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February 12, 2016 Commissioner Mark Myers Re: LAS 27436 – Request for Information Dear Commissioner Myers: The Resource Development Council of Alaska, Inc. (RDC) is writing to provide information to the Alaska Department of Natural Resources (DNR) regarding RDC’s standing to pursue an appeal to the October instream flow reservation (IFR) decision to the Chuitna Citizens Coalition, LAS 27436 (Stream 2003). RDC is a statewide business association comprised of individuals and companies from Alaska’s mining, oil and gas, forest products, tourism and fisheries industries. RDC’s membership also 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’s membership consists of many companies in both the mining and mining support industry across the state, including Pac Rim Coal, LP (PRC). DNR has already determined PRC has standing, in a letter to PRC from DNR dated January 25, 2016. This alone is sufficient to establish standing for RDC in the Stream 2003 decision, showing the decision has potential to harm our member PRC. Further, other RDC members – including mining, oil and gas, and fishing – are directly affected by the DNR decision for Stream 2003. Our members depend on a reliable, predictable and reasonable permitting process. In our view, DNR is misreading its statutory and regulatory requirements and making it far too easy for a person or private entity to secure an IFR. The decision would likely result in unnecessary or unsupported IFRs granted around our member projects and facilities increasing uncertainty in the permitting process. This uncertainty sends a negative message to future investors, affecting the ability of RDC’s members to attract investment for new and existing projects in Alaska. We are very troubled that this decision empowers an opponent of resource development to enforce water rights below a proposed mine. Make no mistake, this precedent will be pursued at other projects, thereby negatively affecting RDC member operations by hampering or even halting the ability of proponents to secure water for project-related uses. Should additional information be needed to further demonstrate RDC’s stake in the Stream 2003 decision, or the negative impacts to RDC’s broad membership, please do not hesitate to contact me. Sincerely, Resource Development Council for Alaska, Inc |
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