1 March 2011

Re: Dalton Highway MP 11-18 Reconstruction

Dalton Highway, Alaska Project No.: 62196/NH-065-2(12) Section 404 Permit Application (POA-2010-948)

Greg Mazer U.S. Army Corps of Engineers, Alaska District 2175 University Avenue, Suite 201E Fairbanks, Alaska 99709-4927 Dear Mr. Mazer: Enclosed please find the application packet for a Department of the Army permit under Section 404 of the Clean Water Act for the above-referenced project in northern Alaska. The project corridor consists of Mileposts (MP) 11-18 of the Dalton Highway and is located in Township 9N, Range 7W, Sections 17, 19, 20, 26 through 30, and 36, Fairbanks Meridian, USGS Quadrangles Livengood C-4 and C-5 (Figure 1). The Alaska Department of Transportation and Public Facilities (DOT&PF) is requesting your review of the proposed project and authorization of its impacts to jurisdictional wetlands and other waters of the U.S. The nature and scope of the work being proposed is described in the attached permit application and supporting figures. The purpose of this project is to improve the safety and performance of the Dalton Highway from MP 11-18 by reconstructing the roadway. This project proposes to widen the existing highway to a uniform top width of 36 feet (lanes and shoulders), widen the recovery area (clear zone), reduce grades, flatten horizontal curves, and construct a realignment at Erickson Creek near MP 12 (Figures 2-13). The cross section upgrades would be consistent with previous Dalton Highway reconstruction projects. Existing culverts would be replaced or removed, and new culverts would be installed as needed to improve drainage (Figure 14). The existing highway profile would be raised in the range of 1 to 15 feet to meet sight distance requirements for a 50 MPH design speed (Figure 15). Stabilization berms – additional fill along the embankments – would be constructed along portions of the reconstructed highway to promote thermal stability where possible (Figure 15). The proposed toe of slope linework depicted in Figures 3-13 includes the thermal berms. At Erickson Creek (MP 12), the project proposes to realign approximately 3,500 feet of the highway (Figures 4 and 5). The MP 12 realignment would replace the existing, 35 MPH horizontal curves with curves that meet requirements for a 50 MPH design speed. The curve improvements would be consistent with previous reconstruction projects completed along the Dalton Highway. In conjunction, there would be a proposed change in the profile by as much as 30 feet to provide flatter grades on the realignment compared to the existing highway (8% vs. 10%) and to facilitate an all-embankment construction to avoid excavation in a known area of ice-rich soils. To accommodate the proposed realignment, the existing 81-foot long by 10-foot

Greg Mazer 1 March 2011 Page 2 of 5 diameter culvert in Erickson Creek would be removed, and a new culvert that is 16 feet in diameter and 213 feet in length would be installed approximately 100 feet south of the existing culvert (Figures 4 and 16). To accommodate the proposed realignment and the larger culvert, roughly 300 feet of the existing Erickson Creek channel would be bypassed and filled. The new culvert is being designed to meet current ADF&G fish passage standards. A Categorical Exclusion (CE) was prepared and approved in July 2010. The Proposed Action represents the least environmentally damaging practicable alternative by utilizing the existing highway alignment to the extent practicable while maintaining roadway safety reconstruction standards and accounting for geotechnical constraints. A “Highway Wetlands Avoidance and Minimization Form” was prepared and is included in the CE. Construction is anticipated to begin in the summer of 2012.

