Resource Development Council

RDC Comments:
Bristol Bay Assessment Extension Request

May 9, 2013

Office of Environmental Information (Mail Code: 28221T)
Docket #EPA-HQ-ORD-2013-0189
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, N.W.
Washington, D.C. 20460

Via email to

Re: Docket #EPA-HQ-ORD-2013-0189

To Whom It May Concern:

The Resource Development Council (RDC) is writing to request the Environmental Protection Agency (EPA) extend the comment period for the Revised Draft Bristol Bay Assessment (BBA) by at least 120 days.

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 comment period ending May 31, 2013 should be extended to adequately allow for public review of the document. The 30-day comment period in place is insufficient and should be extended at least 120 days to allow commenters ample time to provide feedback. The comment period does not provide sufficient time to fully consider responses for such a technical and lengthy document.

Additionally, RDC requests the EPA provide a detailed breakdown of the changes made to the previous draft to develop the current draft. The EPA has noted 233,000 comments were received, but does not clearly indicate responses to the comments by showing changes or reasons why changes were made. RDC urges the EPA to outline responses to previous comments, and clarity on how those comments impacted the current draft of the BBA.

It is one of RDC’s top priorities 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.

RDC is also writing to reiterate that an assessment of the Bristol Bay area must be objective and thorough. The findings of this assessment must also be based on extensive study, sound science, and a project applicant’s formal plans and proposed mitigation measures, as the EPA is likely to base key decisions about mining in Bristol Bay upon the outcome of it.

Lastly, RDC continues to be 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 existing state and federal permitting process will not be done in haste, as it is stringent and thorough. The hurried public review of the assessment in one month is irresponsible for a project of such magnitude.

An extension of the comment period will greatly enhance the public’s ability to respond with meaningful and substantive comments. RDC intends to submit formal comments on the draft Bristol Bay Assessment at a later date. Thank you in advance for your consideration of our request.

Resource Development Council for Alaska, Inc.

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