Revised Bristol Bay Assessment


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    May 29, 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 Re: Revised Bristol Bay Assessment To Whom It May Concern: The Alaska Chamber is an organization dedicated to improving the business environment in Alaska. The Alaska Chamber represents hundreds businesses from Ketchikan to Barrow that share a common goal: to make Alaska a viable and competitive place to do business. The Alaska Chamber has previously submitted comments articulating its concerns with the Bristol Bay Watershed Assessment. Unfortunately, our concerns have not been satisfactorily addressed in the revised draft assessment. Alaska Chamber members, whether in retail, finance, transportation or natural resource extraction, support efficient, predictable regulatory and permitting processes. It is upon such a baseline that businesses evaluate the risk and cost of investing their dollars in any business endeavor. For this reason, the EPA’s assessment action and the potential to initiate a 404(c) veto process on a project that has not initiated permitting in the Bristol Bay is extremely disconcerting since it vacates known regulatory and permitting processes. Despite comments received from the public, State regulators, peer reviewers, and engineers, who explained the dangers of using a hypothetical mine scenario that employs outdated techniques, the revised assessment continues to make assumptions using archaic technology. Using these techniques in the assessment is more than irresponsible given the fact that such techniques would not pass State of Alaska or federal regulatory muster. The fact that the EPA has stated that this assessment will inform agency decision making sends a very clear and chilling message to the business community through Alaska and the entire U.S.. By simply indicating that

471 W. 36th Ave., Suite 201, Anchorage, AK 99503 Ÿ (907) 278-2722 Ÿ alaskachamber.com

  it can or may issue preemptive actions on 404 permits prior to a project permitting process the EPA introduces uncertainty into the business development process. Such unpredictability drives business investment dollars overseas and fails to help the U.S. economy recover. While the Alaska Chamber would like the agency to abandon this premature assessment altogether, we request that the comment period be extended from a mere 30 days to a full 120 days to afford us and the public additional time to comment. Sincerely,

Rachael Petro President/CEO      

471 W. 36th Ave., Suite 201, Anchorage, AK 99503 Ÿ (907) 278-2722 Ÿ alaskachamber.com