Pebble Mine Final Environmental Impact Statement: Faulted, Rushed, Still Bad for Salmon

Tell President Trump and the EPA to stop Pebble Mine

The U.S. Army Corps of Engineers released their Final Environmental Impact Statement for Pebble Mine (FEIS) yesterday. Unsurprisingly, the rushed FEIS identifies permanent habitat destruction and fails to address to concerns of stakeholders, tribes, cooperating agencies, and experts. This document will guide the Army Corps’ decision on whether or not  Pebble Limited Partnership (PLP) receives a federal permit. That decision will happen in the next 30-90 days. However, there are two remaining avenues to block the mine: the EPA can exercise veto authority on the project, and President Trump can still intercede to deny the permit.

If you’ve followed Pebble Mine over the years, you’re aware of Pebble’s lengthy backstory and the context of this document. In 2014, the Obama Administration blocked the Mine, “to protect the world’s largest salmon fishery from what would certainly be one of the world’s largest open pit mine developments ever conceived of.” But, almost immediately after President Trump’s victory, his regulatory agenda jolted life back into the project.

Since then, stakeholders, advocates, and everyday people who cherish wild places have tirelessly tried to block the mine at every stage possible. More than likely, you’ve seen a “No Pebble Mine” sticker or signed on to a letter advocating for the protection of Bristol Bay. Today, unfortunately, the mine is as close as it has ever been to being built.

Here is a brief background:

  • Pebble Mine would be located in the headwaters of Bristol Bay, which produces the world’s largest Sockeye Salmon fishery and one of the last prolific Chinook Salmon runs.
  • The massive gold and copper mine would generate 70 million tons of unearthed material each year of its 20 year operating life and poses a major threat to the delicate balance of the Bristol Bay environment, Alaska’s $1.5 billion fishing economy, and Native People’s ways of life.

One of the biggest concerns of Bristol Bay stakeholders and experts is what happens after an initial permit approval and construction of Pebble Mine is completed. Currently, PLP plans to mine roughly 14 percent of the deposit’s ore. So, after all the initial infrastructure is built for Pebble Mine, the worry is that will facilitate numerous more mines, substantially increasing the risk for the long-term health and vitality of Bristol Bay.

In February 2019, the Army Corps of Engineers released a draft environmental impact statement (DEIS) for Pebble Mine. An immediate uproar to the document ensued, and for good reason. The DEIS, plainly speaking, was flawed: it did not adequately review potential impacts, left out essential analyses, made unreasonable conclusions, and under-predicted the potential impacts on natural resources. All of these flaws and more were repeatedly highlighted during the public comment and review period, which for a project of this magnitude was shockingly rushed.

In the months that followed, more than 685,000 Americans expressed their formal opposition to the mine. Over 250 outdoor recreation businesses sent President Trump a letter indicating their opposition to Pebble Mine. 62 percent of Alaskan voters oppose the construction of Pebble Mine. The United Tribes of Bristol Bay opposed the mine. Experts highlighted the fact that Pebble Mine–in its current form–would be financially infeasible. Today’s FEIS release, highlights the grim reality that Pebble Mine’s approval is all but imminent.

Inside the Final Environmental Impact Statement

The FEIS contains glaring issues, both procedurally and physically for Alaska’s people and natural resources. A preliminary FEIS, released several months ago, revealed that many of the criticisms of the Draft document were unresolved, and the mining plan had changed. For example, further analysis of the financial feasibility of the current sized mine and studies on the mine’s impacts to Alaska’s natural resources including salmon and water are absent. Additionally, the Corps scrapped the original plan to transport materials and equipment by ferry, replacing it with an 82 mile road to which PLP does not have property rights.

The Natural Resources Defense Council issued a scalding review of the FEIS. NRDC’s Taryn Kiekow Heimer wrote, “Wetlands, rivers, and streams that will be impacted by the proposed mine still have not been mapped. Fish, water quality, hydrologic studies, and wildlife surveys remain missing or incomplete. Most egregious, the Army Corps continues to limit tribal consultation.” The FEIS remains incomplete and inadequate for a project this size.

Alternative 3, PLP’s preferred alternative, has a mine site footprint of 8,390 acres–an acre is roughly the size of a football field. The final size of the open mine pit is 609 acres, which would be a larger area than Washington, D.C.’s national mall and tidal basin. If approved and built, Pebble would be the largest mine in North America.

Guido Rahr, CEO of Wild Salmon Center said, “The science is clear: this mine is indefensible. It cannot be safely built without harming the fishery in Bristol Bay. And a catastrophic tailings dam failure would release toxic waste that would affect the long-term productivity of salmon fisheries. It’s just too big a risk to take. And it’s time for the EPA to step in and stop this mine.

