June 9, 2021

Submitted via e-mail to: [email protected]

Re: Comments on Central Yukon Draft Resource Management Plan and Environmental Impact Statement 

Dear Ms. Ethun:

The Resource Development Council for Alaska, Inc. (RDC) is writing to comment on the Central Yukon (CY) Draft Resource Management Plan (RMP) and Environmental Impact Statement (EIS), issued in December 2020. 

RDC is a statewide trade association comprised of individuals and companies from Alaska’s fishing, forestry, mining, oil and gas, and tourism 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 encourage the exploration and development of Alaska’s natural resources, including mineral and energy resources. Therefore, RDC supports Alternative D of the CY RMP, which allows for the most resource development potential of all the Alternatives. Further, Alternative D most closely adheres to the “multiple use” mandate of the Bureau of Land Management (BLM).

RDC continues to urge the BLM to incorporate resource management, such as opening the area to resource development, increased access for exploration, mineral leasing, mining, and oil and gas development. Much of Alaska’s federally managed lands are closed to responsible resource development, and Alternative D provides the greatest opportunities for public access, including potentially necessary access to State and private projects (primarily land owned by Alaska Native Claims Settlement Act [ANCSA] corporations), and provides opportunities for overland access to remote communities. 

Benefits of maintaining multiple-use areas
The RMP will provide future direction for approximately 13 million acres of BLM-managed land in central and northern Alaska, including lands surrounding rural communities, the Dalton Highway Corridor, and the central Yukon River watershed, and therefore it is vital BLM plan for multiple uses. 
 
RDC maintains that multiple uses should include mining (exploration, leasing, development) for oil and gas, coal, and minerals, as well as recreational and other potential uses. With less than one percent of Alaska in conventional private ownership, access should be available on other lands, including public lands. Resource development in the area could provide economic benefits to the region, as well as improved or added infrastructure and access to areas for multiple use. RDC encourages the BLM to recognize that multiple use activities often incorporate mitigation measures, and that a one size fits all plan should not be considered. 
 
Rare Earth Elements are a much-needed commodity
Alaska contains known and likely unknown deposits of Rare Earth Elements (REEs). Many of these REEs are imported to the United States, often from countries with lesser environmental regulations. According to the Mineral Commodity Summaries 2021 report by the U.S. Geological Survey, the U.S. depended on imports of 50-100% of needs for 46 minerals in 2020, some of which are found in Alaska. Keeping areas open to mining in Alaska not only provides the opportunity for future responsible resource development, it also may improve national security.
 
Therefore, areas like the Central Yukon that have not been fully inventoried, should be open to mineral exploration and development, and should be mapped by the U.S. Bureau of Mines, and listed as favorable for mineral discoveries. RDC asserts that the potential for mining in the area should be fully considered and designated as such in the RMP.
 
Concerns with proposed ACEC designations and general objections to ACECs
RDC is concerned Areas of Critical Environmental Concern (ACECs) add an unnecessary layer of “protection” to BLM managed public land that already has protections and restrictions in place. RDC discourages additional land use restrictions inhibiting access to areas in Alaska and encourages the BLM not to adopt unwarranted ACEC designations.
 
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.
 
RDC is further concerned the ACECs proposed lack scientific basis, and RDC offers general objections to ACECs as they are unwarranted. 
 
Conclusion
RDC urges caution against unnecessary duplication and potential conflicts in the RMP with existing State and Federal laws and regulations for environmental permitting and resource management, and encourages the BLM to simplify the final plan. 
 
In addition, RDC urges the BLM to carefully consider the comments of the Alaska Miners Association (June 7, 2021). The issues and concerns expressed by AMA, RDC, and others need to be addressed before the RMP can be finalized. Thank you for the opportunity to comment.

Sincerely,
Resource Development Council for Alaska, Inc.