Saturday, April 13, 2019

Public Comment on the Pebble Mine Project Draft EIS

The Pebble Mine project area is within the Lake and Peninsula Borough (LPB) to the east of the Aleutians East Borough (AEB). The mine site is within the Koktuli River and Upper Talarik Creek (UTC) watersheds. The Koktuli watershed is approximately 83 miles upstream of the Nushagak river and 109 miles upstream of Bristol Bay. The UTC watershed is approximately 39 miles upstream from the Kvichak river, and 89 miles upstream of Bristol Bay. Both Nushagak and Kvichak support some of the largest and most important salmon stocks in the Bristol Bay.  

The U. S. Army Corps of Engineers (USACE) is soliciting public comment on the draft Environmental Impact Statement (DEIS) for the Pebble Mine project, as required by the National Environmental Policy Act (NEPA). The public comment period is open March 1 through May 31, 2019.  There will be a public hearing in Anchorage, Tuesday April 16th from noon until 8pm at the Dena’ina Center.

The DEIS looks at the No Action Alternative and action alternatives for a functioning Pebble mine project that meet the purpose and need statement and are reasonable and practicable under Council on Environmental Quality (CEQ) standards. The EIS also analyzes environmental impacts of each alternative including direct, indirect and cumulative effects.                                

In general, the No Action Alternative would not contribute to any direct, indirect or cumulative effects on salmon or salmon habitat.

Concerns resulting from Action Alternative 1 potential impacts include but are not limited to the following:

Although the DEIS purports that most potential risks identified have a low probability of occurrence, the magnitude, extent and longevity of impacts would be disastrous.
The DEIS has a section regarding Spill Risk which identifies activities with risk that span beyond the localized project site – this non-exhaustive list includes diesel fuel, natural gas, copper-gold ore concentrate, chemical reagents, bulk and pyritic tailings, and untreated contact water. Although the section is comprehensive, many of the scenarios are theoretical – some scenarios have few existing studies to draw comparable assumptions from, many of the scenarios are circumstantial (severity would depend on timing, location, etc.), and do not explore secondary and tertiary impacts on affected ecosystems. The concerns for fishermen are addressed, but not given due consideration.

The USACE has invited 38 federally recognized tribes throughout the region to consult during the EIS decision process, including Port Heiden Village Council and the Chignik Tribal Councils.  No tribes within the AEB have been invited for consultation. Likewise, the LPB and the State of Alaska have been invited to participate as cooperating agencies, but the AEB has not been invited or directly consulted about the proposed project.
Direct, indirect and cumulative impacts of the project, and resulting mitigation measures are calculated in the DEIS for communities and activities near to the proposed project, not for neighboring communities or fishing activities in the AEB.

NEPA requires agencies to consider mitigation measures to avoid or reduce environmental impacts, or to compensate through mitigation, any unavoidable impacts. Mitigation can be achieved through project design and use of best management practices.
From DEIS Section 4.24.2.1- In terms of magnitude and extent of impacts, project construction, operations, and closure at the mine site would have a footprint of 8,806 acres (10.7 square miles), of which 3,458 acres are wetlands or other waters. Duration of impacts to these affected areas would be long term, lasting throughout the life of the project, and they would be certain to occur if the project is permitted and constructed.
From DEIS Section 4.6.6.2 - Pebble Mine Expanded Development Scenario - The Pebble Mine Expanded Development Scenario would result in an additional 78 years of mining/milling and include a larger open pit mine with expanded and new storage facilities for tailings and waste rock.
From DEIS Section 4.24.6 - Reasonably foreseeable future actions (RFFAs) combined with natural events, have the potential to contribute to adverse effects on aquatic resources by altering flow regimes and drainage patterns; direct habitat loss; diminishing water quality from riverbank erosion, turbidity, and sedimentation; changes in water chemistry; fish displacement and injury; and degrading the extent of productive habitat conditions.

The proposed Pebble project may offer opportunities like temporary employment to local residents. However, salmon is the cultural and economic foundation for all of our communities, and all Southwest Alaska fishermen harvest salmon that are bound for Bristol Bay. Any of the potential negative impacts to salmon runs would directly affect These fishermen. Since there is no discernable direct benefit to most fishermen from the development of the proposed mine, but potential for significant risk due to myriad of possible failures associated with the project, it could be said that the fishermen have nothing to gain but everything to lose from any of the alternatives except the No Action Alternative.