DISCHARGE OF FILL IN WETLANDS (SECTION 404 IMPACTS) Although the National Wetlands Inventory (NWI, 1977) classified a majority of the project area as uplands, field delineations revealed that wetlands are more prevalent. An initial field delineation for the proposed project area was performed in September 2005 in accordance with the 1987 Corps of Engineers Wetlands Delineation Manual. A smaller, supplemental delineation was conducted in August 2007 compliant with the Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Alaska Region (Version 2.0) September 2007. The study area consisted of 362 acres along the highway (Figures 3-13) and 192 acres at the 19-Mile Hill Quarry Material Site (Figure 17). A request for concurrence with the resulting wetlands assessment, mapping, and preliminary jurisdictional determination was submitted on 9 December 2010. Impacts are described in the following sections, summarized below in Table 1, and illustrated in the attached permit sheets (Figures 2-13). The wetlands assessment concluded that over 60% (225 acres) of the area abutting the existing highway is wetlands. The different wetland types are located in a wide range of landscapes including undisturbed black spruce forests, severely burned areas from a 2003 forest fire, isolated wetlands associated with previous construction and clearing/firebreak activities, and a small number of roadside ditches that are permanently flooded. The dominant wetland types are Saturated Emergent Meadow, Saturated Broadleaf Evergreen/Needleleaf Evergreen Scrub, and Saturated Broadleaf Evergreen Scrub/Emergent Meadow. Vegetated uplands were found in higher elevations along south facing slopes, riverbanks, and disturbed areas along the existing highway. Numerous intermittent streams are present in the project area and can generally be characterized as small, headwater streams that are likely dry for a majority of the year. All of these waters are considered non-navigable; there are no navigable waters (Section 10) present within the project area. The mapped wetland area in the vicinity of the MP 12 realignment consists of Upper Perennial River, Saturated Broadleaf Deciduous Scrub, and Saturated Emergent Meadow. Erickson Creek, which crosses the Dalton Highway near MP 12, is a permanently flooded creek, classified as a Relatively Permanent Water that ultimately connects downstream to Hess Creek and the navigable Yukon River.

Greg Mazer 1 March 2011 Page 3 of 5 Fill would be placed in wetlands and other waters of the U.S. adjacent to the highway as necessary to facilitate roadway reconstruction and drainage improvements. Calculated impact areas and fill quantities have been summarized below in Table 1. Fill is required for the 3,500-foot realignment at MP12 and to adequately secure the culvert at Erickson Creek so that it meets fish passage standards. The proposed MP 12 realignment accounts for approximately 30% of the total impact area. Material Site Impacts (MS# 65-3-013-2: 19-Mile Hill Quarry)

An existing 200-acre, State-owned material site, commonly known as 19-Mile Hill Quarry, would be made available for the project. Existing roads would provide access. Wetland delineations along with cultural and historical surveys of the material site were completed in conjunction with the MP 11-18 highway corridor. The site includes both previously mined and undisturbed areas. The estimated quantity of material required is 850,000 cubic yards. It is anticipated that material would be extracted from both the active mining and the undisturbed areas. Approximately 192 acres were delineated; 139 acres of this total are classified as wetlands (Figure 17). The dominant wetland type (131 acres) is Saturated Emergent Meadow. Approximately 54 acres were classified as Upland and Upland Fill with 25 acres (Upland Fill) comprising the disturbed or active mining portions of the site. It is estimated that approximately 250,000 cubic yards of material would be generated within the active mining and Upland areas by increasing the depth of excavations. The balance of material (600,000 cubic yards) would need to be extracted from approximately 12.5 acres of undisturbed wetland areas (Figure 17). An additional 10.5 acres would need to be cleared for stockpiling the overburden and waste (material not meeting specifications), processing, and for stockpiling the construction materials. Material unsuitable for reuse would be disposed of at a contractor-provided location. The actual mining area within the material site would be established by the contractor in an approved mining plan; this would determine the exact location and type of wetland impacts.

Table 1. Summary of Section 404 Impacts

HIGHWAY IMPROVEMENTS MATERIAL SITE

Area (Acres) Fill/Cut Quantities in cubic yards (CY)

Area (Acres) Fill/Cut Quantities in cubic yards (CY)

OTHER WATERS OF THE U.S.

