From: Jeff Keener
Sent: Friday, September 26, 2014 8:49 AM
To: BBAYComments (GOV sponsored)
Subject: Comments: BM 4

The State of Alaska must defend the rights of mining claim owners on state lands, as they should for any other right. These are lands that are specifically designated as mineralized in character and open for entry to mineral location and extraction. These are valid mining claims on which the presumption that mining will occur should be rational and logical. The SOA requires annual rents and minimum expenditure to maintain these rights. If, after 30 years of requiring these expenditures, the SOA turns around and extinguishes these rights, the locators will have a strong basis for a takings suit against the state - fraud and misrepresentation. The SOA will be on the hook for compensation due the locators in the amount of billions of dollars. Further, the SOA is obligated to defend its rights holders against the proposed denial of due process by federal organs such as the EPA and USACE. To allow the federal government to break their promise to Alaska would be unforgivable and would open the floodgates to numerous costly and harassing actions by EPA and their revolving-door cronies in NGOs and lobbying firms. The notion that this action would be limited to only those development projects in the Bristol Bay region is remarkably naive and worse, intentionally misleading. If the EPA and those opposed to Pebble are truly committed to denial of due process, they should do the only honorable thing and buy out the Pebble Partnership's mineral rights and then sit on them while performing desultory minimum assessment work and rents. Unfortunately, I expect them to act dishonorably and unlawfully.

Jeff Keener