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June 28, 2013
Office of Environmental Information (OEI) Docket (Mail Code: 28221T)
Docket # EPA-HQ-ORD-2013-0189
U.S. Environmental Protection Agency
1200 Pennsylvania Ave., N.W.
Washington, DC 20460
Via: http://www.regulations.gov
To Whom It May Concern: The Resource Development Council for Alaska, Inc. (RDC) is writing to further comment on the Environmental Protection Agency’s (EPA) Revised Draft Bristol Bay Assessment (BBA).
RDC 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.
In addition to the comments outlined below, RDC has attached a copy of our comments dated May 29, 2013 and respectfully requests the EPA also address our initial concerns submitted via the May letter.
RDC urges the EPA to consider the benefits of the jobs not only in Alaska, but in the nation, that will likely come from development of Pebble. The prospect is one of the most significant mineral deposits in the United States, with the potential for billions in economic activity and thousands of jobs.
In addition, RDC maintains the project is clearly too important to be judged based on a hypothetical mine, or on uncertain legal grounds. The project should not be deprived of the due process that is consistent with other projects in Alaska and throughout the nation.
RDC requests the EPA address our concerns about the recommendations in the BBA which are based on research from a discredited scientist, Ann Maest, as well as the deference given to work done by groups actively opposed to development of the Pebble Project. RDC is concerned that these sources further result in lack of credibility of the report.
Moreover, RDC believes the EPA did not use the best available science in development of the assessment, and that the engineering modeling in the BBA is seriously flawed and not based on realistic, modern standards. The EPA should also explain the geology background of the BBA, or lack thereof, and include the credibility of the geologists and their knowledge/work in the Bristol Bay area.
The BBA includes discussion on potential mitigation efforts in response to large-scale hardrock mining in the Bristol Bay watershed that is based on hypothetical measures, which do not consider new industry standards or innovative practices. Additionally, the section on compensatory mitigation was cursory and dismissive; the importance of this issue is belittled through the EPA’s wholly inadequate 16-page treatment of the topic.
Other groups opposing the proposed Pebble Project claim to have spent millions of dollars on years of research in the area, the Pebble Partnership has studied the deposit area for over eight years, spending over $150 million dollars. Why is this research ignored in the BBA?
Furthermore, the revised draft has not clarified the purpose and the scope of the assessment, and has resulted in more confusion and uncertainty. RDC is concerned this will further hamper investment in Alaska. Investors already see Alaska as more expensive to do business, in part due to logistics and climate, but also because of the long lead times in the permitting process and regulatory uncertainty.
In conclusion, RDC writes to again urge the EPA from further premature action on the BBA. RDC urges the EPA not to use the BBA to preemptively halt a project as such action would deprive government agencies and stakeholders of the specific information, science, and rigorous reviews that would come out of the multi-year process. The EPA should not preemptively veto projects in the Bristol Bay area, or anywhere, and should stop undermining existing regulatory processes and avoid setting a dangerous precedent for development. Investment in Alaska should not be jeopardized by federal overreach. Further, the BBA should not be used to inform the process until its numerous flaws are corrected and it addresses a formal development plan, as well as a suite of mitigation measures, submitted by the project sponsor.
Thank you for the opportunity to comment on this important issue.
Sincerely,
Resource Development Council for Alaska, Inc.
