From: Les Gara, 1242 W 10th Ave, Anchorage, AK 99501; firstname.lastname@example.org.
Date: June 7, 2022
Re: Action Needed Because Alaska’s Governor Won’t Prevent Toxic Pebble Proposal; All Laws Needed To Protect Bristol Bay Salmon and Communities.
Docket Number EPA–R10–OW–2022–0418
1. The Pebble Mine is a Toxic Danger to the World’s Greatest Wild Salmon Waters and Runs, and to World Class Wild Rainbow Trout and Grayling and Other Fish
In a normal case I’d look to state law to protect Alaska’s people and the fish we rely on. A vast majority of Alaskans oppose this project, as it poses a great risk to livelihoods, food, fish, and to a way of life for people in the Bristol Bay Region, and even outside the region. Alaskans care about fish, and are unified on the protection of our fish runs.
But in this case Alaska has a Governor who has explicitly spent state money to side with the Canadian Pebble Mine project owners, and stood against Alaskans in favor of the unacceptable risk this mine poses to people, and the fish and water Alaskans rely on. Therefore, Alaskans need to look to every available law that would protect them from a toxic mine at the headwaters of the world’s greatest remaining wild salmon runs. I therefore submit these comments.
I would note that I’ve opposed this toxic danger to Alaska’s fish during my career as an Alaska legislator, and that this remains my position today. I should note I am running for Governor in the State of Alaska, and hod the same views on this danger to Alaska’s fish as I have for over a decade as a legislator.
I would also note that the term “veto” – normally used when the EPA is asked to overrule an Army Corps of Engineers permit – does not seem to apply here, as Corps did not issue a permit under the Trump Administration.
This is a rare case of a major project that the last two elected Presidents of the Unites States, from different parties, and their agencies, have opposed, underscoring the common assessment that this mine is a danger. That, you know. What you may not know is that the threat of this project has hung over the heads like a dark storm cloud for over a decade, and Alaskans want that to stop. I ask that you not delay a decision on this project, and recognize the uncertainty and stress this proposed project has caused many in the Bristol Bay region.
This proposed project poses what the law considers “unacceptable adverse effects” to the area’s world’s greatest salmon runs, the people who rely on them, and the waters in Bristol Bay.
Not only are its size and danger exceptional, but it is a project that involves dams that pose an additional risk of breach given that region, and much of Alaska, are earthquake-prone. That adds to the risk that any dam will breach.
Alaskans have supported responsible mining. This is not a responsible mine project. Both the actual proposal, and the one Pebble Partnership has pretended to “scale back”, with public admissions that the full, vastly larger project will follow, violate legal clean water and fish protections.
The chemical processing and on-site storage, even of the vastly understated, deceptively “scaled back” 1.4 billion tons of earth and toxic waste ore, puts Bristol Bay, and the livelihoods and interests of the Bay’s residents (most of whom oppose it) at risk for generations.
That will be the most waste rock stored at any open pit mine in Alaska, and appears to be the most waste ore (definitely among the most) of any open pit mine in the United States.
Last year 66 million sockeye salmon returned to Bristol Bay.
The Nushugak River, which would be put at risk by a catastrophic spill, is home to Alaska’s largest wild King Salmon returns. In evaluating this mine proposal, the law requires an evaluation of potential fisheries impact from mine pollution. The highest quality wild salmon run in the world requires that the risks posed by this mine be smaller than risks posed in parts of the nation where a toxic leech would cause far less damage to people, a way of life, or wild fish.
Endless comparisons can be made to other mines, some that have had catastrophic failures after false promises of foolproof safeguards, and some that have not. But none of those are located by communities where the way of life is tied to the world’s greatest wild salmon runs. Even if you didn’t think this was the wrong mine in another area, it is in the wrong place . The risks are too great given the reality of the damage that is threatened by this project..
