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Aleutians West Coastal Resource Service Area Volume II Resource Inventory and Analysis Appendix C Coastal Management Plan Mitigation Opportunities in Unalaska State Review Draft Prepared June 2008 by

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Page 1: Aleutians West Coastal Resource Service Area Volume II · 2008-07-14 · Aleutians West Coastal Resource Service Area, Volume II-Appendix C, Mitigation Opportunities in Unalaska June

Aleutians West Coastal Resource Service Area

Volume II Resource Inventory and Analysis

Appendix C

Coastal Management Plan

Mitigation Opportunities in Unalaska

State Review Draft Prepared June 2008 by

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V. II - iii

Aleutians West Coastal Resource Service Area

Coastal Management Plan Volume II - Appendix C

Mitigation Opportunities in Unalaska

CRSA Board Members

Frank Kelty, Chairman Unalaska

Dave Boisseau, Vice-chairman Unalaska

Tammy Peterson Unalaska

Hal Gray Unalaska

Greg Peters Unalaska

Agrafina Kerr Nikolski

Leonty Lokanin Atka

Program Director Karol Kolehmainen

PO Box 1074 Palmer, AK 99645

State Review Draft

Prepared June 2008

by

of

This report is funded by the Alaska Coastal ManagementProgram, Department of Natural Resources, pursuant toNational Oceanic and Atmospheric Administration Award No.NA07NOS4190084. The preparation of this report is fundedby a grant from the National Oceanic and AtmosphericAdministration, and administered by the Alaska Department

of Natural Resources, Division of Coastal and Ocean Management (DCOM), and the Department Commerce, Community and Economic Development (DCCED), Division of Community and Regional Affairs. The views expressed herein are those of the author(s) and do not necessarily reflect the views of the NOAA or any of its sub-agencies.

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RESOLUTION NO. 2008-01 A RESOLUTION OF THE ALEUTIANS WEST COASTAL RESOURCE SERVICE AREA (CRSA) BOARD OF DIRECTORS SUPPORTING THE ALEUTIANS WEST CRSA COASTAL MANAGEMENT PLAN MINOR AMENDMENT: MITIGATION OPPORTUNITIES IN UNALASKA VOLUME II, APPENDIX C, APRIL 2008. WHEREAS, the Aleutians West CRSA is a designated coastal district under the Alaska Coastal Management Program and provides coastal management planning and implementation in the western Aleutian area including the City of Unalaska, and WHEREAS, the Aleutians West CRSA received enhancement grant funding to complete an amendment to their coastal management plan to incorporate Mitigation Opportunities in Unalaska as an appendix to the plan, and WHEREAS, the Aleutians West CRSA interviewed community members, held public meetings, provided a draft document with a public comment period, and held a public hearing on May 15, 2008 to identify and refine worthy mitigation projects, and WHEREAS, the Aleutians West CRSA Board is satisfied that the plan amendment will encourage completion of pre-approved projects that will be of benefit to the community and result in streamlined consistency reviews for the state and the applicant, and NOW, THEREFORE BE IT RESOLVED that the Aleutians West CRSA Board of Directors supports the Aleutians West CRSA Coastal Management Plan Minor Amendment: Mitigation Opportunities In Unalaska Volume II, Appendix C, April 2008. PASSED AND APPROVED BY THE Aleutians West CRSA Board of Directors on this 19th day of June 2008. IN WITNESS THERETO: _______________________ Frank Kelty, Board Chair ATTEST: _______________________ Hal Gray, Secretary/Treasurer

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CITY OF UNALASKA UNALASKA, ALASKA

RESOLUTION NO. 2008-33

A RESOLUTION OF THE UNALASKA CITY COUNCIL IN SUPPORT OF ALEUTIANS WEST COASTAL RESOURCE SERVICE AREA (AWCRSA) COASTAL MANAGEMENT PLAN MINOR AMENDMENT: MITIGATION OPPORTUNITIES IN UNALASKA VOLUME II, APPENDIX C, APRIL 2008.

WHEREAS, The Aleutians West Coastal Resource Service Area ("CRSA") is a designated coastal district under the Alaska Coastal Management Program ("ACMP") whose boundaries include the City of Unalaska; and

WHEREAS, The City of Unalaska is a first class municipality, exercising Title 29 powers through local zoning and other controls on land uses within city limits; and

WHEREAS, in 1999, the CRSA and the City of Unalaska signed a Memorandum of Agreement for the implementation of the Coastal Management Plan that included Unalaska and Amaknak Island; and

WHEREAS, the Memorandum of Agreement outlines the necessity for the Coastal Management Plan and Title 8, Unalaska Code of Ordinances Planning and Land Use Development to be consistent; and

WHEREAS, The Planning Commission has determined the proposed mitigation plan is consistent with Title 8, UCO Planning and Land Use Development; and

WHEREAS, the Planning recommended support for the Aleutians West Coastal Resource Service Area (AWCRSA) Coastal Management Plan: Mitigation Opportunities In Unalaska Final Plan Amendment Volume 11, Appendix C, April 2008 to the City of Unalaska City Council by Resolution 2008-15; and

NOW THEREFORE BE IT RESOLVED that the Unalaska City Council supports Aleutians West Coastal Resource Service Area (AWCRSA) Coastal Management Plan Minor Amendment: Mitigation Opportunities in Unalaska Volume II, Appendix A, April 2008.

PASSED AND APP.R?~ED BY A DUJCONSTITUTED QUORUM OF THE UNALASKA CITY COUNCIL THIS /07 1 \ DAY OF UN- 2008.

ATTEST:

Aun~ CITY CLERK

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Table of Contents Table of Contents....................................................................................................................... C-i List of Figures ........................................................................................................................... C-ii List of Tables.............................................................................................................................C-iii List of Maps...............................................................................................................................C-iii Acknowledgements................................................................................................................... C-v 1.0 Introduction ......................................................................................................................... C-1 1.1 Background ........................................................................................................... C-2 1.2 Methodology............................................................................................................ C-4 1.3 Purpose ..................................................................................................................C-4 2.0 Mitigation Opportunities Identified....................................................................................... C-7 2.1 Coastal Resources, Uses and Activities ................................................................. C-7 2.2 Categorization of Mitigation Opportunities .............................................................. C-7 3.0 Mitigation Opportunities Evaluated .................................................................................. C-11 3.1 Coastal Development Mitigation Opportunities .................................................... C-11

Project 1. Wetland Preservation – Unalaska Lake Wetlands/Riparian .... C-11 Project 2. Wetland Preservation - Captains Bay/Shaishnikof River ....... C- 13 Project 3. Wetland Preservation - South Channel Iliuliuk Harbor ............. C-14 Project 4. Wetland Preservation – Other Opportunties ............................ C-15 Project 5. Iliuliuk Lake Restoration .......................................................... C-15 Project 6. Iliuliuk River Restoration........................................................... C-17 Project 7. Unalaska Lake Restoration ...................................................... C-19 Project 8. Bird Habitat Enhancement/Lake Ilulaq..................................... C-20 Project 9. Kelp Bed Enhancement............................................................ C-21 Project 10. Red King Crab Habitat Enhancement ...................................... C-22 Project 11. Small Estuary Enhancement/Captains Bay.............................. C-23 Project 12. Artificial Benthic Reefs - Fish Habitat ....................................... C-25 Project 13. Fish Passage Restoration - Morris Cove.................................. C-25 Project 14. Fish Passage Maintenance - All Area Streams........................ C-29 Project 15. Nearshore/Offshore Habitat - Derelict Fishing Gear Removal C-31 Project 16. Nearshore Habitat Enhancement - Bird Resting Reefs............ C-31 Project 17. Habitat/Biomass Enhancement ............................................... C-32 Project 18. Summer Bay Salmon Habitat Restoration................................ C-32 Project 19. Areawide Stormwater Run-off Control...................................... C-34 Project 20. Beach Stabalization and Re-vegetation - Areawide ................. C-34 Project 21. Areawide Educational Signage ................................................ C-35 Project 22. Derelict Vessel Removal - Captains Bay.................................. C-37 Project 23. Derelict Vessel Removal - End of Airport runway .................... C-38 Project 24. Tanaxtagax, Amaknak Spit Site ............................................... C-39 Project 25. Nearshore/intertidal Species Surveys ..................................... C-40 Project 26. Manson Saltery Restoration and Access ............................... C-41

3.2 Utility and Transportation Mitigation Opportunities................................................ C-42

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Project 27. Erosion Control and Re-vegetation - Broad Bay ..................... C-42 Project 28. Erosion Control and re-vegetation - Nateekin Bay ................... C-43

3.3 Habitats Mitigation Opportunities .......................................................................... C-44 Project 29. Areawide Invasive Species Control - Vegetation ..................... C-44 Project 30. Areawide Invasive Species Control - Rats ............................... C-44

3.4 Oil Spill Mitigation Opportunities ........................................................................... C-44 Project 31. Wildlife Cleaning Equipment .................................................... C-44

3.5 Out-of Kind Mitigation Opportunities ..................................................................... C-45 Project 32. Solid Waste Recycling.............................................................. C-45 Project 33. Beach and Creek Cleanup Program ........................................ C-46

4.0 Summary and Conclusions .............................................................................................. C-49 5.0 References and Bibliography............................................................................................ C-51

