Overview:

The renewal of the National Pollutant Discharge Elimination System (NPDES) general permit is critical to continued oil and gas production in Cook Inlet. Both the U.S. Environmental Protection Agency (EPA) and the Alaska Department of Environmental Conservation (DEC) have published their draft documents online.

The conditions and limits established through this renewal process will govern operations during the next five-year permit term. It is essential that permit conditions are technically and economically achievable.

There are a number of conditions in the proposed permit that are of concern to industry.  All of these conditions add to the costs of operation and reduce the period of time that Cook Inlet facilities will continue to meet economical thresholds for operation. 

Action Requested:

Please participate in the public process surrounding the NPDES permit.  Those who oppose oil and gas development will be submitting comments and testifying at public hearings on the draft permit. Therefore, it is important for those of us who support the industry and rely on oil and gas from Cook Inlet, to make our position for a responsible and reasonable permit known as well. There are two ways you can become involved:

Submit a letter to the EPA and ADEC by May 31:

Attend one or more public hearings on the draft permit to present brief testimony:

Homer: April 4, 7 p.m., Alaska Islands & Oceans Visitor Center

Kenai/Soldotna: April 5, 7 p.m., Kenai Peninsula Borough Office

Anchorage: April 6, 7 p.m., Hilton Garden Inn, 100 W. Tudor Road 

Points to consider in your comments:

• The renewal of the Cook Inlet General NPDES permit is critical to oil and gas production in Cook Inlet. It is essential that permit conditions are technically and economically achievable.
• Major revisions to the existing permit that result in increased monitoring and regulation are unnecessary, especially given the fact that studies have consistently demonstrated no environmental degradation of the environment after 40 years oil and gas activity in Cook Inlet.
• Under existing state and federal permits, industry must comply with stringent water quality standards that protect aquatic life. All discharges, which have relatively low toxicity, are strictly monitored prior to release.  The State has acknowledged that because of the swift currents, tides and the mixing capacity of Cook Inlet, discharges do not accumulate in the Inlet.
• The new permit must allow operations to continue under the existing regulatory regime with improvements directed at making monitoring more efficient and reducing the number of samples required.
• There are a number of conditions in the proposed permit that are of concern. For example, setbacks for no discharge zones included in the permit by EPA will limit areas that can be open for exploration or development. EPA is requiring additional studies be done, proposing increased monitoring, as well as increased frequency of monitoring, and requiring physical changes to facilities which are very expensive.
• Because Cook Inlet fields are nearing the end of their useful lives, major permit changes now could negatively impact the economic viability of existing operations. Despite high energy prices, four facilities have been shut down.
• Renewal of the current permit is in the best interest of Alaska and local communities. It is protective of the environment and allows for continued operation of industry facilities, which provide the region with its daily energy needs.

Deadline for Comments: May 31, 2006