• Department of Fish and Game
• Department of Transportation and Public Facilities
• Division of Oil and Gas
• Division of Geological and Geophysical Surveys
• Division of Mining Land and Water, Mineral Property Management
• 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 were received verbatim in the first agency review:

• Jorgenson, Torre, Yoshikawa, Kenji, Kanevskiy, Mikhail, Shur, Yuri, Romanovsky, Vladimir, Marchenko, Sergei, Grosse, Guido, Brown, Jerry, and Jones, Ben, 2008, Permafrost characteristics of Alaska, in Kane, D.L., and Hinkel, K.M., eds., Proceedings of the Ninth International Conference on Permafrost: Fairbanks, Alaska, Institute of Northern Engineering, University of Alaska Fairbanks, p. 121-122.
• Mulliken, K.M., Schaefer, J.R., and Cameron, C.E., 2018, Geospatial distribution of tephra fall in Alaska: a geodatabase compilation of published tephra fall occurrences from the Pleistocene to the present: Alaska Division of Geological & Geophysical Surveys

DMLW Realty Response: Thank you for your comment. The Certificate of Allotment for FF-01823lA, AK.106534449, dated March 5, 2002, shows the allotment in question does not extend into Section 12. However, this may change after the township is surveyed. If the allotment extends into Section 12, BLM will remove the allotment lands from the UA conveyance area prior to issuing the final patent through the conformation to survey process.

DNR, DMLW, Public Access, Assertion, and Defense Section (PAAD): PAAD does not oppose the relinquishment of these lands for the UA project. There are no navigable waters (AS 38.04.062) and there are no known RS 2477 trails within the areas.

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 GS-4513 & GS-5712- Kauk River Lands Selection. The Resource Assessment & Development Section (RADS) has reviewed the available data, satellite imagery, and the Northwest Area Plan (2008) and provides the following comments.

Background & Discussion:

The University of Alaska is selecting these lands:

T. 10 N., R. 8 W., K.R.M. Secs. 01-05, inclusive, All; Secs. 07-16 inclusive excluding lakes. Containing approximately 9,557 acres

T. 11 N., R. 8 W., K.R.M. Sec. 08, All; Secs. 11-30, inclusive, All; Secs. 33-36, inclusive, All; Containing approximately 15,904 acres. Aggregating approximately 25,461 acres.

The parcel falls within the Northwest Area Plan boundary, specifically within unit K-9 which is co-classified Minerals Land and Habitat Land. The management intent for K-9 says to manage for mineral values and the unit is described as having high mineral potential with numerous ARDF occurrences.

Recommendation:

Taking all the above into account, RADS sees no reason not to move forward with this relinquishment. Parts of unit K-9 are highly mineralized. This part of the Unit that is being considered for relinquishment, while it does include some USGS Alaska Resource Data points, I would not consider "highly mineralized".

Thank you for the opportunity to review.

DMLW Realty Response: Thank you for your comment.

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

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 US 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. Four 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.

• 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.
• 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.
• ADF&G would retain management of fish and wildlife resources on the lands, including State subsistence regulations, should ownership be transferred to the UA.
• 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/.
• 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.
• While this land was selected by the State of Alaska under the Alaska Statehood Act for its natural resources, mineral resources, and fish and game interests, the selected lands are ranked three or 'medium' in the statehood selection prioritization in the Realty Section's 2025 evaluation of selected land. This means, while the land is selected, other lands selected by the State may be an equal or higher priority to acquire as 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.
• The December 2022 CAA for fiscal Year 2023 created a mechanism for BLM to convey 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. While this land was selected by the State of Alaska under the Alaska Statehood Act for its natural resources, mineral resources, and fish and game interests, the selected lands are ranked three or 'medium' in conveyance priority for statehood land entitlement selections. This means, while the land is selected, other lands selected by the State may be an equal or higher priority to acquire as part of the Statehood Land Entitlement. The Statehood Act land selection process is further discussed in Section X below.
• 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.

