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 18.104.22.168- 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 22.214.171.124 - 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.