Resource Development Council

RDC Comment Letter:
ADEC Proposed Multi-Sector General Permit

February 7, 2014

Mr. William Ashton
Alaska Department of Environmental Conservation
555 Cordova Street
Anchorage, AK 99501

Via email to

Re: Alaska Department of Environmental Conservation Proposed Multi-Sector General Permit

Dear Mr. Ashton:

The Resource Development Council for Alaska, Inc. (RDC) is writing in response to the State of Alaska Department of Environmental Conservation (DEC) proposed revisions to the Multi-Sector General Permit (MSGP).

RDC is an Alaskan business association comprised of individuals and companies from Alaska's oil and gas, mining, forest products, tourism, and fisheries industries. Our membership includes all of the Alaska Native regional corporations, local communities, organized labor, and industry support firms. RDC's purpose is to expand the state's economic base through the responsible development of our natural resources.

RDC thanks you for developing the proposed MSGP, and applauds your efforts to increase efficiency of the program. Nearly every industry in Alaska, including fishing, oil and gas, tourism, mining, and timber is permitted under the Clean Water Act. Each of these industries has a high interest in supporting an efficient MSGP program. Please consider the following comments and concerns:

  • The term “applicable water quality standards (WQS)” is used throughout the proposed regulations, however, lacks a definition.
  • The term “uncontaminated” has inconsistent definitions.
  • The language on pages 24 and 25 regarding multiple sectors being covered under a single permit may cause confusion, please clarify.
  • A pre-application review would provide greater certainty to the applicant.
  • Section 11.H.4.1.3 Maintain Natural Buffer Areas is redundant to the current Alaska Surface Coal Mine Control and Reclamation Act managed by the Alaska Department of Natural Resources, the habitat permit managed by the Alaska Department of Fish and Game, and the U.S. Corps of Engineers 404 permit program for controlling waters of the United State. If streamlining the MSGP is DEC’s goal, this section contradicts that.

Alaskans have a great interest in ensuring their waters are clean and safe. However, RDC is concerned that some of the new sections of the MSGP are too stringent, even beyond the guidelines of the U.S. Environmental Protection Agency.

As the guidance will have an impact on industries across the state, it is vital definitions and descriptions are consistent and accurate. As this routine permit is required for continued operations of projects and in keeping projects in compliance with regulations, RDC appreciates your efforts to streamline the process.

Thank you for the opportunity to comment.

Resource Development Council for Alaska, Inc.