In February of 2013, the U.S. Fish & Wildlife Service released its Final Environmental Impact Statement (FEIS) for a proposed land exchange and road in Alaska’s Izembek National Wildlife Refuge and selected the alternative of “no action” as CSE, The Wilderness Society, and others argued for. The decision represented a victory on a project CSE and TWS had been collaborating on since 2009.
Congressional legislation passed in 2009, P.L. 111-11, the Omnibus Public Land Management Act Legislation, directed the FWS to analyze a proposal for a new road through the heart of the Izembek National Wildlife Refuge and for the Secretary of the Interior to determine whether or not the proposed road is in the “public interest.” In order to fulfill the terms of the legislation, a proper benefit-cost analysis (BCA) is necessary, as it is crucial for determining whether or not the proposed action is in the public interest and represents a good balance between competing resource values (i.e. benefits exceed costs), creates demonstrable rather than speculative socio-economic benefits, and rests on a solid economic foundation.
CSE and The Wilderness Society partnered to monitor the environmental impact statement process as it evolved and provided three sets of comments and analysis including comments on the Draft Environmental Impact Statement (DEIS) released in the spring of 2012. In our DEIS comments, we concluded that the Fish and Wildlife Service’s (FWS) failure to conduct and incorporate a BCA into the DEIS had led the agency to erroneously conclude that the project is beneficial from an economic standpoint. A cursory examination of benefits and costs indicated that costs are likely to exceed benefits by a huge margin – a factor of 7 in the most optimistic scenario, a factor of 13 more likely.
The final decision represented a turnaround that CSE and TWS are now working to uphold. Despite the USFWS decision, Congress has forced the Department of Interior to reconsider its decision and hold a series of public meetings to gather input. CSE recently sent a letter to Secretary of Interior Sally Jewell asking her to uphold the USFWS decision because the “no action” alternative is the only decision that can meet the required public interest test.