Resource Development Council

RDC Comment Letter:
National Ocean Policy Draft Implementation Plan

March 28, 2012

National Ocean Council
722 Jackson Place, NW
Washington, DC 20503

Submitted via

Re: Comments on the National Ocean Policy Draft Implementation Plan

Dear National Ocean Council Members:

Thank you for the opportunity to comment on the National Ocean Policy Draft Implementation Plan (Draft Plan).

The Resource Development Council for Alaska, Inc., is an Alaskan 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.

RDC has submitted comments regarding the plan on several occasions, and again urges the National Ocean Council (NOC) to fully consider the following concerns regarding the Draft Plan:

RDC is concerned with the potential negative impacts National Ocean Policy will have on Alaskan communities and projects. The Draft Plan includes 53 actions and almost 300 benchmarks, of which more than half are supposed to be completed by the end of 2013.

This plan places additional burden and uncertainty on Alaskans, threatening to further restrict our ability to access and responsibly develop our natural resources. Alaska has the highest interest in protecting and ensuring the protection of our coastal and marine resources. These resources are vital to Alaska’s economy. Alaska, and the U.S., can benefit from our largely untapped resources such as the estimated 27 billion barrels of oil and the 132 trillion cubic feet of natural gas in the Outer Continental Shelf. But development of these resources must not be further restricted or further hindered by unnecessary bureaucratic delay.

In part, Alaska was granted statehood due to our vast natural resources, the federal government expected Alaska to utilize its natural resources to build and sustain its economy. Note that Alaska’s constitution includes, “It is the policy of the State to encourage the settlement of its land and the development of its resources by making them available for maximum use consistent with the public interest.” But, we must have access to our resources, and avoid uncertainty and unnecessary regulations that offer no added benefit to the environment.

In regard to public policy, RDC questions how the policy can proceed without Congressional authorization. Implementation of the Plan will likely cost a considerable amount of federal dollars and adds another level of bureaucracy to our already highly regulated and protected oceans and surrounding areas. The Draft Plan’s national objectives should focus on reducing unnecessary measures and improving existing programs and policy.

In response to the recent announcement to include a seat on the Regional Planning Bodies (RPB) for a member of the Regional Fishery Management Councils (RFMC), RDC is disappointed in the limiting factor that the individual must be a government representative. This continued refusal to include stakeholders outside of government reflects the lack of consideration for all other stakeholders. Additionally, RDC remains concerned that the authorities of the RFMCs to manage fisheries will be undermined by the actions of the Regional Planning Bodies. Having a single seat on the RPB does not mitigate this concern.

Coastal and Marine Spatial Planning
RDC continues to be concerned with the NOC’s goal to develop Coastal and Marine Spatial Planning (CMSP). RDC reiterates our previous recommendation to use areas interested in and supportive of CMSP as pilot projects. CMSP should not be enforced by the federal government in areas which are already well managed and where it is unsolicited.

Further, the Handbook for Regional CMSP should be subject to public input, review, and comment. All stakeholders should have the opportunity to be engaged, and all science, including that of industry, should be used to develop any policy. CMSP should be transparent and should demonstrate exactly what the program is expected to achieve, how such actions will be achieved, and who has authority to make related decisions.

Changing Conditions in the Arctic
The Draft Plan calls for improvement of Arctic development response, coordination of science and data, and new studies. The NOC must ensure the new studies and efforts do not unnecessarily delay or curtail activities, effectively making those activities unviable.

Regulations intended to reduce sea ice loss will likely negatively impact Alaska’s economy at a disproportionately higher magnitude.

Before further proceeding, the NOC must fully consider the potential economic impacts that the National Ocean Policy may have on industries across the nation, including fishing, oil and gas, energy, mining, transportation, tourism and more.

In addition to the comments above, RDC respectfully endorses the more detailed comments developed by the National Ocean Policy Coalition (dated February 27, 2012).

Thank you for the opportunity to comment.

Resource Development Council for Alaska, Inc.

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