AFFTA’s Watershed Comments on Pebble Mine



June 19, 2013

The Honorable Robert Perciasepe
Acting Administrator
US Environmental Protection Agency
Ariel Rios Building
1200 Pennsylvania Ave., N.W
Mail Code 1101A
Washington, DC 20460

RE: #EPA-HQ-ORD-2013-0189 (Bristol Bay Watershed Assessment)

Dear Administrator Perciasepe:

On behalf of the manufacturers, retailers, lodges, outfitters, media, and travel businesses in the fly fishing industry, I’m writing you to express our deep concerns regarding the potential mining activity in the Bristol Bay eco-system. Our association and it’s members, are aware of and understand the extraction of natural resources is a vital economic force for which the state of Alaska and the United States economy depend upon, but the Bristol Bay region and it’s eco-system should not be put at risk from any mining activity, ever.

We thank the EPA for the diligent work, transparent process and extensive scientific review in evaluating the potentially destructive impacts of large-scale mining in the Bristol Bay, Alaska region through its Bristol Bay Watershed Assessment.

The report’s findings have made it extremely clear, that we as an intelligent society and temporary custodians of the Bristol Bay eco-system cannot wait any longer to provide protections from the unavoidable consequences of mining on a scale that is being discussed in the region.  Bristol Bay’s extremely healthy sockeye salmon fishery supports over 14,000 jobs across multiple industry segments and generates more than $1 billion in annual revenues. Bristol Bay alone accounts for nearly half of the global annual supply of sustainable sockeye salmon. The EPA’s Assessment has found that up to 90 miles of salmon streams and up to 4,300 acres of vital salmon habitat will be destroyed if the Pebble deposit is mined regardless of a major spill or catastrophic failure of preventative measures designed to contain such a devastating event.  Essentially, even in a best-case scenario there will be significant adverse impacts to Bristol Bay’s waters, salmon, and the economy, which is dependent upon them.

The risks associated with mining in the region may provide a short-term economic gain for some, but the long-term consequences of putting such a valuable global eco-system at risk is what we must be concerned about now and for future generations.

The historical use of Section 404c of the Clean Water Act to restrict inappropriate developments is a tool that hasn’t been utilized often, but we respectfully urge you to take such action now while continuing to allow reasonable development to proceed in the Bristol Bay region that doesn’t put the eco-system at risk.  If ever a place deserved use of Section 404c, we cannot think of one more appropriate than in Bristol Bay.

Again, thank you for your work on this important issue, and for your consideration of our comments as you move forward in your efforts.


Benjamin Bulis
AFFTA President


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