Return to Action Alert
Via email to ORD.Docket@epa.gov
May 30, 2013
Dear EPA,
Your so called study of the Bristol Bay watershed is at best a joke. The entire study should be destroyed. Your "study" is trash and should be treated as such.
The first draft of the Bristol Bay Assessment was reviewed by a "Pier Review Panel" your organization paid for. Yet some of the panel members found faults with your study. This is rather remarkable as the EPA has a record of choosing "scientists" whom approve your documents and studies. As people hired found fault with your study imagine what truly independent scientists would say?
Your original "study" and the new draft included no new science, and relied heavily on open source documents without vetting the people / groups who provided that information. The EPA didn't even look at the methodology used to create the documents you relied on. In short you did not do a real study and produced a purely political document. I expect better from the EPA!
While the EPA is charged with protecting the natural environment you should also consider the benefit to humans responsible development will have. I expect you to carefully evaluate each proposed project including its mitigation and reclamation plan, attempt to replicate at least half of the data regarding a specific development and weigh the projects potential benefits prior to making any type of decision or finding.
Your original "Bristol Bay Assessment" used a mine scenario that would never be allowed in the USA nor most other places in the world. You didn't even have a mining person on your "team" to insure your "study" used the best most modern mining methods. In short your mine scenario was based on a fantasy for the sole purpose of saying a mine was bad. The current draft of you "study" is no better, it simply added additional mine scenarios that could never be permitted in the USA.
Never before in history has the EPA attempted to use it's 404 ( c ) authority to reject a project prior to that project having gone through established permitting processes. How can you have an honest assessment without a formal application from a developer? Attempting to use 404 ( c ) authority to preempt the legal permitting process sets a bad precedent. What is next? Will the EPA use it's 404 (c ) authority to ban all proposed development? Any claim that the EPA will not attempt to reject all development is negated simply by the current Draft Bristol Bay Assessment. If you can reject something by sighting fictitious scenarios on this project why not on all future projects?
Your Bristol Bay Study DESTROYS ALL CREDIBILITY THE EPA EVER HAD! Your current Bristol Bay Study (EPA-HQ-ORD-2013-0189) if adopted will condemn the people of South West Alaska to poverty for several more generations. Lack of jobs creates despair, leading to drug and alcohol addition. Just as tragic, communities and villages are being abandon as people move to areas they can make a living. If you study is left as is the EPA will have partial responsibility for destroying a culture that is thousands of years old.
I request the following action be taken immediately.
1- extend the comment period on EPA-HQ-ORD-2013-0189 by at least another 90 days. People in Alaska are currently busy dealing with the ice break up and fishing. Many do not have time to comment now as they are protecting their homes from flooding and getting food to survive next winter. Allow more time for comments so more Alaskan's can read your "assessment" then submit comments. Give the people in this state until September 2013 to submit comments.
2- Scrap this "study" EPA-HQ-ORD-2013-0189 completely. Wait until there is a real proposal submitted by a developer (such as The Pebble Partnership) and then do a real scientific study.
By doing the 2 things I have asked of you, the EPA will regain some credibility. It will be harder for people like me to say your study and decisions are political rather than scientific if you actually do science and review an actual min proposal.
Respectfully,
Michael Jesperson
