Izembek National Wildlife Refuge
World-class biodiversity stronghold at risk
Introduction
Near the tip of the Alaska Peninsula between the rich waters of the Bering Sea and Gulf of Alaska lies the smallest Wildlife Refuge in the State of Alaska, but its size does not reflect its outsized value as a biodiversity stronghold. Spanning over 310,000 acres—the size of Grand Teton National Park—Izembek National Wildlife Refuge is home to hundreds of species, including caribou, brown bears, foxes, wolves, salmon, seals, sea otters, walrus, and tens of thousands of resident and migratory birds and waterfowl that depend on the Refuge’s wetlands for their survival. Virtually the entire global populations of Pacific brant and emperor geese depend on Izembek to feed and build fat reserves for migration. A proposed road through the heart of the Refuge and congressionally designated Wilderness threatens to irreparably harm wildlife and its habitat, including a critical migration corridor and globally significant wetlands.
The Alaska National Interest Lands Conservation Act (ANILCA) does not allow the Secretary of the Interior to execute a land exchange in Izembek Wilderness for a road. Moving forward with a land exchange threatens the integrity of ANILCA and would subsequently jeopardize the congressional protections of over 150 million acres of national public lands under ANILCA.
In 1960 the Izembek National Wildlife Range was established by President Eisenhower. In 1980, President Jimmy Carter signed ANILCA into law which redefined the Wildlife Range as the Izembek National Wildlife Refuge. ANILCA designated 300,000 acres (or nearly all of Izembek) as a Wilderness Area. Congressionally designated Wilderness is intended to offer the highest levels of protection to lands by permanently restricting roads and other industrial developments.
At the heart of the Refuge’s vibrant ecosystem is the Izembek and Kinzarof Lagoons Complex. Rich in nutrients like nitrogen and phosphorous from nearby volcanic activity, the lagoons are a vital and irreplaceable habitat for hundreds of species within the Refuge. A narrow, three-mile-wide isthmus separates the lagoons and provides a movement corridor between the east and west sides of the Refuge, allowing bears, caribou, and wolves to travel and migrate freely throughout the Refuge.
The threat of road construction in the isthmus and adjacent to the Izembek and Kinzarof Lagoons in designated Wilderness has loomed over the Refuge since 1983. Studies have repeatedly found that the road would have devastating consequences for the land and wildlife of the Refuge. Additionally, if a controversial land exchange to allow for such construction is approved, it would set a dangerous precedent that threatens all conservation lands - over 150 million acres - protected under ANILCA.
Traditions and Cultures of the Alaska Peninsula
The Alutiiq/Sugpiaq, and Unangan people have lived and thrived on the Alaska Peninsula for thousands of years, subsisting on the abundance of natural resources in this region, including marine and terrestrial species.
The Unangan people have long harvested seals, whales, sea lions, sea otters, fish, caribou, and waterfowl for food and traditional clothing. Seal and sea lion skins were also used to make the iqyax, a one-to-two-person boat used for hunting and trade along the Alaska Peninsula. Seals, in particular, remain an important subsistence resource for the Native people of the Alaska Peninsula, and depend on the Izembek lagoon as a nursery and feeding ground.
The Yup’ik, Cup’ik, and Athabascan people of the Yukon-Kuskokwim Delta (Y-K Delta) in western Alaska and Iñupiat in Alaska’s Arctic regions are also connected to Izembek’s National Wildlife Refuge through the birds they share. Many of these species that breed and nest in the Y-K Delta are an important resource for subsistence harvesters and depend on the Izembek Lagoons to survive their migrations to and from this region. Black brant are vital to subsistence harvesters locally, in the Arctic, and within the Y-K Delta. Waterfowl like the brant make up a significant portion of the subsistence diet for Tribes throughout the Y-K Delta region. Due to this connection to black brant, emperor geese and other waterfowl, people of the Y-K Delta region have closely watched and engaged in the Izembek road controversy over many years.
