We have reached another important phase in the ongoing effort to protect Bristol Bay, Alaska—home of one of the world’s most prolific wild salmon and trout fisheries. Your support thus far is appreciated, and it has been effective. So many of you have been helpful in spreading the word on the comment period and weighing with multiple requests over the past few months. Please read the attached letter below and consider signing on. If you’d like to add your name/org/logo please let Nellie Williams know by June 28th at 2pm AK/6pm EST. If you are doing your own separate comments, that is also welcomed and you can grab information from this letter if it’s helpful. Please send signed letters to Nelli Williams (Nelli.Williams@tu.org).
Also, if you have a moment, please review this video. It is a great social media tool, so please feel free to share it. https://www.facebook.com/SaveBristolBay/videos/10156420937484450/
June 29, 2018
U.S. Army Corps of Engineers, Alaska District
Program Manager, Regulatory Division
ATTN: DA Permit Application POA-2017-271, Pebble Limited Partnership
P.O. Box 6898
Joint Base Elmendorf Richardson, AK 99506-0898
RE: Comments on the Proposed Pebble Mine in the Bristol Bay Region of Southwest Alaska (DA Permit Application POA-2017-271).
Dear Mr. Shane McCoy,
On behalf of the undersigned businesses and organizations, which employ hundreds of individuals in Alaska’s Bristol Bay region and represent thousands of sportsmen and sportswomen, please accept these comments on the Pebble Limited Partnership’s (PLP) application for the proposed Pebble Mine (DA Permit Application POA-2017-271). We have many serious concerns about the proposed project and its impacts. Furthermore, because the pending permit application is incomplete, we urge the Corps of Engineers to suspend its review of the permit application until additional plans, specification, and background data are available to provide a comprehensive and thorough review of the proposed project and its potential impacts.
Bristol Bay fish and wildlife, and its salmon in particular, are the centerpiece of the region’s economy, culture and its communities. All five species of North American Pacific salmon return to the rivers, streams and lakes that feed Bristol Bay, with nearly 60 million salmon returning in 2017 alone. These huge annual salmon returns contribute to the entire region’s productivity and biodiversity, and are the result of the region’s high-quality and diverse aquatic habitats, the hydrologic and chemical connectivity between surface and subsurface waters, and the relatively low levels of human development.
Bristol Bay is the world’s most valuable wild-salmon fishery, generating $1.5 billion in annual economic output, more than 30% of all Alaska salmon harvests, and more than half of all private-sector jobs in the region. Hunters and anglers travel from throughout the globe to the Bristol Bay region for its trophy fish and game, its remote scenery, and its wild character. Native Alaskans have lived in the Bristol Bay region for thousands of years, relying on the bounty of the land and waters to sustain their traditional and customary way of life. Generations of families have fished commercially in the region. Numerous businesses, both large and small, have carved out niches capitalizing on Bristol Bay’s flourishing salmon populations.
The Bristol Bay region is the world’s premier wild-salmon fishery, and one of the last places left where an entire region from the headwaters down to the bay remain intact and fully functioning. In addition to salmon, the Bristol Bay region also supports abundant populations of bear, caribou, moose, and various other important wildlife species. The Bristol Bay watershed, an area roughly the size of West Virginia, is nestled between two National Parks (Katmai and Lake Clark), and the nation’s largest state park. The area hosts three active volcanoes and Lake Iliamna, the 8th largest lake in the United States. The Bristol Bay region is a world-class resource, as the EPA observed in its Bristol Bay Watershed Assessment:
[Bristol Bay] sockeye salmon represent the most abundant and diverse populations of this species remaining in the United States. Bristol Bay’s Chinook salmon runs are frequently at or near the world’s largest, and the region also supports significant coho, chum, and pink salmon populations. Because no hatchery fish are raised or released in the watershed, Bristol Bay’s salmon populations are entirely wild. Bristol Bay is remarkable as one of the last places on Earth with such bountiful and sustainable harvests of wild salmon. One of the main factors leading to the success of this fishery is the fact that its aquatic habitats are untouched and pristine, unlike the waters that support many other fisheries.
Federal agencies and the public must have the opportunity to rigorously review PLP’s mine plan in its entirety to have a clear understanding of the nature and magnitude of the proposed activity’s potential impacts. In its permit application to the U.S. Army Corps of Engineers, PLP proposes a mile-wide and 1/3-mile-deep mine pit, an 83-mile-long transportation corridor with more than 200 road crossings over salmon streams and a year-round ice-breaking ferry across Lake Illiamna, and a 230-megawatt power plant with a 188-mile gas pipeline. The proposed project would fill more than 4,000 acres of wetlands and waters. While this permit application contemplates a 1.2 billion-ton mine with a 20-year mine life, we know this is not the entire mine plan since the deposit is close to 10.89 billion tons and PLP has made clear it intends to expand its operations far beyond what it proposes in its pending permit application. PLP’s own website advertises that it “believe[s]it’s possible that the Deposit may hold a century’s worth of minerals.” In addition, PLP’s President and CEO recently boasted the project is “a multi-generational opportunity. It’s size and scale will lead to a very, very long life mine.”
