April 23, 2010
Mr. Ray Burger
Division of Mining, Land & Water
Resource Assessment and Development
550 West 7th Avenue, Suite 1050
Anchorage, AK 99501-3579
Re: Susitna Matanuska Area Plan
Dear Mr. Burger:
The Resource Development Council Development Council (RDC) appreciates the opportunity to comment on the draft Susitna Matanuska Area Plan. RDC’s comments begin with the following premise: the plan should implement the state’s constitutional and statutory policies to develop its resources, making them available for maximum use, and consistent with the overall public interest. The planning area has vast natural resources, including timber and minerals, and responsible development of these resources would diversify and expand the local and state economy, create new jobs and generate additional government revenues.
RDC is a statewide 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 governments, organized labor and industry support firms. Our 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.
In addition to making natural resources available for maximum use, the plan must ensure resource management allows for the sustained yield of renewable resources such as timber harvesting, that environmental concerns are balanced with development opportunities to support the local and state economy, and that public access to state land is provided. Moreover, the plan must protect valid existing uses and rights and preserve multiple use resource development opportunities on lands most suitable for development.
Extensive forest resources exist within the planning area. In fact, approximately 685,000 acres have been classified “Forestry” in this plan. RDC supports designating forestry as the primary use on these lands. Considering the fact that trees are a renewable resource and that the region and state economy would benefit from a more diverse economy, the plan should encourage the sustained-yield harvest of these lands. Such harvests would also improve forest health and vigor.
Harvesting timber resources in the Susitna Valley on a sustained yield basis would provide for important economic opportunities and stability in the forest products industry. A critical factor for such stability is the designation of large blocks of forest lands for timber harvesting, which this plan proposes.
Moreover, the plan recommends consideration be given to the creation of a state forest in the planning area. RDC supports this concept of a “working forest” as it would provide a more vigorous approach to the management of forest stands and represent a long-term commitment to maintaining a significant timber supply. A working forest should emphasize active management of forest lands to provide wood for commercial and personal uses.
Another factor in building stability in the forest products industry is a reasonable regulatory and permitting regime that allows for economic timber sales. In our view, there is no need for additional, restrictive standards beyond what is already in place under current riparian protections and state law. As a result, the plan should not impose additional requirements on forest harvesting.
The state should continue to make available to public and private users sufficient, suitably located materials sites to meet long-term economic needs for material resources. The gravel industry is a major component of the regional economy and is key to affordable residential and commercial construction. The new plan should encourage the development of new material sites, not hamper such efforts.
Areas considered to have mineral potential and for which mining is considered an appropriate use, should remain open to mineral development. The plan should not create any new mineral closing orders beyond those imposed by the 1985 plan. In order to preserve future development opportunities and expand the economy, all remaining state-owned lands outside the 1985 closures should remain open to mineral entry.
Oil and Gas Resources:
Oil and gas resources are likely present within the planning area. The land use designations of the plan are multiple use in character and should not preclude future oil and gas development. As with development of forest and mineral resources, new oil and gas exploration, development and production would enhance the region’s economy and create new jobs.
While coal potential within the planning area is generally considered low to moderate, recent advances in technology and changes in the economics of extraction may increase this level to high in those areas where coal is buried at depth. This plan should not impose requirements on coal exploration and extraction beyond those cited in statute and regulation. All areas, except those within areas closed to such activity in leg islatively designated areas, should remain open to coal leasing, exploration, development and extraction.
Thank you for the opportunity to submit comments on the Susitna Matanuska Area Plan.
Resource Development Council for Alaska, Inc.