"I am a father, a husband, a veteran, a hunter, a fisherman, and I am the Chief for Native Village of Hooper Bay. My number one concern for our people is protecting our ability to hunt and to provide for our families. Our health and our survival depend on our ability to hunt and to live our traditional ways. The U.S. Fish and Wildlife Service has already shown that the Izembek land exchange and road project will harm brant and emperor geese."
Chief Edgar Tall (far right) with other Tribal Council members and affiliates.
The Association of Village Council Presidents’ (AVCP) Waterfowl Conservation Committee passed a resolution opposing the proposed road through Izembek National Wildlife Refuge in 1998 which was reaffirmed in 2007, 2013, and 2015. AVCP represents 56 Tribes in Western Alaska. Twenty resolutions that represent 78 Tribes and one village corporation have been passed opposing a land exchange and road in Izembek Refuge. Opposition to the land exchange and road comes from Tribes representing 8 language groups: Yup’ik, Cup’ik, Iñupiaq, Gwich’in Athabascan, Koyukon Athabascan, Han Athabascan, Ahtna Athabascan, and Dena’ina Athabascan. Click the link to access the Tribal resolutions.
Meet the Wildlife of Izembek
The Izembek and Kinzarof lagoons contain some of the largest eelgrass beds in the world. Spanning approximately 42,000 acres, these eelgrass beds are an essential resource for many species within the Refuge.
Eelgrass (Zostera marina) is a type of seagrass that grows in shallow coastal waters in the north temperate region of the globe. Eelgrass beds are especially vibrant here because of the rich nutrients from nearby volcanic ash. Eelgrass beds stabilize coastlines, absorb and fix atmospheric carbon, act as heavy metal sinks, maintain water quality, and provide food and habitat for hundreds of species within the Refuge.
The eelgrass beds at Izembek are experiencing impacts from climate change and a road could further impact this vital resource.
A Hotspot for Migratory Birds
The Izembek National Wildlife Refuge sits at the intersection of three major migratory flyways.
The East Asian-Australasian migratory flyway
The West Pacific migratory flyway
And the Pacific Americas migratory flyway
Each year, the lagoon complex hosts hundreds of bird species as they migrate along these routes.
Virtually the entire populations of Pacific brant and emperor geese, and significant portions of the world’s populations of Steller’s eider and Taverners cackling geese stop at Izembek along their migration routes to feed voraciously and build fat reserves.
Black Brant (Niġlinġaq)
Izembek is a critical staging habitat for black brant (Branta bernicla), known as niġlinġaq in Iñupiaq, as they complete one of the longest waterfowl migrations in North America [1]. Between late August and early November, Izembek hosts almost the entire world's brant population (about 150,000 individuals). After traveling over 700 miles from the Y-K Delta or farther north, the brant stop in Izembek to refuel before many of them make a roughly 3,000-mile journey to Baja, California, or farther south to parts of Northern Mexico. The brant repeats this migration in the spring, stopping at Izembek again in April. During their fall residency in the Refuge, black brant spend up to 80% of their day feasting on eelgrass. By the time they leave the Refuge, the brant will have consumed 15% of the eelgrass within Izembek’s 96,000-acre lagoon. No other bird species within the Refuge relies as heavily on eelgrass as the black brant. Since the 1960s, subsistence users and researchers have noted a significant decline in brant populations, especially in the Y-K Delta [2].
Brant are a significant subsistence and cultural resource for the Unangan people of the Alaska Peninsula and for the Yup’ik, Cup’ik, and Athabascan cultures of the Y-K Delta. In response to declines in the brant population and other species of waterfowl, the people of the Y-K Delta, along with federal and state agencies signed the Hooper Bay Agreement in 1984, now known as the Yukon-Kuskokwim Delta Goose Management Plan. Signatories to the Agreement and Plan have collaborated with other agencies and organizations throughout the Pacific Flyway to recover waterfowl populations and their habitat throughout the brant’s nesting, breeding, and wintering ranges and migratory flyway. Recovery efforts have included habitat protection and, when necessary, moratoria on the subsistence hunting and egg collecting of brant and emperor geese in particular in the Y-K Delta region.
