Resource Development Council

RDC Comment Letter:
Long Range Transportation Plan for Alaska Federal Lands

April 11, 2012

Mr. Steve Hoover
Attn: Alaska LRTP
4601 DTC Blvd Ste 700
Denver, CO 80237

(submitted electronically through

Dear Mr. Hoover:

The Resource Development Council for Alaska, Inc. (RDC) writes to provide feedback on the draft Long Range Transportation Plan (LRTP) for Alaska Federal Lands.

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 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.

RDC understands that federal legislation requires land management agencies to conduct long range transportation planning, and that this LRTP brings Alaska’s federal lands into compliance with such legislation. Nonetheless, we question the purpose of this document, and we stand concerned the document does not adequately address the multiple-use potential of Alaska’s federally-owned lands, resulting in no meaningful transportation improvements to the state.

RDC believes a very deliberate and measured approach must be taken when planning for transportation on and across federal lands in Alaska. In specific, we ask that any LRTP address the following components:

Alaska’s unique situation
Close to 59% of Alaska’s 365 million acres are federally-managed, most of which is undeveloped land with little or no infrastructure. The sheer size of this expanse is only one of the factors that differ Alaska from other U.S. states. Alaska has challenging geography, an extreme climate, and species not present anywhere else in the nation. It has aboriginal peoples who have inhabited the land for thousands of years, and have preserved their way of life to sustain for thousands more. It has a significantly ‘younger’ history with the nation, having only entered into statehood in 1959. Needless to say, there are many characteristics of Alaska that cannot be managed using techniques applied to other states.

While the LRTP Executive Summary acknowledges that Federal Land Management Agencies (FLMAs) understand the unique nature of travel in Alaska, there is little attention paid to this fact in the remainder of the document.

Transportation by Alaska residents includes air, marine, rail, all-terrain vehicle, automotive, and even dogsled. These modes vary by season and location, and are restricted by the fact that Alaska’s transportation facilities are both scarce and limited in services. In fact, the last major road built in Alaska was the Parks Highway in 1971. Most Alaskan communities are inaccessible by road or rail, including our capital city, Juneau. Any LRTP should address development of infrastructure and increased road access through and across Alaska lands, regardless of ownership.

Resource and Community Development
RDC is concerned that the LRTP document is largely focused on recreational activities and does not address transportation needs related to resource development and the development of Alaska’s communities. While the plan does recognize that Alaska’s federal lands contribute to the state’s tourism industry, it fails to recognize the lands also provide for the development of oil and gas, mining, fishing, and timber resources, as well as hunting, construction of new facilities in local communities, and more.

Federally-owned lands in Alaska contain areas vital to the state and the nation’s economy, and access to and across these areas is paramount to any future development. The National Petroleum Reserve (NPR-A), designated specifically for oil and gas development and thought to contain at least one billion barrels of oil, the Dalton Highway and Trans-Alaska Pipeline System (TAPS) corridor, and a transportation corridor that would connect the Chukchi Sea to existing infrastructure on the Central North Slope should be thoroughly addressed in the LRTP. Timber harvesting is recognized in the U.S. Forest Service Plan, while ample opportunities exist for responsible development on this renewable resource. Also, many federal lands in the state have high mineral potential, advanced exploration projects, and even operating mines located on them, and need to be given careful consideration to maximize development opportunities.

Access to Alaska’s resources is key to the advancement and sustainability of Alaska’s economy. Alaska’s resource potential in oil and gas, minerals, and timber convinced Congress that this northern land, disconnected from the contiguous 48 states, could sustain itself economically and therefore would be admitted to the Union. Just as in the Lower 48 states, an efficient and well-developed surface transportation network is essential to the development of Alaska’s natural resources and its economy.

Federal land guarantees outlined in ANCSA and ANILCA, RS2477
The LRTP appears to have overlooked access routes guaranteed by the Alaska Native Claims Settlement Act (ANCSA) Section 17(b), which provide access across and through ANCSA lands to lands managed both federally and by the State of Alaska. These access routes are managed by federal agencies, and their exclusion from the LRTP is troubling.

The emphasis on lands with “Wilderness Characteristics” is of grave concern to RDC. Alaska is indeed scenic, even in urban areas, but that does not merit any consideration to designate lands as Wilderness. Passage of the Alaska National Interest Lands Conservation Act (ANILCA) set aside millions of acres in Alaska protected as Wilderness and provided a ‘no more’ clause guaranteeing no further land withdrawals. To determine further acreage of land as having “Wilderness Characteristics” is inconsistent with the ANILCA promise and jeopardizes the multiple-use management of Alaska lands. Attached to these comments is the RDC-issued publication “Who Owns Alaska,” which outlines ownership of Alaska’s lands, history and outcome of Alaska land legislation like ANILCA and ANCSA, Conservation System Units, and more. RDC encourages FMLAs to consider this document when developing the LRTP.

Also, it appears as though the entire planning document ignores Revised Statute 2477, providing state-claimed routes across federal lands. These routes provide access for a variety of uses currently, and may do so in the future, therefore should be noted and honored in the LRTP.

While briefly outlined in the appendix materials, the plan should more explicitly acknowledge the unique provisions of ANILCA that Congress included in the final legislation in order to help mitigate the impacts of Alaska’s vast land withdrawals and Conservation System Units. Title 11 of ANILCA addresses access for transportation and utility corridors. The LRTP is an opportunity to educate federal employees, and the general public, of these unique provisions.

Cooperating agencies and stakeholder input
The LRTP was produced by several FMLAs, as well as the Alaska State Department of Transportation and Public Facilities (DOT). While involvement by DOT is critical, we question why the State’s land management agency, the Department of Natural Resources (DNR), was not given a seat at the table, as well as local/municipal governments and Native Corporations. All of these entities are important landowners in Alaska and their input should be included, and in fact highly regarded, in the LRTP.

In conclusion, RDC wishes to reiterate its questioning of the plan’s purpose, while understanding that a plan will likely proceed. If so, we ask the plan be revised to address the aforementioned concerns and suggestions, and that all future planning be done in collaboration with state, local, and Alaska Native entities. Furthermore, RDC believes that such a complex LRTP should be nothing if not thorough, therefore the period for submitting comments on the draft LTRP should be extended so that all affected parties and stakeholders have an opportunity to comment.

Thank you for the opportunity to comment.

Resource Development Council for Alaska, Inc.

Cc: Senator Mark Begich
Senator Lisa Murkowski
Congressman Don Young
Governor Sean Parnell
Commissioner Dan Sullivan, Alaska Department of Natural Resources
Commissioner Mark Luiken, Alaska Department of Transportation