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mills consistent state of non-compliance as evidenced in our suit underscores 

 the immediate need to contain and cleanup the toxic waste in and about Ward 

 Cove To ignore the connection between toxic pollution and cancer, reproductive 

 disorders, and immune dysfunction, shirks our responsibility to both the present 

 and future generations of the residents of Ketchikan. 



KPC has routinely used the people of Ketchikan and their economic survival as a 

 shield from compliance with environmental laws. KPC consistently operates in a 

 manner that violates the Toxic Substances Control Act, the Resource Conservation 

 and Recovery Act, the Rivers and Harbors Act, the Clean Water Act, the Clean Air 

 Act, the Comprehensive Environmental Response/Compensation and Liability 

 Act, the Alaska Solid Waste Regulations, the Alaska General Safety Codes, and 

 the Alaska Water Quality Standards. 



As you know these laws were passed to protect public health, maintain healthy 

 fish populations, and allow diverse economic and recreational use of PUBLIC 

 waters. If you or I conducted our daily business as KPC has and does, we'd 

 probably be in a federal prison. 



In 1994 EPA finally issued a standard industry permit for the mill, to replace 

 the mill's administratively extended permit, now twelve years old. This new 

 Ward Cove permit would have required compliance with the minimal 

 requirements of State and Federal law. But KPC knew that they could not 

 comply with even the most minimal of standards. KPC has blocked the adoption 

 of the '94 permit for nearly two years; while it continues to discharge toxic 

 waste. In an attempt to preempt the Ward Cove permit, KPC has applied for a 

 new discharge permit to begin the pollution of the adjacent water body of 

 Tongass Narrows. 



KPC officials have stated their intention to eliminate the use of elemental 

 chlorine. We support this goal. But while eliminating the creation of highly toxic 

 organochlorines is a positive step towards the protection of public health, these 

 same process changes are expected to increase the concentration of other wastes 

 in the mill's effluent that rob oxygen from the water, further increasing the 

 toxicity of the mill!s discharge to aquatic life. 



Everyone agrees that KPC's antiquated facility is a dinosaur of the pulp industry. 

 But there is no agreement that even a major rebuilding of the mill would allow 

 the operation to meet State and Federal water quality standards. 



Instead of discussing a fifteen year extension of a contract that locks us into the 

 past, we should be designing and constructing a new, more efficient timber 

 based industry for Southeast Alaska, while using the $110 million Economic 

 Disaster Fund to establish a safety net to protect the mill workers and their 

 families until the new industry is operational. 



