RDC Comment Letter:
Support of EPA's Stormwater Assertion
(Docket # EPA-HQ-OW-2012-0195)

October 4, 2012

Water Docket
Environmental Protection Agency
Mailcode 2822T 1200
Pennsylvania Avenue NW
Washington, D.C. 20460

Attention: Docket # EPA-HQ-OW-2012-0195

The Resource Development Council for Alaska, Inc. (RDC) is writing to support the Environmental Protection Agency’s (EPA) assertion that stormwater discharges from logging roads are not stormwater discharges associated with an industrial activity requiring Clean Water Act (CWA) Section 402 National Pollutant Discharge Elimination System (NPDES) permits.

RDC is an Alaskan, non-profit, membership-funded organization founded in 1975. The RDC 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.

The State of Alaska promulgated statutes and implemented regulations to protect water quality from stormwater-related discharges from forest and logging roads. The State manages runoff from these roads through regulations developed under the direction of the Alaska Forest Resources and Practices Act for water quality management and pollution control. Best Management Practices (BMP) are in place to control erosion and sedimentation during road construction and to address ongoing drainage. Ongoing monitoring demonstrates the effectiveness of this approach. Similarly, the U.S. Forest Service has also developed BMPs that are consistent with those of the Alaska Forest Resources and Practices Regulations.

The State of Alaska is highly successful at protecting water quality through its current approach. RDC supports the continued use of the State’s BMP-based programs, in lieu of requiring permitting under Section 402 of the Clean Water Act.

Thank you for the opportunity to comment.

Sincerely,
Resource Development Council for Alaska, Inc.