Notice of Decision Partial Release of State Interest, GS-5705, GS-5709 (Selawik Hills)

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Notice of Decision Partial Release of State Interest, GS-5705, GS-5709 (Selawik Hills)

STATE OF ALASKA
DEPARTMENT OF NATURAL RESOURCES
Division of Mining, Land and Water

NOTICE OF DECISION

PARTIAL RELEASE OF STATE INTEREST
State Selection Files: GS-5705, GS-5709

Relinquishment of Certain State-Selected Lands

AS 38.05.035(a)(11), AS 38.05.035(e), Consolidated Appropriations Act for Fiscal Year 2023
(Pub. L. 117-328) and the University of Alaska Fiscal Foundation Act

I. ACTION
This decision addresses the proposed relinquishment of State of Alaska (State) land selections
on certain lands. The purpose of relinquishment is to facilitate University of Alaska (UA) land
selections under the University of Alaska Fiscal Foundation Act. The University of Alaska
Fiscal Foundation Act was included in the federal Consolidated Appropriations Act for Fiscal
Year 2023 (Pub. L. 117-328) (CAA 2023).

II. AUTHORITY
The CAA 2023 provides that the Bureau of Land Management (BLM) may convey up to
360,000 acres of land selected by the State of Alaska (State-selected land) pursuant to Section
6(b) of the Alaska Statehood Act (Pub. L. 85-508) to the University of Alaska. Additional
information about the Fiscal Foundation Act can be found at:
https://www.alaska.edu/ualand/about/land-grant/index.php.

The ability to relinquish Statehood Act selections in favor of the UA is codified in Sec. 302(c)
of the CAA 2023. The provisions of Alaska Statute (AS) 38.05.035(a)(11) allow the Director
of the Division of Mining, Land and Water (DMLW) to manage Statehood Entitlement
selections. AS 38.05.035(e) provides authority for disposals of lands, resources, property, or
interests in them. Article XIII of the Alaska Constitution provides guiding principles for
maximum use of state lands and resources and authority for disposals of interests in lands and
resources.

III. BACKGROUND AND PROCESS
The CAA 2023 authorizes the BLM to directly convey up to 360,000 acres of land to the UA.
The available lands must be federal lands selected by the State pursuant to Sec. 6(b) of the
Alaska Statehood Act.

The University of Alaska Land Management Office (UALMO) reviewed available State land
selections and identified possible land for conveyance. UALMO submitted land selections to
the DMLW Realty Services Section (Realty). Realty worked with UALMO to refine the
selection, then completed state-wide agency review and public notice for the specific proposed
relinquishment. This decision reflects a consideration of comments received during agency
review and public notice and will be published on the State's online public notice board while
the reconsideration period runs. Information about how to file a request for reconsideration is
appended to this decision. Following the closure of the reconsideration period, provided there are no requests for reconsideration, the State and UALMO will jointly submit to BLM lists of
lands to be conditionally relinquished by the State and conveyed to the UA. Any request for
reconsideration will be reviewed under the applicable state law and process. Final
relinquishment of the State's selections would be affected upon conveyance of the lands to the
UA.

Notice with a concurrent agency review was conducted from February 19, 2026, to April 3,
2026. Agencies were given the opportunity to evaluate and comment on the relinquishment to
determine if it is in the State's best interest to release the land selection.

IV. ADMINISTRATIVE RECORD
The selection files for state selections, GS-5705 and GS-5709, constitute the administrative
record for this action.

V. LOCATION
The proposed-for-relinquishment lands are located approximately 15 miles northeast of
Buckland. See legal description section for exact locations. Please see Attachment A for a
visual depiction of the area.
• USGS Map Coverage: Selawik A3, A4, Candle D3, D4
• Regional Corporation: Nana Regional Corporation
• Federally Recognized Tribe: Native Village of Buckland
• Village Corporations: Buckland Nunachiak Corp.

VI. LEGAL DESCRIPTION
Within the Kateel River Meridian, Alaska:
Township 7 North, Range 9 West, Sections 1, 5-7, 18, 19, 30
Containing approximately 4,314 acres
Township 8 North, Range 9 West, Sections 1-18, 21-29, 31-36
Containing approximately 20,936 acres
Total acreage aggregating approximately 25,250 acres.

VII. SELECTION HISTORY
• State records indicate lands in townships K007N009W (GS-5705 & GS-5709) and
K008N009W (GS-5709) were selected in December 1992; the applications were
published in August 1993.
• UA submitted a request to DNR to consider relinquishing the subject lands on
November 25, 2025.
• The lands are currently ranked as a mix of priority levels three (3) or medium, and four
(4) or low, in the statehood selection prioritization for their importance as wildlife
habitat, potential mineral potential, and utility as hunting and subsistence areas.

VIII. AGENCY REVIEW
Information and comments received from State agencies have been considered and included
in the preparation of this decision. The proposed relinquishment documents were distributed
to State agencies for review from December 11, 2025, through December 29, 2025. Public
Notice with a concurrent agency review was conducted from February 19, 2026, to April 3, 2026. Agencies are given the opportunity to evaluate and comment on the relinquishment to
determine if it is in the State's best interest to release the land selection.

The following agencies or groups were included in the first agency review:
• Department of Fish and Game
• Department of Transportation and Public Facilities
• Division of Oil and Gas
• Division of Geological and Geophysical Surveys
• Division of Forestry
• Division of Parks and Outdoor Recreation
• Division of Mining Land and Water, Mineral Property Management
• Division of Mining Land and Water, Water Section
• Division of Mining Land and Water, Northern Regional Office
• Division of Mining Land and Water, Land Conveyance Section
• Division of Mining Land and Water, Public Access, Assertion, and Defense Section
• Division of Mining Land and Water, Resource Assessment and Development Section

The following comments, reproduced verbatim, were received in the first agency review:

Department of Fish and Game (ADFG): ADFG reviewed the state selection in the Selawik
Hills East of the Buckland River. If DNR determines it is in the best interest of the state to
relinquish, the land will be available for the Bureau of Land Management (BLM) to convey to
the University of Alaska. The selected lands are within Secs. 1. 5-7, 18, 19, 30, T. 7 N., R. 9 W.,
and Secs. 1-18, 21-29, 31-36, T. 8 N., R. 9 W., KRM, and contain approximately 25,250 acres.

Fisheries
Drainages within this selection include streams draining into an anadromous tributary (AWC Code: 331-00-10650-2115-3031) of the Fish River (AWC Code: 331-00-10650-2115). The creeks in the selection likely contain a seasonal presence of Juvenile Dolly Varden.

Wildlife
This selection of Selawik hills is known to contain groups of muskoxen from the Seward
Peninsula population, which utilize the windswept hilltops for winter grazing, to maximize
predator defense, and escape deep snow. Due to its limited size, this muskox population can only
support a limited subsistence hunt, and the muskoxen groups within the Selawik Hills are some
of the closest to access for subsistence users from the villages of Buckland and Selawik.
Restriction of access to this land may result in the loss of access to some of these muskoxen for
subsistence users. Additionally, any development activity within this selection may disturb or
displace these muskoxen to less suitable habitats or outside of the current hunt boundaries.
Portions of this selection have been used by the Western Arctic Caribou Herd during spring and
fall migration and are characterized by medium density caribou use through the winter months
(Nov 8-May 5th). Utilization of the land may impact localized caribou movements and presence.

ADF&G concerns
From a public access perspective, any conveyance of land out of the State public-use system
would be a loss to both local and non-local Alaskan residents. Game Management Unit (GMU)
23, which encompasses these lands, has about 15%

State-owned land, with the remaining bulk being federally owned. In the past several years, the
Federal Subsistence Board has, at times, closed all Federal public lands to non-local users
wishing to hunt caribou or moose; this means that over 75% of GMU 23 becomes unavailable
for hunting to most Alaska residents, who then become limited to State-owned land. Reducing
State-owned land within GMU 23 further restricts hunting (both subsistence and recreational)
opportunities to Alaskan residents.

ADF&G does not support the relinquishment of this selection. Thank you for the opportunity to
review and provide comments on this selection. Please send us copies of any subsequent
decisions or documents related to these lands.

DMLW Realty Response: Thank you for your comment and valuable information.

Department of Public Transportation and Public Facilities (DOT&PF): Thank you for the
opportunity to review this proposal. The Alaska Department of Transportation & Public
Facilities has no comment at this time.

DMLW Realty Response: Thank you for your comment.

DNR, Division of Oil & Gas: Thank you for the opportunity to comment on the proposed
relinquishment of the State's selections. The Division of Oil and Gas has no objection to the
proposal and no third-party interests in this area.

DMLW Realty Response: Thank you for your comment.

DNR, Division of Geological & Geophysical Surveys (DGGS): DGGS has no objections to
this proposed relinquishment.

Agency Review Request: Selawik Hills UA Lands selection

Geologic Units: Alluvial deposits, colluvial deposits (extensive solifluction), eolian deposits
(including windblown silt), glacial deposits, paludal peat deposits, bedrock.

Suitability For Construction: Areas of clean sand and gravel may be suitable as a material
resource, depending on their distribution and thickness, as well as the thickness of any finegrained
surface cover. Materials on slopes may be unsuitable as a resource due to potential
instability. Ice-rich areas susceptible to thawing and areas of poor drainage may be unsuitable
as foundation material. Use best construction practices.

Permafrost: Continuous (90-100%)

Susceptibility To Frost Action: Generally intense frost action where sediments are fine-grained
and/or wet. Generally, less intense where sediment is coarse-grained and/or well-drained.
Bedrock may be susceptible to frost action along bedding planes or joints.

Thaw Stability: Thaw unstable where ice content is high, especially in areas of poor drainage.
Generally, well-drained, course sediments are more thaw-stable than poorly drained, finegrained
sediments.

Surface Drainage and Flooding Potential: Flooding is possible along streams in the spring and during intense storm events. Surface drainage is often poor near swamps and areas of
permafrost, especially where sediment is fine-grained. Surface drainage is good along slopes
where the soil is unfrozen as well as in course-grained sediment when it is unfrozen.

Seismic Hazard: Low; standard best building practices should be used to accommodate the
regional seismic hazard.

Volcanic/Ashfall Hazard: This area has been subject to ashfall from erupting Alaska Peninsula
volcanoes; past ash events include multiple older tephras.

Radon: Radon, a naturally-occurring cancer-causing radioactive gas, has been modeled to be
low in this area (https://maps.dggs.alaska.gov/radon/). The Environmental Protection
Agency's (EPA) Action Level for radon is 4 pCi/L; the EPA suggests homeowners consider
radon mitigation for test results of 2-4 pCi/L. Any home, school, or building can have high
levels of radon and should be tested.

Mineral Resources: No comment.

Energy Resources: The selected lands occupy the highlands south of the Selawik trough.
Although the Selawik trough north of the highlands is known to be a shallow sedimentary
basin, it is not known as prospective for energy resources. It's rumored that there is a nearby
hot spring, but it does not appear on the State geothermal resources map.

Optional Reference (s):
Patton, W.W., Jr., and Miller, T.P., 1968, Regional geologic map of the Selawik and
southeastern Baird Mountains quadrangles, Alaska: U.S. Geologic Survey Miscellaneous
Geologic Investigations Map 530, 1 sheet, scale 1:250,000.

DMLW Realty Response: Thank you for your comment.

DNR, Division of Parks and Outdoor Recreation (DPOR): DPOR has no issues.

DMLW Realty Response: Thank you for your comment.

DNR, DMLW, Mineral Property Management Section (MPM):
Regarding the Selawik Hills UA Land selection including:
Kateel Meridian:
T. 7 N., R. 9 W.,
Secs. 1, 5-7, 18, 19, 30 all.
Containing approximately 4,314 acres
T. 8 N., R. 9 W.,
Secs 1-18, 21-29, 31-36 all.
Containing approximately 20,936 acres
Aggregating approximately 25,250 acres.
The Mining Section has no concerns regarding the proposed relinquishment of these lands.

DMLW Realty Response: Thank you for your comment.

