Legislature(2017 - 2018)BARNES 124
04/06/2018 01:00 PM House RESOURCES
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| Audio | Topic |
|---|---|
| Start | |
| HB331 | |
| Presentation: Alaska Industrial Development and Export Authority | |
| Adjourn |
* first hearing in first committee of referral
+ teleconferenced
= bill was previously heard/scheduled
+ teleconferenced
= bill was previously heard/scheduled
| += | HB 331 | TELECONFERENCED | |
| + | TELECONFERENCED | ||
| + | TELECONFERENCED |
HB 331-TAX CREDIT CERT. BOND CORP; ROYALTIES
1:03:28 PM
CO-CHAIR JOSEPHSON announced that the first order of business
would be HOUSE BILL NO. 331, "An Act establishing the Alaska Tax
Credit Certificate Bond Corporation; relating to purchases of
tax credit certificates; relating to overriding royalty interest
agreements; and providing for an effective date."
1:04:25 PM
KEN ALPER, Director, Tax Division, Department of Revenue (DOR),
continued his presentation from the previous House Resources
Standing Committee hearing of HB 331 on 3/30/18, and explained
the language of HB 331 incorporates the following:
• a structure creating the bond corporation and
authorization to sell bonds
• a structure containing conforming changes to existing
language to ensure the existing process to purchase tax
credits is not overwritten, but is supplemented through the
bonding method
• a structure containing a series of new sections describing
the mechanisms by which DOR values the tax credits and
other factors
• a Department of Natural Resources (DNR) statute related to
how DNR would negotiate and authorize overriding royalty
interests offered by companies
MR. ALPER directed attention to a sectional analysis of HB 331,
provided in the committee packet, which read [original
punctuation provided]:
Section 1:
Exempts the bond corporation created in Sec. 2, and
any overriding royalty interests negotiated under Sec.
11, from the procurement code.
Section 2:
Establishes the Alaska Tax Credit Certificate Bond
Corporation within DOR. [Largely patterned after
Alaska Pension Obligation Bond Corporation, AS 37.16]
37.18.010 Creates the corporation.
37.18.020 Establishes the board of directors, all
of whom are state department commissioners.
37.18.030 Authorizes the corporation to issue
bonds up to $1 billion and contract for associated
services.
37.18.040 Authorizes the corporation to have a
reserve fund which will hold funds to be used for
repurchase, as well as funds appropriated for the
purpose of interest and principal payments to bond
holders.
37.18.050 Authorizes the corporation to set the
terms of bonds to be issued.
37.18.060 Corporation must adopt a resolution to
approve the issuance of bonds.
37.18.070 Gives certain enforcement rights to
certain bond holders.
37.18.080 Bonds may not be issued unless the
discount rate by which tax credits are purchased is at
least 1.5% greater than the total interest cost of the
bonds.
37.18.090 Corporation may refund bonds prior to
the maturity date.
37.18.100 Bonds are legal instruments.
37.18.800 This chapter shall be liberally
construed to carry out its purposes.
37.18.810 Corporation may adopt regulations
necessary to implement this chapter.
37.18.900 Definitions.
Section 3: Amends the Gas Storage Credit to enable
repurchase of any credits via the bond program.
Section 4: Amends the LNG Storage Credit to enable
repurchase of any credits via the bond program.
Section 5: Amends the Refinery Infrastructure Credit
to enable repurchase of any credits via the bond
program.
Section 6: Amends various provisions of AS 43.55.028,
the tax credit repurchase fund. .028(e) The department
may either use the tax credit fund money, or money
disbursed from the bond program, to purchase tax
credits. Written to maximize flexibility and retain
the existing program and procedures.
Section 7: .028(g) Clarifies that the current $70
million per company per year cap, with the associated
"haircut", does not apply to repurchases via the bond
program.
Section 8: .028(i) Adds definitions for "money
disbursed to the commissioner," and "total interest
cost."
Section 9: .028(j) Clarifies that if a company has an
outstanding liability to the state, this can be offset
against a payment via the bond program as well as via
traditional repurchase.
