BSWI RMP Preliminary Alternatives

May 31, 2015

Bering Sea-Western Interior RMP
Bureau of Land Management
Anchorage Field Office
4700 BLM Road
Anchorage, AK 99507

Re: Bering Sea – Western Interior Preliminary Alternatives

To Whom It May Concern:

The Resource Development Council for Alaska, Inc. is writing to comment on the Bering Sea – Western Interior (BSWI) Resource Management Plan (RMP) Preliminary Alternatives.

RDC is an Alaskan 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 notes the Preliminary Alternatives document is lengthy so these comments will focus on the Preliminary Alternatives and Areas of Critical Environmental Concern (ACEC) Report on Relevance and Importance.

RDC opposes management actions that would prohibit development in the area

RDC is concerned the Preliminary Alternatives are overreaching and exclusive of the necessary information needed to make decisions on lands in the BSWI RMP. Therefore, RDC encourages the BLM to withdraw the proposal and engage stakeholders in land planning to develop an RMP that encompasses multiple use and access.

The Preliminary Alternatives selected by BLM create more restrictions for resource development, as virtually no BLM land in the planning area will be made available for resource development or access.

It is one of RDC’s priorities to encourage new exploration and responsible development of Alaska’s mineral resources. RDC encourages the BLM to incorporate multiple-use 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, much of the lands BLM manages surround or is near by rural communities in Alaska. RDC encourages BLM to involve these communities and stakeholders in development of management plans. Access to private, native and village corporation, and state lands should be addressed and a primary concern for BLM.

Multiple-use should be in BLM land management plans, and should include mining (exploration, leasing, development) for oil and gas, coal, and minerals, as well as recreational, community development, and other potential uses. With less than one percent of Alaska in conventional private ownership, access should be available on other lands.

RDC opposes new ACECs and urges BLM to revisit and remove existing ACECs

No ACECs should be designated in the planning area, and RDC encourages responsible resource development in this economically-challenged region. It is the most consistent within the fundamental principles of the Alaska Native Claims Settlement Act (ANCSA), the Alaska National Interest Lands Conservation Act (ANILCA) and the Alaska Statehood Act. It was the intent of Congress in 1959 that the new State of Alaska become self sufficient, and its natural resource potential has long been recognized as key to fulfilling that intent.

In August, RDC urged BLM to withdraw its “call” for ACEC nominations, writing:

“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 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.”

The ACEC appears to be a blanket closure to mineral entry, and lacks justification and explanation for the closure.

In conclusion, RDC encourages BLM, as a multiple-use agency, to set the stage for responsible resource exploration on its lands in the planning area. Thank you for the opportunity to comment and for your consideration of our comments.

Sincerely,
Resource Development Council for Alaska, Inc.