Alaska Native Villages Need Not Apply


Time lapse photo of the Pretty Rocks Formation on the Denali Park Highway sliding downhill

The National Park Service already has an environmental assessment out for the proposed repairs to the Denali National Park Road at Polychrome Pass. Readers may recall the existing road crosses a rock glacier and climate change has accelerated the glacial flow, carrying off the road. The Park Road is closed east of Polychrome Pass.

You can comment on the environmental assessment. WC has:

While WC strongly supports the effort to re-open the Park Road past Polychrome, WC doubts that the current version of the Environmental Assessment (EA) is adequate to pass applicable legal review standards. WC’s specific concerns fall into three categories:

(1) The geology of the Teklanika Formation is inadequately discussed in the EA. From WC’s observations and reading, the alleged competent rock is itself heavily fractured and faulted. There is no discussion to support the assumption that rock is structurally capable of supporting the proposed bridge and the construction requirements such a bridge will impose. Obviously, it is insufficient to say it is better than the ash/clay layer. If there have been engineering studies to support the assumption that those ancient, fractured lava flows will support pile-driving, they should be a part of the EA. Otherwise, this is not a “full and fair analysis.”

(2) The case law under NEPA strongly disfavors “all or nothing” analysis, where the alternative analyzed are solely the preferred alternative and inaction, yet that’s what this EA presents. That approach is particularly dubious where, as here, the absence of a geologic analysis of the rock proposed to anchor the abutments is omitted. Properly, the EA should consider and analyze the other two alternatives (the northern route over Polychrome Mountain and the southern route along the river) as well. Instead, they are rejected out of hand.

(3) WC is concerned that the construction effort will further fracture the already severely fractured basalt and rhyolite. Pile-driving, in particular, imposes rhythmic shocks that can generate resonate vibrations. Even if the construction effort only generates micro fractures at the surface, the water/ice freeze/thaw cycle will quite rapidly create quite large mass wasting events. Erosion always wins. The EA is ambiguous as to how the anchor pilings for the bridge and the sheet pilings the retaining wall will be installed.

Consider: the NPS has the present problem because the current route wasn’t carefully considered. No one intentionally builds a permanent road over a rock glacier. In dealing with the problems created by the absence of due diligence in the 1930s, don’t make the same mistake again.

It’s unsurprising that the Federal government was able to find $41 million to repair the Denali Park Road with all the businesses facing financial problems with more than half of the road closed. It’s sadder, and even less surprising, that the Federal government can’t find money to help the fifteen or more Alaska Native villages threatened with destruction by erosion that’s resulted from anthropogenic climate change. But that’s not a basis for a NEPA comment.

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