Bristol Bay at Risk

Imagine a place where the watershed is un-engineered, where the ecosystem’s productivity and potential is fully realized. It produces half the world’s wild sockeye salmon and is home to more brown bears than people. Then imagine that greed for minerals, driven by mass consumption, threatens it.

Alaska’s Bristol Bay is that place.

GIF of underwater footage of adult coho salmon

Bristol Bay is a 42,000 square mile (1.87 million hectare) watershed that encompasses the southeast corner of the Bering Sea. Ringed by the Kuskokwim Mountains to the north and the Aleutian Range to the south and east, the area is almost wholly undeveloped. The watershed includes two of the nation’s largest national parks (Katmai and Lake Clark), three giant national wildlife refuges (Alaska Peninsula, Becharof, and Togiak), the nation’s largest state park (Wood-Tikchik), as well as millions of acres of undeveloped lands and waters. In short, it is one of the most spectacular and wildest landscapes on the continent.

Wildness, however, doesn’t equate unpeopled. Humans have lived in the Bristol Bay region for at least 9,000 years and likely longer (the oldest human habitation sites were probably flooded by rising sea levels at the end of the last ice age).  Bristol Bay’s Yupik, Alutiiq, and Dena’ina developed a complex relationship with the resources they used to survive, especially salmon. Today, salmon remain the cultural, economic, ecological heartbeat of the region.

Born in freshwater and grown large in the sea, salmon are a conveyor of energy and nutrients. Their upriver migration feeds everything from mink, otter, eagles, and brown bears to 30 inch-long rainbow trout and 10-pound char. After spawning, they die and their decomposing bodies distribute millions of pounds of fertilizer, substantially increasing the productivity of an otherwise nutrient poor freshwater system. Salmon even help plants grow faster.

The area’s abundance isn’t fantasy either. Bristol Bay’s 2018 salmon run was the largest on record, with over 62 million wild salmon returning. Of that run, 21 million sockeye went uncaught and escaped upstream to spawn. 2018 was the fourth consecutive year that sockeye salmon runs exceeded 50 million fish. Exvessel value, the activities that occur when a commercial fishing boat lands or unloads a catch, was worth $281 million dollars. In 2010, during a much smaller run compared to 2018, harvesting, processing, and retailing Bristol Bay salmon created $1.5 billion in sales across the U.S. The value of salmon is even higher when all salmon related jobs—fishing, processing, tourism, supplies, services, and government—are taken into account.

Pebble Mine puts all that at risk.

GIF of underwater footage of sockeye salmon

Pebble Mine is a proposed open pit copper and gold mine at the northern headwaters of Bristol Bay. The fully developed mine site would encompass over 8,000 acres. Tailings ponds and an open pit would straddle two incredibly productive salmon producing watersheds—the Kvichak and Nushagak. Supporting infrastructure would include a 270-megawatt power generating plant, a 188-mile natural gas pipeline, dozens of miles of roads, and up to three new ports where no development currently exists.

As part of the required permitting process, the Army Corps of Engineers is currently soliciting comments on its draft Pebble Mine Environmental Impact Statement (DEIS). Comments will be accepted until May 30. I’m working on my comments now and plan to share them in another post, but the draft is huge, over a thousand pages long, so it’s taking me some time to read. However, my initial evaluation of the document has revealed major concerns.