Section 10:
.028(k) New section authorizing the department to
negotiate a repurchase of all credits held by a
company, and describing how the holder of credits
indicates their desire to participate in the program.
This section contemplates that if a holder of credits
existing at the time of a bond issuance declines to
participate in the program, such holder is precluded
from submitting such existing credits for purchase in
connection with future bond issuances. This provision
does not preclude such holder from submitting credits
claimed after a bond issuance for purchase in
connection with a future bond issuance.
.028(l) New section describes the mechanism by which
the department estimates the expected cash flow to a
company via the current repurchase process and
expected schedule. From this estimate, a purchase
offer can be calculated based on the discount rate
determined in (m).
.028(m) New section establishing a base discount rate
of 10%, with four methods to reduce this to a number
equal to total interest cost + 1.5%.
1. For a seismic credit, the company has waived
the 10-year confidentiality period for the data and
allowed it to become public;
2. The company has agreed to an overriding
royalty interest (ORRI) accepted by the Department of
Natural Resources;
3. The company has committed reinvest the entire
amount received within an Alaska oil and gas project
within 24 months;
or 4. The credit is against the corporate income
tax, primarily impacting refinery infrastructure
credits.
.028(n) New section clarifying that the amount of a
credit in excess of the discounted amount purchased
retains no value and cannot be used against taxes or
sold.
Section 11: Authorizes the Department of Natural
Resources to negotiate Overriding Royalty Interests
(ORRI). These are then valued, and a determination is
made whether the incremental value received by the
state warrants the approval of the lower discount rate
for purposes of credit repurchase.
Section 12: Authorizes DNR and DOR to adopt
regulations to implement this act
Section 13: Authorizes retroactive application of
regulations.
Section 14: Immediate effective date.
1:06:02 PM
MR. ALPER further explained Section 1 contains conforming
language exempting the bond corporation and royalty interest
from the Alaska Procurement Code. Section 2 is similar to other
Alaska state statutes creating special purpose bonding
mechanisms such as the pension obligation bond authority, and
other authorities that are delegated to the commissioner of DOR.
Also included in Section 2 is the provision that the structure
of the bond is left to the discretion of the commissioner of
DOR.
REPRESENTATIVE PARISH expressed his understanding that the
Alaska Pension Obligation Bond Corporation has never issued
bonds.
MR. ALPER said correct.
REPRESENTATIVE PARISH asked whether any other state corporations
- that would acquire debt in a similar manner to the proposed
bond corporation - have been created "without revenue streams
internal to them."
1:08:38 PM
MIKE BARNHILL, Deputy Commissioner, Office of the Commissioner,
DOR, before responding to Representative Parish, made the point
of correction: the commissioner of DOR does not set the
structure of the bond debt service under the statute but the
board of directors of the Alaska Tax Credit Bond Corporation
would perform that function. The board of directors would
include the commissioners of DOR, the Department of Commerce,
Community & Economic Development (DCCED), and the Department of
Administration (DOA).
REPRESENTATIVE PARISH restated his question.
MR. BARNHILL advised there are many state entities that issue
bonds and deferred to Devin Mitchell.
1:10:19 PM
DEVEN MITCHELL, Executive Director, Alaska Municipal Bond Bank
Authority, DOR, explained a similar entity would be the Alaska
Housing Finance Corporation (AHFC) which entered into an
agreement with the state to purchase what is now known as the
[Robert B. Atwood Building]; there were no revenues in the
agreement except for the state's pledge to pay on a "subject to
appropriation" basis, as allowed by standalone law, and which is
exactly as proposed in HB 331. Further, the proposal is a
familiar structure to the state as well as to municipal market
participants.
REPRESENTATIVE PARISH commented the aforementioned example was a
lease purchase agreement; however, HB 331 proposes a debt of up
to $1 billion for the state with no lease directly involved. He
asked how HB 331 resembles a lease purchase agreement.
