Murkowski's complaint about ANWR becoming a monument has little to no connection with the residents of the islands wanting a sanctuary around their homes and requesting one. An ANWR monument would not violate ANILCA because ANILCA specifically exempted areas set aside prior to 1980. ANWR was set aside in 1960. Further, the 'no more clause' in ANILCA would not survive close examination by the courts, who have held since 1920 that large monuments are permitted, and that the size of the monument is the presidents call. Monuments in ANWR and Bristol Bay will be upheld, under Supreme Court precedent, and the fact AK has no standing to challenge any monuments in its borders , under Alaska vs Carter (1980). It is the courts, not Congress, that determine the legality of actions by the presidents, in the case of monuments, the courts have upheld every monument ever challenged, including all 17 of Carters. Likewise any monuments Obama creates will be upheld.