March 3, 2010
Alaska Department of Environmental Conservation
Commercial Passenger Vessel Environmental Compliance
Program
Attn: Denise Koch
PO Box 111800
Juneau, AK 99811-1800
Re: 2010 DRAFT Large Commercial Passenger Vessel Wastewater Discharge General Permit
Dear Ms. Koch:
The Resource Development Council for Alaska, Inc. (RDC) appreciates the opportunity to comment on the 2010 DRAFT Large Commercial Passenger Vessel Wastewater Discharge General Permit.
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.
The Department of Environmental Conservation (DEC) has endorsed the discharge requirements in place today as among the most stringent in the world. However, the modifications in effluent limits proposed in the Department’s 2010 DRAFT General Permit are unattainable, as the technology to reach these limits simply does not exist.
Alaska’s environmental standards, across all resource sectors, are second to none. Indeed, in 2001, DEC called the requirements developed through collaboration with the cruise industry and members of the public “the most stringent water quality standards in the world.” A 2002 Science Advisory Panel study reaffirmed this and stated that ships discharging into a mixing zone, while adhering to these requirements, caused no negative environmental effects. The industry then spent millions of dollars to upgrade Alaska ships with advanced wastewater treatment systems to meet the newly imposed requirements.
Four years later, the 2006 Ballot Initiative instituted a “point of discharge” requirement, which holds cruise ships to an impossible standard by eliminating the mixing zone. The new required levels of effluent limits, measured right at the pipe, are technologically unattainable. These standards far exceed what is currently in place for municipal and statewide wastewater facilities in Alaska and isolates the cruise industry in a separate playing field with no known added benefit to the environment.
At one time, Alaska had a flourishing tourism industry that annually brought over one million cruise ship passengers to the state, provided thousands of jobs, and had an estimated economic impact of over $1.3 billion. Now, inequitable environmental standards like those proposed in the general permit, coupled with an unpredictable tax regime, have resulted in the cruise industry rerouting their ships out of Alaska. This will result in devastating cuts in jobs and wages to residents, in revenues to governments statewide, and the failure of many small, family-owned tourism businesses.
State water quality requirements should not be a standard for one, but for all entities. Ultimately, this general permit proposes environmental regulations that single out cruise ships from other entities in the state that discharge water. Requiring cruise ships to meet effluent limits that are much stricter than what is required of other dischargers in the state is discriminatory. Furthermore, the proposed limits in the general permit for cruise ships are unattainable.
RDC encourages DEC to retain the attainable, the still very stringent standards currently in place for cruise ships. It is a balanced compromise that will keep Alaska’s waters clean and provide for a healthy environment in which cruise ships can continue to bring visitors and economic opportunities to Alaska.
Thank you for the opportunity to comment on this important issue.
Sincerely,
Resource Development Council for Alaska, Inc.
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