West Susitna Access:


404 Permitting
 

Permit Application Number: POA-2022-00165 (USACE Skwentna River / West Susitna Access Road)

Comment Deadline: October 13, 2026 (18-day window)

Submission Email: WestSusitnaAccess78@usace.army.mil

 

The West Susitna Access Project requires a Section 404 permit from the U.S. Army Corps of Engineers before any construction can begin. A 404 permit is required under the Clean Water Act whenever a project places fill, such as gravel, rock, or roadbed material, into wetlands, rivers, streams, or other waters of the United States.

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To support transparency in this process, the Susitna River Coalition is sharing the documents we received through Freedom of Information Act (FOIA) public document requests to the US Army Corps.​​​ Despite paying $889.88 in December 2025 and being asked for an additional $6,957.55 in disputed production fees, AIDEA has still failed to fulfill your outstanding records request, having shared original application materials and the Owl Ridge fish studies to date.

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 A. Official Application & Resources:

• Corps public notice POA-2022-00165 (September 25, 2026)

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• AIDEA 404 Permit Application and Cover Letter (July 24, 2026)

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• AIDEA West Su Road Project Description (July 2025)

 

Resources

1. 33 CFR 327.4, requesting a public hearing​

   Anyone may ask the Corps in writing, before the comment period closes, to hold a public hearing. The request has to explain the reasons for it.

2. 33 CFR 325.2(e)(4), emergency processing

   The regulation the Corps cites for its special procedures. It describes the kind of emergency that justifies skipping standard review.

3. DOT&PF West Susitna Access project

   The state's proposed 22-mile road and Susitna River crossing. The AIDEA road would begin where this one ends. The Corps has no permit application for it yet. 

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B.  State Studies (AIDEA / USACE)

• AIDEA Section 404 Alternatives Analysis: Skwentna Crossing Alternative (SCA) Application & 404(b)(1) Analysis: This is AIDEA's technical report justifying its choice of the Skwentna Crossing Alternative (SCA) over northern and southern alignments. It details the road footprint across 113 stream crossings and asserts that the SCA reduces jurisdictional wetland impacts by 39.6% compared to the North Skwentna Alternative.

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• AIDEA Aquatic Resource Maps: Proposed Jurisdictional vs. Non-Jurisdictional Wetland Maps: AIDEA Detailed plan-view maps depicting where AIDEA draws the legal boundary between "jurisdictional" waters and "non-jurisdictional" wetlands along the 78.5-mile road corridor.

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• AIDEA Draft Environmental Assessment: Applicant-Prepared Draft EA:  AIDEA's June 2026 draft Environmental Assessment submitted to USACE. It evaluates project purpose and need, typical road cross-sections, gravel material sites, and applicant-claimed environmental consequences for wetlands, streams, and fish habitat.

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C. Baseline Fisheries & Ecological Studies

• 2024 Owl Ridge Fish Survey Report (Revised Jan 2025): West Susitna Access Alternate Route Fish Surveys: The primary biological baseline study evaluating 115 stream crossings. Crucially, it documents that 19 out of 26 priority stream crossings were never physically sampled on foot because brush and bog conditions prevented helicopter landings. On streams that were ground-sampled, electrofishing documented Coho salmon, Steelhead/Rainbow trout, and Dolly Varden, leading to six new stream nominations to the Anadromous Waters Catalog (including Canyon Lake Creek).

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• 2022 Owl Ridge Fish Survey Final Report: West Susitna Access Project Baseline Fish Surveys: The initial 2022 baseline survey covering 129 stream locations along earlier route options, detailing water chemistry and initial fish species distribution.

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D. Public Records & Agency Correspondence

• State Briefing Memorandum to Secretary Doug Burgum: An internal state briefing memo prepared by AIDEA for Governor Dunleavy to use with National Energy Dominance Council Chair Secretary Doug Burgum. It recommends asking Burgum to issue top-down direction forcing USACE to decouple AIDEA's road permit from ADOT&PF's connecting road project and grant an expedited permit.

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• AIDEA Letter to USACE Regarding Application Completeness & Public Notice List (Sept. 23, 2025 ): 

1. Challenging USACE Authority on "Aquatic Resources" vs. Sackett Jurisdictional Wetlands: AIDEA formally demanded legal citations for USACE's definition of "aquatic resources". AIDEA argued that USACE was trying to evaluate a broad "project footprint" beyond actual federal Clean Water Act jurisdiction as narrowed by the Supreme Court's Sackett v. EPA ruling, and questioned the Corps' authority to collect or share data on non-jurisdictional waters

2. Demanding a Fast 6-Month Environmental Assessment (EA): Citing what it claimed was a "small amount of federal jurisdictional wetlands involved," AIDEA asserted that a quick Environmental Assessment (EA) completed within six months was the appropriate NEPA path, rather than an Environmental Impact Statement (EIS)

3. Withholding the 404(b)(1) Alternatives Analysis: AIDEA stated that its CWA Section 404(b)(1) alternatives analysis was underway but explicitly refused to provide it until USACE first deemed AIDEA's application complete.

