NRHP in March 2015.
The Dunbar-Brooks Terminal Trail (Alaska Railroad Corporation [ARRC] Route 63) (LIV-00556, FAI-
02102) was constructed by locals in 1915–1916 connecting the Happy Creek Station on the Alaska
Railroad to Livengood via Moose Creek Summit and Minto Flats. The trail was recommended eligible
for listing in the NRHP under Criterion A at the local level for its association with the ARRC road system
development and its association with transportation of people and goods for gold mining in the Livengood
area of the Tolovana Mining District. The trail's character defining feature is that it is a simple, single-
lane sled and wagon trail with minimal developed grade, often only distinguished by a cleared brush trail
through the lowland spruce/birch forest. The portion of the trail crossed by the Project retains essential
features to convey its historic significance and the integrity necessary to be eligible for listing in the
NRHP.
A total of 32 cultural resources were identified within the Mainline corridor between Livengood and
Healy. Seventeen of the cultural resources along this segment of the Mainline are prehistoric, 12
resources are historic, 1 resource contains both prehistoric and historic components, 1 is modern, and 1 is
of undetermined age. Nine of these resources are eligible or recommended eligible for listing in the
NRHP. Twelve resources are recommended for Phase II evaluation, 10 are ineligible for the NRHP, 1
site requires additional Phase I investigation, and 1 site was not relocated. The nine resources eligible for
the NRHP include four prehistoric lithic scatters (LIV-00748, LIV-00749, LIV-00776, HEA-595), a
multi-component site with a prehistoric Athapaskan component and an early 20th century historic
component (HEA-00062), and four trails or highways.
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LIV-000748 is a lithic scatter with a diverse assemblage that includes microblades that may be indicative
of a Holocene or late Pleistocene period occupation focused on subsistence activities. LIV-00749 is one
of the few archaeological sites located on the Minto Flats and contains artifacts like a grooved manuport
and possible red ochre that indicate a varied activity set. LIV-00776 is a lithic scatter identified during
subsurface testing at exposed granite outcrop on ridge system between the Tolovana and Tatlina rivers.
HEA-595 is a multi-component prehistoric site with a lower component dating from the Early to Middle
Archaic period with debitage and an ungulate tooth, and an upper component marked by debitage that
was probably occupied a few thousand years later (Proue et al., 2016c, 2016d). Site HEA-00062 is a
multi-component site with a prehistoric Athapaskan (AD 1495–1687) camp site with a large
concentration of fire-cracked rock and calcined bone, and a historic component that was apparently
associated with construction of the Alaska Railroad during the 1920s.
The Dunbar-Minto-Tolovana Trail (FAI-02177) was a 121-mile-long sled road from 1910 to 1935 and
was used to transport goods and people between Dunbar and Tolovana. The trail connected the Dunbar
Railroad Station with many small communities and was instrumental in the 1925 serum run from Nenana
to Nome, a significant event in the history of Alaska. The Nenana-Knights Roadhouse Trail (also known
as the Nenana-Kantishna Trail) (FAI-02366) was cut in 1920 and formed an important transportation
route between the Kantishna Mining District and the railroad at Nenana. The trail was the primary route
to the mining district from Fairbanks. The proposed Mainline would also cross the Dunbar Brooks
Terminal Trail (LIV-00556, FAI-02102) in three additional locations on the Livengood to Healy
construction spread. The rise of aviation in the 1930s led to the decline of this and other trails throughout
the state. The trail’s character-defining features are distinguished by a cleared brush trail through the
lowland spruce/birch forest (Proue et al., 2016c).
The 135-mile-long Denali Highway (HEA-00450) extends from the Richardson Highway at Paxson west
to Cantwell Road at the George Parks Highway. The road is currently treated as eligible for the NRHP by
the ADOT&PF, a status that requires that projects must evaluate the portion of the resource that may be
impacted by an undertaking (ADOT&PF, 2012). The highway would be crossed multiple times by
various components of the Project, including the pipeline at MP 566.22 and access roads near MP 566.17,
MP 566.25, and MP 566.52. A desktop DOE recommended that these portions of the Denali Highway
were eligible for the NRHP (Proue et al., 2016c).
The 10 cultural resources identified within the Mainline APE between Healy and Trapper Creek include
two prehistoric/protohistoric, two historic, two historic/modern, two modern, and two of undetermined
age. Two of the sites are recommended eligible for listing in the NRHP and Phase II evaluation is
recommended at two other sites; the remaining six sites are determined or recommended ineligible for
NRHP listing. One eligible site is a subsurface lithic scatter (TLM-00327), and is characterized by fine
silts that may derive from tephra from a Hayes volcano eruption event that may date from 3,500 to 3,800
years ago. Although limited Phase II testing at the site yielded only a few pieces of debitage, the integrity
and research potential of this site led researchers to recommend that the site is eligible for listing in the
NRHP (Proue et al., 2016c). The other eligible site (TAL-00180) is a historic period domestic site located
on the eastern bank of the Chulitna River. The site consists of several historic features and artifacts
including a semi-subterranean structure with associated borrow pits and artifact assemblage dating to the
mid-20th century. Phase II investigations indicated that these features are largely intact and although the
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ethnicity of its occupants could not be distinguished, the site has the potential to yield information
valuable in addressing a variety of research questions. OHA/SHPO concurred that the site is eligible for
the NRHP under Criterion D.
The 14 cultural resources identified along the pipeline corridor between Trapper Creek and Cook Inlet
include seven sites that date from the prehistoric/protohistoric period, four sites from the historic period,
and three sites of undetermined age. Two of the prehistoric sites, four of the historic sites, and one
undetermined age site are eligible or recommended eligible for the NRHP. Another five prehistoric sites
and one undetermined age site require Phase II evaluation to assess their NRHP statuses. One of the
undetermined sites is ineligible for listing in the NRHP.
Nearly all of the sites attributed to the prehistoric and undefined periods appear to represent pit houses
and/or cache pits, which are most concentrated in the Deshka River-Alexander Creek area. Site TYO-
00320 consists of a single rectangular semi-subterranean house pit depression with antechamber and
formal entryway, along with four associated cache pits. The site was recommended eligible under
Criterion A for reflecting broad patterns of Dena’ina subsistence patterns and culture and under Criterion
D for the archaeological features and probable archaeological materials that have the potential to shed
light on Dena’ina habitation site selection (Proue et al., 2016c). Sites TYO-00337 and TYO-00338, also
located in the area exhibit similar features and are also considered eligible for listing in the NRHP even
though they are not yet formally evaluated (Proue et al., 2016a). Site TYO-00337 consists of several
surface depressions including two small square house pits, nine small circular pit features (likely cache
pits), and one indeterminate square pit with a circular pit attached. The smaller depressions are clustered
around both house pit features, creating two distinct concentrations. Site TYO-00338 is a habitation site
consisting of a large house pit depression, two small cache pits, and a possible double-celled cache pit.