• 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.
• 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.
• ADF&G would retain management of fish and wildlife resources on the lands should ownership be transferred to the UA.
• 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/.
• 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.
• 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/.
• While this land was selected by the State of Alaska under the Alaska Statehood Act for its natural resources, mineral resources, and fish and game interests, the selected lands are ranked three or 'medium' in the statehood selection prioritization in the Realty Section's 2025 evaluation of selected land. This means, while the land is selected, other lands selected by the State may be an equal or higher priority to acquire as 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.
• The December 2022 CAA for fiscal Year 2023 created a mechanism for BLM to convey 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. While this land was selected by the State of Alaska under the Alaska Statehood Act for its natural resources, mineral resources, and fish and game interests, the selected lands are ranked three or 'medium' in conveyance priority for statehood land entitlement selections. This means, while the land is selected, other lands selected by the State may be an equal or higher priority to acquire as part of the Statehood Land Entitlement. The Statehood Act land selection process is further discussed in Section X below.
• 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 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-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. 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.

• 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.
• 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.
• ADF&G would retain management of fish and wildlife resources on the lands, including State subsistence regulations, should ownership be transferred to the UA.
• 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/.
• 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.
• While this land was selected by the State of Alaska under the Alaska Statehood Act for its natural resources, mineral resources, and fish and game interests, the selected lands are ranked three or 'medium' in the statehood selection prioritization in the Realty Section's 2025 evaluation of selected land. This means, while the land is selected, other lands selected by the State may be an equal or higher priority to acquire as 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.
• The December 2022 CAA for fiscal Year 2023 created a mechanism for BLM to convey 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. While this land was selected by the State of Alaska under the Alaska Statehood Act for its natural resources, mineral resources, and fish and game interests, the selected lands are ranked three or 'medium' in conveyance priority for statehood land entitlement selections. This means, while the land is selected, other lands selected by the State may be an equal or higher priority to acquire as part of the Statehood Land Entitlement. The Statehood Act land selection process is further discussed in Section X below.
• 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 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.

• 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.
• 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.
• ADF&G would retain management of fish and wildlife resources on the lands, including State subsistence regulations, should ownership be transferred to the UA.
• 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/.
• 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.
• While this land was selected by the State of Alaska under the Alaska Statehood Act for its natural resources, mineral resources, and fish and game interests, the selected lands are ranked three or 'medium' in the statehood selection prioritization in the Realty Section's 2025 evaluation of selected land. This means, while the land is selected, other lands selected by the State may be an equal or higher priority to acquire as 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.
• The December 2022 CAA for fiscal Year 2023 created a mechanism for BLM to convey 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. While this land was selected by the State of Alaska under the Alaska Statehood Act for its natural resources, mineral resources, and fish and game interests, the selected lands are ranked three or 'medium' in conveyance priority for statehood land entitlement selections. This means, while the land is selected, other lands selected by the State may be an equal or higher priority to acquire as part of the Statehood Land Entitlement. The Statehood Act land selection process is further discussed in Section X below.
• 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.

Realty also received 9 comments that either did not specify any certain UA selection or included the proposed relinquishment as well as other UA selections. While these comments are all very similar in content, they are included in full below.

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.

• 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.
• 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.
• ADF&G would retain management of fish and wildlife resources on the lands, including State subsistence regulations, should ownership be transferred to the UA.
• 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/.
• 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.
• While this land was selected by the State of Alaska under the Alaska Statehood Act for its natural resources, mineral resources, and fish and game interests, the selected lands are ranked three or 'medium' in the statehood selection prioritization in the Realty Section's 2025 evaluation of selected land. This means, while the land is selected, other lands selected by the State may be an equal or higher priority to acquire as 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.
• The December 2022 CAA for fiscal Year 2023 created a mechanism for BLM to convey 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. While this land was selected by the State of Alaska under the Alaska Statehood Act for its natural resources, mineral resources, and fish and game interests, the selected lands are ranked three or 'medium' in conveyance priority for statehood land entitlement selections. This means, while the land is selected, other lands selected by the State may be an equal or higher priority to acquire as part of the Statehood Land Entitlement. The Statehood Act land selection process is further discussed in Section X below.
• 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.

