Pebble Watch Guide

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A reference guide to the issues, featuring a compilation of previous Pebble Watch articles - all in one place.

Impartial, educational & fact-based information about the proposed Pebble mine


Understanding the basics

Public input How, why & when


The players & the process

Putting facts first The proposed Pebble mine has dredged up strong emotions and no small amount of controversy. The potential for effects from a largescale copper mine operation has stirred concerns about the safety and even survival of Bristol Bay’s world-class sockeye salmon runs. As with any such issue, sometimes the facts become secondary; the science becomes clouded in emotion. Bristol Bay Native Corporation created Pebble Watch in December 2011, and built a team of scientists, and communicators, as well as experts in land management and permitting. With funding from BBNC’s Land Department, this team is tasked to review scientific data being compiled in relation to the proposed mine, as well as related legislation and regulations, and present the facts to the general public. To meet this goal, Pebble Watch has created several newsletters and special publications, in addition to a website rich with resources and links

to a variety of information for further study. It also has a growing Facebook presence. Pebble Watch does not seek to sway opinion one way over another. The team works to provide a balanced view so that readers can stay upto-date on the Pebble project’s development and permitting process, including how to access and understand available resources and scientific data. It also covers public input, providing information for public comment opportunities, including dates, tips on making effective comments and links to additional resources. With this publication, Pebble Watch has pulled from its past work to gather relevant topics into a single document for ease of use. Readers will find information on the overall debate, as well as details on Alaska’s mining permit processes, and the scientific research on Bristol Bay’s fisheries habitat. We’ve also included helpful maps, short articles on the salmon-based cultures observed by the Alaska

Native peoples who live in the region, and a look into the world-class fishery and the recreation and tourism it draws. This issue is a resource that can be referenced again and again for a broad overview of the concepts and terms that we will hear more about during upcoming discussions on Pebble Limited Partnership’s mine plan, during the permitting process, and during the U.S. Environmental Protection Agency’s efforts to finalize its Bristol Bay watershed assessment. Whether you favor or oppose the proposed Pebble mine, these materials will give you a common language and solid grounding on the issues. BBNC and its Land Department are dedicated to continuing this effort throughout this process. We welcome your feedback and suggestions for future publications.

Jason Metrokin President and CEO Bristol Bay Native Corporation

Bristol Bay Native Corporation (BBNC) is a responsible Alaska Native investment corporation dedicated to the mission of “Enriching Our Native Way of Life.” Established through the Alaska Native Claims Settlement Act of 1971 (ANCSA), BBNC works to ensure the continuation of the life and culture of its over 9,300 shareholders — the Eskimo, Indian and Aleut Natives of Southwest Alaska’s Bristol Bay region. For more information, visit


contents About Bristol Bay History and culture, subsistence, economy.............................3 World-class fishery..................................................................4 Biodiversity..............................................................................6 Influence of salmon.................................................................8 Land & tourism......................................................................10

About the proposed Pebble Mine Who, what, why, when, where...............................................12 The deposit...........................................................................14 Mine design and construction...............................................15 Permitting process................................................................16 Permitting claims...................................................................18

Studying the environment Bristol Bay studies.................................................................19 Peer review...........................................................................19

EPA Watershed Assessment Watershed assessment overview..........................................20

PLP studies Environmental Baseline Document........................................22 Keystone dialogue process...................................................23 Soil & sediment.....................................................................24 Geotechnical & seismic studies.............................................26 Meteorology..........................................................................28 www.facebook/pebblewatch Produced by the BBNC Land Department Questions? Call (800) 426-3602 or email: Photo credits: All photos by Bristol Bay Native Corporation unless otherwise credited.

Wetlands...............................................................................30 Water quality.........................................................................32 Hydrology.............................................................................34 Water interactions.................................................................36 Fish & aquatic invertebrates..................................................38 Fish habitat...........................................................................40 Visual resources & recreation.................................................42 Importance of landscape.......................................................43

Learn more Adding your voice/public input..............................................44 Pebble mine debate..............................................................46

Bristol Bay The Bristol Bay region is located in Southwest Alaska. Its 31 villages are situated along vast waterways leading to the eastern arm of the Bering Sea.


History and Culture


Aleut, Alutiiq, Athabascan and Yup’ik Eskimos have made the region their home for the past 10,000 years. Just over 200 years ago, the explorer Captain Cook named the area “Bristol Bay” in honor of an English Admiral. The name stuck. Even though the land is referenced by a modern name, residents of Bristol Bay continue to observe the traditions, languages and subsistence ways of their ancestors— along with influences from explorers and fur traders, missionaries, commercial fishermen and aviators.

The Bristol Bay watershed has long been known for its amazing sockeye salmon runs. Predictions for 2013 are down from previous years, but a harvest of over 16 million sockeye will still feed people all over the world. Aside from government jobs, the commercial fishing industry is the largest driver of the economy in Bristol Bay. And that industry makes a big impact state-wide as well. Between one-third and onehalf of Alaska’s total salmon fishing earnings come from Bristol Bay.


During the busy summer months, the population swells in Bristol Bay, as commercial fishermen, cannery workers, sport fishermen and tourists descend on the region to make the most of the summer light and the endless fishing.

The Native peoples of Bristol Bay have always cultivated a close connection to the land­­. More than a simple activity, subsistence is an entire lifestyle. In Yup’ik, they call it Yuuyaraq, the Way of Life. Long ago, hunting wildlife, catching fish and gathering edible plants and berries were time-intensive skills, critical to survival. A subsistence lifestyle today still requires an investment of time and money, and is still seen as an important value. Passing knowledge and traditions on to younger generations is important for Elders, who see spiritual benefits from a connection to the land, and health benefits from natural foods and the physical activity associated with getting them. Perhaps the most important subsistence activity centers around salmon, making the people of Bristol Bay one of the few remaining salmonbased cultures on Earth.

Mineral exploration, particularly at the proposed Pebble mine, has brought new attention to the area. Rich mineral deposits are as notable for geologists as salmon runs are for fishermen. In fact, there are several mining claims in the region that are currently being explored. Tourists, particularly to state and national parks, are contributing more than ever to the local economy. Cultivating a robust tourism industry is challenging due to the remoteness of the area and lack of infrastructure. However, it is seen as a viable way to improve the local economy.

The foundation of the Bristol Bay region is committed families, connected to our land and waters. We believe future generations can live healthy and productive lives here. Across our region, we share common values of community, culture, and subsistence. We see a future of educated, creative people who are well prepared for life.

– from the Bristol Bay Regional Vision, 2011,

About Bristol Bay

In brief • At 40,000 square miles, the Bristol Bay region is larger than 15 U.S. states. • Bristol Bay is home to 17 state and federal parks, refuges, sanctuaries and critical habitat areas, including the largest state park in the U.S. (WoodTikchik). • According to the U.S. Census, estimated population in the three Bristol Bay census areas was 7,673 in 2011 (with around 64 percent identifying as American Indian/Alaska Native). • The Bristol Bay Online website identifies many original names for locations and landscape features in the area: • Iliamna Lake is Alaska’s largest lake; it’s the 8th largest in the U.S. Its Denaina name, Nila Vena, means “island’s lake.”

Salaries earned in the Bristol Bay region

Government Seafood processing Services Transportation, communications, utilities Retail trade Other Source:


World-class fishery

Economy, ecology, heritage Economy Salmon are the lifeblood of Bristol Bay—a resource that can be quantified by volume and dollar value. When it comes to sockeye salmon, Bristol Bay provides about half of the world supply. Expand the criteria to include all kinds of wild salmon (kings, reds, silver, pinks), and Bristol Bay’s salmon harvest accounts for 7 percent of all world salmon catches. Factor in farmed salmon, and Bristol Bay’s contribution still represents 3 percent of world harvests.

The economics of the fishery benefit thousands of people. From subsistence and commercial fishermen to seafood processors and recreational fishing guides, about 9,600 full-time equivalent jobs are directly dependent on the wild salmon ecosystem. The payroll value of Bristol Bay wild salmon is significant ($283 million, according to an April 2012 report on the economic value of wild salmon ecosystems, coauthored by Bioeconomics, Inc. and the University of Alaska Institute of Social and Economic Research). The recreational fishery in Bristol Bay inspires about 29,000 sport fishing trips annually, with Bristol Bay

residents averaging nearly 12 trips each. While out-of-area residents have fewer trips, they end up spending more in the area for travel, supplies, lodging and food. Overall, Bristol Bay anglers spend approximately $58 million within the Bristol Bay economy, with $47 million of that spent by nonresidents. Subsistence fishing activities, which take place mainly in the Nushagak and Naknek-Kvichak river drainages, add direct spending and indirect savings to the economic health of the region. More than $7 million was spent in 2005 on subsistence fishing activities. If residents were not able to harvest subsistence fish,

“It’s not just locals who know about the importance of Bristol Bay, America’s ‘Fish Basket.’ The Alaska brand in seafood marketing is huge.” – Laine Welch, columnist and broadcaster covering Alaska fishing news


“Anybody in the salmon world knows about Bristol Bay fisheries. It’s very big by any standard. It’s legendary for the sheer size of harvest, and it’s extremely valuable for the hundreds of millions of dollars it brings in for wholesale value of fish produced.” – Gunnar Knapp, Professor of Economics, ISER, University of Alaska Anchorage

the replacement value of that food could add up quickly, as detailed in a November 2009 report from Alaska Department of Fish and Game by James A. Fall, Theodore M. Krieg, and Davin Holen. “An Overview of the Subsistence Fisheries of the Bristol Bay Management Area” showed that in 2005, the annual wild food harvest per household in Koliganek was 2,139 pounds. About half of this was wild salmon. At a replacement cost of $7 a pound, a household without subsistence salmon would have to spend more than $7,000 on other foods throughout the year.

An ecologic anomaly The long-term sustainability of Bristol Bay’s fish population sets it apart from other fisheries around the world. “A large part of the sustainability of the Bristol Bay system comes from the fact that there are a lot of fish populations in a number of lakes, each with different habitat needs and

About Bristol Bay

life history patterns,” says Thomas Quinn, a professor in the School of Aquatic and Fishery Sciences at the University of Washington. “When conditions are unfavorable for some, they are favorable for others, so the whole system is much steadier than any of the individual components.” Compare this to the Lower 48, where many salmon populations have dwindled, or are already extinct. “The remaining populations swing up and down in abundance with little to buffer them,” Quinn says. Along the Pacific Northwest and California, an estimated 29 percent of the 1,400 historical salmon populations are extinct, with another one-third of the remaining populations threatened or endangered. In the Bristol Bay region, none of the salmon species is extinct.

Heritage from the sea When the fish return each year

to Bristol Bay, Alaska Natives reconnect with a history that goes back thousands of years. Subsistence fishing activities provide a common bond across generations through the sharing of work and the handing down of stories and techniques. This traditional lifestyle strengthens communities materially, socially and nutritionally. “Values that support families and communities are expressed, emphasized, and taught during the harvest, preparation and sharing of wild foods,” stated the authors of a 2009 Alaska Department of Fish and Game report. Even though much has changed in the last century, “subsistence activities and values remain a cornerstone of area residents’ way of life, a link to the traditions of the past, and one of their bases for survival and prosperity.”



The portfolio effect Scientists are understanding just how essential biodiversity is to a healthy ecosystem. When there are several different species of one type of plant, animal or fish, the chances are better that the entire group won’t get wiped out during stressful environmental conditions. Bristol Bay is home to all five species of Pacific salmon: humpy, chum, sockeye, coho and chinook. But what makes the Bristol Bay salmon fishery unique and successful is the diversity found even within a single species. Scientists from the University of Washington have been studying Bristol Bay sockeye salmon for five decades. Two of them, Daniel Schindler and Thomas Quinn, have documented the importance of this “population diversity,� noting that there are several hundred different populations of salmon that have adapted to differing conditions in the lakes, rivers and tributaries of Bristol Bay. Differences include the types of spawning areas (beaches, creeks, rivers) they choose, and in the timing of smolt and adult migration. Schindler and Quinn make a direct connection between this diversity and the success of the fishery. For example, the fact that the migration time is staggered lengthens the window of time in which fish can be harvested and reduces the chance that too many numbers will overwhelm the capacity of the fishing fleet and the processors. The stability of the runs makes it much easier to plan for and capture the maximum number of fish allowed. U. S. Fish & Wil

dlife Service


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Online resource

Photo: U.S. Fish and Wildlife Service/ Togiak National Wildlife Refuge


This coloring book produced by the U.S. Fish and Wildlife Service helps kids easily understand the salmon life cycle and the differences between salmon types that live in Bristol Bay. Visit for a link.

Biological diversity—or biodiversity—is a term that has been in use only since the late ’60s, although the concept of “species diversity” or “species richness” has been around much longer. “Variability in annual Bristol Bay salmon returns is 2.2 times lower than it would be if the system consisted of a single homogenous population rather than the several hundred discrete populations it currently consists of,” they wrote. “Furthermore, if it were a single homogeneous population, such increased variability would lead to ten times more frequent fisheries closures.” Schindler and Quinn liken this species variability to portfolios in the financial world. Financial advisors are always telling us to diversify our investment portfolios. This is in order to protect our overall assets in case any one type of stock or bond doesn’t work out.

“What we have here is truly exceptional in the realm of salmon: The Bristol Bay fishery has been sustainable for over a century and gives every indication that it will be so in the future.” – Thomas Quinn, Professor, School of Aquatic & Fishery Sciences, University of Washington

This comparison makes it easy to understand why biodiversity is important for ecosystems. When there is variability in the species, it is better able to absorb the impact of changing climates and loss of habitat. According to Schindler and Quinn, the diversity of the Bristol Bay salmon is due in part to a landscape that is mainly undisturbed, with natural water flow, no invasive species and no hatchery-bred salmon (which reduce diversity). In this way, we understand scientifically what fishermen have known instinctively for thousands of years—a successful fishery is directly connected with the quality of land and waters of Bristol Bay.

About Bristol Bay


Influence of salmon

Drying salmon, North shore, Aniakchak Bay, July 1973. Photo: National Park Service

“We want to give to our children the fish, and we want to keep the water clean for them … It was a gift to us from our ancestors, which will then be given to our children.” ­­ – Elder interview, Boraas/Knott report

Salmon-based culture For the people of Bristol Bay, wild fish and clean water are more than healthy food sources. They are a connection to the past, inspiration for art, shapers of language, and resources full of spiritual meaning.

Nushagak and Kvichak Watersheds, Alaska” includes information from multiple resources, and excerpts of interviews with 53 Elders and culture bearers from seven Bristol Bay communities.