MR. MITCHELL answered a lease purchase agreement is based on a
lease which is subject to appropriation; HB 331 [bond] debt
would be based on a contract, also subject to appropriation. He
remarked:
In the case of the lease, [should the state choose not
to appropriate], the negative ramification would be
you would not only get downgraded, you would lose
access to the building for a period of time. Not the
entire life of the building, but just a period of time
as established in the lease. And, that could be
negotiated down to as short as a year, and then the
state would again have right to occupy the facility
even though there'd been a failure. So, again, it's a
familiar structure to the state and it's a familiar
structure to the capital markets.
REPRESENTATIVE PARISH referred to the Constitution of the State
of Alaska, Article IX, Section 8. State Debt., which read [in
part, original punctuation provided]:
No state debt shall be contracted unless authorized by
law for capital improvements or unless authorized by
law for housing loans for veterans, and ratified by a
majority of the qualified voters of the State who vote
on the question.
REPRESENTATIVE PARISH continued to Section 11. Exceptions.,
which read [in part]:
The restrictions on contracting debt do not apply to
debt incurred through the issuance of revenue bonds
....
REPRESENTATIVE PARISH asked whether the proposed bonds are
revenue bonds.
1:12:57 PM
MR. MITCHELL said they are not. He clarified the bonds would
be revenue bonds of the corporation; the corporation would issue
either revenue bonds or general obligation bonds of the
corporation, however, the final structure has not been
determined. Mr. Mitchell continued:
I work with another public corporation, the Alaska
Municipal Bond Bank [Authority (AMBBA)], [and] we, we
borrow money based on underlying communities' need of
borrowing money. So, when we borrow money in the
capital markets, we issue general obligation bonds of
the Alaska Municipal Bond Bank, which [are] secured by
that cross-collateralized underlying borrowing pool as
well as the State of Alaska's moral obligation pledge.
And, in the instance of the ... bond bank, we sell
general obligation bonds for both revenue bonds of
underlying communities as well as general obligation
bonds of underlying communities. And so, the
corporation, ... the separately legally existing
corporation we're talking about, would be able to
potentially sell general obligation bonds, but the
only thing that would be securing those would be the
revenues that it would derive from this contract it
would enter into with the state. And so, it could
also be structured ... potentially as a revenue bond.
REPRESENTATIVE PARISH questioned whether the proposed bond
corporation's issuance of a general obligation bond would be
subject to a majority vote of the qualified voters.
MR. MITCHELL restated such a bond would be a general obligation
bond of the corporation and not of the state. Public
corporations, such as the Alaska Student Loan Corporation
[Postsecondary Education Commission], Department of Education
and Early Development, the Alaska Industrial Development and
Export Authority (AIDEA), Department of Commerce, Community &
Economic Development, AMBBA, and AHFC, can issue general
obligation bonds of the corporation. He characterized general
obligation bonds as "a more limited pledge, obviously, than the
State of Alaska's general obligation pledge, but could be a full
faith and credit pledge of that legal existence, of that
entity."
1:15:11 PM
WILLIAM MILKS, Senior Assistant Attorney General, Labor and
State Affairs Section, Civil Division(Juneau), Department of Law
(DOL), directed attention to a letter addressed to Senator
Giessel, dated 3/2/18, from Mr. Mitchell, representing DOR, and
himself, representing DOL, that was included in the committee
packet. Mr. Milks informed the committee the letter addresses
the constitutionality issue, opining the proposed bonds are
constitutional because they are "subject to appropriation"
bonds. He returned attention to Article IX, Section 8, [text
previously provided, in part], commonly known as the debt
provision, and further advised Section 8 applies specifically to
a general obligation bond, backed by the full faith and credit
of the State of Alaska, and thereby not a subject to appropriate
bond. General obligation bonds must be paid regardless of the
state's financial circumstances, are issued for capital
improvements, and are usually subject to voter approval. As
noted in the letter, a key case was reviewed by the Alaska
Supreme Court, Carr-Gottstein Properties v. State, 899 P.2d 136,
142-44 (Alaska 1995), and the court decided the issue is whether
a bond is subject to appropriation, and the special meaning of
debt under the constitution. Mr. Milks concluded if a bond does
not hold the full faith and credit of the State of Alaska for
repayment, it is subject to appropriation, which is a procedure
the courts have permitted in Alaska and elsewhere.