Four of the five sites recommended for Phase II evaluation are characterized by surface features similar to
other Deshka River area sites, many of which are eligible for listing in the NRHP. These include sites
with depressions that look like cache pits (TYO-00350), ovoid features and a possible hearth (TYO-
00341), five circular or oval depressions (TYO-00348), and ovoid surface expressions with charcoal
(TYO-00340). The last site (TYO-00343) recommended for Phase II evaluation is a subsurface lithic
scatter (Proue et al., 2016a).
Site TAL-00181 is a historic log cabin with associated features and artifacts dating from 1920 to 1940.
According to a local historian, the cabin was constructed by Oliver and Noah Rabideaux in the early
1920s as a trapping cabin shelter and was used by other area trappers following their deaths in 1932 and
1936. The setting, construction features, and style are consistent with cabins constructed by the
Rabideaux brothers. The cabin and associated archaeological materials were determined eligible for
listing in the NRHP under Criterion A for their association with the earliest Euroamerican settlement in
the Trapper Creek area and under Criterion D for the research potential of the archaeological assemblage
that remains (Proue et al., 2016d).
Two trails associated with the Iditarod National Historic Trail system are crossed by the proposed
pipeline. The Knik-Rainy Pass Trail (TYO-00084) is currently mapped in the AHRS on the east side of
the Susitna River, but cultural resource surveys conducted in 2014 recorded a portion of the trail crossing
the Mainline corridor at MP 725.19 (Greiser et al., 2014). The Susitna River-Old Skwentna Connecting
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Trail (TYO-00086) was identified at MP 720.57 (Greiser et al. 2014). Both of these trails were
determined eligible for the NRHP as part of the Iditarod National Historic Trail system that includes
resources from Seward to Nome (BLM, 1986; Proue, 2016a).
A third trail, the USGS Base Winter Trail 1 (TYO-00228), is crossed by the proposed pipeline at MP
702.13 in the Big Lake community area. Portions of this trail were recognized as eligible for the NRHP
due to its association with the recent listing of the Iditarod Dog Sledding Historic District/Historic
Vernacular Landscape (ANC-03326/TYO-00203) (Braund, 2009). The OHA/SHPO concurred with the
desktop determination of eligibility study’s recommendation that the portion of the trail crossed by the
Project is eligible for the NRHP (Proue, 2016a).
All 14 of the cultural resources identified on the Kenai Peninsula between Cook Inlet and the
Liquefaction Facility near Nikiski are prehistoric or of undetermined age. All nine of the sites that are
recommended as eligible for listing in the NRHP have depressions indicative of pit houses and/or cache
pits. The remaining five sites are lithic scatters with indications of subsurface deposits that warrant
additional Phase II evaluation to assess their eligibility for listing in the NRHP (Proue et al., 2016a).
A cluster of seven sites on the north shore of the Kenai Peninsula all exhibit surface depressions
indicative of pit houses and/or cache pits. Although all of the sites include depressions characterized as
pit houses, some are circular (KEN-00681, KEN-00680), others are rectangular (KEN-00685, KEN-
00686, KEN-00682, KEN-00601), and some are ill-defined (KEN-00683, KEN-00684). Although no
subsurface testing was conducted at these sites during the cultural resources survey, the similarity to other
pit house sites in the region led researchers to conclude that these sites are eligible for listing in the NRHP
(Proue et al., 2016a).
An eighth pit house site is located a short distance from the group of sites on the shores of Cook Inlet.
Site KEN-00601 is a large prehistoric and historic period site that consists of three rectangular depression
features that could either be remains of prehistoric house pits or remains of earthen foundations for a log
or timber frame structure; a stovepipe fragment was recovered from one of these features, but no other
structural evidence could be located. In addition to the pit features, approximately 15 possible cache pits
were also present (Proue et al., 2016a). A pedestrian reconnaissance survey in 2015 located two
additional house pit features and 11 cache pits extending north and east of the previously recorded
boundaries. The evidence suggests the remains are of a Dena’ina habitation that could either date to
historic or prehistoric/protohistoric time periods, and was therefore determined eligible for the NRHP
under Criterion D.
A review of historic and database inventory records, geophysical remote-sensing data, and geotechnical
sample materials collected for the Project engineering indicated that although there was little potential for
submerged prehistoric cultural resources, historic period resources may be present (Rogers 2016).
Database records in the BOEM/MMS Shipwreck Database indicate the potential for shipwrecks in the
portion of Cook Inlet crossed by the proposed pipeline but is of limited value in identifying wrecks within
the APE because the locations are based on reported shipwreck positions that are often described only in
terms of general landmarks in historical literature and have not been ground-truthed. Information
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included in the AWOIS database does not contain the full record of information that may be of interest to
this Project because it is a compilation of data on wrecks and obstructions that may pose a hazard to
surface navigation. Finally, the AHRS inventory was consulted and it was determined that there are no
records of known shipwrecks located in the study area.
Remote sensing data and geophysical samples collected to identify and characterized seafloor features
and hydrographic conditions was reviewed for cultural and anthropogenic potential. Data from single-
and multibeam bathymetry, side-scan solar imagery, magnetometry, and chirp and boomer sub-bottom
profiles were examined. Side-scan targets were regular or symmetrical shape of size, or patterns of
clustering or regular placement were identified as most likely of anthropogenic origin. Magnetometer
anomalies with high signal strength also were noted. The study examined data along two marine routes
across Cook Inlet but only the western Optional Route (Route 2) is currently under consideration. The
area examined along Route 2 (Western Route) encompassed an area measuring 2,066 feet (630 meters)
wide and approximately 27 miles (43 kilometers) long (Rogers 2016).
Two of 14 sonar targets identified in geophysical data collected in study area exhibit regular or
symmetrical size and shape and are potentially of anthropogenic origin. Sonar Target 2 is a rectangular
object measuring approximately 8.5 by 12.1 feet (2.6 by 3.7 meters) standing 6.6 feet (2 meters) above the
sea floor. Sonar Target 7 is a wedge-shaped symmetrical object measuring 17.7 by 29.2 feet (5.4 by 8.9
meters) with virtually no relief above the seafloor. Only two of the 22 magnetic anomalies identified had
high signal strength, with peak-to-peak amplitudes exceeding 500 gammas. None of the magnetic
anomalies were coincident with sonar targets.
The submerged cultural resources report indicated that although the existing data indicates that Sonar
Targets 2 and 7 were most certainly anthropogenic in origin, they do not provide sufficient information to
determine whether they may be resources that should be considered of eligibility to the NRHP. The
report also notes that although none of the magnetic anomalies were coincident with sonar targets, they
probably represent materials that are buried in sediment and should be investigated further prior to
Project-related ground-disturbing activities in the vicinity of these anomalies. Further investigation of
these targets and anomalies is recommended if it appears that final routing and Project design would
result in ground-disturbing impacts in these locations (Rogers 2016).
4.5.3 Sites Located within Mainline Associated Infrastructure
Cultural resources identified within the areas proposed for Mainline compressor stations, extra
workspaces, storage yards, construction camp sites, access roads, and other facilities are summarized in
Table 4-5-1 and are listed in Table E-3. A total of 79 AHRS sites are located within the direct APE for
the facilities where cultural resource investigations were conducted. Like the Mainline sites, lithic
scatters predominate in the north while pit house and cache pit depressions are more common in the
south. Linear transportation sites including trails and highways are often recorded under multiple AHRS
numbers and would be intersected multiple times by the Project.