In recent years, a growing number of brant have chosen to winter in Izembek. Researchers hypothesize that this shift is due to climate change reducing the frequency of specific weather patterns that trigger brant migration [4]. As Izembek becomes a place that brant rely upon for longer periods of time, maintaining the quality of this habitat will become even more critical to the brants’ survival.
Brant are highly sensitive to human disturbance and likely to avoid or abandon areas with high human traffic. A road bifurcating this key staging ground has the potential to displace brant from critical feeding and freshwater drinking areas they depend on to survive their migrations and reproduce successfully.
Emperor Goose (Nacaullek, Qagmangix)
The emperor goose (Anser canaliculus), known as nacaullek in Yup’ik and qagmangix in Unangam Tunuu, or the “painted goose,” lives almost exclusively in Alaska [3]. These geese nest and breed in the Y-K Delta and winter in the Aleutian Islands and the southern end of the Alaska Peninsula. Emperor geese migrate in the spring and fall, completing an almost 2,200 km journey to their staging areas in the Izembek lagoons complex and other locations on the Alaska Peninsula. Most emperor geese migrate to their wintering sites by early December, but some stay within Izembek Refuge or in other estuaries along the Peninsula if ice-free habitat exists.
Emperor goose populations suffered a sharp decline in the 1970s and 1980s due to a combination of overharvest, food scarcity from climate change, marine pollution, and high rates of adult mortality before the breeding age. Fortunately, their populations are slowly recovering [5]. However, a road constructed through one of their most important habitat areas could reverse that progress.
Taverner’s Cackling Geese (Tuutangayak)
The Taverner’s cackling goose (Branta hutchinsii taverneri), known as Tuutangayak in Yup’ik, is a subspecies of the cackling goose, which was officially classified as a separate species from the Canada goose in 2004 [3].
Like the black brant and emperor goose, Taverner’s geese nest in the Y-K Delta and stage at Izembek while migrating to northern Washington and Oregon for the winter. Taverner’s geese feed on eelgrass, wetland grasses and berries while staging in the Refuge. They also are an important subsistence species.
Tundra Swan (Qugyuk/Qugsuk)
Tundra swans (Cygnus columbianus), known as Qugyuk or Qugsuk in Yup’ik, migrate throughout northern North America between breeding grounds, summer ranges, and winter ranges [3]. However, one population of tundra swans is special and does not migrate at all. The Izembek tundra swan is the world’s only non-migratory population and maintains residence at Izembek’s rich lagoons year-round. These swans spend their entire lives in the Refuge, nesting and raising their young on the narrow isthmus between the lagoons. A road through that isthmus would significantly harm this unique population of tundra swans and their nesting habitat. Check out the map on the right to see how tundra swan abundance varies throughout the Izembek Wildlife Refuge.
Birds aren’t the only creatures relying on the Lagoon complex to complete their yearly migrations.
Five species of pacific salmon (chum, coho, chinook, sockeye, and pink) swim through these lagoons on their way to spawning streams in the Refuge. Pacific Herring and other fish species also migrate to the lagoons to spawn and feed.
Brown bears are most highly concentrated in the Joshua Green Watershed, which supports the highest density of brown bears on the southern Alaska Peninsula. The Joshua Green River and salmon spawning grounds make this area a resource-rich environment for bears. The watershed is also an important denning habitat and a key area for juvenile brown bears and sows with cubs. A road through Izembek's isthmus will harm brown bears by fragmenting habitat and providing much greater human access to brown bears causing disturbance and increased mortality.