REPRESENTATIVE PARISH recalled previous testimony that if [the
legislature] failed to appropriate [funds for repayment], the
state's bond rating could be downgraded two or three times, and
surmised the state's faith and credit is "on the line," although
creating a shell corporation would "dodge" the narrowest reading
of the law. He asked, "How is this really substantively and
significantly not state debt if our credit rating could take an
enormous hit for failure to pay?"
1:17:52 PM
MR. MILKS pointed out the bill on page 2, [lines 19-22],
specifically states the bonds do not constitute general
obligations to the State of Alaska. He reiterated the Alaska
Supreme Court has interpreted this provision to be a moral
authority bonding, which is subject to appropriation. He
deferred to Mr. Mitchell for a further response.
MR. MITCHELL acknowledged the state could choose not to pay,
have its credit rating downgraded, and lose access to the
capital markets with the subject to appropriation commitment;
with a general obligation commitment, the state would be forced
and compelled to pay. In fact, the Alaska Statute provides a
standing appropriation that does not require annual legislative
action to pay general obligation bond debt service; however,
there is no similar provision for any subject to appropriation
obligation.
CO-CHAIR JOSEPHSON, in response to Representative Parish,
advised testimony by the department representatives would be
ending; however, the representatives may be available to answer
additional questions [following the hearing].
1:19:54 PM
REPRESENTATIVE PARISH stressed HB 331 provides for a debt of
possibly $1 billion; therefore, he would like all his questions
exhausted on the record at this hearing. The fundamental
question is whether the state can create a corporation to take
on debt which is neither revenue debt, revenue bonds, nor
general obligation bonds, but is "a sort of nebulous additional
... category," and if so, whether there is any limit to the
amount of debt. He questioned whether a state corporation could
accrue $5 billion in loans so [the legislature] could follow the
statutory dividend formula to pay the Permanent Fund Dividend,
and observed the Alaska Supreme Court decision [Bill
Wielechowski, Rick Halford, and Clem Tillion v. State of Alaska
and Alaska Permanent Fund Corporation] found that the power of
appropriation rests with the legislature and thus, the statute
cited earlier becomes murky.
1:21:32 PM
MR. MITCHELL disagreed that the aforementioned legal opinion
relates to general obligation bonds and the state's commitments,
which are embedded in the state constitution. He deferred to
Mr. Milks for further discussion in this regard. He said
Representative Parish's questions have been asked "many times
before"; however, [the proposal within HB 331] is legal under
Alaska law and is accepted as a common form of financing
utilized by Alaska and other states.
REPRESENTATIVE JOSEPHSON, in response to Representative Birch's
suggestion to end testimony on HB 331, advised further review of
constitutional questions may be necessary prior to hearing
amendments to the bill, which is scheduled for 4/9/18.
REPRESENTATIVE PARISH remarked:
On this specific question, the difference has been,
been clearly established as to whether or not a, the
state should be allowed to contract state debt without
a general vote of the people, without a revenue bond,
and without any of the other specific exceptions
listed in the constitution. And on the counterpoint,
there's, there's the assertion that because lease
purchase agreements in the past have gone forward
because the Pension Obligation Bond Corporation was
established, and because, the bill says, " ... it is
constitutional," I guess, I guess that's, that's just
a disagreement which may have to get resolved in the
courts.
1:25:03 PM
CO-CHAIR TARR stated under current Alaska statute there is
already a formula - subject to appropriation - for paying the
[tax] credits; HB 331 is an alternative proposal to pay the tax
credits which would also be subject to appropriation. She
cautioned the reason for the current debate is because "no one
read the statute" before making business decisions to spend
money and obtain bank financing based on the state's repayment
of tax credit certificates. Co-Chair Tarr suggested if the
statute had been read, beneficiaries would have acted more
cautiously and would not be defaulting on loans while waiting
for the state to repay tax certificates. Although the funding
provision within HB 331 is subject to appropriation, there would
be every expectation that the money would be appropriated. She
concluded HB 331 does not resolve the current fundamental
problem, which is having sufficient funds to pay the credits
that are due.
