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  • AOGA - Chuitna Water Reservation Appeals

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    5 of 10 Appeal letters filed Oct. 26, 2015 in protest of the Oct. 6 decision (see in AKSteve's documents) to grant Chuitna Citizens Coalition a water reservation for the Lower Reach of the Middle Fork

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    5 of 10 Appeal letters filed Oct. 26, 2015 in protest of the Oct. 6 decision (see in AKSteve's documents) to grant Chuitna Citizens Coalition a water reservation for the Lower Reach of the Middle Fork

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    © All Rights Reserved
    Download as PDF or read online from Scribd
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    Download as pdf
    745 views5 pages

    AOGA - Chuitna Water Reservation Appeals

    Uploaded by

    Steve
    5 of 10 Appeal letters filed Oct. 26, 2015 in protest of the Oct. 6 decision (see in AKSteve's documents) to grant Chuitna Citizens Coalition a water reservation for the Lower Reach of the Middle Fork

    Copyright:

    © All Rights Reserved
    Download as PDF or read online from Scribd
    Flag for inappropriate content
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    of 5
    Alaska Oil and Gas Association 121 W. Firewoed Lane, Suite 207 ‘Anchorage, Alaska 99503-2035 Phone: (007) 272-1481 Fax: (907) 270-6114 mal: kindred@acga.org Joshua M. Kindred, Environmental Counsel October 26, 2015 DEPARTMENT OF NATURAL RESOURCES OCT 2 6 2015 ‘Alaska Department of Natural Resources COMMISSIONERS OFFICE 550 W7® Ave, Suite 1400 ‘ANCHORAGE ‘Anchorage, AK 99501 Via email to das-appeals@ilaska.gov. Re: Appeal of DNR Water Resources Section decision to grant Reservation of Water {for Stream 2003/Middle Creek — Lower Reach (LAS 27436) Dear Commissioner Myers: ‘The Alaska Oil and Gas Association (AOGA) writes to appeal the October 7, 2015 decision by the State of Alaska Department of Natural Resources (DNR), Water Resources Section, which granted a reservation of water for Stream 2003/Middle Creek - Lower Reach (LAS 27436), This letter does not constitute an appeal of the decisions that denied the applications for reservations at the Middle and Main Reach (LAS 27437 and LAS 27340, respectively) AGA is a professional trade association whose members account for the majority of oil ‘and gas exploration, development, production, transportation, and refining activities ‘onshore and offshore in Alaska. AOGA greatly appreciates the DNR’ effors to fairly and prudently adjudicate In-Flow Reservation (“reservation”) applications. AOGA. believes that the state of Alaska, rather than outside interest groups, i inthe best position to properly manage our environmental resources. More importantly, AOGA believes abandoning that responsibility and duty is in violation of Alaskans best interest. It will also surely encourage more ofthis type of “gamesmanship” in the future, which will further erode state sovereignty ata time where Alaska already struggles to contol its own, Page 2 AOGA Appeal of DNR Water Resources Section Decision (LAS 27436) October 26,2015 destiny. In that vein, AOGA appeals DNR’s decision granting a reservation at the Lower Reach of Middle Creek. Failure to remedy that decision will only serve to undermine faith inthe process and discourage future investment.! Ultimately, AOGA’s appeal is predicated on the following arguments: (1) the decision represents an impermissible delegation of regulatory authority; (2) the original application fails to meet the threshold requirement; (3) the decision will serve as precedent for outside terest groups to corrupt Alaska’s regulatory process; and (4) the decision will discourage investment in current and prospective projects. 1. DNR Cannot Abandon Regulatory Supremacy ‘There will always be a friction between those who want to shield the entirety of Alaska. from natural resource development and those who want to consider development scenarios. throughout Alaska. It is that fundamental conflict that serves to properly define the scope: of what is at stake given DNR’s decision in this matter. Iti the DNR’s responsibilty to fairly and objectively balance competing interests in making decisions that meet the best interests of Alaskans. Invariably, when faithful to this process, the DNR’s decision will represent a fitting and appropriate compromise between competing philosophies. Thus, AOGA finds it unsettling that the DNR would consider compromising this process by allowing one adversary to effectively serve asthe ultimate arbiter. Anecdotally, the DNR’s decision to grant authority to Chuitna Citizens Coalition (CCC) is tantamount toa criminal Judge allowing a criminal defendant or victim to determine what sentence and sanction is appropriate. The conflict of interest is overt and overwhelming. Hyperbole aside, DNR’s

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