List of Figures Figure 1. Wetlands at head of Unalaska Lake, November 29, 2007 .................................... C-12 Figure 2. Wetlands at head of Unalaska Lake from Dutton Rd. May 12, 2008 .................. C-12 Figure 3. Shaishnikof River Wetland. May 13, 2008 ........................................................... C-14 Figure 4. South Channel Iliuluk Harbor Wetland. May 13, 2008 ......................................... C-14 Figure 5. Iliuliuk Lake facing west from Dutton Road. November 29, 2007.......................... C-16 Figure 6. Iliuliuk Lake facing west from Dutton Road. May 12, 2008 .................................. C-16 Figure 7. Upper Iliuliuk River. May 14, 2008. ....................................................................... C-17 Figure 8. Middle Iliuliuk River - erosion and trampling. May 14, 2008................................. C-18 Figure 9. Middle Iliuliuk River facing upstream. May 13, 2008 ............................................. C-18 Figure 10. Lower Iliuliuk River facing downstream toward mouth. May 13, 2008 .................. C-19 Figure 11. Unalaska Lake Restoration. May 14, 2008........................................................... C-20 Figure 12. Lake Ilulaq. May 12, 2008 ..................................................................................... C-21 Figure 13. Kelp Beds. May 14, 2008 ..................................................................................... C-22 Figure 14. Morris Cove Lake and outlet stream looking east. May 13, 2008.......................... C-26 Figure 15. Morris Cove Lake and outlet stream looking west. May 13, 2008 ........................ C-27 Figure 16. Outlet stream at mouth. May 13, 2008 ................................................................. C-27 Figure 17. Morris Creek historical streambed. May 13, 2008 ................................................ C-28 Figure 18. Riparian trampling and debris. May 13, 2008 ....................................................... C-28 Figure 19. Pyramid Creek facing upstream. November 29, 2007 .......................................... C-30 Figure 20. Pyramid Creek facing downstream. November 29, 2007...................................... C-30 Figure 21. Example of a natural reef. May 4, 2005 ................................................................ C-32 Figure 22. Summer Bay. May 13, 2008 ................................................................................ C-33 Figure 23. Summer Bay Lake. May 13, 2008 ........................................................................ C-33 Figure 24. Summer Bay Creek outlet. May 13, 2008 ............................................................. C-33 Figure 25. Front Street vegetated back beach berm. May 13, 2008 ...................................... C-35 Figure 26. Example of potential location for interpretive signage, Airport Rd. May 13, 2008 C-36 Figure 27. Sample Interpretive Sign - Summer Bay Archeological Site. May 13, 20008....... C-37 Figure 28. Derelict Vessel, Captains Bay. May 13, 2008........................................................ C-37 Figure 29. Derelict Vessel, Captains Bay. May 13, 2008 ....................................................... C-38 Figure 30. Derelict Vessel, Airport Runway. May 14, 2008 ................................................... C-38 Figure 31. Tanaxtagax Interpretive Sign. May 14, 2008 ........................................................ C-39 Figure 32. Manson Saltery. May 15, 2008 ............................................................................. C-41 Figure 33. Broad Bay. May 13, 2008 ..................................................................................... C-42

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Figure 34. Nateekin Bay. May 13, 2008 ................................................................................ C-43 Figure 35. Unalaska Landfill. May 13, 2008 .......................................................................... C-45 Figure 36. Beach Debris, Airport Beach, March 23, 2005. ..................................................... C-46 Figure 37. Trash, Lower Iliuliuk River Riparian Area, November 29, 2007. ........................... C-47

List of Tables Table 1. Mitigation Opportunities by Regulatory Requirement.............................................. C-8

List of Maps

Map 1. Index to Mitigation Project Locations..................................................................... C-11 Map 2. Captains Bay/Shaishnikof River Wetland Preservation location ........................... C-13 Map 3. South Channel Iliuliuk Harbor Wetland Preservation location .............................. C-14 Map 4. Captains Bay Small Estuary locations................................................................... C-24 Map 5. Anadromous Stream locations .............................................................................. C-29 Map 6. Tanaxtagax, Amaknak Spit Site (UNL-00055) ...................................................... C-40

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Acknowledgements In 2004 LaRoche+Associates was hired to revise the AWCRSA coastal management plan to conform to the new laws that govern the Alaska Coastal Management Program. The revised plan went into effect February 11, 2007. Given the limited timeframe for those mandatory revisions, developing a list of pre-identified mitigation projects such as this was not possible. LaRoche+Associates would like to recognize the AWCRSA Board and Program Director Karol Kolehmainen for their willingness to pursue this minor amendment to enhance the AWCRSA Coastal Management Plan. In addition, the AWCRSA Board and Program Director provided significant information and data, along with a careful review of all materials. The AWCRSA Board and staff and LaRoche+Associates would also like to thank the community of Unalaska for their contribution and support and for their hospitality during visits to the community. Thanks to the City of Unalaska Planning staff for their contribution and volunteer hours. Thanks to the State of Alaska Department of Natural Resources, Division of Coastal and Ocean Management and Department of Community and Economic Development staffs for their guidance and assistance. Finally, LaRoche+Associates would like to thank the City of Unalaska and its consultant TNH for preparing the Evaluation of Mitigation Opportunities in Unalaska, Final Report March 1996, which served as the starting point for this project.

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1.0 Introduction

This report presents the results of a study conducted by the Aleutians West Coastal Resource Service Area (AWCRSA) to identify and evaluate mitigation opportunities that could be implemented as compensation for future development activities within the coastal boundaries of Unalaska. The coastal boundaries of Unalaska have not previously been distinguished from the coastal boundary of the entire AWCRSA, which extends from Unalga Pass on the east to Attu on the west1. However, for all practical purposes, it encompasses all land and water areas of Unalaska and Amaknak Islands to the three-mile territorial limit. The use of the term “mitigation” in this study is the same as that provided in Alaska Administrative Code.

11 AAC 112.900. Sequencing process to avoid, minimize, or mitigate. (a) As used in this chapter and for purposes of district enforceable policies developed under 11 AAC 114, “avoid, minimize, or mitigate” means a sequencing process of

(1) avoiding adverse impacts to the maximum extent practicable; (2) where avoidance is not practicable, minimizing adverse impacts to the maximum extent practicable; or (3) if neither avoidance nor minimization is practicable, conducting mitigation to the extent appropriate and

practicable; for purposes of this paragraph, “mitigation” means (A) on-site rehabilitation of project impacts to affected coastal resources during or at the end of the life of

the project; or (B) to the extent on-site rehabilitation of project impacts is not practicable, substituting, if practicable,

rehabilitation of or an improvement to affected coastal resources within the district, either on-site or off-site, for a coastal resource that is unavoidably impacted.

(b) For a project that requires a federal authorization identified under 11 AAC 110.400, the coordinating agency shall consult with the authorizing federal agency during that federal agency’s authorization review process to determine whether the mitigation requirements proposed by the federal agency for that federal authorization would satisfy the mitigation requirements of (a)(3) of this section. If the coordinating agency determines that the mitigation requirements proposed by the federal agency would not satisfy the mitigation requirements of (a)(3) of this section, the coordinating agency shall require appropriate mitigation in accordance with (a)(3) of this section. (c) For purposes of (a)(3) of this section, a determination of practicability includes the consideration of the following factors, as applicable: (1) the magnitude of the functional values lost by the impacted coastal resources;

(2) the likelihood that the mitigation measure or improvement will succeed in actually rehabilitating the impacted coastal resources; and

(3) the correlation between the functional values lost by the coastal resources impacted and the proposed mitigation measure or improvement.

(d) To the extent feasible and not otherwise addressed by state or federal law, any requirements imposed under (a)(3) of this section for mitigation through on-site or off-site rehabilitation of project impacts shall be established by the coordinating agency at the time of the project’s consistency review under 11 AAC 110. (e) In applying the mitigation process described in (a)(3) of this section, unless required by a federal agency issuing an authorization identified under 11 AAC 110.400 for the project, the coordinating agency may not require (1) that no net loss of impacted coastal resources occur; or (2) monetary compensation. (Eff. 7/1/2004, Register 170; am 10/29/2004, Register 172) Authority: AS 46.39.010 AS 46.39.040 AS 46.40.040 AS 46.39.030 AS 46.40.010

1 For a more detailed explanation of the coastal boundary refer to AWCRSA Coastal Management Plan, Volume III, Chapter 2, page 31.

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This report contains summaries of possible mitigation opportunities that were identified in 2008. There may be additional opportunities that exist that were not identified, and future opportunities may arise. Although this report provides a basis for selecting mitigation projects, it is not intended nor should it be construed as a complete and final list of all potential mitigation opportunities in the Unalaska area. It must further be noted that the possible mitigation opportunities are just that – possible opportunities. They are neither required nor binding until such time that that they are adopted, modified or otherwise as part of a state or federal authorization that may be required for a particular development project.

1.1 Background In 1996, the City of Unalaska contracted a report titled Evaluation of Mitigation Opportunities in Unalaska to provide a basis for mitigation discussions for consistency reviews. The pre-identification and evaluation of designated worthy projects that could be implemented to compensate for future development activities in coastal areas was useful in helping to streamline consistency reviews. Because the report was dated, many projects had been completed while others needed to be reevaluated to determine if they were still viable. There were also other new mitigation project ideas that needed to be considered in an updated study. The amended AWCRSA Coastal Management plan no longer contains enforceable policies with a mitigation component. However, several state standards including coastal development (11 AAC 112.200 (c))2, utility routes and facilities (11 AAC 112.240 (b)), transportation routes and facilities (11 AAC 112.280), and habitat (11 AAC 112.300 (b)) have mitigation components. The AWCRSA has been encouraged to participate in state consistency reviews though use of the state standards. The AWCRSA will be able to encourage implementation of pre-approved projects that will be of benefit to the community with this updated Evaluation study. The incorporation of this Evaluation study via an amendment to the AWCRSA CMP is intended to aid and assist state reviewers and project applicants through identification of potential mitigation projects. The intent is to streamline consistency reviews of future development activities while ensuring that local knowledge and preferences are considered when mitigation is required.