A total of two cultural resources were identified within the areas surveyed for pipe storage yards. One of
these resources are prehistoric and one is historic. The historic site is treated as eligible for the NRHP and
the prehistoric sites was determined eligible by OHA/SHPO. The prehistoric resource eligible for the
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NRHP (LIV-00284) is one of at least 17 sites associated with the Rosebud Knob Archaeological District.
The historic site (LIV-00501) is a portion of the Dalton Highway, a site treated as eligible for listing in
the NRHP by ADOT&PF, which is a status that requires that projects evaluate the portion of the resource
that may be impacted by an undertaking.
Two cultural resources were identified within the areas surveyed for the Ray River Compressor Station,
one of which is historic and the other prehistoric. The prehistoric resource (BET-00252) is a surface lithic
scatter and is recommended for Phase II evaluation. The historic site (BET-00200) is a portion of the
Dalton Highway, a site treated as eligible for listing in the NRHP by ADOT&PF, which is a status that
requires that projects must evaluate the portion of the resource that may be impacted by an undertaking.
A total of four cultural resources were identified within the areas surveyed for camps, one of which is
prehistoric and the remaining three historic. The prehistoric site has been determined eligible by
OHA/SHPO, one of the historic sites is treated as eligible for the NRHP, one historic site is recommended
for avoidance, and the final site was determined not eligible for inclusion in the NRHP by OHA/SHPO.
The prehistoric resource (LIV-00284) is one of at least 17 sites associated with the Rosebud Knob
Archaeological District. The Dalton Highway (BET-00200) is treated as eligible for listing in the NRHP
by ADOT&PF, a status that requires that projects evaluate the portion of the resource that may be
impacted by an undertaking. Site HEA-00292 is the historic burial site of Frank Secondchief’s mother,
Fanny; while no determination has been made for inclusion in the NRHP, avoidance of this cultural
resource has been recommended.
Thirty-seven cultural resources were identified within ATWS areas. Fourteen of these sites are historic,
19 are prehistoric, 1 has both prehistoric and historic components, and 3 are of undetermined age.
Eighteen of the sites are eligible or recommended eligible for listing in the NRHP and another 6 are
treated as eligible for listing. Nine sites were recommended for Phase II evaluation and one site was
recommended for additional Phase I investigation. The remaining three sites were determined or
recommended ineligible for the NRHP. One paleontological site (LIV-00170) was assigned an AHRS
number but is not cultural in origin.
The sites determined or recommended eligible for the NRHP include 10 prehistoric, 6 historic, 1
prehistoric and historic, and 1 site of undetermined age. Several of the sites, including PSM-000578,
LIV-00284, LIV-00553, LIV-00749, and HEA-00595 consist of prehistoric lithic scatters with intact
subsurface deposits. The most extensive of these sites is the Rosebud Knob Archaeological District (LIV-
00284), which consists of a cluster of sites associated with exposed chert used for stone tool manufacture.
Site BET-00074 is a prehistoric site consisting of three loci containing bone tools. Four other sites are
characterized by surface depressions consistent with pit houses and cache pits located in the vicinity of
the Deshka River (TYO-00338) and Cook Inlet on the Kenai Peninsula (KEN-00682, KEN-00685, KEN-
00686). A fifth pit house site of undetermined age is located on a terrace east of Alexander Creek (TYO-
00326). The site is characterized by a very large concentration of pit house and cache pits.
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The historic period sites include a domestic sites including a can scatter (CHN-00025), an early 20th-
century log cabin (TAL-00181), and transportation routes such as the Dunbar-Brooks Terminal Trail
(FAI-02102), the Denali Highway (HEA-00450), the Knik-Rainy Pass Trail (TYO-00084), and a
connecting trail to the Iditarod Historic Trail (TYO-00086).
CHN-00025 is a widely spread historic can scatter originally located in 2001 and verified in 2010, which
consists of cans with manufacturing features before the 1920s, one of which was identified as a Lipton
Tea canister dating between 1900 and 1930. Also noted to the east of the Lipton Tea can was an axe-
hewn post that may have been a mining claim post from more recent activities. A survey in 2011
recovered terrestrial animal bone in a shovel test located just below the root mat. The site is
recommended eligible under Criterion A for its association with the boom period of mining and resource
development of the Koyukuk Historic Mining District, and is also eligible under Criterion D for its
potential to yield further information from intact surface and subsurface deposits.
Site HEA-00062 is a multi-component site with a prehistoric Athapaskan (AD 1495-1687) camp site with
a historic component that was apparently associated with construction of the Alaska Railroad during the
1920s.
A total of 16 cultural resources were identified within the areas surveyed for material sites. Nine of the
cultural resources are historic, 6 are prehistoric, and 1 has both historic and prehistoric components. Four
of these resources were eligible or recommended eligible for listing in the NRHP. Three resources were
recommended Phase II evaluation, and two resources were recommended additional Phase I investigation.
Finally, three resources were determined ineligible for inclusion in the NRHP. The four resources
eligible for the NRHP include three linear historic transportation features (LIV-00556, FAI-02102, LIV-
00764) and a multi-component site featuring three rectangular depression features and approximately 15
cache pits (KEN-00601). KEN-00601 is discussed in detail in Section 4.5.3.4 (ATWS). Four material
sites intercept the Dalton Highway (PSM-00570, CHN-00070, WIS-00408, BET-00200), a cultural
resource that is treated as eligible for listing in the NRHP by ADOT&PF, a status that requires that
projects evaluate the portion of the resource that may be impacted by an undertaking.
The Dunbar-Brooks Terminal Trail (LIV-00556, FAI-02102) is crossed a total of three times within
Borrow areas, and has been described in detail within the Mainline section of this report. The Elliott
Highway (LIV-00764) is crossed one time, and although a large portion of the highway has been altered
sufficiently to not retain its integrity, this portion was bypassed by later alteration and therefore does
retain its integrity under Criterion A and was determined eligible.
A total of 28 cultural resources were identified within the areas surveyed for access roads. Eighteen of
the cultural resources are historic, nine are prehistoric, and one resource is modern; two other resources
are paleontological and do not constitute cultural resources. Eight of these resources are eligible or
recommended as eligible for listing in the NRHP and another eight are treated as eligible by OHA/SHPO.
Six resources were recommended Phase II evaluation, and one was recommended Phase I evaluation.
Four resources were determined ineligible for the NRHP. The nine resources eligible for the NRHP
include one site (LIV-00284) associated with the Rosebud Knob Archaeological District, two lithic
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scatters (PSM-00578, LIV-00748), an Alaska Railroad station (HEA-00066), and three trails and two
highways.
Site PSM-00578 is described in the discussion of sites in the Material Sites. LIV-00748 is an isolated,
subsurface lithic find of one quartz flake recovered from a depth of 5 to 8 centimeters discovered in 2014.
