RDC Member Comment Letter:
Revised Draft Bristol Bay Assessment

Return to Action Alert

May 31, 2013

US Environmental Protection Agency
EPA Docket Center EPA-HQ-ORD-2013-0189, Mail Code 28221T
1200 Pennsylvania Ave., NW
Washington, DC 20460

Gentlemen:

This is to once again provide comments relative to the above study although comments such as mine and others of similar nature, I doubt, will have little to no influence on your conduct or intentions as demonstrated by consideration of our precious comments. My comments, regardless, follow in bullet order:

• The demonstrated over-reach by the federal government to influence the permitting of a mine on State of Alaska land that is designated for mineral development is atrocious and demonstrates a complete disregard for state sovereignty
• This pre-emptive action prior to permit application and completion of the NEPA process is unacceptable whether it be approval or denial of any project in any industry
• The revised assessment continues to use a hypothetical mine as a basis for its study, and refers to outdated mining and environmentally responsible techniques
• The assessment and potential harm caused by the Pebble project are premature since the project study has not been finalized and no permit applications have been submitted to government agencies
• The EPA study is faulty, based on an pre-determined outcome, was poorly conducted, and not based on scientific methodologies and data gathering methods; to spend less than one year assessing an area in this study the size of New Jersey and Maryland combined is ludicrous
• The comment period is too short and should be extended to 120 days or more, considering that EPA might give some credence to meaningful comments
• With the US economy in the “toilet” and declining we need job development and the opportunity for economic growth; assuming that the Pebble Partnership can demonstrate through effective & responsible actions, preventive measures, and is approved, it will have the following economic effects:
  o Create 4,725 direct and indirect jobs in Alaska during the construction period of about 5 years; the ripple effect will be to create about 3.4 times that many indirect jobs in the L48
  o Create about 11,450 direct and indirect jobs in Alaska for a very long period and create at least 5 times that many indirect jobs in the L48
  o Pay huge federal, state and borough taxes and thereby support federal and local governments; Lake & Peninsula Borough taxes, alone, will be at least $29 Million per year in severance taxes are calculated at this time after production is commissioned
• To spend taxpayer dollars on a complete over-reaching, illegitimate study, effectively delaying a very credible project in times economic constraints is irresponsible
• The mining industry, to the enjoyment of the environmental community and EPA, is now holding back with investments in Alaska as a result of your ill-advised, mis-directed, and sloppy study; this will further hinder economic growth here and possibly jeopardize short to long-term economic growth.

I’m sure that I’ve wasted my time, but at least I’ve tried to provide constructive criticism and possibly insert some reason into your processes.

Very concerned & responsible miner, ?

Richard A. Hughes, PE
Fairbanks, AK