4. Conditioning the State Section 401 Water Quality Review: AIDEA similarly stated it would not request a pre-filing meeting with the Alaska Department of Environmental Conservation (DEC) for Clean Water Act Section 401 Water Quality Certification until USACE officially declared the permit application complete

5. Clarifying the Eastern Road Terminus (Attachment A): AIDEA provided "Attachment A" attempting to address the Corps' concern about how the road connects on its eastern end (showing a connection to ADOT&PF's planned road west of Alexander Creek)

6. Requesting Legal Definitions for Impact Categories: AIDEA asked USACE to supply specific legal citations and example tables defining "temporary," "permanent," "direct," and "indirect" impacts.

7. AIDEA's formal objection to USACE's request to send public notices to 755 nearby property addresses. AIDEA argues that "adjacent" must apply strictly to properties that physically border or abut the road, resulting in a drastically reduced notification list.

8. Pushing for a Jurisdictional Determination Meeting: AIDEA requested a face-to-face meeting with USACE staff to go over its proposed Sackett-based jurisdictional determination.

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• ​​AIDEA’s September 2025 Response to USACE Request for Information: Technical enclosures accompanying AIDEA’s September 2025 RFI response, featuring map figures for the road's eastern highway connection, a preliminary multi-year project schedule, and AIDEA's revised adjacent landowner notification list.

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• AIDEA’s April 2026 Revised Project Purpose and Need: AIDEA’s updated justification for the 78.5-mile road corridor, defining the project's primary objective as providing industrial access to mineral deposits and natural resources in the West Susitna basin.

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• Governor Dunleavy’s Expedited Permitting Demand Letter: Request for expedited permitting pursuant to POTUS Alaska EO 14153.pdf Governor Dunleavy's formal letter invoking Executive Order 14153 to demand 15-day and 30-day elevated Corps decision windows, emergency fast-tracking under EO 14156, and restricting Section 106 historic preservation reviews strictly to physical stream crossing footprints.

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• USACE Initial Request for Information August 26, 2025: 

1. Disconnected Eastern Terminus & Unmet "Purpose and Need": USACE pointed out that while AIDEA's stated purpose was to connect remote areas to the "existing highway system," AIDEA's drawings showed the 78.5-mile road terminating in the bush near Alexander Creek without any connection to an established road network. The Corps stated that without an existing connection, the project failed to meet its own stated purpose and need.

2. Missing Pre-Development Aquatic Resource Mapping: USACE notified AIDEA that its application lacked figures clearly displaying the location and extent of all pre-development aquatic resources across the entire project footprint, which is required before a public notice can be published.

3. Mandatory Impact Quantification Table: USACE instructed AIDEA to submit a structured table breaking down all direct, indirect, temporary, and permanent impacts across specific aquatic types (palustrine, lacustrine, riverine, and uplands) totaling the entire road footprint.

4. Presumption of Upland Alternatives (Clean Water Act 404(b)(1) LEDPA): The Corps explicitly reminded AIDEA that an access road is a "non-water dependent activity". Under federal CWA Section 404(b)(1) guidelines, the law presumes that practicable upland alternatives exist with less environmental damage. USACE noted that AIDEA's initial submittal failed to rebut this presumption or prove that its route represented the Least Environmentally Damaging Practicable Alternative (LEDPA).

5. Clean Water Act Section 401 Water Quality Certification Rules: USACE laid out the mandatory federal sequence under 40 CFR Part 121, requiring AIDEA to request a formal 30-day pre-filing meeting with the Alaska Department of Environmental Conservation (DEC) before applying for state Water Quality Certification.

6. Internal Executive Hold (Context from Agency Emails): Internal Corps correspondence reveals that District staff had this RFI letter drafted in early August 2025, but were ordered by Headquarters and the Office of the Assistant Secretary of the Army for Civil Works—ASA(CW)—to hold off on sending it to AIDEA until receiving high-level clearance

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• AIDEA’s official Form 4345 application and cover letter

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• The Jurisdictional Determination Report outlining wetlands and waters impacted by the project

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• The most recent project description and appendices, which explain design features, access routes, and anticipated effects​

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Source documents available by request

SRC has obtained records about this project through public records requests to the U.S. Army Corps of Engineers and AIDEA. These include application materials, correspondence, and GIS shapefiles of both AIDEA's proposed route (the Skwentna Crossing Alternative) and a second route AIDEA provided to the Corps, the North Skwentna Alternative, which is not shown in the public notice. To request copies, email info@susitnarivercoalition.org.

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These materials form the foundation of how the project is being characterized to federal regulators. By making them publicly available, we hope to ensure that community members, Tribal governments, and local organizations have access to the same information being provided to decision-makers.

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The Puplic Comment period opened on September 25th and will close on October 13th in an expedited permitting process. 

 

During the comment period, the public will have an opportunity to weigh in on:

• the extent of wetland and stream impacts

• whether the project meets Clean Water Act standards

• whether less damaging alternatives exist

• impacts to fish, wildlife, water quality, and subsistence

• effects on cultural and community resources

• whether a full Environmental Impact Statement should be required​​​​

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