DNR, DMLW, Public Access, Assertion, and Defense Section (PAAD): These two townships hold not known RS 2477 ROW's or DOT 1973 inventory trails. There are no navigable waters per AS 38.04.062(title). There is one pond approximately 11 acres in size, the streams are all headwater streams.

DMLW Realty Response: Thank you for your comment.

DNR, DMLW, Resource Assessment and Development Section (RADS): Thank you for
the opportunity to review and comment on the proposed UA Selawik Hills selections. The
Resource Assessment & Development Section (RADS) has reviewed the available data,
satellite imagery, and the Northwest Area Plan and provides the following comments.

Background & Discussion:
The Statehood Entitlement Unit received a request to relinquish Statehood Act land selections
under General Grants GS5705 and GS-5709 within MTRSs K008N009W and K007N009W,
located approximately 13-22 miles from the community of Buckland and its airport. These
parcels are within the Northwest Area Plan (NWAP, adopted 2008), were selected since 1992,
and remain state selected lands with priority 4 according to BLM records. The management
intent of NWAP 2008 remains in effect, should the lands be conveyed to the state, and applies
to the surrounding state and selected lands. The requested parcels are situated contiguously
between ANILCA top-filed lands to the west (GS 4004) and selected lands to the east (GS
5708), bridging these selections.

All parcels are located within NWAP Kotzebue Sound Region, management unit K-9 (Map
7), classified as Mineral Land and Wildlife Habitat Land (designated for Minerals and Habitat,
p. 3-41). The stated management intent is to "manage
for mineral values" and any authorizations of long-term or permanent uses are to consider
impacts upon the Western Arctic Caribou Herd (WACH) with ADF&G consultation and
special consideration given during the spring, winter, and fall
seasons, when the region is part of the herd's migratory and core ranges.

Recommendation:
RADS recommends against relinquishing the selections to UA. Relinquishment of the
requested parcels would fragment adjacent state selections, potentially isolating eastern
selections from access through the Buckland airport. Additionally, these selections are
important to the management of the WACH, with management intent specified to the herd's
habitat use. Current management intent would likely be abandoned and contravened under
management as private trust lands, which could degrade the land's availability for the herd's
migration corridors and core winter range.

DMLW Realty Response: Thank you for your comment and valuable information. Should
DNR relinquish its selection, the ADF&G would retain management of fish and wildlife on any
lands conveyed to the UA.

If DNR relinquishes its selection, any proposed future use, development, or sale of the land
would include a public process on the part of the UA. Additionally, many types of development
projects would include both a State and Federal permit process.

Dedicated access to and through UA lands, or for commercial applications, is available by
obtaining a permit from the UALMO. More information on the permit process can be found
here: https://www.alaska.edu/ualand/permits/.

The following agencies or groups were included in the second agency review, which ran
concurrently with the public notice:

• Department of Fish and Game
• Department of Transportation and Public Facilities
• Division of Oil and Gas
• Division of Geological and Geophysical Surveys
• Division of Parks and Outdoor Recreation
• Division of Forestry
• Division of Mining Land and Water, Mineral Property Management
• Division of Mining Land and Water, Water Section
• Division of Mining Land and Water, Northern Regional Office
• Division of Mining Land and Water, Land Conveyance Section
• Division of Mining Land and Water, Public Access, Assertion, and Defense Section
• Division of Mining Land and Water, Resource Assessment and Development Section

The following additional comments, reproduced below, were received in the second agency
review:

Department of Transportation and Public Facilities (DOT&PF): Thank you for the
opportunity to review the proposal. The Alaska Department of Transportation & Public
Facilities has no comment at this time.

DMLW Realty Response: Thank you for your comment.

DNR, Division of Oil & Gas: Thank you for the opportunity to comment on the proposed
relinquishment. The Division of Oil and Gas has no objection to the proposal. The Division
does not have any third-party interests in the vicinity of the parcel.

DMLW Realty Response: Thank you for your comment.

DNR, Division of Parks and Outdoor Recreation (DPOR): DPOR does not have issues.

DMLW Realty Response: Thank you for your comment.

DNR, DMLW, Resource Assessment and Development Section (RADS): No further
comment.

DMLW Realty Response: Thank you for your comment.

IX. PUBLIC COMMENT
Public notice of the proposed relinquishment was conducted from February 19, 2026, through
April 3, 2026. The notice was posted to the State of Alaska Online Public Notice System.
Copies of the notice were sent to the University of Alaska, BLM Anchorage Field Office, BIA Regional Realty Office and Title Services Center, the U.S. Post Masters of Selawik, Buckland,
Deering, Kotzebue, and Noorvik, Kotzebue Kikiktagruk Inupiat Corporation, Native Village
of Kotzebue, Selawik Akuliuk Incorporation, Native Village of Selawik, Buckland Nunachiak
Corporation, the City of Buckland, Deering Ipnatchiak Corporation, the City of Deering,
Deering Putoo Corporation, the City of Noorvik, Northwest Arctic Borough, Davis-Ramoth
School in Selawik, Kotzebue Middle High School, Buckland School, Deering School,
Aqqaluk Noorvik School, the Arctic Sounder, the Kotzebue AC Store, Selawik Rotman Stores,
Inc., Buckland Native Store, Deering Native Store, Noorvik Native Store, Selawik National
Wildlife Refuge, the Alaska Reindeer Herders Association, Alaska Department of Natural
Resources Commissioners Office, The Alaska Board of Game, Alaska Fish and Game Northern
Seward Peninsula and Lower Kobuk Advisory Committee Coordinator, Alaska State
legislature, adjacent landowners, and interested private parties.

Confirmation that the Public Notice was posted in a place accessible to the general public was
received from the Deering Post Office and the Buckland School.

Realty received 13 comments via email in response to the proposed relinquishment. Eight of the
comment submissions did not specify which particular UA relinquishment they were regarding
and have been addressed in all UA relinquishments that were undergoing public notice at the
time the email was received. All 13 comments are reproduced verbatim below:

Public Comment 1:
I am writing to submit my opposition to the proposed relinquishment of the State of Alaska's
entitlement land selections to the University of Alaska.

Relinquishing these selections now will remove the State's authority to impose protections for
the public. Many other non-selected federal lands across Alaska could satisfy the University's
entitlement without conflicting with established State selections or jeopardizing public access
routes. I've attached my letter for public comment. For these reasons, I strongly urge the
Department of Natural Resources to retain its selections on these parcels unless robust public
access protections including recognition of existing trails and rights-of-way are guaranteed
prior to any relinquishment or conveyance.

Thank you for considering my comments during this public input period.
On behalf of myself, Morgan Christensen, I submit the following concerns regarding the
proposed relinquishment of State of Alaska land selections for the purpose of conveyance to
the University of Alaska. The land selections I am concerned with is Kauk River and Selawik
Hills.

I recognize the intent of the federal Consolidated Appropriations Act for Fiscal Year 2023 to
resolve the University of Alaska's historical land grant entitlement. However, these parcels
raise serious concerns because they were already strategically selected by the State of Alaska
under the Alaska Statehood Act for their public value, access potential, and long-term benefit
to Alaskans. Alaska's land selection process, guided by Article VIII of the Alaska Constitution,
prioritizes managing resources for the maximum benefit of the people and protecting public
access to land and water. By selecting these lands, the State positioned itself to secure
easements, recognize trails (including RS 2477 rights-of-way), and ensure continued public
use. Relinquishing the selections now would strip the State of its authority to impose those

protections, such as requiring BLM to reserve easements or subject the University's title to
public access corridors, bypassing the established framework designed to keep these lands in
the public interest.

These areas contain established trail systems and patterns of traditional use. I personally use
this area for Hunting, Fishing, Subsistence Activities, Hiking, Snowmaching,
Historical/Family Traditional Use. I have concerns regarding Loss of public access to trails
and routes, Risk to existing/historic RS2477 rights-of-way, Bypassing State's land selection
process under Statehood Act, Potential closure of traditional use areas, better alternatives exist
on non-selected federal lands elsewhere. Relinquishing before routes are documented and
protected will permanently disrupt generational access.

Other non-selected federal lands across Alaska could satisfy the University's entitlement
without conflicting with State selections or endangering public access. For these reasons, I
believe the State should not relinquish its selections on these parcels under the current proposed
conditions. I respectfully urge the State of Alaska to retain its selections on these parcels unless
public access protections, including recognition of existing trails and rights-of-way, can be
guaranteed prior to any conveyance.

o DMLW Realty Response: Thank you for your comments. UALMO has created a
program allowing hunting and subsistence activities on UA lands. Additionally, during
the review period of this decision, UALMO implemented a trapping program. More
information about both programs can be found here:
https://www.alaska.edu/ualand/permits/hunting-revised.php.

o Realty notes that lands within the area of discussion are validly selected by the State,
therefore the Federal subsistence priority created under the Alaska National Interest
Lands Conservation Act (ANILCA) does not apply.

o ADF&G would retain management of fish and wildlife resources on the lands,
including State subsistence regulations, should ownership be transferred to the UA.
o Public access and use of UA lands for non-commercial uses such as hiking and berry
picking are allowed without a permit. Dedicated access to and through UA lands, or for
commercial applications, is available by obtaining a permit from the UALMO. More
information on the permit process can be found here:
https://www.alaska.edu/ualand/permits/.

o No RS-2477 rights-of-way or DOT 1973 inventory trails were found to exist on the
parcel. A review of satellite imagery did not find any evidence of trails on the land.

o While this land was selected by the State of Alaska under the Alaska Statehood Act for
its public value, access potential, and long-term benefit, the selected lands currently
ranked as a mix of priority levels three (3) or medium, and four (4) or low, in the
statehood selection prioritization in the Realty Section's 2025 evaluation of selected
land. This means, while the land is selected, other state-selected lands are a higher
priority to acquire as a part of the Statehood Land Entitlement. The State has selected
more lands than remain available for conveyance under the Statehood Act, therefore
DNR is required to relinquish over-selections while actively working to fulfil its
remaining Statehood Act land entitlement. The land selection period granted in the
CAA 2023 expires in Dec. 2026 and DNR is unlikely to have completed acquisition of
the statehood land grant before the CAA 2023 grant sunsets. Therefore, DNR needs to
pursue relinquishment of the University selections simultaneously with its efforts to
continue land acquisition.

o The CAA 2023 created a mechanism for BLM to transfer lands to the UA in furtherance
of what was deemed by Congress to be a public purpose, and for management and use
consistent with the University's public mission. The State is participating in the program
towards those ends, consistent with the Alaska Constitution's Article VII directives for
the University. The scope of this decision is limited to whether DNR should relinquish
its land selection to facilitate conveyance of the lands to the UA. Realty notes the only
lands available under the CAA 2023 are lands selected or top-filed by the State under
the Alaska Statehood Act. Federal lands not selected or top-filed by the State are
unavailable for selection or transfer to UA.

Public Comment 2:
I am writing to submit my opposition to the proposed relinquishment of the State of Alaska's
entitlement land selections to the University of Alaska.

Relinquishing these selections now will remove the State's authority to impose protections for
the public. Many other non-selected federal lands across Alaska could satisfy the University's
entitlement without conflicting with established State selections or jeopardizing public access
routes. I've attached my letter for public comment. For these reasons, I strongly urge the
Department of Natural Resources to retain its selections on these parcels unless robust public
access protections including recognition of existing trails and rights-of-way are guaranteed
prior to any relinquishment or conveyance.

Thank you for considering my comments during this public input period.
On behalf of myself, Natalie Mccullough, I submit the following concerns regarding the
proposed relinquishment of State of Alaska land selections for the purpose of conveyance to
the University of Alaska. The land selections I am concerned with is Kauk River and Selawik
Hills.

I recognize the intent of the federal Consolidated Appropriations Act for Fiscal Year 2023 to
resolve the University of Alaska's historical land grant entitlement. However, these parcels
raise serious concerns because they were already strategically selected by the State of Alaska
under the Alaska Statehood Act for their public value, access potential, and long-term benefit
to Alaskans. Alaska's land selection process, guided by Article VIII of the Alaska Constitution,
prioritizes managing resources for the maximum benefit of the people and protecting public
access to land and water. By selecting these lands, the State positioned itself to secure
easements, recognize trails (including RS 2477 rights-of-way), and ensure continued public
use. Relinquishing the selections now would strip the State of its authority to impose those
protections, such as requiring BLM to reserve easements or subject the University's title to
public access corridors, bypassing the established framework designed to keep these lands in
the public interest.

