July 7, 2008
Ms. Alice Allen
Glacier Ranger District
Girdwood, AK 99587-0129
Re: Spencer Glacier Mineral Material Project
Dear Ms. Allen:
Thank you for the opportunity to submit comments on the Spencer Glacier Draft Environmental Impact Statement for the Spencer Glacier Mineral Material Project. The Resource Development Council (RDC) is writing to express its support for the proposed action, Alternative A, with modification.
RDC is a statewide, non-profit, membership-funded organization founded in 1975. The RDC membership is comprised of individuals and companies from Alaska’s oil and gas, mining, timber, tourism, and fisheries industries, as well as Alaska Native corporations, local communities, organized labor, and industry support firms. RDC’s purpose is to link these diverse interests together 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 strongly supports mineral extraction from the Spencer Glacier area. The site contains high quality deposits of both quarry rock and gravel aggregate that are in high demand in the Southcentral Alaska region. The site is located immediately adjacent to the Alaska Railroad and has provided these materials for nearly 100 years.
The extraction of minerals would be an appropriate multiple use in an area where both recreation and mining has historically occurred in a compatible fashion. This area is not new to development, having been a quarry since the early 1900s. The Chugach National Forest Revised Land and Resource Management Plan established direction to manage this area in a manner that facilitates both recreation development and mining activities. The forest plan was designed to balance the interaction between recreation and mining at Spencer. We agree with the Forest Service that mineral extraction can occur in this area in a way that is compatible with recreational uses. We also agree that the area can be reclaimed in a manner that will benefit future recreational uses.
RDC supports Alternative A as it will provide the maximum total acreage available for mining. A larger land base will provide the operator with greater flexibility in developing the resource. In addition, Alternative A contains the highest potential volume of mineral resources, an important consideration in the economic feasibility of any future operation, which must invest in expensive infrastructure to develop the resource.
However, RDC encourages several modifications to Alternative A to improve the economics of future mining in the area. We believe these modifications will not have significant adverse impacts on recreational uses. Proposed modifications include:
- Increasing annual production from 250,000 tons of gravel and 20,000 tons of rock to a total of one million tons. The increased production is important to economically amortize infrastructure costs, as well as allowing for more efficient utilization of rail transportation. Larger annual production would help the operator meet local demand for the resource at a competitive rate. The estimated daily production would need to be modified to accommodate higher annual production. The number of trains per week would also need to be increased, as well. It is likely that without this increase in volume, it would not be economically feasible to develop the area.
- Mining below the water table should be allowed. This is a preferred method of gravel extraction across much of Alaska and the Lower 48, allowing for maximum utilization of the disturbed area. This method of operation would allow for a larger volume of gravel to be extracted per acre while reducing the overall footprint of mining. Moreover, the extraction of gravel below the water table, with proper planning, can enhance habitat and recreational opportunities after mining has ended. Allowing for mining below the water table would increase the likelihood of the Forest Service receiving maximum benefit from any future mineral operation in the area.
- Seasonal mining restrictions prohibiting operations from November 1 to April 30 should be eliminated to allow for greater flexibility in mining the resource. Such flexibility would allow for an operator to transport material directly to customers as it is needed, minimizing handling and reducing costs. Greater flexibility would also allow for the operator to take advantage of periods of good weather and to respond to immediate market demand.
- Blasting restrictions and daily hours of operation should be modified. Blasting operations should be expanded beyond the current spring and fall seasonal windows. The timing of blasting can be modified to mitigate potential conflicts on recreational users. For example, blasting could be scheduled at the same time each day and restricted to days when recreational use is low. With regard to daily hours of operation, proposed restrictions are unnecessary and could potentially compromise the economics of future operations. Removing daily operating restrictions would give an operator greater flexibility in work schedules and improve the economic feasibility of the operation.
While RDC strongly supports mineral extraction in a responsible manner from the Spencer Glacier area, we are aware of potential conflicts with existing placer miner claims. RDC encourages the holders of existing mining claims, the Forest Service and the material extraction operator to reach a cooperative agreement that will facilitate maximum resource production. We believe coordination with existing mining claims can occur so as to mitigate potential conflicts and impacts.
Thank you for the opportunity to comment on this important project.
Resource Development Council for Alaska, Inc.