11 AAC 112.200. Coastal development. (c) The placement of structures and the discharge of dredged or fill material into coastal water must, at a minimum, comply with the standards contained in 33 C.F.R. Parts 320 - 323, revised as of July 1, 2003. (Eff. 7/1/2004, Register 170) Authority: AS 46.39.010 AS 46.39.040 AS 46.40.040 AS 46.39.030 AS 46.40.010

2 Mitigation requirements are contained in 33 C.F.R. Parts 320.4 (r) and in 40 CFR 230.70 through 40 CFR 230.77 (Subpart H of the 404(b)(1) Guidelines), which are cross-referenced in 33 C.F.R. Parts 320.1. Thus by reference these mitigation requirements are a component of 11 AAC 112.200(c).

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11 AAC 112.240. Utility routes and facilities. (b) Utility routes and facilities along the coast must avoid, minimize, or mitigate (1) alterations in surface and ground water drainage patterns; (2) disruption in known or reasonably foreseeable wildlife transit; (3) blockage of existing or traditional access. (Eff. 7/1/2004, Register 170) Authority: AS 46.39.010 AS 46.39.040 AS 46.40.040 AS 46.39.030 AS 46.40.010 11 AAC 112.280. Transportation routes and facilities. Transportation routes and facilities must avoid, minimize, or mitigate (1) alterations in surface and ground water drainage patterns; (2) disruption in known or reasonably foreseeable wildlife transit; and (3) blockage of existing or traditional access. (Eff. 7/1/2004, Register 170) Authority: AS 46.39.010 AS 46.39.040 AS 46.40.040 AS 46.39.030 AS 46.40.010

11 AAC 112.300. Habitats. (b) The following standards apply to the management of the habitats identified in (a) of this section:

(1) offshore areas must be managed to avoid, minimize, or mitigate significant adverse impacts to competing uses such as commercial, recreational, or subsistence fishing, to the extent that those uses are determined to be in competition with the proposed use;

(2) estuaries must be managed to avoid, minimize, or mitigate significant adverse impacts to (A) adequate water flow and natural water circulation patterns; and

(B) competing uses such as commercial, recreational, or subsistence fishing, to the extent that those uses are determined to be in competition with the proposed use;

(3) wetlands must be managed to avoid, minimize, or mitigate significant adverse impacts to water flow and natural drainage patterns;

(4) tideflats must be managed to avoid, minimize, or mitigate significant adverse impacts to (A) water flow and natural drainage patterns; and

(B) competing uses such as commercial, recreational, or subsistence uses, to the extent that those uses are determined to be in competition with the proposed use;

(5) rocky islands and sea cliffs must be managed to (A) avoid, minimize, or mitigate significant adverse impacts to habitat used by coastal species; and

(B) avoid the introduction of competing or destructive species and predators; (6) barrier islands and lagoons must be managed to avoid, minimize, or mitigate significant adverse impacts (A) to flows of sediments and water;

(B) from the alteration or redirection of wave energy or marine currents that would lead to the filling in of lagoons or the erosion of barrier islands; and

(7) exposed high-energy coasts must be managed to avoid, minimize, or mitigate significant adverse impacts (A) to the mix and transport of sediments; and

(B) from redirection of transport processes and wave energy; (8) rivers, streams, and lakes must be managed to avoid, minimize, or mitigate significant adverse impacts to

(A) natural water flow; (B) active floodplains; and (C) natural vegetation within riparian management areas; and (9) important habitat

(A) designated under 11 AAC 114.250(h) must be managed for the special productivity of the habitat in accordance with district enforceable policies adopted under 11 AAC 114.270(g); or

(B) identified under (c)(1)(B) or (C) of this section must be managed to avoid, minimize, or mitigate significant adverse impacts to the special productivity of the habitat.

(Eff. 7/1/2004, Register 170; am 10/29/2004, Register 172; am 6/25/2005, Register 174) Authority: AS 46.39.010 AS 46.39.040 AS 46.40.040 AS 46.39.030 AS 46.40.010

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1.2 Methodology The AWCRSA partnered with the City of Unalaska to produce this study. Following a review of City of Unalaska’s 1996 report3, the consultant and Program Director traveled to Unalaska to conduct interviews with City representatives, native corporation representatives, and members of the public to obtain preliminary information. State and federal agencies were solicited for mitigation project ideas. A project kick-off meeting was held as part of the AWCRSA regular meeting schedule November 29, 2007 to obtain public input. A presentation was also made to the Unalaska City Council November 27, 2007. The analysis in this report includes the goal of each potential mitigation project, the project location and field photographs, a project description, the objectives of the project, and identification of any potential implementation issues and feasibility. Following advice provided by City staff, the project descriptions and analysis are intentionally brief. It was suggested that indepth study and mitigation project design is best carried-out at the time of project planning, when the scope of the development and thus the impacts are known.

1.3 Purpose The purpose of this study is to identify viable mitigation opportunitites which would satisfy regulatory requirements4 for compensation of development impacts such as: (1) alterations in surface and ground water drainage patterns; (2) disruption in known or reasonably foreseeable wildlife transit; (3) blockage of existing or traditional access;

(4) adverse impacts to competing uses; (5) adverse impacts to adequate water flow and natural water circulation patterns; (6) adverse impacts to habitat used by coastal species; and the introduction of

competing or destructive species and predators; (7) adverse impacts to the mix and transport of sediments; and from redirection of

transport processes and wave energy; (8) adverse impacts to natural riverine water flow, active floodplains and natural

vegetation within riparian management areas; and (9) adverse impacts to the special productivity of important habitiats. It is hoped that the pre-identification and evaluation of acceptable mitigation activities will greatly improve coastal management in regard to future development activities by streamlining project permitting and at the same time ensuring that local priorities are incorporated into state and federal permitting. For this study, a general assumption has been made that adequate measures will be taken to avoid or minimize potential impacts caused by a particular development project as is required by 11 AAC 112.200 (c), 11 AAC 112.240 (b), 11 AAC 112.280, and 11 AAC 112.300 (b).

3 Tryck Nyman Hayes, Inc. (TNH). 1996. Evaluation of Mitigation Opportunities in Unalaska Final Report. Prepared for the City of Unalaska, Public Works. 4 See text boxes on preceding pages for regulatory language.

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Therefore, this study focuses on mitigation that is required to be undertaken to compensate for impacts that were found to be unavoidable. Throughout the interview process, the issue of appropriate mitigation for impacts from recent oils spills was mentioned. While not required to comply with the Alaska Coastal Management Program or the AWCRSA Coastal Management Plan, it is also hoped that the agencies responsible for determining mitigation that may be required as a result of oil spills will consider the projects listed herein.

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2.0 Mitigation Opportunities Identified

2.1 Coastal Resources, Uses and Activities The identification of mitigation opportunities necessarily considers the resources that will potentially be impacted by the anticipated use or development. Coastal Resources and Environmental Sensitivity Index (ESI) maps were developed for the coastal zone of the Aleutians West Coastal Resource Service Area (AWCRSA) for the 2007 update to the AWCRSA Coastal Management Plan. These maps include information for three main components: shoreline habitats; sensitive biological resources; and human-use resources. The intertidal habitats of the AWCRSA were mapped using three systems: the ESI shoreline ranking scheme, the General Shoreline Type ranking scheme, and coastal habitats as defined by Alaskan Coastal Management Program (ACMP).5 For Unalaska and Amaknak Islands, the reader is specifically referred to the Coastal Resource Inventory Maps, Aleutians West-1 and Aleutians West-2. For information concerning coastal development, utility and transportation uses and activities the reader is directed to the Unalaska section of the AWCRSA Coastal Management Plan, Volume II.6

2.2 Categorization of Mitigation Opportunities For ease of use during state consistency reviews, the mitigation opportunities are categorized by the state standard that would most likely require the mitigation. For example, most developments involve either the placement of structures or fill in coastal waters, thus invoking the coastal development standard. The mitigation requirements for the placement of structures or fill also tend to be all-encompassing whereas the management considerations for transportation and utilities are narrowly constrained to alterations in surface and ground water drainage patterns, disruption in known or reasonably foreseeable wildlife transit, and blockage of existing or traditional access. For this reason almost all projects are listed under coastal development. It is also true that a development activity may have impacts to more than one coastal resource or use and would thus invoke more than one of the state standards. For this reason a cross-reference table is provided in this chapter (Table 1). Table 1 lists all of the potential mitigation opportunities in this study in the far left column. The column headings across the top contain either a state standard, or oil spill and “out-of-kind”. A simple check indicates that the mitigation opportunity goals and objectives match the regulatory requirements. A key follows the table which lists the state management considerations for utilities, transportation and habitats. Because utilities, transportation and habitats management considerations are not as all-

5 The approaches are outlined in detail in the AWCRSA Coastal Management Plan, Volume I Coastal Resources Inventory and Environmental Sensitivity Maps, pp. 1-6. 6 AWCRSA Coastal Management Plan, Volume II, Coastal Resources Inventory and Analysis, pp 90-103.

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encompassing as the coastal development mitigation requirements, a number indicates which objective(s) of the mitigation opportunity corresponds to the regulatory requirement. For example, if a utility project along the coast (which would invoke 11 AAC 112.240. utility routes and facilities) adversely impacts bird transit, then mitigation opportunity #10 could be an appropriate choice. To further the example using mitigation opportunity #10, it is also possible that a development involving the placement of structures and/or the discharge of dredged or fill material into coastal water could adversely impact bird habitat and again, #10 could be an appropriate mitigation choice. Finally, although not required to comply with the Alaska Coastal Management Program or the AWCRSA Coastal Management Plan, an oil spill could adversely impact bird habitat and again, #10 could be an appropriate choice. In accordance with the regulatory preference for “in-kind” mitigation (e.g. estuarine wetland restoration for estuarine wetland loss) the identification of mitigation opportunities, for the most part, assumes that the required mitigation would be “in-kind”. There are a few mitigation opportunities that were identified during the course of this study that do not directly correlate to the reasonably foreseeable “in-kind” mitigation requirements. These are denoted as “out-of-kind” in Table 1.

