Comments in support of Alternative A for the Ambler Draft Environmental Impact Statement (DEIS)

October 29, 2019                                                                                                            

Bureau of Land Management
Comment period for the Draft Environmental Impact Statement and ANILCA Section 810 Evaluation
Submitted via

National Park Service
Comment period for the Draft Environmental and Economic Analysis (EEA)
Submitted via [email protected]

Re: Comments in support of Alternative A for the Ambler Draft Environmental Impact Statement (DEIS)

To Whom It May Concern:

The Resource Development Council for Alaska, Inc. (RDC) is writing to comment in support of Alternative A in the Draft Environmental Impact Statement (DEIS) and Alaska National Interest Lands Conservation Act (ANILCA) Section 810 Evaluation, and the Draft Environmental and Economic Analysis (EEA) for the Ambler Mining District Industrial Access Project (AMDIAP). The project is being proposed by the Alaska Industrial Development and Export Authority (AIDEA). 

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 one of RDC’s priorities to encourage the responsible development of Alaska’s natural resources, and to encourage new exploration and projects. Alternative A, the 211-mile-long gravel access road in the southern Brooks Range foothills, would provide industrial access to the Ambler Mining District.

The 211-mile road will cross state (61%), Native corporation (15%), and federal lands (24%). The planned route is the shortest route between the existing Dalton Highway and the rich Ambler mining district. Further, according to AIDEA, the planned route minimizes impacts to wildlife, wetlands, the environment, and cultural and subsistence areas. 

Social and Economic Benefits

The road project will offer access to additional projects that will create much needed job opportunities which will likely lead to reduced out-migration, helping to maintain rural schools and culture, including traditional ways of life. It is in a region of Alaska where few other economic opportunities exist. 

In addition to jobs, development of the planned road includes access to fiber optic for a future mine, which communities along the way will have the option of tying into it for educational, medical, and other uses. 

The estimated economic benefits of development are expected to be $1.3 billion to State and local government, upwards of $17 billion in labor income for road and mine development, creating 14,000 jobs. If the road is built, it will ultimately be paid for by private money through a financing plan.

Access to Much Needed Resources

According to the BLM, the road is designed as an industrial access road to provide surface transportation to the Ambler Mining District. The road is being permitted as a private road and would be closed to the public.

The resources in the Ambler Mining District could be used for the growing worldwide demand for the products and technology related to renewables and the green economy. The deposits could be beneficial for increasing Alaska, and America’s, technology and energy resource materials.

America’s foreign mineral dependence has increased significantly in recent years. In 2018, the U.S. imported at least 50 percent of its supply of 48 mineral commodities, including 100 percent of 18 of them. U.S. mineral security is an emerging major issue as domestic vulnerabilities to foreign supply restrictions have become a rising threat to our economy, competitiveness, and national security. 

With the growing worldwide consumption and dependence upon technical products (including electric vehicles) powered by critical minerals and the expanding demand for renewable energy technologies, the Ambler Mining District has the potential to reduce our dependence on foreign suppliers and generate economic activity for Alaska, as well as revenues for state and local governments. 

This project is modeled after the DeLong Mountain Transportation System, a successful example of a Public-Private-Partnership. However, when a road is formally proposed, it will be important for all stakeholders to provide input, including land owners. 

Mining and the Alaskan Economy

RDC knows resource development projects in Alaska can be done responsibly, with a strong focus on protecting the environment, including cultural activities and wildlife, providing well-paying jobs, many of which require training and offer a lifetime of opportunity, and improving the long-term economic future for Alaska.

The Alaskan economy is dependent on natural resource development and will continue to be indefinitely. Article VIII, Section I of the Alaska Constitution mandates “the settlement of Alaska’s land and the development of its resources by making them available for maximum use consistent with the public interest,” to encourage economic prosperity for Alaska’s peoples.

Alaska, and Alaskans alike, depend on the development of natural resources to diversify and support the economy. Further, economic opportunities in rural Alaska are often scarce. The lack of family wage jobs in many regions has resulted in an outmigration of Alaska Natives from the lands their ancestors have lived on for thousands of years.

Today, the mining industry in Alaska pays an average wage of over $100,000 per year. Some of these jobs require technical skills and often offer training that can be used for similar or future jobs.

Alaska utilizes a well-established permitting and review process, with multiple opportunities for public input, and review by local, state, and federal agencies. RDC believes the permitting process is the best place to make decisions about the merits of development projects in Alaska. 

Alaska has enjoyed the benefits of mining for well over 100 years, with the last several decades seeing new innovations and advancements for protecting the environment. Alaska has stringent regulations to protect its lands and waters. As the Alaskan economy is dependent on natural resource development, including mining, it is vital to have predictable and efficient federal and state permitting processes that are based on sound science. 

While no mine has been proposed at this time, there will be many opportunities for public input and participation should one be advanced for permitting in the future. Further, the State of Alaska Department of Natural Resources enforces stringent regulations overseeing mining activities statewide that effectively protect the environment, wildlife, and human health.


RDC urges the BLM to select Alternative A, and to expeditiously move this project forward. Thank you for the opportunity to comment.