The strong influence of salmon on cultural practices and belief systems makes the Dena’ina and Yup’ik among the last salmon-based cultures in the world. The U.S. Environmental Protection Agency (EPA) draft Bristol Bay Watershed Assessment includes a lengthy article about these cultures, written by Alan Boraas and Catherine Knott, both anthropology professors at Kenai Peninsula College.

Interviews illustrate that belief systems of the Dena’ina and Yup’ik peoples are tied directly to water and salmon. Common beliefs include:

“Traditional Ecological Knowledge and Cultural Characterization of the 8

• To be healthy, people need salmon and other wild foods. • Salmon are shared with family and friends, and people feel good when they give or receive salmon. • It is important for families to fish together. • Salmon and streams both have

Learn more • Read the full Boraas/Knott study at (under “Resources”). • Watch for an analysis of data on subsistence and traditional knowledge from 20 Bristol Bay communities to be published by the Pebble Limited Partnership as part of its Environmental Baseline Data. • Explore resources provided by Bristol Bay Native Corporation, including,, and

Mending nets in Dillingham, June 2012.

spirits. When the first salmon of the season is caught, people give thanks through prayer and an offering. Eating fish that is connected to fish one’s ancestors ate is important to Yup’ik and Dena’ina descendents living today, write Boraas and Knott. The researchers cite studies saying people can become genetically changed from eating the same salmon in as little as 3,000 years. Salmonbased traditions go back thousands of years. Ancestors of the Yup’ik peoples relied on salmon as an important part of their diet as long as 4,000 years ago. “Evidence is building that Yup’iks are biologically adapted to salmon,” wrote Boraas and Knott. Moreover, an active subsistence lifestyle and high intake levels of omega-3 fatty acids from fish are important factors for good cardiovascular health. As one Elder noted, “If we don’t eat fish, we won’t have anything to eat. That is our health.” The Yup’ik and Dena’ina languages include very specific vocabulary

About Bristol Bay

related to fish and water, which further emphasizes their cultural importance. For example, in Yup’ik, the word aciirturtet means “the first group of king salmon running under the smelt.” This is just one of several cultural terms included in the Boraas/Knott study. The Dena’ina language has similar descriptive terms about fish, and also explains physical directions in relation to streams. Instead of using markers like “north” or “south,” the Dena’ina people would describe a location in terms of whether it was upstream or downstream of a particular spot on the river.

are examples of spiritual activities that hold great meaning for these Native cultures. As the Boraas/Knott study shows, the health of the Bristol Bay fishery supports the physical, economic, social and spiritual well-being of the people who live there. Many salmon-based cultures in other areas—Japan, Russia, Canada and other parts of the U.S.—have had to adapt to nontraditional food sources due to overfishing and habitat destruction. Bristol Bay is one of the last strongholds for wild salmon.

Connections to fish and water are seen through spiritual beliefs, such as reverence for nature and animals and the importance of sharing food with family, friends and even other villages in need. Over time, Alaska Native beliefs have blended with Russian Orthodox views, which put the “old beliefs” in a Christian context. Specific celebrations such as the “Blessing of the Waters” (keeping the water clean and free of contaminants) and the “First Salmon Ceremony” (sharing the first king salmon catch) 9

Land & tourism

Protected places Since the creation of Katmai National Monument (later Katmai National Park and Preserve) almost 100 years ago, both the state of Alaska and the U.S. government have designated specific areas in Bristol Bay as parks, refuges, reserves and critical habitat areas. Alagnak Wild River - This place name means “making mistakes” or “going the wrong way” in Yup’ik. Alaska Maritime National Wildlife Refuge – This 3.4 million acre area includes Bristol Bay coastline and provides essential habitat for 40 million seabirds (representing more than 30 species).

Katmai National Park and Preserve Photo: National Park Service

Visitors to Katmai National Park have a significant economic impact.


Approximate economic impact (in millions of dollars) of visitors to Katmai National Park, according to a 2010 study. This figure, based on 2007 tourism and including money spent in the five boroughs surrounding the park, adds about $33 million to previous estimates. Previous studies overlooked Alaska parks’ inaccessibility and different visiting patterns. Published by National Parks Conservation Association and Katmai National Park and Preserve, the report is available at


Number of Alaska Geographic bookstores located in the Bristol Bay region (Port Alsworth, King Salmon, Brooks Camp). A nonprofit, Alaska Geographic provides direct financial support to Alaska parks and refuges and publishes print and online resources. Learn more at

Alaska Peninsula National Wildlife Refuge – Its 3.5 million acres feature active volcanoes like Mt. Veniaminof, rugged coastline and rolling tundra. Aniakchak National Monument and Preserve – Home to a six-mile-wide “caldera,” or crater, left by a volcanic explosion nearly 3,500 years ago. Becharof National Wildlife Refuge – Boasts a 35-mile lake that’s been described as a “salmon factory.” Bristol Bay Fisheries Reserve – Designated in 1972 under Alaska state statute in order to help protect the fishery; it covers 1,793 square miles of submerged land and shoreland. Critical Habitat Areas (CHA) – There are five designated CHAs near major estuaries on the southern shore of Bristol Bay, encompassing 284,050 acres. (Egegik CHA, Pilot Point CHA, Cinder River CHA, Port Heiden CHA and Port Moller CHA). Katmai National Park and Preserve – Here you’ll find the Valley of Ten Thousand Smokes. Lake Clark National Park and Preserve – Two active volcanoes (Iliamna and Redoubt) are found here. McNeil River State Game Sanctuary and Refuge – Only 10 people a day can visit, but there’s no limit for bears. Togiak National Wildlife Refuge – You can find the Bristol Bay Salmon Camp here on Lake Aleknagik. Walrus Islands State Game Sanctuary – Protects seven small islands southwest of Dillingham. Hot spot for viewing birds and sealife. Wood-Tikchik State Park – At 1.6 million acres, it’s the largest state park in the United States.


Total square miles of the 17 parks, refuges, reserves and critical habitat areas found in Bristol Bay (larger than the state of Indiana).


Katmai bears Photo: National Park Service

Each year tens of thousands of visitors make their way to Bristol Bay. They come to hike, hunt, float, fish and view wildlife. They are attracted as well by the authentic experiences of daily life in rural Alaska. Can this tourism be further developed to benefit local communities? Several studies suggest as much. The 2004 Bristol Bay Product Development Trip report, funded by Bristol Bay Native Corporation (BBNC), highlights the value of the day-to-day lifestyle of Bristol Bay residents: “What defines local people’s ways of life is also what is attractive about the region—namely, the culture and natural surroundings in Bristol Bay. Visiting Bristol Bay is an authentic encounter with a different place, a different way of life. It is a rare experience in the United States today.” The 2011 Comprehensive Economic Development Strategy report published by Bristol Bay Native Association (BBNA) also highlights tourism and ecotourism as viable economic opportunities for the region. Currently, there is limited infrastructure, but plenty of attractions for sport fishers, hunters and adventurers. The 2005 Bristol Bay Angler Survey conducted by the University of Montana found that many anglers come to Bristol Bay specifically for its world-class rainbow trout fishing opportunities. The “uncrowded, remote and wild setting” influenced their decisions to fish in Bristol Bay. Seasonal activities that are a means of survival for locals are top-dollar “once in a lifetime” opportunities for tourists. So how can residents benefit from this shared appreciation for fishing and hunting in Bristol Bay? Currently, most visitors who come for worldclass fishing and hunting rely on guides to show them the ropes. Dozens of lodges offer fly-in fishing and hunting packages to remote areas of Bristol Bay. But many lodge owners and guides are not local, which means not all profits stay locally. According to BBNA’s economic development report, sport fishing alone brought in more than $61 million to the local economy in 2005, “but a majority of that money is earned by non-resident-owned businesses and taken from the region when the season is over.”

About Bristol Bay

Clara Gosuk and Theodora Sutton of Togiak participated in the 2010 Bristol Bay Fly Fishing Academy. Photo: Clark James Mishler. Courtesy: Bristol Bay River Academy.

There are various strategies for keeping profits local when developing local tourism. They may include local training, building infrastructure, microlending and—in the case of Bristol Bay—maintaining local ownership and design of tourism opportunities from the outset. The BBNA Comprehensive Economic Development Strategy report outlines next steps for building such tourism, including creating a locally generated Bristol Bay Visitor Guide and a Visitor’s Council that could explore marketing strategies. The Bristol Bay River Academy is one project that offers a solution. The academy is in its sixth year of providing a week-long training experience for Bristol Bay youth, ages 15 to 24, who want to explore careers as guides. Homegrown guides who know the waters, the wildlife, the people and the way of life in Bristol Bay could land highpaying lodge jobs, thus capturing some of the economic benefit of the industry. Visit for details.


Pebble mine Who

developers of Pebble mine.

Anglo-American One of the world’s largest mining companies, based in London, with projects around the world. Invested in Pebble prospect in 2007.


Northern Dynasty Minerals (NDM) Vancouver, Canada-based mineral exploration and development company. Purchased Pebble prospect in 2001. (London-based global mining leader Rio Tinto also has a 19.8 percent equity share in NDM.)

Pebble Limited Partnership (PLP) Company created in 2007 by NDM and Anglo-American to design and permit a mine at Pebble.

As of October 2012, more than 100 million feet of core had been drilled at the Pebble deposit from 1,075 core holes. This represents 189 miles of core, drilled for exploration and collection of environmental and engineering data.



large Mineral deposit.

The Pebble prospect is reportedly one of the largest North American discoveries of copper, molybdenum and gold. According to PLP, the deposit area contains 80.6 billion pounds of copper, 107.4 million ounces of gold and 5.6 billion pounds of molybdenum. It is worth an estimated $400 billion. The deposit was originally located by Cominco Alaska Exploration, which began exploring the area in 1986. It wasn’t extensively explored until NDM optioned it in 2001. Early efforts focused on a deposit area known as Pebble West. In 2005, NDM discovered Pebble East, an even larger deposit area.



Development of the proposed Pebble mine is in what is known as the “advanced exploration” stage. PLP continues to gather environmental baseline data, and is preparing for permitting by finalizing a mine plan. This timeline published by NDM in February 2013 illustrates the different stages of the development process. An April 2013 press release from NDM states a goal of entering the permitting process by the end of 2013. Before then, PLP plans on releasing a national economic impact study and a workforce development plan.



Mineral deposits at the proposed Pebble mine site are valued in the hundreds of billions of dollars. Mine proponents cite an economic benefit for the local, state and national economy. A preliminary assessment prepared for NDM in 2011 studied the economic benefit of operating an open pit mine at Pebble for 25, 45 and 78 years. Under the 45-year reference case, economists predicted that initial capital invested in the mine would be paid back within just 3.2 years, and that only 32 percent of the mine’s resources would be extracted in the first 45 years.


bristol bay watershed.

The Pebble deposit is located about 17 miles northwest of the village of Iliamna. Other nearby communities are Newhalen and Nondalton. In total, PLP and NDM hold interests in over 600 square miles of mineral claims in Southwest Alaska.

Pebble deposit area

ti m eli n e from NDM

About the proposed Pebble mine


The deposit

Land ownership The state of Alaska owns the lands on which the Pebble project has staked mining claims. This state-owned land is located within the Lake and Peninsula Borough, about 17 miles northwest of the village of Iliamna, and neighbors many different land owners, including Native corporation lands. In total the Pebble Limited Partnership (PLP) holds mineral rights to 186 square miles of lands surrounding the Pebble deposit. Other nearby communities are Newhalen and Nondalton.

BBNC lands • No portion of the mining claims are on land owned or managed by Bristol Bay Native Corporation (BBNC). A February 2011 document that Northern Dynasty Minerals Ltd. released to the public shows a transportation corridor crossing BBNC land. Assuming a continued need to transport materials from mine to port, it is reasonable to expect a final plan may involve similar road construction. Land Ownership in the Proposed Project Area

Proposed Pebble Mine Area

Bristol Bay Native Corporation boundary

Proposed Transportation Corridor


aL Iliamn

Mining Claims on State of Alaska Properties Village / Regional Corporation Lands (Patents, Interim Conveyed, or Selected) Bureau of Land Management National Park Lands State Lands Native Allotments

Land West of the dashed line is owned by Iliamna Natives Limited.

Land East of the dashed line is owned by Pedro Bay Native Corporation. Š 2010 BBNC All Rights Reserved.

Land ownership map. Image: BBNC. Background map of Pebble deposit area. Image: U.S. Geological Survey


Getting ready for the mine plan PLP has asked stakeholders to hold off judging its project until an official mine plan is released. Timeline • The plan is in production now; the public should receive updates in 2013. Pebble Watch interviewed Mike Heatwole, PLP’s vice president of public affairs, who said that creating the best plan is a complicated process involving engineers from PLP, Northern Dynasty Minerals and Anglo American. Any time a new component is considered, it has a domino effect on the plan. “We’re also spending significant time working our way through closure,” he said. “What does it look like … how will we get land back to chemical, biological and physical stability, what is the plan for long-term monitoring?” Plan rollout • PLP intends to take the plan to communities and get initial feedback from people shortly before permitting begins. “There are physical things you can’t change, like where the ore body is,” said Heatwole. But other aspects of the plan will change through the process. “It’s helpful for folks to understand that the project that gets initially rolled out and put into permitting is not a final. There are always terms and conditions that come out of that process based on public input and technical input.” Understanding technical aspects of the plan • PLP will be making multiple visits to different communities to make sure everyone gets a chance to see the plan presented in person. Staff members are working on explaining complicated terminology and concepts in layman’s terms, as well as possibly having multiple versions of the plan— an in-depth version for those who want details, as well as a “lighter” version that gives more of an overview.

About the proposed Pebble mine

Image: Northern Dynasty Minerals

Mine design & construction Mine developers have considered many mining scenarios with economic and environmental goals in mind. PLP has stated a commitment to environmental stewardship and its intent to employ modern technology to develop a mine that will meet regulatory requirements. A complete mining plan has not yet been published, but developers have provided some details of what will be needed for various aspects of the mine.

Type of mine

According to PLP, the mine will be “modern open pit”; according to Northern Dynasty, it could be open pit, a high-volume underground mine (block caving), or a combination of both.

Milling and processing

Metals in this deposit are distributed throughout the surrounding rock, so need to be ground into powder and then separated. Industry-standard froth flotation will likely be the main method used to accomplish this. Much of the material processed will be waste (tailings) that needs a long-term storage solution so that it does not create acid mine drainage that would adversely affect the environment.