These areas contain established trail systems and patterns of traditional use. I personally use
this area for Historical/Family Traditional Use. I have concerns regarding Loss of public access
to trails and routes, Risk to existing/historic RS2477 rights-of-way, Bypassing State's land
selection process under Statehood Act, Potential closure of traditional use areas, Better
alternatives exist on non-selected federal lands elsewhere. Relinquishing before routes are
documented and protected will permanently disrupt generational access.

Other non-selected federal lands across Alaska could satisfy the University's entitlement
without conflicting with State selections or endangering public access. For these reasons, I
believe the State should not relinquish its selections on these parcels under the current proposed
conditions. I respectfully urge the State of Alaska to retain its selections on these parcels unless
public access protections, including recognition of existing trails and rights-of-way, can be
guaranteed prior to any conveyance. Alaska is truly the last frontier. By ultimately privatizing
nature, the wild eventually will cease to exist. Earths delicate ecosystem, especially human
life, depends on clean air & water. Mining, clear cutting, building, polluting is counter
productive to restoring balance to the massive carbon footprint already made. Protect what's
left of our natural resources- that is your entire department. Thank you.

o DMLW Realty Response: Thank you for your comments. UALMO has created a
program allowing hunting and subsistence activities on UA lands. Additionally, during
the review period of this decision, UALMO implemented a trapping program. More
information about both programs can be found here:
https://www.alaska.edu/ualand/permits/hunting-revised.php.

o Realty notes that lands within the area of discussion are validly selected by the State,
therefore the Federal subsistence priority created under the Alaska National Interest
Lands Conservation Act (ANILCA) does not apply.

o ADF&G would retain management of fish and wildlife resources on the lands should
ownership be transferred to the UA.

o Public access and use of UA lands for non-commercial uses such as hiking and berry
picking are allowed without a permit. Dedicated access to and through UA lands, or for
commercial applications, is available by obtaining a permit from the UALMO. More
information on the permit process can be found here:
https://www.alaska.edu/ualand/permits/.

o No RS-2477 rights-of-way or DOT 1973 inventory trails were found to exist on the
parcel. A review of satellite imagery did not indicate trails on the land.

o The scope of this decision is limited to whether DNR should relinquish its land
selection to facilitate conveyance of the lands to the UA. Comments regarding future
land use, development, or land use restrictions or preservation are beyond the scope of
this decision. Realty notes that relinquishment of DNR's land selection does not
authorize any development or land use. Should the lands be conveyed to the UA, any
future actions would be subject to applicable State and Federal environmental
regulations and permits. Realty also notes that any proposed future use, development,
or sale of the land would include a public process on the part of the UA, including
public notice on their website: https://www.alaska.edu/ualand/.

o While this land was selected by the State of Alaska under the Alaska Statehood Act for
its public value, access potential, and long-term benefit, the selected lands currently
ranked as a mix of priority levels three (3) or medium, and four (4) or low, in the
statehood selection prioritization in the Realty Section's 2025 evaluation of selected
land. This means, while the land is selected, other state-selected lands are a higher
priority to acquire as a part of the Statehood Land Entitlement. The State has selected
more lands than remain available for conveyance under the Statehood Act, therefore
DNR is required to relinquish over-selections while actively working to fulfil its
remaining Statehood Act land entitlement. The land selection period granted in the
CAA 2023 expires in Dec. 2026 and DNR is unlikely to have completed acquisition of
the statehood land grant before the CAA 2023 grant sunsets. Therefore, DNR needs to
pursue relinquishment of the University selections simultaneously with its efforts to
continue land acquisition.

o The CAA 2023 created a mechanism for BLM to transfer lands to the UA in furtherance
of what was deemed by Congress to be a public purpose, and for management and use
consistent with the University's public mission. The State is participating in the program
towards those ends, consistent with the Alaska Constitution's Article VII directives for
the University. The scope of this decision is limited to whether DNR should relinquish
its land selection to facilitate conveyance of the lands to the UA. Realty notes the only
lands available under the CAA 2023 are lands selected or top-filed by the State under
the Alaska Statehood Act. Federal lands not selected or top-filed by the State are
unavailable for selection or transfer to UA.

Public Comment 3:
I am writing to submit my opposition to the proposed relinquishment of the State of Alaska's
entitlement land selections to the University of Alaska.

Relinquishing these selections now will remove the State's authority to impose protections for
the public. Many other non-selected federal lands across Alaska could satisfy the University's
entitlement without conflicting with established State selections or jeopardizing public access
routes. I've attached my letter for public comment. For these reasons, I strongly urge the
Department of Natural Resources to retain its selections on these parcels unless robust public
access protections including recognition of existing trails and rights-of-way are guaranteed
prior to any relinquishment or conveyance.

Thank you for considering my comments during this public input period.
On behalf of myself, Stuart Jones, I submit the following concerns regarding the proposed
relinquishment of State of Alaska land selections for the purpose of conveyance to the
University of Alaska. The land selections I am concerned with is Kauk River and Selawik
Hills.

I recognize the intent of the federal Consolidated Appropriations Act for Fiscal Year 2023 to
resolve the University of Alaska's historical land grant entitlement. However, these parcels
raise serious concerns because they were already strategically selected by the State of Alaska
under the Alaska Statehood Act for their public value, access potential, and long-term benefit
to Alaskans. Alaska's land selection process, guided by Article VIII of the Alaska Constitution,
prioritizes managing resources for the maximum benefit of the people and protecting public
access to land and water. By selecting these lands, the State positioned itself to secure
easements, recognize trails (including RS 2477 rights-of-way), and ensure continued public
use. Relinquishing the selections now would strip the State of its authority to impose those
protections, such as requiring BLM to reserve easements or subject the University's title to
public access corridors, bypassing the established framework designed to keep these lands in
the public interest.

These areas contain established trail systems and patterns of traditional use. I personally use
this area for Hunting, Fishing, Subsistence Activities, Hiking, Snowmaching. I have concerns
regarding Loss of public access to trails and routes, Risk to existing/historic RS2477 rights-ofway,
Bypassing State's land selection process under Statehood Act, Potential closure of
traditional use areas, better alternatives exist on non-selected federal lands elsewhere.
Relinquishing before routes are documented and protected will permanently disrupt
generational access. No school needs 50k acres of wilderness

Other non-selected federal lands across Alaska could satisfy the University's entitlement
without conflicting with State selections or endangering public access. For these reasons, I
believe the State should not relinquish its selections on these parcels under the current proposed
conditions. I respectfully urge the State of Alaska to retain its selections on these parcels unless
public access protections, including recognition of existing trails and rights-of-way, can be
guaranteed prior to any conveyance.

o DMLW Realty Response: Thank you for your comments. UALMO has created a
program allowing hunting and subsistence activities on UA lands. Additionally, during
the review period of this decision, UALMO implemented a trapping program. More
information about both programs can be found here:
https://www.alaska.edu/ualand/permits/hunting-revised.php.

o Realty notes that lands within the area of discussion are validly selected by the State,
therefore the Federal subsistence priority created under the Alaska National Interest
Lands Conservation Act (ANILCA) does not apply.

o ADF&G would retain management of fish and wildlife resources on the lands should
ownership be transferred to the UA.

o Public access and use of UA lands for non-commercial uses such as hiking and berry
picking are allowed without a permit. Dedicated access to and through UA lands, or for
commercial applications, is available by obtaining a permit from the UALMO. More
information on the permit process can be found here:
https://www.alaska.edu/ualand/permits/.

o No RS-2477 rights-of-way or DOT 1973 inventory trails were found to exist within the
selected area. A review of satellite imagery did not reveal any trails.
o While this land was selected by the State of Alaska under the Alaska Statehood Act for
its public value, access potential, and long-term benefit, the selected lands currently
ranked as a mix of priority levels three (3) or medium, and four (4) or low, in the
statehood selection prioritization in the Realty Section's 2025 evaluation of selected
land. This means, while the land is selected, other state-selected lands are a higher
priority to acquire as a part of the Statehood Land Entitlement. The State has selected
more lands than remain available for conveyance under the Statehood Act, therefore
DNR is required to relinquish over-selections while actively working to fulfil its
remaining Statehood Act land entitlement. The land selection period granted in the
CAA 2023 expires in Dec. 2026 and DNR is unlikely to have completed acquisition of
the statehood land grant before the CAA 2023 grant sunsets. Therefore, DNR needs to
pursue relinquishment of the University selections simultaneously with its efforts to
continue land acquisition.

o The CAA 2023 created a mechanism for BLM to transfer lands to the UA in furtherance
of what was deemed by Congress to be a public purpose, and for management and use
consistent with the University's public mission. The State is participating in the program
towards those ends, consistent with the Alaska Constitution's Article VII directives for
the University. The scope of this decision is limited to whether DNR should relinquish
its land selection to facilitate conveyance of the lands to the UA. Realty notes the only
lands available under the CAA 2023 are lands selected or top-filed by the State under
the Alaska Statehood Act. Federal lands not selected or top-filed by the State are
unavailable for selection or transfer to UA.

Public Comment 4:
I am writing to submit my opposition to the proposed relinquishment of the State of Alaska's
entitlement land selections to the University of Alaska.

Relinquishing these selections now will remove the State's authority to impose protections for
the public. Many other non-selected federal lands across Alaska could satisfy the University's
entitlement without conflicting with established State selections or jeopardizing public access
routes. I've attached my letter for public comment. For these reasons, I strongly urge the
Department of Natural Resources to retain its selections on these parcels unless robust public
access protections including recognition of existing trails and rights-of-way are guaranteed
prior to any relinquishment or conveyance.

Thank you for considering my comments during this public input period.
On behalf of myself, Shelby Wood, I submit the following concerns regarding the proposed
relinquishment of State of Alaska land selections for the purpose of conveyance to the
University of Alaska. The land selections I am concerned with is Kauk River and Selawik
Hills.

I recognize the intent of the federal Consolidated Appropriations Act for Fiscal Year 2023 to
resolve the University of Alaska's historical land grant entitlement. However, these parcels
raise serious concerns because they were already strategically selected by the State of Alaska
under the Alaska Statehood Act for their public value, access potential, and long-term benefit
to Alaskans. Alaska's land selection process, guided by Article VIII of the Alaska Constitution,
prioritizes managing resources for the maximum benefit of the people and protecting public
access to land and water. By selecting these lands, the State positioned itself to secure
easements, recognize trails (including RS 2477 rights-of-way), and ensure continued public
use. Relinquishing the selections now would strip the State of its authority to impose those
protections, such as requiring BLM to reserve easements or subject the University's title to
public access corridors, bypassing the established framework designed to keep these lands in
the public interest.

These areas contain established trail systems and patterns of traditional use. I personally use
this area for Hiking. I have concerns regarding Loss of public access to trails and routes, Risk
to existing/historic RS2477 rights-of-way, Bypassing State's land selection process under
Statehood Act, Potential closure of traditional use areas, better alternatives exist on nonselected
federal lands elsewhere. Relinquishing before routes are documented and
protected will permanently disrupt generational access.