A Phase II survey in 2015 expanded the survey area, recovering a further 26 artifacts from the site,
including a biface fragment, three microblades, 13 flakes, and 10 flake fragments. The biface material
was obsidian, which was sourced to an area roughly 270 kilometers (167.5 miles) north of the site. Based
on its potential to yield further information on site use, subsistence patterns, and lithic organization along
the upland ridges east of the Minto Flats, the site was determined eligible under Criterion D.
Site HEA-00066 was a water and coal Alaska Railroad station called the Broad Pass railroad section
facility. The station and more than 20 associated structures were built between 1918 and the 1970s.
While survey of the site in 2005 discovered that the station and associated buildings had been removed,
numerous historic artifacts associated with railway activity were recovered nearby, and the site was
ultimately determined eligible by SHPO under Criterion A.
The three trails crossed by access roads include the Dunbar-Brooks Terminal Trail (LIV-00556) crossed
one time, the Dunbar-Minto-Tolovana Trail (FAI-02177) crossed one time, and the Susitna River-Old
Skwentna Connecting Trail (TYO-00086) also crossed one time. The Denali Highway (HEA-00450) is
crossed a total of three times, and the Dalton Highway (XBP-00114, SAG-00097, PSM-00570, CHN-
00070, WIS-00408, BET-00200, LIV-00501) is crossed by access roads a total of 233 times. All of these
resources are described in detail in the Mainline section of this report.
4.5.4 Non-Jurisdictional Facilities
Non-jurisdictional facilities identified as connected actions include the PTU Expansion Project and the
PBU MGS Project as well as relocation of the Kenai Spur Highway. Modifications to or construction of
manufacturing facilities to fabricate Project components outside of Alaska and third-party pipelines and
associated infrastructure to transport natural gas from interconnection points to markets in Alaska are not
yet known and cannot be analyzed at this time, but may be considered as part of a future analysis of
cumulative impacts in the final Environmental Report (Resource Report No. 1, Appendix M).
The PTU Expansion would include granular expansions of the existing Central and West Pads, a new
granular material mine to support infrastructure construction, and construction of a new gathering line
connecting the West Pad to the Central Pad. An East Pad, road, and a gathering line from the East Pad to
the Central Pad was previously permitted by the Initial Production System (IPS) Project. Comprehensive
cultural resource investigations were conducted for the PTU facilities to support the NEPA review
conducted for the Point Thomson Project IPS Final EIS (USACE, 2012). These surveys remain valid and
indicate that newly proposed infrastructure at Point Thomson would not affect any known cultural
resource sites. In addition, the new West Gathering Line is proposed to be installed on vertical support
members (VSMs) shared with PTTL, the route for which was surveyed by this Project in 2015. The
AHRS inventory additionally confirms that previously recorded cultural resources sites are more than
2,000 feet from proposed facilities at the PTU.
The PBU MGS Project includes: pad expansion at the CGF Pad and Skid 50 Pad; construction of new
feed gas and propane pipelines; construction of new byproduct pipelines, and drilling and tie-in of
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approximately 10 new production and injection wells. Although cultural resource surveys have not been
completed for these facilities, an approximately 3.9-mile segment of the approximately 25-mile
Byproduct pipeline connecting the CGF module route to the GTP area was surveyed in 2013 for the
Project. A review of data on previously recorded cultural resources indicates that there are three sites in
the AHRS inventory within 2,000 feet of the non-jurisdictional facilities to be constructed at the PBU.
The Prudhoe Bay Oil Field Discovery Well site (XBP-00056) is located adjacent to the GTP facility and
approximately 800 feet from a non-jurisdictional connecting line. The NRHP-eligible site is discussed in
greater detail previously in Section 4.5.1. The Putuligayuk River Delta Overlook Site (XBP-00007) is
located approximately 815 feet from a PBU expansion pipeline ROW east of the GTP. The site is a
prehistoric site consisting of nine fire hearths and surface scatters of lithic debitage with artifacts from the
Arctic Small Tool tradition, Northern Archaic tradition, and Paleoarctic tradition dating from between BP
4000 and 8000 (AHRS 2016). Site XBP-00109 is located approximately 1,980 feet south of the ROW for
the Byproduct line connecting the GTP to Well Pads Z and W west of the facility. The site consists of the
remains of a hearth adjacent to a pingo.5 All three sites appear to be located outside of the APE for the
non-jurisdictional facilities to be constructed at the PBU.
Several alternate routes are under consideration for the relocation of the Kenai Spur Highway between
Kenai Spur Highway MP 18 and MP 25. These routes all move the existing highway east of the
Liquefaction Facility to be constructed for the Project. Project representatives are working with the
ADOT&PF and the Kenai Peninsula Borough to identify a route and complete environmental studies. At
present, no cultural resource investigations have been completed for the relocation of the Kenai Spur
Highway. A review of data indicates that only 1 of the 11 previously recorded sites located within 2,000
feet of the alternate routes under consideration is located outside of the Liquefaction Facility. Nine of the
10 sites located in the Liquefaction Facility areas were determined ineligible for listing on the NRHP
(KEN-00643, KEN-00644, KEN-00645, KEN-00647, KEN-00648, KEN-00649, KEN-00650, KEN-
00652, and KEN-00651). The 10th site (KEN-00656) was recommended eligible by the investigators
(URS/AECOM 2015b). The sole site located outside of the Liquefaction Facility (KEN-00011) is
described as two well-defined house depressions with extra rooms and tunnels overlooking a small lake
north of the Liquefaction Facility. Revisited in 2012, the site was found to be totally destroyed by
modern construction (AHRS 2016). Additional information on the relocation of the Kenai Spur Highway
will be provided in the FERC application.
4.6 ETHNOGRAPHIC STUDY
An ethnographic analysis is underway to identify Alaska Native groups or other groups with ties to the
Project area and to identify properties of traditional, religious, or cultural importance to those
organizations, interested parties, and ethnic groups. The study will provide an ethnographic overview of
Native cultures within the North Slope, Yukon River, Tanana River, Copper River, Southcentral Alaska,
Prince William Sound, and the Kenai Peninsula. The primary cultures within these regions are the
Inupiat, Athabascan, and Sugpiat (also called Alutit). The Athabascans in the study regions are further
divided into the Koyukon, Gwich’in, Tanana, Ahtna, and Dena’ina cultural groups. The study will
describe selected ethnographic topics that characterize the Native study communities and their inhabitants
5 A pingo is a periglacial landform consisting of a mound of earth covered ice formed as a result of hydrostatic pressure on water from
permafrost.
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within a region, identify agents of change, and address cultural themes that have the potential to be
affected by the Project. It is anticipated that the ethnographic report will be completed in the fall of 2016.
An interim version of the ethnographic report (Braund 2015) is available in Appendix B of this report; the
complete ethnographic study will be included with the FERC application.
