Comment letter on APDES Draft Permit for Furie Operating Alaska LLC, KLU Julius R. Platform

December 28, 2020

Re: APDES Draft Permit AK0053686 for Furie Operating Alaska LLC, KLU Julius R. Platform

To Whom It May Concern: 

The Resource Development Council for Alaska, Inc. (RDC) is writing to urge approval of the Department of Environmental Conservation (DEC) proposed Alaska Pollutant Discharge Elimination System (APDES) Draft Permit AK0053686.

RDC is a statewide trade association comprised of individuals and companies from Alaska’s fishing, forestry, mining, oil and gas, and tourism 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. 

RDC supports DEC’s approval of the APDES permit to Furie Operating Alaska LLC (Furie). The permit authorizes and sets appropriate conditions on the discharge of pollutants from this facility to waters of the United States. The permit ensures protection of water quality and human health, places limits on the types and amounts of pollutants that can be discharged from the facility and outlines best management practices to which the facility must adhere. 

As stated in the APDES permit, the authorized discharge of treated wastewater into Cook Inlet will result from a net positive water balance thus necessitating the need to discharge excess water. Further, Furie will monitor the treated water, and reports will be reviewed by DEC and available to the public.

With regard to the Furie project, the potential benefits of future production are significant, and they will continue to strive to provide affordable and sustainable energy to Alaska utilities. The optimization of the Furie assets and securing this wastewater discharge permit will help ensure that a diverse market basket of gas supplies is available, as well as the future opportunity to tap into new and expandable gas reserves in Kitchen Lights, a natural gas production unit.

If developed, RDC believes the project will be done in a way that creates opportunity for local employment and economic growth, while protecting the subsistence resources and culture of the region, and the environment. 

In conclusion, RDC urges the DEC to approve this APDES permit in a timely manner. As our state faces a fiscal crisis, it is also imperative projects be allowed to go through Alaska’s well-vetted permitting process without unnecessary delay and show investors that Alaska is “open for business.”

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

Sincerely,
RDC