Table 1. Mitigation Opportunities by Regulatory Requirement # Name Coastal

Develop-ment

Utility & Transpor-tation

Habitat Oil Spill Out-of-kind

1 Wetland Preservation – Unalaska Lake Wetlands/Riparian

1

6,10

2 Wetland Preservation - Captains Bay/Shaishnikof River

1

6,10

3 Wetland Preservation - South Channel Iliuliuk Harbor 1 6

4 Wetland Preservation – Other 1 6 5 Iliuliuk Lake Restoration 1 6,10 6 Iliuliuk River Restoration 1,3 10 7 Unalaska Lake Restoration 1,3 10 8 Bird Habitat

Enhancement/Lake Ilulaq 2 9 Kelp Bed Enhancement 10 Red king crab Habitat

Enhancement 4,5 11 Small Estuary

Enhancement/Captains Bay 5 12 Artificial Benthic Reefs - Fish

Habitat 4,5 13 Fish Passage Restoration -

Morris Cove 10 14 Fish Passage Maintenance -

All Area Streams 10 15 Derelict Fishing Gear Removal 4

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# Name Coastal

Develop-ment

Utility & Transpor-tation

Habitat Oil Spill Out-of-kind

16 Nearshore Habitat Enhancement - Bird Resting reefs 2 4,5,7,8

17 Habitat Enhancement - increase surface area on sheet pile

18 Summers Bay Salmon Habitat Restoration 1 10

19 Areawide stormwater run-off control 1

20 Beach Stabalization/Re-vegetation - areawide 1,3 9

21 Areawide Educational Signage 3

5,6,7,8,9,10

22 Derelict Vessel Removal – Captains Bay

23 Derelict Vessel Removal - end of Airport runway

24 Tanaxtagax, Amaknak Spit Site 25 Nearshore/intertidal species

surveys 26 Manson Saltery Restoration

and Access 3 27 Erosion control/re-vegetation -

Broad Bay 1,3 10 28 Erosion control/re-vegetation -

Nateekin Bay 1,3 10 29 Areawide Invasive species

control - vegetation 8,10 30 Areawide Invasive species

control - rats 8 31 Wildlife Cleaning Equipment 32 Solid Waste Recycling 33 Beach and Creek Cleanup

Program Key (1) transportation & utilities - alterations in surface and ground water drainage patterns

(2) transportation & utilities - disruption in known or reasonably foreseeable wildlife transit (3) transportation & utilities - blockage of existing or traditional access (4) offshore - impacts to competing uses such as commercial, recreational, or subsistence fishing (5) estuaries - impacts to adequate water flow and natural water circulation patterns; and competing

uses such as commercial, recreational, or subsistence fishing (6) wetlands - impacts to water flow and natural drainage patterns (7) tideflats - impacts to water flow and natural drainage patterns; and competing uses such as

commercial, recreational, or subsistence uses (8) rocky islands and sea cliffs - impacts to habitat used by coastal species; and avoid the introduction

of competing or destructive species and predators (9) exposed high-energy coasts - impacts to the mix and transport of sediments; and from redirection

of transport processes and wave energy (10) rivers, streams, and lakes - impacts to natural water flow; active floodplains; and natural

vegetation within riparian management areas

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3.0 Evaluation of Project Alternatives

Map 1. Index to Mitigation Project Locations.

3.1 Coastal Development Mitigation Opportunities Project 1. Wetland Preservation – Unalaska Lake Wetlands/Riparian Goal: preservation of freshwater wetlands and other aquatic resources, including adjacent

riparian areas. Description This area includes the land adjacent to Unalaska Lake, the Iliuliuk River, and Unalaska Creek. The habitats covered by this area include riverine and wetland areas that support wildlife and are important for spawning and rearing of anadromous fish.

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Preservation of wetlands and associated riparian areas through land acquisition and other methods are potential mitigation projects. This category of mitigation includes:

• Purchase of land or conservation easements by a project applicant, • Zoning restriction by a public entity; and • Other non-regulatory mechanisms for habitat protection such as education &

voluntary agreements

Objectives: variable depending on the specific wetland development for which mitigation is required. Implementation Issues/FeasibilityAn evaluation of the lacustrine and riverine wetland functions that are impacted and for which compensation will be required must be preformed. The feasibility of site preservation would vary considerably with the mechanism employed which varies with the level of protection afforded by the particular mechanism. In theory, the cost of land acquisition depends on the size of the site and the assessed value of the land.

Figure 1. Wetlands at head of Unalaska Lake looking northwest. November 29, 2007.

Figure 2. Wetlands at head of Unalaska Lake from Dutton Rd. May 12, 2008.

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Project 2. Wetland Preservation - Captains Bay/Shaishnikof River Goal: preservation of estuarine and riverine wetlands and other aquatic resources, including

adjacent riparian areas. Description This area, particularly the estuarine area at the south end, is important for marine organisms. Preservation of wetlands and associated riparian areas through land acquisition and other methods as described above (project 1) are potential mitigation projects. Objectives: variable depending on the specific wetland development for which mitigation is required. Implementation Issues/FeasibilityAn evaluation of the estuarine and riverine wetland functions that are impacted and for which compensation will be required must be preformed. The feasibility of site preservation would vary considerably with the mechanism employed which varies with the level of protection afforded by the particular mechanism. In theory, the cost of land acquisition depends on the size of the site and the assessed value of the land.

Map 2. Captains Bay/Shaishnikof River Wetland Preservation location

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Figure 3. Shaishnikof River Wetland. May 13, 2008.

Project 3. Wetland Preservation - South Channel Iliuliuk Harbor Goal: preservation of wetlands and other aquatic resources, including adjacent riparian areas. Description This area is important for marine organisms and is also an area of potential further development. A new bridge will be completed in 2008. The Little South America (LSA) Boat Harbor construction was expected to begin in 2008, but now may be delayed. Stellar Eider resting reefs will be constructed as mitigation for the LSA Boat Harbor. A large portion of the tidelands has been transferred to the City of Unalaska. Projects that restore and enhance functions that support subsistence salmon and crab, and preserve riparian areas through purchased conservation easements are a possibility in the area. Objectives: variable depending on the specific wetland development for which mitigation is required. Implementation Issues/FeasibilityAn evaluation of the wetland functions that are impacted and for which compensation will be required must be preformed. Since the tidelands are zoned developable and the adjacent uplands are zoned marine dependent/industrial, the likely mechanisms are though zoning overlays.

Figure 4. South Channel Iliuluk Harbor Wetland. May 13, 2008.

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Map 3. South Channel Iliuliuk Harbor Wetland Preservation location

Project 4. Wetland Preservation – Other Opportunities Goal: preservation of wetlands and other aquatic resources, including adjacent riparian areas. Description The AWCRSA Coastal Management Plan Volume 1 identifies many wetland areas suitable for preservation. These areas are depicted in red on the Coastal Resource Inventory Maps, Supplemental May 2003, Aleutians West-1 and Aleutians West-2. Areas suitable for wetland preservation include, but are not limited to, the head of Kashega Bay, the southwest arm of Makushin Bay, Broad Bay, Nateekin Bay, Summers Bay, Morris Cove, and Usof Bay. Objectives: variable depending on the specific wetland development for which mitigation is required. Implementation Issues/FeasibilityAn evaluation of the wetland functions that are impacted and for which compensation will be required must be preformed. The feasibility of site preservation would vary considerably with the mechanism employed which varies with the level of protection afforded by the particular mechanism. Ownership and zoning is variable and thus the appropriate mechanism will vary. Project 5. Iliuliuk Lake Restoration Goal: restore and enhance lacustrine wetland functions that were lost by isolation from

Unalaska Lake. Description

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Two sections of Unalaska Lake that where isolated by the development of Broadway Road are potential sites for mitigation. The larger section is known as Iliuliuk Lake. New culverts were installed in recent years improving both circulation and fish passage. However flooding was a significant problem during a 2007 storm event. This project would involve restoring and enhancing the wetland functions and values by correcting problems with water circulation, drainage and adding riparian cover.

Figure 5. Iliuliuk Lake facing west from Dutton Road. November 29, 2007.

Figure 6. Iliuliuk Lake facing west from Dutton Road. May 12, 2008.

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Objectives: increase water circulation, shoreline area and riparian cover; restrict access to portions of lake; remove trash and debris; preserve the site.

Implementation Issues/FeasibilityImplementation of this project would require that access to the land surrounding the lake be obtained through an arrangement with the landowners or one of the formal land acquisition or other preservation mechanisms previously described. The type of acquisition or preservation mechanism will have significant impact on feasibility. Implementation would require coordination with the Army Corps of Engineers because it involves alteration of shorelines, placement of fill, and modification of drainage. Construction of this project would not require any special equipment, skills or expertise that is not locally available. Project 6. Iliuliuk River Restoration Goal: restore and enhance the riverine and riparian functions (fish spawning habitat, erosion

control, flood retention, recreation/subsistence use) that have been lost over time by incremental development activity and heavy use.

Figure 7 Upper Iliuliuk River. May 14, 2008.

Description This project encompasses the length of the Illiuliuk River from the outlet of Unalaska Lake to its discharge into Iliuliuk Harbor, spanning a linear distance of approximately 3,000 feet. This is an important anadromous fish system in the Unalaska Bay area, and due to its location within the village of Unalaska is of high value for recreational and subsistence users (ADFG Anadromous Stream No. 302-31-10500).

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Figure 8. Middle Iliuliuk River - erosion and trampling. May 14, 2008.

Figure 9. Middle Iliuliuk River facing upstream. May 13, 2008.

