January 17, 2014
Ms. Jeanie Cole
Bureau of Land Management
Fairbanks District Office
1150 University Avenue
Fairbanks, AK 99709
Via email to CentralYukon@blm.gov
Re: Central Yukon Resource Management Plan/Environmental Impact Statement
Dear Ms. Cole:
The Resource Development Council for Alaska, Inc. (RDC) is writing to comment on the Bureau of Land Management’s (BLM) Central Yukon Resource Management Plan/Environmental Impact Statement (CY RMP) scoping plan.
RDC is a statewide, non-profit, membership-funded organization founded in 1975. The RDC membership is comprised of individuals and companies from Alaska’s oil and gas, mining, timber, tourism, and fisheries industries, as well as Alaska Native corporations, local communities, organized labor, and industry support firms. RDC’s purpose is to link these diverse interests together 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 appreciates the opportunity to comment on the RMP scoping, and respectfully requests the BLM incorporate the following comments and suggestions in the RMP.
One of RDC’s priorities is to encourage the new exploration and responsible development of Alaska’s mineral resources. RDC encourages the BLM to incorporate resource management, such as opening the area to resource development, increased access for exploration, mineral leasing, mining, and oil and gas development. Much of Alaska’s federally managed lands are closed to responsible resource development, and the RMP 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 2013 report by the U.S. Geological Survey, the U.S. depended on imports of 50-100% of needs for 41 minerals in 2012, 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 Central Yukon that have not been inventoried, should be open to mineral development, and should be mapped by the U.S. Bureau of Mines, and listed as favorable for mineral discoveries. 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
The area under consideration in this RMP is 59 million acres, and surrounds many rural communities. Resource development in the area could provide economic benefits to the region where well-paying jobs are scarce, 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.
Additionally, RDC encourages the BLM to recognize that multiple use activities often incorporate mitigation measures, and that a one--size fits all plan should not be considered.
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.
RDC encourages the BLM to incorporate resource management, such as opening the area to resource development, increased access for exploration, mineral leasing, mining, and oil and gas development. Thank you for the opportunity to comment on this important issue.
Resource Development Council for Alaska, Inc.