Letter to Alaska’s Congressional Delegation
March 11, 2019 The Honorable Lisa Murkowski The Honorable Dan Sullivan The Honorable Don Young Alaska’s Congressional Delegation
Dear Senators Murkowski and Sullivan, and Congressman Young: The undersigned coalition of organizations, representing many of Alaska’s industry sectors write to share our collective view that the National Environmental Policy Act (NEPA) and Clean Water Act (CWA) must be applied to the Pebble Project in a manner consistent with other resource projects in Alaska. The U.S. Army Corps of Engineers (USACE) recently pub- lished the Draft Environmental Impact Statement (DEIS) for the Pebble Project. From the time it received the project ap- plication, the USACE has committed to conducting the re- aTPbL^PʯNTPY_WdLYO_]LY^[L]PY_WdL^[Z^^TMWPTYQ`WWNZX - pliance with NEPA and other applicable federal laws. This formal process began in December 2017 when the USACE re- ceived a CWA Section 404 permit application from the proj- PN_?SP@>,.0T^^`POL_TXPWTYPQZ]LʭYLW[P]XT_OPNT^TZY by 2020 and set interim timelines for the DEIS, a Final EIS, and a Record of Decision (ROD). Recently, some have called upon the USACE to extend the public comment period for the DEIS from 90 to 270 days, and we urge you to take this opportunity to defend and uphold the NEPA process.
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agency’s process would be inconsistent with these initia- tives, and would set a dangerous precedent for future re- source development project reviews in Alaska. Our organizations represent members that have long struggled with Alaska’s reputation as a state challenged by regulatory instability. Deviations from the permitting pro- cess, like the lengthy comment window extension requested for the Pebble Project, only serve to further that reputation. BP`]RPdZ`_ZSZWOʭ]XZY]PL^ZYLMWP]PR`WL_Z]dLN_TZY^ to help demonstrate that Alaska truly is open for business.
The Pebble Project is controversial, howev- er, controversy does not justify extraordinary treatment. The USACE’s mandate to facilitate LYZMUPN_TaP_]LY^[L]PY_LYOPʯNTPY_[]ZNP^^ despite the controversy is what Congress in- tended NEPA to facilitate. The establishment of a project schedule with clear timelines and responsibilities for all stakeholders at the start of the process should be applauded, not ques- tioned or criticized. Despite allegations that the DEIS would not be comprehensive enough, the USACE published a DEIS that is approximately 1,400 pages, excluding appendices, with an 80- page Executive Summary. The USACE recently noted that a 45-day comment window would be the norm for reviewing this amount of data when compared to other complex projects in Alaska, as seen in Table 1 (below). Because the agency recognized they would receive requests for additional time for public review and com- ment, it established a 90-day public comment window, double what is required. You have long championed for permitting and NEPA reviews that are objective and fol- low science and process. You’ve also advocated for permitting reform, citing the need to “im- prove the quality and timeliness of decisions,” speaking out against delay tactics that abuse NEPA, and encouraging regulators to improve [P]XT__TYRPʯNTPYNd?ST^T^PcLN_Wd_SPPʬZ]_ that is being undertaken by USACE in the Peb- ble Project permitting process and it should MP OPQPYOPO ,Yd PʬZ]_ _Z ^WZb OZbY _SP
CONGRATULATIONS, PETE!
Donlin Gold has been a proud sponsor of Iditarod winner Pete Kaiser over the past decade, and we look forward to supporting his future accomplishments on and off the trail.
www.donlingold.com
April 2019
The Alaska Miner
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