August 29, 2014
BLM Fairbanks District Office
1150 University Avenue
Fairbanks, AK 99709
Via email to CentralYukon@blm.gov
Re: BLM request for ACEC nominations for the Central Yukon RMP
To Whom It May Concern:
The Resource Development Council for Alaska, Inc. (RDC) is writing in response to the Bureau of Land Management’s (BLM) request for nominations for Areas of Critical Environmental Concern (ACECs) and comments on existing ACECs for the Central Yukon Resource Management Plan (RMP).
RDC is an Alaskan 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 a priority of RDC to advocate for increased access to and across public lands for resource and community development. RDC believes the BLM should not seek ACEC designations through yet another step in the RMP process. A “Call for Nominations” is unnecessary and confusing. The “Call” implies ACECs are missing and needed, when in fact there are 25 ACECs already designated in the Central Yukon RMP, some of which are unwarranted.
RDC is further concerned the ACECs add an unnecessary “protection” of BLM managed public land that already has protections and restrictions in place. Moreover, some of the existing ACEC and Research and Natural Area (RNAs) designations are unwarranted as existing state and federal regulations provide protection for the resources that were used to initially justify the designations. For example, many of the existing ACECs were established to protect fish habitat, despite numerous existing state and federal laws and regulations that adequately protect fish habitat. RDC discourages additional land use restrictions inhibiting access to areas in Alaska and encourages the BLM to keep the ACEC designation process as part of the RMP revision instead of a separate step.
In January, RDC commented on the Central Yukon RMP scoping, noting it is a priority of RDC to encourage the new exploration and responsible development of Alaska’s mineral resources. RDC encouraged 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.
In addition, past federal government promises assured access for resource development in this area and others not set aside through the Alaska National Interest Lands Conservation Act (ANILCA). The passage of ANILCA in 1980 withdrew 106 million acres of federal lands in Alaska into conservation system units. Today, Alaska accounts for 70 percent of all national park lands in the United States, as well as 53 percent of federally designated Wilderness.
Lastly, RDC urges the BLM to fully address the concerns submitted by the Alaska Miners Association (AMA) (August 29, 2014). In particular, AMA’s requests to reduce or eliminate ACEC designations that are unwarranted, and also the request that BLM consider mineral potential in ACECs.
Thank you for the opportunity to comment.
Sincerely,
Resource Development Council for Alaska, Inc.
