Pebble Mine

E.P.A. Vetoes Pebble Mine!

/ Mike Fitz / 8 Comments

On January 31, the U.S. Environmental Protection Agency banned the disposal of mine waste associated with the Pebble deposit in southwest Alaska. The mine could have become one of the largest open pit mines in the world and would have imperiled Earth’s last great salmon run. The EPA’s decision is a great victory for the Bristol Bay region and its salmon.

Seventy-nine million salmon returned collectively to Bristol Bay in 2022, setting a new record high for the region. Bristol Bay’s wholly intact watersheds make this possible. Water flows freely from snowmelt-fed rivulets and springs high in the mountains through the chains of lakes that occupy glacially-carved basins and into the lower stems of rivers that empty into the Bering Sea. Adult salmon swim upstream without encountering human-made obstructions or water diversions. And, instead of being displaced by shore-line hardening structures to protect buildings or roads, such as it is throughout much of the U.S. west coast, billions of salmon fry in Bristol Bay find ample refuge in the slack-waters along stream margins, grassy marshes, and lakes. Vast numbers of salmon don’t even see a bridge during their entire lives. The diversity and health of the watersheds make Bristol Bay whole. 

Turbulent water filled with salmon. A red-colored salmon's tail fin breaks the surface at upper left. At center, a more silver-colored salmon's face breaks the surface.
salmon jumping at waterfall. salmon are jumping from bottom center to lip of falls on upper left.
GIF of underwater footage of salmon fry. Water is clear. Salmon swim in current facing right over pebbly bottom.

I was late to the Pebble fight, only learning about the proposed mine in 2007 during my first summer as a park ranger in Katmai National Park. But many people in the Bristol Bay region have been advocating against Pebble Mine for 20 years. I hope the fishing boat captains and their deck hands; Alaska Native Tribes, village councils, and coalitions; lodge owners, employees, and fishing guides; chefs; scientists; those who work for non-profit and conservation organizations; and many others have the opportunity to rest well for at least a few days now that the threat of the mine is no longer looming. I thank them for their work.

Landscape scene from mountaintop. Scree slope in foreground transitions to lowland area with, forests, some mountains, and large lakes. No human development can be seen.
GIF of underwater footage of sockeye salmon. Salmon are facing left over stream bottom covered in cobbled

Before I had the fortune of living in the Bristol Bay area, I did not understand—or even fathom—the importance of salmon to place and people. The calendar in Bristol Bay is centered on salmon. The region’s economy is centered on salmon. Its ecology is centered on salmon. And it works, beautifully.

I’ve said many times before that our world is wounded. Too much of humanity seems to have a unique desire and capability to consume land, habitats, material without considering the rights of other creatures or the value that future generations of people might place on those things. I wish I could take everyone to Bristol Bay at the height of the summertime salmon run to see the fishing fleet and processors, to stand on the edge of a river while tens of thousands of salmon swim upstream, to watch brown bears gorge on their most important and sought-after food, to see an ecosystem functioning at its fully realized potential. It just might change your perspective on what should be and what is possible for our world.

A Victory for Bristol Bay

/ Mike Fitz / 8 Comments

Much of my hair fell out this year, perhaps due to stress from, you know, everything, or just being a male human of a certain age, but in the midst of all else one thing that definitely did not help was the continued threat of large scale open pit mining in the headwaters of Bristol Bay, home to the world’s last great salmon run.

Read the Backstory: Bristol Bay at Risk

For about 20 years, the prospect of Pebble Mine has loomed over Bristol Bay and the communities who depend on its salmon for their livelihood. The most recent mine proposal, a scaled-back version of previous plans, would have been one of the largest surface mines in the world. According to the Army Corps of Engineers, the mine would remove 1.4 billion tons of material, and irreparably alter more than five square miles of currently undeveloped tundra and wetlands. The open pit will gouge almost 2,000 feet into the earth and stretch over a mile and a half wide—a hole so deep the Washington Monument could be stacked on top of the Empire State Building and not reach the original land surface. A 500-foot tall earthen dam would be built to hold waste rock and other tailings. All of this was proposed for a site at the headwaters of the Nushagak and Kvichak rivers, two of the most productive salmon producing watersheds on the planet.