Other non-selected federal lands across Alaska could satisfy the University's entitlement
without conflicting with State selections or endangering public access. For these reasons, I
believe the State should not relinquish its selections on these parcels under the current proposed
conditions. I respectfully urge the State of Alaska to retain its selections on these parcels unless
public access protections, including recognition of existing trails and rights-of-way, can be
guaranteed prior to any conveyance.

o DMLW Realty Response: Thank you for your comments. UALMO has created a
program allowing hunting and subsistence activities on UA lands. Additionally, during
the review period of this decision, UALMO implemented a trapping program. More
information about both programs can be found here:
https://www.alaska.edu/ualand/permits/hunting-revised.php.

o Realty notes that lands within the area of discussion are validly selected by the State,
therefore the Federal subsistence priority created under the Alaska National Interest
Lands Conservation Act (ANILCA) does not apply.

o ADF&G would retain management of fish and wildlife resources on the lands should
ownership be transferred to the UA.

o Public access and use of UA lands for non-commercial uses such as hiking and berry
picking are allowed without a permit. Dedicated access to and through UA lands, or for
commercial applications, is available by obtaining a permit from the UALMO. More
information on the permit process can be found here:
https://www.alaska.edu/ualand/permits/.

o No RS-2477 rights-of-way or DOT 1973 inventory trails were found to exist in these
two parcels. An examination of satellite imagery did not reveal the presence of trails
on the lands.

o While this land was selected by the State of Alaska under the Alaska Statehood Act for
its public value, access potential, and long-term benefit, the selected lands currently
ranked as a mix of priority levels three (3) or medium, and four (4) or low, in the
statehood selection prioritization in the Realty Section's 2025 evaluation of selected
land. This means, while the land is selected, other state-selected lands are a higher
priority to acquire as a part of the Statehood Land Entitlement. The State has selected
more lands than remain available for conveyance under the Statehood Act, therefore
DNR is required to relinquish over-selections while actively working to fulfil its
remaining Statehood Act land entitlement. The land selection period granted in the
CAA 2023 expires in Dec. 2026 and DNR is unlikely to have completed acquisition of
the statehood land grant before the CAA 2023 grant sunsets. Therefore, DNR needs to
pursue relinquishment of the University selections simultaneously with its efforts to
continue land acquisition.

o The CAA 2023 created a mechanism for BLM to transfer lands to the UA in furtherance
of what was deemed by Congress to be a public purpose, and for management and use
consistent with the University's public mission. The State is participating in the program
towards those ends, consistent with the Alaska Constitution's Article VII directives for
the University. The scope of this decision is limited to whether DNR should relinquish
its land selection to facilitate conveyance of the lands to the UA. Realty notes the only
lands available under the CAA 2023 are lands selected or top-filed by the State under
the Alaska Statehood Act. Federal lands not selected or top-filed by the State are
unavailable for selection or transfer to UA.

Public Comment 5:
I am writing to submit my opposition to the proposed relinquishment of the State of Alaska's
entitlement land selections to the University of Alaska.

Relinquishing these selections now will remove the State's authority to impose protections for
the public. Many other non-selected federal lands across Alaska could satisfy the University's
entitlement without conflicting with established State selections or jeopardizing public access
routes. I've attached my letter for public comment. For these reasons, I strongly urge the
Department of Natural Resources to retain its selections on these parcels unless robust public
access protections including recognition of existing trails and rights-of-way are guaranteed
prior to any relinquishment or conveyance.

Thank you for considering my comments during this public input period.
On behalf of myself, Craig Allen, I submit the following concerns regarding the proposed
relinquishment of State of Alaska land selections for the purpose of conveyance to the
University of Alaska. The land selections I am concerned with are {the Land}.

I recognize the intent of the federal Consolidated Appropriations Act for Fiscal Year 2023 to
resolve the University of Alaska's historical land grant entitlement. However, these parcels
raise serious concerns because they were already strategically selected by the State of Alaska
under the Alaska Statehood Act for their public value, access potential, and long-term benefit
to Alaskans. Alaska's land selection process, guided by Article VIII of the Alaska Constitution,
prioritizes managing resources for the maximum benefit of the people and protecting public
access to land and water. By selecting these lands, the State positioned itself to secure
easements, recognize trails (including RS 2477 rights-of-way), and ensure continued public
use. Relinquishing the selections now would strip the State of its authority to impose those
protections, such as requiring BLM to reserve easements or subject the University's title to
public access corridors, bypassing the established framework designed to keep these lands in
the public interest.

These areas contain established trail systems and patterns of traditional use. I personally use
this area for Hunting, Fishing, Hiking, Camping. I have concerns regarding Loss of public
access to trails and routes, Risk to existing/historic RS2477 rights-of-way, Bypassing State's
land selection process under Statehood Act, Potential closure of traditional use areas, Better
alternatives exist on non-selected federal lands elsewhere. Relinquishing before routes are
documented and protected will permanently disrupt generational access.
Other non-selected federal lands across Alaska could satisfy the University's entitlement
without conflicting with State selections or endangering public access. For these reasons, I
believe the State should not relinquish its selections on these parcels under the current proposed
conditions. I respectfully urge the State of Alaska to retain its selections on these parcels unless
public access protections, including recognition of existing trails and rights-of-way, can be
guaranteed prior to any conveyance.

o DMLW Realty Response: Thank you for your comments. UALMO has created a
program allowing hunting and subsistence activities on UA lands. Additionally, during
the review period of this decision, the UALMO implemented a trapping program. More
information about both programs can be found here:
https://www.alaska.edu/ualand/permits/hunting-revised.php.

o Realty notes that lands within the area of discussion are validly selected by the State,
therefore the Federal subsistence priority created under the Alaska National Interest
Lands Conservation Act (ANILCA) does not apply.

o ADF&G would retain management of fish and wildlife resources on the lands should
ownership be transferred to the UA.

o Public access and use of UA lands for non-commercial uses such as hiking and berry
picking are allowed without a permit. Dedicated access to and through UA lands, or for
commercial applications, is available by obtaining a permit from the UALMO. More
information on the permit process can be found here:
https://www.alaska.edu/ualand/permits/.

o No RS-2477 rights-of-way or DOT 1973 inventory trails were found to exist in these
two parcels. A review of satellite imagery did not reveal the existence of trails on the
lands.

o While this land was selected by the State of Alaska under the Alaska Statehood Act for
its public value, access potential, and long-term benefit, the selected lands currently
ranked as a mix of priority levels three (3) or medium, and four (4) or low, in the
statehood selection prioritization in the Realty Section's 2025 evaluation of selected
land. This means, while the land is selected, other state-selected lands are a higher
priority to acquire as a part of the Statehood Land Entitlement. The State has selected
more lands than remain available for conveyance under the Statehood Act, therefore
DNR is required to relinquish over-selections while actively working to fulfil its
remaining Statehood Act land entitlement. The land selection period granted in the
CAA 2023 expires in Dec. 2026 and DNR is unlikely to have completed acquisition of
the statehood land grant before the CAA 2023 grant sunsets. Therefore, DNR needs to
pursue relinquishment of the University selections simultaneously with its efforts to
continue land acquisition.

o The CAA 2023 created a mechanism for BLM to transfer lands to the UA in furtherance
of what was deemed by Congress to be a public purpose, and for management and use
consistent with the University's public mission. The State is participating in the program
towards those ends, consistent with the Alaska Constitution's Article VII directives for
the University. The scope of this decision is limited to whether DNR should relinquish
its land selection to facilitate conveyance of the lands to the UA. Realty notes the only
lands available under the CAA 2023 are lands selected or top-filed by the State under
the Alaska Statehood Act. Federal lands not selected or top-filed by the State are
unavailable for selection or transfer to UA.

Public Comment 6:
I am writing to submit my opposition to the proposed relinquishment of the State of Alaska's
entitlement land selections to the University of Alaska.

Relinquishing these selections now will remove the State's authority to impose protections for
the public. Many other non-selected federal lands across Alaska could satisfy the University's
entitlement without conflicting with established State selections or jeopardizing public access
routes. I've attached my letter for public comment. For these reasons, I strongly urge the
Department of Natural Resources to retain its selections on these parcels unless robust public
access protections including recognition of existing trails and rights-of-way are guaranteed
prior to any relinquishment or conveyance.

Thank you for considering my comments during this public input period.
On behalf of myself, Kaylee Cabana, I submit the following concerns regarding the proposed
relinquishment of State of Alaska land selections for the purpose of conveyance to the
University of Alaska. The land selections I am concerned with is...

I recognize the intent of the federal Consolidated Appropriations Act for Fiscal Year 2023 to
resolve the University of Alaska's historical land grant entitlement. However, these parcels
raise serious concerns because they were already strategically selected by the State of Alaska
under the Alaska Statehood Act for their public value, access potential, and long-term benefit
to Alaskans. Alaska's land selection process, guided by Article VIII of the Alaska Constitution,
prioritizes managing resources for the maximum benefit of the people and protecting public
access to land and water. By selecting these lands, the State positioned itself to secure
easements, recognize trails (including RS 2477 rights-of-way), and ensure continued public
use. Relinquishing the selections now would strip the State of its authority to impose those
protections, such as requiring BLM to reserve easements or subject the University's title to
public access corridors, bypassing the established framework designed to keep these lands in
the public interest.

These areas contain established trail systems and patterns of traditional use. I personally use
this area for Subsistence Activities, Historical/Family Traditional Use. I have concerns
regarding Loss of public access to trails and routes, Potential closure of traditional use areas,
Better alternatives exist on non-selected federal lands elsewhere. Relinquishing before routes
are documented and protected will permanently disrupt generational access.

Other non-selected federal lands across Alaska could satisfy the University's entitlement
without conflicting with State selections or endangering public access. For these reasons, I
believe the State should not relinquish its selections on these parcels under the current proposed
conditions. I respectfully urge the State of Alaska to retain its selections on these parcels unless
public access protections, including recognition of existing trails and rights-of-way, can be
guaranteed prior to any conveyance.

o DMLW Realty Response: Thank you for your comments. UALMO has created a
program allowing hunting and subsistence activities on UA lands. Additionally, during
the review period of this decision, UALMO implemented a trapping program. More
information about both programs can be found here:
https://www.alaska.edu/ualand/permits/hunting-revised.php.

o Realty notes that lands within the area of discussion are validly selected by the State,
therefore the Federal subsistence priority created under the Alaska National Interest
Lands Conservation Act (ANILCA) does not apply.

o ADF&G would retain management of fish and wildlife resources on the lands should
ownership be transferred to the UA.

o Public access and use of UA lands for non-commercial uses such as hiking and berry
picking are allowed without a permit. Dedicated access to and through UA lands, or for
commercial applications, is available by obtaining a permit from the UALMO. More
information on the permit process can be found here:
https://www.alaska.edu/ualand/permits/.

o No RS-2477 rights-of-way or DOT 1973 inventory trails were found to exist in these
two parcels. Realty reviewed satellite imagery for existing trails on the land, and none
were found.

o While this land was selected by the State of Alaska under the Alaska Statehood Act for
its public value, access potential, and long-term benefit, the selected lands currently
ranked as a mix of priority levels three (3) or medium, and four (4) or low, in the
statehood selection prioritization in the Realty Section's 2025 evaluation of selected
land. This means, while the land is selected, other state-selected lands are a higher
priority to acquire as a part of the Statehood Land Entitlement. The State has selected
more lands than remain available for conveyance under the Statehood Act, therefore
DNR is required to relinquish over-selections while actively working to fulfil its
remaining Statehood Act land entitlement. The land selection period granted in the
CAA 2023 expires in Dec. 2026 and DNR is unlikely to have completed acquisition of
the statehood land grant before the CAA 2023 grant sunsets. Therefore, DNR needs to
pursue relinquishment of the University selections simultaneously with its efforts to
continue land acquisition.

o The CAA 2023 created a mechanism for BLM to transfer lands to the UA in furtherance
of what was deemed by Congress to be a public purpose, and for management and use
consistent with the University's public mission. The State is participating in the program
towards those ends, consistent with the Alaska Constitution's Article VII directives for
the University. The scope of this decision is limited to whether DNR should relinquish
its land selection to facilitate conveyance of the lands to the UA. Realty notes the only
lands available under the CAA 2023 are lands selected or top-filed by the State under
the Alaska Statehood Act. Federal lands not selected or top-filed by the State are
unavailable for selection or transfer to UA.

Public Comment 7:
I am writing to submit my opposition to the proposed relinquishment of the State of Alaska's
entitlement land selections to the University of Alaska.

Relinquishing these selections now will remove the State's authority to impose protections for
the public. Many other non-selected federal lands across Alaska could satisfy the University's
entitlement without conflicting with established State selections or jeopardizing public access
routes. I've attached my letter for public comment. For these reasons, I strongly urge the
Department of Natural Resources to retain its selections on these parcels unless robust public
access protections including recognition of existing trails and rights-of-way are guaranteed
prior to any relinquishment or conveyance.