Wolves, like bears, range throughout the Alaska Peninsula and within Izembek National Wildlife Refuge, often using the isthmus between lagoons to move between the east and west sides of the refuge.
Caribou
The Southern Alaska Peninsula Caribou herd range across the isthmus. The isthmus provides winter habitat and a migratory corridor to their summer range. A road fragmenting this corridor would significantly impact the distribution and survival of the herd.
Endangered Species
Izembek is home to three species protected under the Endangered Species Act: the Alaska breeding populations of the Steller’s eider, the southwest Alaska stock of northern sea otter, and the western Alaska stock of Steller sea lion.
Steller's Eider (Caqiar)
Steller’s eider (Polysticta stelleri), known as Caqiar in Yup’ik, is an arctic-dwelling seaduck that nests within the coastal plain of the Arctic National Wildlife Refuge and winters along the Alaska Peninsula, preferring lagoons rich in eelgrass. The Steller’s eider eats grasses, shoots, mollusks, crustaceans bristleworms, snails, fish, and other small invertebrates that live within Izembek’s eelgrass-covered lagoons.
Steller’s eiders are currently listed as threatened under the Endangered Species Act and their designated critical habitat includes Izembek Lagoon.
Northern Sea Otter
The southwest Alaska population of northern sea otters is a distinct population segment (DPS) listed as threatened in September 2005. Their range extends from the Attu Island on the western end of the Aleutian Islands to Kamishak Bay on the west side of Cook Inlet and includes the coastal waters along the Aleutians Islands, the Kodiak Archipelago, the Alaska Peninsula, and the Barren Islands. A portion of this range was designated as critical habitat in 2009.
During the commercial fur harvests of the 18th and 19th century, sea otter populations experienced significant declines from overhunting. The International Fur Seal Treaty of 1911 allowed the southwest population to rebound, but declines began again in the mid-1990s, coinciding with offshore habitat declines along the Alaska Peninsula [6]. The cause of the precipitous sea otter declines in the 1990s is uncertain, but increased killer whale predation is a possible primary agent while contaminants and disease may have also played a role [7].
Steller Sea Lion
The Steller sea lion population ranges along the North Pacific Rim from northern Japan to California. The eastern and western DPS inhabit that range but only the western DPS range includes waters around the Izembek National Wildlife Refuge.
The western DPS decreased from between 220,000 - 265,000 animals in the late 1970s to less than 50,000 in 2000 [8]. The primary cause of these declines remains unknown, but disease and prey availability are considered potential factors [9].
In April 1990, the National Marine Fisheries Service listed the Steller sea lion as threatened under the Endangered Species Act and re-classified the Western U.S. DPS as endangered in 1997. Although none of the critical habitat designations are within Izembek National Wildlife Refuge, Izembek Lagoon is nearby current haul out points and their buffer zones.
Steller sea lions consume a variety of fish species, many of which depend on Izembek Refuge for food and spawning habitat. Degradation of fish habitat within the Refuge’s lagoons could further impact prey availability for the Steller sea lions. NMFS does not have an abundance estimate for the Western DPS but has modeled a population of 52,932 animals, representing a slight increase from the 2000 population assessment, but remaining far below previous estimates [6].
Neighbors of the Refuge
King Cove and Cold Bay are two small communities that border the Izembek National Wildlife Refuge.
Cold Bay was formed as an air force base during World War Two and today is a tiny community of about 50 people. Cold Bay’s airport has the third longest runway in Alaska and serves as a regional hub for small carriers.
King Cove began as a fish cannery settlement in 1911, when Pacific American Fisheries built a large cannery there and employed Asians, Scandinavians, and Alaska Native people who came from surrounding villages. The fishing and canning industry has been an economic stronghold of the community for decades, but as of 2024 the cannery is indefinitely shuttered.
