Proposed ACECs in BLM’s Eastern Interior RMP/EIS

March 3, 2015

Eastern Interior Field Office
Attn.: Eastern Interior RMP
Bureau of Land Management
1150 University Avenue
Fairbanks, AK 99709

Via email to EasternInterior@blm.gov

Re: Proposed ACECs in BLM’s Eastern Interior RMP/EIS

To Whom It May Concern:

The Resource Development Council for Alaska, Inc. (RDC) is writing in response to the Bureau of Land Management’s (BLM) proposal for two Areas of Critical Environmental Concern (ACECs) in the Draft Eastern Interior Resource Management Plan (RMP)/Environmental Impact Statement (EIS).

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 resource and community development. RDC urges the BLM to implement the “no action” alternative, Alternative A.

RDC is concerned the proposed ACECs will add an unnecessary protection of BLM managed public land that already has protections and restrictions in place.  Moreover, some of the existing ACEC and Research and Natural Area (RNAs) designations in Alaska are unwarranted as existing state and federal regulations provide protection for the resources that were used to initially justify the designations. For example, many of the existing ACECs were established to protect fish habitat, despite numerous existing state and federal laws and regulations that adequately protect fish habitat. RDC discourages additional land use restrictions inhibiting access to areas in Alaska.

In April 2013, RDC commented on the Eastern Interior RMP/EIS, discouraging the BLM from listing additional lands as ACECs, designating Wild and Scenic Rivers, or adding more Wilderness. Instead, RDC encouraged the BLM to incorporate responsible resource leasing, mining, and oil and gas development. Much of Alaska’s federally managed lands are closed to responsible resource development, and the RMP/EIS should include provisions to open more areas to resource development activity instead of proposing unwarranted ACECs.

In addition, past federal government promises assured access for resource development in this area and others not set aside through the Alaska National Interest Lands Conservation Act (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.

Fortymile Proposed ACEC
The proposed reconfiguration of the Fortymile ACEC is unwarranted and precludes activities, likely with no added benefit to the environment and wildlife. The proposal lacks science, and specifically targets mineral entry and leasing without justification. RDC asserts that any mineral entry and leasing will be required to provide a Plan of Operations to explore and develop in the area. Only at the time that a proposal or Plan of Operations be submitted should mitigation be considered and commented on by stakeholders.

Mosquito Flats Proposed ACEC
The proposed Mosquito Flats ACEC is not necessary and also unwarranted for the same reasons as the Fortymile listed above. Additionally, the proposal lists “the amount and rate of degradation” to the area as a reason for ACEC designation, however does not explain the cause of the “degradation,” yet closes the area to mineral entry.

Native Corporation Land Access
Private land owners, like Doyon Limited, should not have access to inholdings blocked or further restricted by unnecessary BLM land designations. Access to native corporation lands has been promised in the “no more” clause of ANILCA, and an ACEC prohibiting or restricting access would violate ANILCA.

Lastly, RDC urges the BLM to fully address the comments and concerns submitted by the Alaska Miners Association (AMA) (March 3, 2015).

Thank you for the opportunity to comment.

Sincerely,
Resource Development Council for Alaska, Inc.