90 day public comment period for the proposed Pebble Mine is now open
In December 2017, Pebble submitted its first Clean Water Act 404 dredge and fill of wetlands permit application to the U.S. Army Corps of Engineers, which kick-started the federal permitting and environmental review process. Per this initial permit application, Pebble seeks to develop the first 1.4 billion tons of its nearly 11-billion-ton deposit, and set the stage for future expansion into nearby areas and ultimately the start of a mining district in Bristol Bay.
The mine under review in this DEIS is described as a scaled-down 20 year operational project with monitoring and water treatment in perpetuity, which underpins Pebble’s claims of minimal environmental impacts though the proposed project is massive. However, the company consistently and publicly tells their investors that this mine will grow beyond its current footprint and last generations. This bait and switch lurks behind all the rosy promises in the DEIS.
The Army Corps has released a Draft Environmental Impact Statement for the proposed Pebble mine and has opened a public comment on that document. The comment period is currently set to close on July 1 and will include a number of public hearings (details below).
This is a historically fast process that’s clearly designed to favor the Pebble Limited Partnership. The document presumes that mining is necessary in Bristol Bay, and does not fully evaluate the risks that will come with it. Further, the process is being rushed to accommodate Pebble’s timelines, rather than to maximize public participation. The EIS processes for other large-scale mines have typically taken at least five years; Pebble’s EIS is on-track to be completed in half that time.
The project, as proposed in Pebble’s Army Corps permit application, includes the following:
Plans to mine a pit over a mile in length, 1-mile-wide and 200 m deep;
Destroy over 3,500 acres of wetlands and more than 81 miles of salmon streams at the mine site located in the headwaters of Bristol Bay’s world-class salmon run
Construct a massive tailings storage facility, treatment ponds, and associated dams and embankments blocking and inundating salmon streams;
Construct a private two-lane 83-mile-long road with more than 200 stream crossings and 8 large bridges;
Develop an ice-breaker barge system across Lake Iliamna with two lakeside terminals in important salmon habitat;
Develop a private and large port facility on Cook Inlet near salmon streams and extending more than 4 miles into the inlet waters and known habitat for sea otters, beluga whales, humpback whales, and seals;
Build and operate a 270-megawatt power plant (with two additional 2mw plants at the port) approximately 15 miles upwind from Lake Clark National Park;
Lay a 188-mile-long natural gas pipeline over land and under Cook Inlet and Iliamna Lake;
At closure, backhaul the 1.1 billion tons of tailings waste into the pit, to be monitored and maintained in perpetuity.
Broadly, the DEIS document fails to consider future mine expansion, meaning it considers a fraction of the risk posed to Bristol Bay, and is riddled with pro-Pebble bias. For instance, when discussing social and economic impacts, the Army Corps focuses on the importance of copper to the global economy over the importance and economic contributions of wild salmon and thriving fisheries to Alaskans and visitors from across the globe. In the wake of a number of prominent catastrophic tailings dam failures in the last few years, the DEIS also fails to address the prospect of a catastrophic tailings dam failure at Pebble, which is a relevant and prominent danger associated with the type of project proposed in Bristol Bay.
The Full DEIS Document can be reviewed here.
COMMENT on the DEIS. Below are a few key issues in the DEIS, but we need you to tell the Army Corps that the only option that will protect Bristol Bay is the ‘No Action Alternative’, meaning that Pebble should not receive its Clean Water Act permit. Please ask for the flawed permitting process to be suspended.
EDUCATE your friends and family and hold them accountable to submit comments as well.
Attend one of the Alaska hearings and testify about the DEIS and the need for the U.S. Army Corps of Engineers to select the No Action Alternative; encourage your friends, staff, or membership to do the same.
Share your concerns about the DEIS with your elected representatives.
What this comment period entails:
Currently, the comment period is 90 days (through July 1) with 9 public hearings in Alaska. Though the U.S. Army Corps of Engineers will be the lead agency, it is equally important that members of Congress, the U.S. EPA, the President and, (if in Alaska) the Governor are aware of continued, broad opposition to the proposed Pebble mine.
Commenting on the Draft Environmental Impact Statement (DEIS) is the last formal opportunity for the public to tell the lead permitting agency to say no to the Pebble Mine - the environmental and socio-economic consequences and impacts of Pebble’s phase one proposal are too high and a “no action alternative” should be taken when it comes to Pebble’s application.