Thank you for considering my comments during this public input period.
On behalf of myself, Paul Turinsky, I submit the following concerns regarding the proposed
relinquishment of State of Alaska land selections for the purpose of conveyance to the
University of Alaska. The land selections I am concerned with is.

I recognize the intent of the federal Consolidated Appropriations Act for Fiscal Year 2023 to
resolve the University of Alaska's historical land grant entitlement. However, these parcels
raise serious concerns because they were already strategically selected by the State of Alaska
under the Alaska Statehood Act for their public value, access potential, and long-term benefit
to Alaskans. Alaska's land selection process, guided by Article VIII of the Alaska Constitution,
prioritizes managing resources for the maximum benefit of the people and protecting public
access to land and water. By selecting these lands, the State positioned itself to secure
easements, recognize trails (including RS 2477 rights-of-way), and ensure continued public
use. Relinquishing the selections now would strip the State of its authority to impose those
protections, such as requiring BLM to reserve easements or subject the University's title to
public access corridors, bypassing the established framework designed to keep these lands in
the public interest.

These areas contain established trail systems and patterns of traditional use. I personally use
this area for Hunting, Snowmaching, ok. I have concerns regarding Loss of public access to
trails and routes, Risk to existing/historic RS2477 rights-of-way, Potential closure of
traditional use areas, it is for WE THE PEOPLE. Relinquishing before routes are documented
and protected will permanently disrupt generational access.

Other non-selected federal lands across Alaska could satisfy the University's entitlement
without conflicting with State selections or endangering public access. For these reasons, I
believe the State should not relinquish its selections on these parcels under the current proposed
conditions. I respectfully urge the State of Alaska to retain its selections on these parcels unless
public access protections, including recognition of existing trails and rights-of-way, can be
guaranteed prior to any conveyance.

o DMLW Realty Response: Thank you for your comments. UALMO has created a
program allowing hunting and subsistence activities on UA lands. Additionally, during
the review period of this decision, UALMO implemented a trapping program. More
information about both programs can be found here:
https://www.alaska.edu/ualand/permits/hunting-revised.php.

o Realty notes that lands within the area of discussion are validly selected by the State,
therefore the Federal subsistence priority created under the Alaska National Interest
Lands Conservation Act (ANILCA) does not apply.

o ADF&G would retain management of fish and wildlife resources on the lands should
ownership be transferred to the UA.

o Public access and use of UA lands for non-commercial uses such as hiking and berry
picking are allowed without a permit. Dedicated access to and through UA lands, or for
commercial applications, is available by obtaining a permit from the UALMO. More
information on the permit process can be found here:
https://www.alaska.edu/ualand/permits/.

o No RS-2477 rights-of-way or DOT 1973 inventory trails were found to exist in these
two parcels. Realty reviewed satellite imagery of the UA selected areas and none were
found.

o While this land was selected by the State of Alaska under the Alaska Statehood Act for
its public value, access potential, and long-term benefit, the selected lands currently
ranked as a mix of priority levels three (3) or medium, and four (4) or low, in the
statehood selection prioritization in the Realty Section's 2025 evaluation of selected
land. This means, while the land is selected, other state-selected lands are a higher
priority to acquire as a part of the Statehood Land Entitlement. The State has selected
more lands than remain available for conveyance under the Statehood Act, therefore
DNR is required to relinquish over-selections while actively working to fulfil its
remaining Statehood Act land entitlement. The land selection period granted in the
CAA 2023 expires in Dec. 2026 and DNR is unlikely to have completed acquisition of
the statehood land grant before the CAA 2023 grant sunsets. Therefore, DNR needs to
pursue relinquishment of the University selections simultaneously with its efforts to
continue land acquisition.

o The CAA 2023 created a mechanism for BLM to transfer lands to the UA in furtherance
of what was deemed by Congress to be a public purpose, and for management and use
consistent with the University's public mission. The State is participating in the program
towards those ends, consistent with the Alaska Constitution's Article VII directives for
the University. The scope of this decision is limited to whether DNR should relinquish
its land selection to facilitate conveyance of the lands to the UA. Realty notes the only
lands available under the CAA 2023 are lands selected or top-filed by the State under
the Alaska Statehood Act. Federal lands not selected or top-filed by the State are
unavailable for selection or transfer to UA.

Public Comment 8:
I am writing to submit my opposition to the proposed relinquishment of the State of Alaska's
entitlement land selections to the University of Alaska.

Relinquishing these selections now will remove the State's authority to impose protections for
the public. Many other non-selected federal lands across Alaska could satisfy the University's
entitlement without conflicting with established State selections or jeopardizing public access
routes. I've attached my letter for public comment. For these reasons, I strongly urge the
Department of Natural Resources to retain its selections on these parcels unless robust public
access protections including recognition of existing trails and rights-of-way are guaranteed
prior to any relinquishment or conveyance.

Thank you for considering my comments during this public input period.
On behalf of myself, Ty Svedin, I submit the following concerns regarding the proposed
relinquishment of State of Alaska land selections for the purpose of conveyance to the
University of Alaska. The land selections I am concerned with are {the Land}.

I recognize the intent of the federal Consolidated Appropriations Act for Fiscal Year 2023 to
resolve the University of Alaska's historical land grant entitlement. However, these parcels
raise serious concerns because they were already strategically selected by the State of Alaska
under the Alaska Statehood Act for their public value, access potential, and long-term benefit
to Alaskans. Alaska's land selection process, guided by Article VIII of the Alaska Constitution,
prioritizes managing resources for the maximum benefit of the people and protecting public
access to land and water. By selecting these lands, the State positioned itself to secure
easements, recognize trails (including RS 2477 rights-of-way), and ensure continued public
use. Relinquishing the selections now would strip the State of its authority to impose those
protections, such as requiring BLM to reserve easements or subject the University's title to
public access corridors, bypassing the established framework designed to keep these lands in
the public interest.

These areas contain established trail systems and patterns of traditional use. I personally use
this area for Hunting, Fishing, Subsistence Activities, Hiking. I have concerns regarding Loss
of public access to trails and routes, Risk to existing/historic RS2477 rights-of-way, Bypassing
State's land selection process under Statehood Act, Potential closure of traditional use areas,
Better alternatives exist on non-selected federal lands elsewhere. Relinquishing before routes
are documented and protected will permanently disrupt generational access.

Other non-selected federal lands across Alaska could satisfy the University's entitlement
without conflicting with State selections or endangering public access. For these reasons, I
believe the State should not relinquish its selections on these parcels under the current proposed
conditions. I respectfully urge the State of Alaska to retain its selections on these parcels unless
public access protections, including recognition of existing trails and rights-of-way, can be
guaranteed prior to any conveyance.

o DMLW Realty Response: Thank you for your comments. UALMO has created a
program allowing hunting and subsistence activities on UA lands. Additionally, during
the review period of this decision, UALMO implemented a trapping program. More
information about both programs can be found here:
https://www.alaska.edu/ualand/permits/hunting-revised.php.

o Realty notes that most lands within the area of discussion are validly selected by the
State, therefore the Federal subsistence priority created under the Alaska National
Interest Lands Conservation Act (ANILCA) does not apply.

o ADF&G would retain management of fish and wildlife resources on the lands should
ownership be transferred to the UA.

o Public access and use of UA lands for non-commercial uses such as hiking and berry
picking are allowed without a permit. Dedicated access to and through UA lands, or for
commercial applications, is available by obtaining a permit from the UALMO. More
information on the permit process can be found here:
https://www.alaska.edu/ualand/permits/.

o No RS-2477 rights-of-way or DOT 1973 inventory trails were found to exist in these
two parcels.

o While this land was selected by the State of Alaska under the Alaska Statehood Act for
its public value, access potential, and long-term benefit, the selected lands currently
ranked as a mix of priority levels three (3) or medium, and four (4) or low, in the
statehood selection prioritization in the Realty Section's 2025 evaluation of selected
land. This means, while the land is selected, other state-selected lands are a higher
priority to acquire as a part of the Statehood Land Entitlement. The State has selected
more lands than remain available for conveyance under the Statehood Act, therefore
DNR is required to relinquish over-selections while actively working to fulfil its
remaining Statehood Act land entitlement. The land selection period granted in the
CAA 2023 expires in Dec. 2026 and DNR is unlikely to have completed acquisition of
the statehood land grant before the CAA 2023 grant sunsets. Therefore, DNR needs to
pursue relinquishment of the University selections simultaneously with its efforts to
continue land acquisition.

o The CAA 2023 created a mechanism for BLM to transfer lands to the UA in furtherance
of what was deemed by Congress to be a public purpose, and for management and use
consistent with the University's public mission. The State is participating in the program
towards those ends, consistent with the Alaska Constitution's Article VII directives for
the University. The scope of this decision is limited to whether DNR should relinquish
its land selection to facilitate conveyance of the lands to the UA. Realty notes the only
lands available under the CAA 2023 are lands selected or top-filed by the State under
the Alaska Statehood Act. Federal lands not selected or top-filed by the State are
unavailable for selection or transfer to UA.

Public Comment 9:
I am writing to submit my opposition to the proposed relinquishment of the State of Alaska's
entitlement land selections to the University of Alaska.

Relinquishing these selections now will remove the State's authority to impose protections for
the public. Many other non-selected federal lands across Alaska could satisfy the University's
entitlement without conflicting with established State selections or jeopardizing public access
routes. I've attached my letter for public comment. For these reasons, I strongly urge the
Department of Natural Resources to retain its selections on these parcels unless robust public
access protections including recognition of existing trails and rights-of-way are guaranteed
prior to any relinquishment or conveyance.

Thank you for considering my comments during this public input period.
On behalf of myself, David Malzac, I submit the following concerns regarding the proposed
relinquishment of State of Alaska land selections for the purpose of conveyance to the
University of Alaska. The land selections I am concerned with are Honolulu Pass, Kauk River
and Selawik Hills, Pediment Creek, Atigun River, Elrington.

I recognize the intent of the federal Consolidated Appropriations Act for Fiscal Year 2023 to
resolve the University of Alaska's historical land grant entitlement. However, these parcels
raise serious concerns because they were already strategically selected by the State of Alaska
under the Alaska Statehood Act for their public value, access potential, and long-term benefit
to Alaskans. Alaska's land selection process, guided by Article VIII of the Alaska Constitution,
prioritizes managing resources for the maximum benefit of the people and protecting public
access to land and water. By selecting these lands, the State positioned itself to secure
easements, recognize trails (including RS 2477 rights-of-way), and ensure continued public
use. Relinquishing the selections now would strip the State of its authority to impose those
protections, such as requiring BLM to reserve easements or subject the University's title to
public access corridors, bypassing the established framework designed to keep these lands in
the public interest.

These areas contain established trail systems and patterns of traditional use. I personally use
this area for Hunting, Fishing, Hiking, Snowmaching. I have concerns regarding Loss of public
access to trails and routes, Risk to existing/historic RS2477 rights-of-way, Bypassing State's
land selection process under Statehood Act, Potential closure of traditional use areas, Better
alternatives exist on non-selected federal lands elsewhere. Relinquishing before routes are
documented and protected will permanently disrupt generational access.