Salmon of Bristol Bay, @flyloutmedia

Habitat Loss

With such a massive footprint in previously undisturbed environments, significant habitat loss is inevitable. The preferred alternative would include direct and indirect impacts to 4614 acres of wetlands and 191.1 miles of streams, of which 2,231 acres of wetlands and 105.4 miles of streams would be permanently destroyed (FEIS, Executive Summary, 98). The preferred alternative differs from other alternatives in that it relies on an 82 mile access road on the North side of Lake Ilamania. Trout Unlimited Alaska’s Neil Williams believes the habitat loss highlighted in the FEIS is underestimated:

“Worse, because of Pebble’s changing plans and lack of scientific studies, experts anticipate those impacts are underestimated. We can’t accept “concept level” plans when all the details are required to make an informed decision on a key permit. We need to have full tailings dam studies that Pebble promised, we need studies of the northern route.”

“All water is connected”

Water Impacts

Streams and wetlands are scattered throughout Pebble Mine’s footprint. An extensive background in hydrology is not needed to understand the disastrous impact of a 8,390 acre mine operation. In general, all water is connected. So, when you destroy one stream, you’re impacting the entire watershed–no matter how minimally. Pebble’s impacts include direct and permanent destruction of wetlands and streams, 205 waterbody crossings, increased stream sedimentation, and changes to stream temperature and chemistry.

Lake Iliamna is home to world-class Rainbow Trout fishing, @paulnicoletti

Salmon and Fish Impacts

Negative impacts by Pebble Mine on wild fish species are unavoidable. Permanent loss of habitat for anadromous and resident fish would occur including 54 fish stream crossings. There would be direct mortality at the mine site and decreased stream productivity. These direct impacts would happen under perfect operations. The impacts to salmon and other fish species in an accident scenario are far greater.

Bristol Bay is home to prolific Chinook Salmon (King Salmon) runs

For example, under a tailings spill scenario, a myriad of negative impacts would be experienced. Unrecovered tailings could produce acid mine drainage for decades. Tailing dam failures are a reality, which have serious implications for ecosystems and have even killed people. The manner in which tailings are stored is arguably one of the most important aspects of the project. Yet, according to the FEIS section on spill risk, “the current level of embankment design for the project is at a very early phase, considered a conceptual phase. Site investigation and engineering plans are still ongoing.” But sure, let’s go ahead and approve the project’s permit…

Land Ownership Issues

One of the many faults of the FEIS is it identifies a plan for which PLP has not secured all the land. In May, the Army Corps changed its recommended plan to replace a ferry system with an 82 mile transportation corridor. PLP, however, does not currently have rights to the necessary land. Further, some of the landowners have indicated that they would not grant PLP access. The Bristol Bay Native Corporation wrote:

“The new route would transverse BBNC surface and subsurface lands, including at its eastern terminus that sits on property jointly owned by subsidiaries of BBNC and Igiugig Village Council. Both entities expressed to the Corps and PLP that these lands are not and will not be available to accommodate Pebble mine. In addition, the permitting process revealed that the northern route is the only one feasible to accommodate the 78-year mine plan that would mine a significantly larger portion of the Pebble deposit, with a significantly larger footprint.”

Next Steps

The Army Corps now must make their final decision on whether to grant PLP a federal permit. That decision is expected to come in the next 30-90 days. However, Pebble can still be stopped. The EPA, through the Clean Water Act, has the authority to veto the project. The direct and possible impacts to water resources from pebble warrant a veto. To let the EPA know that you oppose Pebble Mine, the Bristol Bay Defense fund created this action-link: TELL THE EPA TO VETO THE PEBBLE MINE!

Additionally, President Trump can still stop the mine. With it being an election year, politicians are generally acutely aware of voters’ preferences and definitely don’t want to anger hundreds of thousands of voters. This is why it is so essential to let President Trump know that you don’t support Pebble Mine. SaveBristolBay created this action form for just that purpose: Tell President Trump to Veto Pebble Mine.

Should the federal permit be approved, legal action would ensue, further stalling the project. Further, PLP would still need to secure the state and local permits, which could take up to four years. And there is the possibility of an Administration in the White House next year that is friendlier to Bristol Bay. So, there is still hope for ensuring the long-term health of Bristol Bay.

I’ll leave you with a quote from Brian Kraft, President of Katmai Service Providers, “If this administration wants to uphold rural American jobs, then the only option is to deny this permit.”

Cover picture curtesy of @flyloutmedia.


 

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