Resource Development Council for Alaska, Inc. • Marleanna Hall • August 21, 2015
Testimony before: Department of Natural Resources Water Resources Section Chief David Schade, and members of the Water Resources team

My name is Marleanna Hall, I am the executive director for the Resource Development Council for Alaska, Inc. Thank you for the opportunity to comment in April and again today.

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.

• It is a policy of RDC to encourage state and federal agencies to allow projects to go through the permitting process. It is also a belief that one resource is not more important than another, and that we can have both.
• Oppose approval of the In-stream Flow Reservation (IFR) applications filed by the Chuitna Citizens Coalition (CCC) currently before the Department of Natural Resources (DNR).
• One of our primary concerns is that approval of the IFRs would undermine existing regulatory processes and set a dangerous precedent for community and resource development projects across Alaska. Investment in Alaska should not be jeopardized by pre-emptive actions to stop responsible development.
• DNR should consider all uses of water in the IFR application process. Granting, or even evaluating, an IFR without considering competing water right applications is not in the public interest. Without evaluating both, DNR cannot truly weigh and balance the economic and public interest of the competing applications, nor mitigation measures.
• The reservation adjudications are premature. The project has not yet been finalized and updated detailed plans and environmental mitigation strategies are still being submitted to government agencies. As a result, the current IFR would pre-emptively deprive government agencies and stakeholders of the specific information, science, and rigorous reviews that would come out of the multi-year process.
• RDC is concerned the actions proposed by CCC to issue the IFRs will hamper predictability, and chill investment in Alaska. We are also concerned potential approval of the IFRs will lead to permitting confusion, and remove integrity from the process.
• Every project, no matter the size or location, should have an opportunity to go through the existing, extensive permitting processes. In the case of mining, there are more than 60 major permits and many more from local, state, and federal agencies that must be successfully obtained. The process will determine the best use of water and will address and consider mitigation, such as re-routing water away from project areas until reclamation can be done. The process will not permit one industry or resource to advance at the expense of another.
• We believe exploration, project design and permitting SHOULD take years, even multiple years, tens of years, to help ensure the proposal is complete and the permit is accurate and complete. Proper studies should and do take years.
• As described by earlier testimony, the proposed PacRim Coal LP project is on Alaska Mental Health Trust Authority lands. The Trust acquired these lands specifically for the development of the coal and the royalties it will provide to the Trust. The Trust has a mandate to maximize revenues from the one million acres of land it was granted throughout the state. Furthermore, the State of Alaska depends on the responsible development of natural resources on its lands to diversify and support its economy (Article VIII of the Alaska Constitution).
• The proposed mine is expected to provide significant economic benefits to Alaskans, including an estimated construction cost at $750 million and employ up to 500 workers over the two year construction phase. After construction, the mine is expected to employ 350 people with an average annual payroll of $35 million, pay an estimated $300 million in royalties to the Alaska Mental Health Trust over the life of the mine, and pay millions in taxes to the State and the Kenai Peninsula Borough.
• These projections are not promises, but potential opportunities. Many regions in Alaska could benefit from projects like this, where few other economic opportunities exist.
• We believe this action by the CCC is being taken solely to stop a project. We urge DNR to reject the applications, which could potentially undermine the permitting process and set a dangerous precedent.
• I am not here today to agree that this or any project for that matter should move forward based on what we know. We don’t have sufficient information to make that decision, but allowing projects to continue to develop plans will help us and other Alaskans to make those decisions. We are all for the process, please don’t undermine it by approving these IFRs.
• RDC believes the approval of these IFRs will severely damage the project. We are concerned other agencies will stop advancing the permitting process. Once issued, it is more difficult to reduce, or remove, a right.

I urge you to not privatize this property right, and instead uphold that water reservations should be held by state agencies. Thank you for the opportunity to comment today. I am open to questions.