Resource Development Council
 
 

RDC Member Comment Letter:
Revised Draft Bristol Bay Assessment

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From: Karl Gohlke
Subject: EPA-HQ-ORD-2013-0189
Date: May 31, 2013 3:21:11 PM AKDT
To: "ORD.Docket@epa.gov" <ORD.Docket@epa.gov>

Dear Federal Environmental Protection Agency,

I know the permitting and regulatory process in Alaska is among the most robust in the world. It is an extensive public process, and one that we as Alaskans are proud of. It is unfortunate that non-Alaskans do not understand our permitting process and are blinded by the public media BS. Every project, no matter the size or location, should have an opportunity to be reviewed under existing legal processes, if not it undermines existing agency responsibilities on both the state and federal level.
Today Pebble Partnership continues their six – going on seven – year study of one of the largest environmental programs ever undertaken for a natural resource project in Alaska – more than 27,000 pages that study over a million acres, 40 independent consulting firms and more than 100 scientists and technicians. Versus EPA’s one year assessment covering only 20,000 acres of the one million acres Pebble Partnership’s study. The short time frame of the study is insufficient and cannot come to a valid concrete conclusion. Again, American’s; through inaccurate reporting, are not getting the real picture and their making poor conclusions that will affect America citizens and their future.

The Bristol Bay Water Assessment (BBWA) Study uses a hypothetical mine as a basis for its study, and periodically refers to outdated mining techniques. The Study and potential 404(c) actions against the Pebble Project are premature because the project has not yet been finalized and no permit applications – including detailed plans and environment mitigations strategies – have been submitted to state or federal government agencies.

A preemptive decision on the Pebble Partnership project, prior to permit or project application and completion of the National Environmental Policy Act (NEPA) process is unacceptable, whether it be approval or denial of any project in any industry. Basing any regulatory decisions on this poorly crafted BBWA will set a terrible precedent not just for the mining industry, but all development and economic growth sectors, and will hurt Alaskans and the residents of Bristol Bay the most.

Pebble Partnership has been on sight in Southwest Alaska for almost nine years. More than half of the studies relate to fish and water, and provide the data they needed to design a mine that co-exists with the fishery. The studies also address the socio-economic environment. Southwest Alaska is one of the most economically challenged regions in the United States. Jobs are scarce, the cost of living is probably the highest in the nation and the population is declining as people leave their traditional homes to find work. The fishing industry is only seasonal, three months at the most.

The Pebble Project has the potential to support about 16,000 total jobs during construction phase. The projected annual operating budget of more than one billion dollars will support 1,000 direct mining jobs with an average annual wage of $90,000. The Pebble Partnership project is under micro micro scope and its success or failure will set the standard for every mining company in America. With the national scrutiny Pebble is enduring, their belief and mine that they can co-exist with the fishery like all the other mineral mines in Alaska. Let it Pebble Partnership work through the legal process before EPA and national environmental groups tear it apart.

Karl I Gohlke

Karl I. Gohlke
Outside Sales
Frontier Supply Company
981 Van Horn Rd.
Fairbanks, AK. 99701