0.4 6,000 0 0

JURISDICTIONAL WETLANDS

24.3 300,000 23 600,000

TOTAL 24.7 306,000 23 600,000

Greg Mazer 1 March 2011 Page 4 of 5

PROPOSED MITIGATION STATEMENT

Several realignment alternatives were considered to address the operational and safety concerns associated with the existing highway geometry at MP 12. Realignment alternatives proposed north of the existing highway were eliminated from consideration primarily due to greater amounts of new highway construction over undisturbed, ice-rich ground, crossing Erickson Creek at new locations, longer culvert lengths, steep grades, and deep sidehill fills. To the extent possible, the proposed realignment utilizes the disturbed areas associated with the existing highway. The Proposed Action, as described in this document, meets the project purpose and need and applicable design criteria while avoiding and minimizing environmental impacts. 1. Avoidance of impacts to waters of the U.S., including wetlands: Efforts to avoid wetland impacts have been included throughout the design of the project. Complete avoidance of wetlands is not possible as more than 60% of areas abutting the existing highway have been delineated as wetlands. By widening the existing highway, the average impact width is estimated to be 15 feet on either side of the highway, thus avoiding greater wetland impacts associated with new highway locations or major realignments. The realignment at Erickson Creek is an essential component of improving safety by replacing the existing 35 MPH reversing horizontal curves with new curves that meet 50 MPH design standards. Impacts to jurisdictional waters in this area cannot be avoided due to the fact that Erickson Creek crosses the highway corridor. As much material as possible (approximately 250,000 CY) would be extracted from the previously mined areas within the available material site to avoid wetland impacts. However, in order to meet the material needs of the project, the mining area would need to be expanded to extract an additional 600,000 CY from previously undisturbed areas thus resulting in additional wetland impacts. Erickson Creek intersects the existing highway; an alternate alignment that would avoid this crossing is not feasible. Coordination with ADF&G was initiated early in project development to avoid and minimize impacts to resident fish species. The new culvert would be designed to meet fish passage requirements in accordance with DOT&PF/ADF&G Culvert Design and Construction Memorandum of Agreement (August 2001). 2. Minimization of unavoidable impacts to waters of the U.S., including wetlands: The Proposed Action meets the project purpose and need while minimizing wetlands impacts to the greatest extent practical. The proposed improvements accommodate future traffic volumes and have been sited to minimize wetland impacts by widening the existing facility. Furthermore, impacts have been minimized by siting the realignment at MP 12, to the extent possible, within previously disturbed areas. All previously considered realignment alternatives in this area would have incurred similar wetland impacts to those of the Proposed Action. Steep side slopes and grades are used in certain areas of the corridor to avoid wetland impacts and still meet minimum design requirements. The DOT&PF is requesting the following special permit condition in order to minimize impacts. The Dalton highway corridor is vegetated beyond the roadway embankment. The existing

Greg Mazer 1 March 2011 Page 5 of 5 vegetation adjacent to the proposed toe of slope would be utilized as a natural buffer for sediment control. Using the existing vegetation as a buffer would prevent additional disturbance associated with the installation of man-made sediment controls such as silt fencing. The inherent wetland function of sediment filtration would be utilized in wetland areas with standing water present. The addition of silt-fencing or other sediment controls in these areas would result in additional impacts and are thus not being proposed. Components of the project have been consolidated where possible. For example, realignment at Erickson Creek and the reconstruction of the corridor could have been separate projects but have been consolidated to minimize impacts and to facilitate construction. The existing road alignment and embankment would be reused. Utilizing an existing material site, access road, and previously mined areas further minimizes wetland impacts. 3. Compensation for unavoidable impacts to waters of the U.S., including wetlands: The extent in which impacts to wetlands have been avoided and minimized is notable. All project components have been designed to accommodate traffic forecasts and anticipated maintenance needs. There is no practicable way to completely avoid wetland impacts given the existence, location, and function of the Dalton Highway. The wetlands impacted by the proposed project are relatively lower in value due to their proximity to the existing highway. Some are considered roadside ditches or ponds where water regularly collects alongside the toe of the road. A new alignment would have a greater impact on undisturbed wetlands, therefore realignment is being used only where absolutely necessary. Impacts to relatively higher value wetlands, such as open water and emergent wetlands, have been minimized as much as possible. The realignment near MP 12 is necessary to correct the poor geometry and upgrade the road to meet current design and safety standards. The crossing of Erickson Creek utilizes the existing highway and previously disturbed areas (uplands) to minimize impacts. The extent to which impacts to jurisdictional wetlands and other waters of the U.S. have been avoided constitutes compensatory mitigation for the Proposed Action.

Should you have additional questions about this packet, please contact Sarah Schacher at the address above, by telephone at 907.451.5361, or by e-mail at sarah.schacher@alaska.gov.

