April 11, 2013
Bureau of Land Management, Fairbanks District Office
1150 University Avenue
Fairbanks, AK 99709-3844
Re: Eastern Interior Resource Management Plan and Environmental Impact Statement
Dear Ms. Heppler:
The Resource Development Council for Alaska, Inc. is writing in reference to the Bureau of Land Management (BLM) Eastern Interior Resource Management Plan (RMP)/Environmental Impact Statement (EIS).
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 supports the adoption Alternative D, which opens the area to resource development, with amendments by the BLM to include increased access for exploration, mineral leasing, mining, and oil and gas development in the area. Much of Alaska’s federally managed lands are closed to responsible resource development, and Alternative D should include provisions to open more areas to resource development activity.
Rare Earth Elements are a much-needed commodity
Alaska contains known and likely unknown deposits of Rare Earth Elements (REEs). Many of these REEs are imported to the United States, often from countries with lesser environmental regulations. According to the Mineral Commodities Summaries 2012 report by the U.S. Geological Survey, the U.S. depended on imports of 50-100% of needs for 43 minerals in 2011, some of which are found in Alaska. Keeping areas open to mining in Alaska not only provides the opportunity for future responsible resource development, it may also improve national security.
Therefore, areas like the White Mountains National Recreation Area that have been mapped by the U.S. Bureau of Mines, and listed as favorable for mineral discoveries, should be open mineral development. RDC asserts that the potential for mining in the area should be fully considered and designated as such in the RMP.
Benefits of maintaining multiple use areas
Resource development in the area could provide economic benefits to the region, as well as improved or added infrastructure and access to areas for multiple use.
RDC maintains that multiple uses should include mining (exploration, leasing, development) for oil and gas, coal, and minerals, as well as recreational and other potential uses. With less than one percent of Alaska in conventional private ownership, access should be available on other lands.
Much of the area has wilderness like qualities and is unexplored
Much of the areas within the RMP have wilderness like qualities, and should not require designation to retain such qualities. RDC is opposed to the BLM listing lands as Areas of Critical Environmental Concern, designating additional Wild and Scenic Rivers, and no areas should be considered for Wilderness designation.
Federal acreage dedicated to Conservation System Units in Alaska is nearly 148 million acres, accounting for 70 percent of all national park lands in the U.S., 80 percent of wildlife refuge acreage, and 53 percent of federally-designated Wilderness, at 58 million acres.
The Alaska National Interest Lands Conservation Act of 1980 (ANILCA) was the final word on additional conservation units for Alaska. The RMP should explicitly acknowledge the unique compromises of ANILCA, which include identification of sufficient conservation lands.
Furthermore, the area included in the RMP should be further evaluated for mineral potential before restrictive land designations are implemented. Sufficient mapping and geological information should be acquired, and until then, the area should be left open to all uses.
Much of the area in the BLM plan, such as the Upper Black River area, has not been explored with modern methods and technology. For this reason, these areas should be accessible for mineral exploration and production.
Additionally, RDC would like to take this opportunity to endorse the comments provided by the Alaska Miners Association (AMA) on April 11, 2013.
The issues and concerns expressed by AMA, RDC, and others need to be addressed before the RMP can be finalized.
Thank you for the opportunity to provide comments.
Resource Development Council for Alaska, Inc.