The No Action Alternative is the least environmentally damaging alternative. While the project has the potential to fulfill the stated purpose and need to develop a non-renewable resource, it could come at the expense of one of Alaska’s most valuable renewable resources, sockeye salmon from Bristol Bay. Bristol Bay sockeye returns are of utmost importance to the fishermen and communities of Southwest Alaska. The proposed project has the potential to adversely impact wetlands and to seriously degrade parts of the Bristol Bay watershed where the salmon are reared.  Salmon are already being stressed from the effects of climate change and changing ocean conditions, including overall rising ocean temperatures and ocean acidification. Any threat to the renewable Bristol Bay sockeye resource is an unacceptable risk. The Pebble project is an avoidable risk. The No Action Alternative is the option in the public’s best interest.




Thursday, December 27, 2018

AEB Winter Fisheries Teleconference Recap


Will the winter fisheries open January 1st as scheduled despite the US Government partial shutdown?   The good news is yes.

NOAA Fisheries Office of law Enforcement (OLE) Special Agent Brent Pristas was the only federal participant during the AEB Winter Fisheries teleconference December 27th.   As an 'essential personnel' Brent Pristas was able give fishery updates and other reminders from the federal agencies to the fishermen listening in.
 
The ‘A’ season Pacific cod total allowable catch (TAC) as relayed in a memo by NMFS Sustainable Fisheries Division:

  •  ‘A’ season pot cod TAC 1031 mt. Season will open Jan 1, and a reminder that the 2018 season is still open for those who wish to get an early start.
  •  ‘A’ season catcher vessel hook & line cod TAC set at 36 mt.  Will not open for the ‘A’ season.
  •  ‘A’ season jig cod TAC is 80 mt. Will open January 1.
  •  ‘A’ season trawl cod TAC set at 1443 mt.  Will not open unless fishermen have a co-op plan in place, to keep from exceeding the TAC.
  •  The crab sideboarded pot cod is 320 mt.  Will open January 1.

The 2019 area 610 pollock season TACs as relayed in a memo by NMFS Sustainable Fisheries Division:

  • Area 610 ‘A’ season TAC 848 mt.  Will not open unless fishermen have a co-op plan in place, to keep from exceeding the TAC.
  • Area 610 ‘B’ season TAC 848 mt.  Will not open unless fishermen have a co-op plan in place, to keep from exceeding the TAC.

Sustainable Fisheries Division and OLE reminds fishermen to please record the correct Statistical area fished in for fish ticket data, especially regarding State or Federal area fished in.
Adak fisheries open and close on Alaska time-zone (AKST), not ‘Adak’ time.

OLE recommends fishermen check vessel VMS; you can call OLE to confirm transmission. 

Reminder to call-in to the ODDs system to check if you need to carry an observer.  Luke Symanski of AIS stated the call center number and hours: 1-855-747-6377, 6am to 10pm AKST, Sand Point residents may need to use an alternate number: 1-206-673-3338. Also reminder to check that your safety decal is up-to-date.

Natura Richardson with ADFG reminded fishermen that the State-waters cod fishery opening date is 7 days after the federal Western Gulf pot cod season closes or March 7th, whichever is later.  State-waters   Jig gear season opens March 15, assuming the parallel ‘A’ season jig TAC is not yet caught.

South Alaska Peninsula 2019 State-Waters Pacific Cod Guideline Harvest Levels: Pot gear GHL 4,291,067 lbs., Jig gear GHL 757,247 lbs.  down about 5.6% from last year. Expected to be a fast season like last year.  Only regulatory change is the removal of the weather delay rule for jig gear. The weather delay rule is still in place for pot gear.

Lara Erickson with the International Pacific Halibut Commission reminded fisherman that the annual IPHC meeting is Jan 28th – Feb 1st.  Regulatory proposals announced Jan 31st, fishing limits announced Feb 1st.

Fisherman Kiley Thompson asked Brent Pristas if there was any concerns from OLE about the flatfish fishery that Sand Point small boat fishermen have been trying out.  Brent noted concerns about bycatch overages in the fishery, especially black cod, but also pollock overages and maybe skate bycatch overages. Kiley suggested a meeting between the fishermen and OLE prior to the season opening Jan 20th to go over some of the concerns for this developing fishery. Brent agreed that was a good idea.

Nathaniel Nichols reminded fishermen to call the ADFG office in Kodiak with any questions about the state season. They are happy to help get registrations and buoy tags sent out.

This teleconference was available at the following sites:
·         King Cove Harbor House
·         Sand Point Borough office
·         False Pass City Office
·         Anchorage AEB office

The meeting was broadcast live on local radio KSDP and the audio is now archived at https://apradio.org/mp3-aleutians-east-borough-winter-fisheries-teleconference/

Friday, July 13, 2018

Another emergency petition aimed at South Peninsula fishermen - this time from CRAA

The Alaska Board of Fisheries meets at the Egan Center July 17th to decide six emergency petitions.  Three of these petitions propose to shut down the South Alaska Peninsula salmon fisheries. You can read all of the petitions including from the BBNA, the Chignik AC and the Chignik Regional Aquaculture Association that would close down the Area M South Peninsula fisheries, at this link.
You can submit comments at the Board of Fish website by clicking the 'Comment on Emergency petitions' button and writing your comment to the Board. The deadline to submit comments for the emergency petitions meeting has been extended until July 16th. There will be no opportunity for public comment at the July 17th meeting. You can find the fifth revised meeting notice here.