  • The DEIS evaluates the mine’s active phase (20 years), but pays little attention to the true lifespan of the mine’s footprint, which will extend for hundreds, even thousands of years and create a permanent hazard to the watershed. After the mine’s proposed 20-year operation phase is complete, the landscape is supposed to be reclaimed. Tailings and waste rock will be stored underground or underwater in the former open pit. The open pit will be allowed to fill with water. Once the open pit lake rises high enough, water would be pumped from it, treated to meet water quality standards, and discharged into the watershed. This must happen forever to prevent groundwater contamination.
  • The DEIS does not evaluate the effects of a catastrophic tailings dam failure, which would release a toxic slurry of material into the Kvickchak and Nushagak watersheds. The risk of this is low, but that’s beside the point. The risk still exists and cannot be eliminated.
  • The DEIS does not evaluate who will pay for and maintain permanent water treatment in the open pit.* There is currently no financial plan to fund wastewater treatment after the 20-year operational phase when the mine is to be “reclaimed.” Who’s to pick up the tab when the Pebble Partnership, the mining consortium owned by Northern Dynasty Minerals, decides to walk away? The partnership claims financial assurance for site closure and monitoring is required before construction, but this does not assure funding for perpetual waste-water treatment. Since the corporation cannot guarantee financial solvency forever, it should not be allowed to create hazards that last forever.
  • The DEIS does not sufficiently evaluate the cultural impact the loss of salmon would represent to local residents, especially Native Alaskans. I’ve never been to any place where a single group of animals means as much to a regional culture as salmon do for the residents of Bristol Bay. For them, loss of salmon would be equivalent to the loss of bison for American Indians across the Great Plains.
  • Supporting roads, ports, and other infrastructure have the potential to disrupt some the best, untrammeled bear habitat in the region, especially for bears that use the McNeil River area just north of Katmai National Park.

Pebble’s proponents argue that the mine and salmon can coexist, but the two are at fundamental odds and always will be. Mike Heatwole, president of Public Affairs at the Pebble Partnership, told Mashable that the mine will cause no “population-level challenges to fish and wildlife resources.”

Screen shot from Pebble Partnership website. Text says, "Where is Pebble? Despite what you may have heard, Pebble is not at the headwaters of Bristol Bay. It is located at the upper reaches of three small tributaries — out of more than 50,000 in the Kvichak and Nushagak watersheds."

Pebble Partnership also claims the mine isn’t at the headwaters of Bristol Bay, which is blatantly false. This screen shot is taken directly from their website.

Despite talk that the salmon “population” won’t be affected, the mine reduces spawning and rearing habitat no matter what. Even under a best-case scenario where Pebble Partnership keeps its word, this is still precisely how we begin to lose salmon—one impassible culvert, one dam, one mine at a time. A few yards of stream here, a little more there. Does that matter? It sure does, as the story of salmon in the contiguous 48 states illustrates.

When Lewis and Clark explored the lower Columbia, they found the riverbanks lined with people, and a regional subsistence and trade economy based on the river’s salmon. In less than 150 years, it was gone. Farther upstream at Spokane Falls, people once gathered for thousands of years to catch 60 – 80 pound chinook. Those runs too are nothing more than memory.

In Washington State today, we bicker over the last of the wild salmon, considering whether to cull sea lions to help save an endangered population of starving orcas. Not far from where I live, Baker River sockeye are completely dependent on human intervention for their survival, because dams now completely block access to their spawning grounds. The outlook for salmon isn’t good on the rest of the west coast either. By 1999, wild salmon had disappeared from about 40 percent of their historic range in Oregon, Washington, Idaho, and California. Across the continent in Maine, where people have taken great strides to clean up rivers and remove some barriers to salmon migration, almost no wild Atlantic salmon remain. Twelve Atlantic salmon returned to Maine’s second and third largest rivers, the Androscoggin and Kennebec, respectively, in 2018. Twelve.

No single factor caused the collapse of salmon runs in New England or the west coast. It was death by a thousand cuts. They were treated as an afterthought at best, undervalued and willingly sacrificed for “progress.” Similarly, if developed, Pebble Mine probably won’t be the end to salmon in Bristol Bay, but it could certainly be the beginning of the end. As Van Victor, president of the Bristol Bay Economic Development Corporation, rhetorically asked, “At the end of the day, do we really want to risk what is truly one of mother nature’s wonders of the world for copper and gold?”

GIF of underwater footage of salmon fry

Young salmon fry feed in one of Bristol Bay untarnished rivers.

If you haven’t seen Bristol Bay, if you haven’t experienced what a truly wild and healthy ecosystem is like, then it might be easy to dismiss my concerns. It can be hard to imagine rivers and streams flooded with fish, where wildlife and people flourish on the seasonal treasure. That dynamic simply no longer exists in most of the rest of North America and we, unfortunately, consider it normal. In conservation biology, this generational amnesia is called shifting baseline syndrome: Every generation sees nature through a different lens and what we view as normal is actually degraded. Our threshold for acceptable environmental conditions is continually being lowered.

