Support for State Primacy of RCRA and 404 Authority to the House Finance Committee

March 21, 2022

Submitted electronically to: [email protected]

Co-Chair Foster and Co-Chair Merrick
State of Alaska Legislature
House Finance Committee

Re: Support for State Primacy of RCRA and 404 Authority

Dear House Finance Co-Chairs Rep. Foster and Rep. Merrick:

The Resource Development Council for Alaska, Inc. (RDC) writes in support of taking all necessary steps to give effect to the statutory authority for the State of Alaska, including funding authorization, to implement primacy of the federal Resource Conversation and Recovery Act (RCRA), which regulates the management of solid and hazardous waste, and Section 404 of the federal Clean Water Act (CWA), which regulates the discharge of dredged or fill materials into waters and wetlands.

RDC is a statewide trade association comprised of individuals and companies from Alaska’s fishing, tourism, forestry, mining, and oil and gas 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 supports and encourages our elected officials to promote an effective, efficient and rigorous permitting and regulatory process. A stable permitting process promotes a robust private sector to build a diverse economy. Ensuring state control over important these important permitting decisions will lead to more timely and less costly permit issuance. We know this can be done without sacrificing our state’s high environmental standards that are already applied in current primacy programs, including the Clean Air Act, Safe Drinking Water Act and the CWA National Pollutant Discharge Elimination System (now the Alaska Pollutant Discharge Elimination System (APDES)). Supporting full implementation of state primacy over these additional programs will also ensure Alaska is well positioned to handle the projects we hope to see supported with funding from the federal Infrastructure, Investment and Jobs Act (IIJA).

At a time when uncertainty in federal environmental permitting is the only thing that seems certain, implementation of state primacy over RCRA and CWA sec. 404 permitting is more critical than ever. We encourage you to support the full implementation of primacy for these programs.

Thank you for your attention in this matter.