The Alaska Miner Summer 2023 10 Learn more at DonlinGold.com Our commitment to hire local employees and vendors ensures a positive economic impact for our community. 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 exploration and development. AMA has also stressed the importance of BLM lands in providing access both to resources on BLM lands, and even more significantly, the importance of BLM lands in providing access to state and private lands, including Alaska Native Corporation lands, in Alaska. RMPs for BLM’s Alaska lands have demonstrated that the existing federal statutes, regulations, and rules provide more than adequate protection for conservation of resources, additional restrictions on development in the proposed rule are not necessary. 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, National Wildlife Refuges, and National Wilderness areas, and National Wildlife and Scenic Rivers. In addition 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 National Recreation Area. Remaining BLM lands were intentionally left as multiple use lands, part of the balance of “public lands necessary and appropriate 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even acknowledge ANILCA requirements in the Proposed Rule is a major deficiency and reason for the Proposed Rule to be withdrawn, if not in its entirety than as it applies specifically to Alaska.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 improper emphasis on designation of Areas of Critical Environmental Concern (ACECs) in the RMP process. BLM already over-emphasizes ACECs in its Alaska RMPs, both in terms of numbers and overly 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 existing state and federal authorities for resource protection, particularly in ACEC designations based on fisheries. In Alaska, the Alaska Department of Fish and Game (ADF&G) has the primary function of ensuring protection of fisheries throughout the State as well as their uses, including for subsistence activities. Rules governing the criteria for determining and applying ACEC designations need reform. ACEC designations to date in Alaska are extremely inconsistent in size,
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