On April 6, 2015, Wilderness Watch was notified by the Manager of the Arctic Refuge of a Draft Environmental Assessment (DEA) concerning an intrusive science project proposed for the Arctic Refuge Wilderness in the vicinity of Lake Peters.

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  Initially, only 15 days were allowed for public comments. Wilderness Watch's request for a 45-day extension resulted in just a 15-day extension. The proposed project is a three-year investigation of glaciology, hydrology and meteorology of the Lake Peters area on the north slope of the Brooks Range. Our review of the DEA found an alarming number of proposed actions that are prohibited in Wilderness, including: helicopter landings, airplane landings on sensitive tundra, extensive motor boat travel, numerous instrument installations, use of mechanized equipment, and the placement of a chemical dye in streams. The Wilderness Act only allows exceptions to prohibited actions if they are "necessary to meet minimum requirements for the administration of the area for the purpose of this Act," in other words, necessary to protect wilderness character. The DEA seriously fails to justify that the proposed actions prohibited by the Wilderness Act are necessary.
  
  Furthermore, as the DEA acknowledges, "in summary, the proposed project would substantially increase the number and types of activities and technology normally prohibited in Wilderness. The combined direct negative effects on wilderness character would be moderate to major, but would also be temporary and local in nature." We do not believe these effects will be temporary and local, and if approved, this project will set a precedent for more wilderness-degrading actions in the future.
  
  Our comments included the following:

• The proposed project will degrade the wilderness character of the Arctic Wilderness.
• The DEA and minimum requirement analysis fail to justify that the prohibited actions are necessary to protect Wilderness.
• The inadequate public notification and comment opportunity fail to fulfill the intent of the National Environmental Policy Act.
• The project should not be approved.

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