April 29, 2011
National Ocean Council
722 Jackson Place, N.W.
Washington, DC 20503
Submitted via www.whitehouse.gov/administration/eop/oceans/comment
Re: Development of Strategic Action Plans
To Whom It May Concern:
The Resource Development Council for Alaska (RDC) is writing to express apprehension regarding the development of strategic action plans for the national policy for the stewardship of the ocean, our coast, and the great lakes, and the potential impacts on Alaska.
RDC is an Alaskan non--profit, 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.
With more coastline than all other states in our nation combined, Alaska’s stake in the emerging ocean policy is unmatched. Subsequently, the impact of any oceans policy will affect Alaska significantly. It is essential that Alaskan stakeholders be involved in the development of the strategic action plans. A large number of industries, not only in Alaska, but across the nation, including transportation, fishing, oil and gas, tourism, and mining, may be impacted in a largely economic way from any new regulations, with no added benefit to the environment.
Moreover, the proposed plans should focus on helping – not harming – American communities. Unfortunately, it appears more harm than good will come of this process. Without enhanced stakeholder involvement, the proposed plans will likely increase litigation on important resource and community projects, causing further burden to projects in rural and remote locations, especially in Alaska.
Please consider the following comments when addressing the nine objectives described by the National Ocean Council.
Objective 1: Ecosystem--Based Management
The science used to develop the foundation for this principal must be the best available science and must include industry--developed science. Much of what is known about the Alaskan Arctic can be attributed to science done in conjunction with natural resource project development and operation, such as through the Minerals Management Service (now BOEMRE), oil industry, and other natural resource developers. Supplemental research will enhance existing knowledge of the Arctic and should be pursued. Alaskan science must be used to develop an ecosystem--based management plan, rather than a one size fits all approach for the nations waters.
Objective 2: Coastal and Marine Spatial Planning (CMSP)
CMSP, or ocean zoning, will have a more substantial impact on Alaska than any other region. CMSP must clarify the role of existing management procedures, such as the North Pacific Fishery Management Council (NPFMC), state specific programs, and others, while addressing valuable science--based practices Alaska already adheres to.
Objective 3: Inform Decisions and Improve Understanding
RDC supports continued research and mapping of oceans and other water bodies, particularly in the Arctic. Consideration should be made to existing studies and procedures to avoid duplication and additional cost to stakeholders. Adding more layers and overriding regulation of successful practices will provide no added benefit to creating a national policy.
Objective 4: Coordinate and Support
Stakeholder involvement has been minimal, at best. RDC urges additional representation in this process from economic stakeholders to include, but not be limited to outer continental shelf and land based oil and gas leaseholders, coastal communities and boroughs, village and Alaska Native leaders, fishing and fish processing, and transportation users. Economic advisory groups should be utilized to identify economic impacts of uses of the oceans, coasts, and river deltas.
Objective 5: Resiliency and Adaption to Climate Change and Ocean Acidification
Alaska – with two-thirds of our nations coastline, over 40% of the surface waters, and over half the nations wetlands – is at the forefront of impacts from changing climate and ocean acidification.
Greenhouse gas emissions/climate change and its potential impacts should not be regulated by ocean zoning. The potential impact to communities and projects if this were to be done could be devastating to Alaska’s economy, with minimal or no added benefit to the environment.
Objective 6: Regional Ecosystem Protection and Restoration
Alaska has developed some of the best resource management practices in the world, with some of the highest standards and requirements for projects.
Alaska has the best--managed fishery in the world under the purview of the NPFMC and State management. These fisheries are managed by the best available science, and are closed when catch limits are met, even when the limits are set at numbers well below the scientific recommendations, thus, creating sustainable fisheries.
Further, some of the best response mechanisms are also in place for development projects in and around water bodies. The oil industry has well developed spill contingency plans specific to Alaska’s unique Arctic conditions. Additional response plans implemented through the strategic action plans will only add another layer that will hinder the opportunity for responsible development in Alaska, driving similar projects to be developed in countries with less stringent standards and regulations.
Objective 7: Water Quality and Sustainable Practices on Land
Existing protection measures are in place and working, such as the National Environmental Policy Act (1969), Coastal Zone Management Act (1972), Magnuson--Stevens Fishery Conservation Act (1977), the Clean Water Act (1977), and as part of the Magnuson--Stevens Act, Essential Fish Habitat (1996). We ask you to consider how another bureaucratic layer would benefit the environment.
Objective 8: Changing Conditions in the Arctic
Alaska is at the forefront of changing conditions in the Arctic, and should be afforded the opportunity to address this issue. Stakeholder involvement is principal from this aspect.
Because of the vast natural resource development potential in Arctic waters off the coast of Alaska, RDC is very supportive of increased Coast Guard presence. With this presence must come additional infrastructure. New Coast Guard bases in Alaska will improve safety to remote villages, while also increasing national security.
Proactively, the Arctic fish management plan was developed closing the Arctic to fishing until further research is completed and data is collected. This action should not imply endorsement of a permanent closure of the area, but rather the need for a better understanding of the ecosystem prior to management decisions being made. Moreover, the need for additional research and stakeholder involvement to develop a plan should be recognized by the National Ocean Council.
Objective 9: Ocean, Coastal, and Great Lakes Observations, Mapping, and Infrastructure
Alaska, being a relatively young state, lacks infrastructure, especially in rural and much of the coastal communities.