Other non-selected federal lands across Alaska could satisfy the University's entitlement
without conflicting with State selections or endangering public access. For these reasons, I
believe the State should not relinquish its selections on these parcels under the current proposed
conditions. I respectfully urge the State of Alaska to retain its selections on these parcels unless
public access protections, including recognition of existing trails and rights-of-way, can be
guaranteed prior to any conveyance.

o DMLW Realty Response: Thank you for your comments. UALMO has created a
program allowing hunting and subsistence activities on UA lands. Additionally, during
the review period of this decision, UALMO implemented a trapping program. More
information about both programs can be found here:
https://www.alaska.edu/ualand/permits/hunting-revised.php.

o Realty notes that most lands within the area of discussion are validly selected by the
State, therefore the Federal subsistence priority created under the Alaska National
Interest Lands Conservation Act (ANILCA) does not apply.

o ADF&G would retain management of fish and wildlife resources on the lands should
ownership be transferred to the UA.

o Public access and use of UA lands for non-commercial uses such as hiking and berry
picking are allowed without a permit. Dedicated access to and through UA lands, or for
commercial applications, is available by obtaining a permit from the UALMO. More
information on the permit process can be found here:
https://www.alaska.edu/ualand/permits/.

o No RS-2477 rights-of-way or DOT 1973 inventory trails were found to exist in these
two parcels.

o While this land was selected by the State of Alaska under the Alaska Statehood Act for
its public value, access potential, and long-term benefit, the selected lands currently
ranked as a mix of priority levels three (3) or medium, and four (4) or low, in the
statehood selection prioritization in the Realty Section's 2025 evaluation of selected
land. This means, while the land is selected, other state-selected lands are a higher
priority to acquire as a part of the Statehood Land Entitlement. The State has selected
more lands than remain available for conveyance under the Statehood Act, therefore
DNR is required to relinquish over-selections while actively working to fulfil its
remaining Statehood Act land entitlement. The land selection period granted in the
CAA 2023 expires in Dec. 2026 and DNR is unlikely to have completed acquisition of
the statehood land grant before the CAA 2023 grant sunsets. Therefore, DNR needs to
pursue relinquishment of the University selections simultaneously with its efforts to
continue land acquisition.

o The CAA 2023 created a mechanism for BLM to transfer lands to the UA in furtherance
of what was deemed by Congress to be a public purpose, and for management and use
consistent with the University's public mission. The State is participating in the program
towards those ends, consistent with the Alaska Constitution's Article VII directives for
the University. The scope of this decision is limited to whether DNR should relinquish
its land selection to facilitate conveyance of the lands to the UA. Realty notes the only
lands available under the CAA 2023 are lands selected or top-filed by the State under
the Alaska Statehood Act. Federal lands not selected or top-filed by the State are
unavailable for selection or transfer to UA.

Public Comment 10:
I am writing to submit my opposition to the proposed relinquishment of the State of Alaska's
entitlement land selections to the University of Alaska.

Relinquishing these selections now will remove the State's authority to impose protections for
the public. Many other non-selected federal lands across Alaska could satisfy the University's
entitlement without conflicting with established State selections or jeopardizing public access
routes. I've attached my letter for public comment. For these reasons, I strongly urge the
Department of Natural Resources to retain its selections on these parcels unless robust public
access protections including recognition of existing trails and rights-of-way are guaranteed
prior to any relinquishment or conveyance.

Thank you for considering my comments during this public input period.
On behalf of myself, Holly Bernosky, I submit the following concerns regarding the proposed
relinquishment of State of Alaska land selections for the purpose of conveyance to the
University of Alaska. The land selections I am concerned with are Honolulu Pass, Kauk River
and Selawik Hills, Pediment Creek, Atigun River, Elrington.

I recognize the intent of the federal Consolidated Appropriations Act for Fiscal Year 2023 to
resolve the University of Alaska's historical land grant entitlement. However, these parcels
raise serious concerns because they were already strategically selected by the State of Alaska
under the Alaska Statehood Act for their public value, access potential, and long-term benefit
to Alaskans. Alaska's land selection process, guided by Article VIII of the Alaska Constitution,
prioritizes managing resources for the maximum benefit of the people and protecting public
access to land and water. By selecting these lands, the State positioned itself to secure
easements, recognize trails (including RS 2477 rights-of-way), and ensure continued public
use. Relinquishing the selections now would strip the State of its authority to impose those
protections, such as requiring BLM to reserve easements or subject the University's title to
public access corridors, bypassing the established framework designed to keep these lands in
the public interest.

These areas contain established trail systems and patterns of traditional use. I personally use
this area for Hunting, Fishing, Snowmaching. I have concerns regarding Loss of public access
to trails and routes, Risk to existing/historic RS2477 rights-of-way, Bypassing State's land
selection process under Statehood Act, Potential closure of traditional use areas, Better
alternatives exist on non-selected federal lands elsewhere. Relinquishing before routes are
documented and protected will permanently disrupt generational access. Please don't let these
lands transfer out of public ownership. This a beautiful country, meant for all to enjoy.

Other non-selected federal lands across Alaska could satisfy the University's entitlement
without conflicting with State selections or endangering public access. For these reasons, I
believe the State should not relinquish its selections on these parcels under the current proposed
conditions. I respectfully urge the State of Alaska to retain its selections on these parcels unless
public access protections, including recognition of existing trails and rights-of-way, can be
guaranteed prior to any conveyance.

o DMLW Realty Response: Thank you for your comments. UALMO has created a
program allowing hunting and subsistence activities on UA lands. Additionally, during
the review period of this decision, UALMO implemented a trapping program. More
information about both programs can be found here:
https://www.alaska.edu/ualand/permits/hunting-revised.php.

o Realty notes that most lands within the area of discussion are validly selected by the
State, therefore the Federal subsistence priority created under the Alaska National
Interest Lands Conservation Act (ANILCA) does not apply.

o ADF&G would retain management of fish and wildlife resources on the lands should
ownership be transferred to the UA.

o Public access and use of UA lands for non-commercial uses such as hiking and berry
picking are allowed without a permit. Dedicated access to and through UA lands, or for
commercial applications, is available by obtaining a permit from the UALMO. More
information on the permit process can be found here:
https://www.alaska.edu/ualand/permits/.

o No RS-2477 rights-of-way or DOT 1973 inventory trails were found to exist in these
two parcels.

o While this land was selected by the State of Alaska under the Alaska Statehood Act for
its public value, access potential, and long-term benefit, the selected lands currently
ranked as a mix of priority levels three (3) or medium, and four (4) or low, in the
statehood selection prioritization in the Realty Section's 2025 evaluation of selected
land. This means, while the land is selected, other state-selected lands are a higher
priority to acquire as a part of the Statehood Land Entitlement. The State has selected
more lands than remain available for conveyance under the Statehood Act, therefore
DNR is required to relinquish over-selections while actively working to fulfil its
remaining Statehood Act land entitlement. The land selection period granted in the
CAA 2023 expires in Dec. 2026 and DNR is unlikely to have completed acquisition of
the statehood land grant before the CAA 2023 grant sunsets. Therefore, DNR needs to
pursue relinquishment of the University selections simultaneously with its efforts to
continue land acquisition.

o The CAA 2023 created a mechanism for BLM to transfer lands to the UA in furtherance
of what was deemed by Congress to be a public purpose, and for management and use
consistent with the University's public mission. The State is participating in the program
towards those ends, consistent with the Alaska Constitution's Article VII directives for
the University. The scope of this decision is limited to whether DNR should relinquish
its land selection to facilitate conveyance of the lands to the UA. Realty notes the only
lands available under the CAA 2023 are lands selected or top-filed by the State under
the Alaska Statehood Act. Federal lands not selected or top-filed by the State are
unavailable for selection or transfer to UA.

Public Comment 11:
I am writing to submit my opposition to the proposed relinquishment of the State of Alaska's
entitlement land selections to the University of Alaska.

Relinquishing these selections now will remove the State's authority to impose protections for
the public. Many other non-selected federal lands across Alaska could satisfy the University's
entitlement without conflicting with established State selections or jeopardizing public access
routes. I've attached my letter for public comment. For these reasons, I strongly urge the
Department of Natural Resources to retain its selections on these parcels unless robust public
access protections including recognition of existing trails and rights-of-way are guaranteed
prior to any relinquishment or conveyance.

Thank you for considering my comments during this public input period.
On behalf of myself, Michele Stevens, I submit the following concerns regarding the proposed
relinquishment of State of Alaska land selections for the purpose of conveyance to the
University of Alaska. The land selections I am concerned with are Honolulu Pass, Kauk River
and Selawik Hills, Pediment Creek, Atigun River, Elrington.

I recognize the intent of the federal Consolidated Appropriations Act for Fiscal Year 2023 to
resolve the University of Alaska's historical land grant entitlement. However, these parcels
raise serious concerns because they were already strategically selected by the State of Alaska
under the Alaska Statehood Act for their public value, access potential, and long-term benefit
to Alaskans. Alaska's land selection process, guided by Article VIII of the Alaska Constitution,
prioritizes managing resources for the maximum benefit of the people and protecting public
access to land and water. By selecting these lands, the State positioned itself to secure
easements, recognize trails (including RS 2477 rights-of-way), and ensure continued public
use. Relinquishing the selections now would strip the State of its authority to impose those
protections, such as requiring BLM to reserve easements or subject the University's title to
public access corridors, bypassing the established framework designed to keep these lands in
the public interest.

These areas contain established trail systems and patterns of traditional use. I personally use
this area for Hunting, Fishing, Subsistence Activities, Snowmaching, Historical/Family
Traditional Use. I have concerns regarding Loss of public access to trails and routes, Risk to
existing/historic RS2477 rights-of-way, Bypassing State's land selection process under
Statehood Act, Potential closure of traditional use areas. Relinquishing before routes are
documented and protected will permanently disrupt generational access. An additional
concern is that the federal government has not yet conveyed all of the land owed to Alaska
under the Alaska Statehood Act. Millions of acres promised to the State remain unconveyed.
These lands were intended to provide an economic base and long-term opportunity for the
people of Alaska.

Other non-selected federal lands across Alaska could satisfy the University's entitlement
without conflicting with State selections or endangering public access. For these reasons, I
believe the State should not relinquish its selections on these parcels under the current proposed
conditions. I respectfully urge the State of Alaska to retain its selections on these parcels unless
public access protections, including recognition of existing trails and rights-of-way, can be
guaranteed prior to any conveyance. I respectfully encourage the Alaska Department of
Natural Resources to ensure that future land conveyances and allocations prioritize broad
public access, opportunity, and benefit for the people of Alaska before transferring large blocks
of land to individual institutions.

In closing, the federal government still owes Alaska millions
of acres under the Alaska Statehood Act. These lands were promised to provide opportunity
and economic strength for the people of this state. Our Constitution is clear that Alaska's
natural resources are reserved for the common use of all Alaskans. As these lands are
transferred, the priority must remain with the people of Alaska. Allocations to institutions such
as the University of Alaska should not come before fulfilling the broader public interest and
ensuring that the benefits of these lands remain available to all Alaskans.

o DMLW Realty Response: Thank you for your comments. UALMO has created a
program allowing hunting and subsistence activities on UA lands. Additionally, during
the review period of this decision, UALMO implemented a trapping program. More
information about both programs can be found here:
https://www.alaska.edu/ualand/permits/hunting-revised.php.

o Realty notes that most lands within the area of discussion are validly selected by the
State, therefore the Federal subsistence priority created under the Alaska National
Interest Lands Conservation Act (ANILCA) does not apply.

o ADF&G would retain management of fish and wildlife resources on the lands should
ownership be transferred to the UA.

o Public access and use of UA lands for non-commercial uses such as hiking and berry
picking are allowed without a permit. Dedicated access to and through UA lands, or for
commercial applications, is available by obtaining a permit from the UALMO. More
information on the permit process can be found here:
https://www.alaska.edu/ualand/permits/.

o No RS-2477 rights-of-way or DOT 1973 inventory trails were found to exist in these
two parcels.

o While this land was selected by the State of Alaska under the Alaska Statehood Act for
its public value, access potential, and long-term benefit, the selected lands currently
ranked as a mix of priority levels three (3) or medium, and four (4) or low, in the
statehood selection prioritization in the Realty Section's 2025 evaluation of selected
land. This means, while the land is selected, other state-selected lands are a higher
priority to acquire as a part of the Statehood Land Entitlement. This means, while the
land is selected, other selected lands in the State of Alaska are a higher priority to
acquire as a part of the Statehood Land Entitlement. The State has selected more lands
than remain available for conveyance under the Statehood Act, therefore DNR is
required to relinquish over-selections while actively working to fulfil its remaining
Statehood Act land entitlement. The land selection period granted in the CAA 2023
expires in Dec. 2026 and DNR is unlikely to have completed acquisition of the
statehood land grant before the CAA 2023 grant sunsets. Therefore, DNR needs to
pursue relinquishment of the University selections simultaneously with its efforts to
continue land acquisition.

o The CAA 2023 created a mechanism for BLM to transfer lands to the UA in furtherance
of what was deemed by Congress to be a public purpose, and for management and use
consistent with the University's public mission. The State is participating in the program
towards those ends, consistent with the Alaska Constitution's Article VII directives for
the University. The scope of this decision is limited to whether DNR should relinquish
its land selection to facilitate conveyance of the lands to the UA. Realty notes the only
lands available under the CAA 2023 are lands selected or top-filed by the State under
the Alaska Statehood Act. Federal lands not selected or top-filed by the State are
unavailable for selection or transfer to UA.

