August 29, 2016

Neil Kornze, Director
Attn.: Protest Coordinator
United States Bureau of Land Management
P.O. Box 71383
Washington, D.C. 20024-1383

 

Re: Objection to BLM’s Proposed Resource Management Plan and Final Environmental Impact Statement for the Alaska Eastern Interior Area

Dear Director Kornze:

The Resource Development Council for Alaska, Inc. (RDC) is writing to object to the Bureau of Land Management’s (BLM) Proposed Resource Management Plan (RMP) and Final Environmental Impact Statement (FEIS) for the Eastern Interior (EI) of Alaska.

RDC is an Alaskan business association comprised of individuals and companies from Alaska’s oil and gas, mining, forest products, tourism and fisheries industries. RDC’s membership includes Alaska Native Corporations, local communities, organized labor, and industry support firms. RDC’s purpose is to encourage a strong, diversified private sector in Alaska and expand the state’s economic base through the responsible development of our natural resources.

It is a priority of RDC to advocate for increased access to and across public lands for responsible resource development. RDC believes the BLM should not seek to further restrict access, but instead follow the intent of the Congress and strive for multiple-use of public lands.

Therefore, RDC writes to object to the Proposed RMP and FEIS, and highlight significant concerns and errors with the document:

  • Alternative E, BLM’s Proposed Alternative in the FEIS, was not included in the Draft Environmental Impact Statement.
  • Resource use limitations in the proposed Areas of Critical Environmental Concern (ACEC) designations were improperly noticed, and RDC has general objections to unwarranted ACEC designations.
  • Many of the proposed withdrawals in the EI constitute a violation of the Alaska National Interest Land Claims Act (ANILCA).

The Proposed Alternative in the FEIS was not included in the DEIS

Creation of a new “combination” alternative (E) should trigger a new comment period open to the public, in which all aspects could be weighed against A, B, C and D, which the public has previously had a chance to review in detail. Review of the new alternative should not be limited to the 30-day protest.

In addition to Alternative E being a new alternative, it is significantly different to the previously Proposed Alternative. The Draft EIS recommended that a large area of land be open to resource development. As noted later, this plan is significantly different.

Further, Alternative E is effectively a new proposal and is not a hybrid of existing alternatives. As a newly introduced alternative, Alternative E should be open to public comment in a Revised Draft EIS (DEIS).

Moreover, RDC raises concerns with the Alternative E, including the proposal for 745,000 acres of lands that are to be managed as park lands, which we believe violates the “no more” clause of ANILCA.

A Revised DEIS and review of Alternative E would trigger a review of potential ANILCA violations.

Resource use limitations in the proposed ACEC designations and general objections to ACECs

RDC previously expressed concern ACECs add an unnecessary layer of “protection” to BLM managed public land that already has protections and restrictions in place. RDC discourages additional land use restrictions inhibiting access to areas in Alaska and encourages the BLM not to adopt unwarranted ACEC designations.

This proposal designates about one million acres as ACECs. It will prohibit mining and petroleum drilling in the White Mountains National Recreation Area and the Steese National Conservation Area.

In addition, past federal government promises assured access for resource development in this area and others not set aside through ANILCA. The passage of ANILCA in 1980 withdrew 106 million acres of federal lands in Alaska into conservation system units. Today, Alaska accounts for 70 percent of all national park lands in the United States, as well as 53 percent of federally-designated Wilderness.

Alternative E will likely result in a violation of ANILCA

Alternative E allows for 1.7 million acres, a fraction of the EI, to be open to possible resource extraction, while recommending the other 4.8 million acres be closed to mining. This mineral extraction closure affects approximately 74% of the federally managed land in the EI area.

This action by BLM appears to be an attempt to restrict resource development and economic opportunity in the EI, and effectively withdraws an additional one million acres of land from development through a derivative of a wilderness designation.

Flawed BLM statute requirement

Lastly, RDC writes to express extreme concern with the BLM’s timing in the release of the documents, as well as the timeline for objections. The statutory requirement that prohibits the BLM from addressing the additional concerns of stakeholders is unacceptable and should be changed to better allow for stakeholder involvement.

Conclusion

RDC endorses the August 2016 comments of the Alaska Miners Association (AMA) and urges the BLM to address the detailed concerns listed by AMA.

Finally, RDC again reiterates that the issues and concerns expressed by AMA, RDC, and others must be addressed before the RMP can be finalized.

For your reference, attached are copies of RDC’s comments on the Eastern Interior Draft RMP and EIS in a letter dated April 11, 2013 and comments on Proposed New ACECs in a letter dated March 3, 2015.

Sincerely,

Resource Development Council for Alaska, Inc. 

Cc: Bud Cribley, BLM Alaska Director