The Proposed Road
History and Background
Discussions about improving access between King Cove and Cold Bay began in the early 1980s. Initial arguments in favor of the proposed road cited economic benefits to King Cove and the regional fishing economy. However, over time road proponents shifted to focus more on the potential beneifts to emergency healthcare. Legislation and litigation have surrounded this issue ever since.
In 1998, Congress enacted the King Cove Health and Safety Act, which seemingly resolved matters by providing funding for marine transportation (a hovercraft), a new hovercraft terminal and road leading to it, and improvements for the King Cove medical clinic and airport.
The Suna X hovercraft operated from Lenard Harbor between 2007 and 2010, performing over 30 medical evacuations in almost every weather condition and providing scheduled passenger service. But interest in a road through the refuge remained, and in 2009 Congress authorized the Secretary of the Interior to determine whether a specific land exchange to allow a road through the refuge was in the public interest. In 2013 Secretary Sally Jewell found that the land exchange and road were not in the public interest, and the legislative authority to approve the land exchange expired in 2016.
Despite the absence of any authority, in 2018 Interior Secretary Ryan Zinke signed an agreement to exchange refuge lands to allow the road. The Alaska federal district court nullified that agreement but another followed in 2019, signed by Secretary Bernhardt who had replaced Zinke. That agreement was also rejected by the Alaska federal district court, which found that Bernhardt had no authority under ANILCA to trade away refuge lands to allow a road. With an appeal pending, Secretary Haaland withdrew the agreement but directed a new process to again assess road and other transportation options between King Cove and Cold Bay.
Throughout this time, concerns were raised about declining waterfowl populations and many entities in Alaska and beyond have worked to protect and restore waterfowl and habitat. Tribes and communities in the Y-K Delta region in southwestern Alaska in particular have led this work and have opposed a road through Izembek Refuge because of the harm that would befall black brant and other subsistence species that rely on the refuge.
A road through Izembek National Wildlife Refuge would have devastating consequences for the wetlands and species within the Refuge and for the people who depend on these resources. A Secretarial land exchange to allow the road would set a legal precedent threatening all lands protected under ANILCA, including all of Alaska’s thirteen National Parks, sixteen National Wildlife Refuges, designated Wilderness areas, and other conservation system units – placing them all at risk of roads and other private development projects via land exchange.
Environmental Impacts
A road through Izembek would harm globally significant wetlands habitat, displace wildlife from critical habitat, and significantly expand hunting access. This puts increased pressure on waterfowl, caribou, brown bears, and other species within the Refuge. This pressure could exacerbate population declines facing subsistence species like black brant, emperor geese, and caribou.
Current roads leading to the edge of the refuge’s designated Wilderness have resulted in increased illegal ATV travel into refuge Wilderness, as shown in this picture, causing substantial habitat damage. The proposed road would increase this type of damage to the refuge and its designated Wilderness. Habitat degradation, noise pollution, and increased human disturbance from the road could...
Displace birds and waterfowl from feeding and nesting grounds
Disrupt caribou migration to calving grounds in the northeast portion of the refuge
Increase den abandonment and bear mortality
Pollute the Izembek and Kinzarof lagoons, harming eelgrass, invertebrates, and critical fish habitat
Road Alternatives
As noted above, the Suna X hovercraft was very successful. The Aleutians East Borough mayor, Stanley Mack, referred to the hovercraft as a “life-saving machine”. However, despite its success, the machine was removed from service and later sold.
In 2015, the U.S. Army Corps of Engineers published a 118-page report entitled “King Cove-Cold Bay Assessment of Non-Road Alternatives.” That report found that a 150-foot ice capable ferry could transport passengers, including those needing emergency medical attention, safely to Cold Bay with 99.9% reliability, at a comparable cost to a road. It also found that transporting passengers from an improved King Cove airport could achieve 95% reliability at lower cost and shorter medevac time. In short, there are viable non-road options between King Cove and Cold Bay that can meet the transportation need without harming refuge wildlife habitat and wilderness values.