Public Comment 12:
I am writing to submit my opposition to the proposed relinquishment of the State of Alaska's
entitlement land selections to the University of Alaska.

Relinquishing these selections now will remove the State's authority to impose protections for
the public. Many other non-selected federal lands across Alaska could satisfy the University's
entitlement without conflicting with established State selections or jeopardizing public access
routes. I've attached my letter for public comment. For these reasons, I strongly urge the
Department of Natural Resources to retain its selections on these parcels unless robust public
access protections including recognition of existing trails and rights-of-way are guaranteed
prior to any relinquishment or conveyance.

Thank you for considering my comments during this public input period.
On behalf of myself, Peter Firmin, I submit the following concerns regarding the proposed
relinquishment of State of Alaska land selections for the purpose of conveyance to the
University of Alaska. The land selections I am concerned with are Honolulu Pass, Kauk River
and Selawik Hills, Pediment Creek, Atigun River, Elrington.

I recognize the intent of the federal Consolidated Appropriations Act for Fiscal Year 2023 to
resolve the University of Alaska's historical land grant entitlement. However, these parcels
raise serious concerns because they were already strategically selected by the State of Alaska
under the Alaska Statehood Act for their public value, access potential, and long-term benefit
to Alaskans. Alaska's land selection process, guided by Article VIII of the Alaska Constitution,
prioritizes managing resources for the maximum benefit of the people and protecting public
access to land and water. By selecting these lands, the State positioned itself to secure
easements, recognize trails (including RS 2477 rights-of-way), and ensure continued public
use. Relinquishing the selections now would strip the State of its authority to impose those
protections, such as requiring BLM to reserve easements or subject the University's title to
public access corridors, bypassing the established framework designed to keep these lands in
the public interest.

These areas contain established trail systems and patterns of traditional use. I personally use
this area for Hunting, Fishing, Subsistence Activities, Hiking, Snowmaching,
Historical/Family Traditional Use. I have concerns regarding Loss of public access to trails
and routes, Risk to existing/historic RS2477 rights-of-way, Bypassing State's land selection
process under Statehood Act, Potential closure of traditional use areas, Better alternatives exist
on non-selected federal lands elsewhere. Relinquishing before routes are documented and
protected will permanently disrupt generational access.

Other non-selected federal lands across Alaska could satisfy the University's entitlement
without conflicting with State selections or endangering public access. For these reasons, I
believe the State should not relinquish its selections on these parcels under the current proposed
conditions. I respectfully urge the State of Alaska to retain its selections on these parcels unless
public access protections, including recognition of existing trails and rights-of-way, can be
guaranteed prior to any conveyance.

o DMLW Realty Response: Thank you for your comments. UALMO has created a
program allowing hunting and subsistence activities on UA lands. Additionally, during
the review period of this decision, UALMO implemented a trapping program. More
information about both programs can be found here:
https://www.alaska.edu/ualand/permits/hunting-revised.php.

o Realty notes that most lands within the area of discussion are validly selected by the
State, therefore the Federal subsistence priority created under the Alaska National
Interest Lands Conservation Act (ANILCA) does not apply.

o ADF&G would retain management of fish and wildlife resources on the lands should
ownership be transferred to the UA.

o Public access and use of UA lands for non-commercial uses such as hiking and berry
picking are allowed without a permit. Dedicated access to and through UA lands, or for
commercial applications, is available by obtaining a permit from the UALMO. More
information on the permit process can be found here:
https://www.alaska.edu/ualand/permits/.

o No RS-2477 rights-of-way or DOT 1973 inventory trails were found to exist in these
two parcels.

o While this land was selected by the State of Alaska under the Alaska Statehood Act for
its public value, access potential, and long-term benefit, the selected lands currently
ranked as a mix of priority levels three (3) or medium, and four (4) or low, in the
statehood selection prioritization in the Realty Section's 2025 evaluation of selected
land. This means, while the land is selected, other state-selected lands are a higher
priority to acquire as a part of the Statehood Land Entitlement. The State has selected
more lands than remain available for conveyance under the Statehood Act, therefore
DNR is required to relinquish over-selections while actively working to fulfil its
remaining Statehood Act land entitlement. The land selection period granted in the
CAA 2023 expires in Dec. 2026 and DNR is unlikely to have completed acquisition of
the statehood land grant before the CAA 2023 grant sunsets. Therefore, DNR needs to
pursue relinquishment of the University selections simultaneously with its efforts to
continue land acquisition.

o The CAA 2023 created a mechanism for BLM to transfer lands to the UA in furtherance
of what was deemed by Congress to be a public purpose, and for management and use
consistent with the University's public mission. The State is participating in the program
towards those ends, consistent with the Alaska Constitution's Article VII directives for
the University. The scope of this decision is limited to whether DNR should relinquish
its land selection to facilitate conveyance of the lands to the UA. Realty notes the only
lands available under the CAA 2023 are lands selected or top-filed by the State under
the Alaska Statehood Act. Federal lands not selected or top-filed by the State are
unavailable for selection or transfer to UA.

Public Comment 13:
I am writing to submit my opposition to the proposed relinquishment of the State of Alaska's
entitlement land selections to the University of Alaska.

Relinquishing these selections now will remove the State's authority to impose protections for
the public. Many other non-selected federal lands across Alaska could satisfy the University's
entitlement without conflicting with established State selections or jeopardizing public access
routes. I've attached my letter for public comment. For these reasons, I strongly urge the
Department of Natural Resources to retain its selections on these parcels unless robust public
access protections including recognition of existing trails and rights-of-way are guaranteed
prior to any relinquishment or conveyance.

Thank you for considering my comments during this public input period.
On behalf of myself, Tim Marvin, I submit the following concerns regarding the proposed
relinquishment of State of Alaska land selections for the purpose of conveyance to the
University of Alaska. The land selections I am concerned with are Honolulu Pass, Kauk River
and Selawik Hills, Pediment Creek, Atigun River, Elrington.

I recognize the intent of the federal Consolidated Appropriations Act for Fiscal Year 2023 to
resolve the University of Alaska's historical land grant entitlement. However, these parcels
raise serious concerns because they were already strategically selected by the State of Alaska
under the Alaska Statehood Act for their public value, access potential, and long-term benefit
to Alaskans. Alaska's land selection process, guided by Article VIII of the Alaska Constitution,
prioritizes managing resources for the maximum benefit of the people and protecting public
access to land and water. By selecting these lands, the State positioned itself to secure
easements, recognize trails (including RS 2477 rights-of-way), and ensure continued public
use. Relinquishing the selections now would strip the State of its authority to impose those
protections, such as requiring BLM to reserve easements or subject the University's title to
public access corridors, bypassing the established framework designed to keep these lands in
the public interest.

These areas contain established trail systems and patterns of traditional use. I personally use
this area for Hunting, Fishing, Subsistence Activities, Hiking, Snowmaching, Recreation. I
have concerns regarding Loss of public access to trails and routes, Risk to existing/historic
RS2477 rights-of-way, Bypassing State's land selection process under Statehood Act, Potential
closure of traditional use areas. Relinquishing before routes are documented and protected will
permanently disrupt generational access. Any loss of trail access in Alaska represents an attack
to our way of life. We'll be making note of politicians supporting this attack.

Other non-selected federal lands across Alaska could satisfy the University's entitlement
without conflicting with State selections or endangering public access. For these reasons, I
believe the State should not relinquish its selections on these parcels under the current proposed
conditions. I respectfully urge the State of Alaska to retain its selections on these parcels unless
public access protections, including recognition of existing trails and rights-of-way, can be
guaranteed prior to any conveyance.

o DMLW Realty Response: Thank you for your comments. UALMO has created a
program allowing hunting and subsistence activities on UA lands. Additionally, during
the review period of this decision, UALMO implemented a trapping program. More
information about both programs can be found here:
https://www.alaska.edu/ualand/permits/hunting-revised.php.

o Realty notes that most lands within the area of discussion are validly selected by the
State, therefore the Federal subsistence priority created under the Alaska National
Interest Lands Conservation Act (ANILCA) does not apply.

o ADF&G would retain management of fish and wildlife resources on the lands should
ownership be transferred to the UA.

o Public access and use of UA lands for non-commercial uses such as hiking and berry
picking are allowed without a permit. Dedicated access to and through UA lands, or for
commercial applications, is available by obtaining a permit from the UALMO. More
information on the permit process can be found here:
https://www.alaska.edu/ualand/permits/.

o No RS-2477 rights-of-way or DOT 1973 inventory trails were found to exist in these
two parcels.

o While this land was selected by the State of Alaska under the Alaska Statehood Act for
its public value, access potential, and long-term benefit, the selected lands currently
ranked as a mix of priority levels three (3) or medium, and four (4) or low, in the
statehood selection prioritization in the Realty Section's 2025 evaluation of selected
land. This means, while the land is selected, other state-selected lands are a higher
priority to acquire as a part of the Statehood Land Entitlement. The State has selected
more lands than remain available for conveyance under the Statehood Act, therefore
DNR is required to relinquish over-selections while actively working to fulfil its
remaining Statehood Act land entitlement. The land selection period granted in the
CAA 2023 expires in Dec. 2026 and DNR is unlikely to have completed acquisition of
the statehood land grant before the CAA 2023 grant sunsets. Therefore, DNR needs to
pursue relinquishment of the University selections simultaneously with its efforts to
continue land acquisition.

o The CAA 2023 created a mechanism for BLM to transfer lands to the UA in furtherance
of what was deemed by Congress to be a public purpose, and for management and use
consistent with the University's public mission. The State is participating in the program
towards those ends, consistent with the Alaska Constitution's Article VII directives for
the University. The scope of this decision is limited to whether DNR should relinquish
its land selection to facilitate conveyance of the lands to the UA. Realty notes the only
lands available under the CAA 2023 are lands selected or top-filed by the State under
the Alaska Statehood Act. Federal lands not selected or top-filed by the State are
unavailable for selection or transfer to UA.

X. DISCUSSION AND ALTERNATIVES
The UA has sought additional lands to complete its territorial land grant for several decades
but has been challenged by legal restrictions about the disposal of state lands in the Statehood
Act and the State Constitution. Previous attempts to rectify the land grant deficit were
ultimately overturned in legal challenges. This history resulted in federal Congressional action
within the CAA 2023 with the intent of establishing a state and federal cooperative program to remedy the deficit and further endow the University with land. Congressional intent is for lands
to be transferred to the UA to complete the entitlement originally intended for conveyance
under the Statehood Act and to provide economic opportunities for the UA. This is consistent
with the UA's public interest mission under Title 14 of the Alaska Statutes and Title VII of the
Alaska Constitution.

DNR must consider and weigh its own and the public's interests in retaining or relinquishing
land selections while supporting the UA's public interests in new land entitlement. Such
interests include resource development, conservation, consideration of existing land uses, and
public access consistent with the public interest - which the UA shares and has many similar
tools and processes to advance. In general, there must be an overarching benefit to Alaskans
in retaining the selections and declining to participate in the Program to defeat the
Congressional intent in the CAA 2023 and the public interests of UA. Any decision DNR
makes must balance and reflect the value of providing land to the UA without undue harm to
the interests of Alaskans.

DNR notes that the CAA 2023 does not require the State to relinquish specific state selected
land and is considering UA selections in light of the balanced interests of the State. The UA's
proposed selection included lands described in Section VI.