Thankfully, we don’t have imagine or scour history books to understand what Bristol Bay’s fishery and ecosystem was once like because it is what it has been since the last of the Ice Age glaciers melted from the landscape. We can still experience it at its full potential. It’s a treasure to savor and protect.

But we could lose it, quite easily in fact. Pebble Mine represents greed over sustainability. If developed, it provides clear evidence we won’t stop till the entire world is consumed. Future generations will judge us poorly if we take everything and leave nothing. It takes a special kind of naiveté to believe otherwise.

 

*I’d like to add a correction on this point. According to James Fueg of the Pebble Partnership, a closure bond would have to be in place before construction can begin, with the bond’s purpose to fund perpetual wastewater treatment by the state. This is good and something I didn’t know about. However, this is of little consolation. It is unethical for a private corporation to create a permanent hazard that the government then must forever ensure is contained. It’s not in the public’s best interest, and shouldn’t be allowed.

Pebble Mine Scoping Comments

Recently, I wrote about an impending threat to Bristol Bay’s salmon: Pebble Mine. The mine, if developed, will have significant effects across some the richest salmon and brown bear habitat left on Earth.

Salmon remain the ecological and cultural heartbeat of Bristol Bay. This mine will create billions of tons of semi-fluid toxic waste, which must be treated and prevented from entering the watershed indefinitely. Impacts from development are never completely restricted to the development’s footprint either. Roads fragment habitat and vehicle traffic displaces wildlife.

When I was born, Pacific and Atlantic salmon fisheries in the Lower 48 states were already significantly degraded. Nearly 40 years later, many salmon stocks in New England, California, Oregon, and Washington remain threatened or endangered. Only a small fraction of fish return to these areas compared to historic levels. I’m not about to let this story repeat itself in Alaska, nor should you. If the mine is developed, future generations will inherit its legacy, and I predict they won’t look upon us fondly for repeating the same mistakes that killed salmon runs in the past.

Please comment during the scoping period on the Army Corps of Engineers’ Pebble Mine Environmental Impact Statement (EIS) and send those comments to your congressional representatives as well. Below you’ll find my scoping comments for the proposed mine. Feel free to copy and personalize them as you see fit. State your concerns now, so when the Army Corps of Engineers writes the EIS it will fully evaluate the mine’s impacts. Don’t let Bristol Bay’s salmon disappear because of our lust for copper and money.

The Corps is accepting comments through June 29, 2018.

salmon jumping at waterfall

Comment to the U.S. Army Corps of Engineers (submitted May 23, 2018):

The proposed Pebble Mine and its associated infrastructure poses a substantial threat to salmon and wildlife across the Bristol Bay region. Pebble Mine will straddle the watershed divide between two of Bristol Bay’s most important salmon spawning and rearing areas. I remain very concerned with the mine’s potential to negatively impact the area’s fisheries and wildlife through its wastewater, tailings, and infrastructure.

The EIS must answer one question: can Pebble Mine be developed without significantly degrading water quality and fisheries? The Corps’ has authority to deny permits under section 404 of the Clean Water Act if a proposed action will significantly degrade water quality and fisheries. This EIS should evaluate and quantify, not just identify, the mine’s potential to significantly degrade water quality and fisheries over short and long-term timespans. The EIS can begin this evaluation by appropriately defining its purpose.

A recent environmental impact statement from the Army Corps of Engineers, the Donlin Mine EIS, merely stated the purpose of the mine and the Corps’ authority to permit it (Donlin Mine Final Environmental Impact Statement – Chapter 1, pg. 1-4, 1-6). The purpose and need of the Pebble Mine EIS should be not be to simply define the project’s purpose (to mine ore) and define the Corps’ regulatory authority. It should be, as I propose, to:

  • Identify the short-term and long-term ecological effects of the proposed Pebble Mine,
  • Evaluate the mine’s and its infrastructure’s impacts on wildlife, including fish, in order to
  • Determine whether the mine’s safeguard can prevent all degradation to water quality, salmon habitat, and wildlife habitat indefinitely.

