Resource Development Council

RDC Comment Letter:
Usibelli Coal Mine Wishbone Hill Air Quality Control Permit

April 9, 2014

Mr. Aaron Simpson
Department of Environmental Conservation
State of Alaska
P.O. Box 111800
Juneau, AK 99811

Via email to

Re: Usibelli Coal Mine Wishbone Hill Air Quality Control Minor Permit AQ1227MSS04

Dear Mr. Simpson:

The Resource Development Council for Alaska, Inc. (RDC) is writing to support approval of the Wishbone Hill Air Quality Control Minor Permit AQ1227MSS04.

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.

It is a policy of RDC to support exploration and development of Alaska’s coal resources. The Wishbone Hill air permit is required to meet National Air Quality Standards, and the Usibelli Coal Mine, Inc. (UCM) has demonstrated compliance with the standards at the permit boundary.

As you are aware, the State of Alaska Department of Environmental Conservation (DEC) enforces stringent regulations overseeing mining activities statewide that effectively protect the environment, wildlife, and human health. The Wishbone Hill air permit application closely follows these regulations. Additionally, UCM holds an outstanding record for operating mines in Alaska, and even began instituting reclamation efforts before it was required by law to do so.

The Wishbone Hill project, located on State, Mental Health Trust, and private land five miles west of Sutton, has been permitted every five years since 1992. UCM plans to operate a coal processing facility, including a crusher and wash plant at the site. In addition to the wash plant, UCM will use a dust palliative on gravel mine roads as a dust inhibitor. Further, dust monitoring will ensure adherence to a fugitive dust control plan.

Wishbone Hill is a zero discharge mine, that has been explored since 1983. The project outlines an extensive reclamation plan, including the enhancement of wildlife and recreational habitat as post-mining priorities. These environmentally-sound practices, combined with the economic benefits the mine would provide, make for a win-win situation in the Matanuska-Susitna region.

Moreover, the permit applicant, Alaskan-owned Usibelli Coal Mine, Inc. has been mining coal since 1943 and has demonstrated a commitment to maintaining and improving the environment through its environmental protections and reclamation process. RDC believes that the aforementioned factors merit timely approval of the permit.

Thank you for the opportunity to comment on this important permit.

Resource Development Council for Alaska, Inc.