To: Governor Dunleavy, the Director of the Division of Agriculture and Commissioner of the Department of Natural Resources

We have seven questions about the Nenana-Totchaket land sale. 

Until these seven concerns can be addressed, the land sale should be paused. 

Continuing with the sale, as is, risks financial disaster for buyers and the state, as well as serious harm to the land.

1. How will buyers be able to access their land if the Tribe doesn't agree to allow use of the bridge or the Federal government blocks an update to the road?

Repairing the road, which is in poor, often unusable condition, will likely require Federal Wetland Permits and Federal funding. These federal actions could require formal tribal consultations and a subsistence evaluation, which haven't happened. What happens to buyers while these processes take place? What happens to buyers if those processes end in failure? 

The lack of a formal tribal consultation is not just disrespectful to the Nenana Tribe, it also puts buyers at great risk.

2. Where is the local preference?

In conversations with people in Nenana, the State of Alaska promised the land sale would include a local preference to ensure that Alaskans had the first opportunity to buy this land. The State also promised that parcels would be under 20 acres and that buyers would have a right of first refusal for bordering property in order to expand.

So why are the parcels so large in this sale? Where is the right of first refusal, and how will folks with interior parcels be able to expand? What steps are being taken to ensure this land is not taken by out of state speculators?

3. Why is clear-cutting required?

The land sale documents legally require buyers to clear 25% of the land they buy. However, at meetings with the public, State representatives have claimed that they will offer land-owners flexibility in how to meet this 25% requirement. This inconsistency raises two concerns. First, it makes us wonder how consistently the State plans to enforce other aspects of the written requirements, like respect for traditional use areas. Second, the 25% requirement creates a great deal of risk for both potential buyers and the land.

The soil map is very general, but local reports show many areas of less than 6 inches of top-soil on top of permafrost. This thin layer of soil, in combination with the increased rates of thunderstorms and flooding in the area, make the land highly vulnerable to erosion, especially if clear-cutting is required. This erosion would have significant negative impacts on the local waterways and wildlife that should at least be estimated before the sale moves forward. 

There are studies currently underway that will provide vital information about tree cover, permafrost extent, and soil quality but the findings won't be available to the public until after the current sale closes.

Without a complete soil map, the sale is highly speculative. Buyers could be left with practically unusable land. Or worse, under the clear-cutting requirements, buyers could be left with land that they have to destroy in order to maintain their title.

Instead of requiring clear cutting, the State of Alaska could develop an evidence-based, locally-tailored management plan or it could support the creation of a Soil and Water Conservation District.

4. How many of the relevant environmental studies have been completed? When is completion expected? Why are many of these studies still incomplete prior to the sale opening?

Another area of grave concern is that the Tanana River Drainage anadromous waters catalog is currently being updated, and this process is as of yet incomplete. This is particularly troubling given last year's collapse in the Yukon River salmon population, and predictions of the same this year. In addition, soil mapping, wildlife areas, and corridor mapping studies all remain incomplete. 

Moving forward with the sale without this information could reduce our state's food security. It could erode the abundance of local subsistence resources. And it risks serious harm to potential landowners, the State, and the local community.

5. What is the total estimated public cost of this entire project?

Some estimates have put the cost in the tens of millions of dollars, including road improvements and electricity. 

In the short term, how does the total spending compare to likely revenue from the sale?

In the long term, if the public investment will increase property values, then by how much? Will the increased tax revenue from that land and agricultural activity on it be adequate to pay for the long-term maintenance of the infrastructure? Or will this spending also saddle taxpayers with an expensive, long-term obligation? 

6. Have archaeological sites and subsistence use areas been identified by the State of Alaska in consultation with the Tribe? What is the State's plan for protecting those areas?

The Nenana Tribe has been using this land for generations, so there are many areas of cultural and historical significance. The sale brochure states that landowners will need permission to farm those areas. Have those areas been identified by the State of Alaska? How will farmers know what land is protected?

7. Why not invest in protecting Mat-Su farmland?

Unlike the Nenana land which is in a raw state and distant from markets, there is land in Mat-Su that is ready to be farmed today and already connected to the road system.

Investing in protecting Mat-Su farmland would seem to have a higher chance of success, a more immediate effect, and a lower cost to the taxpayer.

If the State of Alaska wishes to immediately invest in food security, we suggest protecting existing Mat-Su farmland.

In sum, we write to ask you to delay the Nenana-Totchaket land sale until appropriate land analyses and Tribal consultations can be completed. This land could benefit from responsible development based on proper research and controls. However the process should not be rushed.

Sincerely,

The Alaska Public Interest Research Group and the Fairbanks Climate Action Coalition, joined by…