View RDC's Formal Comment Letter
View the Suggested Comment Letter
Comment deadline closed May 19, 2008
Overview:
The U.S. Fish & Wildlife Service (USFWS) is considering a land exchange in the Yukon Flats National Wildlife Refuge with Doyon Limited, the largest private landowner in the refuge. Created in 1980, the refuge is comprised of 11 million acres, roughly the size of Maryland. Doyon owns 2 million acres within the refuge boundary. In 2004, USFWS and Doyon tentatively agreed to the terms of a land exchange. The Department of Interior initially determined that an Environmental Impact Statement (EIS) was not required. Doyon and others, however, requested an EIS, given it would offer residents in the Yukon Flats more details on the potential impacts of the trade and potential development in the area.
Under the proposed trade, Doyon would turn over 150,000 acres rich in fish and game resources, including prime waterfowl habitat in the wet low lands of the refuge. In exchange, Doyon would receive oil and gas rights to 200,000 prospective acres. However, Doyon would have surface rights to only 110,000 of those acres, most of which is in the uplands with lesser habitat values. The remaining acreage would be reached only by directional drilling. If Doyon discovers and produces oil and gas on the lands acquired through the exchange, the Service would receive a production payment equal to 1.25% of the value at the wellhead and a commitment from Doyon to sell up to 120,000 acres more land to the USFWS. In addition, Doyon would reallocate 56,000 acres of remaining entitlement within the refuge to locations outside the refuge.
Birch Creek is the closest community to the land trade area and the Birch Creek Tribal Council and its leadership support the trade. Doyon is supportive of both the Proposed Action Alternative and Alternative 1. Detailed information on the alternatives and the overall EIS can be found at:
http://yukonflatseis.ensr.com/yukon_flats/
Action Requested:
Submit written comments to:
Yukon Flats EIS Project Office
c/o ENSR
1835 South Bragaw, Suite 490
Anchorage, AK 99508
Submit on-line comments at
http://yukonflatseis.ensr.com/Yukon_Flats/Comments.aspx
To save time, consider submitting the draft letter below, with edits of your own choosing. For those who wish to compile their own comments, please refer to the bullet points following the comment letter.
View the Suggested Comment Letter
Points to consider for your comments:
- The proposed land exchange is in the public’s best interest as it would allow the USFWS to achieve its conservation goals and consolidate land ownership.
- The exchange would allow the agency to acquire many of the highest-priority fish and wildlife habitats on Doyon lands.
- The land exchange would allow Doyon to consolidate its holdings within the refuge so it can improve the economics of drilling for oil and gas. The entire flats show favorable signs of oil and gas, but the highest petroleum potential lies under land proposed for exchange.
- The Yukon Flats could hold significant quantities of natural gas and oil. The U.S. Geological Survey offers a mean estimate of 5.5 trillion cubic feet of recoverable natural gas and 173 million barrels of recoverable oil. A recent private-sector assessment estimates the area could hold 300 million to almost 1 billion barrels of oil and 15 trillion cubic feet of natural gas. The area is potentially another energy province on the scale of Cook Inlet and could hold two Alpine-size oil fields.
- If oil and gas are discovered, many public benefits would be generated, including billions of dollars pumped into Alaska’s economy. State revenues would grow and new energy supplies would flow into the American market.
- The land exchange and subsequent discovery of energy resources would allow for the creation of a long-term economic base in an economically-disadvantaged part of rural Alaska. Development would create 1,000 or more good paying jobs. It would help fulfill ANCSA’s promise to enhance social and economic well-being of Native people, creating jobs and other opportunities for Doyon shareholders.
- Other benefits include village and regional Native corporation revenue sharing under ANCSA, which means more revenue statewide for these entities.
- The land exchange does not include the biological heart of the refuge.
- If all of the areas under the exchange turned into development opportunities, less than one percent of the Yukon Flats would be disturbed.
- Doyon will proceed with development opportunities, with or without the land exchange. If there is no exchange, there is increased potential for development in high value habitat areas of the refuge. With the trade, there is more land for Doyon to explore, land considered low in habitat value with little subsistence use.
Comment deadline closed May 19, 2008
