June 5, 2019
Col. Phillip J. Borders
U.S. Army Corps of Engineers – Alaska District
645 G St.
Suite 100-921
Anchorage, AK 99501
Re: Public Input on the Proposed Pebble Mine Project (POA-2017-271)
Dear Colonel Borders, Mr. McCoy, and Ms. Newman:
The undersigned entities, which represent hundreds of thousands of sportsmen and sportswomen,
provide these comments requesting that the U.S. Army Corps of Engineers require from the
Pebble Mine applicant all the information necessary to reach a fully informed permitting
decision. We further request that the ongoing administrative process to consider the Pebble Mine
permit application be suspended until this vitally important additional information is received.
Sportsmen and sportswomen strongly support an appropriate role for federal-level deliberation
and analysis of the varied views and scientific aspects of land and water use decisions. This type
of deliberative process is especially vital in situations such as the proposed Pebble Mine, given
the significant and potentially long-lasting threats it could pose to one of the foremost sport
fishing and hunting regions in the world. Specifically, a robust, deliberative, and informed public
process cannot occur on the Pebble Mine permit application without a mine economic feasibility
report and environmental baseline studies for Bristol Bay and Cook Inlet.
It is important to note that the permitting decision on Pebble Mine is about far more than
choosing between natural resource development and the environment. It is also about ensuring
that impacts created by one natural resource dependent industry do not displace or
disproportionally impair another. Sport fishing and hunting contribute more than $60 million
annually to Bristol Bay’s regional economy and support thousands of jobs. Additionally, all
anglers depend on healthy populations of Bristol Bay’s five salmon species (including its famed
run of sockeye salmon) in order make a living and feed their families.
In previous communications to the Army Corps, we have requested that the Corps conduct a fair,
rigorous, science-based permitting process. We have also shared our concerns about the Army
Corps’ rushed timeline and missing information in the Pebble Partnership’s permit application.
The Draft EIS released on February 20, 2019 only reinforces our concerns. Accordingly, we
submit the following comments to the Draft EIS for the proposed Pebble Mine in Alaska:
• Size of proposed mine. The DEIS should look at the environmental impacts of a larger
mine as an action alternative given that Pebble has made clear it plans to mine the nearly
11-billion-ton deposit in Bristol Bay over time. Applicable law requires the Corps to
consider all impacts including direct, indirect and cumulative impacts that are reasonably
foreseeable, yet none of the action alternatives in the DEIS consider the potential for
future expansion. While the DEIS recognizes that the cumulative impacts of mining the
entire deposit must be analyzed, the DEIS fails to do so. The Corps should consider the
cumulative impacts of mining the entire deposit and not just review the initial phase of
development that is contemplated by the pending permit application.
• Thorough and realistic analysis of a potential tailings dam failure. The tailings dam
failure assessment in the Draft EIS is inadequate and only looks at a small fraction of
what is possible and likely to occur over the lifespan of the mine. Given that the tailings
dam will be a permanent structure that exists in Bristol Bay in perpetuity, it is critical that
the Army Corps look at the full range of impacts and increased probability of failure over
time.
• The Draft EIS is inadequate because it lacks an economic analysis of potential
impacts to already existing industries and businesses. This includes but is not limited
to the outdoor recreation and seafood industries, which depend on Bristol Bay’s intact
habitat and clean water. Given Bristol Bay’s reputation for pristine wilderness and pure,
wild seafood, the Draft EIS must look at Pebble’s impacts on the public perception and
market value of the “Bristol Bay” brand.
• The Draft EIS is inadequate because it lacks a mitigation plan that includes
compensatory mitigation for Pebble’s adverse impacts on the Bristol Bay watershed.
The proposed Pebble Mine threatens thousands of existing jobs, businesses, and
industries that depend on the productivity of Bristol Bay’s salmon populations. The Draft
EIS needs to include details about how Pebble will address its adverse impacts on the
entire Bristol Bay watershed.
Given the continued shortcomings of the permitting process, we once again ask the Army Corps
to suspend its review until the Pebble Partnership delivers sufficient environmental baseline and
economic data, including cumulative data, as well as a comprehensive mitigation and
reclamation plan. The NEPA process should ensure transparency and a thorough analysis of
environmental impacts, especially in places like Bristol Bay that provide irreplaceable public
goods and benefits. In that light, especially, sportsmen and women and others whose livelihoods
are inextricably linked to the rich natural treasures of Alaska’s Bristol Bay are entitled to
understand and comment on every aspect about this proposed mine and its expected impacts
during the permit review process. The undersigned entities request that the Army Corps pause its
review of the Pebble Partnership’s permit application until additional essential information is
provided.
We appreciate your consideration of the future of Bristol Bay’s tremendously productive lands
and waters. Individual organizations signed on below may submit further comments for the Draft
EIS record.
Sincerely,
American Fly Fishing Trade Association
American Sportfishing Association
Bass Pro Shops
Camp Fire Club of America
Coastal Conservation Association
Congressional Sportsmen’s Foundation
Delta Waterfowl
Fly Fishers International
Guy Harvey Ocean Foundation
Houston Safari Club
International Game Fish Association
Izaak Walton League of America
Marine Fish Conservation Network
Mule Deer Foundation
National Wildlife Federation
The Orvis Company
Pheasants Forever
Pope & Young Club
Quail Forever
Quality Deer Management Association
Shimano North American Holding Inc.
Simms Fishing Products
Theodore Roosevelt Conservation Partnership
Trout Unlimited
Wild Sheep Foundation
Wildlife Forever
Yamaha U.S. Marine Business Unit