Other Impacts for Consideration: Alaska’s Abundant Natural Resources and People
In addition to the previously listed concerns, please consider the following cultural, economical and societal characteristics of Alaska in developing a final plan that will preserve opportunities and ways of life for Alaskans.
Alaska’s People
In 2010, Alaska’s population was roughly 710,000 people in a state with more than 365 million acres. With over 3 million lakes, 3,000 rivers and 34,000 miles of coastline, Alaska is a unique part of the United States. Alaska’s economy, based on responsible resource development – development done in accordance with local, state and federal environmental protections and laws already in place – must be fully considered before plans are implemented, and projects, cultures and communities are jeopardized.
Fishing
Alaska is one of the most bountiful fishing regions in the world, producing a wide variety of seafood and over half the U.S.’s annual harvest. All five species of Pacific salmon, four species of crab, many kinds of groundfish, shrimp, herring, and sablefish are all harvested from Alaska. The fisheries of Alaska continue to be recognized as some of the best--managed fisheries in the world, providing thousands of jobs and a vital, sustainable economic engine for Alaska communities and the state.
Seafood harvesting and processing jobs provide more than 50 percent of the private sector employment in coastal Alaska. In recent years, the fishing industry generated nearly 54,000 jobs.
Alaskans must continue to have access to this valuable and traditional resource without further bureaucratic levels and regulations, which would provide no added benefit to the resource.
Mining
Much of the existing infrastructure in Alaska, such as roads, docks, and airports was originally constructed to serve the mining industry. Alaska’s active mineral extractions include silver, zinc, gold, and lead, as well as coal production. Additionally, Alaska could potentially produce copper and molybdenum, increasing overall statewide mineral extraction. In 2007, Americans needed 19 minerals that were 100% imported, while an additional 50% of 25 other minerals were also imported. Of the 30 minerals the U.S. imports from abroad, 22 of them are found in Alaska.
Mining activity provides for 3,500 direct, well--paying jobs, and over $350 million in direct and indirect payroll. Mining contributed $71.9 million to local and state government in 2010. In addition, mining paid $145 million to Alaska Native Corporations.
Mining in Alaska, overseen by rigorous and thorough local, state, and federal regulations should not be unnecessarily subjected to additional layers of government, which these plans may bring forth, leading to further delay and unwarranted litigation.
Oil and Gas
As America’s energy consumption continues to rise, affordable energy is much needed. In 2009, over half the petroleum consumed in the U.S. was imported. Alaska has significant energy resources, both on and offshore, that can be produced as America continues to work its way to renewables. The ocean, specifically the nation’s outer continental shelf, can also go a long way to helping the U.S. reduce its dependence on foreign sources of energy. Emphasis in any ocean policy must be placed on allowing access to these resources while protecting traditional uses such as subsistence hunting and other cultural uses. We urge the administration to include Alaska on the forefront for development of offshore resources, including renewable and non--renewable resources.
In recent years, the oil industry has supported as much as one-third of Alaska’s workforce, employing people in well paying jobs. Since 1957, the State of Alaska has received $95 billion from the oil and gas industry.
Similar to mining, oil and gas development has existing local, state, and federal regulations and should not be subjected to unnecessary extraneous layers of government. Oil and gas development in Alaska should be applauded as an effort to reduce the U.S. dependence on foreign oil.
Tourism
Alaska is like no other place. It has more mountains, glaciers and wildlife than just about anywhere else in the world. Alaska has become a top visitor destination and the industry has experienced steady growth as more people than ever discover Alaska.
Alaska’s tourism industry depends on access to waterways for travel by cruise ship and access to land transportation by dock. Many communities, such as those in Southeast Alaska, depend on seasonal visitors, offering boat tours, fishing excursions, and recreational activities like kayaking and rafting. In recent years, tourism accounted for 27,000 direct jobs with a payroll of $800 million.
Tourism is a renewable resource. New restrictions could have a negative impact on people and businesses in coastal and inland communities where no other resources are available.
Transportation
Transportation providers also rely on future access to the ocean for their responsible and ongoing operations. Shipyards, ports and transportation companies all benefit from activities and energy production in Alaska’s waters. The Arctic Ocean, a potential new route for shipping and transportation will present new opportunities for Alaska, and the U.S.
Duplicitous regulations may cause confusion and delays in transportation, increasing cost and waste, especially for remote locations.
Rural, Coastal, and Village Communities
Alaska’s resource development projects create and provide jobs in communities throughout Alaska, many of which have few other jobs available. Many of those communities will disappear if overly burdensome regulations are added to existing and new projects.
Community and traditional knowledge, further studies, and plans specific to regions should be first and foremost. Any policy for Alaska should be tailored to fit Alaska’s specific needs and characteristics, not a one size fits all plan for the nation.
Conclusion
RDC urges cautious development of strategic action plans for national ocean policy, and encourages the task force to take into consideration programs that have already been established and proven to protect and manage the oceans. National oceans policy should include measures to address the need for more research and data collection in the oceans. Any ocean policy should coordinate with existing management programs and stakeholders with a focus on avoiding redundancy and maintaining access. Increased bureaucracy would hamper the already slow processes, delaying projects vital to Alaska’s economy with minimal or no added benefits to the environment.
In conclusion, RDC encourages enhanced, open, and transparent communication and coordination with Alaskan stakeholders for national ocean policy. Thank you for the opportunity to comment on this important issue.
Sincerely,
Resource Development Council for Alaska, Inc.