Brief History of Legal Proceedings
1980
ANILCA signed into law, creating Izembek National Wildlife Refuge and the Wilderness areas within.
1994
King Cove passes resolution 94-26, supporting the road because it would link the cannery in King Cove to the airport at Cold Bay.
1995
Alaska Governor Tony Knowles says that he favors the road “for transporting salmon to a community with a runway that could handle large planes.”
1998
Congress passes the King Cove Health and Safety Act, providing funds for a hovercraft to transport passengers, including those needing emergency medical attention, from King Cove to the airport at Cold Bay – for medevac service to Anchorage hospitals.
2001-2003
The U.S. Army Corps of Engineers drafts an Environmental Impact Statement to determine the best location for a hovercraft terminal. Congress makes the decision instead in 2003, mandating the “Northeast Terminal,” which requires over 17 miles of new road to be built north from King Cove into the Izembek refuge and up to the Wilderness boundary.
2007-2010
While the road is under construction, the hovercraft successfully operates from Lenard Harbor.
2009
Omnibus Public Lands Management Act (OPLMA)- Congress grants the Secretary of the Interior limited authority, until 2016, to determine whether a specific land exchange and road corridor is in the public interest.
2010
The hovercraft is removed from service in 2010, raising questions about the need for the 17-mile access road to the Northeast Terminal, which is still under construction. The Borough states that if the Secretary does not approve the OPLMA land exchange, then it will provide marine service from the Northeast Terminal.
2013
The U.S. Fish and Wildlife Service completes an Environmental Impact Statement (EIS) assessing the OPLMA proposed land exchange/road.
December 23, 2013
Secretary Jewel finds the OPLMA land exchange not in the public interest and selects the No Action alternative in the EIS. The Borough completes the $40 million taxpayer-funded road to the “Northeast Hovercraft Terminal” but never provides the promised marine transportation, hovercraft or otherwise, from that location and eventually sells the $9 million taxpayer-funded hovercraft.
2016
Secretarial authority for OPLMA land exchange in Izembek sunsets.
January 22, 2018
Secretary Zinke signs land exchange agreement with King Cove Corporation to allow road.
March 29, 2019
Alaska federal District Court of Alaska rejects Zinke land exchange.
June 28, 2019
Secretary Bernhardt signs a second land exchange agreement.
June 1, 2020
Alaska federal District Court rejects Bernhardt land exchange.
March 16, 2022
A three-judge panel of the U.S. Court of Appeals for the Ninth Circuit overturns District Court decision and remands to district court for further proceedings.
November 10, 2022
Ninth Circuit court agrees to rehear the case, vacating the March 16 panel decision.
March 14, 2022
Secretary Haaland withdraws the land exchange, mooting the appeal. She directs the FWS to further consider King Cove-Cold Bay transportation options by supplementing the 2013 EIS.
November 15, 2024
FWS releases a draft supplemental EIS, identifying another land exchange/road as the preferred alternative.
For a more complete timeline of relevant events, download the pdf timeline here
Recent Developments
In 2023, Cold Bay received a Port Infrastructure Development Grant Award for $43,376,746 [10]. The project will include constructing a new dock in Cold Bay that will accommodate commercial use, freight and fuel transportation, private vessels, public transportation use, and emergency medical services. This combined with the 99.9% dependability rating of a marine ferry from the Army Corps of Engineers 2015 analysis suggests that a marine ferry would be an excellent transportation solution.
A second new development is that the Coast Guard plans to have a helicopter in Cold Bay year-round, which could greatly help with emergency medical transport between King Cove and Cold Bay.
The Alaska Department of Transportation also recently released the 2024-2027 Statewide Transportation Improvement Program (STIP) [11]. To be eligible for federal highway funding, which typically covers 90% of road construction costs, projects must be included in the STIP. The recent STIP includes improvements to the Cold Bay dock, but not a road between King Cove and cold Bay.
