The Proposed Rule disregards and is in clear violation of ANILCA. ANILCA designated 135 million acres, approximately 60 percent of ALL Federal lands in Alaska into National Parks and Preserves, Na - tional Wildlife Refuges, and Nation - al Wilderness areas, and National Wildlife and Scenic Rivers. In addi - tion to six BLM-managed Wild and Scenic Rivers, ANILCA set aside over two million acres of BLM lands as the Steese National Conservation Area and White Mountains Nation - al Recreation Area. Remaining BLM lands were intentionally left as mul - tiple use lands, part of the balance of “public lands necessary and ap - propriate for more intensive use and disposition.” Congress, in 1980, determined that ANILCA provided the proper balance between conservation and resource development in Alaska. The failure to even acknowledge ANILCA requirements in the Pro - posed Rule is a major deficiency and reason for the Proposed Rule to be withdrawn, if not in its entirety than as it applies specifically to Alaska.
The proposed rule proposes im- proper emphasis on designation of Ar- eas of Critical Environmental Concern (ACECs) in the RMP process. BLM already over-emphasiz - es ACECs in its Alaska RMPs, both in terms of numbers and over - ly expansive scales of ACEC. This leads to unnecessary restrictions on non-conservation land uses in these areas. BLM’s existing designations of ACECs already fail to consider ex - isting state and federal authorities for resource protection, particularly in ACEC designations based on fish - eries. In Alaska, the Alaska Department of Fish and Game (ADF&G) has the primary function of ensuring pro - tection of fisheries throughout the State as well as their uses, including for subsistence activities. Rules governing the criteria for de- termining and applying ACEC designa- tions need reform. ACEC designations to date in Alas - ka are extremely inconsistent in size,
BLM, CONTINUED from PAGE 8
Alaska-Specific comments on the Proposed Rule
AMA advocates for the multiple use management of BLM Public Lands, consistent with FLPMA. AMA has long advocated for making BLM lands in Alaska available for mining explora - tion and development. AMA has also stressed the importance of BLM lands in providing access both to resources on BLM lands, and even more signifi - cantly, the importance of BLM lands in providing access to state and pri - vate lands, including Alaska Native Corporation lands, in Alaska. RMPs for BLM’s Alaska lands have demonstrated that the existing federal statutes, regulations, and rules pro - vide more than adequate protection for conservation of resources, addi - tional restrictions on development in the proposed rule are not necessary.
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The Alaska Miner
Summer 2023
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