Tailings storage options

The study team is looking at a range of options. What is known is that the tailings facility will be earthen, with waste material covered by a shallow layer of water, which will be constantly monitored.

Transportation, power and related infrastructure

• An 86-mile transportation corridor would be built between the deposit site and a new port planned for Cook Inlet. It would include a two-lane road and four pipelines for copper-gold concentrate, reclaim water, natural gas, and diesel fuel. • A natural gas-generating plant (approximately 400 megawatts) would be built at the mine site. 15

Permitting process Permitting any large mine in Alaska is complicated, with federal, state and local permits needed before development can begin. For the Pebble project, the “cornerstone” permit is Section 404 under the Clean Water Act, related to discharging dredge or As part of the permitting process, an Environmental Impact Statement is written to assess how an area fill material (including mine would be affected by development. tailings) into waters or wetlands. The U.S. Army Corps of Engineers approves Section 404 permits, which are subject to a federal environmental review listed under the National Environmental Policy Act (NEPA). The Corps of Engineers will serve as the “lead agency” for Pebble permitting, and will be responsible for preparing an Environmental Impact Statement (EIS) as part of the NEPA process.

“Scoping” the issue. Once a 404 permit application is filed and NEPA analysis begins, the Corps of Engineers will begin what is called “scoping,” or identifying issues that need to be addressed during NEPA review. This is when many of the public participation opportunities happen. Expect meetings, chances to talk about the proposed mine plan, and the ability to submit written comments online or by mail. State permits will have their own public participation requirements. For an example of how the Pebble permitting documents/process might look, Sharmon Stambaugh, of Alaska’s Department of Natural Resources (DNR), suggests checking out the Corps of Engineers web page related to scoping for the proposed Donlin Gold Project (Yukon-Kuskokwim region). The site, at, shows mine plan documents, meeting times and comment forms. Public input – does it make a difference? Once the NEPA process

begins, members of the public can submit written comments for various permit applications. But does that make a difference? Stambaugh says yes. As someone involved in scoping for the Pogo mine in Interior Alaska, she saw changes that came out of the process. “The initial design allowed for discharge into a salmon rearing area, but they ended up changing the outfall so that it minimized impact to the Goodpaster River,” she said. The type of public input that can best contribute to these changes is specific, rather than “generalized comments of support or opposition,” said Stambaugh. With the technical nature of a mine plan, specific comments are usually submitted by the applicant, federal agencies or non-governmental organizations with staff scientists. Local knowledge is also welcome. “In the case of Pebble, we look forward to comments from the many residents who use the area and who have valuable local knowledge,” said Stambaugh.


Agencies that may play a role in permitting the proposed Pebble mine: ADEC

Alaska Department of Environmental Conservation


Alaska Department of Natural Resources


Alaska Department of Labor


Alaska Department of Transportation & Public Facilities


Alaska Department of Public Safety


Bureau of Alcohol, Tobacco and Firearms


U.S. Army Corps of Engineers


Department of Homeland Security


Environmental Protection Agency


Federal Aviation Administration


Federal Communication Commission


Joint Pipeline Office


Lake and Peninsula Borough


Mine Safety and Health Administration


National Marine Fisheries Service


State Historic Preservation Office


Threatened & Endangered Species


U.S. Coast Guard

USDOT U.S. Department of


USFWS U.S. Fish and Wildlife Service

All about permitting U.S. Corps of Engineers Regulatory Field Guide

Alaska Department of Natural Resources Pebble Project page

This field guide provides descriptions of wetlands, permits (Section 10, Section 404) and mitigation procedures.

Find easy links to reference sites and guides like this NEPA publication at:

Cooperative Extension NEPA Project Permits Page

Large Mine Permitting in Alaska

The Cooperative Extension at the University of Fairbanks offers this resource to describe the National Environmental Policy Act (NEPA) and how Alaska residents can participate in shaping proposals near their communities.

The Alaska Department of Natural Resources Large Mine Permitting webpage details the process for permitting projects like Pebble. Find fact sheets, presentations and links to several large projects coordinated by the team.

Citizen’s Guide to the NEPA

Section 404 of the Clean Water Act

The Bureau of Land Management has a detailed guide to the NEPA process at its website, along with a handbook that addresses public participation in the NEPA process (see Chapters 6, 8, 9 and 12).

“The permitting process for Pebble will be a big challenge. I don’t think there’s any doubt that it will be the largest, thickest environmental impact statement ever done in Alaska, maybe the nation, maybe the world.” ­ – Ed Fogels, Alaska DNR deputy commissioner, Frontline documentary “Alaska Gold”


Permitting Guide


PERMITS ent periods MINOR ng public comm

is either study-level) design (prefeasibility filed. process. PFS-level n needs to be late in the permitting a particular permit applicatio not requiri ns will be filed be available before permit applicatio information will Most of these or the additional minor permits,


for all



Burn Permit



Burn Permit


Notice of Proposed


or Alteration




Explosives License to Transport s (BATF) for Use of Explosive Permit and License for Blasting d Firing Area Notice of Controlle



r (Resource s Waste Generato Obtain Hazardou Recovery Act [RCRA]) and Conservation Number Identification Registration Number Hazardous Materials Hazardous Materials Approval to Transport







on ROW

Driveway Permit

Hazardous Cargo g Fuel Offloadin Certification Person in Charge



Radio License



g Plan and Retrainin Miner Training tion Number Mine Identifica Legal Identity Notification of






a Public Water t and Operate Approval to Construc review required) (plan Supply System Permit Food Sanitation Safety Plan Check Life and Fire Certificate of Plan Review State Fire MarshallBldg Approval for Each Fired and Unfired for n Inspectio Certificate of Pressure Vessel


tion Employer Identifica


Number Registrat


Operations Plan on Port Security Coordinator Certificati Port Facility Security



About the proposed Pebble mine – Permitting








d content related

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mine • www.p



that details on permits See inside for for the Pebble will likely be required project. Visit www.peb to

the links of this guide with an overview of for a version guide to provide n. has created this required for the additional informatio Pebble Watch es that may be nt ations, and process for a public comme permits, authoriz those that allow Major permits and to identify Overall project Pebble project, period. phase. Once Project design mitting pre-per Dam Safety project is in a of Pebble mine Reclamation the long process Currently, the ers can begin mAjor take permits minimum time frames may be extended. ! complete, develop s. This could Water a mine plan is and federal agencie Water Discharge from local, state Agency WhAt permit covers gaining permits Storm Water

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Section 404 Water Act

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n focuses on This EPA publicatio Act, the Clean Water Section 404 of ns of agenices including descriptio wetlands information on involved and

provides This field guide wetlands, descriptions of 10, permits (Section and mitigation Section 404) procedures.


The Pebble Watch Permitting Guide shows the types of permits potentially required for development of the Pebble project and identifies which permits will have public input periods. It also lists agencies that will likely be involved in permitting. Download a copy at using the “Permitting Timeline” link at the top of the page. AGENCY

nal, and fact-base

Permitting gu

111 W. 16th Ave. Ste. 400 AK Anchorage,

Pebble Watch resource


This EPA publication focuses on Section 404 of the Clean Water Act, including descriptions of agencies involved and information on wetlands identification.


Impartial, educatio



This page describes the Pebble project and links to permit applications, field reports and more.

Cooperative Extension NEPA Page s Project Permit

tive Extension The Coopera y of at the Universit this Fairbanks offers the resource to describe ental National Environm and how Policy Act (NEPA) s near shaping proposal in te can participa actions, Alaskan residents the process, NEPA ities. Read about their commun ideas. and participation

Citizen’s Guide


Large Mine Permitt in Alaska

ent of The Alaska Departm s maintains Natural Resource Permitting” a “Large Mine details web page, which process for the permitting presentations Find fact sheets, Pebble. as the Large projects such coordinated by large projects and links to several g Team. Mine Permittin

ent of Alaska Departm ces Pebble Natural Resour Project page s the Pebble This page describe to permit project and links field reports and applications, more.

to the NEPA

ent has Land Managem The Bureau of to the NEPA process a detailed guide as well as a 184-page at its web site, on download. Informati handbook for the participation in relating to public in is contained mainly NEPA process 9, and 12. Chapters 6, 8,


up to three years.

und injection Detailed Construction and Operation DeAll Undergro scription Water use

= critical comment period


Water Discharge

Oil Spill tion Discharges to surface waters and wetlands ental Conserva Section 402 National Pollutant Discharge EPA or ADECProtectio n ent of Environm Elimination System Water Discharge Fish and Wildlife Alaska Departm Resources Permit ADEC ent of Natural ent Alaska Departm Certificate of Assurance (Section 401) ADEC Discharges to surface waters and wetlands (linked Local Governm ADNR ent of Labor to USACE Section 404 Permit Application Process) Alaska Departm & Public Facilities ADOL Minor permits Transportation Non-Domestic Wastewater Disposal Sec- quality ADEC Detailed treatment process plans Department of Air Safety ADOT/PF Alaska tion of Waste Management Permit ent of Public Aviation Alaska Departm Plan Review for Non-Domestic EPA orications ADEC Detailed design and construction plans , and Firearms ADPS Tobacco Commun Wastewater Treatment System* (not a Bureau of Alcohol, Engineers Explosives BATF and wastes permit; plan review only) Army Corps of United States Hazardous materialstion COE Plan Review and Construction Approval ADEC transporta Homeland Security Highway Department of for Domestic Sewage System* (not a DHS Marine safety Protection Agency permit; plan review only) Environmental Mine safety EPA Administration and safety Federal Aviation Public health ion Storm water FAA ication Commiss ions Federal Commun Storm Water Construction and Operation Registrat APDES Run-off from disturbed ground surface FCC Security ce Permit Joint Pipeline Offi JPO Borough a Lake and Peninsul ration Storm Water Pollution Prevention Plan State of Run-off from disturbed ground surface L&PB Health Administ Alaska Mine Safety and MSHA Fisheries Service Underground Injection National Marine NMFS ervation Office State Historic Pres Underground Injection Control Well Division of Underground injection of water or drilling muds SHPO Species Endangered Water (DEC) Threatened & T&ES Coast Guard Water Use United States Transportation USCG 12/2012 Department of Temporary Water Use Permit ADNR Construction and early operation; good up to five United States Service USDOT Wildlife years and Fish United States USFWS Permit to Appropriate Water ADNR Post 5-year operation Air

• Prevention of Significant Deterioration


minimum time frames may be extended.


= critical comment period

WhAt permit covers

Dredge or fill discharge into wetlands/waters of the U.S.


Discharges to surface waters and wetlands (linked None to USACE Section 404 Permit Application Process)

Fish & Wildl

Wetland Fills Section 404 Permit for Discharge of Dredge or Fill Materials into Waters of the U.S., including wetlands None None None


Fish Habitat P 30 - 60 days

Migratory Bird

Threatened & (ESA) Consult

Solid Waste Disposal (landfills, waste rock and tailings) Solid Waste Disposal Section of Waste Management Permit


Disposal of solid waste, (e.g., tailings, waste rock)

30-day minimum


Structures over navigable waters

30-day minimum

Bridge or causeway over navigable waters

30 Days

Non-mobile air emissions (stacks, dust, non-road engines, e.g., light plants, pumps)

• Minor permit

• Title V Operating Permit


locAl gove Development

Construction in or Over Navigable Waters


30-day minimum

None 30-day minimum

Section 10 Permit for Construction of any Structure in or over any Navigable Waters of the U.S. (Part of 404 application)

Construction Permit for a Bridge or Cause- USCG way Across Navigable Waters of the U.S. Material Sale Material Sale on State Land (MLW)


Sale of State gravel

None None

lAnd use State Land

7 days posted on website and notice to T&ES Agency None

30-day minimum

Upland Mining Lease


30-day minimum

30-day minimum


Mining on land


for all in this section

30-day minimum

30 days

Large Project

About nepA Under the Nat environmental the environme decision to ap one agency w supervise prep the Pebble pro Army Corps o

Millsite Permit


“Surface authorization” for mill facility

30-day minimum

the public r

Tidelands Lease


Tidelands structures for use of state-owned tidelands. Less than 3 miles to ordinary high water.

30-day minimum

“The public ha

Lease of Other State Lands


Specific as needed

30-day minimum

Miscellaneous Land Use Permit


Misc. uses (e.g., borrow sites)

30-day minimum

Road Right of Way (ROW)

ADNR or landowner

Road right-of-way


Pipeline right-of-way

(These permit applications are not required by Alaska law to have a comment period.)

Section 106 Historical and Cultural Resources Protection


Cultural resources protection

30 days

Cultural Resources Authorizations


Cultural resources protection

30 days

Spill Prevention, Control, and Countermeasure (SPCC) Plan


Spill prevention


Oil Discharge Prevention and Contingency Plan (ODPCP or “C” Plan)


Spill prevention and response

45 days

Facility Response Plan (FRP)


Spill response

Facility Response Plan (FRP)


Power Line ROW None


(ADNR MLW tends to bundle permit comment periods into one big process.)

