December 10, 2008
Lindsay Guzzo
Office of Water and Watersheds
USEPA Region 10
10200 Sixth Avenue, Suite 900
OWW-130
Seattle, WA 98101
Re: Proposed NPDES Permit Number AKG 524000
Dear Ms. Guzzo:
The Resource Development Council for Alaska, Inc. (RDC) writes to express its concerns regarding new permit requirements of the National Pollutant Discharge Elimination System (NPDES) General Permit AKG 524000 for Offshore Seafood Processors in Alaska.
RDC is a statewide, non-profit, membership-funded organization founded in 1975. The RDC membership is comprised of individuals and companies from Alaska’s oil and gas, mining, timber, tourism, and fisheries industries, as well as Alaska Native corporations, local communities, organized labor, and industry support firms. RDC’s purpose is to link these diverse interests together to encourage a strong, diversified private sector in Alaska and expand the state’s economic base through the responsible development of our natural resources.
RDC opposes the need for multiple discharge permits governing the same areas of water, and proposes the new permit be specific to federal waters, three or more nautical miles from shore. Alaska’s primacy over pollutant discharge elimination systems in Alaska’s waters should encompass zero to three miles from shore. Over-lapping water jurisdiction results in unnecessary complications and burden on Alaska’s fishing industry.
Furthermore, the draft NPDES permit describes new and excessive reporting requirements for influent/effluent monitoring and testing for metals. The At-Sea Processors Association (APA) proposes revisions to these requirements via comment letter (December, 2008) with which RDC concurs.
RDC encourages the EPA to remove the revisions regarding scupper blockage and annual reporting of discharge tracking and mapping for safety and proprietary purposes. The purpose of a scupper is vessel safety, and blocking it would jeopardize the vessel stability in high seas. Mapping and recording of discharge tracks would be overly burdensome and would reveal fishing strategies of each vessel.
Alaska, being the number one fishing state in the union, relies on fishing for over 50,000 direct and indirect jobs (2007) and as a renewable resource pumping dollars and opportunity into the economy. RDC members, specifically fishing members, have a large stake in maintaining water standards and protecting fish. With the revisions listed in this letter, and those proposed by APA, the permit will still require extensive guidelines and protections be met through continuous monitoring and reporting.
RDC appreciates the opportunity to comment on this important issue.
Sincerely,
Resource Development Council for Alaska, Inc.
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