108 



Ketchikan Pulp Company complies with Federal and State laws governing 

 environmental protection. Our operations aire fully regulated and covered by 

 approximately 75 different permits, plans, response procedures and mandatory reports. 

 A list of these is attached to my testimony as Attachment C, and a copy of each is 

 available here for committee review. These documents cover everything from logging 

 camp stormwater control, to air emissions permits for our boilers and pulp mill waste 

 water disposal permits. Some of these are permits to operate -- without a permit there 

 can be no production. Also available for the Committee to review are twelve studies 

 and workplans which are underway right now. These new programs are the measures 

 agreed to in an enforcement action taken by the EPA, and settled in 1995. Part of that 

 settlement was our plea to one felony and thirteen misdemeanor violations of the Clean 

 Water Act. The information contained in the plans and reports offered here today 

 details our environmental compliance results and is available for your review. 



The claims made by individuals and groups opposed to our continued operation 

 are based on our own reported information. Their claims attack our performance, vilify 

 our people, distort our record, and support their assault bv presenting our own data out 

 of the context in which it was originallv reported. Our data is interpreted by our 

 o pponents without regard for the strict scientific methods which are mandated bv 

 regulation. Conclusions are reached which are based on the subjective values of the 

 presenter instead of the objective measures which are established bv law. Data are 

 separated from regulatory reports, and rearranged without regard to the purpose for 

 which thev are collected . Information which is reported by KPC in the normal course 

 of environmentcil complijince is manipulated and distorted by those who wish to shut 



Page 20 



