August 12, 2013
National Park Service – Alaska Region
Joan Darnell, Team Manager
Environmental Planning and Compliance
240 West 5th Avenue
Anchorage, AK 99501
Re: Gates of the Arctic National Park and Preserve Land Protection Plan – L7619 (AKRO-EPC)
Dear Ms. Darnell:
The Resource Development Council for Alaska (RDC) is writing to comment on the National Park Service’s (NPS) Gates of the Arctic National Park and Preserve Land Protection Plan (LPP).
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.
It is one of RDC’s priorities to encourage the new exploration and responsible development of Alaska’s mineral resources. While the LPP does not directly oppose mining in the nearby area, RDC is concerned some statements indicate resource development could impact cultural sites, and visitor resources and values.
RDC also supports multiple use of lands, such as mining (exploration, leasing, development), recreational, and other potential uses.
Further, concerns about a nearby project potentially impacting the environment will be considered through the Department of Natural Resources’ stringent regulations overseeing mining activities statewide that effectively protect the environment, wildlife, and human health.
RDC’s concerns begin with the discussion beginning on page 9 of the LLP under Mining Claims, specifically, the NPS “recommends that the state close the beds of navigable waters to new mineral entry, extraction of oil and gas, and sand and gravel resources, and will apply to the state for these closures.” RDC believes this is not the responsibility of the NPS, and that these actions are unwarranted.
Additional concerns lie within the list of Incompatible Uses on page 11:
- large-scale, new or increased commercial developments or use – the notion that the NPS would “attempt to prevent such uses” is an overreach by the NPS, especially on land that has been designated for mining within the preserve, or has been previously staked.
- construction of airstrips that significantly alter vegetation, terrain, visual qualities – it is one of RDC’s priorities to advocate for access to and across public lands for resource and community development. Further, the discouragement of improved or newly constructed airstrips could compromise human safety.
The LPP describes an easement as “permanent, enforceable interests in property,” and as “rights that stay with the property and are binding on future owners.” RDC is concerned with the significant number of acres already patented. With less than one percent of Alaska in conventional private ownership, RDC discourages the NPS from further land takes.
The Ambler Mining District (AMD) lies within an area of Gates of the Arctic National Park and Preserve. RDC urges the NPS to include language to explicitly acknowledge access to the AMD through the Kobuk River Preserve (the “Boot”) as guaranteed by the Alaska National Interest Lands Conservation Act. RDC concurs with the interpretation of ANILCA Section 201(4) in the LPP, “When Gates of the Arctic National Park and Preserve was established, a provision was made for a right-of-way to link the Alaska pipeline haul road to the Ambler Mining District across the western Kobuk River Preserve unit (ANILCA section 201).”
Access to the AMD is important to future projects, as the area has mineral potential but faces lack of roads and power infrastructure, as well as the likelihood of litigation from groups opposed to development in Alaska. The AMD promises to provide needed economic opportunity to the Upper Kobuk region of Northwest Alaska. Prompt adjudication of the access rights embodied in 201(4) of ANILCA will facilitate allow access to one of the world’s largest and richest volcanogenic massive sulfide districts.
Lastly, RDC encourages the NPS to address and mitigate concerns put forth by the Alaska Miners Association (AMA) in their letter dated August 12, 2013. The AMA’s request for definitions to terms used in the LPP, inclusion of references to scientific literature for statements, and reminder that the NPS must stay within the scope of its mission are all arguably sound requests.
Thank you for opportunity to comment on this Land Protection Plan.
Resource Development Council for Alaska, Inc.