You can find additional talking points throughout the comment period on the Save Bristol Bay blog.
How to write a quality comment:
The Pebble Project Draft Environmental Impact Statement (DEIS) is over 1,400 pages long. The website Quality Comment has gathered facts and findings and put them all in one place, allowing you to easily gather information, write your comment, and effectively voice your credible concerns.
This site also provides resources for people who are new to the issue of Pebble Mine, as well as information on commenting and participating in the public process. Use it to submit an effective comment in as little as 10 minutes. Get started!
Why is it important to weigh in again?
The Army Corps of Engineers needs to hear from Americans about their concerns about Pebble’s proposed mine and that the egregiously fast-tracked process is unacceptable. It’s likely that this project will wind up in litigation, and we need to build a record showing the inadequacy of this document and opposition to the project.
We will also use this opportunity to contact elected officials in addition to the Army Corps, as they will also be important decision makers related to Pebble going forward.
Let us be clear, Bristol Bay is no place for Pebble Mine, no matter the size of the project. But Pebble is trying to sneak a permit through with the promise of a small mine. Due to risk to the fishery, we don’t support that mine, and we certainly do not support the size of mine that Pebble continues to sell to potential investors - one that seeks to mine over 10 billion tons of material. This larger mine is in no way accounted for in this DEIS. Therefore, at the size proposed here, or the size touted to investors, there is no way to evaluate the full risk of Pebble if they are not evaluating the complete project, thus making this document incomplete.
Here are a few other concerns that jump out at us that you could incorporate into your comments:
Water treatment: PLP estimates that its water treatment plants will need to treat tens of billions of gallons of wastewater per year, containing metals and other pollutants harmful to fish and public health. This is an unprecedented volume of wastewater to treat, and we know of no other operating U.S. mines that treat such a large volume.
Tailings Dam Failure Scenarios: The DEIS claims that "No population-level impacts would be expected for fish from either tailings release scenario.” (Executive Summary, p. 71) and that “Elevated metals concentrations in downstream waters are expected to last no more than 1 week for the bulk tailings release,and several weeks for the pyritic tailings release.” (Executive Summary, p. 70) However, the DEIS analysis on failure scenarios is inadequate to make such conclusions. The Army Corps has created an effects conclusion based on an unreasonable assumption that any tailings failure would be miniscule, an assumption contrary to actual tailings failures examples throughout the world and scientific literature on the scale of tailings dam failures. Because the Army Corps did not do their job, Bristol Bay fishermen had to engage a geophysicist to model tailings dam failure. That model shows tailings flows over 100 KM down the Koktuli River.
Health Impact Assessment: The DEIS fails to include a Health Impact Assessment (HIA), noting that "Funding and completion of a health impact assessment (HIA) following Alaska guidelines is strictly voluntary in Alaska and is not required by either Alaska law or federal law (ADHSS 2015)." DEIS, p. 3.10-3 An HIA was specifically requested by Bristol Bay communities in scoping hearings and written comments. The Army Corps' failure to address vital human health concerns by conducting an HIA is one more indication of a rushed and less than adequate NEPA process.
Direct impacts to over 3,500 acres of wetlands and over 80 miles of stream are described by mine infrastructure alone. These figures are vastly underestimated. Claims by Pebble Limited Partnership CEO, Tom Collier, regarding "no significant adverse impacts to the fishery," are not supported by the DEIS, which conservatively estimates permanent loss of over 80 miles of streams. Fisheries scientist, Chris Frissell, Ph.D., has documented that 100% of these waterways are connected to anadromous (salmon) habitat, and are essential to general watershed function and ecology. Moreover, the estimates of habitat impacted are disingenuous. Percentage estimates of anadromous habitat impacted are based only on direct stream removal by the mine footprint and do not consider downstream water quality or physical habitat degradation; transportation corridor impacts; foodweb, behavioral, or other indirect ecological effects; accidental spills, or catastrophic failure. The estimates do not even consider impacts of water withdrawals. This is an extremely biased reporting and vastly underestimates actual impacts. The executive summary indicates timing of construction in anadromous streams would be adjusted to minimize impacts to eggs, juveniles, and adults. There is no time of year that at least one of those life stages, particularly of Chinook and coho salmon are not present in rivers. Finally, one entire salmon-bearing tributary will be eliminated that currently supports kings, sockeye, and coho.
Additional technical and scientific concerns will be highlighted throughout the comment period on the Save Bristol Bay blog. Please check there for more details.