Pipeline ROW

Power line right-of-way

particularly du issues should

Impact Statem

in an agency’s participate in

related hearin

comments dire

culturAl resources protection

oil spill ADEC

Fish Passage

Bald Eagle Pr

Section 404 Permit Review Certificate of Assurance (Section 401)


public comment period



Fill/mAteriAl use & plAcement

Air Quality Air Quality Control Permit to Construct (one of the following):

mAjor permits

public comment period

How the project is to be constructed and operated

until Approval Plan of Operations ADNR All aspects of the project on State land be created project cannot Air Using this guide ly. It is for the Pebble Air quality general guide on of required permits project design An actual list nt ould be used as a are grouped Use and Placeme ned, so this list sh or design. Permits Fill/Material the project is defi Damamount Safety of project plans Wetland fills of future Pebble based on the not indicative Certificate of Approval to Construct a Dam waste Detailed design plans as major or minor “minor” Solid ADNRdisposal navigable are designated The “major” or tion in or overDetailed operational plan Certificate Approval to Operate a Dam ADNR by function, and to acquire each. Construc needed be of and time needed ce, as each may waters information, effort Reclamation a permit’s importan an associated have reference sale not Material Most major permits Reclamation Plan Approval designation does ADNR Closure design and preparation (e.g., stockpile project may proceed. locations) Land Use before a complete period. t and commen State land public review WAter es Protection Cultural Resourc

None None



must take into

the public and

the comment p

Permitting claims Permitting claims Once the permitting process has begun, the state of Alaska has never before rejected a large mining project. Technically true But it’s more complicated than that, says Sharmon Stambaugh, large mine project coordinator for the Alaska DNR. “We say no all the time. We make people go back to the drawing board, modify this, review that, flesh this part out. Sometimes what happens is that the applicant says ‘No’ itself. For example, the Alaska-Juneau gold mine project in Southeast was never permitted because there were so many aspects of that project that didn’t prove to be viable.” The permitting process is open-ended and “iterative,” so a developer can continue to submit changes to get to a plan that meets all regulatory requirements. It is likely that Pebble developers will go forward with multiple revisions to get the permits they need. At its essence, this claim suggests that once Pebble permitting begins, the state will approve the necessary state permits. This quote from the PBS Frontline documentary Alaska Gold seems to back that up: “If the company … can show that water quality will be protected and that air quality will be protected and the fish and wildlife resource will be protected … essentially they’re due a permit.” Alaska DNR deputy commissioner Ed Fogels

Alaska has the world’s most stringent regulatory system. Maybe, but needs back up This statement can be used as an assurance that the regulatory process is more protective in Alaska than anywhere else, but it is difficult to find research or comparisons that back up this claim. According to Sharmon Stambaugh, of Alaska DNR, the state does differ from other areas, especially in terms of water quality standards. “A lot of states rely on federal standards, but because Alaska protects most of its water for all uses, including aquatic life, it has set very stringent state standards.” Stambaugh said the permitting process is more complex due to factors such as land-ownership, endangered/threatened species, anadromous fish, and issues with access to sites. Once a site opens, there are permitrequired environmental audits every five years. “To our knowledge, these environmental audits are not generally standard requirements in other jurisdictions,” said Stambaugh. But does that mean Alaska has the world’s most stringent standards? It’s unclear until a factual comparison is conducted. 18

Miners Association How trueLeft: areAlaska statements presentation, June 2012 Below: Report from Wild Salmon Center/ you may Trout hear about Unlimited, January 2012 permitting large mines in Alaska?

Alaska is viewed in a negative light by the industry because of its regulatory process and length of time for getting permits. Not necessarily A January 2012 report on “The Economic Impacts of Alaska’s Mining Industry,” reports 81 significant exploration projects in Alaska in 2010. Thirty-four of these each had expenditures of more than $1 million. Most of this exploration funding came from Canadian and other international sources. And the Fraser Institute’s 2011/2012 survey of 802 mining companies around the world ranked Alaska in the top 25 for “policy potential,” or how well different factors encourage investment. Factors included in the survey were: existing regulations; environmental regulations; regulatory duplication and inconsistencies; taxation; uncertainty concerning native land claims and protected areas; infrastructure; socioeconomic agreements; political stability; labor issues; geological database; security; and corruption. In the same report, a consultant company is quoted saying, “Alaska, during transition to statehood, settled all native land claims. The resulting land tenure certainty and entrepreneurial native corporations have given Alaska stability that neighbouring provinces can only dream of.” Find links to these reports at

Studying the Environment To determine how large-scale mining activities might impact the environment in Bristol Bay, scientists first need to accurately describe, or characterize, the area. Pebble Limited Partnership studies Since 2004, private contractors have been studying various aspects of the environment in the area of Bristol Bay near the Pebble deposit. This data was compiled by several different companies, and is available in one Environmental Baseline Document made available by the Pebble Limited Partnership (PLP) in 2012. The document includes topics ranging from meteorology to wetlands, fish and wildlife. It will play a large role in the permitting process.

EPA Watershed Assessment In 2011, the U.S. Environmental Protection Agency (EPA) began its own study of the area, by compiling available research on the Kvichak and Nushagak river drainages. EPA released the first draft of its Bristol Bay Watershed Assessment (formally known as “An Assessment of Potential Mining Impacts on Salmon Ecosystems of Bristol Bay, Alaska”) in May 2012. EPA solicited feedback from a peer review team and collected public comments on the draft. It released a second draft for public/peer review in April 2013, with a final document expected in fall 2013.

In the following pages, Pebble Watch provides an overview of portions of these studies.

Environmental science and peer review

Peer review: how studies are assessed Peer review is a process that provides a critical review of scientific papers. Collecting data and presenting results may seem straightforward, but scientists can overlook details or make flawed conclusions. In peer review, other scientists familiar with the subject will critically review a paper and provide comments to the author. For scholarly papers to be published in journals like Nature or Science, peer review is an essential part of the selection process. According to its own “Peer Review Handbook,” the EPA describes peer review as a process intended to “uncover any technical problems or unresolved issues in a preliminary (or draft) work product through the use of independent experts.” The responses from peer reviewers help authors revise their drafts. For the EPA, peer review “is a process for enhancing a scientific or technical work product so that the decision or position taken by the agency, based on that product, has a sound, credible basis.” In October 2011, Science magazine published an overview of a public forum in Dillingham that focused on the proposed Pebble mine. The forum was part of a symposium sponsored by the Arctic Division of the American Association for the Advancement of Science. Author Edward Lempinen wrote: “What the Arctic Division meeting made clear … was that science will be critically important both to public opinion and policy decisions on the project.” With science playing such an important role for individuals forming opinions about the proposed Pebble mine, it helps to understand not only the facts and figures, but the peer review process as well.


EPA watershed assessment

Top: Kaskanak Creek in the Kvichak watershed. Photo: U.S. Environmental Protection Agency Bottom: EPA public hearing on the watershed assessment, Dillingham, June 2012.


In May 2012, the U.S. Environmental Protection Agency (EPA) released the first draft of a Bristol Bay Watershed Assessment. EPA conducted the assessment “to determine the significance of Bristol Bay’s ecological resources and evaluate the potential impacts of largescale mining on these resources.” EPA has authority under the Clean Water Act to invoke a 404(c) ruling that could limit development in the area, which is one reason for intense interest in the document. EPA has said the watershed assessment will inform its decision on whether to proceed with such a ruling, and continues to state that it will make no judgment about using 404(c) authority until the final assessment is complete. EPA was both lauded and criticized for the first draft of the watershed assessment, and received more than 230,000 official comments through its online system and during public meetings. A peer review panel of 12 scientists was also tasked with reviewing the document. Comments and suggestions were incorporated into a second draft, released in April 2013 for review by the public and the same 12-member peer review group. EPA states it will carefully consider all comments when preparing the final document, which it plans on completing later in 2013.

Why the assessment was conducted Concern for the ecological goods and services provided by the Bristol Bay watershed, most notably commercial, sport and subsistence fishing. Mining and the 17 mine claims in the watershed, the largest of which belongs to the Pebble Limited Partnership. Multiple requests to the EPA, including a request from Bristol Bay Native Corporation, to step in to protect aquatic resources and salmon in the watershed.

How it was developed EPA first completed background research on Bristol Bay, Pacific salmon, Alaska Native cultures, mining, and other watersheds that support salmon fisheries and surface mining. This characterization was used to develop conceptual models that show potential links between human activity and the effects on fish, wildlife and Alaska Natives. Since no official mine plan exists for any of the mining claims in Bristol Bay, EPA developed a hypothetical mine scenario. This scenario and the conceptual models were used to develop an “ecological risk assessment” based on EPA guidelines.

Visit for the full text of the EPA Bristol Bay Watershed Assessment, links to public comments submitted, and the peer review report.

EPA Bristol Bay Watershed Assessment

Highlights from the EPA’s draft watershed assessment About salmon – All five species of North American Pacific salmon are found in Bristol Bay. The Bristol Bay watershed supports the largest sockeye salmon fishery in the world. The Kvichak River produces more sockeye than any other river in the world, while the Nushagak River is the fourth-largest producer of chinook in North America. Effects of mining – Even with no significant accidents or failures, a large-scale mine would have impacts on water resources and fish habitat near the operations. At a minimum, there would be direct loss of some streams and wetlands, including spawning and rearing habitat for fish. Mine failure – Failures in infrastructure or processing would have wider-ranging effects on wildlife, fish habitat and indigenous culture. The assessment includes a detailed chart of possible failures, their probability and related consequences. The probability of many types of catastrophic failures is very low. However, some activities, such as water collection and treatment operations, were found to have high or even certain probability of failing. If not treated into perpetuity, for example, untreated leachates would flow to the streams. Sociocultural effects – Loss of salmon-based subsistence resources due to mining effects or failure would lead to negative impacts on Alaska Native nutritional, social and spiritual health. For more detail, find a Pebble Watch summary of EPA’s watershed assessment at 21

PLP studies Environmental Baseline Document In January 2012, the Pebble Limited Partnership (PLP) released its Environmental Baseline Document (EBD), a report created to describe—or “characterize”—the environment in the area surrounding the Pebble deposit. The report includes 24 topic areas for two different study regions: the Bristol Bay area, where the Pebble deposit is located, and the Cook Inlet area, where PLP has proposed building a transportation corridor to bring material to and from the Pebble deposit. Topics each fit into one of three broad categories: the physical and chemical environment, the biological environment, or the human environment.

Creating the EBD Developers hired a number of contractors representing different specialties to prepare reports for the EBD, primarily focused on data collection from 2004 through 2008. According to PLP, technical content was reviewed by various scientific experts, combined and edited for consistency to produce the final document. Additional baseline data from continuing studies may become available in separate documents in the future. 22

How the EBD relates to the development of Pebble mine PLP has called the EBD “the cornerstone” of the permitting process. It includes many of the same topics and data that would appear in an Environmental Impact Statement (EIS) before mine permits are granted. However, an EIS would also include other elements, such as analysis of how the mine plan would impact the environment, and a range of alternative actions that would cause fewer impacts. Baseline data included in the EBD is also typically used to support engineering design as a mine plan is being formulated.

Exploring the EBD Readers should be able to review the EBD following general guidelines that scientists use to understand and evaluate reports. Methodology – Were study methods consistent from year to year and appropriate to the region?

Data gaps – Is data complete? Age of data – Is data current enough for an accurate characterization? Outlier data – Were there “outlier” data points significantly different from other results? If so, how were these addressed? Availability of data – Is raw data available in a format that other scientists could use to assess the quality themselves? References – When references are made to past literature or studies, were these the best sources? Were there others not considered? Peer review – Did other scientists (peers) review for accuracy?

Review the entire EBD, or a short overview produced by PLP (pictured above) at

Keystone dialogue process “Scientists aren’t naturally objective. But they need to be impartial. That’s where the scientific method comes in. It’s sort of a check and balance against your values and personal feelings getting too close or too involved in your science.” – Todd Bryan, Keystone Center

For general readers, a critical review of the EBD and its 20,000 pages of technical information likely isn’t feasible. To help readers get a head start on asking critical questions about the EBD, Pebble Watch developed a series of fact sheets on scientific topics included in the document. Portions of these are included in this publication. Scientists funded by various organizations (including Bristol Bay Native Corporation) also began to review portions of the EBD to evaluate whether there are gaps or errors in data, and whether studies can be reproducible (a cornerstone of the scientific method). The nonprofit Keystone Center also organized a series of science panels to review and evaluate sections of the EBD. The Keystone Center, based in Boulder, Colo., was contracted by PLP in 2007 to conduct an “independent stakeholder assessment and dialogue feasibility study” on the Pebble project. According to Keystone senior associate Todd Bryan, the recommendation to hold science panels came out of the stakeholder assessment process. After interviewing 90 individuals in Southwest Alaska on their issues related to the proposed Pebble mine, Keystone recommended panels made up of credible scientists from “academic institutions, government agencies, and science-based nongovernmental organizations in Alaska and the U.S.” Because the dialogue process is funded by PLP, environmental groups have called into question Keystone’s independence. Bryan points out that Keystone has built a reputation for working on national environmental, energy and health policy issues using impartial, transparent methods. At the very least, Keystone’s science panels provide an opportunity for stakeholders to learn more about PLP’s report, and to ask their own questions about the findings before PLP begins the official permitting process. Visit for video and presentations from past dialogues and details on future panels.

Goal of the science panels “We’re trying to help inform people about the state and federal permitting process ... through objective, impartial science,” said Keystone Center’s Todd Bryan. “Keystone recognizes this is probably the most important decision the region will make in several generations.” Panel content/organization

Panels include presentations from PLP-contracted scientists, as well as evaluations and suggestions from panelists. Panelists review specific EBD chapters and other relevant outside papers that were accepted by Keystone. These include several reports from scientists not affiliated with PLP. Independent panelists

Keystone took a number of measures to ensure independence, Bryan said, including consultations with the National Research Council on best practices. Keystone’s Science Advisory Panel was tasked with finding independent panel members. They checked for potential conflicts of interest, ruling out scientists who had monetary ties to Pebble or advocacy groups, those employed by agencies that would be reviewing the baseline document during permitting, and those employed by stakeholder agencies. With such strict criteria, it’s been a challenge to fill the panels. “It’s hard to find scientists who will review thousands of pages of data and take the time to participate in the panels without being paid,” said Bryan. Panelist Chris Waythomas, geologist with the Alaska Volcano Observatory, speaks with Ricky Delkittie at an October 2012 Keystone science panel.

Pebble Limited Partnership studies – Environmental Baseline Data


Soil & sediment In August 2010, Pebble Watch reviewed Pebble Limited Partnership’s (PLP) “Report Series E: Trace Elements (Sediments & Soils),” an overview of three years of soil and sediment sampling at the proposed mine, port and transportation corridor sites (from 2004-2007). The sampling analysis included trace elements, organic compounds like benzene, and inorganic compounds like ammonia. The report includes details on where, when and how often soils and sediments were sampled, as well as how sampling locations were determined. It explains that the trace elements studied occur naturally in very small amounts, and that the primary objective of sampling is to identify and characterize their naturally occurring levels. According to the report, “The studies will establish background levels for the purpose of long-term monitoring of project operations.” Other information from the report includes: • sampling results from the proposed mine site, Iliamna Lake, the proposed port area, and along the proposed transportation corridor

Sampling sediment in the transportation corridor study area.

Trace elements studied may be safe in very small amounts, but in larger amounts are toxic to plants, animals and people. For this reason, information on the presence and concentrations of these and other “naturally occurring constituents” is often collected prior to development of a mine where accidental or unintentional release is of concern. In total, PLP sampled more than 30 constituents, including ammonia, arsenic, chloride, fluorine, and sulfates, as well as mercury, copper and other metals.

Organic compounds, such as petroleum hydrocarbons, were also sampled in sediments at the proposed port site. In addition to providing data of interest to the public, such sampling provides baseline data that will later contribute to the permitting process. Long-term monitoring referenced in the report will likely be required by state or federal agencies or both. Such monitoring can take place before, during—and even after—mine operations.

