EPA’s study of Bristol Bay is troubling

By Marleanna Hall

In its comments on the Revised Draft Bristol Bay Assessment (BBA), RDC urged the Environmental Protection Agency (EPA) to halt its premature assessment and warned that use of the BBA to preemptively veto a project would deprive government agencies and stakeholders of the specific information, science and rigorous reviews that would come out of the multi-year National Environmental Policy Act (NEPA) process.

RDC said any use of the assessment by the EPA to derail a project from navigating the permitting process would undermine existing regulatory processes and set a dangerous precedent for development.

One of RDC’s top priorities is to promote and defend the integrity of the existing permitting process and to advocate for predictable, timely, and efficient state and federal permitting based on sound science and economic feasibility.

“A preemptive decision, prior to permit or project application and completion of the NEPA process, is unacceptable,” wrote RDC, “whether it be approval or denial of any project, in any industry.”

In its letter, RDC stressed, “The revised assessment remains significantly flawed since it continues to refer to a hypothetical mine, and outdated mining techniques. Although the revised BBA has fewer references to old practices, the report still fails to incorporate current high tech and state-of-the-art mining practices and regulatory requirements” and that “the BBA should not be used to inform the process until its numerous flaws are corrected and it addresses a formal development plan, as well as a suite of mitigation measures, submitted by the project sponsor.”

RDC maintained that the Pebble copper and gold prospect in Southwest Alaska is clearly too important to be judged based on a hypothetical mine, or on uncertain legal grounds. The project should not be deprived of the due process that is consistent with other projects in Alaska and throughout the nation.

In its letter, RDC highlighted the seven large operating mines in Alaska that coexist with other resources and activities. The economic value from production at these mines and the many placer mines and rock, sand and gravel operations was $3 billion in 2012. Jobs created by these projects are high paying and generate revenue in regions in Alaska where few other opportunities exist. All seven of these projects have been subject to existing processes and procedures. Projects in the Bristol Bay region must be allowed to go through the same process.

RDC urged the EPA to consider the benefits of the jobs not only in Alaska, but in the nation, that will likely come from development of Pebble. The prospect is one of the most significant mineral deposits in the United States, with the potential for billions of dollars in economic activity and thousands of jobs.

In a recent letter to the EPA, RDC said the Pebble copper and gold prospect in Southwest Alaska should not be deprived of the due process. “A preemptive decision, prior to permit or project application and completion of the National Environmental Policy Act process, is unacceptable,” RDC said. Pictured above is the Pebble prospect.

While other groups opposing the proposed Pebble Project claim to have spent millions of dollars on years of research in the area, the Pebble Partnership has studied the deposit area for over eight years, spending in excess of $150 million dollars. In its letter, RDC questioned why this research is ignored in the BBA.

Karl Gohlke, on behalf of Frontier Supply Company in Fairbanks, wrote that the Pebble Partnership has been studying the area for nearly nine years, and that not just its science must be considered, but the socioeconomic aspects must be included, too. “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,” Gohlke said.

In comments submitted to the EPA by the National Mining Association (NMA), Amanda Aspatore urged the EPA to abandon the BBA, as “EPA’s extra-regulatory actions with respect to the Bristol Bay watershed are premature and inappropriate, and will undoubtedly have a stifling effect on economic growth in Alaska and beyond. The lands in question are open to mineral exploration, and EPA should allow such exploration to proceed and wait until the proper time to evaluate any proposed mine plans.”

The Alaska Miners Association included a condensed comment on the Revised BBA entitled, “Lipstick on a Pig,” noting the “EPA made only cosmetic changes to its 2012 draft. The 2012 draft was fundamentally flawed in numerous ways.” RDC supports AMA’s comments, including its extensive and well-written Technical Review.

In previous cases, Alaska’s governor and congressional delegation expressed support of due process and fair consideration of the Pebble project. Alaska’s Attorney General has asked the EPA to stop its work on the assessment process until there is a permit application submitted to the federal government.

RDC applauds the numerous groups who commented on the BBA, from the Alaska Forest Association and the Associated General Contractors, to the many elected officials and individuals who care about bringing investment to Alaska and a fair, dependable process.

To view comments submitted by RDC and others, visit akrdc.org.

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