Resource Development Council

RDC Comment Letter:
Opposition to Proposition 204: Tangle Lakes Game Refuge

February 15, 2007

Alaska Department of Fish and Game
Boards Support Section
PO Box 115526
Juneau, AK 99811-5526

Attention: Bog Comments

To Whom It May Concern:

The Resource Development Council (RDC) is writing to express its strong opposition to Proposition 204, which calls for the Board of Game to recommend to the legislature the establishment of a wildlife refuge north of the Denali Highway and west of the Richardson Highway. The intent of this proposal is to stop hard rock mining in an area selected by the State for its high mineral potential.

RDC is a statewide organization made up of all resource sectors, business associations, labor unions, Native corporations, tourism providers, local governments and individuals.  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 area proposed for refuge status is covered with scores of mining claims held by various companies and individuals. Mining has occurred there in the past, as well as ongoing exploration activities. There have been no significant adverse impacts on wildlife from these activities.

Alaska has one of the most comprehensive regulatory and permitting systems in the United States for protecting the environment and our wildlife and fishery resources.  Any project proposed for the region will be thoroughly scrutinized by regulators through Alaska’s extensive permitting process and the

National Environmental Policy Act. In fact, major development projects typically require more than 50 state and federal permits.

The specific area proposed for refuge status has been managed for multiple use and open to mineral entry for decades. The holders of the numerous state mining claims in the area possess valid and existing rights that must be recognized and not usurped by a refuge intentionally placed over the area, effectively blocking mineral exploration and development. Any project must be subject to reasonable regulations and should be allowed to proceed through the permitting process to determine if it is environmentally sound.  The process should not be derailed by a refuge designation that essentially changes the rules in mid-process.

A major concern of RDC’s is the precedent Proposal 204 sets, not just for one particular project or industry, but for any individual or company working to follow the rules to develop a project in Alaska. Proposal 204 is bad public policy. It could have a chilling effect on future investment in mining and other resource industries.  Investors would look at Alaska as a riskier place to do business because of the potential for government to change or add new land use designations following new discoveries.

More than 60 percent of the federal lands in Alaska and 40 percent of the total acreage in Alaska are set aside as Conservation System Units. In addition, the State has a vast park and refuge system, the largest in the nation. Combined, these State and federal lands severely restrict development and access is minimal.

Proposal 204 should be rejected.  Thank you for considering our comments.


Resource Development Council