Resource Development Council

RDC Comments:
EPA Request for Extenstion on
Bristol Bay Assessment Review Panel

March 6, 2012

Mr. Richard Parkin
Environmental Protection Agency Region 10, Bristol Bay Watershed Assessment
1200 Sixth Ave Suite 900
Seattle, WA 98101

Dear Mr. Parkin:

The Resource Development Council for Alaska, Inc. (RDC) writes to request an extension of at least 60 days to the nomination period for submitting qualified experts to the Bristol Bay Assessment peer review panel.

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.

While we recognize your recent time extension of one week, moving the deadline from March 9 to March 16, 2012, we feel there is still insufficient time to identify the caliber of candidates that should be considered for such a highly technical assessment.

One of RDC’s top priorities is to promote and defend the integrity of the permitting process and advocate for predictable, timely, and efficient state and federal permitting processes based on sound science and economic feasibility.

An assessment of the Bristol Bay watershed should be nothing if not thorough. The findings of this assessment should be based on extensive study and sound science, as the EPA is expected to base key decisions about mining in Bristol Bay upon the outcome. Therefore, it is imperative the peer review panel be a representation of all stakeholders and consist of knowledgeable, well-qualified persons. The short nominating period hampers the ability to present such persons, and therefore should be extended.

If the EPA is unwilling to further extend the nomination deadline, RDC will attempt to provide nominations for the panel within the allotted time.

Additionally, RDC is concerned the EPA is conducting the assessment to pre-empt a project in the area (the Pebble Mine) that has not yet applied for any development permits. The permitting process already in place is not done in haste, but is stringent and thorough. The hurried assembly of a review panel, as well as requiring the assessment to be done in only one month is irresponsible for a project of such magnitude, and undermines a diligent process already in place.

Thank you for considering RDC’s concerns on this important issue.

Resource Development Council for Alaska, Inc.

Cc: Dennis McLerran, Region 10 Administrator

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