• 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.
• 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.
• ADF&G would retain management of fish and wildlife resources on the lands, including State subsistence regulations, should ownership be transferred to the UA.
• 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/.
• 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.
• While this land was selected by the State of Alaska under the Alaska Statehood Act for its natural resources, mineral resources, and fish and game interests, the selected lands are ranked three or 'medium' in the statehood selection prioritization in the Realty Section's 2025 evaluation of selected land. This means, while the land is selected, other lands selected by the State may be an equal or higher priority to acquire as 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.
• The December 2022 CAA for fiscal Year 2023 created a mechanism for BLM to convey 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. While this land was selected by the State of Alaska under the Alaska Statehood Act for its natural resources, mineral resources, and fish and game interests, the selected lands are ranked three or 'medium' in conveyance priority for statehood land entitlement selections. This means, while the land is selected, other lands selected by the State may be an equal or higher priority to acquire as part of the Statehood Land Entitlement. The Statehood Act land selection process is further discussed in Section X below.
• 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.

• 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.
• 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.
• ADF&G would retain management of fish and wildlife resources on the lands, including State subsistence regulations, should ownership be transferred to the UA.
• 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/.
• 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.
• While this land was selected by the State of Alaska under the Alaska Statehood Act for its natural resources, mineral resources, and fish and game interests, the selected lands are ranked three or 'medium' in the statehood selection prioritization in the Realty Section's 2025 evaluation of selected land. This means, while the land is selected, other lands selected by the State maybe an equal or higher priority to acquire as 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.
• The December 2022 CAA for fiscal Year 2023 created a mechanism for BLM to convey 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. While this land was selected by the State of Alaska under the Alaska Statehood Act for its natural resources, mineral resources, and fish and game interests, the selected lands are ranked three or 'medium' in conveyance priority for statehood land entitlement selections. This means, while the land is selected, other lands selected by the State may be an equal or higher priority to acquire as part of the Statehood Land Entitlement. The Statehood Act land selection process is further discussed in Section X below.
• 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.

• 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.
• 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.
• ADF&G would retain management of fish and wildlife resources on the lands, including State subsistence regulations, should ownership be transferred to the UA.
• 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/.
• 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.
• While this land was selected by the State of Alaska under the Alaska Statehood Act for its natural resources, mineral resources, and fish and game interests, the selected lands are ranked three or 'medium' in the statehood selection prioritization in the Realty Section's 2025 evaluation of selected land. This means, while the land is selected, other lands selected by the State may be an equal or higher priority to acquire as 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.
• The December 2022 CAA for fiscal Year 2023 created a mechanism for BLM to convey 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. While this land was selected by the State of Alaska under the Alaska Statehood Act for its natural resources, mineral resources, and fish and game interests, the selected lands are ranked three or 'medium' in conveyance priority for statehood land entitlement selections. This means, while the land is selected, other lands selected by the State may be an equal or higher priority to acquire as part of the Statehood Land Entitlement. The Statehood Act land selection process is further discussed in Section X below.
• 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.

• 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.
• 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.
• ADF&G would retain management of fish and wildlife resources on the lands, including State subsistence regulations, should ownership be transferred to the UA.
• Public access and use ofUA 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/.
• 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.
• While this land was selected by the State of Alaska under the Alaska Statehood Act for its natural resources, mineral resources, and fish and game interests, the selected lands are ranked three or 'medium' in the statehood selection prioritization in the Realty Section's 2025 evaluation of selected land. This means, while the land is selected, other lands selected by the State may be an equal or higher priority to acquire as 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.
• The December 2022 CAA for fiscal Year 2023 created a mechanism for BLM to convey 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. While this land was selected by the State of Alaska under the Alaska Statehood Act for its natural resources, mineral resources, and fish and game interests, the selected lands are ranked three or 'medium' in conveyance priority for statehood land entitlement selections. This means, while the land is selected, other lands selected by the State may be an equal or higher priority to acquire as part of the Statehood Land Entitlement. The Statehood Act land selection process is further discussed in Section X below.
• 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.

• 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.
• 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.
• ADF&G would retain management of fish and wildlife resources on the lands, including State subsistence regulations, should ownership be transferred to the UA.
• 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/.
• 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.
• While this land was selected by the State of Alaska under the Alaska Statehood Act for its natural resources, mineral resources, and fish and game interests, the selected lands are ranked three or 'medium' in the statehood selection prioritization in the Realty Section's 2025 evaluation of selected land. This means, while the land is selected, other lands selected by the State may be an equal or higher priority to acquire as 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.
• The December 2022 CAA for fiscal Year 2023 created a mechanism for BLM to convey 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. While this land was selected by the State of Alaska under the Alaska Statehood Act for its natural resources, mineral resources, and fish and game interests, the selected lands are ranked three or 'medium' in conveyance priority for statehood land entitlement selections. This means, while the land is selected, other lands selected by the State may be an equal or higher priority to acquire as part of the Statehood Land Entitlement. The Statehood Act land selection process is further discussed in Section X below.
• 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 ofland 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.

