September 28, 2009
Air Docket
Environmental Protection Agency
Mailcode 6102T
1200 Pennsylvania Avenue, NW
Washington, DC 20460
To Whom It May Concern:
This letter is in response to your solicitation for public comments regarding the proposal of Emission Control Area (ECA) designations for geographic control of emissions from ocean-going ships.
The Resource Development Council (RDC) is a statewide business association comprised of individuals and companies from Alaska’s oil and gas, mining, forest products, tourism and fisheries industries. RDC’s membership includes Alaska Native Corporations, local communities, organized labor, and industry support firms. RDC’s purpose is to encourage a strong, diversified private sector in Alaska and expand the state’s economic base through the responsible development of our natural resources.
In its ECA application to the International Maritime Organization (IMO), the EPA included Southeast and Southcentral Alaska, indicating a need for emission control in these areas. However, EPA has stated, “Our air quality modeling does not extend beyond the 48 contiguous states, therefore, it will be necessary to find other ways to measure the health and environmental impacts of marine emissions on health and human welfare outside the continental United States.” Furthermore, the EPA has committed to collaboration with the Alaska Department of Environmental Conservation (ADEC) on ECA designations, yet has overlooked air sampling done by ADEC that proves pollutant levels in coastal communities of Alaska are well below state and national air quality standards. Without its own air quality modeling, the EPA should not turn a blind eye to the State of Alaska’s science surmising that no harmful affects on human health or environment exist in the air of these communities.
In addition to requiring scientific studies to justify an ECA, the IMO requires an economic analysis be done to consider the cost of implementing new standards, and the subsequent economic impacts to local communities. The Alaskan communities served by ocean-going ships, as well as the remainder of the state’s residents, would certainly feel the effect of immense cost increases to vessel operations. This must be a factor that is taken into consideration before including Alaska in an ECA designation.
Creating an ECA in Alaska without sufficient air quality modeling will greatly impact Alaskans in all walks of life. RDC members across all resource sectors stand to be adversely affected: transportation companies that bring goods in and ship cargo out of the state will face significant cost increases in continued operations. Cruise ships, which bring an estimated one million visitors to Alaska annually, will face a nearly impossible task of complying with designations, given they will remain within the ECA boundaries during the entire trip. Exportation of commodities, particularly Alaska’s natural resources like oil and gas, minerals, and timber, will become increasingly more expensive if ships carrying them have to incur higher operating costs.
In conclusion, RDC requests that you exclude Alaska from any ECA designations until adequate air quality modeling and economic impact analyses are conducted for the state.
Thank you for the opportunity to submit comments on this important issue.
Sincerely,
Resource Development Council for Alaska, Inc.