4.7 POTENTIAL CONSTRUCTION IMPACTS AND MITIGATION MEASURES
Preliminary plans indicate that the Project has potential to impact cultural resources that are eligible for
listing in the NRHP. A total of 149 cultural resources were identified within the direct APE for the
Mainline, 12 resources in the direct APE for the Liquefaction Facility, and 84 resources within the direct
APE for facilities associated with the Project. These resources were evaluated applying the National
Register Criteria for Evaluation (36 CFR 60.4 [a-d]) and 53 of the cultural resources were listed,
determined eligible, or recommended as eligible for the NRHP. Another nine resources are treated as
eligible by OHA/SHPO and other Alaska state agencies. These resources are varied, including prehistoric
camps and pit house villages, historic gold rush related sites, Iditarod trails, and trails/highways built as a
result of the discovery of oil in Prudhoe Bay. The potential construction impacts of the Project on these
resources depend on the specific type of construction activity, as well as the features and character-
defining attributes of each resource.
FERC, in consultation with OHA/SHPO, makes an assessment of adverse effects on the identified historic
properties (listed or eligible for listing in the NRHP) based on criteria found in ACHP’s regulations. If
FERC determines that there would be an adverse effect, it would begin consultation to seek ways to
avoid, minimize, or mitigate the adverse effects. An adverse effect results when an aspect of the proposed
Project would negatively affect any of the characteristics of a historic property that qualify it or make it
eligible for listing in the NRHP (36 CFR 800.5). Physical destruction of a historic property or
diminishment of the integrity of the property’s location, design, setting, materials, workmanship, feeling,
or association are considered an adverse effect (36 CFR 800.5; NPS, 2002).
In general, any ground-disturbing activity, including such activities as removal of the vegetative mat,
grading, trenching, earth-moving, blasting, and driving equipment across a site, may result in direct
adverse effects to cultural resources. Indirect effects on cultural resources also must be considered.
Indirect effects may result from changes in the landscape that could impact the viewshed of historic or
traditional cultural properties or by increasing access to areas with sensitive NRHP-eligible cultural
resources. Because the plans for aboveground facilities are still developing, consultation with FERC,
OHA/SHPO, and BLM to define the APE for indirect effects is ongoing.
Although the Project plans to avoid affecting NRHP-eligible resources to the extent practicable, it is
unlikely that it would be possible to avoid impacting all resources. An engineering review would be
conducted for each resource to determine which resources could be avoided and which would require
treatment or mitigation plans. A variety of treatment approaches might be applied to avoid, minimize, or
mitigate these effects. Project redesign may be an option, depending on SHPO, FERC, and/or BLM
concurrence or requirements. Should engineering treatment options be pursued, plans would be prepared
and presented in the treatment plans for the Project. Treatments for direct effects may include
construction during the winter when the ground is frozen, horizontal directional drilling, reconfiguration
of workspaces, and/or necking down the construction workspace to avoid impacts. Treatments for
indirect visual effects might include vegetative screening or sympathetic building design. Finally, if other
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options are not practical, data recovery might be suitable for archaeological sites that are significant under
NRHP Criterion D for the information that they contain. Data recovery plans would be developed for
these archaeological sites. These plans would identify research questions to be addressed by
archaeological investigations at the site and specify field and laboratory methods to ensure that the
necessary data would be collected.
Once engineering studies and planning are complete, a detailed assessment of the potential Project
construction impacts would be conducted on those cultural resources that are eligible for or listed in the
NRHP. A list of potentially affected resources and treatment plans would be prepared for review and
comment by FERC, OHA/SHPO, BLM, other appropriate state and federal agencies, relevant federally
recognized Indian Tribes, and consulting parties on the Project. It is anticipated that drafts of these
documents will be prepared in 2016/7 for eligible sites identified to date that cannot be avoided. A
Memorandum of Agreement would be prepared that would outline the measures to avoid, minimize, or
mitigate adverse effects on historic properties in consultation with OHA/SHPO and others, such as
federally recognized Indian Tribes and Alaska Native Corporations. If necessary, ACHP may participate
in the consultation to resolve adverse effects.
Although most cultural resources are identified through surveys conducted for the Project, it is possible
that some historic resources could escape detection and would be discovered during construction. For this
reason, the Unanticipated Discovery Plan was prepared to provide protocols for identifying cultural
resources and human remains discovered during construction, evaluating their eligibility for listing in the
NRHP, and resolving effects if necessary (see Section 4.9 and Appendix F).
4.7.1 Liquefaction Facility
The Liquefaction Facility would be a new facility constructed on the eastern shore of Cook Inlet in the
Nikiski area of the Kenai Peninsula. The facility would consist of the LNG Plant and Marine Terminal.
Only 1 of the 12 cultural resources recorded within the Liquefaction Facility is recommended eligible for
the NRHP. Site KEN-00656 is a prehistoric and historic period cluster of four house pit depressions and
11 cache pit depressions, and is located in the southern portion of the Liquefaction Facility. Additional
offshore surveys are required to address magnetic and sonar anomalies identified to date.
To date, no formal coordination or consultation has been undertaken with state or federal agencies
regarding proposed mitigation measures or treatment plans for any of the cultural resources that are listed
or determined eligible for listing in the NRHP. These plans would be developed in consultation with state
and federal agencies and emphasize avoidance as the preferred treatment. If the cultural resource could
not be avoided, efforts would be made to minimize impacts to the site resulting from the Project by
measures such as matting or construction during the winter. The site-specific treatment plans would
provide information and plans on avoidance and minimizing impacts. Should it be impossible to avoid
adversely impacting a cultural resource, a detailed data recovery plan would be developed for review by
state and federal agencies, as appropriate, before submitting to FERC for final review.
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4.7.2 Interdependent Facilities
The Mainline would be a 42-inch-diameter natural gas pipeline, approximately 804.3 miles in length from
the GTP on the North Slope to the Liquefaction Facility on the shore of Cook Inlet near Nikiski. A
majority of the proposed Mainline route generally follows the TAPS and adjacent highway infrastructure
corridor south to the vicinity of Livengood, Alaska, where it turns south toward the Liquefaction Facility.
Approximately 36 percent of the proposed Mainline route is collocated with existing ROWs (see
Resource Report No. 1, Section 1.3.2.1). The pipeline would be belowground for most of the route, with
the exception of four planned aerial winter crossings, aboveground crossings of active faults, and the
offshore pipeline.
Fifty-seven of the 149 cultural resources identified within the APE for the Mainline are listed or eligible
for the NRHP. These resources include a variety of types of cultural resources, such as short-term camps
and lookouts, lithic reduction and quarry sites, pit house villages, early 20th-century trapper cabins and
gold rush-related sites, and oil extraction-related sites. Several of the sites are elements of linear trail or
road features such as the Hickel Highway, Dalton Highway, early trails, and the Iditarod National Historic
Trail.
To date, no formal coordination or consultation has been undertaken with state or federal agencies
regarding proposed mitigation measures or treatment plans for any of the cultural resources that are listed
or determined eligible for listing in the NRHP. These plans would be developed in consultation with state
and federal agencies and emphasize avoidance as the preferred treatment. If the cultural resource could
not be avoided efforts would be made to minimize impacts to the site resulting from the Project by
measures such as narrowing the construction corridor, directional drilling, or construction during the
winter. The site-specific treatment plans would provide information and plans on avoidance and
minimizing impacts. Should it be impossible to avoid adversely impacting a cultural resource, a detailed
data recovery plan would be developed for review by state and federal agencies as appropriate before
submitting to FERC for final review.