Stormwater run-off controls (paving, storm drain, oil separators) have been installed to help address problems with sedimentation, however many opportunities still exist. The project would involve restoring and enhancing the wetland and riparian functions of the site by correcting problems with shoreline trampling, erosion, and sedimentation. Public access that is designed to control and manage access points, such as a constructed trail or elevated boardwalk, could be incorporated into the project. Objectives: maintain and enhance traditional access while reducing impacts to shoreline

associated with existing skiff docks; stabilize and revegetate the river banks and adjacent uplands; restore river substrates for pink salmon spawning; increase shallow water emergent vegetation.

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Figure 10. Lower Iliuliuk River facing downstream toward mouth. May 13, 2008.

Implementation Issues/Feasibility Depending on the access route that is selected, implementation of this project could require that access to the land along the riverbanks be obtained through an arrangement with the landowners or one of the formal land acquisition or other preservation mechanisms previously described. If access is provided along the base of Haystack Mountain, acquisition would not be necessary as the city of Unalaska owns the land. The type of acquisition or preservation mechanism will have significant impact on feasibility. Implementation would require coordination with the Army Corps of Engineers because it involves alteration of shorelines, placement of fill, and modification of drainage. Many examples of controlled public access with elevated walkways using low impact development techniques such as pin foundations exist in Alaska. The Kenai River Management Plan provides a good example. Project 7. Unalaska Lake Restoration Goal: restore and enhance functions that have been lost (spawning habitat for sockeye) over

time due to sedimentation of the lake’s littoral zones.

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Figure 11. Unalaska Lake Restoration. May 14, 2008.

Description Sedimentation along the east shore and part of the south shore of Unalaska Lake has filled in areas previously used for spawning. The project would include a limiting factors analysis for sockeye salmon production within Unalaska Lake and then implementation of measures to address the limiting factors (e.g. sedimentation control and substrate enhancement). There is also an opportunity to develop a public access trail along one side of the lake where the City owns the land. Objectives: evaluate sockeye spawning and rearing habitat; evaluate feasibility of improving

habitat, including removing sediments; public access trail development; implement a habitat enhancement plan.

Implementation Issues/FeasibilityBecause the City only owns the land on one side of the lake, implementation of this project would require that access to the land surrounding the lake be obtained through an arrangement with the landowners or one of the formal land acquisition or other preservation mechanisms previously described. The type of acquisition or preservation mechanism will have significant impact on feasibility. Implementation would require coordination with the Army Corps of Engineers because it involves alteration of shorelines, placement of fill, and modification of drainage. A formalized restoration and enhancement plan would be required. Project 8. Bird Habitat Enhancement/Lake Ilulaq Goal: enhance habitat values by creating habitat (bird nesting) that did not previously exist. Description Ilulaq Lake is a small lake on the hill above Biorka Drive on Amaknak Island. It has also been known as Chevron Lake and Water Supply Lake. There are no surface water outlets and thus it does not support anadromous fish. However it does provide lacustrine wetland functions of flood attenuation, erosion control and ground water recharge. The site has been identified as a possible location for bird habitat enhancement.

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Figure 12. Lake Ilulaq. May 12, 2008.

Objectives: evaluate bird habitat; evaluate feasibility of improving habitat, including placement

of nesting islets; implement a habitat enhancement plan. Implementation Issues/Feasibility The riparian area is designated open space on the City Zoning maps. Implementation would require coordination with the Army Corps of Engineers because it could involve alteration of shorelines, and placement of fill. A habitat enhancement plan would need to consider reports of the need for bunker-c oil cleanup and WWII ordinance in the lake. Project 9. Kelp Nerocystis luetkeana, Alaria sp., and Laminaria sp. Bed Enhancement Goal: increase the functional value of certain marine intertidal sites by creating kelp beds that

provide habitat for invertebrates, shellfish, finfish and other marine life. Description Many areas in the Unalaska Bay vicinity are suitable for Kelp bed enhancement. Three potential areas that were previously identified for deployment of artificial kelp substrates are Captains Bay, South Channel, and Dutch Harbor, but many others exist and may be more appropriate depending on the need for mitigation. This project would involve placement of artificial and rubble substrates at the appropriate depth for colonization by kelp (primarily Nerocystis luetkeana, Alaria sp., and Laminaria sp.).

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Objectives: identify appropriate sites for deployment of kelp substrates; design and construct kelp substrates; deploy substrates at appropriate sites.

Implementation Issues/FeasibilityImplementation of this project is relatively simple. A formal project plan, including designs and cost estimates would be developed in consultation with resource agencies. The design of kelp substrates would be guided by evaluating substrates at a reference area located in a similar environmental setting. Implementation would require coordination with the Army Corps of Engineers because it involves placement of fill in navigable waters. Use of the tidelands would require permission from the landowner, for the most of Unalaska Bay this would be either the State of Alaska or the City of Unalaska. Construction of this project would not require any special equipment, skills or expertise that is not locally available. Artificial reef material, including quarry rock, is available locally.

Figure 13. Kelp Beds. May 14, 2008.

Project 10. Red King Crab Paralithodes camtschaticus Habitat Enhancement Goal: increase the functional value of certain marine nearshore sites by creating artificial reefs. Description The use of artificial reefs for enhancement of marine populations has received considerable attention in recent years (for examples see Jensen 2002). Such structures may be assembled from a variety of components including natural (logs and rocks), seminatural (concrete blocks, modules, or concreted boulders), and non-natural (tires, coal ash, wrecked ships, junked cars, and derelict oil platforms). Reefs have been constructed for a variety of recreational and

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commercial uses, including fisheries enhancement, scuba diving, aquaculture, habitat restoration, environmental mitigation, resource conservation, and research (Seaman 2002). Generally, production can be improved by use of highly complex structures that provide high levels of structural heterogeneity at appropriate scales. Such structures probably function to reduce mortality during critical life stages by reducing predation, and providing improved foraging opportunities (Bohnsack et al. 1997). Most studies of artificial reefs to date have focused on highly mobile fauna such as reef-associated or pelagic fishes. Those dealing with benthic resources have addressed fouling organisms (Foster et al. 1994), or epibenthic prey species (Jara & Cespedes 1994) of very low motility. Few have studied the use or impacts of artificial structures on commercially significant decapod crustaceans, which are highly motile within limited ranges. Notable exceptions include studies of Florida spiny lobsters Panulirus argus (Herrnkind & Butler 1986, Butler & Herrnkind 1997, Herrnkind et al. 1997a, Herrnkind et al. 1997b). These researchers have demonstrated that habitat availability limits the abundance of juvenile lobsters, and enhancement with appropriate artificial substrates can greatly increase abundance, whereas artificially increasing the abundance of juveniles by seeding is not effective. Such increases occur primarily through settlement rather than by immigration (Herrnkind et al. 1997a). This project would involve placement of artificial reefs at the appropriate depth for red king crab settlement. Structures that provide a greater variety of interstices in a more compact structure are recommended. Such structures might include crushed rock or gravel, or specifically designed man-made substrata. Objectives: identify appropriate sites for the deployment of red crab substrates; design and

construct red crab substrates; deploy substrates. Implementation Issues/FeasibilityImplementation of this project is relatively simple. A formal project plan, including designs and cost estimates would be developed in consultation with resource agencies. The design of red crab substrates would be guided by evaluating substrates at a reference area located in a similar environmental setting. Implementation would require coordination with the Army Corps of Engineers because it involves placement of fill in navigable waters. Use of the tidelands would require permission from the landowner, for the most of Unalaska Bay this would be either the State of Alaska or the City of Unalaska. Construction of this project would not require any special equipment, skills or expertise that is not locally available. Artificial reef material, including quarry rock, is available locally. Project 11. Small Estuary Enhancement/Captains Bay Goal: increase the functional value of an estuarine intertidal site by enlarging and enhancing it

by providing the necessary hydrological control, geometry, bathymetry and substrate for establishment of estuarine conditions, including brackish water habitat and salt marsh vegetation.

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Description This project could be done at small estuaries within the Unalaska area where creeks discharge into marine water ands site conditions are suitable. This project would involve placement of artificial reef structures adjacent to existing small estuarine areas of non-anadromous streams to increase retention of tidal water and thereby enhance the estuarine habitat. Objectives: evaluate coastal engineering and hydrology of the site; create an artificial reef/levee to impound water; create a lagoon area for brackish water to accumulate and promote salt marsh type vegetation; stabilize and revegetate disturbed areas; transplant emergent and submerged salt marsh vegetation into lagoon areas; remove trash and debris from area. Implementation Issues/Feasibility The design of the sites would be guided by evaluating a reference salt marsh located in a similar environmental setting. Implementation would require coordination with the Army Corps of Engineers because it involves modification of shorelines, dredging and placement of fill in navigable waters. Use of the tidelands would require permission from the landowner, for the most of Unalaska Bay this would be either the State of Alaska or the City of Unalaska.

Map 4. Captains Bay Small Estuary Locations

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Project 12. Artificial Benthic Reefs - Fish Habitat Goal: increase the functional value of marine areas by providing substrate for colonization and

cover for fish, eventually resulting in enhanced fish production that could be utilized by recreational, commercial and subsistence fishing interests.

Description Three potential areas for deployment of artificial benthic reefs are Captains Bay, South Channel, and Dutch Harbor. This project would create a new type of habitat where either none or a different type previously existed. Objectives: identify appropriate sites for deployment of artificial reefs; design and construct

artificial reefs, deploy reefs at appropriate sites. Implementation Issues/Feasibility Implementation of this project is relatively simple. A formal project plan, including designs and cost estimates would be developed in consultation with resource agencies. The design of the artificial reef substrates would be guided by evaluating substrates at a reference area located in a similar environmental setting. Implementation would require coordination with the Army Corps of Engineers because it involves placement of fill in navigable waters. Use of the tidelands would require permission from the landowner, for the most of Unalaska Bay this would be either the State of Alaska or the City of Unalaska. Construction of this project would not require any special equipment, skills or expertise that is not locally available. Artificial reef material, including quarry rock, is available locally. Project 13. Fish Passage Restoration - Morris Cove Goal: restore the functional value of Morris Cove Lake and the small stream that drains it. The

functions include access for anadromous fish to spawning and rearing habitat. Full restoration of the site would include rechanneling the stream into the historical streambed.