In late July, the Army Corps released its final environmental impact statement (EIS) on the mine. While the EIS was not the final word on the mine, by most accounts it seemed favorable. In August, however, as I was trying to prepare myself mentally for the disappointment and anger I would have felt had the mine been approved, the Army Corps issued a press release stating that Pebble Mine “as currently proposed, cannot be permitted under section 404 of the Clean Water Act.” The Corps required Pebble Limited Partnership to provide a new mitigation plan to offset the mine’s impacts on streams and wetlands before it could receive a federal permit. In a letter to Pebble Limited Partnership, the Corps stated “discharges at the mine site would cause unavoidable adverse impacts to aquatic resources and . . . those adverse impacts would result in significant degradation to those aquatic resources.”

In early November, Pebble Limited Partnership submitted a new mitigation plan. But, it failed to satisfy the Army Corps. On November 25, 2020, the Army Corps issued its record of decision on the proposed mine and denied a permit for it. The Army Corps wrote that the mitigation plan was noncompliant with Clean Water Act guidelines, was insufficient in scope to overcome the damage the mine would do to the landscape, and that the mine was “contrary to the public interest.”

I was elated to read the Corps had reached this conclusion. In my public comments on the Army Corps draft Pebble Mine EIS, I had in fact called for the Army Corps to deny a permit for the mine partly because it was contrary to public interest.

The cheapest, most feasible, and most environmentally ethical decision is to conclude this mine poses unacceptable risks to Bristol Bay—specifically the Nushagak and Kvichak watersheds—reject the mine alternatives, and choose the no action alternative for the final EIS. This is well within the Corps’ legal authority: “No Action Alternative could be selected if USACE determines during its Public Interest Review (33 CFR Part 320.4[A]) that it is in the best interest of the public, based on an evaluation of the probable impacts of the proposed activity and its intended use on the public interest.” (Ch. 2-8)

There is no doubt the no action alternative is in the best interest to the public. We have so little to lose by leaving the ore at Pebble Mine in the ground and so much to gain by protecting it for current and future generations. The decision is clear. The only acceptable alternative proposed in the DEIS is the no-action alternative. Do not permit this mine to be developed. 

While campaigning for the US presidency, Joe Biden stated that he opposed the mine. His election along with the Army Corps’ decision during the final weeks of Donald Trump’s anti-conservation administration serves as a death knell for this iteration of Pebble Mine. However, the ore remains on State of Alaska lands open to mining. Mine executives and investors will continue to ogle it. Even as the current Pebble Mine proposal is killed, a new version may rear its ugly head in the future. We came closer than ever before to sacrificing the last great salmon run along with the regional economy and ecology dependent on it.

Now, we must work ensure that this unique landscape is permanently protected from development that is incompatible with salmon. Because mine permit applications can be resubmitted, Bristol Bay’s salmon remain under threat.

The United Tribes of Bristol Bay has called for Congress to establish a Bristol Bay national fisheries area. It would provide federal “protection for the watersheds of Bristol Bay, Alaska. It must permanently ban any toxic mine waste from the proposed Pebble Mine and large scale projects like it that would harm Bristol Bay rivers, lakes and wetlands.” The effort has already gained support from the Seattle Times, Commercial Fishermen for Bristol Bay, Alaska Audubon, and the Natural Resources Defense Council among others.

I wholeheartedly support this proposal. Congress and the State of Alaska should work together to permanently protect all of Bristol Bay’s headwaters from development that is incompatible with the protection of salmon. We’ve sacrificed freshwater salmon habitat for mining, irrigation, hydropower, roads, industry, and plain convenience nearly everywhere outside of Alaska and Bristol Bay. Meanwhile, climate change will make it harder for salmon to survive in places where runs already struggle. We and the ecosystems who depend on healthy salmon runs pay the price when they don’t return, and it’s a lot more expensive and difficult to restore salmon runs than to protect healthy runs in the first place.

Salmon are valuable for more than food and aesthetics. As conveyors of energy and nutrients from the sea, salmon enrich freshwater and terrestrial habitats. Ecosystems are more productive and wildlife more abundant in areas with healthy runs of wild salmon. Bristol Bay salmon support tens of thousands of jobs and the well being of the people who call the area home.

