Resource Development Council

RDC Comment Letter:
Lake Clark Park and Preserve General Management Plan

March 26, 2014

Lake Clark GMP
National Park Service
Denver Service Center – Read
P.O. Box 25287
Denver, CO 80225


Re: Lake Clark General Management Plan Amendment

To Whom It May Concern:

The Resource Development Council for Alaska, Inc. (RDC) is writing to comment on the National Park Service’s (NPS) Lake Clark Park and Preserve General Management Plan (GMP) Amendment.

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.

RDC appreciates the opportunity to review and comment on the Lake Clark GMP. RDC is concerned some comments in the GMP are overreaching and stipulate resource development projects in nearby areas will “affect water and air quality, disrupt wildlife corridors, and affect visitor use in the park.” It is not the responsibility of the NPS, nor the mission of the NPS to address or mitigate these unfounded concerns.

While the GMP states, “None of the alternatives in this plan directly address these external forces, nor are indirect affects expected to interact with the impacts of the action alternatives,” it remains unclear if the NPS intends to further speculate on the “external forces.” RDC urges the NPS to omit speculative impacts of potential resource development, as well as community development projects on lands adjacent to the park.

Further, RDC is also concerned with the NPS description on page 17 of the document, referring to “External Pressures and Boundary Issues.” Assumptions about the Pebble prospect can not be made before project proponents submit a development plan and apply for permits.

Additionally, the GMP states, “The proposed Pebble Mine, which would be the world’s largest open-pit copper, gold, and molybdenum mine, would be near the park and would directly impact the Chulitna River (the second-largest tributary to Lake Clark).” The GMP should list a specific distance from the park boundary to the deposit claims. There is no evidence or indication the Chulitna River will be impacted by potential development of the Pebble prospect, as the prospect is not in the Chulitna drainage. Finally, the project can not be described in such a manner until a development plan is put forward and a permit application is filed.

In reference to development projects outside of the park boundaries affecting visitor experience in the park, RDC believes such potential impacts are subject to the individual park visitor. A generalized statement implying all visitors to the park will be affected is inaccurate and should not be implied.

RDC discourages the inclusion of a Wilderness Eligibility designation of the Johnson River area in Unit 3. The area essentially surrounds inholdings of Cook Inlet Region Inc., and should not be designated Wilderness.

However, RDC agrees with the following statement, “Based on public comments during scoping for the plan, preparing a wilderness study was not seen as an important issue for the park.” It is a policy of RDC to oppose additional Wilderness designations in Alaska. Approximately 64% of the park is already subject to the Wilderness Act. Moreover, with Alaska accounting for over half of all federal Wilderness in the nation, RDC discourages any re-evaluation of Wilderness Eligibility.

Thank you for the opportunity to comment on the Lake Clark GMP.

Resource Development Council for Alaska, Inc.