Sincerely,

Bruce W. Campbell Northern Region Environmental Manager

Attachments: Application for Department of the Army Permit (ENG FORM 4345) Figure 1: Location and Vicinity Map Figure 2: Project Area/Impacts Summary Figures 3 - 13: Plan Views Figure 14: Culvert Summary Figure 15: Typical Section Figure 16: Typical Section – Erickson Creek Crossing Figure 17: Material Site

APPLICATION FOR DEPARTMENT OF THE ARMY PERMIT (33 CFR 325)

OMB APPROVAL NO. 0710-0003 Expires August 31, 2012

Public reporting burden for this collection of information is estimated to average 11 hours per response, including the time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information. Send comments regarding this burden estimate or any other aspect of this collection of information, including suggestions for reducing this burden, to Department of Defense, Washington Headquarters, Executive Services and Communications Directorate, Information Management Division and to the Office of Management and Budget, Paperwork Reduction Project (0710-0003). Respondents should be aware that notwithstanding any other provision of law, no person shall be subject to any penalty for failing to comply with a collection of information if it does not display a currently valid OMB control number. Please DO NOT RETURN your form to either of those addresses. Completed applications must be submitted to the District Engineer having jurisdiction over the location of the proposed activity.

PRIVACY ACT STATEMENT Authorities: Rivers and Harbors Act, Section 10, 33 USC 403; Clean Water Act, Section 404, 33 USC 1344; Marine Protection, Research and Sanctuaries Act, 33 USC 1413, Section 103. Principal Purpose: Information provided on this form will be used in evaluating the application for a permit. Routine Uses: This information may be shared with the Department of Justice and other federal, state, and local government agencies and the public may be made available as part of a public notice as required by Federal law. Submission of requested information is voluntary, however, if information is not provided the permit application cannot be evaluated nor can a permit be issued. One set of original drawings or good reproducible copies which show the location and character of the proposed activity must be attached to this application (see sample drawings and instructions) and be submitted to the District Engineer having jurisdiction over the location of the proposed activity. An application that is not completed in full will be returned.

(ITEMS 1 THRU 4 TO BE FILLED BY THE CORPS)

1. APPLICATION NO.

2. FIELD OFFICE CODE 3. DATE RECEIVED 4. DATE APPLICATION COMPLETED

(ITEMS BELOW TO BE FILLED BY APPLICANT)

5. APPLICANT’S NAME First - Bruce Middle - Last- Campbell Company – Alaska Department of Transportation & Public Facilities

Northern Region E-mail Address - bruce.campbell@alaska.gov

8. AUTHORIZED AGENT’S NAME AND TITLE (an agent is not required) First - Middle - Last- Company – E-mail Address -

6. APPLICANT’S ADDRESS Address – 2301 Peger Road City - Fairbanks State - Alaska Zip - 99709 Country -USA

7. AGENT’S ADDRESS Address – City - State - Zip - Country -

7. APPLICANT’S PHONE NOS. W/AREA CODE a. Residence N/A b. Business: 907.451.2238 c. Fax

10. AGENT’S PHONE NOS. W/AREA CODE a. Residence b. Business c. Fax

STATEMENT OF AUTHORIZATION

11. I hereby authorize to act in my behalf as my agent in the processing of this application and to furnish, upon request, supplemental information in support of this permit application. APPLICANT’S SIGNATURE DATE

NAME, LOCATION AND DESCRIPTION OF PROJECT OR ACTIVITY

12. PROJECT NAME OR TITLE (see instructions)

Dalton Highway MP 11-18 Reconstruction Project No.: 62196/NH-065-2(12)

13. NAME OF WATERBODY, IF KNOWN (if applicable)

Erickson Creek

14. PROJECT STREET ADDRESS (if applicable) Address

Dalton Highway Mileposts (MP) 11-18 City - State - Zip

15. LOCATION OF PROJECT

BOP: Latitude: 65°33’53”N Longitude: 148°54’59”W EOP: Latitude: 65°36’34”N Longitude: 149°04’12”W

16. OTHER LOCATION DESCRIPTIONS, IF KNOWN (see instructions) State Tax Parcel ID - NA Municipality - NA Sections - 17, 19, 20, 26 through 30, and 36 Township - 9N Range – 7W Meridian – Fairbanks USGS Quad Map – Livengood C-4 and C-5

17. DIRECTIONS TO THE SITE

The project area is between MP 11-18 of the Dalton Highway, approximately 85 miles north of Fairbanks in interior Alaska.