The Mainline includes several types of aboveground facilities. The proposed design includes eight
compressor stations, one standalone heater station, two meter stations, multiple pig launching/receiving
stations, multiple Mainline block valves, and five interconnection points in locations that are currently
unknown at this time. Designs for these aboveground facilities have not yet been made available for
review by SHPO; as such, consultation about the appropriate APE for indirect effects has not yet been
initiated. Once this APE is defined, cultural resource investigation will be undertaken to identify and
evaluate resources in that area. Potential effects of the aboveground facilities may include visual effects
from the new construction, as well as possible effects of vibration and noise.
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Construction of the Mainline would require the use of additional temporary facilities and other resources
in the area of the permanent pipeline ROW. The associated infrastructure may include the following
facilities:
Temporary workspace for construction activities (e.g., staging areas truck turnarounds and
utility crossovers);
Access roads and shoo-flies (i.e., temporary roads bypassing constrained sections of the
construction ROW);
Equipment fueling facilities;
Helipads and airstrips;
Construction camps, pipe storage areas, contractor yards, and rail spurs;
Existing and new material sites to supply granular material; and
Disposal sites for excavated material, blast rock, and acid drainage rock removed from the
permanent pipeline ROW.
Since much of the Pipeline Associated Infrastructure would be temporary, the potential effects would be
restricted primarily to historic properties that would be directly affected by the construction activities.
Cultural resource investigations conducted to date have identified 35 cultural resources that are listed,
eligible, or treated as eligible for the NRHP. Many of these are multiple crossings of long linear historic
trails and highways, such as the Dalton Highway. NRHP-eligible sites also include lithic scatter camp
sites, pit house depression sites, historic cabins, and historic artifact scatters.
As proposed, the PTTL would be an approximately 62.5-mile, 32-inch-diameter pipeline installed
aboveground on vertical support members (VSMs), minimizing potential ground disturbance. No cultural
resources are recorded within the direct APE for the proposed alignment of the PTTL.
If the Project were to have an adverse effect on historic properties identified within the APE for the
PTTL, consultation would be initiated to resolve those effects and develop treatment/mitigation plans as
appropriate.
According to the proposed design, the PBTL would be an approximately 1-mile, 60-inch-diameter
aboveground pipeline to transport natural gas from the CGF to the GTP. The Prudhoe Bay Meter Station
would be collocated within the CGF boundary to measure the natural gas entering the PBTL from the
CGF. The PBTL would be installed aboveground on VSMs, minimizing potential ground disturbance.
No cultural resources are recorded within the direct APE for the PBTL.
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If the Project were to have an adverse effect on historic properties identified within the APE for the
PBTL, consultation would be initiated to resolve those effects and develop treatment/mitigation plans, as
appropriate.
The proposed GTP is designed to treat natural gas received from the PBU and PTU. The GTP would be
constructed on the North Slope near the Beaufort Sea coast. The GTP would include the GTP pad and
Operations Center pad. The GTP would be built on a granular pad to protect the permafrost.
If the Project were to have an adverse effect on historic properties identified within the APE for the GTP,
consultation would be initiated to resolve those effects and develop treatment/mitigation plans as
appropriate.
Several additional facilities would be constructed to operate the GTP facility, including a new module
staging area, West Dock modifications, a water reservoir, associated transfer pipeline, access roads, ice
roads, construction camps, and a material site.
If the Project were to have an adverse effect on historic properties identified within the APE for the
associated GTP infrastructure, consultation would be initiated to resolve those effects and develop
treatment/mitigation plans, as appropriate.
4.7.3 Non Jurisdictional Facilities
The PTU Expansion project would use information gathered from field and literature cultural resource
surveys to avoid and protect known sites during construction, implement unanticipated discoveries
protocols, and provide training for the construction workforce on the importance of protecting cultural
sites and proper procedures to do so. No sites are known to exist within the proposed footprint.
The PBU MGS project would use available information from previous cultural resource surveys
conducted in the project area and literature sources to identify any known resource sites prior to
construction. PBU MGS project would follow federal, state, and local requirements regarding discovery
of previously unknown cultural resources and provide training for contractors on procedures if such
resources are uncovered during project activities.
4.8 POTENTIAL OPERATIONAL IMPACTS AND MITIGATION MEASURES
Prior to the FERC issuing the Order for the Project, a cultural resources survey will have been completed
for the entire operational area of the Project. Cultural resources will be identified and evaluated for
NRHP eligibility. Because there would be an inventory of all resources that are listed or eligible for
listing in the NRHP, operational protocols would include information on the location of culturally
sensitive areas and any resources that would be very close to the permanent easement or facilities would
be marked with signage or fencing identifying that the location is an environmentally sensitive area.
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Specifics of any operational protocols or mitigation measures to be implemented for operation and
maintenance activities will be presented in the FERC application. In addition, it would be necessary to
make maintenance personnel aware of the procedures for cultural resources and human remains presented
in the Unanticipated Discovery Plan (see Section 4.9 and Appendix F).
4.8.1 Liquefaction Facility
Natural buffer areas around the Liquefaction Facility that would remain undeveloped (i.e., graveled) as
part of facility construction would be maintained during operations. Minimal maintenance would be
conducted in these areas in accordance with the Alaska LNG Project’s Plan and Procedures. All
materials required during maintenance would be transported to the site via existing roads and personnel
would be housed in local accommodations. All maintenance and turn-around activities would be
conducted within plant boundaries.
4.8.2 Interdependent Facilities
After installation of the pipelines, the operations ROW would be maintained to facilitate identification of
surface conditions and serve as a visual indicator of the existence of a pipeline for anyone performing
construction activity nearby. ROW access for maintenance and emergency response in areas subject to
seasonal ground transportation limitations, such as permafrost areas within the North Slope, would use
approved air transport or low pressure tire ground transportation methods. In some cases, this may
include construction of temporary ice roads to access ROW areas in the winter.
Maintenance of the pipeline ROWs would be conducted according to the measures outlined in the Alaska
LNG Project’s Plan and Procedures. The Project entity would be responsible for ensuring successful
revegetation of soils disturbed by Project-related activities. Trees would not be allowed within the
boundaries of the operations ROW, except over horizontal direction drilling crossings or direct pipe
crossings, because tree roots have the potential to damage pipeline coating, which may contribute to the
loss of integrity of the pipeline.
Pipeline patrols would be employed to inspect and observe surface conditions on and adjacent to the
pipeline ROW for indications of leaks, construction activity, and other factors affecting safety and
operation. Inspections are often performed via aerial patrol, with other inspection methods including
vehicle and foot patrols.
Planned maintenance of aboveground facilities would also include routine checks, inspection, and
servicing equipment. Unplanned maintenance would include investigating problems identified by control
and monitoring systems and implementing corrective actions. A fire buffer would be maintained for all
compressor stations and the heater station. This zone would be a cleared strip of land that extends
outward approximately 130 feet from the station fence on three sides. The vegetation in the buffer zone
would be controlled by cutting and removing large trees and brush.
