Scoping Input to BLM on the Ambler District Industrial Access Project Supplemental Environmental Impact Statement

RDC Action Alert  

November 4, 2022

Submitted via https://eplanning.blm.gov/​eplanning-ui/​project/​57323/​510

Re:        Comment period for the BLM Scoping for the Supplemental Environmental Impact Statement (SEIS) for the Ambler Project

To Whom It May Concern:

The Resource Development Council for Alaska, Inc. (RDC) is writing to comment regarding the proper scope of analysis for the Bureau of Land Management (BLM) to undertake as part of a supplemental environmental impact statement (SEIS) for the Ambler Mining District Industrial Access Project (AMDIAP or Project).  This is pursuant to a recent order from the U.S. District Court for the District of Alaska (District Court).  The project is being proposed by the Alaska Industrial Development and Export Authority (AIDEA).  For the reasons that follow, BLM should keep the scope of the SEIS limited to the narrow parameters identified by the District Court. 

RDC is an Alaskan non-profit trade 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.  The AMDIAP is a proposed 211-mile road that 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 deposit rich Ambler mining district – a district rich in critical minerals.  RDC has commented several times in support of this Project and reiterates its support today.   Projects such is this are more important than ever to provide responsible development of our nation’s critical minerals in a permitting jurisdiction held to some of the highest environmental standards in the world.  

Social and Economic Benefits 

The 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 at least $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, especially with regards to “critical minerals” as designated by the U.S. Geological Survey.  For example, 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 a 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 (DMTS), a successful example of a Public-Private-Partnership working with the leading regional Alaska Native corporation and balancing local hire with a rural and subsistence way of life. Revenue sharing models set in law by the Alaska Native Claims Settlement Act (ANCSA) ensures that revenues generated as a result of the mining project accessed by the DMTS are shared with Alaska Native shareholders. The DMTS is model worth repeating for the AMDIAP and for the responsible development of Alaska’s abundant resources.  AIDEA has committed to working with all stakeholders, including landowners.  

While no specific 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.

The Ambler Project 2020 FEIS and JROD was the product of extensive environmental analysis and consultation.

Over the years, RDC has submitted several comment letters and testified in support of the Ambler Project.  RDC applauds the extensive efforts of BLM and the other joint agencies to engage in a thorough, multi-year science-based analysis of the project that culminated in a final environmental impact statement (FEIS) and Joint Record of Decision (JROD) in 2020.  BLM’s extensive analysis was in cooperation with multiple state, federal, and local cooperating agencies, with extensive public hearings, scoping meetings, and consultations, which began as early as 2015, when AIDEA first submitted its application.  BLM’s review included more than 330 days of public comment, public scoping period, and fifteen public meetings in thirteen rural Alaska village communities, including Allakaket, Huslia, Alatna, Hughes, Kobuk, Shungnak, Noorvik, Kiana, Ambler, and Evansville.  After the draft EIS was released in August 2019, BLM held another eighteen public hearings in the same village communities, Anchorage, Fairbanks and Washington, D.C.  BLM processed more than 29,000 written comments to the DEIS alone.  Consultation was also extensive: more than 52 letters to federally recognized tribes were sent to solicit input on the Project; fifteen government-to-government consultations occurred; eleven Section 106 consultation meetings occurred; and an additional eight stakeholder meetings were held.  More than thirty cooperating agency meetings were held that included representatives from Allakaket Tribal Council, Alatna Village Council, Hughes Traditional Council, Northwest Arctic Borough, Noorvik Native Community.

RDC disagrees with the Department of Interior’s subsequent decision seeking voluntary remand of the JROD from the District Court. Notwithstanding that, the District Court has now ordered BLM to perform a limited review of discrete issues through a supplemental environmental impact statement (SEIS). Specifically, the court’s order focuses on two area (1) regarding subsistence impacts under ANILCA Section 810; and (2) consultation with tribes pursuant to Section 106 of the National Historic Preservation Act (NHPA). The proper scope of BLM’s analysis should be as limited.

 With respect to this current phase to supplement that analysis with a SEIS, RDC recognizes and wants to point out that a majority of BLM’s extensive and existing analysis of the FEIS and JROD was upheld by the court.  Therefore, the supplemental analysis beyond the specific issues identified in the court order is not required nor, as a matter of law, should the entire JROD and FEIS be reopened. 

Conclusion 

After several years of intense environmental review and analysis, going above and beyond the statutory time periods for public comment on scoping, public hearings and consultations, the AMDIAP has received more than sufficient review.   RDC therefore encourages the BLM to limit the scope of SEIS to the District Court’s order and perform a prompt and timely review to expeditiously move this Project forward.  Thank you for the opportunity to comment.

Sincerely,