July 1, 2011
National Ocean Council
722 Jackson Place, N.W.
Washington, DC 20503
Submitted via http://www.whitehouse.gov/administration/eop/oceans/sap/comments
Re: Strategic Action Plan Outlines
To Whom It May Concern:
The Resource Development Council for Alaska (RDC) is writing to address concerns related to the interim strategic action plan outlines (SAP outlines).
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.
Overall, RDC respectfully requests the NOC fully consider the following suggestions, after which, RDC addresses the nine SAP outlines.
In comments at the listening session held in Anchorage, Alaska on June 10, 2011, RDC asked that instead of adding another layer of policy, please improve coordination of existing protection measures, such as the Clean Water Act, the National Environmental Policy Act, and the Magnuson-Stevens Fishery Conservation Act.
Alaska’s economy is based on responsible resource development that is done in accordance with existing local, state, and federal environmental protections and laws. We must continue to have access to our valuable and traditional resources.
Responsible development of these resources creates jobs in communities throughout Alaska, many of which have few other jobs available. Many of these communities will disappear if overly burdensome regulations are added to existing and new projects.
RDC also notes that in comments to the NOC on April 29, 2011, we asked that Alaskan stakeholders be involved in the development of the SAPs. We write to reiterate those comments and recommendations.
Alaska is an ocean state, with coastlines on two oceans, the Arctic and the Pacific, and with three different seas: Chukchi, Beaufort, and the Bering Sea. Alaskan stakeholders, including all RDC members, have a large interest in protecting these seas, as well as the three million lakes and three thousand rivers in Alaska.
There is an existing array of measures in place to protect our nation’s waters, which clearly demonstrates our nation’s interest in not only safeguarding, but also wisely using our ocean resources.
The actions outlined in the SAPs could negatively impact many industries in Alaska, with no added benefit to the environment. The potential negative economic impact to communities all over Alaska could result from damage to industries in Alaska, such as transportation, commercial fishing, mining, tourism, construction, and energy – including oil, gas, and renewable.
Strategic Action Plan Outlines Comments
Objective #1: Ecosystem-Based Management (EBM) EBM must be fully defined and must not be developed rapidly. Alaska’s ecosystem will be very different than that of a state on the Atlantic. If EBM becomes guidance for new federal regulations, then it must be developed with the best available science, stakeholder involvement, and additional research.
Objective #2: Coastal and Marine Spatial Planning (CMSP) Any CMS Plan must involve the regional Fishery Management Council. The North Pacific Fishery Management Council oversees the world’s healthiest and best managed fisheries in Alaska.
Objective #3: Inform Decisions and Improve Understanding The plan to prioritize research activities is based on a study not yet available to the public. Stakeholders cannot review and understand the basis of this plan without access to the guiding documents.
Objective #4: Coordinate and Support RDC continues to support coordination of management entities and encourages the NOC to not add an additional layer of regulation.
Objective #5: Resiliency and Adaption to Climate Change and Ocean Acidification Alaska has many communities directly impacted by climate change, however, greenhouse gas emissions/climate change should not be regulated by ocean policy.
Objective #6: Regional Ecosystem Protection and Restoration Existing protection and restoration efforts in Alaska are adequate. RDC recommends these efforts be better coordinated, in place of new and costly federal regulations.
Objective #7: Water Quality and Sustainable Practices on Land Again, existing measures are already in place and working, such as the National Environmental Protection Act (1969), the Coastal Zone Management Act (1972), and other federal, state, and community regulations.
Objective #8: Changing Conditions in the Arctic Alaska is what makes the United States of America an Arctic Nation. This said, Alaska must be allowed to improve infrastructure and increase access to it oceans. With increased access comes more research and a better understanding of the Arctic. Additional research and stakeholder involvement must be recognized by the NOC before moving forward.
Objective #9: Ocean, Coastal, and Great Lakes Observations, Mapping, and Infrastructure RDC encourages the NOC to support continued research and delay implementation of any new regulations without adequate input from stakeholders.
In conclusion, RDC believes any ocean policy should coordinate with existing management programs and stakeholders with a focus on avoiding redundancy and maintaining access.
Thank you for the opportunity to comment on the outlines.
Resource Development Council for Alaska, Inc.