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Comments in Support of the Ambler Site Specific Plan
April 1, 2022 Submitted electronically: [email protected] Nina Brudie, Land Use Planner Re: Ambler Road Site Specific Plan Dear Ms. Brudie: The Resource Development Council for Alaska, Inc. (RDC) is writing to comment in support of a site specific plan (SSP) on state-owned and state-managed lands to construct a road for the Ambler Access Project (AAP). 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 mining, oil and gas, forest products, tourism and fisheries industries. RDC’s membership includes Alaska Native Corporations, including regional as well as village 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. Approval of an SSP for the AAP fits that that criteria. The AAP would provide much needed access to the state’s Ambler Mining District. This access was guaranteed more than forty years ago with the passage of the Alaska National Interest Land Claims Act (ANILCA). It is time for the State to gain the needed access for this remote, but resource rich, region. The proposed 211-mile road will cross state (61%), Native corporation (15%), and federal lands (24%). Of this route, approximately 125 miles are on lands managed by the State of Alaska Department of Natural Resources (DNR). 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. This project is modeled after the DeLong Mountain Transportation System, a successful example of a Public-Private-Partnership. The RDC supports access to the Ambler mining district, as well as support for seeing any proposed projects, such as mining, be allowed to go through the permitting process. This includes support for AIDEA’s application for a SSP to facilitate access to the Ambler Mining District. Social and Economic Benefits 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 America’s foreign mineral dependence has increased significantly in recent years. In 2022, the U.S. Geological Survey (USGS) released a list 50 critical mineral needed domestically for economic and national security. In 2018, for example, 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. Mining and the Alaskan Economy 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. We acknowledge that there are special interests that oppose further development of mined materials in Alaska and elsewhere. However, mineral development in Alaska could ultimately prove indispensable as forecasts indicate our nation’s mineral demands will increase. The demands will continue to be satisfied, often through the use of imported minerals, when instead the resources should be developed and produced here in Alaska where operations are strictly regulated and best management activities are employed to avoid and minimize impacts. Approving the SSP to this district is especially important now in light of geopolitical pressures overseas, including a global pandemic and the Russia-Ukraine conflict. The Biden Administration’s recent announcement to use the Defense Production Act to secure domestic production of critical minerals, including many known to have robust deposits in the Ambler region, provides the opportunity to realize the full potential of the Ambler mining district. This will allow environmentally responsible domestic production of critical minerals much needed for the development of our national security, and preservation of domestic critical infrastructure and clean energy without having rely on foreign sources for minerals known to exist in Alaska, including graphite, cobalt, manganese and more. 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 (DNR) enforces stringent regulations overseeing mining activities statewide that effectively protect the environment, wildlife, and human health. Conclusion Sincerely, RDC
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