In the meantime, what can you do to help? If you have the time, write to your congressional representatives and urge them to permanently protect Bristol Bay. If you eat salmon, be sure to purchase salmon that is sustainably sourced (if you buy wild Alaska sockeye salmon, it’s very likely to be from Bristol Bay). And share the wonders of the Bristol Bay region with your friends and family.  While explore.org’s bearcams in Katmai National Park are offline for the winter, even the cam highlights show an ecosystem working at its full potential. It’s hard to not feel awe and wonder at the sight of bears competing for the opportunity to catch salmon.

On a societal level, 2020 hasn’t produced many celebratory occasions. We remain in the midst of a pandemic, one that is raging more than ever. Climate change hasn’t slowed one bit, and this year is on track to be one the warmest on record. The extinction crisis is worsening. Plus our partisan and political divisions are deeper than at any other point in my lifetime, hampering our collective ability to resolve these issues.

Stopping Pebble Mine now is significant and a cause for celebration. It underscores that we value clean water and sustainable fisheries.

But the fight isn’t over. Given the poor state of North American salmon outside of Alaska, with collapsed runs existing at small fraction of historic highs, Bristol Bay should be our line in the sand. It is the last great salmon run left on Earth and it cannot be compromised.

My Pebble Mine Draft EIS Comments

/ Mike Fitz / 12 Comments

As I’ve written before (here, here, and here) and commented on (here and here), Pebble Mine represents an unacceptable threat to Bristol Bay, home to the last great salmon run left on Earth. Through June 29, you can submit comments on the Army Corps of Engineers draft Pebble Mine environmental impact statement. I encourage everyone who cares about wildlife and wild places to comment. Tell the Army Corps of Engineers that this mine is unacceptable.

I also realize that not everyone has the time to read the draft EIS, which is huge, containing about 1,400 pages. So, I’ve copied my comments on the draft EIS verbatim below. You can also download a rich text file of the comments. I hope they inform your comments about Pebble Mine, the development of which would be a grievous mistake.

red salmon swimming in shallow water

Draft Pebble Mine Environmental Impact Statement Comments

I firmly oppose the development of Pebble Mine. The draft EIS (DEIS) fails to adequately address the mine’s short-term and long-term impacts. Additionally, its development would create several permanent hazards to the watershed, and the mine merely represents the first of many potential large-scale developments that will continually degrade salmon habitat in Bristol Bay. After reviewing the DEIS, I urge the Army Corps of Engineers to reject the permit application for Pebble Mine and select the no action alternative.

Permanent Mine Hazards

The mine and its infrastructure create several permanent environmental hazards. Two of these hazards, the open pit lake and tailings storage areas, are particularly concerning, because the DEIS does not provide adequate or convincing information on how these hazards can be contained indefinitely. For example, page 8 of the executive summary states,

“Pyritic tailings and PAG waste rock would be placed into the open pit for long-term storage below the pit lake water level. Once the material has been transferred to the open pit, the pit lake (i.e., the water that would accumulate in the open pit as a lake at closure) would continue to fill, and would be allowed to rise to the pre-determined control elevation threshold (about 890 feet). Once the level of the open pit lake rises to the control elevation, water would be pumped from the open pit, treated as required to meet State water quality standards, and discharged to the environment.”

This final stage of the open pit requires indefinite water treatment and discharge of water from the open pit. This is neither acceptable nor feasible in perpetuity since treatment facilities must be funded and maintained forever. Even if Pebble Limited Partnership is required to establish a bond to fund treatment, government solvency cannot be guaranteed over time spans necessary to treat wastewater from the open pit. Additionally, if costs to treat wastewater exceed the money available in the bond, then the burden to prevent contamination to the watershed will fall to taxpayers.

Page 8 of the executive summary also states,

“The bulk TSF would be closed by grading its surface so that all drainage would be directed off the TSF, and then the tailings surface would be covered with soil and/or rock and possibly a geomembrane or other synthetic material. This would prevent water from ponding on the TSF surface, and is known as a dry closure. Once this surface runoff from the bulk TSF is demonstrated to meet water quality criteria, it would be directly discharged to the environment.”

Since geomembranes have only been in use for 30 to 40 years, we lack adequate information on how they perform over the time span (essentially forever) necessary to keep the bulk tailings storage facility dry and prevent groundwater from leaching in or out. Simply covering it with soil, rock, and a synthetic membrane only delays groundwater contamination. It will not prevent it. The impacts of a degraded geomembrane leading to groundwater contamination are reasonably foreseeable but are currently unevaluated in the DEIS. The EIS needs to evaluate the impacts and timeline of a degraded geomembrane, not just presume that it will protect groundwater forever. It won’t.

