Resource Development Council

RDC Comment Letter:
Lake Clark Land Protection Plan

August 12, 2013

National Park Service – Alaska Region
Joan Darnell, Team Manager
Environmental Planning and Compliance
240 West 5th Avenue
Anchorage, AK 99501


Re: Lake Clark 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) Lake Clark 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.

One of RDC’s priorities is 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. With less than one percent of Alaska in conventional private ownership, access should be available on other lands.

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 is also concerned with the discussion beginning on page 6 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.

RDC requests the NPS make the following changes to the LPP:

  • Page 9, regarding the Pebble Project – a specific distance from the preserve should be indicated, instead of the vague description given.
  • Page 9, regarding the Pebble Project – assumptions about the Pebble Project cannot be made before the project proponents submit plans and apply for permits.
  • Page 11, the suggestion that mineral development on state land, "especially at Pebble . . . could result in major impacts to park resources and values," assigns a relative magnitude to potential Pebble impacts that is not necessary or warranted. Again, assumptions about the Pebble Project cannot be made before the project proponents submit plans and apply for permits. Absent specific demonstration of such impacts based on evaluation of a detailed mine plan, RDC cannot envision how development and operation of the Pebble Project could cause meaningful impacts, let alone "major" impacts to Park resources. References to “major” impacts should be revisited and reworded, at a minimum, and NPS should consider all or no mitigation measures.

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.

In summary, RDC is concerned by potential misuse of LPPs to curtail resource development in nearby areas. Conclusions that indicate activities outside of the preserve will create a disturbance to the park and visitors not only sets a dangerous precedent, but also overlooks potential mitigation measures.

Thank you for the opportunity to comment.

Resource Development Council for Alaska, Inc.