ENG FORM 4345, SEPT 2009 EDITION OF OCT 2004 IS OBSELETE Proponent: CECW-OR

18. NATURE OF ACTIVITY (DESCRIPTION OF PROJECT, INCLUDE ALL FEATURES)

The project proposes to widen the existing highway to a uniform top width of 36 feet (lanes and shoulders), widen the recovery area (clear zone), reduce grades, flatten horizontal curves, and construct a realignment near Erickson Creek (MP 12). The cross section upgrades would be consistent with previous Dalton Highway reconstruction projects. Existing culverts would be extended, failed culverts replaced, and new culverts installed as needed to improve drainage. The existing highway profile would be raised in the range of 1 to 15 feet to meet sight distance requirements for a 50MPH design speed. At Erickson Creek (MP 12), the project proposes to realign approximately 3,500 feet of the highway in order to replace the existing 35 MPH reversing horizontal curves with new curves meeting 50MPH design standards. In conjunction, there would be a proposed change in the profile by as much as 30 feet to provide flatter grades on the realignment compared to the existing highway (8% vs. 10%) and to facilitate an all-embankment construction to avoid excavation in a known area of ice-rich soils. To accommodate the proposed realignment, the existing 81-foot long by 10-foot diameter culvert in Erickson Creek would be removed, and a new culvert that is approximately 16 feet in diameter and 213 feet in length would be installed approximately 100 feet south of the existing culvert. An existing 200-acre material site (MS#65-3-013-2, 19-Mile Hill Quarry) would be made available to the contractor.

Thermal berms – additional fill along the embankments – would be constructed along portions of the reconstructed highway to promote thermal stability of the permafrost in areas where feasible. The berms would not be constructed near drainage culverts or in areas of steep grade where the amount of fill would be substantial. Guard rails would be installed at the edge of the shoulder at Erickson Creek and MP 15.3 to minimize fill requirements and culvert length.

19. PROJECT PURPOSE (DESCRIBE THE REASON OR PURPOSE OF THE PROJECT, SEE INSTRUCTIONS)

The purpose of this project is to improve the safety and performance of the Dalton Highway between MP 11-18 by reconstructing the roadway. The Dalton Highway is part of the National Highway System and provides the only vehicle access across Interior Alaska from Fairbanks to Deadhorse, serving as a critical supply route between commerce and industrial centers. The original roadway was thought of as a haul route to support the Trans-Alaska Pipeline System and was constructed to the former State of Alaska Department of Highways secondary road standards. Today, the Alaska DOT&PF general data log designates the Dalton Highway as a rural principal arterial that supports heavy truck and tourism traffic. DOT&PF anticipates an increase in future traffic with continued industrial development, regional tourism, and renewed interest in the Alaska natural gas pipeline. Reconstruction of the roadway to current standards would substantially improve safety along this narrow, winding section of the highway and increase its service life.

USE BLOCKS 20-22 IF DREDGED AND/OR FILL MATERIAL IS TO BE DISCHARGED

20. REASON(S) FOR DISCHARGE

Fill would be placed in wetlands adjacent to the highway as necessary to facilitate roadway reconstruction and drainage improvements. Additional fill is needed for the 3,500-foot realignment and to adequately secure the culvert at Erickson Creek so that it meets fish passage standards.

21. TYPE(S) OF MATERIAL BEING DISCHARGED AND THE AMOUNT OF EACH TYPE IN CUBIC YARDS

A total of approximately 306,000 cubic yards (CY) of classified fill would be discharged to wetlands (300,000 CY) and other waters of the U.S. (6,000 CY). Suitable material originating from excavation along the project corridor would be redistributed as necessary. The existing culvert at Erickson Creek would be secured with native material, riprap, and classified material.