The land described in Section VI represents a moderately sized, compact, and contiguous block
of land. Conveyance of medium to large sized blocks of land generally simplifies land and
resource management. Larger blocks help enable landscape level considerations when land use
authorizations are proposed. It helps the public understand land ownership boundaries and
acquire any relevant permits prior to land use. Additionally, it may reduce the potential for
user confusion and conflict across areas of mixed land ownership. For this reason, after agency
review comments were considered, it was administratively determined that it was in the best
interests of the State and public to consider the lands for possible relinquishment and
conveyance to the UA.

Lands surrounding the UA's Selawik Hills selection are a mixture of: Federal public lands
selected by the State and currently managed by the BLM, Federal public lands managed by the
BLM with a top-filed State selection, Federal lands managed by the BLM or the U.S. Fish and
Wildlife Service, private lands, and private Native Corporation owned lands. The State selected
the lands as possible acquisitions for natural resources, mineral, and fish and game interests.
The UA selections are currently ranked as a mix of medium and low priority for acquisition by
DNR.

The lands are not crossed by any accepted and codified Revised Statute 2477 (RS 2477) Trails.
There are no trails within the selection area that are permitted by the BLM or the State. Realty
was unable to find any evidence that trails have been surveyed or dedicated to the public. A
review of Federal records indicates there are no current applications with BLM for a permit,
easement, or right-of-way by any individuals or groups.

BLM Alaska Reindeer Grazing permit AKFF-085605 is an active permit issued that includes UA's
Selawik Hills selection and the adjoining townships. AKFF-085605 was initiated in December of
1986 and expires November of 2033. A Memorandum of Agreement (MOA) exists between BLM,
DNR, and NPS to coordinate the permitting of reindeer grazing on the Seward Peninsula, which
was last updated in 2010. The permit is a valid existing right and if the land were transferred to the UA it would no longer be subject to the MOU; Although the University's title would be "subject
to" (or subservient to) the interests held by the permittee. Once the reindeer grazing permit listed on
the deed expires, the affected party would need to work with the UALMO to obtain a new grazing
permit-subject to the availability of such a permit from UALMO.

The UA has excluded the beds of navigable waterbodies where title was conveyed to the State
at Statehood under the Submerged Lands Act and the Equal Footing Doctrine. Ownership of
the lands below the ordinary high-water mark of navigable water bodies will remain with DNR
under the Public Trust Doctrine. Both Realty and PAAD reviewed the Selawik Hills selection
and determined there are no navigable water bodies within the area. This further supports
public use and enjoyment of the area regardless of land ownership.

AS 38.05.127 requires that before a disposal of an interest in state land, DNR must determine
if waterbodies within or adjacent to the proposed area for disposal are navigable or public
water; and if they are to reserve access easements. However, statehood entitlement selections
do not provide the State with management authority or title in land, but rather a valid prior
existing right requiring BLM to convey to the state the selection when certain conditions are
met. Given this, the State is unable to reserve access easements for relinquishments of
entitlement selections but has instead met this need through the processes above.

Additionally, pursuant to 11 AAC 51.045(a)(2), DNR finds that reserving an access easement
is not necessary to ensure free access to navigable or public water. A statehood entitlement
selection does not provide the public with rights of access different from the general right of
the public to access navigable or public water bordered by non-State land: that is, the right to
use and have access to water below the ordinary high water mark for recreational or other
public purposes for which the water is used or capable of being used consistent with the public
trust. Because access to navigable or public water will remain the same after the relinquishment
of the entitlement selection as before, it is not necessary to reserve an access easement.

Balancing development, access, subsistence use, public recreation, and wildlife habitat are
challenges that must be addressed when managing the Selawik Hills lands, irrespective of
ownership. This balance is achieved through the development of land management plans, clear
land use guidelines and regulations, and a robust public notice process. Relinquishment of
State selected lands would not allow unrestricted development by the UA. Many projects and
developments require State and Federal permits regardless of land ownership. Most
development projects also require extensive studies and public consultation before a project is
approved. Any proposed development, sale, or disposal of the lands by the UA would have to
be approved by the UA Board of Regents (BOR) and would be publicly noticed under existing
UA policies.

Agency comments noted the habitat, hunting, fishing, and subsistence values of the selected
lands. While the lands have value as wildlife habitat and for subsistence related activities, it is
not clear that these values are inherently threatened by conveying the lands to the UA or require
State acquisition to preserve them. If the selection is relinquished and the lands conveyed to
the UA, personal use hunting and fishing activities will still be available under UALMO's
hunting program. Personal recreational use of the lands is allowed under existing UA BOR
policies. Commercial hunting and guiding can be permitted under UALMO's land use permit
system.

ADF&G noted that most (approximately 75%) of Game Management Unit (GMU) 23 lands
are Federally owned and managed, and that should the Federal Subsistence Board close Federal
public land to non-local users most of GMU 23 would be off-limits to many Alaska residents.
Should DNR relinquish the lands and they are subsequently conveyed to the UA, the Federal
Subsistence Board would no longer have jurisdiction on the lands. Likewise, non-commercial
hunting activities would continue on the lands under existing UALMO programs.

RADS noted that the Selawik Hills parcel and adjoining lands are classified as Mineral and
Wildlife Habitat Land in the Northwest Area Plan (NWAP). The NWAP requires any
development or use of DNR owned lands must account for potential impacts to the western
arctic caribou herd (WACH). Realty notes that DNR area plans only apply to DNR owned
lands and that the UA will not be bound by the NWAP. However, should UA acquire the
Selawik Hills parcel, it's likely that use or development proposals would have to account for
potential impacts to the WACH under State and Federally required permit reviews.

Agency comments also noted that relinquishing the Selawik Hills selection could create access
issues for adjoining DNR selected lands. Currently, DNR has less than 4 million acres of
remaining Statehood Act land available for conveyance. DNR has selected lands in and around
the Selawik Hills, however the selections are a lower priority and likely will not be acquired
by DNR due to the remote location, lack of adjoining State-owned lands, and low potential for
multiple-use opportunities. Should priorities on adjacent lands change and DNR seek title to
them, DNR can work with UALMO to secure access through the Selawik Hills parcel for any
proposed development or DNR related uses.

All public comments opposed the transfer of the lands to the UA. Commentors voiced concerns
that the UA's decision to develop or sell the lands would result in a reduction or complete loss
of access across the lands, loss of traditional use areas, or loss of subsistence, hunting, and
recreation opportunities. Commentors also raised concerns that the Selawik Hills parcel is part
of a larger strategic selection by the State under the Statehood Act, and relinquishing the lands
would deprive the State and public of access guarantees in the State Constitution and the
resources that engendered the original State selections. Commentors recommended that the
Selawik Hills parcel remain public lands unless public access protections can be guaranteed
prior to the conveyance. As discussed above regarding the policies and processes UALMO has
put in place to support access, this decision supports those interests to the greatest degree
possible, while balancing the University's interests in having valuable land available for the
program.

The public voiced concerns about limited public access to and through the Selawik Hills
selection area. Current UA policies allow for greater public access than many lands around the
state. UA policies allow unpermitted non-commercial access and provide a permitting
framework for other activities. In addition, UALMO has a permit system to provide for
dedicated public and private access easements to reach inholdings or specific areas. While
large, the block of land is smaller than many contiguous blocks of ANCSA Native Corporation
land, which often have more restrictive public use requirements than those developed by the
UA BOR.

While BLM recognizes some RS2477 trails as prior valid rights, Statehood Act land grant
Federal regulations do not provide a mechanism for BLM to reserve those interests from UA's
land title. Consequently, Realty worked with UALMO to exclude areas with valid RS2477 trails from their selections. Realty also worked with UALMO to exclude areas with known
publicly used or developed trails from their selections. While public comments referenced
trails in and near the Selawik Hills parcel, no commentor provided specific trail location or
seasonal use information. Reviewing aerial and satellite imagery failed to find evidence of
trails on the lands.

The State selected large parcels in and around the Selawik Hills area under the Statehood Act.
However, the post-Alaska Native Claims Settlement Act (ANCSA) and post-Alaska National
Interests Land Conservation Act (ANILCA) land pattern has changed how DNR views land
acquisitions in the area. ANCSA Village and Regional Corporations acquired lands along the
easiest north/south access corridors. The Selawik National Wildlife Refuge blocked the
planned east/west access corridor to the Ambler Mining District. The remaining DNR
selections in the area are isolated, with no connectivity to other State-owned lands. This has
led to DNR selections in the area being classified as lower priority for acquisition. Because the
State is over-selected under the Statehood Act, it's highly likely that DNR will not acquire title
to lower priority lands.

The State may benefit from potential mineral exploration of the Selawik Hills selection if
conditional relinquishment was declined, but the resource potential has not been fully explored
nor have mineral resources been completely defined. The presence of potentially valuable
resources is not inherently a sufficient reason for the State to maintain a selection. Nor would
the potential value of those resources necessarily be harmed by UA ownership. While the State
might lose potential income from development, that same revenue going to the UA would help
fund the public interest in higher education in Alaska. Both options would provide benefits to
the wider state economy. It is not clear that it is in the State's best interest to maintain a
selection on these lands solely based on mineral potential, and there are no "at-risk" State
mining claims filed on the selected lands.

Overall, the land appears suitable for relinquishment in favor of the UA and agency comments
did not provide evidence of an overarching need for DNR ownership. Public comments were
opposed to the land transfer to the UA. The State's interests in retaining these lands must be
balanced with providing potentially valuable lands to the UA while protecting the State's
interests in potentially valuable land, State owned or selected adjacent lands, access to public
lands, and the overall management of an area. UA ownership provides options for access that,
while less than what is available on DNR owned lands, does not constitute an overriding State
interest to retain a selection on these lands. When considered fully, the State's interest in
retaining a selection on these lands is not compelling and supports relinquishment. In addition,
relinquishment of the lands fulfills the purpose of the CAA 2023 in providing lands to the UA.

Realty considered the following alternatives in adjudicating the request for relinquishment:

Alternative 1: Conditionally relinquish the State's selection on lands described in Section VI.

Alternative 2: Decline to conditionally relinquish the State's selection on lands described in
Section VI.

XI. DECISION
This decision considers all public and agency comments received. After considering the facts
and input described above, the Department finds it is in the best interest of the State to choose Alternative 1 and proceed with conditional relinquishment the lands described in Section VI.

Recommended by:

Carrie Hallinan
Natural Resource Specialist 2
Realty Services Section
Division of Mining, Land and Water
Department of Natural Resources

Approved by:

Lacy Hamner
Natural Resource Manager 2
Realty Services Section
Division of Mining, Land and Water
Department of Natural Resources

Approved by:

Commissioner-designee Crowther
Department of Natural Resources

Reconsideration Provision

Reconsideration
An eligible person affected by this decision, and who provided timely written comment or
public hearing testimony to the department, may request reconsideration to the DNR
Commissioner per AS 44.37.011 and 11 AAC 02. Any request for reconsideration must be
received by the Commissioner's Office within twenty (20) calendar days after issuance of the
decision under 11 AAC 02.040. The Commissioner may order or deny a request for
reconsideration within thirty (30) calendar days after issuance of the decision. If the
Commissioner takes no action on a request for reconsideration within thirty (30) days after
issuance of the decision, the request for reconsideration is considered denied. The
Commissioner's decision on reconsideration, other than a remand decision, is a final
administrative order and decision of the department. An eligible person must first request
reconsideration to the Commissioner before seeking relief in superior court. The Alaska Court
System establishes its own rules for timely appealing final administrative orders and decisions
of the department.

Reconsideration may be mailed or hand-delivered to the DNR Commissioner's Office,
550 W. 7th Avenue, Suite 1400, Anchorage, Alaska, 99501; or faxed to (907)-269-8918 or
sent by electronic mail to [email protected]. Reconsideration must be accompanied by the fee established in 11 AAC 05.lG0(d)(l)(F), which has been set at $200 under the provisions
of 11 AAC 05.lG0(a)-(b). A copy of 11 AAC 02 is available on the department's website at
https://dnr.alaska.gov/mlw/pdf/DNR-11- AAC-02.pdf.

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