Description Morris cove is located in the Summer Bay area. The lake and the small stream draining from the lake have historically provided spawning and rearing habitat for pink, coho and sockeye salmon (ADFG 302-31-100010). This project would involve maintenance of fish passage at a small stream that drains Morris Cove Lake. The stream mouth has been cleared several times but it has not lasted. The project would include restoration of the trampled riparian area and removal of debris. An additional, optional component of this project would be to restore and rechannel the stream into its historical streambed, which would create a watercourse of greater length and provide more habitat. Many interviewees favor this option, believing that re-routing might result in a more permanent solution to fish passage. Objectives: maintain access for anadromous fish during periods of migration; avoid

unnecessary damage to adjacent meadow and riparian areas; avoid disturbance of archeological sites in area.

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Implementation Issues/Feasibility A formal project plan, including designs and cost estimates would be developed in consultation with resource agencies. Implementation would require coordination with the Army Corps of Engineers because it involves dredging activity and alteration of shorelines. Implementation of this project would require that access to the land surrounding the lake (Hope native allotment and O.C. land) be acquired. Construction of this project would not require any special equipment, skills or expertise that is not locally available.

Figure 14. Morris Cove Lake and outlet stream looking east. May 13, 2008.

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Figure 15. Morris Cove Lake and outlet stream looking west. May 13, 2008.

Figure 16. Outlet stream at mouth. May 13, 2008.

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Figure 17. Morris Creek historical streambed. May 13, 2008.

Figure 18. Riparian trampling and debris. May 13, 2008.

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Project 14. Fish Passage Maintenance - All Area Streams Goal: maintain the functional values (anadromous fish access and upstream spawning and rearing habitat) of area streams. Description Anadromous fish streams in the Unalaska Bay area support pink, chum, sockeye and coho salmon. Also, anadromous and resident Dolly Varden are present within this area. These streams from east to west are:

Morris Cove Creek (ADFG # 302-31-10010) Humpy Creek (ADFG # 302-31-10020) Summer Bay Creek/Lake (ADFG # 302-31-10030) Iliuliuk River/Unalaska Lake (ADFG # 302-31-10500) Pyramid Creek (ADFG # 302-31-10600) Shaishnikof River (ADFG # 302-31-10700) Nateekin River (ADFG # 302-31-10800) Makushin River (ADFG # 302-31-10900)

Map 5. Anadromous Stream locations

The project would involve monitoring and maintenance of fish passage in the anadromous streams throughout the Unalaska area. Potential areas of blockage include culvert crossings, slope failures, riprap rock and other debris, and road crossings. This project would be

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conducted in partnership with ADFG for a specified period of time for individual mitigation project requirements. Objectives: maintain access for anadromous fish during periods of migration; avoid unnecessary

damage to adjacent riparian and wetland areas.

Figure 19. Pyramid Creek facing upstream. November 29, 2007.

Figure 20. Pyramid Creek facing downstream. November 29, 2007.

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Implementation Issues/Feasibility Implementation would require coordination with the Army Corps of Engineers because it may involve dredging. Implementation of this project would require that access to the land surrounding the sites. Project 15. Nearshore/Offshore Habitat - Derelict Fishing Gear Removal Goal: reduce safety, liability, nuisance and environmental issues associated with derelict fishing

gear in marine waters. Description Decades of commercial and recreational fishing have contributed hundreds of tons of lost or abandoned gear throughout the Bering Sea and Gulf of Alaska. Alaska removed 90 tons of derelict gear in 2004. Common types of derelict fishing gear include nets, crab and shrimp pots, lines and ropes. Derelict fishing gear presents safety, liability, nuisance and environmental impact issues in marine waters. Identifying and safely removing derelict fishing gear can reduce these impacts. Objectives: remove derelict nets, crab and shrimp pots, lines and ropes from nearshore and

offshore waters of the Unalaska area. Implementation Issues/Feasibility Derelict fishing gear has successfully been removed from Alaska waters. Protocols would need to be developed and modeled after past successes. Locations of gear are typically identified using side-scan sonar and underwater videography which can be cost prohibitive if a strategic and targeted approach is not taken. Project 16. Nearshore Habitat Enhancement - Bird Resting Reefs Goal: increase the functional value of certain marine nearshore sites by creating bird resting

reefs. Description Modeled after the mitigation for the Little South America Harbor development, the project would be to deploy artificial reefs in the nearshore for bird resting. This project would create a new type of habitat where either none or a different type previously existed. Objectives: identify appropriate sites for deployment of bird resting reefs; design and construct

artificial reefs, deploy reefs at appropriate sites. Implementation Issues/Feasibility A formal project plan, including designs and cost estimates would be developed in consultation with resource agencies. The design of bird resting reefs would be guided by evaluating reference sites located in a similar environmental setting. Implementation would require coordination with the Army Corps of Engineers because it involves placement of fill in navigable waters. Use of the tidelands would require permission

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from the landowner, for the most of Unalaska Bay this would be either the State of Alaska or the City of Unalaska. Construction of this project would not require any special equipment, skills or expertise that is not locally available. Artificial reef material, including quarry rock, is available locally.

Figure 21. Example of a natural reef. May 4, 2005.

Project 17. Habitat/Biomass Enhancement Goal: increase the functional value of intertidal areas by providing increased surface area for

colonization by marine organisms. Description The addition of chain to existing sheet pile docks has been shown to increase biomass. The project would involve incorporating chain and other surface structures to increase biomass on exiting sheet pile docks and fill areas. Objectives: identify appropriate sites for deployment of chain; design and construct tackle,

deploy chain at appropriate sites. Implementation Issues/Feasibility Implementation of this project would require that access across private docks be obtained through an arrangement with the landowners. Construction of this project would not require any special equipment, skills or expertise that is not locally available. Project 18. Summer Bay Salmon Habitat Restoration Goal: maintain the functional values (anadromous fish access, foraging, spawning and rearing

habitat) of the bay, stream and lake system. Description When the MV Kuroshima grounded at Summer Bay, the nearshore, stream and lake system

(ADFG # 302-31-10030) was adversely impacted. Previously, the system supported healthy runs of silver and red salmon. The goal of the Summer Bay Habitat Enhancement project would be to restore the entire system, in addition to fish passage (project # 14).

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Figure 22. Summer Bay. May 13, 2008.

Figure 23. Summer Bay Lake. May 13, 2008.

Objectives: maintain access for anadromous fish during periods of migration; avoid

unnecessary damage to adjacent meadow, riparian and wetland areas. Implementation Issues/Feasibility A formal project plan, including designs and cost estimates would be developed in consultation with resource agencies. Implementation would require coordination with the Army Corps of Engineers because it may involve dredging activity and alteration of shorelines. Implementation of this project would require that access to the land surrounding the lake be acquired.

Figure 24. Summer Bay Creek outlet. May 13, 2008.

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Project 19. Areawide Stormwater Run-off Control Goal: restore water quality and aquatic functions that have been impaired over time due to

stormwater run-off and associated problems with erosion and sedimentation. Description The single-most commonly identified issue for the community of Unalaska is the lack of stormwater run-off control and associated problems with erosion and sedimentation. In areas of unstable soils or steep slopes, heavy accumulations of snow or intense rainfall contribute to erosion, mudslides, landslides, debris flow, and avalanches. The City of Unalaska encompasses 116 square miles of land with 38 miles of road maintained by the City. There are currently storm drains along Unalaska Lake, Summer Bay Road and Ballyhoo Road. Although progress has been made to pave roads and install catch basins to manage stormwater run-off and sedimentation, the majority of the road system remains un-paved and surface water run-off is directly into the rivers, lakes and nearshore marine waters. Numerous opportunities exist at varying scales to address this area-wide problem including paving, ditching, installation of catch basins and sediment traps, and retention ponds as well as “Low Impact Development” approaches such as re-vegetation with native plant species. Objectives: Perform an evaluation of water quality and functions that are impacted by stormwater run-off in various locations. Develop a formal project plan, including designs and cost estimates in consultation with resource agencies. Design, construct and implement appropriate techniques to manage and control stormwater run-off. Implementation Issues/Feasibility The feasibility of an areawide stormwater management system would vary considerably with the techniques employed. A suite of options at different scales of geography and complexity would have a greater chance of being implemented over time.

Project 20. Beach Stabilization/Re-vegetation - Areawide Goal: restore the functional values of the beach areas that were lost by the development of

adjacent roadways. Description Most of the roads in the Unalaska area (Airport Road, Captains Bay Road, Front Street, Summer Bay Road, etc.) follow the coastline often impinging on the back beach zone. The compacted roadbed material does not provide a good substrate for natural colonization of vegetation, and therefore remains mostly unvegetated and is an area of active erosion. Also, the absence of vegetation allows the stormwater sediment to be transported and discharged into receiving waters. The project would consist of stabilizing and re-vegetating the beach area. A coastal engineering evaluation of the project would be required to develop an appropriate project design. The project should also include access management plans that provide access to the beaches at specified areas while preventing trampling and damage to developing vegetation. The project locations also present opportunities for an interpretive signage component.

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The City conducted a similar project along Front Beach which has been successful although opportunities remain for additional enhancements in this location. Objectives: create a vegetated sea berm that mimics natural sea berms where practicable;

create access point to the beach for recreation and subsistence use; install interpretive signage at access points.

