February 5, 2007
Bureau of Land Management, Anchorage Field Office
Bay Draft RMP / EIS
6881 Abbott Loop Road
Anchorage, AK 99507
To Whom It May Concern:
The Resource Development Council (RDC) appreciates the opportunity to provide comments on the Bay Area Draft Resource Management Plan and Environmental Impact Statement. RDC supports Alternative B, which would provide maximum access to oil, gas and mineral resources.
RDC is a statewide non-profit business association comprised of individuals and companies from Alaska’s oil and gas, mining, forest products, fisheries and tourism industries. RDC’s membership also 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.
The planning area is rich in mineral potential and Alternative B would encourage responsible resource development in an economically-challenged region. It is the most consistent alternative within the fundamental principles of the Alaska Native Claims Settlement Act (ANCSA), the Alaska National Interest Lands Conservation Act (ANILCA) and the Alaska Statehood Act. It was the intent of Congress in 1959 that the new State of Alaska become self sufficient, and its natural resource potential has long been recognized as key to fulfilling that intent.
While Alternative D may be viewed as the option that strikes a balance between development and preservation interests, ANILCA set that balance through the withdrawal of more than 100 million acres across the state into Conservation System Units (CSUs). In the planning area itself, at least 43 percent or 9.7 million acres is already permanently closed to most mineral development. Of the federally-managed lands, only 1.4 percent or 152,746 acres are open to locatable mineral entry. Most federal lands in the planning area have been closed since 1971 through ANCSA and the establishment of 17 (d) (1 and 2) withdrawals.
BLM should honor the “no more” principle of ANILCA which implied no more administrative or legislative set asides of federal lands in Alaska. RDC believes Alternative D compromises that principle. New restrictions and closures of significant portions of the region to mineral entry is not necessary since the existing regulatory and permitting process provides extensive protection to our lands, wildlife and other resource users.
Specifically, RDC urges the BLM to complete the land transfer process and to lift the ANCSA 17 (d) (1) withdrawals. RDC opposes the establishment of additional “Areas of Critical Environmental Concern (ACEC)” such as the 62,863-acre Carter Spit ACEC, and Visual Resource Management Level III setbacks. ANILCA specifically created very large CSUs, so as to incorporate buffers inside the units. These buffers stand as an extra layer of protection between the heart of a unit and the surrounding lands outside its boundaries.
The Bay planning area is under-explored for mineral resources due to land closures and poor access. Modern exploration techniques could lead to successful exploration ventures in the region if the lands are open to mineral entry. Alternative B would do the most to facilitate new discoveries and economic activity, providing much needed jobs to local residents.
In summary, Alternative B is the best option for encouraging responsible resource development and new economic opportunities in this economically-depressed region. Given the significant amount of land already closed to development through state and federal CSU classifications, Alternative B strikes a reasonable balance between development and preservation, especially when put into the existing regulatory and permitting framework. Moreover, ever-evolving technology has dramatically reduced the footprint of development.
RDC supports Alternative B and encourages BLM, as a multiple use agency, to set the stage for responsible resource exploration on its lands in the planning area.
Sincerely,
Resource Development Council