MR. MITCHELL did not respond to the policy aspects of the
question. From a debt perspective, he said HB 331 differs from
the sort of subject to appropriation commitment that currently
exists in financing markets. He expressed his concern about
maintaining the state's credit rating, its access to capital
markets, and its ability to accomplish needed capital projects
through the use of financing tools. Within all capital markets,
an entity's ability to borrow is only as good as how its word is
perceived. In the event an entity fails to pay its bills, that
entity will experience higher interest rates or diminished
access. Also related to financing in capital markets, the
current diminished payments that have been made on the credits
currently due have a lesser impact on the state's credit rating
than if the state defaults - a non-payment - on a subject to
appropriation bond issue of a public corporation.
There followed a short discussion regarding the deadline for
amendments to HB 331.
1:29:36 PM
The committee took an at-ease from 1:29 p.m. to 1:32 p.m.
1:31:25 PM
CO-CHAIR JOSEPHSON posed a scenario in which credit holders, who
may or may not have transferred their credits, would be able to
decline to have provisions of the bill applied and would instead
proceed under the normal payment schedule. He asked whether,
under the aforementioned circumstances, the state would need to
pay [tax credit certificates] under two different payment
streams.
MR. ALPER returned to the sectional analysis of HB 331 and said
Sections 3, 4, and 5 are similar in structure and relate to the
existing tax credits that are in the corporate income tax
statute, AS 43.20. Existing corporate income tax provisions
include a gas storage credit for the Kenai Gas Storage Facility,
a liquefied natural gas (LNG) storage credit for the main
storage tanks in Fairbanks, a credit for the Interior Gas
Utility, and a refinery infrastructure credit. As currently
written, the aforementioned credits can be purchased with money
from the tax credit [repurchase] fund. However, the existing
language would be amended by HB 331, so the credits could also
be purchased with proceeds of the [tax credit] bonds.
MR. ALPER explained Sections 6-9 amend portions of AS 43.55.028,
the tax credit [repurchase] fund, as follows: Section 6 relates
to the use of tax credit fund money or money disbursed from the
bond program to purchase tax credits; Section 7 clarifies that
there is no $70 million [per company per year] cap on
repurchases via the bond program; Section 8 adds definitions,
notably, "money disbursed to the commissioner" means the
proceeds of the bond; Section 9 clarifies that a right to offset
a credit payment held by a company would be extended to a bond
purchase. Section 10 is a new section adding four new
subsections to AS 43.55.028. Subsection (k) requires companies
to offer their credits to the program, and all credits must be
offered. Further, companies that choose not to participate
cannot offer credits in a subsequent bond offering. Mr. Alper
characterized the provisions in subsection (k) as language that
is intended to prevent parties from "gaming the system."
1:37:07 PM
MR. ALPER said subsection (l) provides the mechanism to
determine a company's expected cash flow under the traditional
credit repurchase structure using new definitions affected by a
company's pro rata share of the annual appropriation per the
formula within [AS 43.55.028(c)]. The existing language would
be clarified by subsection (l), and he remarked:
We're going to presume we are appropriating for the
next five, six years at "x" dollars per year based on
the fact that you have this much credit in 2016,
they're going to get paid first pro rata for however
many years it takes, and then all the 2017 credits
will be paid pro rata for however many years it takes.
So, every company will be given a unique expected cash
flow under the traditional system, which is then
discounted at a discount rate. The discount rate is
covered in subsection (m), and what subsection (m)
says is that the base discount rate is 10 percent per
year, and then there are four different ways by which
a company could buy that down to the lower rate, which
is written in as, as the true interest cost plus 1.5
percent, which we currently forecast to be about 5.1
percent interest. But that would be determined closer
to the date of final issuing of the bonds. We've
talked about what those four methods are, they're
clearly written out in (m). Either you have the
overriding royalty interest; the commitment to
reinvest all of the proceeds. If you have seismic
credits, ... you have to waive your 10 years of
confidentiality on the seismic data. Or, if you have
one of those corporate income tax credits - primarily
the refinery credit - outstanding, you're
automatically bought in at the lower interest rate.