Salmon are a crucial species of fish to Bristol Bay Residents, and fishing for subsistence, commercial and sport use. Legally, the impact on all important species of fish in these drainages must be considered. Nationally and locally important wild fish species that grow to magnificent sizes include wild rainbow trout, wild char, wild grayling and other fish which are important fish species to Alaskans and Americans who visit this region to catch those fish, or who just value salmon and non-salmon species of fish in their wild state. And mammals that rely on these fish must be considered. The impacts on bears and other animals, including bird life, must be considered.
As you know, the Pebble project owners have improperly segmented the project into phases. Both the falsely reduced size of the first segment, and the 800% larger full project violate the law. The first “phases” is dangerous enough, but this also the tip of the Titanic.
The CEO of the foreign mining corporation, Northern Dynasty, which runs the “Pebble Partnership”, admitted at a 2019 investor conference that Pebble will be expanded far beyond Phase One’s 1.4 billion ton waste ore project – after they get their nose under the tent.
Northern Dynasty’s CEO called expansion of the mine after Phase 1 the “whole purpose” of this project at a February, 2019 investor and mining forum in Denver, where they were pitching the project to possible investors. That explains why Northern Dynasty lists the size of the mine with Canadian regulators at 11 billion tons of removed ore and earth, or eight times the size of this first phase project.
That would be the largest toxic open pit mine in North America. I feel this reality should also factor into the decision in this case.
2.Risks Posed By The Mine to Bristol Bay Residents, Commercial, Subsistence and Sport fishermen and women, and the World’s Greatest Remaining Wild Salmon Fishery.
Two toxic and potentially fallible tailings dams are proposed. That’s where most of the removed earth and the toxic ore, plus tons of added water that will add stress to the “protective” dam walls, will be stored. Until they fail, as many expect, they’ll “permanently” hold heavy concentrations of pyrite (which turns to sulfuric acid when exposed to air and water). The world has seen catastrophic dam breaches from smaller mines, without an earthquake. I’m not willing to risk the highest quality wild fisheries in the world with a larger dam in an earthquake-prone region. As the Exxon Valdez reminds us, spills happen.
These toxic open, uncovered tailings dams will cover a massive 3,700 acre area. That’s just for the false Phase One Project that will be multiplied in size by 800% when it is transformed into the full project Pebble concedes it will pursue.
The major danger is that they will leach, and toxins will find their way to two of Bristol Bay’s major drainages, the nearby Koktuli River and Upper Talarik Creek. Upper Talarik drains into Lake Iliamna, the Kvichack River and then Bristol Bay. The prized Koktuli drains into the Mulchatna and then Nushugak Rivers before hitting Bristol Bay.
This “smaller” Phase One open pit mine will also return 6.8 billion gallons of treated wastewater every year back into these drainages.
What else? Water will be taken from Upper Talarik Creek and the Koktuli, as groundwater and 80 miles of streams will be filled and destroyed.
The main commercial ores the mine is intended to produce are copper and gold. Leeching copper has been scientifically proven to damage salmon by impairing their ability to find their rearing streams.
Other questions remain beyond the breach of a dam and the removal of water from these streams.
How many earthquakes can be expected in the future, and or what magnitude?
How much pyrite dust will blow into flowing waters in this often windy region from the mine? That is not assessed.
Also, how safe is transporting ore across a windy, pristine Lake Iliamna? That is not assessed.
How often will there be human error, or dangers that come with cost saving efforts that have been proven to result from a pay structure upper level management will receive? The danger goes up as employees are paid more for cutting costs, and in many instances, cutting corners.
How safely will the toxic chemicals used in the initial ore separation on-site be handled and stored, in an area of wetlands and streams and wind that can carry toxins downstream?
The vast majority of Alaskans oppose this mine. The vast majority of Bristol Bay Residents oppose this mine. Their fears toxic leakage and toxic damage to greatest remaining wild salmon runs on this earth are justified.
This mine should not move forward.
P.S. – Out of caution I add these words under Alaska’s campaign laws, though I believe this statement is not required for a public comment:
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