December 1, 2017

Ms. Judith Bittner
State Historic Preservation Officer
Office of History and Archaeology
Alaska Division of Parks and Outdoor Recreation
550 West 7thAvenue, Suite 1310
Anchorage, AK 99501

Re: Ch’u’itnu Traditional Cultural Landscape Nomination

Dear Ms. Bittner:

The Resource Development Council for Alaska, Inc. (RDC) is writing to express its opposition to the listing of the proposed Ch’u’itnu Traditional Cultural Landscape (CTCL) in the National Register of Historic Places (NRHP). RDC has serious concerns regarding the nomination and believes the listing would set a troubling precedent across Alaska and America. It could be used to hinder and potentially block community, village, and resource development projects, including needed infrastructure in Alaska and elsewhere.

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.

Although proponents of a listing claim it would not mean limitations would be placed on a property, landowners and project sponsors elsewhere have reported serious impacts, including costly delays, increased uncertainty in the permitting process, and litigation – all of which severely complicate and hinder projects from moving forward.

At a time when Alaska needs to grow and diversify its economy, the Ch’u’itnu nomination could ultimately result in the lock-up of an entire Alaska watershed of private and State land, potentially blocking future infrastructure, oil and gas, and mineral development. RDC and many of its members are concerned the Ch’u’itnu proposal could be used as a model across the nation to further extend the National Environmental Policy Act process and put broad swaths of land under a designation which could jeopardize community and resource development.

In conclusion, RDC is opposed to listing the CTCL on the NRHP. The proposed CTCL is not a “property” or “district” which meets the criteria justifying listing under the National Historic Preservation Act. 

RDC appreciates the opportunity to provide comments on the Ch’u’itnu nomination, which we believe poses significant ramifications for community infrastructure projects and responsible resource development in Alaska and other states. 

Sincerely,

Resource Development Council