MR. ALPER continued to subsection (n) which clarifies if a
credit is sold at less than face value, the remaining value
cannot be cashed, sold, or used to offset taxes. Section 11
authorizes the Overriding Royalty Interests (ORRI) and provides
the mechanisms and rules for negotiations between DNR and credit
holders related to the value of fields offered for credit and
factors affecting said value. For example, calculations would
include cash flow, royalty interest, and present value. In
fact, the mandate is: the present value of the overriding
royalty interest must be at least equal or greater than the
incremental value the company would receive from the lower
discount rate versus the higher discount rate. Sections 12-14
are: authority to write regulations; the ability for those
regulations to take effect retroactively if they are not
finalized before the effective date; the effective date. Mr.
Alper concluded, noting HB 331 has an immediate effective date,
thus after its expected passage in May, [2018], the process of
underwriting and preparing bonds would be completed and bonds
would be issued in August or September [2018].
1:41:10 PM
[HB 331 was held over.]
| Document Name | Date/Time | Subjects |
|---|---|---|
| HB331 Transmittal Letter.pdf |
HRES 3/30/2018 1:00:00 PM HRES 4/4/2018 1:00:00 PM HRES 4/6/2018 1:00:00 PM HRES 4/7/2018 2:00:00 PM HRES 4/9/2018 1:00:00 PM HRES 4/10/2018 8:00:00 AM |
HB 331 |
| HB331 Version A.PDF |
HRES 3/30/2018 1:00:00 PM HRES 4/4/2018 1:00:00 PM HRES 4/6/2018 1:00:00 PM HRES 4/7/2018 2:00:00 PM HRES 4/9/2018 1:00:00 PM HRES 4/10/2018 8:00:00 AM |
HB 331 |
| HB331 Fiscal Note -DNR-DOG 1.29.18.pdf |
HRES 3/30/2018 1:00:00 PM HRES 4/4/2018 1:00:00 PM HRES 4/6/2018 1:00:00 PM HRES 4/7/2018 2:00:00 PM HRES 4/9/2018 1:00:00 PM HRES 4/10/2018 8:00:00 AM |
HB 331 |
| HB331 Fiscal Note-DOR-TAX 2.5.18.pdf |
HRES 3/30/2018 1:00:00 PM HRES 4/4/2018 1:00:00 PM HRES 4/6/2018 1:00:00 PM HRES 4/7/2018 2:00:00 PM HRES 4/9/2018 1:00:00 PM HRES 4/10/2018 8:00:00 AM |
HB 331 |
| HB331 Supporting Document - Presentation Credit Bonds for HRES 3.30.18.pdf |
HRES 3/30/2018 1:00:00 PM HRES 4/6/2018 1:00:00 PM HRES 4/7/2018 2:00:00 PM HRES 4/9/2018 1:00:00 PM HRES 4/10/2018 8:00:00 AM |
HB 331 |
| HB331 Supporting Document - DOR.LAW 3.2.18.pdf |
HRES 3/30/2018 1:00:00 PM HRES 4/4/2018 1:00:00 PM HRES 4/6/2018 1:00:00 PM HRES 4/7/2018 2:00:00 PM HRES 4/9/2018 1:00:00 PM HRES 4/10/2018 8:00:00 AM |
HB 331 |
| HB331 Sectional Analysis 3.29.18.pdf |