All maintenance and patrol activities would be conducted within the operations ROW and access roads
used during construction activities. Apart from instances where cultural resources remain and are marked
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by fencing/signage, operations/maintenance is expected to have minimal new disturbance and impacts,
particularly considering that these activities would occur within the construction footprint.
Because there are no cultural sites found along the PBTL and PTTL, maintenance activities would have
no impacts.
Because there are no sites found at the GTP site, or in any of the associated infrastructure, there would be
no impacts to cultural resources during operations.
4.8.3 Non Jurisdictional Facilities
No sites are known to occur within the proposed footprint of the PTU Expansion project and therefore
there are no impacts to cultural resources expected during operations.
Information related to the PBU MGS and Kenai Spur Highway relocation will be provided at a later date.
4.9 UNANTICIPATED DISCOVERIES PLAN
A draft Unanticipated Discoveries Plan has been developed following the regulatory guidance related to
Section 106 of the NHPA. A copy of the draft plan is included as Appendix F. The plan establishes
procedures to be used in the event that an historic property or human remain is found during construction
of the Project. OHA/SHPO, FERC, and the BLM have received the Unanticipated Discoveries Plan for
review and comment. During construction, copies of the Unanticipated Discoveries Plan would be kept
at the main construction office on each spread; construction field management and environmental
inspectors would be trained in its contents.
4.10 REFERENCES
Alaska Heritage Resources Survey (AHRS). 2014. Site Card for Site PSM-00204, Atigun Archaeological
District. Card on file at the Alaska Office of History and Archaeology. Accessed October 17,
2014.
Alaska Heritage Resources Survey (AHRS). 2016. Site Card for Site TYO-00132, Ch’u’itnu
Archaeological District. Card on file at the Alaska Office of History and Archaeology. Accessed
February 9, 2016.
Alaska Heritage Resources Survey (AHRS). 2016. Site Card for Site XBP-00007, Putuligayuk River
Delta Overlook Site. Card on file at the Alaska Office of History and Archaeology. Accessed
March 23, 2016.
Alaska Heritage Resources Survey (AHRS). 2016. Site Card for Site KEN-00011. Card on file at the
Alaska Office of History and Archaeology. Accessed March 23, 2016.
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Alaska LNG Project 2015. Letter from Charlie Kominas (Alaska LNG) to Office of History and
Archaeology, Alaska Department of Natural Resources from Alaska LNG regarding Evaluating
the Presence of Submerged Cultural Resources in Cook Inlet.
Alaska Department of Transportation and Public Facilities (ADOT&PF) 2012 Interim Guidance for
Addressing Alaska Historic Roads Under the February 23, 2010 Programmatic Agreement
Among the Federal Highway Administration, the Advisory Council on Historic Preservation, the
Alaska Department of Transportation and Public Facilities, and the Alaska State Historic
Preservation Officer Regarding Alaska’s Highway System Roads Affected by the Federal-Aid
Highway Program in Alaska. Copy on file, Alaska Department of Transportation and Public
Facilities, Anchorage.
Alaska Department of Transportation and Public Facilities (ADOT&PF) 2014 Alaska Roads Historic
Overview, Applied Historic Context of Alaska’s Roads. Mead & Hunt, and Cultural Resource
Consultants, LLC. Anchorage, Alaska.
Alaska Office of History and Archaeology (OHA) 2003 Standards and Guidelines for Investigating and
Reporting Archaeological and Historic Properties in Alaska. Historic Preservation Series No. 11.
Alaska Office of History and Archaeology, Alaska Department of Natural Resources, Anchorage.
Arctic Slope Regional Corporation Energy Services (ASRC). 2011. Alaska Stand Alone Gas
Pipeline/ASAP. Cultural Resource Report for the 2010 Field Season. Prepared for Alaska Gasline
Development Corporation. Report on file: OHA, Anchorage.
ASRC. 2012. Alaska Stand Alone Gas Pipeline/ASAP. Cultural Resource Report for the 2010 and 2011
Field Seasons. Prepared for Alaska Gasline Development Corporation. April.
Bittner, Judith E. 2015 Memorandum to Shannon Miller (ADNR, State Pipeline Coordinator’s Office)
regarding 2014 Phase I Cultural Resources Inventory Report, Nikiski, Alaska, February 12, 2015.
Bittner, Judith E. 2016a Letter to Karen Wuestenfeld regarding National Register of Historic Places
Eligibility Recommendations for 70 Cultural Resource Sites within Alaska LNG Project Area,
February 11, 2016.
Bittner, Judith E. 2016b Letter to Karen Wuestenfeld regarding Phase II Cultural Resources Evaluation
Report, 24 Determinations of Eligibility for the Alaska LNG Project Area, March 21, 2016.
Braund, Stephen R. & Associates (Braund & Associates) 2009 Port MacKenzie Rail Extension Project,
Report for 2008 Cultural Resources Fieldwork. (updated 2010). Prepared for Surface
Transportation Board and ICF International. On file at OHA, Anchorage.
Braund, Stephen R. 2015 Interim Ethnographic Report – Iñupiat. (USAI-UR-BRZZZ-00-000003-000)
Report prepared by Stephen R. Braund for the Alaska LNG Project.
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Bureau of Land Management (BLM) 1986 The Iditarod National Historic Trail, Seward to Nome Route,
Comprehensive Management Plan. Bureau of Land Management, Anchorage District Office,
Anchorage.
United States Army Corps of Engineers (Corps) 2012 Point Thomson Project Final Environmental
Impact Statement. United States Army Corps of Engineers, Alaska District, JBER, AK. Available
online at: http://www.arlis.org/docs/vol1/AlaskaGas/Report3/Report_PtThom_FEIS/index.html
Exp Energy Services, Inc. (exp) 2015 Cultural Resource Advisor Summary Report, Alaska LNG. Report
prepared by exp Energy Services, Inc., for the Alaska LNG Project.
Federal Energy Regulatory Commission (FERC). 2002. Guidelines for Reporting on Cultural Resources
Investigations for Pipeline Projects. Office of Energy Projects, Washington, DC.
Greiser, T. Weber, Molly Proue, Timothy King, Andrew Higgs, Lindsay Argo, Burr Neely, Michael S.
Kelly, and Michael D. Gray. 2013a. 2010, 2011, and 2013 Phase I Cultural Resource Summary
Report: Archaeological Survey and Site Documentation (USAKE-UR-SRZZZ-00-0017). Report
prepared by Northern Land Use Research Alaska, LLC for the Alaska LNG Project.
Greiser, T. Weber, Molly Proue, Timothy King, Andrew Higgs, Lindsay Argo, Burr Neely, Michael S.
Kelly, and Michael D. Gray. 2013b. 2013 Phase I Cultural Resource Report: Archaeological
Survey and Site Documentation on Bureau of Land Management Lands (USAKE-UR-SRZZZ-
00-0020). Report prepared by Northern Land Use Research Alaska, LLC for the Alaska LNG
Project.