22. SURFACE AREA IN ACRES OF WETLANDS OR OTHER WATERS FILLED (SEE INSTRUCTIONS)

A total of approximately 24.7 acres of wetlands (24.3 acres) and other waters of the U.S. (0.4 acres) would be impacted by the Proposed Action along the road corridor for highway improvements including the MP 12 realignment. The Proposed Action would impact approximately 23 acres at Material Site #65-3-013-2.

23. DESCRIPTION OF AVOIDANCE, MINIMIZATION, AND COMPENSATION (SEE INSTRUCTIONS)

Refer to permit application cover letter for avoidance and minimization statement.

24. IS ANY PORTION OF THE WORK ALREADY COMPLETE Yes, No. IF, YES, DESCRIBE THE COMPLETED WORK

25. ADDRESS OF ADJOINING PROPERTY OWNERS, LESSEES, ETC., WHOSE PROPERTY ADJOINS THE WATERBODY (IF MORE THAN CAN BE ENTERED HERE, PLEASE ATTACH A SUPPLEMENTAL LIST)

Adjacent lands are owned by the State of Alaska.

26. LIST OF OTHER CERTIFICATIONS OR APPROVALS/DENIALS RECEIVED FROM OTHER FEDERAL, STATE, OR LOCAL AGENCIES FOR WORK DESCRIBED IN THIS APPLICATION AGENCY TYPE APPROVAL* IDENTIFICATION NUMBER DATE APPLIED DATE APPROVED DATE DENIED

ADF&G, Division of Habitat

Title 16 Fish Habitat Permit (Erickson Creek)

N/A Concurrently Pending N/A

*Would include but is not restricted to zoning, building and flood plain permits

27. Application is hereby made for a permit or permits to authorize the work described in this application. I certify that the information in this application is complete and accurate. I further certify that I possess the authority to undertake the work described herein or am acting as the duly authorized agent of the applicant.

SIGNATURE OF APPLICANT DATE SIGNATURE OF AGENT DATE

The application must be signed by the person who desires to undertake the proposed activity (applicant) or it may be signed by a duly authorized agent if the statement in block 11 has been filled out and signed.

18 U.S.C. Section 1001 provides that: Whoever, in any manner within the jurisdiction of any department or agency of the United States knowingly and willfully falsifies, conceals, or covers up any trick, scheme, or disguises a material fact or makes any false, fictitious or fraudulent statements or representations or makes or uses any false writing or document knowing same to contain any false, fictitious or fraudulent statements or entry, shall be fined not more than $10,000 or imprisoned not more than five years or both.

CULVERT SUMMARY

PROPOSED CULVERT LOCATION

DIMENSIONS (diameter by length in feet)

CULVERT TYPE PLAN VIEW

#

67+60 Erickson Creek

16 x 213 Replaces Existing Culvert 4B

100+18 3 x 136 Replaces Existing Culvert 5A 113+50 3 x 98 Replaces Existing Culvert 5B 165+78 3 x 117 New Culvert 7A 181+50 3 x 104 Replaces Existing Culvert 7B 191+35 3 x 122 Replaces Existing Culvert 8A 211+46 3 x 119 Replaces Existing Culvert 8B 220+59 3 x 144 Replaces Existing Culvert 8B 224+49 3 x 150 Replaces Existing Culvert 8B 232+73 3 x 160 Replaces Existing Culvert 9A 241+32 2 x 92 Replaces Existing Culvert 9A 258+45 3 x 120 Replaces Existing Culvert 9B 267+48 3 x 131 Replaces Existing Culverts 10A 272+50 3 x 160 Replaces Existing Culvert 10A 288+50 3 x 130 Replaces Existing Culvert 10B 296+68 2 x 89 Replaces Existing Culvert 10B 310+55 3 x 118 Replaces Existing Culvert 11A 329+96 3 x 126 Replaces Existing Culvert 11B 346+70 3 x 133 Replaces Existing Culvert 12A 374+43 3 x 138 Replaces Existing Culvert 13A 380+33 3 x 118 Replaces Existing Culvert 13A 389+01 3 x 114 Replaces Existing Culvert 13B 402+07 2 x 103 Replaces Existing Culvert 13B