Resource Development Council

RDC Comment Letter:
NPDES Permit AK-003865-2 for the Red Dog Mine

May 25, 2011

Office of Water and Watersheds
1200 Sixth Avenue, Suite 900
Seattle, WA 98101

Submitted via email to

Re: NPDES Permit AK-003865-2 for the Red Dog Mine

To Whom It May Concern:

The Resource Development Council for Alaska (RDC) is writing to support the Environmental Protection Agency’s (EPA) proposed discharge limitations outlined in the Draft Permit dated January 8, 2010 (draft permit) and specifically those proposed limits for Total Dissolved Solids (TDS) and cyanide.

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 discharge limitations detailed in the draft permit establish realistic standards while still protecting human health and the environment. The EPA had determined these limits are not only protective, but also within the bounds of the Clean Water Act.

Since production began at the Red Dog Mine, improvements to the water quality of the Red Dog Creek have been achieved and maintained. The discharge of treated water from Red Dog has improved water quality, reducing naturally occurring acid and metals, enhancing fish populations.

The Red Dog Mine provides hundred of jobs to the Northwest Alaska economy and funds the entire tax base of the Northwest Arctic Borough. In 2010, royalties of nearly $146 million to NANA Regional Corporation, with as much as $82 million dispersed to all other Alaska Native Corporations, were paid by the Red Dog Mine.

In conclusion, RDC supports the reinstatement of the 2010 permit limitations, and applauds the EPA’s efforts to avoid overly stringent regulations that could severely impact the Northwest Alaska economy. Thank you for the opportunity to comment on this important issue.

Resource Development Council for Alaska, Inc.