Implementation Issues/Feasibility A formalized restoration, enhancement and management plan, including engineering designs and cost estimates would be developed in consultation with resource agencies. Implementation would require coordination with the Army Corps of Engineers because it would involve placement of fill and alteration of shorelines.

Figure 25. Front Street vegetated back beach berm. May 13, 2008.

Project 21. Areawide Educational Signage Goal: promote stewardship and understanding of Unalaska resources through education

signage.

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Description Numerous opportunities throughout Unalaska exist for education signage. Types of signage include

• educational signs that inform the public about fuel handling, nonpoint source pollution prevention, contaminated shellfish or sensitive habitats; and

• interpretive signs that provide information about historic/cultural sites, wildlife viewing, or geologic forms.

The project would involve design and installation of any number of signs as appropriate for the required mitigation. Objectives: install areawide signage at appropriate locations with consistent design themes. Implementation Issues/Feasibility Implementation of this project is relatively simple. An areawide signage plan, including locations, consistent design themes and cost estimates would be developed. Construction of this project would not require any special equipment, skills or expertise that is not locally available. In some instances the location of signage may require landowner agreements.

Figure 26. Example of potential location for interpretive signage, Airport Rd. May 13, 2008.

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Figure 27. Sample Interpretive Sign - Summer Bay Archeological Site. May 13, 20008.

Project 22. Derelict Vessel Removal - Captains Bay Goal: remove derelict vessel from Captains Bay. Description The project would be to remove the derelict vessel at the head of Captains Bay and restore any damage to the substrate. The project would involve funding both the removal/salvage and disposal. Objectives: remove derelict vessel; restore any damage to substrate. Implementation Issues/Feasibility Derelict vessels have successfully been removed from Alaska waters. Protocols would need to be developed modeled after past successes. There is local expertise in marine salvage logistics and techniques.

Figure 28. Derelict Vessel, Captains Bay. May 13, 2008.

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Figure 29. Derelict Vessel, Captains Bay. May 13, 2008.

Project 23. Derelict Vessel Removal - end of Airport runway Goal: remove derelict vessel from marine waters at the end of the runway.

Figure 30. Derelict Vessel, Airport Runway. May 14, 2008.

Description The project would be to remove the derelict processing barge at the end of the airport runway, near the shooting range and re-contour the surrounding area as necessary. The project would involve funding both the removal/salvage and disposal. Objectives: remove derelict vessel; restore any damage to beach profile. Implementation Issues/Feasibility Derelict vessels have successfully been removed from Alaska waters and beaches. Protocols would need to be developed modeled after past successes. There is local expertise in marine salvage logistics and techniques.

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Project 24. Tanaxtagax, Amaknak Spit Site Goal: excavate and curate the Amaknak Spit Site (UNL-00055). Description The Amaknak Spit Site (UNL-00055) is near the town of Unalaska, on Unalaska Island. The site is situated at the base of Amaknak, or Dutch Harbor Spit, a mile long spindle of land stretching southward from the site to form a natural breakwater protecting the port of Dutch Harbor from the Bering Sea. The site and most of the surrounding land is owned by the Ounalashka Corporation. The site has research history dating back to the 1970s, and thus has a number of synonyms in the literature – Uhlaktha Spit, Tanaxtagax, site “A”, and Amaknak Spit. The AHRS lists the site as UNL-00055 or Tanaxtagax. This term may be related to the Unangan word tanasxa meaning “field’ or “kitchen gardens”, probably associated with the use of the rich organic sediments or midden sites around Unalaska Bay as gardens beginning in the Russian era. Tanaxtagax was a prehistoric Unagan village beginning as early as 3,000BP. The site has been documented and some restoration has occurred. However, due to erosion and deterioration, the site needs to excavated and artifacts curated. The mitigation project would fund the excavation. The project could be facilitated by the Museum of the Aleutians. Objectives: excavate the Amaknak Spit Site (UNL-00055) and curate recovered artifacts. Implementation Issues/Feasibility The project is relatively straightforward and well defined as a result of previous studies. The site and most of the surrounding land is owned by the Ounalashka Corporation. The Museum of the Aleutians could coordinate appropriate agencies.

Figure 31. Tanaxtagax Interpretive Sign. May 14, 2008.

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Map 6. Tanaxtagax, Amaknak Spit Site (UNL-00055)

Project 25. Nearshore and Intertidal Species Surveys Goal: document intertidal and nearshore species. Description Much has been done to document birds, sea otters, seals and other marine mammals. However, little has been done to document intertidal and nearshore species at the level of detail that is necessary to determine appropriate levels of compensation for development impacts. The project could be performed at various geographic scales as appropriate for mitigation and would look at a variety of species including, but not limited to eelgrass Zostera marina, kelp beds Nerocystis luetkeana, Alaria sp., and Laminaria sp., and caplin (also capelin) Mallotus villosus spawning.

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Objectives: document the location, distribution and variation of intertidal nearshore species. Additional objectives may be developed for each species as appropriate.

Implementation Issues/Feasibility Coordinate with the resource agencies to determine appropriate protocols. Local expertise exists to successfully carry-out the project. Project 26. Manson Saltery Restoration and Access Goal: stabilize or restore historic structures and develop public access

Figure 32. Manson Saltery. May 15, 2008.

Description The site is located on the shore of Iliuliuk Harbor, at the western base of Haystack Mountain, a short distance north along the shoreline from the Bridge to the Other Side between Amaknak and Unalaska Islands; Tax I.D. Lot ## 04-04-250. Manson's Herring Saltery is made up of three relatively small wood frame structures. The first structure measures 6' by 15', has an earth floor, and rusted metal exterior wall panels, over (full dimension) 2x wood framing. This structure is covered by a gable roof, covered with rolled asphalt roofing material laid over 1x wood decking and 2x wood rafters. Two gabled wood cupolas rise from the roof ridge; two open doorways (with the doors now removed) enter the building on the east elevation. The second structure measures 16' by 12', has a wood plank floor, and painted red horizontal weatherboard exterior siding, with 1" by 4" corner boards, over 2x wood framing. This structure is covered by a corrugated metal roof, laid over 1x wood decking and 2x wood rafters. Two single-light windows penetrate the west elevation wall; one single-light window penetrates the north elevation wall; an open doorway (with the door now removed) enters on the north elevation. The third building measures 12' by 12', has a wood plank floor, and rusted, painted red, corrugated metal exterior walls over 2x wood framing. This structure has a tall 1 1/2-story gabled section, with a gabled cupola, with lower shed-roofed

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sections on the north and east sides. One single-light window opening penetrates the south elevation. A single open doorway is centered on the west elevation. The project would involve stabilizing and possibly restoring one or more of the structures and developing parking and trail access to the site. Interpretive signage could be installed to convey the historical significance of the site. The Manson Saltery buildings are the only remaining structures in Unalaska associated with the thriving salt herring industry of the early part of the twentieth century. Objectives: stabilize or restore as appropriate three small historic wood frame structures; develop public parking and trail access; install interpretive signage. Implementation Issues/Feasibility The structures are located on city property and trail access could be developed from the state ROW, near the Bridge to the Other Side, across city lands to the site. The structures are currently subject to vandalism. It has been suggested that management of the site could be turned over to the local kayak club who could use the site for kayak storage and launching.

3.2 Utility and Transportation Mitigation Opportunities Project 27. Erosion Control and Re-vegetation - Broad Bay Goal: restore the ground cover and the beach profile at Broad Bay. Description Broad Bay is located on the west side of Unalaska Bay at the mouth of the Makushin River. The area is zoned “subsistence tidelands” with adjacent “marine dependent industrial”. Furthermore, the AWCRSA Coastal Management Plan has designated a portion this area for recreational and subsistence use as follows: Broad Bay - The area within 1000 feet of either side of the ordinary high water mark of the Makushin River. The designated area extends 300 feet offshore and 250 feet inland as measured from mean high water.

Figure 33. Broad Bay. May 13, 2008.

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This project would involve contouring and reseeding with native plant materials, if practicable, to restore the ground cover and the beach profile. Objectives: stabilize and revegetate the river banks, riparian areas and adjacent uplands; develop a motorized vehicle management plan which may include an educational signage component. Implementation Issues/Feasibility The project is relatively straightforward. The challenge will be to maintain the restored areas and implement a motorized vehicle management plan in a remote area. Project 28. Erosion Control and Re-vegetation - Nateekin Bay Goal: restore the ground cover and the beach profile at Nateekin Bay. Description Nateekin Bay is located on the west side of Unalaska Bay at the mouth of the Nateekin River. The area is zoned “developable tidelands” with adjacent “marine dependent industrial”. Furthermore, the AWCRSA Coastal Management Plan has designated a portion this area for recreational subsistence use as follows: Nateekin Bay - The area within 1000 feet of either side of the ordinary high water mark of the Nateekin River. The designated area extends 300 feet offshore and 250 feet inland as measured from mean high water. This project would involve contouring and reseeding with native plant materials, if practicable, to restore the ground cover and the beach profile. Objectives: stabilize and revegetate the river banks, riparian areas and adjacent uplands; develop a motorized vehicle management plan which may include an educational signage component. Implementation Issues/Feasibility The project is relatively straightforward. The challenge will be to maintain the restored areas and implement a motorized vehicle management plan in a remote area.

Figure 34. Nateekin Bay. May 13, 2008.