• sampling frequency (twice a year in most cases) • the total number of samples collected, listed by site, including more than 200 sediment samples and 257 soil samples from the proposed mine site, and an additional 177 samples from the other studied areas. 24

Soil studies

Soils in the Bristol Bay region were included in a survey of Alaska soils completed by the U.S. Department of Studying soils in Alaska began Agriculture’s Soil Conservation Service in 1979. Thein 1914, as partcovered of a study for possible Exploratory Soil Survey of Alaska much of the routes for the Alaska Railroad. Bristol Bay area, finding three general types of soils, with significant influence from volcanic ash.

–– – – – – –– – – – – –– – – – – –– – – – – –– – – – – –– – – – – –– – – – – –– – – – – –– – – – – –– – – – – –– – – – – –– – – – – –– – – – – –– – – –

Understanding the data

To help interpret the large number of site-specific data presented in PLP’s soil and sediment studies, Pebble Watch calculated the average concentrations of copper (Cu) and arsenic (As) found in 250 soil samples taken from 133 locations in the proposed mine area. We also highlighted the highest concentrations collected for each. State and federal agencies use scientific studies and risk analysis to determine “safe” concentrations of such constituents for humans, animals, plants and other life, and they have developed numerous benchmarks for comparison. In this graphic, using data for copper and arsenic as examples, we show how amounts sampled compare to two such benchmarks: the Alaska Department of Environmental Conservation (ADEC) maximum allowable soil concentration for migration to groundwater level considered safe for human ingestion and the Environmental Protection Agency (EPA) Ecological Soil Screening Levels. What about “safe” levels for aquatic life? See “Water Quality,” p. 32, and “Fish Habitat,” p. 40.

–– – – – – –– – –

Pebble Limited Partnership studies – Environmental Baseline Data


Geotechnical & seismic studies

Detail of an aeromagnetic map over Lake Clark fault, U.S. Geological Survey

Geotechnical studies focus on the location and properties of bedrock and soils and the water contained within them. They help to characterize the stability of soils and rock, as well as how groundwater may move through them. Seismic investigations describe motions that occur within bedrock during an earthquake, and evaluate the likelihood of large earthquakes in the region. To design safe mine and pollution containment systems, developers must have a thorough understanding of the stability of soils and rocks in the mine area, as well as how water levels may change as water moves through the materials. Mining involves creating embankments and dams to contain waste rock­—called tailings—in ponds or other holding systems. Such dams must be designed to withstand earthquakes. Mine excavation also involves the creation of steep slopes, which have potential to slide and fail, depending on the type of rock and soil material involved, and how the mine 26

is designed. Proper design, which considers all of the geotechnical aspects of affected materials and water bodies, is crucial for preventing pollutants from escaping into the surrounding environment. Because mining activities involve the removal of massive amounts of material, there is potential to raise or lower the water table. This can affect surrounding wetlands and water bodies, as well as how often floods occur, potentially affecting the stability of tailings dams. Therefore, mine design warrants a thorough analysis of how and where water is contained within the rocks and soils, and how mining may change these waters. Earthquakes also can trigger slides and cause failure of containment systems. Ground movement can cause liquefaction, where waterlogged soil loses its structure and becomes liquid, so that it can no longer support the weight of buildings or other structures.

Understanding faults The Earth’s crust is made up of several large pieces of rock called tectonic plates. Movement of these plates against each other can cause a fracture in the crust. If the bedrock on either side of this fracture is offset, it’s called a fault (see images below). Stresses can build up along faults over time and eventually lead to earthquakes. Geologists map rocks and look for offsets of geologic patterns to find faults. They study the ages of these offsets to determine how recently movement occurred along the fault. A fault is considered active if movement has occurred within the time since the last glacial advance in that region, or if there is a continuing record of very small earthquakes. However, earthquakes have occurred along faults once thought to be inactive. For example, in 1994 a magnitude 6.7 quake struck Los Angeles, and in 1999 a magnitude 7 quake fractured part of the Mohave Desert. Both were located on faults considered to be inactive. U.S. Geological Survey

Three main types of faults Normal fault

Strike-slip fault

Thrust fault

What have Pebble studies found? By itself, Alaska produces about 15 percent of the world’s earthquakes, so a robust study to assess the probability of a quake affecting the proposed Pebble mine is necessary. The Pebble Limited Partnership (PLP) included a geotechnical/seismicity chapter in its Environmental Baseline Document (2011) that described studies conducted between 2004 and 2008. Scientists researched top layers of earth as well as bedrock by digging five 10-foot test pits and collecting cores from holes ranging in depth from 100 to 5,000 feet. They measured water pressure and conducted geophysical surveys to characterize bedrock layers deep below the earth’s surface. Researchers also conducted a review of historical and scientific reports relating to regional earthquake history. They conducted site investigations only at the proposed mine site, not the proposed transportation corridor. Bedrock and water • Results of the field investigations showed that bedrock lies from 10 feet to 250 feet below the surface in most of the study area. The water table ranges from being close to the surface to about 200 feet below. Water moves slowly through most of the rocks and soils within this area. Earthquake potential • The report presents the potential of a large earthquake (larger than magnitude 8 to 9) off the coast of Alaska due to movement of the Earth’s plates. Scientists estimate the frequency of such earthquakes to be about every 650 years. But other earth movement may be more frequent along faults such as the Lake Clark-Castle Mountain fault system northeast of the study area. The western end of the Lake Clark-Castle Mountain fault system is east of the Pebble mine study area at the end of Lake Clark.

Researchers suggest the Lake Clark fault does not cross under this area, citing literature and research that found no surface evidence of fault activity, and a hypothesis that the location of the fault is associated with the direction of glacial advance. In 2011, based on studies showing no movement since the last glacial period, and no earthquakes along the fault in the last 1.8 million years, the U.S. Geological Survey (USGS) classified the Lake Clark Fault as “inactive.” The Castle Mountain fault is active, however, and capable of earthquakes larger than magnitude 7 within the next 50 to 70 years. A 5.7 earthquake occurred along this fault in 1994, and another measured 4.6 in 1996. Two other smaller faults exist north of the Lake Clark fault, and the region could be affected by other faults farther from the region. Study authors state that seismic hazards are not a

concern from these faults because ground accelerations generated by earthquakes decrease with distance from the epicenter. During the October 2012 Keystone Center dialogue on the topic, however, panelists recommended that PLP assess relative hazards by listing them along with factors such as their distance to the source, magnitude, recurrance rate, and likely shaking amplitude. They also recommended considering the effect of earthquakes in the transportation corridor, especially from known hazards such as the Bruin Bay fault and the Iliamna deep cluster earthquakes. Hazards associated with slope stability, landslides and rock falls could be better assessed with more information on the surficial geology of that area. Additional studies on the Lake Clark fault were also recommended, with one panelist noting, “Whether the Lake Clark fault extends further to southwest is still an open question.”

Volcanoes and mine operations Alaska has hosted some pretty powerful volcanic eruptions, including significant events to the west of the Pebble deposit. Geologists participating in the Keystone Center dialogue in October 2012 said volcanoes like Katmai, Novarupta and Aniakchak would have the potential to affect the mine site through ashfall over an extended period of time, even after an eruption is over. Ash can be remobilized by the wind and is very abrasive. It can disrupt air service for days or weeks, which would affect mine operations. Aniakchak Caldera (similar to a volcanic crater). Photo: M. Williams, National Park Service, 1977. Courtesy Volcano Hazards Team/USGS

Pebble Limited Partnership studies – Environmental Baseline Data



How Weather Affects Air Quality Wind temperature Higher temperatures can promote chemical reactions that add to increased particle pollution and creation of ozone. Relative humidity Low relative humidity reduces air movement, causing pollutants to build. High relative humidity causes particles to absorb moisture and swell, reducing visibility.

High Pressure High pressure affects other weather conditions that contribute to increases in pollutant concentrations. For example, temperatures and humidity increase on the tail end of high pressure systems. Wind speed As pressure builds over an area and winds decrease, particle pollution builds up, providing a more favorable environment for chemical reactions that create ozone and particle pollution. Wind direction Responsible for transport and travel of pollutants. Predominant wind direction can have a considerable effect on regional air quality, as follows: Upwind sources: Air quality can worsen in your community if the wind is blowing from a region with numerous sources of pollution. Winds from areas with little or no pollution can make your air quality better. Very light to no wind can be a problem for urban areas, because all the pollution that a city creates stays in one place. Recirculation: The clockwise rotation of winds in a high pressure system can create a phenomenon called recirculation, causing a dirty parcel of air in one location to circle back around to where it started after accumulating more pollution. Recirculation often plays a role in the worst air quality episodes. Adapted from EPA “Air Quality Awareness,” html (accessed Sept. 23, 2010).


In October 2010, Pebble Watch reviewed PLP’s “Report Series A: Meteorology,” which described the meteorological monitoring program maintained since 2005 by Pebble developers in anticipation of air quality permitting needs. According to the report, seven of nine stations collect permittingquality data. Six of these are near the Pebble deposit. The seventh is at a proposed port site on Cook Inlet. Two other stations near the mine area collect data for design purposes. Data collected includes wind speed and direction, temperature, solar radiation, precipitation, evaporation, relative humidity and barometric pressure. Collecting detailed and specific information about surrounding weather conditions is a required part of the permitting process, used by state and federal agencies to identify factors that could affect air quality during construction or mine operation. Measuring weather conditions, such as wind or solar radiation, is critical to air quality because these conditions help determine what regions and resources may be affected by a pollutant, how long they are exposed to a pollutant, and if conditions are likely to promote chemical interactions that might create more pollutants, such as ozone. Of course, meteorological information provides only part of this picture. After the type and quantity of potential emissions is known, other factors that are considered include comparison to national air quality standards and pre-existing (background) emissions in the region. Depending on the type of facility, quantity of expected emissions, and regional air quality concerns, a new potential “source” of emissions can be subject to stricter monitoring guidelines, specific controls, or additional permit submittals.

Permitting Requirements The Alaska Department of Environmental Conservation (ADEC) Division of Air Quality requires air quality permits for mine construction and mine operation. At the federal level, the Environmental Protection Agency (EPA) Air Quality Permit review can require a Prevention of Significant Deterioration (PSD) permit or a Minor New Source Review permit. Which permits are required depends upon the type of pollution source, its location and how its emissions are classified under existing National Ambient Air Quality Standards (NAAQS). The NAAQS establish permissible levels for six common air pollutants: Carbon monoxide, sulfur dioxide, nitrogen dioxide, ozone, lead, inhalable particulate matter (PM) containing particles smaller than 10 micrometers (PM10), and PM containing particles smaller than 2.5 micrometers (PM2.5). These are called “criteria pollutants” because they are regulated based on health and environmental sciencebased criteria. The Clean Air Act additionally provides guidelines for 189 “hazardous air pollutants.” The closest source of data on regional criteria pollutants near Pebble is a monitoring station at Tuxedni Wilderness near the northern coast of Lake Clark National Park and Preserve. The U.S. Fish and Wildlife Service (USFWS) is Federal Land Manager of the site and monitors air quality here because it is classified as a federal Class I air quality area under the Clean Air Act. The classification provides for additional protection from man-made air pollution by requiring consideration of air quality and air quality related values (AQRVs), including: vegetation, wildlife, soils, water quality, visibility, odor, and cultural and archaeological resources. The remainder of Lake Clark National Park and Preserve is a Class II air quality area.

Understanding the data As an example of how to read and use the information in the PLP report, Pebble Watch highlighted data from two meteorology stations located within five miles of the proposed mine area. A “wind rose” diagram that shows wind speed and direction collected over time provides a meaningful way to represent and understand the data collected continuously at each station. The wider part of each fan-blade shape in these roses indicates the direction from which the wind was blowing. The length indicates the percent of the time it blew from that direction. Pebble Station 1 is located at a proposed mill site, atop a knoll just west of the first discovered mine ore body, at about 1,550 feet elevation. The wind rose that combines wind direction information collected from 20052007 shows winds predominantly from the northwest and southeast. Pebble Station 4 is located at a proposed tailings site, on another knoll, five miles south of the mine ore body, at about 1,200 feet elevation. At this site, winds in 2007 were predominantly from the north, east and southeast.

Pebble Station 1 wind rose

Pebble Limited Partnership studies – Environmental Baseline Data

Pebble Station 4 wind rose

Wind data superimposed on a map of the study area suggests how winds follow topography.



Alaska is covered with wetlands—marshes, bogs, sloughs, river flood plains and shallow ponds. You may have appreciated wetlands for the vast amount of berries that grow in these environments, or the valuable hunting and fishing. Or, you may have been frustrated by how difficult it is to keep your socks dry when slogging through them. Either way, wetlands are an important landscape in Alaska—covering about 43 percent of the surface area in the state. In the Lower 48, by contrast, wetlands only occupy about 5.2 percent of the surface area. Wetlands are complex ecosystems that develop in areas mostly inundated by or saturated with water. Whether that ecosystem is a marsh, a swamp or another type of wetland is determined by three factors: the types of plants living there, the unique combination of soil properties, and the source and flow of water (also known as “hydrology”).

How wetlands relate to mine development With approximately 45 percent of the Pebble project area covered by wetlands, impacts are inevitable. The project would likely require the dredging of wetlands for a mine site, and filling of wetlands for roads and other infrastructure. Wetlands may be at the crux of the permitting process for the mine, because Section 404 of the Clean Water Act specifically regulates the dredging and filling of wetlands. A Section 404 permit from the U.S. Army Corps of Engineers would be required to build the mine and related infrastructure.

Questions to consider • What percentage of the wetlands will be altered? Is this percentage biologically significant with regard to fish and wildlife habitat? • How will the filling affect the wetlands’ ability to perform wetland ecosystem functions?

Wetlands “perform vital and valuable physical, chemical and biological functions. As a consequence of these functions, Alaska’s wetlands help to support the state’s fish and wildlife populations, water resource quantity and quality, diverse human communities, and economy.” – Wetland Functional Assessment Guidebook, Alaska Department of Environmental Conservation


• What is the impact threshold for wetlands in the project area? (How severe does the impact need to be before mitigation is required?)

Other regulations affecting wetlands Clean Water Act Section 301 – Prohibits the discharge of any pollutants into wetlands without a permit. Clean Water Act Section 402 – Requires the EPA to ensure that standards for water quality and effluent (wastewater) limitations are maintained. Alaska Fish Way Act – Requires permits from the Alaska Department of Natural Resources for activities that affect waters important for anadromous fish. National Environmental Policy Act – Requires extensive evaluation of impacts to the environment, including wetlands.

