Proposed Large Commercial Passenger Vessel Wastewater Discharge General Permit, Number 2013DB0004

May 23, 2014

Alaska Department of Environmental Conservation, Division of Water
Commercial Passenger Vessel Environmental Compliance Program
P.O. Box 111800
Juneau, AK 99811-1800

Re: Proposed Large Commercial Passenger Vessel Wastewater Discharge General Permit, Number 2013DB0004

To Whom It May Concern:

The Resource Development Council for Alaska, Inc. (RDC) is writing in support for timely approval of the Proposed Large Commercial Passenger Vessel Wastewater Discharge General Permit, Number 2013DB0004.

RDC is a statewide, non-profit, membership-funded organization founded in 1975. The RDC membership is comprised of individuals and companies from Alaska’s oil and gas, mining, timber, tourism, and fisheries industries, as well as Alaska Native corporations, local communities, organized labor, and industry support firms. RDC’s purpose is to link these diverse interests together 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 applauds the Alaska Department of Environmental Conservation (DEC) for its efforts to improve the large commercial passenger vessel wastewater discharge permit. The draft permit, based on science and technology, is a positive example for regulatory bodies to follow for resource and community development.

It is a policy of RDC to advocate for equitable environmental laws for cruise ships and to support reasonable mixing zones for all resource and community development, including the tourism industry. DEC’s new regulations require cruise ships that travel through Alaska’s inside passage to have better wastewater treatment systems than that of some coastal communities.

The draft permit recognizes that cruise ships visiting Alaska have some of the highest levels of treatment of wastewater. The draft permit, which is largely based upon the work of the science panel and the legislative statutory changes in 2013, authorizes mixing zones for cruise ships. The draft permit utilizes a process based upon science, best technology, and more closely aligns cruise ship permits with the process used for other dischargers.

Further, it is a policy of RDC to advocate for predictable, timely, and efficient state and federal permitting processes based on sound science and economic feasibility. RDC believes part of economic feasibility includes equitable and competitive regulations. Having reasonable regulations that are protective of the environment yet still allow businesses to operate is critical.

The tourism industry in Alaska has a direct visitor spending of more than $1.8 billion annually, excluding travel costs. Additionally, tourism is the second-largest private sector employer, and accounts for one in eight Alaskan jobs. The most recent available data indicates that the tourism industry generates over 39,000 direct and indirect jobs, 9% of Alaska employment, and $1.32 billion in combined labor income.

Of the 1.96 million visitors in 2013, about half arrived on a cruise ship. One in three Alaska visitors are repeat travelers to the state. Many of the independent travels returning to the state first visited Alaska via cruise ship. Dozens of Alaska communities and boroughs combined collected $78 million in sales and bed taxes, and docking fees in 2013 to the State of Alaska collected $101 million in visitor related revenues.

In addition to comments in this letter, RDC encourages DEC to address concerns made by Cruise Lines International Association, Alaska (CLIA Alaska) in a letter submitted May 23, 2014 regarding the draft permit. The scientific and technical concerns in CLIA Alaska’s letter offer recommendations for using reasonable methods and standards consistent with other permits, all while continuing to adequately protect the environment.

RDC also encourages DEC to review and consider removing provisions of the permit that place additional restrictions on cruise vessels with no added benefit to the environment.

Alaska’s environmental standards, across all resource sectors, are second to none. Ultimately, RDC is pleased this general permit offers a more-balanced approach and requirements that will keep Alaska’s waters clean and provide for a healthy business environment in which cruise ships can continue to bring visitors to Alaska.

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

Sincerely,
Resource Development Council for Alaska, Inc.