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3.2 Habitat Mitigation Opportunities Project 29. Areawide Invasive Species Control – Vegetation Goal: restore habitat used by coastal species by removing competing species Description Interviewees report that there is a wide-spread invasive plant species problem. In coordination with the Alaska Plant Materials Center (PMC), the project would remove red clover and thistle and re-seed with native plants. PMC is a section of the Division of Agriculture within the Department of Natural Resources. The Plant Materials Center's work advances applied plant research for northern latitudes and includes a Revegetation and Native Seed Production program. Objectives: remove red clover and thistle; identify appropriate native plants; reseed with native

plants. Implementation Issues/Feasibility Develop a removal and revegetation plan in consultation with the Department of Natural Resources, Division of Agriculture’s Plant Materials Center. Project 30. Areawide Invasive Species Control – Rats Goal: restore habitat used by coastal species be removing destructive species and predators Description Rats present a significant problem at various locations in the Unalaska area. The project would address a problem area to be identified at the time the mitigation is required. The project proponent would be responsible for removing rats by trapping and/or with poison. Inclusion of public education and outreach components of this project is very important. Objectives: remove rats by trapping and/or with poison; develop a public education and outreach component to minimize re-infestation. Implementation Issues/Feasibility Rat control is a recurring problem. In addition to the removal portion of the project it will be essential to develop and implement a public education and outreach program to minimize re-infestation.

3.4 Oil Spill Mitigation Opportunities Project 31. Wildlife Cleaning Equipment Goal: develop local capacity to rehabilitate wildlife affected by oil spills.

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Description Wildlife cleaning equipment is designed to clean and rehabilitate wildlife affected by oil spills. Animals that are affected by an oil spill could be cleaned by professionals and trained volunteers using this equipment. The project would involve contacting experienced entities such as the International Bird Rescue Research Center's Anchorage oiled wildlife care facility to obtain a list of appropriate cleaning equipment. The project would also require that the project proponent arrange for warehousing of the purchased equipment. Objectives: identify, acquire and store appropriate wildlife cleaning equipment. Implementation Issues/Feasibility This is a straightforward project. By contacting experienced entities as suggested above, the project proponent should easily be able to identify, acquire and arrange for warehousing of the necessary equipment.

3.5 Out-of-Kind Mitigation Opportunities Project 32. Solid Waste Recycling Goal: reduce impacts to the landfill though recycling.

Figure 35. Unalaska Landfill. May 13, 2008.

Description Currently there is limited ad hoc recycling of solid waste because in many instances it is not cost effective. The City of Unalaska compares the cost of disposal of solid waste at $139/ton versus an estimated $2000/ton for recycling (personal communication Chris Hladick, 2007). However, there are significant environmental benefits that could be realized through recycling. Recycling presents a number of mitigation opportunities that could be scaled and designed as one-time projects to target the impact requiring mitigation. For example, the project proponent

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could take possession of certain articles from the landfill, transport and recycle them. Such articles include nets, cars and scrap metal. Objectives: Specific objectives would be developed for each recycling project as needed. Implementation Issues/Feasibility This is a straightforward project. The project proponent would take possession of certain articles (nets, cars and/or scrap metal) from the landfill, transport and recycle them. Project 33. Beach and Creek Cleanup Program Goal: conduct volunteer-based cleanup events in the Unalaska area for removing trash and

debris from creeks, lakes, wetlands and beaches.

Figure 36. Beach Debris, Airport Beach, March 23, 2005.

Description This project would take place throughout the Unalaska Bay area and include the inhabited areas of Unalaska as well as the outlying areas of Unalaska and Amaknak Islands. Both the City and Ounalashka Corporation have beach clean-up programs. Although volunteer-based, these types

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of programs require funding. A potential mitigation project would involve funding the administration and coordination of the event, as well as transportation and disposal of recovered items. Objectives: remove trash and debris from area creeks, lakes, wetlands and beaches; provide administration and coordination of volunteer-based cleanup events; facilitate community involvement and education in conservation of local coastal resources; provide an opportunity for community members, industry, and local government to work together. Implementation Issues/Feasibility This project would require personnel with the skills or training in administering and coordinating volunteer-based events. This project is expected to be highly successful due to the community support that was expressed during the interview process for this study.

Figure 37. Trash, Lower Iliuliuk River Riparian Area, November 29, 2007.

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4.0 Summary and Conclusions Thirty-two mitigation opportunities were identified in this study. These were categorized and cross-referenced to the state standard that would require mitigation (see Table 1). Using the information that was available, the mitigation opportunities were evaluated for location, description, goals, objectives and implementation issues/feasibility. The mitigation opportunitiy evaluations were intentionally brief because indepth study and mitigation project design is best carried-out at the time of project planning, when the scope of the development and thus the impacts are known. The general conclusions of this study can be summarized as follows: • There are numerous mitigation opportunities that may satisfy the requirements of the coastal

development standard 11 AAC 200 (c), and by reference 33 C.F.R. Parts 320.4 (r) and in 40 CFR 230.70 through 40 CFR 230.77 (Subpart H of the 404(b)(1) Guidelines).

• Although not required to comply with the Alaska Coastal Management Program or the

AWCRSA Coastal Management Plan, there are likewise numerous mitigation opportunities that could be implemented to compensate for the impacts from oil spills.

• The impacts of transportation and utilities projects for which mitigation may be required are

limited to alterations in surface and ground water drainage patterns, disruption in known or reasonably foreseeable wildlife transit, and blockage of existing or traditional access. For this reason, less than half of the mitigation opportunities identified in this study could be required as mitigation for transportation and utilities projects.

• The impacts to certain habitats for which mitigation may be required are also very limited

and are specific to a particular habitat. For this reason it may be necessary to use the habitat standard in conjunction with the coastal development standard in order to justify the need for mitigation opportunities that are broad in scope.

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5.0 References and Bibliography Bowers, Forrest. Alaska Department of Fish and Game, Unalaska, Alaska. Personal communication with Gabrielle LaRoche, LaRoche and Associates. 2008. Fulton, John, Director, City of Unalaska Planning Department. Unalaska, Alaska. Personal communication with Gabrielle LaRoche, LaRoche and Associates. May 2008. Golodoff, Suzy. Former member AWCRSA Board. Unalaska, Alaska. Personal communication with Gabrielle LaRoche, LaRoche and Associates. November 2007. Hall, Robin, Former Director, City of Unalaska Planning Department. Unalaska, Alaska. Personal communication with Gabrielle LaRoche, LaRoche and Associates. November 2007. Hancock, Jeff. Aleutian Adventure Kayak Tours, Unalaska, Alaska. Personal communication with Gabrielle LaRoche, LaRoche and Associates. November 2007. Hawley, Jeff P., Director Parks, Culture and Recreation, City of Unalaska, Alaska. Personal communication with Gabrielle LaRoche, LaRoche and Associates. May 2008. Hawthorne, Wendy, CEO and David Gregory, Land Manager. Ounalashka Corporation. Unalaska, Alaska. Personal communication with Gabrielle LaRoche, LaRoche and Associates. November 2007. Herring, Doug. Operations Manager Pacific Stevedoring & Freight, Inc. Dutch Harbor, Alaska. Personal communication with Gabrielle LaRoche, LaRoche and Associates. November 2007. Hladick, Chris, Manager, City of Unalaska, Alaska. Personal communication with Gabrielle LaRoche, LaRoche and Associates. November 2007. Johnson, Zoya, Director, Museum of the Aleutians. Unalaska, Alaska. Personal communication with Gabrielle LaRoche, LaRoche and Associates. November 2007. Knecht, Richard and Richard Davis. Archaeological Evaluation of Tanaxtagax, The Amaknak Spit Site (UNL-00055) Final Report. Prepared for the U.S. Army Corps of Engineers, Alaska District by The Museum of the Aleutians, Unalaska Alaska. February 2003. Masoni, Dan, Librarian. Department of Parks, Culture and Recreation, City of Unalaska, Alaska. Personal communication with Gabrielle LaRoche, LaRoche and Associates. May 2008. Morrison, Shannon. TelAlaska, Inc. Unalaska, Alaska. Personal communication with Gabrielle LaRoche, LaRoche and Associates. November 2007. Osterback, Alvin. Director Port of Dutch Harbor, Unalaska, Alaska. Personal communication with Gabrielle LaRoche, LaRoche and Associates. November 2007.

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Paul, A. J. and K. O. Coyle. Taxa Composition and Biomass of the Surface-Dwelling Crustaceans during Spring Pycnocline Formation in Auke Bay, Southeastern Alaska, Journal of Crustacean Biology, Vol. 13, No. 3 (Aug., 1993), pp. 594-600 doi:10.2307/1548800 Peterson, Nancy, Director, City of Unalaska Public Works. Unalaska, Alaska. Personal communication with Gabrielle LaRoche, LaRoche and Associates. November 2007. Rankin, Denise, Vice President, Qawalangin Tribe. Unalaska, Alaska. Personal communication with Gabrielle LaRoche, LaRoche and Associates. November 2007. Joe Shaishnikoff, Sea Otter Surveys, Unalaska, Alaska. Personal communication with Gabrielle LaRoche, LaRoche and Associates. November 2007. Stevens, Bradley G., J. Eric Munk and Peter A. Cummiskey Utilization of Log-piling Structures as Artificial Habitats for Red King Crab Paralithodes Camtschaticus, Journal of Shellfisheries Research, April, 2004. Svarny-Livingston, Sharon. Unalaska, Alaska. Personal communication with Gabrielle LaRoche, LaRoche and Associates. November 2007. Tryck Nyman Hayes, Inc. (TNH). 1996. Evaluation of Mitigation Opportunities in Unalaska Final Report. Prepared for the City of Unalaska, Public Works. West, Brad. West Construction. Unalaska, Alaska. Personal communication with Gabrielle LaRoche, LaRoche and Associates. November 2007. Wilt, Sinclair. Vice President Alyeska Seafoods, Inc. Unalaska, Alaska. Personal communication with Gabrielle LaRoche, LaRoche and Associates. November 2007. Woodbridge, Abi. Former member AWCRSA Board. Unalaska, Alaska. Personal communication with Gabrielle LaRoche, LaRoche and Associates. November 2007.