• 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.
• 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.
• ADF&G would retain management of fish and wildlife resources on the lands should ownership be transferred to the UA.
• 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/.
• No RS-2477 rights-of-way or DOT 1973 inventory trails were found to exist in these two parcels.
• While this land was selected by the State of Alaska under the Alaska Statehood Act for its natural resources, mineral resources, and fish and game interests, the selected lands are ranked three or 'medium' in the statehood selection prioritization in the Realty Section's 2025 evaluation of selected land. This means, while the land is selected, other lands selected by the State may be an equal or higher priority to acquire as 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.
• The December 2022 CAA for fiscal Year 2023 created a mechanism for BLM to convey 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. While this land was selected by the State of Alaska under the Alaska Statehood Act for its natural resources, mineral resources, and fish and game interests, the selected lands are ranked three or 'medium' in conveyance priority for statehood land entitlement selections. This means, while the land is selected, other lands selected by the State may be an equal or higher priority to acquire as part of the Statehood Land Entitlement. The Statehood Act land selection process is further discussed in Section X below.
• 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 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.

• 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.
• 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.
• ADF&G would retain management of fish and wildlife resources on the lands should ownership be transferred to the UA.
• 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/.
• No RS-2477 rights-of-way or DOT 1973 inventory trails were found to exist in these two parcels.
• While this land was selected by the State of Alaska under the Alaska Statehood Act for its natural resources, mineral resources, and fish and game interests, the selected lands are ranked three or 'medium' in the statehood selection prioritization in the Realty Section's 2025 evaluation of selected land. This means, while the land is selected, other lands selected by the State may be an equal or higher priority to acquire as 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.
• The December 2022 CAA for fiscal Year 2023 created a mechanism for BLM to convey 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 VIl directives for the University. While this land was selected by the State of Alaska under the Alaska Statehood Act for its natural resources, mineral resources, and fish and game interests, the selected lands are ranked three or 'medium' in conveyance priority for statehood land entitlement selections. This means, while the land is selected, other lands selected by the State may be an equal or higher priority to acquire as part of the Statehood Land Entitlement. The Statehood Act land selection process is further discussed in Section X below.
• 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 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.

• 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.
• 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.
• ADF&G would retain management of fish and wildlife resources on the lands should ownership be transferred to the UA.
• 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/.
• No RS-2477 rights-of-way or DOT 1973 inventory trails were found to exist in these two parcels.
• While this land was selected by the State of Alaska under the Alaska Statehood Act for its natural resources, mineral resources, and fish and game interests, the selected lands are ranked three or 'medium' in the statehood selection prioritization in the Realty Section's 2025 evaluation of selected land. This means, while the land is selected, other lands selected by the State may be an equal or higher priority to acquire as 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.
• The December 2022 CAA for fiscal Year 2023 created a mechanism for BLM to convey 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. While this land was selected by the State of Alaska under the Alaska Statehood Act for its natural resources, mineral resources, and fish and game interests, the selected lands are ranked three or 'medium' in conveyance priority for statehood land entitlement selections. This means, while the land is selected, other lands selected by the State may be an equal or higher priority to acquire as part of the Statehood Land Entitlement. The Statehood Act land selection process is further discussed in Section X below.
• 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 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 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.

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 valuable land to the UA without undue harm to the interests of Alaskans.

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 initial 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 Kauk River 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 medium 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 the Kauk River UA 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. Both Realty and PAAD reviewed the Kauk River selection and determined there are no navigable water bodies within the area. This further supports public use and enjoyment of the area regardless ofland 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 Kauk River lands, irrespective of ownership. This balance is achieved through the development ofland 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.

RADS noted that the Kauk River 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 Kauk River 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.

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 Kauk River 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 Kauk River parcel remain public lands unless public access protections can be guaranteed prior to the conveyance. As discussed above, this decision supports those interests to the greatest degree possible due to the adjustment of the parcel to continue to provide public access for these kinds of uses, 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 Kauk River 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 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 RS 2477 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 RS 2477 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 Kauk River 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.