Assessing the importance of wetlands Wetlands are key habitat for many types of wildlife, and they also provide essential ecosystem functions, such as: water storage and flood control, water quality maintenance, groundwater recharge/discharge, erosion control, carbon storage, aquatic habitat, and recreation and aesthetics. Throughout the research and permitting phases of a project, developers and regulators take several steps to determine how important each wetland is to the ecosystem. Typical process


Status for Pebble project


2 3 4 5

For the purposes of protecting wetlands, the U.S. Army Corps of Engineers has developed an official wetland definition that includes specific factors related to the soil, plants, and water of the area.

In the Pebble Partnership’s Environmental Baseline Document, scientists identified wetlands (as defined by regulation) in the mine area (33 percent - 9,825 acres) and in the transportation corridor (12 percent - 2,425 acres).

Classification Classification provides essential information in evaluating which wetland ecosystem functions are present and how well they are performed. For example, a “slope wetland” is associated with the ecosystem function of groundwater discharge to a land surface.

Pebble scientists used two different systems to classify each wetland: • Enhanced National Wetlands Inventory system (ENWI), and • HGM, a hydrogeomorphic system. They found that “slope wetlands” dominate both study areas.

Function analysis The process for analyzing wetland functions is extremely complicated, and follows specific guidelines outlined by the U.S. Army Corps of Engineers.

Ranking Typically, the function analyses allow for wetlands to be ranked as high functioning, moderate functioning or low functioning. This ranking is used when determining how wetland loss will be compensated for during the permitting process.

Mitigation During mitigation, steps are taken first to avoid or minimize adverse impacts to wetlands. Unavoidable impacts require compensatory mitigation to make up for any loss.

Crowberry (Empetrum nigrum) is one of the dominant wetland shrubs found in the mapped Pebble deposit area. Like other wetland plants, it is adapted to growing in waterlogged soils with poor nutrient availability and little oxygen.

Additional resources Function analysis, ranking, and mitigation take place during the permitting process.

Pebble Partnership Environmental Baseline Document Chapters 14 and 39 on Wetlands

The wetlands function analysis has not yet been completed, and is not included in the Environmental Baseline Document. However, it will be critical for determining the relative importance of each wetland, and impacts that could result from altering the wetlands.

EPA Fact Sheets on Wetlands and Wetland Regulations outreach/facts_contents.cfm

Watch for function analysis and ranking during the Environmental Impact Statement phase of permitting. The Corps of Engineers will be responsible for determining the amount and type of compensatory mitigation required by the project. (Methods include restoration, establishment, enhancement and preservation of wetlands.)

Pebble Limited Partnership studies - Environmental Baseline Data

EPA Bristol Bay Watershed Assessment U.S. Army Corps of Engineers Regulatory Division Alaska Wetlands and Wildlife Vol. 5 of The Alaska Wildlife Curriculum Teacher’s Guide Alaska Department of Fish and Game, (907) 267-2216


Water quality Water quality data are important for water use, water discharge and wastewater disposal permits. In February 2011, Pebble Watch reported on PLP’s “Report Series F: Surface Water and Groundwater Quality,” which describes the water quality collection program developers conducted between 2004 and 2007. The report included results for surface water, seeps and groundwater collection near the deposit site, as well as for water quality analyses from sites in Iliamna Lake and the transportation corridor.

Surface water study Surface water was collected from 41 sites in locations on the North Fork Koktuli River, South Fork Koktuli River, Upper Talarik Creek, Kaskanak Creek, and their tributaries. Sites were selected based on their proximity to the mineral deposit, proposed tailings disposal area or other proposed mine facilities, and were located both upstream and downstream of the deposit. Surface water samples were also collected from pond and water body locations, springs or seeps near the deposit area, Iliamna Lake, and river-crossing sites along the proposed transportation corridor.

Groundwater study The groundwater quality study area includes locations surrounding the headwaters of the Koktuli River and Upper Talarik Creek. Thirty-seven dedicated sampling wells were installed and sampled between 2004 and 2007. Samples were collected 32

Collecting water quality samples in the transportation corridor area.

from these wells quarterly to document seasonal variations in the movement, distribution, and quality of water. Samples were also taken from drinking water wells in Iliamna, Newhalen, Nondalton, and Pedro Bay. Laboratory analyses included tests for 24 trace metals such as copper, aluminum, iron, silver and barium, as well as for other constituents such as cyanide, pesticides, petroleum hydrocarbons, nutrients, dissolved and suspended solids, and dissolved organic carbon. Acidity, alkalinity and hardness were also measured.

Use of data Collecting water quality data is useful for planning the construction of mine facilities and is required for the permitting process. Establishing baseline water quality data is essential in the Pebble deposit area to show what an undeveloped environment looks like. It also documents any seasonal or sitespecific conditions in the region, which includes habitat for salmon and other fish harvested for both personal and commercial use. Some mining activities and facilities

can affect water quality, so federal and state agencies often require monitoring programs to continue well beyond operations and closure as a condition of the permit. This ongoing water-quality analysis is essential to protecting waterways and fisheries by identifying changes that may occur. For example, monitoring could help identify when activities such as water use for mining may alter conditions in rivers and tributaries, which in turn could affect fish.

Looking at study results Surface water sampling provides data about the water chemistry of lakes, streams and other fresh water sources. Sampling of groundwater provides data on water found beneath the surface of the ground, such as in porous soil or in the fractures of bedrock. Both types of water quality can be important to human health, through the direct ingestion of water from drinking wells and springs, or by consumption of aquatic life, such as fish. The decision about what kinds of lab analyses are done to determine water quality is usually based on existing standards, or “criteria,” which

Understanding the data

Concentrations (Micrograms/Liter)

Mean copper concentrations by location This map shows water copper concentrations in micrograms per Liter (μg/L) and how they change in relation to proximity to the Pebble deposit. The South Fork Koktuli contains higher concentrations of copper as it drains from the deposit area. As water moves downstream, copper concentration becomes diluted by other water sources.

allow comparisons to be made for permitting and other purposes. These criteria establish standards, in fresh water or saltwater, for substances that may be toxic or otherwise harmful for aquaculture (fish farming or oyster farming), seafood processing, raw consumption, and the propagation of fish, shellfish and other aquatic life and wildlife. In general, measurements that do not meet water quality criteria may represent circumstances known to cause harm to aquatic or human life, or both.

one sample location on the South Fork Koktuli River and compared it to State of Alaska standards for drinking water and aquatic life protection.

Pebble Watch looked at several years of surface water data collected from

• During some low-flow periods, concentrations of aluminum,

Based on the data, the background water quality generally meets aquatic life protection criteria—the more stringent of the two—for almost all parameters. Exceptions were sitespecific and seasonal variations due to thaws (such as those occurring during spring breakup), precipitation and geology:

Pebble Limited Partnership studies – Environmental Baseline Data

manganese and iron did not meet either set of criteria at some sites. • During some periods of high water flow, levels of alkalinity, as well as concentrations of aluminum, copper, manganese, iron, lead and cyanide, did not meet chronic aquatic life protection criteria at some sites. Data results from the collection sites showed low levels of dissolved solids, low alkalinity and neutral pH in water. Dissolved oxygen concentrations were higher in winter. Copper and sulfate levels were high near (continued p. 35)



The Hydrologic Cycle Precipitation



Hydrology is the scientific study of water and its movement, especially in relation to land. Understanding how water moves through an area is important to predicting how that area may be affected by development. Water moves in a continuous cycle. It evaporates from the Earth’s surface or transpires from plants as water vapor—then it settles back as condensation and precipitation, such as dew or rain or snow. Surface water collects on the ground or in water bodies like streams, rivers or lakes. Water also collects and travels below the earth’s surface. 34

Surface Flow

Groundwater Flow

Though hidden, this groundwater is a critical part of the water cycle, as it is by far the largest source of available fresh water on earth. Groundwater does not move like a stream, but travels much more slowly, within gravel, sand and fractures in limestone or bedrock.

to feed springs, streams, or smaller pools of water, called seeps—at which point it is considered surface water.

Knowing how water moves both above and below ground helps to develop a picture of existing conditions and to forecast changes that may occur.

Groundwater discharged in one area can travel as surface water in some areas and then be recharged into the ground miles away from its starting point. The rate and amount of water flow from surface to underground and back again is influenced by many factors, including geology and seasonal changes in precipitation.

There is a give-and-take relationship between surface water and groundwater. Groundwater may be replenished (recharged) by rain, snow and other precipitation, or seepage from streams. In turn, groundwater may well up (discharge) to the surface

Because this interplay is so complex, and because groundwater is such an important resource, developers must have an in-depth understanding of regional hydrology to avoid groundwater depletion or contamination.

Groundwater studies Pebble project developers have funded extensive groundwater studies in the proposed mine area in order to minimize groundwater impact, include measures to mitigate residual effects, and identify optimal locations for mine facilities. During studies conducted from 2004 to 2007, monitoring wells were used to collect groundwater samples and monitor groundwater levels. Piezometers, which are similar to monitoring wells, were also installed to measure groundwater levels. Data was collected from 259 wells located at 196 sites throughout the watershed areas of Upper Talarik Creek and the north and south forks of the Koktuli River. Data was recorded as frequently as hourly in some wells. Developers have been studying, or “characterizing,” the surface and subsurface geology in the Pebble project area as well. They are measuring hydraulic conductivity (how fast water flows through soil and rock), as this is a major indicator of how closely How this data may be used groundwater and surface water are Pump test data helps connected. Hydraulic conductivity is determine how quickly determined by the permeability and groundwater recharges in porosity of a material. For example, an area after being pumped clays allow very little water transport, out. In addition, data from while coarse-grained material such as subsurface geologic tests gravel allows water to fill in between can help assess hydraulic the rocks and move through it faster. conductivity of different rock units, which impacts recharge Chapter 3 of Pebble’s EBD delves rates. Ultimately, this data is further into the surficial geology of the used in a groundwater model Pebble deposit area, noting that the to evaluate potential changes complex land formations were caused in local and regional water by four separate glacial episodes. tables, as well as groundwater These glaciers left behind sand, soil interaction with local streams, and rock in a number of moraines, wetlands and lakes. meltwater deposits and outwash aprons.

Pebble Limited Partnership studies – Environmental Baseline Data

(“Water quality” from p. 33)

mineralized areas, with the highest concentrations of copper occurring during high water flow conditions, such as during spring breakup and periods of rain. As monthly winter sampling continues, it will contribute further to understanding the role of groundwater during low-flow periods in winter, when lakes and streams are frozen. Data from the mine region also suggest the potential for interplay between surface water and groundwater—with both surface and groundwater sharing constituents through interbasin transfer, a naturally occurring transfer of water. (See “Water interactions,” p. 36.) Water quality samples taken from the same sites used for fish studies should further help relate water chemistry to data about local populations of fish and other aquatic life, as such data becomes available. In some cases, mining operators may use site-specific criteria to petition the state for a site-specific exception to state water quality standards. Under Alaska state law, exceptions can be granted if evidence shows species or habitat present are more or less sensitive to a constituent than indicated by existing criteria.


Water interactions

One Resource Historically, groundwater and surface water were evaluated as separate systems, but today they are considered one related resource. Alaska is one of the few western states that has adopted a conjunctive water rights management system, treating both groundwater and surface water the same from a regulatory standpoint. Since groundwater can’t be readily seen, there are significant challenges to understanding all the ways it interconnects with


surface water, especially since these interactions can take place in a widespread area. As one example, Pebble project developers noted in baseline studies that groundwater originating in the South Fork Koktuli River in the Nushagak watershed actually makes its way into Upper Talarik Creek, which is in the Kvichak watershed. In and around the Pebble deposit, there is evidence of significant interaction between groundwater and

surface water, including the presence of seeps (when groundwater comes up into streambeds and land surface area). Published data show more than 4,500 documented seeps in an area about 193 square miles in size. Cold groundwater coming up through clean gravel beds provides important spawning sites for Bristol Bay salmon, making it necessary to understand how changes to groundwater might affect water in those areas.

flow of groundwater into Water temperature – The temperature, which has a stream moderates stream populations. an impact on fish health and

Studying and predicting Understanding the complex movement and interaction of groundwater and surface water requires a variety of data. This can include the study of rock and soil to see how quickly water moves through it (hydraulic conductivity), and water monitoring to measure water level and how fast water is replenished. Visual observations and aerial photography are also sources of information (to inventory locations of seeps, for example). Data are used to chart typical conditions and seasonal changes, but it isn’t possible to measure everything. That’s why groundwater modeling is used to simulate how water moves in an existing system—and to predict changes that might occur if any known aspect of that system were to change. Modeling might be thought of as an equation where known information about an area is input—its geology, its surface water, groundwater and water flow—to understand what is not known. For example, such a model could be used to show how various locations for a mine tailings pond might affect ground and surface waters. Such models provide a numerical 3D overview of a water system. The type of program used and the data the model is built upon are critical for an accurate understanding of an area’s hydrologic conditions. Although a certain amount of sitespecific assumptions are made during modeling, regulatory agencies have accepted this method for predicting how activities such as mining can affect hydrology in a specific area. Models also must be standard enough that they can be subject to independent testing and review by regulators. In addition, current research highlights the need for models to take into account the uncertainty inherent in model predictions, and the impact of long-term climate changes on hydrology, instead of basing predictions on fixed parameters. During PLP’s October 2012 Keystone science panels on hydrology, panelists acknowledged the importance in getting groundwater model predictions right, documenting why certain calibrations are made, and considering alternative models, such as the Discrete Fracture Network (DFN), that simulates bedrock water flow to explicitly represent every single fracture or representative of that fracture.

h as dewatering impact Water flow – Mining activities suc potentially change the the existing hydrologic system and undwater upwelling location, quantity and timing of gro moves downward to and recharge (when surface water ing can reduce flow to replenish groundwater). Dewater er levels to a depth surface water and lower groundwat itat needs to survive. below what vegetation/wildlife hab

Pebble Limited Partnership studies – Environmental Baseline Data

Mining and water Water Quantity Too much groundwater can create unsafe conditions for mining, so engineers must create plans to “dewater” (remove water from) the work area. However, large quantities of water are also necessary for mining operations. For example, a July 2006 water rights permit indicated that estimated surface and groundwater usage in the proposed Pebble project area would equal more than 34 billion gallons a year. This would provide potable water for the camp and be used in activities such as processing ore, dust control and tailings storage.

Water Quality Sulfide mining carries an inherent risk of water contamination, since the waste it produces contains known toxins. Modern methods to minimize the risk of contamination include treatment and recycling of waste water when possible, and the containment of water used to stabilize tailings in a permanent tailings storage area. Knowledge of how water flows above and below ground can be used to understand where potential contamination might travel should it be released into ground or surface water, and to determine appropriate sites for tailings storage.

