Resource Development Council

RDC Comment Letter:
Environmental Protection Agency on the
303(d) Program and Ocean Acidification

May 21, 2010

Clean Water Act Section 303(d): Notice of Call for Public
Comment on 303(d) Program and Ocean Acidification
Environmental Protection Agency, Mailcode: 4503–T
1200 Constitution Ave., NW
Washington, DC 20460

Attn.: Docket ID No. EPA–HQ–OW–2010–0175

Dear Sir or Madam:

The Resource Development Council for Alaska (RDC) appreciates the opportunity to comment on the 303(d) program and ocean acidification to the Environmental Protection Agency.

RDC is an Alaskan, membership-funded organization founded in 1975. Our 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.

Alaska’s cold and highly productive waters are thought to be more susceptible to carbon dioxide (CO2) absorption than other waters of the U.S. Subsequently, if guidance regarding the listing of waters as threatened or impaired for ocean acidification is developed, Alaska would likely be disproportionately impacted. Such designation could severely affect responsible development of much needed resources in and around Alaska, regardless of the project’s potential impact on the water body.

The regulation of greenhouse gas emissions and their potential impacts should be through independent legislation, rather than through vehicles such as the Clean Water Act. Therefore, RDC requests that guidance not be developed to designate waters as impaired or threatened under the 303(d) program when the listing is a result of ocean acidification caused by atmospheric CO2.

Thank you for the opportunity to provide comment.

Resource Development Council for Alaska, Inc.