June 13, 2019

Ms. Jorjena Barringer, Project Manager
BLM Anchorage Field Office
Attention – BSWI RMP
4700 BLM Road
Anchorage, Alaska 99507

Via email to [email protected] 

Dear Ms. Barringer:

The Resource Development Council for Alaska, Inc. is writing to provide brief comments on the Bering Sea – Western Interior (BSWI) Draft Resource Management Plan (RMP).

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.

RDC is writing in support of Alternative D as it is the alternative most consistent with the intent of the Federal Land Policy and Management Act (FLPMA), the Alaska National Interest Lands Conservation Act (ANILCA), the Alaska Land Transfer Acceleration Act (ALTAA), the Alaska Statehood Act and Alaska Native Claims Settlement Act (ANCSA). Alternative D “provides the fewest management restrictions at the planning level and the most flexibility at the project-specific implementation level.”  

Further, Alternative D relies on existing federal laws and National Environmental Policy Act (NEPA) than alternatives B and C, to determine how best to manage multiple uses. This is most appropriate as much of the BLM land in the planning area is currently used primarily for hunting and fishing, with limited existing resource development. Other than the current Donlin Gold project, no other major resource development projects are currently pending.

With regard to Areas of Critical Environmental Concern (ACECs), RDC continues to have significant concerns about the intention of BLM’s actions to apply ACECs, particularly in the flawed Alternative B. 

RDC is concerned our previous comments in letters regarding the ACEC application in BSWI have been largely ignored. RDC has expressed concern that ACECs 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 (RNA) designations are unwarranted as existing state and federal regulations provide protection for the resources that were used to initially justify the designations.

As a reminder, past federal government promises assured access for resource development in this area and others not set aside through ANILCA. Alaska accounts for 70 percent of all national park lands in the United States, as well as 53 percent of all federally-designated Wilderness.

Much of the actions to apply ACECs appear to be blanket closures to resource development, particularly mineral entry, and lack justification for the closure. 

In conclusion, RDC urges BLM, as a multiple-use agency, to select Alternative D. RDC applauds BLM for offering Alternative D as it is a priority of RDC to advocate for increased access to and across public lands for resource and community development. Thank you for the opportunity to provide brief comments. 

Sincerely,

Resource Development Council for Alaska, Inc.