Importantly, it is also completely unethical for a private corporation to create permanent hazards of this type. The mine has the potential to become another superfund site. If the Corps is to evaluate whether this project is in the public’s best interest, then it cannot ethically allow the creation of these hazards.

Scope of DEIS

The DEIS repeatedly presents information on best-case scenarios or merely states that something is “expected to happen” in an ideal way. For example, page 39 of the executive summary states,

“Water extraction activities would be required to meet the requirements of the Alaska Department of Natural Resources for temporary water use authorizations, and the Alaska Department of Fish and Game (ADF&G) for fish habitat permits (if issued). The rate and volume of water withdrawals would be monitored at each source to ensure permit requirements are met (as per permit stipulations). Therefore, the magnitude of the impacts to surface water resources is generally expected to result in changes in water quantity likely within the limits of historic and seasonal variation. The duration of the impacts is likely to be the life of the road, and the geographic extent of the impacts is likely to be relatively close to the road.”

Page 41 of the executive summary states,

“Overall, downstream impacts from pit lake level management during post-closure would not be expected.”

For another example, page 43 of the executive summary states,

“Under Action Alternative 1, impacts to water quality would generally be limited to the mine site area, within the zone of contact water capture and treatment, with potential minor exceptions of temperature and turbidity effects. Potential effects of contact and runoff water during construction of downstream water and sediment quality would be minimized through treatment prior to discharge, and would be expected to be minor.”

Statements such as these presuppose nothing will go wrong, ever, not with water treatment, not with the tailings storage areas, not with the fuel or the natural gas pipeline, not with the water extraction sites along the road. It downplays potentially significant risks. The DEIS does not adequately evaluate cumulative, foreseeable, long-term impacts.

Problems maintaining water quality can be expected over the life of the mine and are likely to increase after the mine is decommissioned. The mine will result in a net loss of spawning and rearing areas for salmon, and the habitat cannot be reclaimed. Throughout the DIES, the text downplays the ultimate impacts of the project. To gloss over impacts to the watershed in this manner represents a lack of due diligence on the part of Army Corps of Engineers and Pebble Limited Partnership.

Potential for Catastrophic Mine Impacts

While a credible worst-case spill from the mine, such as a tailings dam failure, is not likely in 20 years, if it were to occur the environmental effects would be devastating. The DEIS, again, neglects to include the possibility of unlikely–but foreseeable–catastrophic events. The agency’s review does not analyze a full breach of the tailings dams. It instead looks at a much smaller partial breach suggesting, “Action Alternative 1 and variants would not be expected to result in a longterm change in the health of the commercial fisheries in Bristol Bay or Cook Inlet.” (DEIS Executive Summary, page 54)

The potential for a tailings dam failure might have been calculated to be small (DEIS K4.15-16) over the near term, for example, but the risk cannot be eliminated and it will increase over time without additional mitigation measures. What is the likelihood of dam failure (large or small) over the next several hundred years? How would a catastrophic tailings dam failure impact the watershed, salmon, other wildlife, and the people who rely on Bristol Bay? This must be evaluated in the EIS. It is a reasonably foreseeable impact for this type of development since tailings dams fail frequently in the United States.

Impacts to Fish and Wildlife

The DEIS does not adequately evaluate the direct or otherwise foreseeable impacts on waters accessible to anadromous fish. As an example,

“The magnitude and extent of impacts, when compared to the total mileage of currently documented anadromous waters in the three tributaries associated with the mine site (i.e., the NFK, SFK, and the UTC), the loss of Tributary 1.19 habitat would represent 4 percent and 3 percent of spawning and rearing habitat for coho salmon, respectively; and 3 percent of Chinook salmon rearing habitat in these tributaries. In the context of the entire Bristol Bay drainage, with its 9,816 miles of currently documented anadromous waters, the loss of Tributary 1.19 represents an 0.08 percent reduction of documented anadromous stream habitat.” (Executive Summary, pg. 49)

Fish populations fluctuate significantly over many years and Pacific salmon utilize different habitats during different life stages. Some places in a creek are good for spawning but not rearing, for example. These habitats do not necessarily occur along a stream’s entire distance, nor do streams support salmon at the same rates consistently. Productivity within a watershed can fluctuate greatly over annual and decadal scales. As recent research1 on the Nushagak watershed demonstrated, entire landscapes stabilize biological production. Patterns of high and low production shift among locations throughout time. Simply acknowledging a stream supports anadromous fish does not adequately acknowledge the complexity of salmon habitat. Subsequent chapters in the DEIS do not present information on the type and relative importance of the habitat that will be lost. Therefore, the DEIS’ conclusions may not reflect the true importance of the stream miles impacted by the mine.