HRES 3/30/2018 1:00:00 PM HRES 4/4/2018 1:00:00 PM HRES 4/6/2018 1:00:00 PM HRES 4/7/2018 2:00:00 PM HRES 4/9/2018 1:00:00 PM HRES 4/10/2018 8:00:00 AM |
HB 331 |
| HB331 Supporting Document - Letter of Support 3.29.18.pdf |
HRES 3/30/2018 1:00:00 PM HRES 4/4/2018 1:00:00 PM HRES 4/6/2018 1:00:00 PM HRES 4/7/2018 2:00:00 PM HRES 4/9/2018 1:00:00 PM |
HB 331 |
| HB331 Credit Bonds for HRES 4-2-18.pdf |
HRES 4/4/2018 1:00:00 PM HRES 4/6/2018 1:00:00 PM HRES 4/9/2018 1:00:00 PM |
HB 331 |
| AOGA Testimony - HB 331 - 4.4.2018.pdf |
HRES 4/4/2018 1:00:00 PM HRES 4/6/2018 1:00:00 PM HRES 4/7/2018 2:00:00 PM HRES 4/9/2018 1:00:00 PM |
HB 331 |
| Ambler_APRN article 1.30.18.pdf |
HRES 4/6/2018 1:00:00 PM HRES 4/9/2018 1:00:00 PM |
Ambler AMDIAR |
| Ambler_AIDEA PPT.pdf |
HRES 4/6/2018 1:00:00 PM |
|
| Ambler_AIDEA statutes re Regional Resource Advisory Council review.pdf |
HRES 4/6/2018 1:00:00 PM |
|
| Ambler_Cardno econ analysis excerpts.pdf |
HRES 4/6/2018 1:00:00 PM |
|
| Ambler_DOT May 2012 Report, Excerpt.pdf |
HRES 4/6/2018 1:00:00 PM |
|
| Ambler_DOWL AIDEA Cost Estims 2.26.18.pdf |
HRES 4/6/2018 1:00:00 PM |
|
| Ambler CSPP PPT.pdf |
HRES 4/6/2018 1:00:00 PM |
|
| Ambler CSPP invited testimony.pdf |
HRES 4/6/2018 1:00:00 PM |
|
| Ambler_Clarke PPT.pdf |
HRES 4/6/2018 1:00:00 PM |
|
| Ambler_Clarke invited testimony.pdf |
HRES 4/6/2018 1:00:00 PM |
|
| Ambler_Trilogy Metals PPT.pdf |
HRES 4/6/2018 1:00:00 PM |
|
| Ambler_Doyon ltr to BLM 1.24.18.pdf |
HRES 4/6/2018 1:00:00 PM |
|
| Ambler_Trustees' Follow-up Letter to BLM re Leg Hearing.pdf |
HRES 4/6/2018 1:00:00 PM |
|
| Ambler_v_Allakaket Opposition Resolution.pdf |
HRES 4/6/2018 1:00:00 PM |
|
| Ambler_v_Ambler Opposition Resolution.pdf |
HRES 4/6/2018 1:00:00 PM |
|
| Ambler_v_Bettles Opposition Resolution.pdf |
HRES 4/6/2018 1:00:00 PM |
|
| Ambler_v_Evansville Opposition Resolution.pdf |
HRES 4/6/2018 1:00:00 PM |
|
| Ambler_v_Huslia Opposition Resolution.pdf |
HRES 4/6/2018 1:00:00 PM |
|
| Ambler_v_Kobuk Opposition Resolution.pdf |
HRES 4/6/2018 1:00:00 PM |
|
| Ambler_v_Kotzebue Opposition Resolution.pdf |
HRES 4/6/2018 1:00:00 PM |
|
| Ambler_v_Koyukuk Opposition Resolution.pdf |
HRES 4/6/2018 1:00:00 PM |
|
| Ambler_v_Louden Opposition Resolution.pdf |
HRES 4/6/2018 1:00:00 PM |
|
| Ambler_v_Rampart Opposition Resolution.pdf |
HRES 4/6/2018 1:00:00 PM |
|
| Ambler_v_Ruby Opposition Resoulution.pdf |
HRES 4/6/2018 1:00:00 PM |
|
| Ambler_WIRAC 2017 Letter.pdf |
HRES 4/6/2018 1:00:00 PM |