Testimony before the EPA • Iliamna, Alaska • October 12, 2017

EPA Notice to Withdraw Proposed Determination of Pebble Deposit Area

Good afternoon, my name is Marleanna Hall, I am the executive director for the Resource Development Council for Alaska, Inc. RDC is an Alaskan trade association with members in tourism, oil and gas, forestry, fishing, and mining, as well as the 12 regional Native corporations, labor, individuals, and others supporting the responsible development of Alaska’s natural resources.

I am here to offer support for the EPA’s proposal to withdraw its July 2014 Proposed Determination on the Pebble Deposit Area. The EPA’s proposal to withdraw the pre-emptive decision will allow the project to be fully evaluated after project plans are put forward. Further, RDC recognizes that withdrawal of the Proposed Determination does not remove the EPA from the process, it only rights a wrong – removal of the pre-emptive decision.

Every project, no matter its size or location, should be allowed to go through the permitting process. That process should ultimately determine whether a project should move forward.

My members firmly believe in due process and the rule of law. A number of trade associations and businesses from across all resources sectors in the state are on the record in opposition of the pre-emptive actions of the EPA. They communicated clearly that the action would send a chill across the investment climate in their industries. For example, the Alaska Oil and Gas Association has previously spoke up in support of allowing all projects to be vetted in the permitting process.

As Alaskans, we have the greatest stake in seeing that any and all development is done in a way that protects resources, including fish and wildlife, whether it is for commercial or subsistence use. I believe it can be done, because it’s already being done.

RDC urges the EPA to work quickly to withdraw the deeply flawed, speculative Proposed Determination. Thank you for the opportunity to comment, I will submit additional detailed comments before the deadline.