The quoted text is also written in a manner that minimizes the mine’s impact on fish (“In the context of the entire Bristol Bay drainage…the loss of Tributary 1.19 represents an 0.08 percent reduction of documented anadromous stream habitat.”). A more ecologically accurate measure would be to calculate this statistic as a percentage of the North Fork Koktuli River watershed. As I note above, not all anadromous streams are created equal. The North Fork Koktuli River watershed likely supports unique stocks of anadromous fish. Sacrificing .08% of Bristol Bay is not inconsequential and should not be written in a manner that suggests as much.

Regarding the transportation corridor, each of the DEIS alternatives are flawed due to the lack of information on the infrastructure impacts on fish and wildlife. For example, the DEIS does not address whether shipping across Lake Iliamna will impact harbor seals. The seals who live in Lake Iliamna are a unique population2. They live their entire lives in freshwater and have never experienced consistent shipping traffic on the scale proposed. The DEIS, therefore, needs to evaluate the impacts of shipping on wildlife in Lake Iliamna.

Water Extraction

At the mine and along the proposed transportation corridor, dozens of “water extraction sites” are proposed, pumping hundreds of millions of gallons of combined from surface features such as ponds, lakes, and streams (DEIS 2-58, 2-59, 2-96, 2-111). The pumping will continue year-round for the lifespan of the mine, and potentially longer as long as the infrastructure exists. However, I was unable to locate information in the DEIS on the impact of water extraction. Text on water extraction cites Appendix K2, which only includes a table about the estimated extraction rate per year.

There is no analysis of the impact of removing 500-1000 gallons per minute from dozens of surface water features. Are the streams identified for water extraction included in Alaska’s anadromous fish catalog? How will each stream react to that level of water removal? Flow rates in Bristol Bay streams vary greatly across seasons. Can the proposed extraction rates be maintained during years of drought or during winter when flow rates are low with no significant impact on aquatic habitat?

Each water feature is hydrologically unique and should be evaluated separately. A lack of evaluation on water extraction on fisheries and wildlife is a major flaw in the DEIS.

Long-term infrastructure use by communities

The DEIS states in several places that mine infrastructure will improve the quality of life for some communities.

“As described in Section 4.12, Transportation and Navigation, Alternative 1 would result in the construction of roads and ports. Although the road and port would have limited access, PLP has stated that they would work with all local communities to identify the best solutions for controlled-access use of the road and ferry for community transportation. Communities adjacent to the natural gas pipeline (Kokhanok, Newhalen, and Iliamna) would have the opportunity to connect to the pipeline. During operations, PLP would work with local communities to identify safe, practicable ways for residents to use the access roads, such as scheduled, escorted convoys for private vehicle transport.” (4.4)

“Communities adjacent to the natural gas pipeline (Kokhanok, Newhalen, and Iliamna) would have the opportunity to connect to the pipeline. Natural gas would likely be less expensive than diesel heating oil, which could lower the cost of living once equipment (e.g., furnace, water heater) is converted to natural gas” (4.4-5)

However, the DEIS repeatedly states that infrastructure will be abandoned or removed after 20 years.

“If no longer required at closure, the pipeline would be cleaned and either abandoned in place or removed, subject to state and federal regulatory review and approval at the decommissioning stage of the project. Surface utilities associated with the pipeline would be removed and reclaimed.” (Executive Summary, pg. 13)

Due to the high cost of living in the area, communities along the infrastructure corridor are likely to use the access road and the natural gas pipeline as soon as they are permitted to do so. These same communities wouldn’t want to give it up that access after 20 years. Therefore, the likely impacts of a natural gas pipeline and roads are not limited to 20 years. Impacts extend indefinitely. The DEIS should be revised so that it evaluates the impacts of a potentially permanent pipeline and road corridor.