Even at very low concentrations, dissolved copper is particularly toxic to salmon, interfering with their ability to navigate and avoid predators. Its effects can manifest over minutes or hours and persist for weeks (Hecht 2007). Can the mine’s wastewater treatment plan adequately remove dissolved copper and prevent it from entering the watershed?

The mine’s tailings also pose a great risk to fish. Any accidental discharge from the pyritic tailings ponds will significantly degrade salmon habitat. Open pit mines, even within the United States, have a poor record containing their toxic tailings. Most tailings dam failures occur at operating mines and 39 percent of such failures worldwide occur in the United States, significantly more than in any other country (Rico 2008). Earthquakes and flooding hazards increase the risk of a tailings pond dam failure in the Bristol Bay region, and tailings ponds cannot be drained in the event of flooding or dam failure due to their toxic contents. The probability of a M8+ earthquake, for example, is low from year to year but remains real at any given time. Therefore, the EIS must also evaluate whether the tailings ponds can be engineered to withstand the greatest potential earthquakes and floods expected over the next several thousand years.

After the mine’s 20-year active phase, the mining company proposes to store toxic pyritic tailings indefinitely under water in the former open pit. This seems to create the potential for acid mine drainage to leach into the watershed over hundreds or thousands of years. What geologic studies suggest this is a feasible long-term plan to store the tailings? Even if subaqueous storage in the former open pit prevents the tailings from oxidizing, what safeguards will prevent dissolved copper and other toxic metals from entering groundwater to eventually oxidize and acidify as it nears the surface in a different part of the watershed?

The mine’s supporting infrastructure also creates risks for salmon and wildlife. Although salmon can navigate and migrate through streams with high sediment loads, they do not spawn in these habitats. Erosion of sediments into streams can irritate the gills of fish, smother eggs, alter feeding habitat for salmon fry, and bury spawning habitat. The effects of road construction and vehicle traffic (estimated by the mining partnership to be 35 round-trip truck trips per day) on wetlands and fisheries should also be evaluated.

The road servicing the proposed Amakdedori Port and the port itself will fragment what is now an unspoiled region of coastline on Cook Inlet. McNeil River State Game Sanctuary is one of the most important brown bear refuges on Earth, home to the largest annual congregation of bears yet observed. The road and port have the potential to displace bears moving to and from the McNeil River and Katmai National Preserve areas. Frequent work and dredging at the port area will also displace wildlife in an area that now experiences very little human activity. Other alternatives to transport ore should be evaluated.

Finally, the EIS needs to address more than the 20-year operational phase, because the mine’s waste legacy will threaten salmon for thousands of years. Tailings stored in the former open pit won’t become benign in the near future and wastewater must be treated indefinitely. Also, the possibility of an expanded mine operating over a long time frame increases the threat to salmon, other wildlife, and clean water.

Combined, the Nushagak and Kvichak rivers support about 40% of Bristol Bay’s sockeye salmon. In 2017 alone, over 56 million sockeye salmon returned to Bristol Bay and over 19 million returning to Nushagak River, the largest in the river’s history. Salmon fishing in Bristol Bay is a billion dollar industry. While commercial fisheries generate the bulk of the salmon’s economic value, the area’s tourism is almost entirely based on salmon as well. Bristol Bay is home to dozens of premier sport fishing destinations, which harbor abundant populations of rainbow trout, Dolly Varden, arctic char, northern pike, lake trout, and grayling. The Bristol Bay area also hosts some of the densest populations of brown bears ever measured. Salmon are the most important food source for these animals, and the vast majority of people who visit Katmai National Park come to watch brown bears (Strawn 2015). After spawning, dead salmon fertilize the ecosystem with nutrients derived from the ocean, boosting the productivity of otherwise nutrient-poor area.

Considering the overwhelming economic and ecological value of salmon to the Bristol Bay region, Pebble Mine could displace thousands of workers and tourists if its safeguards fail to protect salmon. Without the energy and nutrients provided by consistently large runs of anadromous salmon, Bristol Bay’s freshwater and terrestrial ecosystems will quickly transition from one of richness to poverty. In many ways, this cycle is a positive feedback loop. The productivity of the area is reliant on large runs of salmon.