Water quality – Move ment of water between surface and ground water can also transport mine-re lated contaminants between the two, increa sing the likelihood of uncontroll ed releases.


Fish & aquatic invertebrates Bristol Bay is rich with fish of many varieties. It’s home to the largest sockeye salmon run in the world. The health of this fishery is at the crux of the Pebble mine debate. Many people believe development of the mine would destroy the Bristol Bay fishery, while others believe the mine could be built without harm to a fishing industry that generates approximately $360 million each year. Studying the current aquatic environment in the Pebble deposit area and transportation corridor helps scientists understand more about the environmental factors that contribute to such a successful fishery. That understanding will help predict what impact mining activities could have on fish and fish habitat.

PLP studies of fish in the Bristol Bay drainages Pebble Limited Partnership’s (PLP) Environmental Baseline Document includes a 6,500-page report on “Fish and Aquatic Invertebrates.” During a five-year study, PLP scientists mainly gathered data by snorkeling, supplemented by other techniques such as electrofishing, dipnetting and aerial helicopter surveys. The result is a complex accumulation of data collected along several miles of water. It includes number of fish, number of species, water flow, water temperature, riverbank vegetation, type of river habitat, and shape of stream or river. The information gathered was used to describe stream flow in various areas and predict how changes to that flow could affect fish habitat.

The nonprofit Keystone Center conducted a science panel in October 2012 on “Fisheries and Marine Ecosystems” that addressed fish data collected in the EBD. Independent scientists and members of the public asked questions and commented on the studies. One of the concerns brought up related to the comparisons of “mean index” fish counts to a total escapement estimate, with discussion centered on how well the fish populations are characterized in the area. Complete video of the panel is available online at www.keystone. org. A written report detailing panelist recommendations regarding fish counts and habitat study will be published in 2013.

U.S. Fish and Wildlife Service


Computer-aided analysis Scientists draw conclusions about fish habitat and population with the help of Physical Habitat Simulation (PHABSIM, pronounced peehab-sim), a computer model that simulates habitat based on known variables. It was developed by the U.S. Fish and Wildlife Service in the 1970s, and was chosen by PLP for use in analyzing habitat and flow data for its Environmental Baseline Document. PLP’s PHABSIM analysis includes spawning habitat, and juvenile- and adult-rearing habitats for various fish species in specific stream reaches in the Pebble deposit study area. PHABSIM simulates habitat based on the physical structure of a stream, its depth and velocity. It does not take into account water quality or temperature; those are analyzed separately.

Considering other models

PHABSIM is one tool for understanding stream flow and fish habitat, but many other approaches have been developed in recent decades. (More than 200 were in use worldwide in 2003.) Some take into account indigenous needs for key harvest species. Some focus on the importance of variability in sustaining river ecosystems. Some use multi-disciplinary “expert panels” to assess stream flow requirements. The Bristol Bay watershed system is complex, and so are factors that contribute to healthy fish habitat. Stakeholders require access to accurate information about the watershed, along with analysis that is easy to understand. PHABSIM has been an industry standard. Would a different model provide a better understanding of this watershed?

Aquatic invertebrates

— those little “bugs” without backbones — are crucial to healthy fish habitat. They serve as a main food source for fish and also help decompose materials in the water (including salmon carcasses), which is an important part of the nutrient cycle. Certain types of invertebrates are very sensitive to stressors like pollution and low oxygen levels. Scientists use the presence of these larvae as an indicator of water quality and stream health.

EPT Index The EPT index is a scientific measurement of the abundance of larvae that are sensitive to pollutants. A high EPT index generally indicates water with low pollution and low disturbance. The letters E, P and T represent the scientific grouping of each invertebrate: Mayfly (order Ephemeroptera) Stonefly (order Plecoptera) Caddisfly (order Trichoptera)

Grouping invertebrates Aquatic invertebrates are commonly grouped and described according to their style of feeding: Shredders break down leaves and other particulates into smaller pieces. Collectors break down very small pieces of organic matter. Grazers and scrapers consume thin layers of algae or microbes attached to rocks and leaves. Predators consume other aquatic invertebrates, as well as tiny fish and tadpoles.

Pebble Limited Partnership studies – Environmental Baseline Data

Mayfly larva Photo: New South Wales Government

Studies of invertebrates in the Bristol Bay drainages PLP studies

Scientists collected invertebrate samples from a range of stream sizes and habitats between 2004 and 2007. They used several standard techniques, including drift net, Surber sampling and kick net. Sampling occurred for two weeks during the first year, and three to four days during each of the next two years. Scientists identified 235 types of macroinvertebrates within both the mine and transportation corridor areas (variations in results over the course of study were possibly the result of using different monitoring methods among some years). There was a low percentage found of those invertebrates that are sensitive to pollution (EPT invertebrates), even though their preferred habitat ­— riffle/ cobble — ­ is the dominant habitat type.

University of Alaska studies

Scientists in the University of Alaska Anchorage Aquatic Ecology program collected data between 2008 and 2010 from 78 wadeable streams in the mine claim areas of the Nushagak and Kvichak watersheds. Five of these streams were sampled repeatedly. A total of 137 types of macroinvertebrates was identified across all of the sites. The presence of four EPT organisms indicates pristine conditions in more than 50 percent of the sites studied. Further analysis will determine how much invertebrate population change is due to natural variation, including the effect of riverbank vegetation and in-stream cover. 39

Fish habitat

U.S. Fish and Wildlife Service

Factors that influence fish abundance Gravel/sedimentation Salmon lay their eggs in a pit and then bury them in gravel. Space needs to be maintained in between the gravel pieces so that the eggs can get oxygen and so the fry can emerge through the bed surface after incubation. If fine sediments infiltrate the gravel bed, they can cut off the oxygen, trap the eggs or wash them away. Scour is another factor impacting the makeup of the streambed; as water flows, material is removed, or “scoured,” from the bed and banks of the river.

Water temperature

Fish require water temperatures that are not too cold or warm. Temperature affects fish at every stage, from spawning and egg incubation to smolting and migration. Water temperature is considered as a factor of water quality by the state of Alaska. The Alaska Department of Environmental Conservation Water Quality Standards lists maximum temperatures for migration (59°F), spawning (55.4°F), rearing (59°C) and egg and fry incubation (55.4°F).

Groundwater influence

Upwelling of groundwater helps regulate stream temperature both in summer and winter months, and it helps maintain stream flow so that water bodies do not dry up and strand fish. Groundwater plays an important role in Bristol Bay waters; we know this in part based on the thousands of “seeps”—areas where groundwater pushes up and forms pools­—in the area. 40

Dissolved oxygen

Salmon need dissolved oxygen at all stages of life. Insufficient oxygen levels can reduce swimming ability, disrupt growth and food conversion efficiency, and impact food sources. Much of the dissolved oxygen in a water body comes from photosynthesis of aquatic plants and diffusion of oxygen from the air near the surface of the water. This is one reason why turbulent, shallow riffles provide good salmon habitat, because the atmospheric oxygen near the surface is more easily mixed into fast-moving water. Several factors can reduce the amount of oxygen available to fish, including high water temperature and high salinity. In spawning areas, oxygen availability also depends on factors like water velocity and the permeability of gravel.


Plants growing along river banks, also called “riparian vegetation,” provide excellent salmon habitat. Vegetation provides shade, keeping water cool. Plant material serves as food sources for invertebrates, which fish feed on as well. Root systems help filter and slow sediments, and also prevent riverbank erosion.

Beaver ponds

Beaver dams trap sediment, keeping it from entering spawning sites downstream. Ponds formed as a result of damming offer important rearing grounds for juvenile fish, partly because they typically host larger quantities of invertebrates—a basic food source for fish. Beaver ponds tend to be warmer than other habitat, and provide ice-free winter refuge.

Food sources

Young salmon fry rely on aquatic insects and their larvae, as well as insects from nearby vegetation that fall into the water. Yearlings add younger fry to their dining options. Once in the ocean, growing salmon find larger prey such as shrimp and smelt. Salmon coming back to lay eggs typically do not eat, so food is not an issue at this stage.


Copper occurs naturally in the environment and is essential to the growth and metabolism of fish, but it can also cause harm at levels only slightly above those required for growth and reproduction. Dissolved copper is a potent neurotoxin that directly damages the sensory capabilities of salmonids at low

concentrations. It can impact enzyme activity, blood chemistry, metabolism, sense of smell, and ability to fight disease or sense the vibrations of predators in salmon.

Stream flow

Fast-moving streams churn up more oxygen into the water, and carry away sediment and debris before it can settle into salmon-spawning beds. Low stream flow can increase water temperature and decrease oxygen. Seasonal changes and precipitation can affect stream flow, as can diversion or withdrawal of water from a water body. Its velocity, or how fast it moves, is determined by the gradient (steepness) of the stream bed and the resistance of materials in the stream bed (roots, logs and rocks/gravels). Stream flow and water chemistry also have a relationship, as indicated in the example to the right.

Water hardness

Whether water is “soft” or “hard” depends on the amount of minerals found in it. Calcium and magnesium are the most common sources of water hardness, and they are essential to the biological processes of aquatic creatures. Not having enough of these types of minerals creates “soft” water. Studies indicate that soft water can increase the toxicity of naturallyoccuring metals such as aluminum, cadmium, copper, iron, lead and zinc.

Water chemistry and stream flow This hydrograph—a graph showing changes in stream-flow level, or discharge, over time—shows 2006 aluminum and water discharge data from a stream gauge located on South Fork Koktuli River, near the Pebble deposit. This graph demonstrates how stream water chemistry fluctuates with changes in stream levels. Here, aluminum concentration rises with higher stream flows and is reduced with lower flows. The largest peaks represent high discharge events associated with spring breakup. Peaks from August to November represent precipitation. Zero flow represents water freezing or disruption of the gauge by ice. Stream in the transportation corridor area

Water alkalinity

Alkalinity can also affect the toxicity of other constituents. Water with higher alkalinity (or ability to neutralize acid) has a greater capability to resist changes in pH. Scientists refer to this capability as buffering capacity. A lower buffering capacity can increase the toxicity of copper, aluminum and other trace minerals in water. According to the state of Alaska’s chronic aquatic life criteria, water should contain at least 20 parts per million (ppm) alkalinity.

Pebble Limited Partnership studies – Environmental Baseline Data


Visual resources & recreation In February 2012, Pebble Watch reviewed the Visual Resources and Recreation chapters included in the Pebble Limited Partnership’s (PLP) Environmental Baseline Document (EBD).

Visual resources The Bristol Bay report on visual resources focused on areas in the vicinity of the Pebble deposit. Researchers took aerial photographs and interviewed interested parties, completing the bulk of their work in 2004. Five areas, or landscape analysis units, were identified for the study: Talarik creeks, Groundhog and Sharp mountains, Iliamna, Pedro Bay, and Chigmit mountains. Report authors used the U.S. Forest Service “Landscape Aesthetics” handbook to analyze the landscape, scenic attractiveness, integrity and scenic “class” of each unit. The official findings won’t surprise anyone who has lived in or visited Bristol Bay: the landscape is a varied and basically untouched wilderness with a high

value for scenic beauty. Researchers also identified four main groups of people who view these landscapes: residents, tourists and recreationists, subsistence users, and aircraft passengers. Although there are some differences in how individuals feel about the landscapes around them, the report indicates that generally all groups share a high appreciation for visual quality. Each group is likely to have a different concern regarding visual resources. For example, tourists might be more concerned with aesthetics, while subsistence users might be concerned with intrusions into the natural landscape. The Environmental Impact Statement (EIS) for the Pebble project will likely contain this type of information on visual resources, as well as a section on how the project would impact those resources. The EIS will take into account any local, state or federal policies on visual resources and aesthetics as they are presented in

Anticipating changes in visual resources These photos from the final EIS for the Port McKenzie Rail Extension (March 2011) use existing (top) and simulated views (bottom) to represent differences in a visual resource once a project is complete. A “before and after” is not included in the Pebble project’s EBD, though such simulations could be included in an EIS. Photos: Courtesy U.S. Surface Transportation Board.


management and comprehensive plans for the area.

Recreation The recreational study “inventories, describes, quantifies and maps the outdoor recreational resources and activities in the Bristol Bay drainages study area.” It uses several published sources, including state and federal reports and management plans. The study provides a detailed overview of sport fishing and hunting, as well as visitor resources such as national parks and lodges. One of the stated study objectives is to “estimate the economic contribution of recreation to the study-area economy.” However, in this area, the report does not provide much detail beyond the conclusion that “lodges’ contribution to resident earnings and local economies is limited.” State and national parks draw thousands of visitors a year, although those numbers are harder to track (as compared to fishing or hunting, which require formal permits). Bottom line? The Bristol Bay area is extremely attractive to tourists, who pay extra to travel here. Multiple agencies provide strategic plans for land use to manage these activities. Local economic contribution is low for sport fishing and hunting, and reports vary on the impact of visits to parks and refuges. Dollar results vary based on the model used to estimate the economic contribution of park visitors. However, a 2010 report on Katmai National Park that was not included in the EBD puts the economic value of park visitors at more than three times previous estimates (for details on this report, see page 10.)

Importance of landscape Landscapes define whole cultures. A simple difference in geography can affect what foods people eat, the clothes they wear, and their modes of transportation. Landscapes affect individuals, too. What they see around them every day helps shape a selfidentity. “I’m an East Coaster,” “I’m a country girl,” and “I’m an Alaskan” all bring to mind images related to a specific landscape.

Landscape shapes culture Traditional aspects of Bristol Bay culture can be linked back to the geography of where each Native group lived. Rugged mountains kept the Aleut/Alutiiq peoples restricted to the coast, so they became boatmakers and sailors, living off fish and sea mammals. Yup’iks on the Bristol Bay side of the Alaska Peninsula were hunters and fishermen who used gill nets, fish nets, harpoons, spears and weirs to survive. The Dena’ina/ Athabascans lived in lake country and enjoyed an abundant diet of salmon, moose and caribou. They were also canoe builders, which was essential for travel. Through these subsistence activities, the people built a deep connection with the land and waters of Bristol Bay.

Landscape inspires Land formations have inspired artists, poets, and musicians. One of Alaska’s most celebrated painters, Sydney Laurence, captured a wide range of landscapes on canvas, but was best known for his depictions of Denali. Lyrics to Alaska’s Flag, by Marie Drake, describe the natural world in relation to the Alaska state flag designed by Benny Benson. The song references the blue of the sea, evening sky and mountain lakes, along with the “gold of the hills and streams.” Landscape inspires other professions as well. The varied geography of Bristol Bay has captured the attention of scientists, naturalists, conservationists and archaeologists. The desire to preserve a landscape for future generations inspired the formation of parks and refuges.