Potential for Larger Mine

The DEIS is a rough evaluation of a mine with a 20-year lifespan, but that is one of the least likely development scenarios. If Pebble Mine is permitted to be developed, then it will open the door for an expanded and much larger mine that will operate for nearly 80 years as well as several other large-scale mineral prospects. The DEIS acknowledges this on page 4.1-8 when it states the Pebble Project Expansion is “reasonably foreseeable” and “would develop an additional 58% of mineral deposits”. The impacts of a much larger Pebble mine and a mining district in the headwaters of Bristol Bay are potentially exponentially greater compared to the mine proposed in the DEIS. This will cause irreparable harm to Bristol Bay’s fishery.

The potential for an expanded mine also increases the likelihood that the Pebble’s supporting infrastructure will remain in place indefinitely. The infrastructure is unlikely to be reclaimed as outlined in the DEIS. It will be used to service not only the larger Pebble Mine but others as well. This will lead to a cumulative degradation of salmon habitat, greater impacts to other species of wildlife, and greater risk for Bristol Bay’s fishing industry and culture. Although it’s not possible for the DEIS to evaluate the impacts of all foreseeable project expansions and other mines, the likelihood of this should at least be acknowledged more prominently, ideally in the executive summary. As currently written it is buried in Chapter 4 and easy to overlook.

In support of the No Action Alternative

Large scale development, especially open-pit mining, is incompatible with salmon habitat. We know this because large scale development has significantly degraded salmon runs and salmon habitat across much of the North Pacific and North Atlantic. Bristol Bay harbors the last great salmon run on Earth. If Pebble Mine is developed, then we will have acknowledged we have learned nothing from the collapse of salmon runs in New England, California, Oregon, or Washington.

The DEIS is largely based on Pebble Limited Partnership’s data. With so many flaws in the DEIS, it’s clear that the applicant’s plan is inadequate and has not met the burden of information necessary to justify their plans.

The cheapest, most feasible, and most environmentally ethical decision is to conclude this mine poses unacceptable risks to Bristol Bay—specifically the Nushagak and Kvichak watersheds—reject the mine alternatives, and choose the no action alternative for the final EIS. This is well within the Corps’ legal authority: “No Action Alternative could be selected if USACE determines during its Public Interest Review (33 CFR Part 320.4[A]) that it is in the best interest of the public, based on an evaluation of the probable impacts of the proposed activity and its intended use on the public interest.” (Ch. 2-8)

Although modern society uses rare earth minerals like gold and copper in many ways, civilization will not collapse if Pebble Mine is not developed. We won’t even be inconvenienced. If developed though, Pebble Mine represents the beginning of the end of Bristol Bay’s salmon. Mining impacts won’t cease after 20 years, and the hazards cannot be mitigated in perpetuity. The infrastructure is a beachhead for a larger scale Pebble Mine as well as many others in the region. The cumulative impacts of each mine will result in the net loss of larger and larger percentages of available anadromous fish habitat. On no metric does the value ore at Pebble exceed the value a healthy Bristol Bay watershed, its tens of millions of spawning salmon, and the economy and culture based on it.

There is no doubt the no action alternative is in the best interest to the public. We have so little to lose by leaving the ore at Pebble Mine in the ground and so much to gain by protecting it for current and future generations. The decision is clear.

The only acceptable alternative proposed in the DEIS is the no-action alternative. Do not permit this mine to be developed. If you do, it will become one of the greatest environmental tragedies of the 21st century, representative of our failure to do what is right by the land, the fish, and the people of Bristol Bay. It will become a monument to human greed and hubris.

Sincerely,
Michael Fitz
Concrete, WA
May 24, 2019

  1. Brennan, S. R., et al. Shifting habitat mosaics and fish production across river basins. Science. Vol. 364. Issue 6442. 24 May 2019
  2. Brennan, S. R., et al. Isotopes in teeth and a cryptic population of coastal freshwater seals. Conservation Biology. Accepted Author Manuscript. 2019. https://doi.org/10.1111/cobi.13303

 

 

 

Bristol Bay at Risk

/ Mike Fitz / 10 Comments

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

/ Mike Fitz / 2 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

/ Mike Fitz / 3 Comments

“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.