We’ve seen, repeatedly, salmon populations in the Pacific Northwest and New England decimated by habitat loss and pollution. Now we’re on the brink of repeating the same mistake in Bristol Bay. Pebble Mine should not be developed. It’s in the greatest interest of Bristol Bay’s fishing industry and culture, watersheds, salmon, and wildlife for the Corps’ EIS to fully evaluate the mine’s near and long-term effects. A failure to contain the mine’s toxic tailings and wastewater would directly impact two of Earth’s most productive salmon producing watersheds. The EIS must address potential groundwater exchange in the abandoned open pit, and whether the mining company can eliminate the risk of acid mine drainage. It must address whether the embankments for tailings ponds can withstand high magnitude earthquakes. It must address whether it’s even appropriate to build a mine whose wastewater will need to be treated indefinitely. It also must critically evaluate the mine’s supporting infrastructure, as it will potentially disrupt the world’s largest seasonal congregation of brown bears. In sum, the EIS must evaluate a worst-case scenario for salmon and other wildlife, since the possibility can’t be completely, or even reasonably, eliminated.

References:

Hecht, S. A., et al. March 2007. An overview of sensory effects on juvenile salmonids exposed to dissolved copper: Applying a benchmark concentration approach to evaluate sub-lethal neurobehavioral toxicity. National Marine Fisheries Service.

Rico, M., et al. 2008. Reported tailings dam failures: A review of the European incidents in the worldwide context. Journal of Hazardous Materials 152: 846–852.

Schindler D. E., et al. 2003. Pacific salmon and the ecology of coastal ecosystems. Frontiers in Ecology and the Environment. 1(1): 31–37.

Strawn, M. and Y. Le. 2015. Katmai National Park & Preserve Visitor Study: Summer 2014. Social and Economic Sciences Research Center, Washington State University, Pullman, WA.

 

Addendum: My comment was apparently too long for the Corps’ comment portal on the Pebble EIS website. So if you use my comment in full, you might receive an error message. To work around it, you can attach the full comment as a PDF or Word document.

The Worst Place in the World for a Mine

“This is the jewel in the crown of America’s fisheries resources – these salmon. If you don’t think this is worth saving, what is? To me, if you don’t draw a line in the sand here, there’s none to be drawn anywhere.”

Thomas Quinn
Professor, University of Washington and author of The Behavior and Ecology of Pacific Salmon and Trout

After more than a decade of controversy, Pebble Mine is inching closer to reality, and from the perspective of salmon, we couldn’t choose a worse place for an open pit mine.

red salmon swimming in shallow water

If you’re unfamiliar with Bristol Bay, its salmon, or Pebble Mine, please watch this 2012 overview on the Pebble Mine controversy, keeping in mind the mine’s currently proposed size and mineral processing plans are different than those outlined in the video.

Pebble Mine is a proposed open-pit copper, gold, and molybdenum mine at the headwaters of some of the last intact and most productive salmon habitat on Earth. Before any development of the mine can begin however, it must be permitted, and before it can be permitted, it must undergo an extensive environmental review. This is where we stand currently: the environmental impact statement (EIS) process for Pebble Mine has begun.

An EIS goes through several stages before a “record of decision” is finalized. Right now, the Pebble EIS is only at the scoping level. If you’re unfamiliar with the EIS process, public scoping is basically a brainstorming step. It’s the public’s opportunity to help define the breadth of the EIS to the lead agency, which in this case is the Army Corps of Engineers. (Read more about the scoping process.) During public scoping, if people don’t express concerns for the ecosystem-wide impacts of Pebble Mine and its infrastructure then the Corps’ EIS will not address them. Therefore, we must comment during the scoping period and demand that the alternatives in the EIS address the mine’s full environmental impact—which will sprawl across southwest Alaska and threaten the last great sockeye salmon run in North America.

