July 29, 2014
Mr. Dennis McLerran
Regional Administrator
U.S. Environmental Protection Agency, Region 10
1200 Sixth Avenue, Suite 900
Seattle, WA 98101
Via email to ow-docket@epa.gov
Re: Extension request for EPA Docket EPA-R10-OW-2014-0505, Proposed Determination of the U.S. EPA Region 10 Pursuant to Section 404(c) of the Clean Water Act
Dear Mr. McLerran:
The Resource Development Council for Alaska, Inc. (RDC) is writing to request an extension of the public comment period by 60 days for the U.S. Environmental Protection Agency’s (EPA) Proposed Determination of the U.S EPA Region 10 Pursuant to Section 404(c) of the Clean Water Act (CWA).
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.
RDC believes the comment period ending September 19, 2014 should be extended to adequately allow for public review of the document. The current comment period is insufficient and should be extended at least 60 days to allow commenters ample time to provide feedback.
Additionally, RDC requests the public meeting times, currently scheduled for August 12-15, 2014, also be delayed. RDC believes stakeholders, especially in Alaska, will benefit from a delayed public meeting schedule.
Further, the proposed determination has been developed under a preemptive effort that undermines the existing permitting process, such as the National Environmental Policy Act (NEPA). The Pebble Limited Partnership has filed suit in U.S. District Court for Alaska seeking an injunction to stop the EPA’s process to preemptively veto the Pebble Project under Section 404(c) of the CWA.
The State of Alaska has also intervened in the suit. RDC urges the EPA to halt further actions, until the court makes a decision, and until a permit is applied for.
Lastly, RDC is concerned about what could be one of the most significant, precedent setting actions ever undertaken by the agency, and as such, a rushed comment period is unacceptable. The EPA should allow for a thorough, well-vetted discussion about this project, such as would be allowed under NEPA.
Thank you in advance for your timely consideration for an extension of this comment period and public meetings. An extension will greatly enhance the public’s ability to respond with meaningful and substantive comments. RDC intends to submit formal comments on the proposed determination before the comment deadline.
Sincerely,
Resource Development Council for Alaska, Inc.