Greiser, T. Weber, Molly Proue, Timothy King, Andrew Higgs, Lindsay Argo, Burr Neely, Michael S.
Kelly, and Michael D. Gray. 2013c. 2013 Phase I Cultural Resource Report: Archaeological
Survey and Site Documentation (USAKE-UR-SRZZZ-00-0021). Report prepared by Northern
Land Use Research Alaska, LLC for the Alaska LNG Project.
Greiser, T. Weber, Molly Proue, Timothy King, Andrew Higgs, Lindsay Argo, Burr Neely, Michael S.
Kelly, and Michael D. Gray. 2014. 2014 Cultural Resources Data Gap Analysis and Sensitivity
Model (USAKE-UR-SRZZZ-00-0033). Report prepared by Northern Land Use Research Alaska,
LLC for the Alaska LNG Project.
Higgs, A. S., T.W. Greiser, L.T. King, and B.J. Neely. 2011a. 2010 Cultural Resource Field Study
Results, Phase I: Identification Cultural Resource Survey of the Alaska Pipeline Project.
Supplemental Report to OHA Permit No. 2010-17. Report USAG-UR-SRZZZ-000011 prepared
for Environmental Regulatory Support Services and TransCanada/ExxonMobil. Prepared by
NHG Alaska LLC, Anchorage, Alaska.
Higgs, A. S., T.W. Greiser, L.T. King, and B.J. Neely. 2011b. Phase I: Identification Cultural Resource
Survey of the Alaska Pipeline Project. Supplemental Report to BLM Permit No. AA-92471.
Report USAG-UR-SRZZZ-000010 prepared for Environmental Regulatory Support Services and
TransCanada/ExxonMobil. Prepared by NHG Alaska LLC, Anchorage, Alaska.
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Higgs, A., T. W. Greiser, L. T. King, K. Garrad, J. Picklesimer, and B. Neely. 2012. Phase I Cultural
Resources Overview and Survey Report for the Alaska Pipeline Project, Prudhoe Bay, to the
Alaska, United States-Canada Border, 2010-2011. Report USAG-UR-SRZZZ-000030 prepared
for Environmental Regulatory Support Services and TransCanada/ExxonMobil. Prepared by
NHG Alaska LLC, Anchorage, Alaska.
Natural Resource Group 2008. Field Study Plan, Denali – The Alaska Gas Pipeline LLC. Report
prepared for Denali – The Alaska Gas Pipeline LLC.
NPS (National Park Service) 2002 How to Apply the National Register Criteria for Evaluation. National
Register Bulletin 15. National Park Service, Washington, DC.
Office of History and Archaeology (OHA/SHPO). 2003. Standards and Guidelines for Investigation and
Reporting Archaeological and Historic Properties in Alaska. Alaska Department of Natural
Resources, OHA, Historic Preservation Series No. 11.
Potter, B. A., P. M. Bowers, S. C. Gerlach, O. K. Mason, M. Ganley, and S. S. Legge. 2001. Site
Location Model and Survey Strategy for Cultural Resources in the Alaska Gas Producers
Pipeline Project Area. Report Prepared for Alaska Gas Producers Pipeline Team by Northern
Land Use Research, Inc., and Chumis Cultural Resource Services, Anchorage, AK.
Proue, Molly, Jill Baxter-McIntosh, T. Weber Greiser, Andy Higgs, Hayley Brown, Patrick Hall, Tim
King, and James Gallison 2016a Alaska LNG 2015 Phase I Cultural Resource Report:
Archaeological Survey and Site Documentation. (USAI-P1-SRZZZ-00-000008-000).Report
prepared for AECOM by Northern Land Use Research Alaska, LLC, Fairbanks.
Proue, Molly, Jill Baxter-McIntosh, T. Weber Greiser, Andy Higgs, Hayley Brown, Patrick Hall, Tim
King, and James Gallison 2016b Alaska LNG 2015 Phase I Cultural Resource Report:
Archaeological Survey and Site Documentation. Bureau of Land Management Lands (USAI-P1-
SRZZZ-00-000009-000). Report prepared for AECOM by Northern Land Use Research Alaska,
LLC, Fairbanks.
Proue, Molly, T. Weber Greiser, Lisa Smith, James Whitney, Andy Higgs, and Burr Neely 2016c Alaska
LNG 2015 Cultural Resource Evaluation Report. (USAI-P1-SRZZZ-00-000007-000) Report
prepared for AECOM by Northern Land Use Research Alaska, LLC, Fairbanks.
Proue, Molly, James Gallison, James Whitney, Lisa Smith, Jill Baxter-McIntosh, Robert Bowman,
Hayley Brown, Patrick Hall, Crystal Glassburn, Mary Ann Sweeney, T. Weber Greiser, Andy
Higgs, and Tim King 2016d Alaska LNG 2015 Phase II Cultural Resource Report: Site
Evaluations. (USAI-P1-SRZZZ-00-000005-000) Report prepared for AECOM by Northern Land
Use Research Alaska, LLC, Fairbanks.
Proue, Molly, James Gallison, James Whitney, Lisa Smith, Jill Baxter-McIntosh, Robert Bowman,
Hayley Brown, Patrick Hall, Crystal Glassburn, Mary Ann Sweeney, T. Weber Greiser, Andy
Higgs, and Tim King 2016e Alaska LNG 2015 Phase II Cultural Resource Report: Site
Evaluations. Bureau of Land Management Lands (USAI-P1-SRZZZ-00-000004-000) Report
prepared for AECOM by Northern Land Use Research Alaska, LLC, Fairbanks.
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Reuther, J.D. 2009. Cultural Resources Survey of the Denali-The Alaska Gas Pipeline Project Proposed
Gas Treatment Plant, Prudhoe Bay, Alaska. Report Prepared by Northern Land Use Research,
Inc. for Denali-The Alaska Gas Pipeline LLC (Doc Repo Record ID #16068527)
Rogers, Jason with shipwreck analysis by Evguenia Anichtchenko 2016. Alaska LNG Submerged
Cultural Resources Review and Assessment, Cook Inlet, Alaska. (USAI-PI-SRZZZ-00-000021-
000). Report prepared by Northern Land Use Research Alaska, LLC, Fairbanks.
URS/AECOM. 2015a. 2014 Phase I Cultural Resources Inventory Report for the Proposed Liquefaction
Facility Component of the Alaska LNG Project, Nikiski, Alaska. (USAI-UR-SRZZZ-00-000014-
000). Report prepared by URS/AECOM for the Alaska LNG Project. (Doc Repo Record ID
#16274742)
URS/AECOM 2015b, 2015 Phase I Cultural Resources Inventory and Monitoring Report for the
Proposed Liquefaction Facility Component of Alaska LNG, Nikiski, Alaska (USAI-UR-SRZZZ-
00-000071-000). Report prepared by AECOM for the Alaska LNG Project.
Wooley, Christopher B 1999 National Register Nomination for the Prudhoe Bay Oil field Discovery Well
site (XBP-00056). Prepared by Chumis Cultural Resource Services for ARCO Alaska, Inc.