Concerns about future expansion of the mine are already coming to fruition while many important details about how the mine will operate remain unanswered. PLP’s recent “project update” proposed an increase in the mine size from 1.2 billion tons to 1.5 billion tons of material—with commensurate increases to the volume of tailings, the size of the mine pit, the size of the power plant, and to the amount of road and marine traffic. Additionally, both the original permit application and the “project update” glaringly omit any sort of economic feasibility report, thorough baseline data, and important details about how PLP will mitigate for its impacts or manage ground and surface waters. Without these essential details, there is no way for the public or for permitting agencies to adequately review PLP’s permit application and do the due diligence required to make an informed decision about the potential and likely impacts of the proposed Pebble mine. Because of this and the great public interest at stake, PLP’s application is incomplete and the Corps of Engineers must suspend its review of the proposed Pebble mine until additional essential information is available.
Although PLP’s permit application and supporting materials are inadequate for a thorough and complete review of the potential impacts of the proposed Pebble mine, they nonetheless raise serious concerns:
- The Corps must consider the potential impacts of developing the entire Pebble deposit and not segment review. Although PLP’s application appears to contemplate mining 1.2 billion tons of mineral, with the “project update” increasing that volume to 1.5 billion tons of material, based on the lack of financial information and PLP’s own statements we know the pending application is for phase one of what will become a much larger and longer-term project. Once the transportation network and power generation facilities are built, we must expect mining activities to expand to include the full deposit and neighboring claims. Based on this information, the Corps of Engineers must consider the full and cumulative impacts of an expanded mine and not segment environmental review.
- The proposed Pebble mine will have catastrophic impacts to important fish, wildlife and water resources. As the EPA’s Bristol Bay Watershed Assessment made clear, even if mining activities are limited to a small-mine scenario like what PLP is proposing in its pending application and everything goes according to plan without catastrophic accidents or mine facility failures, we must expect significant unacceptable adverse impacts to the region’s fisheries, wildlife populations and waters. The mine pit, tailings facilities, and associated infrastructure will destroy important waters and wetlands. The transportation corridor will fragment important fish and wildlife habitat; impair fish and wildlife migration; cause increased sedimentation, erosion and channelization of nearby streams; alter streamflow; and disturb nearby wildlife populations. Groundwater pumping will disrupt the water table, disrupt important natural ground-surface water exchanges, and dewater some surface water bodies while flooding other surface water bodies. The tailings facility will pose an ongoing threat and potentially require permanent maintenance, with the potential for catastrophic consequences if the facility fails.
- The lack of adequate baseline data makes it impossible to adequately evaluate the potential impacts. PLP’s proposal is unsupported by adequate baseline data or studies on the region’s fisheries, wildlife populations, hydrology, soils, geology, seismic activity, and air quality, among other resources. Without this information, it is impossible to understand or evaluate the potential impacts of the proposed Pebble mine.
- The proposed Pebble mine will spell economic disaster for Bristol Bay. Bristol Bay fisheries generate $1.5 billion in annual economic output, more than 30% of all Alaska salmon harvests, and more than half of all private-sector jobs in the region. The region provides world-class angling, hunting and wildlife viewing that attracts visitors from throughout the globe. This economic engine depends on the region’s healthy habitat, clean water, wild character, and the natural beauty and productivity of the region. If the Corps grants PLP a permit to construct the proposed Pebble mine, the ensuing impacts to Bristol Bay’s unique natural resources will cause commensurate impacts to the region’s economy. These impacts will compound over time and forever change the culture and economy of the region. Even if PLP’s most optimistic estimates and assumptions about the economic benefits of its project are true, which we cannot assume since PLP has provided no economic feasibility study to support its application, granting a permit to construct the proposed Pebble mine will result in an economic loss to the region.
- The proposed Pebble mine will forever alter the culture and communities of the Bristol Bay region. In addition to the irreplaceable Alaska Native culture that has existed in the Bristol Bay region for millennia, the region plays a unique role for early and modern-day Alaska outfitter, guide and sportsmen culture. Sportsmen and women from throughout the globe have been traveling to the Bristol Bay region to fish and hunt for generations, drawn by the region’s unique fishing and hunting opportunities, unspoiled landscapes and wild character. If PLP is allowed to construct and operate its proposed Pebble mine, it will forever alter the landscape and we risk losing the region’s important cultural resources.
Because PLP’s permit application is incomplete, the Corps must suspend its review until PLP resubmits a complete application. At a minimum, an updated application must include a current economic feasibility report, comprehensive and up-to-date environmental baseline data, a detailed water management plan and mitigation plan, and specifications for the tailings facility and other related infrastructure. Without these details, it is impossible for the public or the Corps to properly evaluate the potential impacts of the project or consider alternatives that may avoid or reduce impacts. Thank you for your consideration and for the opportunity to provide comments.
 See EPA, An Assessment of Potential Mining Impacts on Salmon Ecosystems of Bristol Bay Alaska EPA 910-R-14-001ES at ES-8 and ES-25 (Jan. 2014) hereinafter Bristol Bay Watershed Assessment.
 Id. at ES-8 (Jan. 2014).
 Id. at ES-1.
 See 33 C.F.R. §§ 235.1(d) and 235.3(a).
 Pebble Limited Partnership, Pebble Project Department of the Army Application for Permit POA-2017-217 at 4-7 (Dec 2017) [hereinafter Pebble Application].
 See Pebble Application at 28-30.
 See https://www.pebblepartnership.com/plan.html#section-operation (last visited June 12, 2018).
 Ron Thiessen, Presentation at the Denver Gold Forum (Sep. 2017), webcast available at http://www.denvergoldforum.org/DGF17/company-webcast/NDM:CN/.
 See Pebble Limited Partnership, Project Updates (May 10, 2018), available at https://pebbleprojecteis.com/files/05_11_2018_Pebble_Project_Updates_to_Proposed_Project.pdf.