There is a regular Board meeting scheduled in February to discuss Chignik and South Peninsula salmon fisheries. The Board should deny the BBNA and Chignik petitions and address the concerns at the upcoming February 2019 Board meeting.

Saturday, July 7, 2018

Comment period on five emergency petitions to the Board of Fish extended until July 16th

The Alaska Board of Fisheries meets at the Egan Center July 17th to decide five emergency petitions. Two of these petitions propose to shut down the South Alaska Peninsula salmon fisheries. The deadline to submit comments for the emergency petitions meeting has been extended until July 16th. There will be no opportunity for public comment at the July 17th meeting. You can find the fourth revised meeting notice here.
You can read the petitions by BBNA and the Chignik AC that would close down the Area M South Peninsula fisheries at this link.
You can submit comments at the Board of Fish website by clicking the 'Comment on Emergency petitions' button and writing your comment to the Board by the extended deadline of July 16th.
There is a regular Board meeting scheduled in February to discuss Chignik and South Peninsula salmon fisheries. The Board should deny the BBNA and Chignik petitions and wait to discuss the concerns at the upcoming February meeting.

Thursday, June 21, 2018

Aleutians East Borough Letter to ADFG Commissioner Cotten 06/20/18


On June 18, 2018 ADFG Sand Point released Commercial Salmon Fishery Announcement #5 an Emergency Order that slashed 48 hours from the 88 hour openings beginning June 20th for seine and drift fishermen and June 22th for set net. Although there was no explanation accompanying the original announcement, it became clear the fishery managers were taking the action as an emergency measure to help the failing Chignik first run of Sockeye salmon. Commissioner Sam Cotten  held a teleconference on the 19th to answer stakeholder questions, and on June 21st ADFG released the Emergency Order including justification for the action. On June 20th Mayor Alvin D. Osterback considered AEB options. The letter that follows is the AEB's initial response to the Emergency Order.

June 20, 2018

Commissioner Sam Cotten
Alaska Department of Fish and Game
333 Raspberry Road
Anchorage, AK 99518

Commissioner Cotten,

The recent emergency management action taken by ADFG to restrict fishing on the South Peninsula was designed to address a failing first Chignik sockeye run. However, data from the WASSIP study suggests that very few Chignik fish will be conserved by restrictions proposed in some areas.

The table below shows numbers of Chignik fish harvested in each of four South Peninsula areas in the last third of June (Appendix D1-D3)[1] and the Chignik run size, for 2006, 2007, and 2008 (Tables 3-5)[2]. The figures are derived by multiplying estimated harvest numbers for each district in the last part of June, by the mean Chignik stock proportion in that fishery period for that year. If one divides that Chignik harvest number by the Chignik run size, the result is a harvest rate estimate for that fishery location and period on Chignik fish. In Shumagin, Unimak, and Ikatan, the harvest rate on Chignik fish is 1% or less for June 20-30. This means that for a Chignik run of 100,000, roughly 1,000 might be saved if no fishing occurred in these areas. In Unimak and Ikatan, the harvest rate is more like 0.5%, saving less than 500 fish.

(numbers in thousands)
2006
Chignik Harvest Rate
2007
Chignik Harvest Rate
2008
Chignik Harvest Rate
Chignik Run size
2,300

1,650

1,500

Shumagin catch of Chignik sockeye
18.1
0.008
14.3
0.009
17.0
0.011
Dolgoi catch of Chignik sockeye
88.1
0.04
8.8
0.005
6.77
0.005
Ikatan catch of Chignik sockeye
4.0
0.002
0.85
0.001
3.84
0.003
Unimak catch of Chignik sockeye
-
-
0.79
0.000
4.9
0.003

We suggest that the department adopt a more targeted and meaningful strategy that still provides some positive impact on the Chignik run, by restricting the Dolgoi area only. We know from the WASSIP study that a higher proportion of Chignik fish is harvested here. Clearly, actions in Unimak and Ikatan, will provide little impact on the troubled Chignik run. This would help alleviate substantial negative impacts on coastal communities of the South Peninsula. 

Sincerely,

Alvin D. Osterback, Mayor


[1] Stock Composition of Sockeye Salmon Harvests (WASSIP), 2006-2008.  ADFG Special Publication No. 12-22
[2] Harvest and Harvest Rates of Sockeye Salmon Stocks (WASSIP), 2006-2008.  ADFG Special Publication No. 12-24