purpose, and documentation. NO statewide review has ever occurred to ensure that the interpretation of Rel - evance and Significance are applied consistently by different planning groups in different regions. This new proposed rule would only further this imbalance in application. The Relevance and Importance criteria which must be met to qual - ify for any ACEC designation should be reviewed and stringently defined based on the resources present in the entire planning area and not as indi - vidual areas. Existing RMPs governing BLM lands in Alaska more than adequately provide for conservation, including any possible designation of ACECs. Additional au- thority is not necessary. BLM manages 70 million acres of land and minerals in Alaska, plus millions of additional acres of min - eral resources under other federal lands. Since the late 1960s, many of these lands have been off limits to mineral exploration and poten - tial development due to withdrawals
to enable the settlement of Native land claims that resulted in the 1971 Alaska Native Claims Settlement Act (ANCSA) and ANILCA. Existing RMPs in Alaska have tak- en years to develop and adding the re- quirements of the proposed rule will further delay implementation of these plans. Most BLM lands in Alaska have approved Resource Management Plans — each has taken years, in some cases, decades to develop. This proposed rule would only add addi - tional time to the already-difficult process. The proposed rule requires additional analysis and adds to the existing complexity and volume of BLM RMPs. The proposed rule fails to consid- er that BLM lands in Alaska are crucial in providing access to state and private lands. BLM lands in Alaska are crucial for providing access to state and private lands, and in many instances the
only access to these lands is across BLM lands. Under the Statehood Act and other federal laws, the state was granted nearly 105 million acres. Under the Alaska Native Claims Set - tlement Act (ANCSA), Alaska Native Corporations were granted nearly 46 million acres. In addition, many Alaska communities are surrounded by federal lands with no developed overland access. The proposed rule would enable BLM to create barri - ers to building communication lines, roads, railroad, and pipeline access routes to these non-federal lands and communities.
In Conclusion
The Proposed Rule is inconsis - tent with law and unnecessary, es - pecially in places like Alaska where the existing RMP process is working and there is no evidence of current or likely undue degradation of BLM lands. Therefore, AMA recommends that BLM withdraw it immediately. If the rule is not withdrawn, BLM lands in Alaska should be exempt from the rule.
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Summer 2023
The Alaska Miner
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