A changing landscape Preserving a landscape is a difficult task, though, because people affect their surroundings just as their surroundings affect them. This interaction is the basis of a science

Pebble Limited Partnership studies – Environmental Baseline Data

called cultural geography. Whether change comes about by direct development of a resource (like the proposed Pebble mine) or as the result of many factors (as with climate change), populations may be forced to adapt. A changing landscape can take an emotional, environmental and economic toll. That’s why Visual Resources are included in environmental studies for development projects. Sudden unexpected changes, such as Alaska’s 1964 earthquake, understandably can cause trauma with lasting impact. But change over time can also affect people. Something about landscape symbolizes who we are, as individuals and as communities. As Petla Noden sang in the documentary Day in Our Bay: Voices and Views from Bristol Bay: “I am created from my land. I am created from my river.” How might changes to those lands and rivers affect the people of Bristol Bay?


Adding your voice

Whether you are submitting comments to local agencies or in response to a call for input in the Federal Register, use these tips to make the most of your letter.

Prepare • Start early. Read the proposed rule or document carefully, underlining points you would like to address. • Contact agency experts if you need additional information.

Residents of New Stuyahok speak to visitors from the U.S. Environmental Protection Agency, June 2011.

Local, state and national decision making can be influenced by everyday citizens. When you have an opinion or concern about a topic that may affect you or your community, there are ways to make your voice heard. Research your topic. Being knowledgeable about your topic is essential when you want to voice your opinion. Researching both sides of a controversial issue like the Pebble prospect gives you a better understanding, and shows that you are well-informed. Finding information: Library resources – A school or community library may have what you need, or the librarian may point you in the right direction. Or search the statewide library at Internet resources – Use the Internet to research topics important to you. Be aware that many sites are biased one way or another, especially about controversial topics. Always try to find a “primary” resource, where a fact was first documented. Interviews – Talk with or email people who are conducting their own research, or who work for or serve on a board of directors. Interview Elders for their Traditional Ecological Knowledge. Partner with others. Join or create an organization to move your ideas forward. Partner with schools, businesses or other organizations that have similar goals. You could also start a petition for change, either gathering support personally or online through sites such as Get funded. If you have a specific project that could help add to the discussion, search for organizations, corporations or agencies that might be able to provide funding. Use different ways to spread the word. Use email, phone, social media and letters to the editor to express your opinion. Make sure your points are clear and well-written. Don’t forget your legislators. Contact local, state and national lawmakers. It’s an important way to let legislators know what their constituents think. 44

Write • Outline your comments, making sure they are directly relevant to the issue. • Be clear about whether you are for or against the stated issue. • Include your own personal experience to individualize your comments. • If you’ve used articles or other documents for reference, provide copies or information about where to find them. • Avoid overly emotional language. • Type or print your comments legibly.

review • Review your comments for accuracy. • Ask a friend or two to review and provide feedback.

Submit • Submit comments by the stated deadline. • Sign your name and give contact information. Anonymous submissions may be discounted.

Tips for preparing written comments

Providing public comment on an issue that affects your home, land and culture is vital to making your voice heard. Here are some ways to make that happen: • This site is the place to go for all information about public input into proposed government rules and regulations. It helps you post written comments, tells you when the comment period is available, and answers questions about what happens to your comments after you’ve posted them. Pebble Watch • The Pebble Watch newsletter, website and Facebook page will keep you up to date on public comment periods for issues of importance to the Bristol Bay region, so keep reading. Public notices • Whenever a comment period is opening up, the government is required to post a public notice about it. These notices are most commonly found in your local newspaper. If you don’t have access to a hard copy of the newspaper that covers your area, go to the online edition and look under “Public Notices.” Look at for notices too. Your comments translated • If you are giving public comment orally and English is your second language, you may have an interpreter to assist you with your testimony. Put it in writing • If public speaking bothers you, submit written testimony instead. See tips at left.

Learn more

More Resources Find lesson plans, including “Project Soapbox,” which teaches you qualities of a good speech and how to structure a speech effectively. Stories about young people who have made a better future for their communities. From recycling soap to running an emergency food assistance program. Visit and search “For the Win.” Interactive games teach about civics—from the local level up to the Presidency. Cooperative Extension resource explains the National Environmental Policy Act (NEPA) and opportunities for public input. 45

Pebble mine debate A basic primer What is the Pebble deposit?

Pebble is a large mineral deposit located in the Bristol Bay region of Southwest Alaska. It is in the advanced exploration stage, with developers currently working on a mine plan that will lead to the permitting process.

What would be mined, and how much has been identified?

Test samples from the Pebble deposit have shown copper, molybdenum and gold. Pebble officials have said that at least three deposits have been found, and have good estimates on two of them. Pebble West has 569 million tons of ore identified in the “measured and indicated” category, and another 143 million tons in the “inferred” (or estimated) category. Pebble East has about 1.52 million tons of ore identified as “inferred.” Mine officials have said the minerals are worth an estimated $400 billion.

Who is trying to develop Pebble?

London-based Anglo American and Vancouver, B.C.-based Northern Dynasty Minerals each have a 50 percent stake in the deposit. They created another company, Pebble Limited Partnership (PLP), in 2007, to design and permit a mine at Pebble.

Why are some groups in favor of developing the Pebble mine?

Aside from the billions of dollars worth of mineral to be mined, proponents of the project generally highlight the benefit to the local, state and national economy. They also note high global demand for copper, as well as its importance in green technologies like wind turbines and electric cars.


Visiting the Pebble deposit area.

How many jobs will the Pebble development create, and will they go to local residents?

PLP estimates that the project will need about 1,000 full-time employees for the first 20 to 25 years of mine operation. They are creating a workforce development plan to meet their goal of filling positions from within the region.

Why are some groups opposed to Pebble mine?

Many groups and individuals believe that development of a large-scale mine in the Bristol Bay watershed will cause damage to the environment and imperil the fishery. Negative impacts to wildlife and native culture have also been raised as a concern.

Are the people living in Bristol Bay opposed to the mine?

A 2011 survey of Bristol Bay Native Corporation shareholders found that 81 percent are opposed to the mine. In a separate poll of Alaskan voters, also conducted in 2011, 54 percent of respondents had unfavorable views of the project.

When will a mine plan be published?

PLP has said it is working on a mine plan and intends to move to the permitting phase of its project by the end of 2013. PLP will likely release the mine plan shortly before or concurrently with permitting.

How does the permitting process work? There are dozens of separate permits (local, state and federal) that developers will need in order to begin construction and operation of a largescale mine in Bristol Bay. The state of Alaska Large Mine Permitting Team will coordinate state permits. The U.S. Army Corps of Engineers will be the lead agency to write an Environmental Impact Statement (EIS) to assess risk of the development.

What is the 404 permit?

The Clean Water Act (CWA) is federal legislation that helps protect U.S. waters. Under the CWA, a Section 404 permit is required when a developer plans to discharge dredged or fill material into the waters of the United States, including special aquatic sites such as wetlands. The U.S. Army Corps of Engineers issues these permits. However, the U.S. Environmental Protection Agency (EPA) also has authority under the CWA to “veto” such a permit (see sidebar).

What is an Environmental Impact Statement?

An EIS is required under the National Environmental Policy Act (NEPA) for any project that might significantly affect the environment. An EIS is a

Learn more

decision-making tool. It lays out both positive and negative environmental effects of a proposed action. Every EIS includes alternative actions, including the impact of a “no action alternative.”

How long does permitting take?

It is expected that the permitting process will take about three years.

How can I keep current on the status of the permitting process for the Pebble Mine project? will post this information as it becomes available. Current resources include our permitting timeline graphic, and a permitting matrix. Our Resources page also includes links to state, federal and project websites.

Why is the EPA conducting a watershed assessment?

In 2010, several tribes and organizations asked the EPA to step in and use its authority under the CWA to invoke 404(c) to limit development in Bristol Bay. Before acting on such a request, the EPA chose to conduct the watershed assessment. Public support for the assessment is high; the majority of more than 230,000 comments submitted during the first public comment period were favorable.

Why are some groups opposed to the EPA’s watershed assessment?

Many groups say that the Pebble project should be allowed to go through the normal permitting process. Critics of the EPA watershed assessment point to its use of a hypothetical mine scenario as a basic flaw. EPA says the scenario is based largely on a plan published by one of the mine developers, Northern Dynasty Minerals.

About Section 404(c) Section 404(c) of the CWA gives the EPA authority to limit or prohibit disposal sites for dredged or fill material­­“if the discharge will have unacceptable adverse effects on municipal water supplies, shellfish beds and fishery areas, wildlife or recreational areas.” The EPA’s Bristol Bay Watershed Assessment is not officially part of the 404(c) process. However, its purpose is to gather information to help the agency decide whether a 404(c) action is warranted. If available science suggests unique factors of Bristol Bay’s watersheds are vital to supporting the region’s one-of-a-kind fisheries and wildlife, EPA may initiate a 404(c) action. If this should happen, the decision would include additional opportunities for public comment. Facts about 404(c)

• EPA’s 404(c) authority has been enacted 13 times since 1980, which represents a fraction of the permit actions it considers annually (around 60,000). • There has never been a 404(c) action in EPA Region 10 (Alaska, Idaho, Oregon, Washington, and 271 Native Tribes). • Whenever EPA invokes 404(c), it must go through an official process that includes a public input period. • 404(c) authority can be invoked at any time, including before permits are applied for or granted. More about 404(c) can be found at


New Stuyahok. Photo: Carl Battreall

How do we know that the science is adequate to create a mine plan? The question of sound science is at the forefront of the Pebble debate, as environmental impacts can only be understood by accurately assessing current conditions and predicting how those conditions might change due to development. The main scientific documents associated with the Pebble project are PLP’s Environmental Baseline Document (EBD) and EPA’s Bristol Bay watershed assessment. Both have been criticized on some level for not being scientifically accurate. The EBD is actually a collection of several scientific studies conducted by 40 different companies and research firms. The goal of the EBD was to describe current environmental conditions. Portions of the document have been read by independent scientists through 48

the Keystone Center’s dialogue process, and many reviewers had specific recommendations for further study. PLP has stated that it will take into account some of these recommendations while still working toward permitting. Understanding current conditions is important for developers as they work on designing an economically feasible mine that mitigates risks to the environment. PLP has stated that mine technology is advanced enough to allow for mining and a healthy fishery in Bristol Bay. Scientists with various agencies will be considering all of these factors when reviewing PLP’s permit applications. The EPA watershed assessment went beyond characterization of the environment to include discussion of the potential risks of large-scale mining. A 12-member review panel provided specific recommendations to

the agency, which prepared a second draft to be studied by the same peer review team and the general public. Clearly scientists are not always in agreement when it comes to the proposed Pebble mine. Sifting through data, reports and peer review recommendations requires a basic knowledge of scientific terms and concepts that many readers do not have. Through publications, posts and educational materials, Pebble Watch seeks to provide summaries and overviews of these materials, so that readers can get the basics, know where to search for additional resources, and begin to formulate their own questions for study authors. In this way, they can join the scientific conversation that will ultimately affect the future of large-scale mining in Bristol Bay.

I have a strong opinion on the mine’s development or would like to share my concern/support. How do I make my voice heard? Permitting Dozens of permits are necessary for development of the proposed Pebble mine, some of which include public comment periods. This offers an opportunity to express your opinions to state and federal agencies involved in the permitting process. Pebble Watch posts information on public comment periods as they are scheduled. Visit to view our Permitting Guide. EPA Watershed Assessment The EPA published a draft of its watershed assessment in May 2012 and held several community meetings to solicit input. A second draft became available for public comment in spring 2013. Visit for more information. You may also email the EPA at: Developers To express concern or support to Pebble Limited Partnership, visit or call (907) 339-2600. Various resources at this site can help answer your questions, including a permitting timeline and guide with links to various state and federal agencies. You may also send your specific questions to the Pebble Watch team: BBNC Call the BBNC Land Department at (800) 426-3602.

Learn more

Fused glass mosaic by Patricia Walsh, Dillingham.

How might the proposed Pebble mine affect salmon runs and habitat? Just what effects a large mine project such as Pebble would have on Bristol Bay salmon fisheries has been the subject of considerable debate. Concerns have been raised over possible impacts from such changes as new road construction crossing salmon streams, or mine operations activities that may change the chemical composition of the water, such as use of local water and tailings disposal. EPA has conducted an assessment of the Nushagak and Kvichak watersheds of Bristol Bay, with a focus on how large-scale mine development such as Pebble could affect the waters (and ultimately the fish) in the area. The draft assessment, based on a hypothetical mine scenario, predicted loss of streams and fish habitat even under normal mine operations. A panel of 12 scientists conducted a peer review of the first draft in 2012. The EPA incorporated suggestions from that peer review team and the public, publishing a second draft in 2013. The final assessment is expected to be complete in late 2013. PLP has said the existing permitting process—informed by data from its Environmental Baseline Document (EBD)—would adequately predict potential impacts and protect salmon and habitat. Chapter 15 of the EBD does provide a description of fish and habitat in the North Fork Koktuli River, South Fork Koktuli River and Upper Talarik Creek watersheds. However, this document merely provides baseline data about the area; it does not predict potential impacts. Permits related to protecting salmon include the Fish Habitat Permit and Fish Passage Permit, although neither allow for public comment, so it is unclear when the public might preview and respond to potential impacts on salmon runs and habitat. Special protections for fish: The Alaska Department of Fish and Game (ADFG) maintains a Fish Distribution Database of streams, rivers and lakes that are important for spawning, rearing or migration of anadromous fish. ADFG has developed an Anadromous Waters Catalog and an Atlas based on this database. The catalog currently lists more than 17,000 water bodies that are afforded special protections by state law. Qualified individuals can nominate new waters to the catalog. As a result of studies conducted for environmental baseline research, Pebble Limited Partnership scientists nominated 23.1 miles of stream to the catalog. Independent scientists who have conducted research in the same area have also nominated 28 miles of salmon-producing stream to the catalog. ADFG estimates that 20,000 or more water bodies used by anadromous species have yet to be identified. 49

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Special issue: A compilation of our most relevant articles from the past two years, featuring: Salmon-based cultures of Bristol Bay, science topics from meteorology to aquatic invertebrates, basics of permitting, EPA watershed assessment, public input, and more. Plus! A Pebble mine primer: your questions answered.

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Port Heiden, Alaska.

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