The Bristol Bay area is exceptionally special and unique. Its landscape remains largely undeveloped and un-engineered. The major factors that decimated salmon elsewhere—habitat loss, dams, and pollution—are absent and salmon runs reach tens of millions of fish annually. Bristol Bay is where we can imagine the richness of fish that used to flood into the Columbia River or New England. It remains home to one of the most valuable and sustainable fisheries on Earth, one of the few remaining places where the full potential of the ecosystem is realized.

salmon jumping at waterfall

Salmon fishing boats in Naknek

Salmon fishing boats sit idle on a late winter day in Naknek, Alaska. The 2017 Bristol Bay salmon harvest was worth $670 million.

The Pebble EIS must address the mine’s potential, worst-case scenario effects on Bristol Bay’s salmon. A failure to contain the mine’s toxic tailings and wastewater would directly impact two of Earth’s most productive salmon producing watersheds. (The Kvichak River watershed, where part of the mine will be located, is home to the single largest salmon run in the world.) It must address potential groundwater exchange in the abandoned open pit, and whether the mining company can eliminate the risk of acid mine drainage. It must address whether the embankments for tailings ponds can withstand high magnitude earthquakes. It must address whether it’s even appropriate to build a mine whose wastewater will need to be treated indefinitely. It also must critically evaluate the mine’s supporting infrastructure, as it will potentially disrupt the world’s largest seasonal congregation of brown bears.

Map outlining Nushagak and Kvichak watersheds. Red star marks location of Pebble Mine.

Pebble Mine will straddle the divide between the Nushagak and Kvichak watersheds, two of Bristol Bay’s riches salmon producing areas.

By law, the EIS process must identify the least environmentally damaging practicable alternative. Common sense implies the least damaging alternative in this case is no mine at all, but the National Environmental Policy Act does not require agencies implement it. If we don’t demand the Corps critically evaluate the myriad impacts from the mine, then the Corps will merely focus on holes in the ground, “alternatives” of natural gas versus diesel to power the mine, how wide the service roads will be, and the size of the ports. The scope of the EIS will be so narrow to be useless for the protection of salmon. (For an idea of what this might be, look no further than the Donlin Mine Final EIS, whose purpose and need is: “produce gold from ore reserves from the Donlin deposit using mining processes, infrastructure, logistics, and energy supplies that are economical and feasible for application in remote western Alaska. The applicant’s stated need for the project is to provide economic benefits to Donlin Gold, Calista, and TKC shareholders; and to produce gold to meet worldwide demand.”)

I recognize a sad irony—or hypocrisy, if you prefer—of using a computer, which contains gold and copper, to type this post. I understand there’s a hole in the Earth, perhaps filled now with toxic water, where the metals in my machine were once trapped in rock. If you, like me, think Pebble Mine is irresponsible, then voice your opposition not only through the EIS process and with your votes at the ballot box (politicians who support Pebble Mine will not receive my vote), but also by reducing your consumption of products that use gold and copper. We, as consumers, need to say enough is enough. Our addiction to ever-higher levels of consumption brought us here. It’s not really sufficient to say “I’m opposed to Pebble Mine” then go out and buy the newest iPhone even though your old phone works just fine.

Everything we use, everything we make, has a cost. We’re at a point in history when surging human population growth and mass consumption are pushing ecosystems and species to their breaking point, creating an ecologically impoverished planet. In New England, wild Atlantic salmon are nearly extinct, and on the U.S. west coast only a tiny fraction of Pacific salmon return compared to historic levels. Don’t kid yourself: This sad story can repeat itself in Alaska.

We lose salmon one impassible culvert, one dam, one levee, one mine at a time, leaving us to suddenly wonder, where did all the fish go? In Bristol Bay we have a chance, maybe our last chance, to save large runs of wild salmon. If the mine is built and its proposed safeguards fail, we risk losing a significant portion one of the world’s last great sustainable fisheries. Future generations won’t be celebrating our decision if we develop this mine. They’ll criticize us for not learning from the mistakes of the past. Are we really willing to let hyper-consumerism and the promise of short-term profits potentially destroy the last great salmon run?

It looks like we’re on track to do so, unless enough people step up and say no.

Through June 29, 2018, you can submit scoping comments on the Pebble Mine EIS. I’ll share my scoping comments in a forthcoming post when they are finished.

Update May 23, 2018: My scoping comments can be found here.